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3.3.5 Relevant legislation, regulations and licensing

As a minimum, EIA should ensure that the planning of a forestry project has occurred within existing statutory or regulatory limits and that the mitigative measures recommended comply with existing standards. Thus, a separate section of the EIR should indicate the existing legislation (including bills, or pending legislation) and regulations that effect the project. The EIR should also summarize the entire licensing procedure required to obtain clearance for the forestry project. The reviewer may need this information in case he decides to grant conditional environmental approval of the project and to the certain phased environmental analyses (or compliance with them) to specific steps in the overall licensing procedure.

3.3.6 General editorial requirements

In general, EIRs should comply with the following editorial standards:

(1) EIRs must be so structured and written that they facilitate the ask task of the reviewer(s) and other decision makers; hence, they must be as brief as possible without loss of critical detail and must focus on significant issues of impact and alternative development; accordingly, EIRs must give differential emphasis to data and interpretation in relation to the importance (to society) of the topics being discussed; lengthy but unavoidable descriptive materials, both narrative and data, should be included in appendixes.

(2) EIRs must be so written that the "intelligent layman" can understand them; discussions of complex scientific or technical matters that concern the reliability of impact predictions must, however, be included appendixes for the benefit of specialists in regulatory agencies or elsewhere.

(3) The EIR should distinguish clearly between adverse and beneficial, and between short- and long-term impacts; it should also state unequivocally what the irretrievable environmental losses are.

(4) Whenever the EIR identifies a deficiency in the data coverage in the predictive techniques? or in the remedial measures, it should recommend an administrative response to this deficiency (whether the deficiency can be ignored for the particular project, whether original field data are needed for a supplementary EIR, whether there should be a delay in the licensing procedure, whether some field experiments should be carried out to clarify the issue and when or whatever).

(5) If the public is consulted during EIA (consultations of local residents are strongly recommended), the EIR should include a summary of the opinions expressed, including opinions that the assessor may consider as having no scientific merit (but which may provide insights into local value systems).

(6) The EIR should have a concise summary that identifies the alternative of least environmental impact, whether this alternative differs from the preferred one (if pertinent), the main short-term and permanent impacts predicted and the principal unresolved issues of impact prediction and mitigation. The summary should include the recommendations regarding further regulatory action, if any.

3.4 Timing of detailed assessment

The preparation of EIRs (and their review; cf. Section 4) should take place while the project can still be modified as to design, location, methods and scheduling of operations. EIA loses much of its usefulness and credibility if a project proceeds before various environmental options have been examined and, if necessary, acted upon. If EIRs are not used effectively as tools for improving the quality of decisions taken in resource management, EIA becomes an expensive administrative exercise. It is in the proponent's (and society's) interest that the cost of EIA be partially or fully recovered by using EIRs to achieve better design and execution of development projects. In the case of forestry, EIRs should load to better forest management,? particularly if due emphasis is given to forest regeneration and to the control of activities (such as excessive shifting cultivation or illegal felling) that are inimical to forestry interests.

EIA also loses much of its usefulness and credibility if proponents are allowed to make premature and irretrievable comments of financial or other resources as a pressure tactic to obtain approval of the project before full and formal review of the impact report.

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