Natalia Huang For The Straits Times 2 Sep 17;
It's time to assess the Environmental Impact Assessment or EIA. How much of it is relevant in a Singapore context, for example?
It is exciting that Second Minister for National Development Desmond Lee has announced the strengthening of Singapore's Environmental Impact Assessment (EIA) process.
In June, he said: "We are seeing how we can strengthen the EIA process, taking on board all the lessons that we picked up in the last few EIAs - improving baseline survey methodology, understanding of Singapore's perspective and situation."
Mr Lee's comments followed two high-profile developments - the Cross Island Line and the Mandai eco-tourism hub - for which EIAs were done by international consultancy Environmental Resources Management.
Here are some observations about the process and what more can be done, especially in the Singapore context.
EIA LAW
When is an EIA legally required in Singapore? Never, if it is related to plants and wildlife. There are EIA laws for potential pollution, but none for any impact on nature. So why are EIAs undertaken at all?
First, because there are stringent behind-the-scenes government requirements. For example, the National Parks Board will request an EIA if the proposed development is within a certain proximity of nature reserves.
Second, because of public outcry. An EIA can be conducted simply because of concerns over public reactions.
However, the current practice does not offer equal or transparent treatment of developments. No one really knows if a development will need an EIA as there are no explicit policies or guidance. Presumably, the lack of an EIA law in Singapore was to ensure that development would not be restricted - understandable given the need to grow and land scarcity.
The very same reason now necessitates an EIA law, or at least a fully transparent EIA framework, to ensure that scarce land and natural resources are managed and cared for properly.
EIA SCOPE
An effective EIA is one that provides the best possible information for the authorities to assess the impact of a development and thus impose measures to minimise it.
What is the best possible information for an EIA and how do we gather that information?
The scope is the first opportunity to define this. Unfortunately, scopes vary across projects in Singapore, and these could be shaped by guidance statements.
EIA guidance statements are published by government departments across the world - but not in Singapore. These outline the methods for collecting the best possible information for EIAs. Without guidelines, Singapore consultants are left to decide for themselves what is needed.
STRATEGIC INFORMATION GATHERING
Information on plants and animals that depend on a site can be collected in two ways - desktop studies based on previously published articles and books, and field studies that involve surveying plants and animals on-site.
In some cases, in-depth field studies might not be necessary. For example, if an area has been extensively studied before, a thorough literature review would provide more helpful information than a month of field surveys. In Singapore, nearly every inch has recent and historical data, so desktop studies must be part of EIAs. What is needed is an open-source repository for all ecological data.
A scientist who understands the scientific method should decide what information to collect and how to collect it, as that must be tailored to the type of development and the nature of the environment. This is arguably the most important aspect of an EIA. If not enough information or the wrong kind is collected, there is a risk that important environmental aspects could be overlooked and the impact on them might not be minimised.
Given the short timeframe and limited budget of EIAs, one must be strategic in collecting relevant information. Field studies should focus on conservation (such as significant species, habitat quality, and areas of importance for plants and wildlife) and ecological processes (such as seed dispersal, population fragmentation, species interactions, hydro-ecology and connectivity to nearby forests).
If monitoring is expected to follow the development, the methods used for the EIA field studies must be designed in such a way that they are replicable and suitable for comparison.
CERTIFIED CONSULTANTS
This is a bit of a cowboy industry, with no regulations governing who can do an EIA or its studies.
As EIAs require an understanding of plants and animals and their interactions, the studies must be done by scientific experts in the field. On one project, there was a hydrologist - someone who studies water - who was told to study plants and wildlife for an EIA. Plants should be studied by botanists, animals by zoologists, and a combination of these by ecologists and biologists.
Surveys should be carried out by scientists with a good understanding of nature in Singapore as well as the peculiar needs of an EIA.
Environmental consultants need a certification and accreditation scheme. In order for arborists - tree experts - to practise, they need to be certified and registered, and they must undergo annual professional training. The same could be applied to EIA consultants.
MORE SCIENTISTS
Where Singapore excels in relation to other countries is in public consultation, at least for recent major EIAs, where nature groups have been consulted throughout the EIA and construction process. Public consultation aims to identify the public's interests and gain feedback to improve the project, and also to foster public understanding of the project.
Where Singapore can improve is in engaging more scientists and academics in the process, as they are the ones who can provide objective scientific information based on research and experience.
Passion without knowledge is like a blindfolded warrior swinging a sharp sword. Remove the blindfolds by engaging scientists and facilitating workshops that encourage knowledge-sharing, and as a way to encourage input from less outspoken experts.
Scientists also need to recognise the realities of the development process, where timeframes are limited and practical decisions need to be made based on little information. We can learn from other countries that have been fine-tuning their EIA processes for years, and create a system that works for us, for the future of Singapore's environment.
The writer is principal ecologist at Ecology Matters, a consultancy providing ecological advice and biodiversity studies for environmental impact assessments.
No need for new law on environmental assessments
Straits Times 7 Sep 17;
Ms Natalia Huang has called for stronger engagement with scientists in shaping the Environmental Impact Assessment (EIA) process, and argued in favour of an EIA law or a fully transparent EIA framework (EIAs: Enigmas in Action?; Sept 2).
Singapore is already under some legal obligation to undertake EIAs.
In the famous case concerning pulp mills on the Uruguay River, the International Court of Justice ruled in 2010 that all countries are legally obliged to undertake an EIA before projects like this are authorised.
The Court left it to individual countries to determine the details of conducting an EIA.
It is not inevitable that Singapore must embrace "hard" laws in the form of a statute.
Codes of conduct can be developed after consultations between public and private stakeholders. An example of this is the Building and Construction Authority's Code of Accessibility in the Built Environment.
A "soft" law approach in strengthening EIA processes has its benefits.
While the code of conduct need not be legally binding, it can be useful in urging private stakeholders to employ some of the best international practices of EIAs.
There are already laws here which govern the actions of private stakeholders. These can be adjusted to encourage buy-in, such as making compliance with the laws a condition for permit renewals.
Ultimately, the Government must retain its legal flexibility to make decisions that advance our collective interests.
Daniel Seah Chin Aun
