Benefits & Substance of Environmental Assessment

John Laforet wrote a great article about the proposed Scarborough Bluffs wind turbine facility, which would be the first ever wind turbine facility in an urban location in the world. If it passes, will probably go through without an environmental assessment; because with a review, it would never pass.

Environmental assessments can be tedious and take years to complete (depending on the baseline data collected), but on the other hand it can take decades to remedy unexpected damages to the environment, not to mention costing millions more in the budget.  An environmental impact assessment can even bring about more than just direct positive benefits to a project.  The example below outlines a hypothetical wind turbine facility construction project (in a rural location), to give a sense of the scope of environmental assessments, and as well as the numerous indirect benefits that can be achieved.

Case Identification & Valued Ecosystem Components
A private company’s proposal for the construction of a large-scale wind turbine generating station in a rural area is considered.  The facility will be located in rural Saskatchewan, and the land will be leased from pre-existing farm owners.  The facility will eliminate the usability of some farms, and will be built in a wind corridor for migrating birds.  The surrounding areas are experiencing a poor economy, and in general economic expansion is constricted by lack of sufficient energy resources.  A preferred tendency towards renewable energy resources exists in the region. The significant VECs (Valued Ecosystem Components) in this scenario are:

I.    Farmland
The existing farmland is important to farmers, who grow crops on the land to sustain themselves and their community.  Loss of farmland will also affect suppliers and consumers of the farms.

II.    Quality of Life
The surrounding residential settlements wish to maintain high standards of living, which could be disturbed by the noise and vibration caused from a wind farm.  The transmission lines necessary to connect the wind farm to a power grid may also affect the safety and property value of local homes.  The visual aesthetic of the area may be decreased by the addition of a wind turbine facility.

III.    Preservation of Ecological Habitats & Wildlife
The construction process will displace soil and organisms that may be critical to ecosystem health. Thousands of species may have to be moved or accommodated before the project can begin.  Furthermore, the wind farm could potentially affect the mortality rate of birds and bats (Orion 2006).

IV.    Economy
The construction of a wind farm could provide local communities with an economic boost through the generation of employment from the construction and maintenance of a new wind turbine facility.  The farmers renting their land to the generation facilities will also make a profit off of the generated electricity.

V.    Wind Energy Utilization
The wind energy available in the rural region is desirable to the proponent, who wishes to use the renewable energy source to power the local electrical grid to relieve pressure on fossil fuel based energy facilities.

 Necessity & Benefits of EIA
The wind turbine facility requires an EIA because:
 
•    It involves construction, which is an activity relating to physical work, and therefore is considered a project.
•    It is not excluded from an EIA (i.e. it is not a small construction project or a maintenance project for pre-existing facilities).
•    It is considered a federal EIA.  Further, substantial energy projects, such as a wind turbine facility, are often evaluated using a comprehensive EIA (Noble 2006, 76).
•    The government is required as a regulatory/licensing authority over a large-scale energy production facility, therefore there is a trigger to initiate the assessment.
 
The primary benefits of conducting an EIA for the proposed wind turbine facility are:
 
I.    Managing Environmental Impacts
An EIA will bring scientific attention to the local ecosystem and boost awareness of the VECs. The result may be a positive benefit that would not have otherwise been implemented (e.g. the construction of a bird sanctuary for an endangered species).  An EIA also ensures that a formal record of the environmental impacts of the project is documented, which results in a useful reference for future similar projects.
 
II.    Mitigation Measures
The project can be planned with the intent of minimizing potential negative effects (e.g. loss of habitat and wildlife) and maximizing positive benefits (e.g. boosting the local economy).  For example, conducting an EIA can help ensure that the poor local economy is recognized and that a certain percentage of workers will be hired from the local community.
 
III.    Cost Savings
The proponent will save money by anticipating problems in the construction of the wind farm and accommodating them in the initial phase of the project, rather than having to implement expensive corrective measures.  For example, planning the locations of transmission lines and power substations in advance by consulting with the community will help maintain the quality of living, which will not result in complaints after beginning construction that could result in having to move transmission lines or stations (Brookings 2006).
 
IV.    Compliance with Standards
Conducting an EIA will ensure that the project meets all government required environmental standards before beginning construction, thereby avoid government intervention after the project is completed.  For example, an EIA could ensure that the proponent is aware of endangered birds in the local area, and adjust the project so that the endangered species is not affected and legal action is not required against the proponent.
 
V.    Corporate Responsibility
The steps in an EIA require public participation as well an unbiased assessment of the biophysical and socio-economic impacts of project. In this sense, conducting an EIA demonstrates the proponent’s appreciation of environmental impacts and the goodwill of their actions.  For the wind turbine facility, an EIA would force public participation in the project planning stages, thereby helping ensure that local stakeholders’ needs are addressed.  The result is a positive public image for the proponent. Many other benefits arise from conducting an EIA for the wind turbine facility in this scenario.  An EIA ensures that baseline data for the local ecosystems are collected, which are a useful scientific contribution.  An EIA can additionally generate “alternatives to” a project, which may result in the selection of a more effective project.

Generation of EIA
The overall objective of an EIA is to ensure that positive benefits are realized from the project through a systematic, rigorous, and transparent routine.  The roles of the participants are shown in Table 1.

Table 1: Roles of major participants in the EIA

Participants	Role	Description
Private Company	Proponent	The private company proposing the project.
Federal Government	Authority	Under CEAA, the federal government's authority is triggered for a large-scale energy project.
The local population affected directly by the project (to be defined through scoping); also, those that would benefit from increased energy generation (i.e. populations hoping to develop and expand in the rural area).	Stakeholders	The population considered "local" will be those who are noticeably affected by the project (e.g. farmers and their suppliers/consumers).  The communities that will benefit from increased power generation also hold stake in the project.  Anyone else interested in the project can also participate in this function.

The EIA process for the wind turbine facility should proceed as follows:
 
I.    Project Definition & Alternatives
The proponent must present their proposed action and describe potential alternatives “to” and alternative “means” for the project.  Possible alternatives to the large-scale wind farm may be to implement small, independent wind turbines as needed to accommodate energy consumption, to research and implement other forms of energy such as solar or geothermal, or to take no action (Orion 2006).
 
II.    Action Design
The proponent must submit their wind farm proposal to the federal authority for review.
 
III.    Screening
The authority will determine whether an EIA is necessary for the wind farm.  (Note: A comprehensive EIA will be required for this project.)

IV.    Scoping
The authority conducting the EIA will identify the VECs associated with the proposal, set the EIA boundaries, perform a baseline study of the affected region, and scope the alternatives to evaluate whether they are viable or desirable.  The VECs will be the focus of attention for the EIA.

Boundaries:    The EIA in this case will be limited in that it only analyzes the presented VECs, rather than a multitude of various issues.  The baseline data may also be constricted to a short period (i.e. less than a year) if there is a significant push to complete the project quickly.  There may also be limitations to the depth of the data collected, due to resource or time constraints.  The extent to which the local population is considered to be a ‘stakeholder’ is also a boundary in this EIA.  For example, while farmers whose land is directly affected by the project are considered to be primary stakeholders, the consumers who purchase produce from that farmer may only be considered secondary stakeholders (and further effects in that food supply chain are not analyzed).  Also, the effect of the environmental impact of the project is only being analyzed in a local region (i.e. the effect of increased avian species mortality is not being analyzed outside of the local environment).

V.    Preparation of EIA Report
An environmental impact statement is generated to predict the environmental and socio-economic impacts of the project (Noble 2006, 104).  Several potential impacts for the wind turbine facility are:
•    Loss of fertile farmland due to construction and building creation
•    Decreased quality of life (Cape 2004)
•    Loss of ecological habitats (Kenetech 1995)
•    Increased mortality rates of migrating birds and bats (Orion 2006)
•    Economic boost to the local economy through job creation (Global 2002)
•    Increased availability of renewable energy, lessening the carbon footprint of the area and enabling residential/economic expansion (Brooking 2006)

The significance of the impacts can be compared through: legal requirements, impact on sustainability, public concern, and reversibility (Noble 2006, 118).  Based on an analysis of the components, increased mortality of avian species and increased availability of renewable wind energy are among the most significant impacts of the project.

VI.    Public & Technical Review
The environmental impact statement, including potential impacts and their significance, is made available to the public for discussion.  Ideally, the stakeholders are involved in every step of the EIA process (as appropriate).  Neutral expert opinions may also be collected to suggest design modifications to the proposal.

VII.    Mitigation
The authority will develop a set of mitigation measures that can be implemented in the project design to reduce predicted negative impacts and maximize potential positive impacts.  For the wind turbine facility, this may include:

•    Locating the wind turbine facility so that a minimal amount of fertile farmlands will be disturbed.
•    Positioning the wind farm, transmission lines, and power substations as far away as possible from current and expected residential and commercial developments to reduce impact on quality of life (Kenetech 1995).
•    Relocating organisms or physical features of the disturbed habitat.  Creating shelters or sanctuaries for species whose habitats will be destroyed.  Constructing warning devices, safety devices, and re-directs where possible to avoid bird and bat mortality due to the turbines (Orion 2006).
•    Making restrictions so that a percentage (e.g. 40%) of newly hired maintenance and construction workers are residents of the locally affected community (Global 2002).

VIII.    Decision Making
The authority conducting the EIA will decide whether the project meets the appropriate environmental standards, and what improvements should be made to the project before implementation.

IX.    Implementation & Monitoring
If the proponent accepts the EIA, they will alter the project to meet the requirements of the EIA, and begin construction.  The resulting project is customized to provide maximum benefits. The final EIA report may be presented in a format similar to the TOC shown in Table 2.  Important summaries in the EIA have been separated in the report for improved readability, while some steps have been combined under a single section for conciseness.

Table 2: Proposed Table of Contents (TOC) for EIA

TOC Entry	Contents
Project Description	Description of case and explanation of necessity for the EIA (screening).
Consideration of Alternatives	Description of alternatives "means" and alternatives "to" the project including scoping of the alternatives.
Boundaries	Presentation of the limitations of the EIA (scoping).
Values Ecosystem Components	Discussion of the key issues in the EIA (scoping).
Description of Affected Environment	Presentation of the collected baseline data (scoping).
Impact Significance & Prediction	Forecasting and evaluation of the importance of the impacts.
Public & Technical Consultation	Public comments on the project supplemented with research and expert recommendations.
Mitigation Measures	Strategies for mitigation including the development of protection plans.
Monitoring & Follow-up	Discussion of methods of continuous data collection to verify mitigation measures and impact prediction.

EIA Process for a Key Impact
A significant impact of the large-scale wind turbine facility proposed in this project is the potential to increase the mortality rates of migrating birds and bats. To effectively address this issue, the following steps should be taken during each stage of the EIA:
 
•    Scoping:    Adequate information should be collected through the baseline study to plot the migration paths of the birds throughout the year, as well as their various habitats (Orion 2006).
 
•    Public & Technical Review:    An expert on bird migratory habits should be consulted to determine whether it is possible to re-direct the birds around the wind farm to any extent.  Scientific information should also be gathered on previous cases with similar problems.
 
•    Mitigation:    Based on the knowledge gained, mitigation measures can be presented. Constructing warning devices, safety devices (e.g. to prevent birds from entering the turbine area), and route re-directs where possible are potential methods that can be implemented to avoid bird and bat mortality due to the turbines.
 
•    Implementation & Monitoring:    The effectiveness of the mitigation measures should be compared and the most appropriate measures should be implemented.  Continuous data should be collected from the site following construction to determine the effectiveness of the mitigation measures, and whether the predictions about increased bird mortality were correct.  The results should be documented to improve the availability of information for companies proposing similar projects in the future. Thus, by following proper EIA procedure, a potentially detrimental environmental impact of the proposed project is lessened and potentially eliminated.

Critical EIA Components
The aspects of the EIA that are key to providing the desired benefits in this scenario are shown in Table 3.  The desired benefits for the EIA are to manage environmental impacts, produce mitigation measures, achieve cost savings, comply with federal standards, and display corporate responsibility for the proponent.

Table 3: Approaches to achieve maximum benefits from an EIA

Aspect of EIA	Approach to Achieving Optimal Benefit	Most Affected Benefit(s)
Accurate identification of key issues (VECs) / Effective scoping	Focusing attention on the key project components will help relevant impacts to be predicted, resulting in an EIA that specifically targets and tries to mitigate the most important issues affected by the project.	Managing environmental impacts
Thorough baseline studies	Comprehensive data will ensure that the project meets all government required environmental standards before beginning construction, thereby avoid government intervention after the project is completed.	Compliance with government regulation, Increase in scientific knowledge
Predicting impacts / Developing mitigation measures	Highly targeted mitigation measures make a difference to the predicted impacts based off of the critical VECs.	Managing environmental impacts, Mitigation measures
Public consultation	The proponent will save money by unusual problems (such as those raised by the stakeholders) in the construction of the wind farm and accommodating them in the initial phase of the project, rather than having to implement expensive corrective measures. Public consultation also signifies the proponent's interest in considering all sides of the project.	Cost savings, Corporate responsibility
Monitoring & Follow-up	Continuous collection of data after the project helps the proponent to determine whether the mitigation measures were successful or whether new measures are necessary.  Monitoring also shows that the proponent genuinely wants to mitigate the impacts of their project.	Managing environmental impacts, Mitigation measures, Corporate responsibility
Consistency, rigidity, and transparency in EIA format	This helps to ensure that a formal record of the environmental impacts of the project is documented, which results in a useful reference for future similar projects.	Managing environmental impacts

REFERENCES

Brookings County Board of County Commissioners, Navitas Energy, Inc., White Wind Farm, LLC, Department of Energy, Western Area Power Authority. 2006. White Wind Farm, Brookings County, South Dakota. Digests of Environmental Impact Statements, EPA number 060343.

Cape Cod Commission (et al.). 2004. Cape Wind Energy Project, Nantucket Sound, Massachusetts. Digests of Environmental Impact Statements, EPA number 040529.

Global Renewable Energy Partners, Inc., Siemens Energy and Automation, Inc., Table Mountain Wind Company, LLC, Department of the Interior, Bureau of Land Management. 2002. Table Mountain Wind Generating Facility, Nevada. Digests of Environmental Impact Statements, EPA number 020036.

Kenetech Windpower, Inc., PacifiCorp, Inc., Department of the Interior, Land Management. 1995. Kenetech/Pacificorp Windpower Project, Carbon County, Wyoming. Digests of Environmental Impact Statements, EPA number 950392.

Noble, B. 2006. Introduction to Environmental Impact Assessment. Don Mills, Ontario: Oxford University Press. Orion Energy LLC, PPM Energy, Inc., Department of Energy, Bonneville Power Administration. 2006.

Klondike III/Biglow Canyon Wind Integration Project, Sherman County, Oregon. Digests of Environmental Impact Statements, EPA number 060379.