ABSTRACT

The practitioners of Environmental Assessment, both consultants and authorities, are still exploring the principles, contradictions, and uncertainties of the way forward to good environmental analysis. There are still many problems.

The clash between national and local environmental issues. Does national economic advantage cancel the damage to a local environment? Do national environmental protection policies override the loss of local jobs? An Environmental Assessment only deals with one project in one place, and a method of dealing with the conflict between national and local policies has yet to be designed. Sometimes it is advisable to go right back to the original decisions on the development and to reconsider first principles; a course which most clients are most unwilling to consider, but which may be the most profitable in the end.

The difficulties of judging which environmental impacts of the development are likely to be significant and which are likely to be insignificant; for whom, for how long, and to what degree. How far can accurate projections of impacts be made? How justifiable is the cultural, economic or social cost of the significant impacts of a development on a natural or human community?

The balancing of quite diverse factors such as employment, visual impact, and use of natural resources. Everyone sets different values on their environment, their job, and their relationship with the natural world; someone has to decide which values shall take priority.

142The problem of providing enough expertise and money to check an Environmental Assessment, and to monitor the development during construction and operation. Should the local planning authority, financed by the local community, carry this load, or should the cost be borne by the developer? Either choice seems unfair, yet someone must pay for proper control of the environment, or else the whole process becomes a pointless exercise in bureaucracy.

The decision on the limits of an Environmental Assessment. Should it cover just the surrounding area, or should the impacts be traced as far as they appear to be significant? A project may be small in size, but its repercussions on rail links the other side of the country, the dumping of wastes in distant valleys, or the pollution of water many miles downstream are still significant to some other part of the ecosystem.

What are the thresholds of tolerance? Is it for the developer to prove that some aspect of his project will be harmless, or is it for the controlling authority to decide whether an impact is tolerable or not? Even for those impacts which are measurable, the thresholds may vary in time and place; every camel has his own set of weights and measures for the last straw. One development, two developments, three developments may be absorbed into the local ecosystem, but one more may well tip the whole human and natural system into disarray as the supporting infrastructure of a district, or the natural regeneration system of a river, breaks down from the overload.

How are multiple developments, in which some projects merit an Environmental Assessment and others do not, to be controlled? Should the entire complex be subjected to assessment, possibly causing a lot of unnecessary work, or should each part be treated on its individual merit, thus denying the relationship between one part of the development and the others?

How far are the promoters of one development to be held responsible for adverse effects generated by later developments consequent on their own, which they could have foreseen but not controlled, and should they be held liable for changes of heart by other bodies working with them on the assessment? A case in point is the proposed rail link from the Channel Tunnel to London, where British Rail originally said nothing about new lines, nor indeed about high speed-trains. The decision to introduce new high-speed tracks to London, and to increase the number of freight trains, appears to have been taken after the Channel Tunnel proposals were accepted, despite 143the close relationship between cross-channel and UK traffic. Even the decision that all freight and passenger traffic should go to London seems to be a later idea, since this concept does not form part of the Channel Tunnel Environmental Statement. Had an Environmental Statement for the associated rail links been integrated with the Tunnel Environmental Statements, both projects might possibly have been modified. Perhaps this type of multiple development is a situation where the Secretary of State could usefully exercise his powers to compel the relevant bodies to prepare interrelated Environmental Statements.