Environmental assessment in forestry: the initial experience

Joctmal of Rural Studies, Vol. 7. No. 4, Printed in Great Britain

pp. 385-395,

1991

0743-0167/91$3.00 Pergamon

+ 0.00 Press

plc

Environmental Assessment in Forestry: the Initial Experience W. Neil Adger and Martin C. Whitby Countryside

Change Unit, University of Newcastle-upon-Tyne,

U.K.*

Abstract - This study analyses the effectiveness of the European Community’s Environmental Assessment Directive of 1985 in its application in the U.K. forestry sector. It assesses the applicability of the regulations in the provision of the public and private outputs of forestry. The environmental assessment regulation may contribute to the provision of the optimal amount of these public and private goods in theory, but it is concluded that, in common with initial results of the environmental assessment process in other sectors, the regulations do not make this contribution in practice in the forestry sector. The main deficiencies of the environmental statements examined were the failure to identify the significant potential impacts; to present alternative project sites and design features; and the erroneous measure of particular externalities. The environmental assessment process was also found to be unsatisfactory in the lack of public accessibility and consultation. The need for revision of the process in the forestry sector is highlighted.

The analysis

of environmental

direct regulation has been effective in the water resources sector in practice, and that the institutional factors are critical in this analysis. The designed objectives of the regulation will be affected by ‘who the losers are, what resources they command, how they react in response to their loss, and what access they have to policymakers (throughout the policy formulation and implementation system)’ ees, 1988). An economic framework for the (R optimal level of afforestation is developed, then environmental assessment in this sector is investigated to establish whether this regulation brings the sector closer to this optimising level of outputs.

regulation

The paper analyses the environmental regulation of Environmental Assessment (EA), introduced by the European Community in 1985 (Council of the European Communities, 198.5). The goals of environmental policy can be pursued through direct control, persuasion and education, the changing of the relevant property rights or through economic incentives such as tradeable permits or taxes and subsidies. Economists have investigated the efficiency of these diverse measures and there is some consensus as to the optimal efficient solution between the instruments, given assumptions about the nature of externalities and of the markets, and the rational economic behaviour of those producing the externalities (Baumol and Oates, 1988).

Environmental

and Social Research

The Directive states that for those development projects with likely significant environmental effects, information about these impacts must be provided by the developer and taken into account by

-__.. __~.__ Change Unit is funded Council.

in the U.K.

Environmental assessment is a procedure for assessing the environmental impacts of development projects or policies. The term now has a specific definition in the U.K. since the implementation of the EC’s Directive in 1985 (Council of the European Communities, 1985), making environmental assessment a requirement for certain types of development where ‘significant environmental effects’ are likely to occur.

the light of the control nature of the EA regulation, and the rationale for this type of regulation at the multi-national level, the effectiveness of the regulation is analysed. The effectiveness of the regulation reflects factors usually held exogenous in economic analysis. These factors, such as the context of the regulation within the existing development control framework or the cost of implementing the are given greater weight by some regulation, analysts. Rees (1988), for example, concludes that In

----_ *The Countryside

assessment

by the Economic

385

386

W. Neil Adger and Martin C. Whitby

the competent authority, ‘with a view to supplementing and coordinating deveiopment consent procedures governing public and private projects’ (Council of the European Communities, 1985). In the U.K. these decisions are taken by local planning authorities, in general, the regulations being incorporated into other members’ environmental policy in various sectors [see Wathern (1988) for survey of adoption by EC members]. The criteria for the likelihood of significant impacts were given in two schedules; Annex 1 listed those projects where an assessment would be obligatory; and Annex 2 defined projects where the significant impacts would not necessarily occur and an EA woutd be required at the discretion of the relevant national authorities. Annex 1 projects included those where a public inquiry in the U.K. would probably be required such as new nuclear generators, new motorways, new port developments over a particular size, and the disposal of nuclear waste. Annex 2 projects include small projects in the same categories as Annex 1 but falling beneath its threshold, as well as waste disposal operations, opencast mining, intensive agricultural activities, land drainage and forestry [see Council of the European Communities (1985) for a complete list of criteria].

Table 1. Rccommen~ations for information requirements in an environmental assessment under EC Directive --.-~.________._ -. 1. Description of the project l l l

Physical and land-use characteristics of the project Characteristics of the operational nature of the project Type and quantity of residues and emissions from the operation.

2. Project alternatives and justification for proposed choice 3. Description of the environment likely to be affected including the aster-refutjonship of any aspects. The aspects are: l l l l l

l

Population Fauna and flora Soil, water and air Climatic factors Material assets, archaeological heritage Landscape.

and

architectural

4. Description of the iikeiy effects on this environment of the implementatjo~ of the proposal due to: l

The existence of the project

l

The use of natural resources The emission of pollutants and creation

l

of nuisance.

5. Descriptjo~~ of the preve~tatjve or reductive measures proposed to be taken 6. Non-technical summary of the previous information

Table 1 is derived from Annex 3 of the EC Directive and shows the desirable attributes of an EA, though it is at the discretion of member states as to how much of this is required - ‘inasmuch as the Member States consider that the information is relevant to a given stage of the consent procedure and to the specific characteristics of a particular project’ (Council of the European Communities, 1985). The second requirement, that project alternative sites or project designs are to be elucidated and the proposed choice of site justified, may go beyond planning legislation demands, what national especially concerning Annex 1 projects. The emphasis of the impacts is on physical poIiuti~~n externalities of the public good type; those externalities which impinge on a large unspecified number of individuals in an economy and potentially have effects on society in other member states and areas outside national jurisdiction. These are the perceived environmental problems which require resolution at the European Community level - transboundary pollution externalities.

7. List of technicaf deficiencies or lack of know-how encountered in compifjng the ir~formution --_

(Adapted from Official Journal 198.5 Annex 3).

L175/40 EC Directive

pollution, recognises that the costs of producing agricuItura1 surpluses are mainly external to each country’s level of contribution to the Common Agricultural Policy. National policies to alleviate the agricultural externalities take the EC internal prices as the reference point; hence optimal national policy solutions will be of a second-best nature to the EC as a whole. Similarly, national environmental regulations for land using and other sectors, where the externalities have the potentia1 to be ‘exported’, will be set at a level to internalise only that part of the pollution confined to the national economy.

Such transboundary externalities arc air pollution leading to acid rain, and inland water or direct sea pollution leading to costs external to any one country’s jurisdiction. Dubgaard’s (1989) recom-

The EC EA Directive has the objective of preventive environmental management and has the potential advantage of being internationally enforced, hence reducing the problems of the member countries implementing environmental regulations unilaterally. Baumol and Oates’ (1988) analysis shows that income in a country imposing the unilateral regulation will fall, while the effect on its trade balance will depend on whether the good is exported or imported. The perception of falling

mendation for EC-wide regulation of input prices to reduce the negative externalities of agricufturul

income leads countries regulations unilaterally.

not to impose environmenta

Environmental

Assessment

The types of development listed in Annexes 1 and 2 of the Directive were already mainly subject to development control under the Town and Country Planning Act of 1971, so the responsibility for the EAs for those types of project not covered by existing planning legislation, such as major highagriculture and forestry projects, power ways, stations and overhead electricity lines, became the separate responsibility of the relevant central government ministry. The EC Directive was the first to influence the U.K. planning system directly (Haigh, 1987). It was enforced in the U.K. through Statutory Instruments incorporating it into existing planning legislation. One Statutory Instrument transferred the Annex 1 and Annex 2 projects of the Directive to national legislation while other Statutory Instruments deal specifically with Scotland, new highways, pipelines, salmon farming in marine waters and new afforestation. Seventeen separate pieces of legislation were required to implement the Directive across the various sectors [see Fortlage (1990) for a summary]. Local planning authorities became responsiblie for the implementation of the majority of EA regulations despite pressure to diminish the role of local authorities by a centralising government in the 1980s. The forestry sector, land drainage and salmon farming had their separate Statutory Instruments, the assessments for forestry being administered by the de fucro planning authority for that sector, the Forestry Commission. The number of assessments in the sectors coming under the town and country planning legislation, the forestry and agricultural legislation in the first two years of operation are given in Table 2. In the DOE Circular (Department of Environment, 1988), Schedule 2 is the interpretation of the EC’s Annex 2. A requirement to consider projects for assessment is explicitly given for some types of agricultural project - the first Table 2. U.K. Environmental

--_. .._.

Assessments 1988-March 1990 ._ __-..

Industrial/retail Power Waste disposal Transport Extracting/quarrying Leisure Settlement Forestry Agriculture/food industry Total

by sector: July

Number of EAs ..-.-. .--- --. 59 10 50 25 44 32 13 28 4

265 _-Source: Journal of Planning and Environmental Law (1989, 1990); Forestry Commission (1990b); Department of Environment (1990).

in Forestry

387

steps to the formalisation of land-use planning in an agricultural context. Thus for pig rearing installations with over 400 sows or 5000 fattening pigs, and salmon farms with 100 tonnes/year expected harvest, an EA is required, at the discretion of the competent authority. The determination of significance under similar federal legislation in the U.S.A. (National Environmental Policy Act of 1969), led to the greatest number of litigations, the definition in the legislation usually being vague. The determination of significance in the U.K. is the remit of the local planning authorities and is likely to cause controversy (Mertz, 1989). Discretionary assessments are required for the Schedule 2 projects under three particular circumstances: where they are of greater than local importance; where the project affects a particularly sensitive location such as a National Nature Reserve, a Site of Special Scientific Interest, a National Park, or an Area of Outstanding Natural Beauty; those projects with perceived unusually complex environmental effects (as determined by planning authorities) (Department of Environment, 1988). Examples of this type of decision can be seen in the forestry sector where half of the assessments have been initiated because the proposed areas partially encroached on a Site of Special Scientific Interest in wetland areas. No formal advice has been given on how significant effects are to be identified, but some guidance on the level of impact significance has been given by the Department of Environment and by contributions by interested parties in the process (Department of Environment, 1989; Nature Conservancy Council, 1991). EAs have been applied in the areas identified in Table 2 and various literature has focused on methodologies (Thompson, 1990; Bisset, 1987) and institutional arrangements involved in the implementation of the EC Directive in the U.K. (Haigh, 1987; Mertz, 1989; Ferguson and Ward, 1990; Wathern, 1988). This paper will focus on the EAs concerned with new afforestation, submitted to the Forestry Commission under that sector’s Statutory Instrument (SI 1207, 1988). Forestry is a sector with easily defined limits, where the environmental assessments identify the impacts over an extensive area with regard to marketed goods, and to nonmarketed goods which may be directly consumed by such as recreation, society, or whose existence confers benefit on society. EA and public goods from forestry The goods provided by the public and private, are jointly

forestry supplied

sector both in that new

388

W. Neil Adger and Martin C. Whitby

afforestation provides some or all of the following in proportions (which may or may not be fixed); timber, recreation, guaranteed employment, the fixing of carbon, the loss of wetland habitat, the loss of the carbon from this drainage and landscape effects. To this Iist may be added the prevention of soil erosion, diminution of water supply, effects on micro-climates and bio-diversity. Public goods have particular characteristics which determine their provision. These are now defined, and the effect of environmental regulation, such as environmental assessment, on goods with these characteristics is highlighted. Some of the outputs of forestry are pure public goods being both non-rival and non-excludable in consumption (Randall, 1987), while others may be regarded as having some public and some private good characteristics. In the case of a pure public good, the characteristics of nonexciudability and non-rivalness in consumption mean that the consumption of these goods can only be defined in terms of production or supply units. So the production of one unit of a pure pubfic good, say the existence value of one unit of habitat of a rare species protected, is not dependent on the location of that habitat within the society expressing the preference for its existence. The provision of goods with pure public characteristics and impure public goods, with only some of these characteristics (see Whitby, 1990) comes about through the joint supply of these goods with each other, and with private goods. For particular bundles of these goods, the mix between public and private is exogenously determined by the production technology and by legal and institutional factors. In forestry for example, a hectare of forest cannot be produced without, at the same time, having positive or negative effects on employment and landscape. The proportions of some of these goods will change through changing management practices and regulations in the forestry sector. Buchanan (1968) defines the provision of pure and impure public goods as those that are organised and supplied by public institutions, implying that political decisions reflect the demand for public goods, rather than the nature of the goods determining which of them should be supplied publicly. No conceivable public good is entirely ‘pure’ as they are not consumed in units of homogeneous quality. A change in regulations, causing a change in the mix between the public and private good outputs, is then equivalent to a movement along the supply curve for public goods, resulting in an increase in the total of environmental goods produced. If the countryside

public and private

goods are

supplied jointly, then what is the optimal mix of these goods? As already stated, forestry is a multioutput process with the proportions of the outputs less than permanently fixed in the long run. Optimality in the mix of the components of forestry output is shown in Fig. 1 and is determined by the market supply of the private goods and by the institutions and regulations determining the supply of public goods. The quantity of private goods provided by forestry Q pr increases along the horizontal axis, and the public goods provided by forestry Qpb on the vertical axis. If the output of forestry were purely private, production would take place somewhere along the horizontal axis but, given the joint supply of these, it is impossible to produce one unit of the private good bundle of forestry without at the same time producing some of the public good. The locus F as drawn shows a variable mix of Qpr and Qpb; the derivation of this optimal locus is given by the tangents of the iso-benefit (Zb) lines to the iso-cost (I,) curves.

F

Figure 1. Private and public good outputs from forestry. The iso-cost functions (ZJ are the standard shape indicating complementarity in joint supply of the different components of forestry output, which means for example that the unique forest recreation public good is most efficiently supplied jointly with the private outputs of forestry. Society’s indifference curves (1,) are convex implying diminishing marginal rates of substitution between the public and private outputs. Figure 2 shows the optimum level of production, given the existing mix from Fig. 1. A change in environmental regulations is postulated to reflect a change in demand for the public/private mix of the joint outputs of forestry and hence to a change in the optimum level of production. Once the optima1 mix of the public and private aspects of forestry production has been established, the level of output of these jointly supplied products is then determined by the familiar equi-marginal position of marginal costs and marginal benefits as represented in Fig. 2. The horizontal axis is the level of output along the

Environmental

0

Assessment

*

Qe' Qc

Figure 2. Levels of aggregate

Hecwcs

of

afforcstation afforestation.

optimal path determined in Fig. 1. Marginal costs and benefits are equal at the position where the distance between them is the greatest, and gives the optimum level of production Q,. The process of EA seeks to identify the public good aspects of forestry and therefore should bring about a change in the optimal mix of the public and private goods of new afforestation. The changing demand for the public good aspects of forestry such as amenity forestry and the avoidance of the public bad of environmental degradation will change the slope of the utility functions (lb) to their new level (I,,‘), altering the locus of the optimal mix of the private and public goods. The introduction of environsuch as the Environmental mental regulation, Assessment Directive and the increasing importance of environmental considerations in forestry policy (House of Commons, 1988) can be interpreted as part of the process leading to change in the relative marginal substitution between the two bundles of goods hence shifting the utility functions and the path of optimal mix (to F). This will change the total social costs and total social benefit (TC and TB) curves of the public expenditure on forestry in an indeterminate way. An upward shift of the social cost curve from TC to TC’ in Fig. 2 would represent the identification of greater potential social costs of new afforestation through an environmental assessment. The divergence of TC and TC’ at higher levels of production is dependent on potential project sites with least potential environmental impact being utilised first, as envisaged under an indicative forestry strategy, for example, consistent with the environmental duties of the - _._

.___

*The effect of all these changes may lead to a change in the level of new afforestation, as reflected in the drop in number of grant-aid applications from 5528 in the year to March 1989, to 4654 in 1990 (Forestry Commission, 1990a). In the same periods the area of new private planting (excluding that under the Farm Woodland Scheme) fell from 24,982 to 12,767 ha (Forestry Commission, 1991).

in Forestry

389

Forestry Commission under the 1985 Wildlife and Countryside (Amendment) Act. If this is not the case and production is evenly or randomly spread over areas with high and low potential degradation, then we would expect TC’ to be parallel to the TC throughout its length. The optimum level of expenditure would then remain at Q,, where the tangents to total costs and benefits would still have the same slope. It is assumed that the Forestry Commission does give weight to environmental objectives, the uptake of planting options is not randomly distributed, and hence TC and TC’ will diverge from each other. The identification of TC’ through EA leads to the equi-marginal level of production of the joint outputs of forestry being lower at Q,‘. The benefits curve may also shift due to environmental enhancement but this further complication is not represented here. The extent of the shift in the TC curve, and hence the optimum level of forestry production, depends on establishing what constitutes an unacceptable level of potential environmental degradation. Other factors reflecting the changing demand for the public goods provided by forestry may be changes in tax and grant incentives for new afforestation which initially spurred the private forestry sector (Bateman and Mellor, 1990).* In practice, the actual level of afforestation may be beyond the optimum level Q,’ due to rent-seeking behaviour of the institutions involved. The above analysis does not determine the actual level of production as it treats government as exogenous to the public decision on the allocation and size of public expenditure [an assumption discussed in Rees (1988) and Adger and Whitby (1990)]. This may be illustrated by the fact that the forestry regulations deal only with grant and loan assisted forestry, so that if the Forestry Commission is not involved in the financing of the proposed afforestation, no environmental assessment is required. Similarly, new afforestation undertaken by the Forestry Commission itself is not subject to the EA regulations. As stated previously the extent to which EA affects the amount of new afforestation depends on the efficacy of the assessments in the identification and amelioration of impacts; the level at which significant environmental impacts are judged to have occurred; and the institutional setting of the regulations. The following section investigates the first of these in the light of experience of the first two years of implementation of the EA regulations. An appraisal

of EA in the forestry sector

The Forestry Commission introduced the requirements of the EA legislation to potential grant

W. Neil Adger and Martin C. Whitby

390

applicants with an explanatory leaflet (Forestry Commission, 1988). In the period to May 1991 there have been 42 proposals where an EA has been deemed necessary by the Forestry Commission due to potentially significant environmental effects. The information summarised in Table 3 shows the reasons for the EA requirement and those where a decision has been taken to date. There has been much concern over the loss of wetland areas in Caithness and Sutherland region of Scotland (Nature Conservancy Council, 1987) and 11 of the assessments directly affected loss of wetiand habitat in this area. Another 11 assessments were required for projects affecting Sites of Speciai Scientific Interest outside Caithness and Sutherland, designated to protect habitat or geological sites. Those projects not specifically regarded as affecting wildlife or habitat were predominantly large-scale afforestations, some within National Scenic Areas in Scotland or within Environmentally Sensitive Areas. The most important expected effect in these areas was on landscape; ‘much in the public eye’ being declared as the reason for an assessment being required in several cases. Of these 42 cases only 17 have completed the environmental assessment process with a decision having been taken on whether the projects qualify for grant under the Woodland Grant Scheme. Eleven accessible cases were analysed under a set of general criteria for the appraisal of EA methodology, developed by Thompson (1990). The 11 environmental statements however, all use the same checklist approach to impact identification, but the criteria capture the important criticism of the environmental statements investigated. Further comments on the erroneous magnitude of the impacts identified (particularly regarding the net employ-

Table

Reason

3.

Forestry Environmental ---

for requirement

--.-. _“..Caithness and Sutherland

1 1 1

Other

2 -_..

Notes: I. Land-use designations

.- ..---

5

3

of

The basis for the assessment of the environmental statements chosen here is adopted from Thompson’s (1990) criteria for the appraisal of EA methodologies. The chosen criteria are: 1. whether a distinction is made between significance and magnitude; 3_. whether the trade-offs between various impacts are explicitly presented; 3. whether provision for lower impact alternatives are encouraged during the assessment; 4. whether the public affected by these impacts are directly consulted at the assessment stage. These ments

criteria are now applied to the assesscarried out in the forestry sector to evaluate

the effectiveness practice.

reasons for rcquircment

_ _.. _ ._ ._~__ I 2 -

properties

Thompson (1990) points out that it is crucial for an EA to distinguish between impact magnitude and impact significance in the environmental statement if it is to fulfil its function as a decision-making tool. His study classifies 24 methodologies by their approaches to determining significance. Techniques include those seeking the advice of a panel of experts giving quantitative weights to environmental and social potential impacts (Solomon er al., 1977), and others make no attempt to indicate the relative significance of impacts. The most effective methodologies, given Thompson’s (1990) criteria, are those which aggregate their quantitative data under separate headings to identify trade-offs, say between ecological and social impacts; and favour the incorporation of public opinion.

Decision after consultation -... Withdrawn Approved Refused

Other SSSI NSA or ESA

Total decisions ..~__. -

Assessments:

ment and carbon sequestration afforestation) are then made.

. _.-

of

the

EA

regulations

and decision: July 1988-May

Decision

---

awaited

in

1991 -__-

Total (category) -.“-

2

7

11

4

4

11

2 I

7

10

7

10

9

25

42

..-_..

--

frequently overlap. Some EAs were required in more than one of the above categories. In these, the case is counted in the main category. 2. Caithness and Sutherland proposed afforestation projects may have fallen within designated Sites of Special Scientific Interest, but arc under this general category because of the highly controversial nature of development in this region. 3. The Other category tends to refer to potential landscape impacts of the proposals. 4. In three cases, the impetus for the withdrawal of proposals came from the Forestry Commission, which may be regarded as a refusal. 5. Approved also includes cases which were approved only in part after consultation.

Environmental

Assessment in Forestry

Significance of impacts and trade-offs

Following the Forestry Commission IeafIet explaining what is required in an EA of afforestation 2988), all environmental (Forestry Commission, statements (the product of the EA process, used at the decision-making stage) in this sector to date have followed a checklist approach, describing the physical details of the project and identifying, if only descriptively, the likely impact of the project on each of the categories given in paragraph 3 of Table 1. The greatest single failing of the forestry environmental statements, from the four criteria, is in the absence of indication of which of the environmental impacts are significant in the context of the locality. The assessment process may have been initiated because of the location of the project in a wetland area, or in a scenic area, but this is rarely the focus of the environmental statements in these areas because of the implicitly equal weighting given to each category of potential impact. The only attempt to show ‘the inter-relationship between the . . . factors’ (Council of the European Communities, 1985) in many of the environmental statements is through a simple impact matrix. Leopold et al. (1971) emphasise that the reason for each score in a cell in a matrix be explicitly stated and that each cell should be scored both for the size of the expected impact, and for its significance. The impact matrices used to date in afforestation environmental statements indicate a positive, negative or zero score (f , - or 0) for each category of impact, then derive the secondary effects on each other category. Only occasionally are these direct effects quantified and the secondary effects are rarely justified. Thus from one environmental statement (Bell Ingram, 1990), an unquantified direct positive benefit to the global climate from afforestation has positive secondary effects on soils, agriculture, forestry, blanket bog, wetland, drains, vegetation, animals, birds, fish and insects; negative secondary effects to recreation; and neutral to landscape, peat cutting, fields, access and employment. This gives I1 positive effects, 1 negative effect and 5 neutrals, none of which is justified. Such a list clearly cannot be meaningfully aggregated to a total net impact. These interaction matrices do, however, conform to an extent to Thompson’s (1990) criterion of showing the aggregated effects in each of the categories of impacts set out in Table 1. Akmarive

project design

Although the consultation procedures take place at the design stage of an assessment, the application for a planting grant under the Woodland Grant Scheme

391

will have already been submitted, so the possibility of alternative sites for the proposed afforestation, the third criterion, is not applicable in this case. No alternative sites are considered in any of the 11 environmental statements, so the only decision to be taken is whether the project proceeds or not, In two cases the consultations involved with the statutory consultees have led to the size of the project being altered to alleviate potential impacts, the resulting proposals being accepted for grant aid in the revised form. The original perceived contribution of EA as an aid to environmental management, on the grounds that ‘the best environmental policy consists in preventing the creation of pollution or nuisances at source’ (Council of the European Communities, 1985), therefore seems in the case of forestry to have been severely limited, due to lack of alternatives in design and location of the projects. This failure ultimately stems from the fact that proposed developments originate in the private sector which has appraised the project for financial viability and therefore will only consider modifications to bring the project within declared standards. Public participation

The fourth criterion for an effective environmental assessment is public participation in the assessment, as the significance of an environmental impact is essentially an expression of the external costs it imposes on society. In the forestry sector standard procedures exist for consultation with appropriate bodies in any application for planting grants or felling licenses (Forestry Commission, 1990a) outside the forestry sector’s EA regulations. The Nature Conservancy Council and the Countryside Commissions are statutory consultees under the EA regulations and as such should be consulted during the preparation of the environmental statement. Thompson (1990) accepts that public consultation is difficult to integrate into decision-making, but regards it as necessary to achieve balance between the opinion of public consultees and the demand by the economy for the public and private goods forestry provides. Environmental agencies have a positive preference for direct environmental regulation which leads to greater involvement in determining methods and significance, also partially due to their mistrust of the effectiveness of other environmental policy instruments, such as incentives and taxes (Shortle and Abler, 1991). There are particular problems in public participation exercises in rural areas (Shucksmith et al., 1985), but the procedures for environmental statements to be readily available to the public, at a reasonable cost, have clearly not been carried out. Indeed the

W. Neil Adger

392 authors have these studies. Erroneous

found

serious

problems

of access

and *Martin C. Whitby to

measures of net impacts

Additional to the deficiencies in the environmental statements examined are the incorrectly measured magnitudes of many potential impacts. The measurement of two of these potentially positive impacts of forestry are analysed in more detail. These are the effects of forestry on rural employment, and on the global climate through the carbon sequestration properties of timber. Although much is made of the objective of forestry policy of rural employment generation, there is confusion between gross levels of employment in forests and net levels. The figures given in Table 4, from the Forestry Commission (undated), show the average level of employment from forestry per 1000 ha, and from alternative uses. The net employment from afforestation, given the average figures, is the difference between the forestry use and the alternative use, say upland sheep farming. In many environmental statements this is ignored, though the existing levels of employment on some of the wetland sites may be very low. Thus if land was being transferred from a hill sheep farm to forest planting it would be appropriate to deduct 1.3 jobs from the total generated in forestry, given the figures in Table 4. Table 4. Labour

requirements

Use

of alternative Employment

Forestry Commission

per 1000 ha ._ 8.7 1.3 28.4

Forestry Hill farm Dairy Upland mixed farm Source:

land uses

7.5 (undated).

The Forestry Commission estimates of the average levels of employment from afforestation may be disputed due to the phasing of the forest employment and the assumed rate of labour productivity growth in forestry. For example, from the employment factors for the North of England collected from Commission forests by Laxton and Whitby (1986), a 40 year rotation of unthinned, Yield Class 12, sitka spruce would require 59 work years for the whole period. The annual average for the whole period would therefore be 1.5, only marginally greater than average employment on hill sheep farms in Scotland. However, in this example 82% of the employment occurs at felling, in year 40. Any labour productivity improvements in forestry will detract further from

the jobs gained through afforestation. If productivity in the felling operation grew by only 1% per year this would eliminate more than one quarter of the employment in the whole rotation, reducing the average employment to below that for current hill sheep farming. The forest employment under a regime including thinning (and therefore involving later final felling) would be greater, but losses due to harvesting productivity might easily offset this gain. Similarly increases in labour productivity in sheep farming would reduce the employment losses resulting from land conversion to forestry. Trends suggest that labour productivity has historically increased at a greater rate in forestry than in hill farming (Laxton and Whitby, 1986). Thus, although the average levels of employment achieved from the cross-sectional data in Table 4 suggest that forestry employment is substantial, those averages do not apply to new planting for the two reasons given. Accordingly, incorporating such average levels into an evaluation of employment for an environmental assessment of new planting simply serves to mislead. Under the ‘climate’ category, few of the environmental statements evaluated the effects of afforestation on the micro-climate, but concentrated on the potential beneficial effects of carbon fixing in new growth trees on the global environment, taking current concern over the greenhouse effect as the rationale. The importance of global effects in forestry policy has been highlighted by Rollinson (1990): the increasing role of forests reducing carbon dioxide levels house effect . . seems likely prominent role in determining

as a potential means of to counteract the greento play an increasingly

future forestry policy.

The storage of carbon per hectare figures in all those statements where this was quantified used Thompson and Matthews’ (1989) estimates of the carbon stored by various species when the carbon equilibrium position is reached. This equilibrium does not occur for over a century for all species grown in the U.K. and the total carbon stored per hectare includes the carbon stored in the timber products, as the coniferous species will be in their third rotation before equilibrium occurs. Those statements which report 70-100 tC/ha as being the carbon sequestration characteristic for the particular projects fail to mention the dynamic nature of the underlying assumptions. These include that the particular area will be harvested for a number of rotations, and the end use of the timber products will have a similar carbon release profile for the next century. Again

the

net effects

of afforestation

on carbon

Environmental

Assessment

sequestration are ignored, as it is the changing land use that results in a change in carbon sequestration. Research in Finland (Silvola, 1986) suggests that under the prevalent climatic and ecological conditions, drainage of wetland results in a net export of carbon. In other soil types, initial cultivation will lead to the loss of soil carbon, but in the following century, the soil carbon content may increase, depending on a variety of factors (Jenkinson, 1988). There remains much debate as to the costs and benefits of global climatic change, and whether afforestation is a cost-effective means of reducing total atmospheric carbon-dioxide. The requirement for a detailed analysis of the carbon fixing potential of afforestation may be beyond the scope of an environmental assessment for a single project; whether the impact of new afforestation is significant relative to the other identified environmental impacts is indeterminate. Summary of afforestation environmental statements From the 11 cases where environmental assessment has been carried out in the forestry sector it is clear that few of the criteria for an effective assessment are met by most of the assessments, and the quality would generally be said to be unsatisfactory, especially in the identification and evaluation of the relevant potential impacts. Despite this, only one project has been refused a grant under the Woodland Grant Scheme, five being approved and five still awaiting a decision. In two of these cases the assessments did, however, lead to the redefining of the scale of the project to ameliorate potential environmental consequences. In four cases the application for grant was withdrawn without an assessment being carried out, though for unknown reasons. It could be that these were projects with potentially large and obviously significant environmental effects, or that the resource cost in undertaking EA made the project unattractive. Although environmental assessments in forestry are concerned with externalities over an extensive area, the financial investment involved in private afforestation is relatively small (a net present value of around f35,OOO for the modal proposed project in the 11 cases). The resource cost of producing an environmental statement in terms of expense and rescheduling through delays in planting, may then increase the capital costs of the project to ensure that, at the margin, resources are allocated more efficiently. The cost of preparing an environmental statement will also lead developers to commit least possible resources to the identification of the potential impacts, consistent with securing grant. The

general

conclusions

above

resonate

with

Lee

in Forestry

393

and Colley’s (1990) study of 12 cases across different sectors where an EA had been required. Their results show only three of the 12 cases achieving an overall assessment of satisfactory, the remainder ranging from failing in some major element to being very unsatisfactory.

Conclusion

The analysis of environmental regulation reflecting society’s demand for particular public goods strongly suggests that the optimal mix of public and private goods from forestry may have been changing. Whether the Environmental Assessment regulations have been effective in changing the actual mix in the short time since their introduction remains indeterminate at present. The process of environmental assessment may deter some developers of projects with potentially significant environmental impacts from application to the Woodland Grant Scheme, though this is difficult to determine. Other outcomes at the decision stage may be the rejection of the project or the invitation to revise the specification of the proposal. This is the postulated reduction in the aggregate level of afforestation Q,’ in Fig. 2. The relative contributions of the EA regulations and changes in financial incentives to private forestry, to the reduction in the numbers of applications for grants since 1988 is not known. The EA regulations will not bring about this change in aggregate levels of afforestation, or in the redesign of these proposals if the process does not work in practice. In the two years since implementation there have been many more EAs than originally predicted (Ferguson and Ward, 1990), but the experience from forestry suggests that the regulation in its present form is by no means a panacea for environmental management. The environmental statements in forestry reviewed here are criticised fundamentally for not correctly identifying the significant likely impacts; for not duly recognising potential alternative sites and project designs; and for excluding the public from the decision-making process and consultation. Thus the original perceived role of EA as an aid to environmental management seems so far not to have been realised in the case of forestry. Whilst the environmental assessments carried out for new forest planting have been found to be technically insubstantial, the criticisms above are offered in recognition of the potential contribution of EA to environmental improvement. Assessments may contribute by directing the developer’s attention to important issues at an early stage in the design of plantations. They may also deter some environmentally or economically unsound invest-

394

W. Neil Adger and Martin

ments among the projects withdrawn when an EA is required. Design improvements may result from the more likely consultation between developers and those with an interest in and respect for other aspects of the environment. In their present form, the regulations oblige developers to undertake and bear the cost of the assessment and encouraging them to present inadequate assessments with the sole objective of gaining development permission or funding. Improvements in the EA process may therefore require a radical revision of Forestry Commission pro-

cedures to make developers responsible for the amelioration of environmental impacts as determined by an independent agency and a more visibly independent process of scrutiny.

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