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Project alternatives assessment in ESIA > too late, too plain and ineffective > how to make a U-turn

Equitable assessment and comparison of possible alternatives is essential for accountable decision-making, in various domains. Obviously, the quantitative, numerical approach provides more rigorous and justified comparison of alternatives. In fact, the quantitative approach has long been an engineering practice for chemical and energy process synthesis, infrastructure and building design, etc. In previous times alternatives analysis mostly considered technical and economical (CAPEX, OPEX) criteria and numbers for deriving business decisions.

However, in the last decades, other indicators and factors were introduced to account for environmental, social, health and nowadays climate aspects of the analyzed alternatives. The breakthrough approach was Life Cycle Assessment (LCA), which introduced numerical weighting and scoring, along with an extended time horizon - covering the whole life cycle of a material or product, incorporating their processes (i.e. cradle-to-grave). LCA is already applied to analyze alternative chemical substances and materials. One of the most important initiatives and recommendations on the chemicals alternatives assessment is proposed by the US EPA. There are a number of the applications, and one example is presented in Figure 1 on LCA-based (EPA TRACI model) numerical assessment of alternative polymers on important environmental and health impacts.

Figure 1. Environmental and health impact assessment of plastic material alternatives using LCA (EPA TRACI model). Source: Tabone, M. D. et al, Environmental Science & Technology, 44, 2010, Copyright American Chemical Society

Application of LCA for alternative assessment goes beyond chemicals, for complex materials and whole products. For instance, LCA is, more recently, combined with Building Information Modeling (BIM) for building materials analysis.

Regarding projects’ design, another type of quantitative approach is applied to assess the alternatives in linear infrastructure developments. It uses various data (topological, geomorphological, biological, populational, etc.) from Geographical Information Systems (GIS), and optimization algorithms (or Analytical Hierarchical Process - AHP, Analytical Network Process - ANP) to evaluate alternative routes, based on defined criteria (economical, ecological, social, etc.). Nowadays, there are advanced and user-friendly software applications (e.g. Pathfinder, Moata Route Optimiser, etc.) for a detailed alternative analysis of linear projects, such as roads, railroads, overhead transmission lines, oil and gas pipelines, etc. However, both the former and latter approaches are not widely used or well integrated in ESIA.

Importance of project alternatives assessment is recognized from the very beginning of EIA systems. However, the outcomes are moderate, at most, with many issues and challenges still present.

Almost all EIA regulatory documents around the globe require accurate and objective project alternatives assessment. The statutory documents define the objectives and general scope which usually includes: outline of all “meaningful or reasonable” alternatives, the reasons why some are not addressed in detail, a rigorous assessment of selected alternatives including “no project option” and elaborated justification why a preferred alternative (i.e. proposed project) is selected.

However, the practice often falls short to the prescribed objectives. The reasons are versatile and some are excellently presented by A. Steinemann in the Environmental Impact Assessment Review publication, back in 2001. First of all, she argues that the ‘choices of alternatives can be subjective and arbitrary, as they often reflect narrow project objectives and preference toward a proposed project’. Based on analysis of 62 EIS in the US the author claims that there are cases in which ‘environmentally sound alternatives are overlooked or informally eliminated before the formal analyses in EIA’ and she provides a compelling list of specific problems. Further, Steinemann emphasizes that ‘public participation often occurs too late in the EIA process to significantly influence the design of alternatives’.

Unfortunately, the main problem still exists after 20 years. In today's practice, initial assessment of project alternatives is done during a project design, when key decisions are made. These are still predominantly driven by the business objectives, usually without an in-depth sustainability analysis. Afterwards, the EIA commonly supports previous decisions on the proposed alternative, with very little power to reverse it, even if detailed assessment would point to a more sustainable and economically acceptable solution. Clearly, this consecutive process can result in suboptimal project design in regard to the environment and societies and in favor of investors' capital interests. The choices made are less considering “alternatives to” the project and much more “alternative means”. Typical example would be assessment of alternative routes (i.e. means) for a motorway within EIA (example in Figure 2.), instead of considering alternatives to car transportation, for instance a more sustainable one, e.g. railroad.

Figure 2. Example of alternative road routing options and the study area. Source: Danish Road Directorate: VVM Frederikssundsmotorvej

Moreover, during the conventionally conducted EIA, the practitioners are usually exhausted with a long and comprehensive analysis of the proposed project impacts. Under time pressure they usually leave-out a detailed analysis of alternatives and their full comparison. Having a previous decisive decision on a preferred alternative also does not “motivate” them to do so. Finally, EIA studies commonly do not provide a quantitative analysis of project alternatives, as the ones seen in the LCA.

How can the current practice be crucially improved for sustainable outcomes?

Preferably, regulators (authorities) should revise the statutory legislation and standards and define the process more thoroughly and precisely. They should be more determined and prescriptive towards consideration of “alternatives to”. And go beyond phrases such as “meaningful or reasonable” alternatives, which can be the excuse for informal or capital-driven discard of options. Since such decisions are strategic in nature, authorities should focus on empowering regulation and ensuring good practice on planning analysis prior to projects’ EIA - Strategic Environmental Assessment (SEA), Cumulative Impact Assessment (CIA) and Ecosystem Services Assessment (ESSA). If those are conducted promptly and properly, the subsequent EIA/ESIA would be somewhat relaxed from strategic decisions that might be completely opposite to project proponent objectives and motivation. The World Bank proposed the preferred steps in alternatives analysis already in 1990’s, in which SEA and ESIA are interconnected for optimal outcomes (Figure 3). However, the workflow could be revised to place more emphasis on the Strategic Environmental Assessment part - include more steps of alternatives consideration, evaluation and selection, prior to ESIA.

Figure 3. Stages in analysis of alternatives, connection of SEA and ESIA. Source: The World Bank, EA Sourcebook, 1996

Another key change would be the formal requirement for quantitative comparison of alternatives. This could be expected on both stages - screening a wider list of alternatives for narrowing options and in detailed assessment of selected alternatives. Nevertheless, before imposing a quantitative approach in standards and regulations, a methodology should be proposed, widely discussed and accepted.

The above mentioned approach with GIS (overlay maps with data) and numerical optimization is very rigorous. However, it is best-suited for linear projects, so may not be applicable to many other project types, as well as for some alternatives even for a linear infrastructure (e.g. strategic alternatives, see above). Also, the results are sometimes incomplete, for instance health or social effects are not fully addressed. As it is also quite specialized and demanding for use, its general adoption might be limited. Therefore, the multi-criteria approach with expert selections, numerical factors and formulas to provide a final score and rank is more realistic for EIA, as well as for SEA, CIA, ESSA. This approach is already long-time applied in ESIA (not so frequently, though), and was recommended in many books and guidelines (e.g. World Bank, IFC, EBRD, etc.). A good example of quantitative screening of alternatives, with weighting scores, is given in Figure 4. However, such Excel based spreadsheets are not very friendly for utilization, replication, data visualization and incorporation in an overall EIA analysis.

Figure 4. Example of alternatives scoring for tailing storage sites (TSF 1b and 1c) in a mining project. Source: Assessment of tailings management alternatives, Knight Piesold Ltd. for Sisson Mines Ltd., 2015

Reaching a wide consensus on quantitative methods is a challenging endeavor for many reasons, which are elaborated in our previous article on Standardization and digitization of methods for impact evaluation, along with proposed actions and possible considerations for quantitative methods derivation.

Nevertheless, before the regulations and methods are adopted (which may take years or even decades), the project proponents and the consultants can take many actions for improving alternatives assessment in their EIA.

The role and support of digital systems in alternatives assessment can and will be significant.

The above stated ambition is probably utopian, given the current situation in which regulators are stagnant, proponents are primarily motivated by business results and consultants are under time and other pressures. Undoubtedly, a comprehensive and quantitative assessment of many alternatives in EIA at two stages (screening and detailed) is demanding and time consuming. However, digital systems and applications can play an indispensable role for obtaining the goals. How?

Firstly, the EIA digital system can be used in the (early) design phase, exploiting quantitative methods and other tools for incorporation of environmental and social aspects. The numerical screening analysis could be performed before formal EIA has commenced. This is already done for many designs, but now it should include methods defined for EIA or SEA, with tight collaboration with environmental and social expert teams. Such a virtual collaboration is enabled with Cloud-based solutions, which should also enclose user-friendly systems for scoring, ranking and presentation of results (visualization). A Cloud platform also allows for early inclusion of public and stakeholders views and concerns in alternatives assessment.

Many experts argue that during a project design phase there is not enough data for reliable assessment of alternatives, especially its environmental and social components. This is true for a detailed assessment, but for the screening phase it should not be critical. The initial methods should account for uncertainty, and the resulting list of alternatives should be wider. The early quantification should primarily prevent subjectivity and arbitrary exclusion of potentially more sustainable solutions.

If the same digital system is utilized, the data and results generated in the project design phase would be directly used later in EIA, for more effective outcomes. So, the time and effort is not duplicated or wasted.

Secondly, such a digital solution can significantly aid the next phase - a detailed quantitative assessment of impacts for each alternative and their comparison. With more alternatives selected for rigorous analysis, the benefits of using software rise sharply. Namely, most of the project alternatives exhibit similar impacts. A digital system allows experts to evaluate the proposed project impacts using a multi-criteria method. This would be a base case to be replicated (all data copied) to alternatives. In the next step an expert would introduce differences between alternatives - adding new impacts and making changes in criteria options (timing, magnitude, sensitivity, etc). Finally, numerical scores of impact significance can be readily visualized in charts (bar, pie, heatmaps, etc.) for an effective and more transparent comparative analysis of alternatives.

There are challenges in this replication-based approach, for instance how to evaluate a “no project” option starting from the base-case (proposed project). Or why to replicate a proposed project if some alternatives are considerably different. However, with proper software design for flexibility, the acceptable solutions can be reached. In contrast, such a comprehensive analysis is almost impossible with the traditional approach (without software support), given the resources and time constraints.

Overall, discussed changes have a potential to make a U-turn in alternatives assessment, for well-informed decision-making, responsible to the environment and local communities.


Nikola Nikačević

Founder of Eon+ and the principal co-author of Envigo

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