Impact Assessment and Project Appraisal

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Environmental impact assessment follow-up and

its benefits for industry

Ross Marshall

To cite this article: Ross Marshall (2005) Environmental impact assessment follow-up and
its benefits for industry, Impact Assessment and Project Appraisal, 23:3, 191-196, DOI:
10.3152/147154605781765571

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Impact Assessment and Project Appraisal, volume 23, number 3, September 2005, pages 191–196, Beech Tree Publishing, 10 Watford Close, Guildford, Surrey GU1 2EP, UK
Industry benefits
Environmental impact assessment follow-up
and its benefits for industry
Ross Marshall
Applying follow-up within environmental impact
assessment (EIA) is no longer an option but a
sound precaution and a proactive measure in to-
day’s heavily regulated industrial environment,
where the announcement of new development is
treated with dismay and opposition by local resi-
dents. Increasingly, successful development is
viewed in terms of its final result — its operational
environmental performance, its acceptance by
stakeholders, its contribution to sustainable dev-
elopment, and, critically, the scale or magnitude
of environmental impact over all life-cycle
phases. For astute proponents, the evidence sug-
gests that EIA follow-up has a valuable role to
play in good developmental practice. It can also
encourage integration of environmental perspec-
tives into developmental programmes, the sys-
tematic implementation of mitigation and the
triggering of environmental risk responses posed
through construction activities. This paper
shares experience with EIA follow-up from an
industry practitioner’s viewpoint to assist with
learning from experience and capacity building.
Seven perceived functions of EIA follow-up are
examined alongside specific case studies.
Keywords: EIA; EIA follow-up; proponent; industry;
monitoring; audit; post-decision; communication
Ross Marshall is EIA Manager, National Environmental As-
sessment Service, Environment Agency, Waterside House, Wa-
terside North, Lincoln, LN2 5HA, UK; Tel: + 44 01522 785885;
E-mail: ross.marshall@environment-agency.gov.uk (he is also
President-elect of IAIA and senior visiting research fellow at the
Graduate School of Environmental Studies, University of
Strathclyde, UK).
Impact Assessment and Project Appraisal September 2005
T
HE DEVELOPMENT of new infrastructure for
society’s needs is fundamentally problematic
in democracies. This is particularly true where
responsibility for planning and installing essential in-
frastructure (for example, power, sewerage, roads) has
been devolved to privatised companies. Since the ad-
vent of privatisation in the UK, this process is compli-
cated further when decision making bodies (DMBs)
(for example, local planning authorities, statutory
consultees) and residents perceive no immediate
benefit to themselves through the siting of necessary
infrastructure, or when schemes benefit members of
society distant from the site of development.
The need for EIA follow-up will be greatest
where inherent uncertainty in impact assessment
requires supplementation, or where stakeholders re-
quire controlling frameworks for mitigation. A regu-
lator’s motivation for follow-up will be bound up
with the desire to control compliance, reduce uncer-
tainty, verify predictions and ultimately improve
decision management in future EIA processes. An
individual or community’s desire for follow-up will
focus on the management of issues of concern.
Under both scenarios, proponents will be agree-
able to follow-up imposition, if it results in devel-
opmental consent without disadvantageous economic
cost. This simplifies the complex interactions among
stakeholders, but highlights an area where the situa-
tion’s practicalities result in proponent acquiescence.
This necessarily implies that the proponent’s
relationship with regulators and stakeholders is
typically reactive — the imposition of monitoring
programmes or audits acting as a regulatory ‘stick’
with which to beat the proponent’s ‘donkey’ into
environmental compliance. Whilst often true, it is
worth examining what other potential opportunities
(‘carrots’) follow-up can hold for proponents.
Arts et al (2001) identified four key activities in
1461-5517/05/030191-6 US$08.00  IAIA 2005 191
Environmental impact assessment follow-up and its benefits for industry
EIA follow-up: monitoring; evaluation; management;
and communication. Examination of these activities
from the proponent’s viewpoint suggests that at least
seven distinct functions of potential advantage
through EIA follow-up can be discerned (Table 1).
ScottishPower’s experience and case studies
The following sections outline the experience and
application of EIA follow-up of ScottishPower, an en-
ergy company. The UK case studies (see Figure 1),
representative of issues that commonly face propo-
nents when developing new projects, have been se-
lected to demonstrate how EIA follow-up can add
value beyond that of basic compliance with imposed
conditions.
Monitoring for conformance
Monitoring for conformance is one of the common-
est forms of EIA follow-up (Arts and Nooteboom,
1999; Arts et al, 2001; Arts and Morrison-Saunders,
2004). The requirement for conformance monitoring
arises when stakeholder concerns exert pressure on
DMBs to ensure that demonstrable control is im-
posed over specific impacts post-decision. Con-
formance monitoring requires proponents to develop
or engage in programmes that provide proof of tech-
nological, management or operational control
over specific environmental concerns. No inter-
nationally accepted methodology exists to imple-
ment or perform conformance monitoring. However,
structured EIA follow-up monitoring or management
systems can form a bridgehead between EIA and
final development construction, ensuring that miti-
gation measures are implemented.
Table 1. EIA follow-up: motivating factors for proponents
Key activities in Proponent orientated forms of EIA
EIA follow-up follow-up
Monitoring Monitoring for conformance
Monitoring for compliance post-
decision
Evaluation Evaluation for future knowledge
Management Management for future consents
and licences
Management for liability avoidance
Communication Communication for consent closure
pre-decision
Stakeholder communication
192
A: Gretna 275/132kV substation
B: Fife 132kV refurbishment
C: Scotland-Ireland Interconnector
D: Sappi Paper Mill
E: Beinn an Tuirc wind farm
F: Shotton Paper Mill 132kV
Figure 1. Map of ScottishPower case studies
The Scotland–Ireland Interconnector, a 90 km
overhead and sub-sea electricity-transmission line
connection between the Scottish and Irish electrical
systems, was developed in partnership between
ScottishPower and the Northern Ireland Electricity
Company. During the course of the EIA, a large
number of mitigation proposals were developed for
the Scottish mainland side of the link (Scottish-
Power, 1997). To reassure stakeholders that individ-
ual consent proposals would be implemented,
ScottishPower proposed and developed, pre-
construction, a ‘Mitigation Handbook’ — a control-
ling document that set out in detail how individual
follow-up measures would be managed.
Description
The collection of data and comparison with standards, predictions or
expectations that provide proof of technological, management or operational
control against a specific consent requirement or voluntary mitigation measure
Monitoring and audit activities that are developed through environmental
management frameworks to demonstrate how the collective body of consent
conditions or voluntary mitigation measures will be enacted and complied with
The appraisal of the actual impact or implemented mitigation with standards,
predictions or expectations in environmental performance for one development,
that can address areas of impact encountered in future developmental EIA
Monitoring and evaluation activities during EIA that facilitate operational or
environmental permitting in subsequent stages of the development’s life cycle
Monitoring and evaluation activities arising from EIA that offset future risk of
liability or compensation issues
Anticipatory proposals that detail management, monitoring or evaluation
proposals submitted pre-decision, their objective being to foreclose concerns
and to positively increase the likelihood of the development being granted
statutory consent
Activities integrated within the EIA process that inform stakeholders or
communities, enhancing the relationship between the developer and such
interested parties to pre-empt concerns or foreclose objections
Impact Assessment and Project Appraisal September 2005
 Environmental impact assessment follow-up and its benefits for industry
During construction, the Handbook became the
main reference document in use among interested
parties, landowners, the contractor and Scottish-
Power. Proof of its value was demonstrated in the
UK outbreak of foot and mouth disease (FMD; a
virulent animal disease in livestock necessitating ex-
treme statutory restrictions and hygiene precautions)
during 2001. During the outbreak, the Handbook
was revised to include specialised FMD-operating
protocols and landowner “entry onto land” consent
forms. These amendments to the Handbook reflected
its acceptance by all stakeholders as a trusted
mechanism for controlling conformance.
Monitoring for consent compliance post-decision
Environmental mitigation or consent conditions are of
little value if they remain unimplemented post-
decision. Only through a proponent’s compliance with
voluntary mitigation or imposed consent conditions
will the EIA-planning process have demonstrated its
merit in safeguarding environmental impact. Trans-
ferring what is envisaged as mitigation into compliant
actions requires effective management. EIA follow-
up applied through environmental management
systems (EMS) ensures that this happens.
The Fife 132 kV refurbishment programme secured
electricity supplies for 160,000 residents in Central
Scotland. During development, ScottishPower was
aware that the proposal for new transmission lines
would attract significant stakeholder concern regard-
ing visual impact, electromagnetic fields and eco-
logical disturbance.
To implement the resulting consent conditions and
mitigation strategies, a project-specific environmental
management plan (EMP) was developed. The EMP
took the concept of the Mitigation Handbook fur-
ther. It ensured that, not only were environmental
obligations complied with, but also that they could
be verified through audit. The EMP model, devel-
oped from an Environment Agency concept (Envi-
ronment Agency, 1999), focused on managing the
significant environmental impacts associated with
construction (ScottishPower, 1999; Marshall, 2002).
Post-construction, because of its proven value, EMP
usage was incorporated into the company’s certified
ISO 14001 EMS system.
Transferring what is envisaged as
mitigation into compliant actions
requires effectual management: EIA
follow-up applied through
environmental management systems
ensures that this happens
Impact Assessment and Project Appraisal September 2005
Evaluation for future knowledge
Although EIA follow-up concentrates on the moni-
toring and control of environmental impact; in spe-
cific cases, knowledge gathered or lessons learnt
through follow-up may be transferred into future de-
velopments. Since 1990, promotion of renewable
energy in the UK, notably windpower, has given rise
to debate regarding specific impacts on nature
conservation, landscape and noise concerns, not
previously encountered in conventional energy
development siting programmes.
The Beinn an Tuirc (BaT) windfarm, situated on
Scotland’s Mull of Kintyre, is now one of the UK’s
most productive windfarms. However, initial scop-
ing studies established that this upland site formed
part of a golden eagle’s (Aquila chrysaetos) range.
To mitigate against the risk of eagle collision and to
improve the overall prey availability for the eagles,
ScottishPower designed, through the EIA process,
an innovative habitat-management plan that sought
to increase prey availability at alternative sites, di-
verting the eagles from the windfarm’s terrain.
ScottishPower, in its analysis of EIA ecological
data pre- and post-construction, recognised the sin-
gular value of EIA follow-up at BaT and its future
application in developing other upland windfarm
sites. The decision was therefore made to extend
ecological and eagle EIA follow-up monitoring pro-
grammes for an additional five years. Access to this
extensive monitoring data bestows on ScottishPower
a competitive advantage unavailable to its competi-
tors. The BaT windfarm has effectively become an
extensive open-air laboratory, with the BaT EIA
follow-up data now directing the siting and devel-
opment of new schemes.
Management for future consents and licences
In the UK, environmental and operational industrial
activities are seldom regulated through one inte-
grated consent; instead, a number of distinct statu-
tory permits are required. For power stations,
developmental consent will be followed by the ne-
cessity to gain an integrated pollution permit prior to
operation, licences to burn specific fuels, to manage
waste or to store oil. With these future obligations in
mind, proponents should bear in mind whether they
can save time, money and effort if they identify and
co-ordinate the EIA and EIA follow-up process to
minimise the data gathering requirements across
their regulatory obligations.
Sappi Paper Mill combined heat and power plant is
a 60 MW gas station in Blackburn, England. Con-
sent to build and operate required an application
under the UK’s Electricity Act 1989 and an envi-
ronmental impact statement (EIS). During initial
scoping, local residents expressed concerns about
the proposed plant’s impact on local air quality
193
Environmental impact assessment follow-up and its benefits for industry
(LAQ), particularly in the vicinity of a primary
school.
Recognising the lack of LAQ ambient data, and
that potential for localised air pollution would be an
important factor in the determination of the consent,
ScottishPower proposed to residents that, in the ab-
sence of LAQ data, a combined weather/nitrous ox-
ide monitoring station be installed on a nearby
school’s roof. Continuous data collection would en-
sure that LAQ was monitored on-line and that the
data would be freely available to the school (for lo-
cal residents), the local authority and ScottishPower.
Subsequently this ‘in-situ’ data was combined
with data obtained through prescriptive atmospheric
dispersion modelling to evaluate the proposed
plant’s impact on LAQ during the EIA. The air-
monitoring programme was subsequently extended
post-decision through EIA follow-up into the con-
struction and commissioning trials. This subsequent
follow-up data has allowed an accurate picture of
ambient LAQ for the area to be developed, the veri-
fication of EIA predictions, and negotiations regard-
ing final emission permits to be based on ‘real’ as
opposed to ‘predicted’ LAQ data scenarios.
The monitoring station remains in place and the
‘win–win’ advantages to stakeholders through this
EIA follow-up programme remain. Local residents
retain access to the data and are reassured regarding
the plant’s environmental impact, the company’s op-
erational LAQ data needs are met, the local authority
has an additional LAQ monitoring station and the
programme has established ScottishPower as a good
neighbour in the area.
Management for liability avoidance
Although the majority of functions are demonstrated
through case studies specific to ScottishPower’s ex-
perience, in the case of liability avoidance, as no
specific ScottishPower case exists, the work of Ross
et al (2001) is best cited.
The Gulf of Guayaquil gasfield development is an
offshore natural gas well development in Ecuador.
Follow-up was utilised as a defensive strategy to
protect the proponent from anticipated claims re-
garding pollution or yield loss from neighbouring
shrimp fisheries, a high profile economic resource,
close to the gas field. The proponent started to moni-
tor in detail their own emissions and impacts, and
the emissions from other industries, to offset the risk
of any non-attributable liability being associated
with their own operations.
Ultimately, a monitoring and EMS was developed
and integrated with operations to protect the com-
pany from liability in the event of adverse impact to
the shrimp fisheries. The Gulf of Guayaquil case is
of note in that it is a rare published example of a
proponent using EIA follow-up to foresee events and
to determine a strategic pathway during future
operational phases.
194
Communication for consent closure pre-decision
For projects with high community visibility and
significant environmental impact, it is important to
retain community acceptance and understanding. It
is a recognised factor of EIA that specific aspects of
a development will come to dominate future debate
and concerns regarding the particular form of devel-
opment, for instance, odour and transport impacts
for waste-handling facilities, air and noise emissions
for power stations, dust and noise for mining opera-
tions. This is commonly termed “issue attention”
(Downs, 1972).
It is the perceived significance of such issues that
results in initial opposition by stakeholders to a de-
velopment proposal, and the perceived effectiveness
of the implemented mitigation that settles such issues.
EIA follow-up, for communication for consent clo-
sure, can provide a controlling vehicle that starts pre-
decision and allows progress to be made in resolving
such issues. The challenge for the proponent is to
anticipate such concerns and proactively to develop
follow-up solutions agreeable to all stakeholders.
The Gretna 275/132kV-substation project, on the
Scotland–England border, was necessitated by the
threatened closure of a regionally important nuclear
power station. The time allocated to obtain planning
permission and to construct the substation was criti-
cal, for, without reinforcement of the electricity net-
work, the nuclear plant’s closure would threaten the
security of electricity supplies in southern Scotland.
ScottishPower sought to fast track the planning
process by pre-empting those environmental con-
cerns that could delay the planning application or the
setting of consent conditions.
The company prepared a detailed in-house EIS,
and undertook scoping and consultation exercises
with local stakeholders. The EIS evaluated the exist-
ing environmental baseline and sought to identify
all environmental aspects of material significance to
the planning application. In anticipation of stake-
holder concerns, and in a variation from existing
practice, the company decided to produce a docu-
ment entitled “The Gretna substation — control of
environmental effects during the construction phase”
(CEE document) (PowerSystems, 2001). The CEE
document’s objective was to set out proposed con-
sent conditions, the frameworks for their manage-
ment and how individual protocols would guide
mitigation implementation or address these concerns
during construction. The document also acted as a
public statement on how ScottishPower would:
• control environmental effects;
• meet its stated environmental commitments;
• follow good construction practice; and
• apply follow-up.
The CEE document was submitted as part of the
planning consent, and the DMB (Dumfries and
Impact Assessment and Project Appraisal September 2005
 Environmental impact assessment follow-up and its benefits for industry
Galloway Council) was invited to set and reference
the document as part of the planning consent. This
they duly complied with.
Stakeholder communication
In the UK, the concept of environmental harm is a
valid material consideration in planning terms when
deciding whether to grant consent, and legitimate
grounds for refusal (Ball and Bell, 1995). Con-
sequently, the mitigation of environmental effects
becomes an important area for resolution post-
decision. It is thus important to ensure that miti-
gation strategies are communicated clearly and
concisely to stakeholders. Regardless of other social,
economic or land-use considerations, unless the en-
vironmental effects of development are deemed to
cross recogniseded boundaries of environmental and
political acceptability, developmental consent will
not be granted.
The Shotton Paper Mill 132 kV transmission
line EIA involved a new overhead line extension into
an existing industrial area in northeast Wales.
Although the DMB supported the strategic econ-
omic necessity to the region of the new transmission
line, limited routeing options would place the
line close to the breeding and roosting lagoons of a lo-
cally important colony of common terns (Sterna
hirundo).
During scoping, a local nature-conservation
group expressed concern about potential disturb-
ance and displacement impacts on the terns, in par-
ticular, their future breeding success. Recognising
that an open approach to consultation and resolution
of the issue would assist communication, Scottish-
Power proposed that an independent ecological
EIA and EIA follow-up study be commissioned
from the British Trust for Ornithology (BTO) to
quantify the conservationists concerns. This was ul-
timately accepted and a tern-monitoring programme
developed.
One of the BTO’s initial conclusions was the
breeding-site limitations in the lagoons were cur-
tailing the expansion of the tern population (Balmer
et al, 2002). In response, ScottishPower proposed,
as compensation and as part of the mitigation
programme, to construct new tern breeding sites that
would also alter existing flightlines into the lagoons
away from the proposed line. The subsequent two-
year EIA follow-up monitoring programme has indi-
cated no significant impact on bird displacement or
disturbance, no recorded collisions with the new
line, adaptation of flightlines to the line, and, en-
couragingly, faster than anticipated colonisation of
the new breeding site.
Unlike the CEE document (Gretna substation case
study), which sought to fast track the consent appli-
cation through consensus building and pre-empting
regulatory and stakeholder concerns, the Shotton ap-
proach highlights that, although economic necessity
Impact Assessment and Project Appraisal September 2005
enhanced the presumption that consent would be
granted, there was an awareness that EIA follow-up
could pre-empt and reassure stakeholder concerns,
while preserving the company’s reputation and
community relations. Through EIA follow-up, early
engagement was initiated and a programme of moni-
toring set up that provided independent verification
of post-construction impacts.
Conclusions
Follow-up is more than just a mutually convenient
way of agreeing developmental terms. For propo-
nents concerned about their environmental perform-
ance and reputation, it forms a strategic link between
EIA and subsequent environmental management
practices. Once embraced, EIA follow-up starts to
define the very approach adopted towards EIA,
stakeholder communication and mitigation. Follow-
up frameworks applied through self-regulated
mechanisms can significantly improve stakeholder
acceptance of development proposals and reduce
opposition.
Embracing EIA follow-up has improved Scottish-
Power’s control over construction programmes and
encouraged the company to integrate environmental
care into its decision-making processes in a manner
that is both cost effective and strategically advanta-
geous. For example, Beinn an Tuirc and Sappi Paper
Mill have both promoted approaches that have been
instrumental in gaining developmental consent and
positive stakeholder engagement.
Equally important is that EIA follow-up has re-
sulted in direct improvements to corporate and
project environmental management systems. As a
result, ScottishPower has benefited from improved
stakeholder interaction, an expansion in the knowl-
edge bases required for future development, ap-
proaches that can be replicated in future
developments and positive adjustments in staff and
contractor attitudes to the controlled management of
environmental impact.
In conclusion, it is evident that proactive
approaches to follow-up, practised through self-
regulated EMS frameworks can enhance the power
of EIA and contribute directly to proponent devel-
opmental success and corporate reputation.
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