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4. Review of environmental impact reports
A detailed description of procedures for reviewing EIRs is beyond the scope of the present Guidelines, which are primarily designed to assists with the preparation of these documents. In addition, more than in the case of assessment, the review and disposition of EIRs constitute administrative, often political, actions that must be left to individual jurisdictions. However, a number of trends and principles that have emerged in countries that have used EIA are summarized below because review procedures influence, to some extent,, the contents of EIRs.
(1) Reviewers are usually boards, panels or commissions that reflect several interests (conservation, development, the public at large, scientific community) rather than individuals; hence the need to use clear, standard language in EIRs.
(2) Reviewers can summon independent witnesses or solicit independent scientific or other opinions.
(3) Review procedures must follow orderly and well-advertised steps, and the decisions of review bodies must be argued or justified so as to avoid the arbitrariness and inconsistency that could undermine the credibility of EIA.
(4) Reviewers should issue guidelines concerning the format and contents of EIRs required in a particular jurisdiction, and should be empowered to reject EIRs on grounds of inadequacy; consistent standards are in the interests of assessors and proponents.
(5) Reviewers usually have the power to call for hearings and to solicit comments and criticisms; there are usually set procedures for incorporating these comments or criticisms into the final EIR used for project approval; comments generated during the review should be added by means of appendixes rather than through a rewriting of the EIR.
(6) Reviewers usually have the authority to request additional study and, hence, to delay the approval of projects.
(7) Reviewers are usually authorized to issue binding prescriptions concerning mitigation, phased analyses, poet-development audits or monitoring, reviewers are thus authorized to issue conditional approvals.
(8) Reviewers may request subsequent filings of documents to ensure compliance with the environmental conditions attached to project approvals.
(9) Reviewers may require proponents to file operational (ie., actually used by field personnel) handbooks concerning routine methods of logging, log skidding, forest-road construction, sediment control, stream protection and other activities. The procedures described in these handbooks may be declared binding.
(10) Reviewers usually have the authority to reject a project on environmental grounds, but this decision is in moat cases subject automatically to review by the Minister responsible.
Review procedures commonly include requests for information that should be borne in mind when preparing EIRs. Information that is often omitted from EIRs and, hence, requested by reviewers includes:
(1) Authors of EIRs and their experience and qualifications;
(2) Time it took to prepare the EIR, including field data collection;
(3) At what point in the overall planning of the forestry project ware environmental factors taken into account;
(4) Who bore the principal responsibility for selecting the alternatives and for designating the preferred d alternative;
(5) The extent to which the opinions of conservation and/or regulatory agencies were taken into account in the selection of alternatives, in judging the adequacy of the baseline data and of the prediction methods, and in the recommendation of remedial measures;
(6) Whether the impacts of the developmental and operational phases of a project have been considered separately insofar as these impacts may be different;
(7) Exactly who will bear the responsibility for applying and supervising mitigative measures in the field during actual development;
(8) Availability of operational handbooks for the various aspects of environmental protection (unless those handbooks are automatically filed with the EIR).
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