Problems and issues in the implementation of EIA audits

Problems and Issues in the Implementation of EIA Audits E r

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Ronald Bisset Ronald Bisset is Research Fellow with the Project Appraisal for Development Control (PADC), Department o f Geography, University of Aberdeen, Aberdeen, Scotland. lie has been workbzg bz EIA for six years and is at present undertaking research on auditing, hz the summer of 1980, he traveled througl, out the United States seeking bzformation on projects that had been audited after completion to test the accuracy of impact predictions made during the planning stages. This article grew out o f that trip.

Since 1970 when the U.S. National Environmental Policy Act became law, thc concept of EIA has spread to many countries. Today there is growing interest in assessing tile effectiveness of existing and proposed E n v i r o n m e n t e l l~pact Assessment Flev[ew, V. 1, N, 4

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A procedures. Most o f the literature on the effectiveness of EIA ficates that tbree aspects of EIA procedures can be assessed. First, e effectiveness of EIA procedures can be considered in terms of their ility in local, regional, and national political processes that are engenred by development projects (Friesema and Culhane 1976). Questions dressed by commentators considering this aspect of EIA concern e role of EIA documents in decision making. For example, Have A documents facilitated decision making by stating objectives and ,tential impacts of a proposed project? Do they clarify opposition and pport for a proposal by acting as focal points for public involvement d discussion in project planning? Generally, those considering this pect of EIA are concerned with tile value of EIA in opening up :cision making and allowing a wider role for the public. In addition to the "political" efficacy o f EIA, assessments f its utility can be made in terms o f the actual decisions made and aplemented. Do EIAs render decisions that reflect more environrental sensitivity than decisions made on proposals for which EIAs ere not carried out? This type o f assessment is extremely difficult ecause there can be no comparison o f EIA procedures with the "noIA" state of affairs. However, examination of the environmental. enefits accruing from EIA procedures have been made" (Council on nvironmental Quality 1976; U.S. Environmental Protection Agency 980). Finally, EIA proccdurcs can be evaluatcd in tcrms o f the :curacy o f predictions made in EIA documcnts. The contents o f ~ch documcnts, oftcn known as environmental impact statcments miSs), are concerned with predictions of likely impacts and identifiation of mitigating actions rcquircd. These prcdictions providc onc of le information bases upon which dccisions on projects are made, but nfortunately this aspect o f thc utility of EIA has receivcd virtually o attcntion in EIA literature. Thcre are a n u m b c r o f reasons for thc rclativc lack of attention aid to thc validity and accuracy of EIA prcdictions. In tile main, EIAs ave comc to bc considcrcd a proccdural rcquircmcnt to bc carricd out uring project planning. Once a decision is made about a projcct, plancrs, dccision makcrs, and intercstcd mcmbers o f thc public tcnd to lift thcir attention to ncw projects. There has been littlc interest in thc rolc o f EIA in projcct and nvir0nmcntal managemcnt by means o f monitoring schemes and fcedack of monitoring data (Holling 1978). Howcvcr, thcrc is cvidence suggcst that this comprehensive view of thc possibilitics offered by ',IA is becoming apparcnt to those involvcd in EIA in many countries. 'or instancc, thc Commission o f tile European Communitics rcquircs a its proposcd EIA directive that thc " c o m p c t c n t authority" check ~hcther "provisions to protcct the environment [contained in an EIS] xc bcing obeycd and whether it needs to take furthcr mcasurcs to ,rotcct thc environmcnt from thc cffccts o f the project" (Environment "80 EIA REVIEW 114

and Consumer Protection Division 1980). This requirement stresses monitoring to ensure that mitigating measures are implemented and to discover any impacts that were not predicted. This is not a direct assessment of the accuracy of the EIA's initial predictions, but it begins to address the need to integrate EIA throughout the planning, development, and operation phases of a project. While some individuals in agencies and other organizations involved in day-to-day EIA matters are aware of the value of testing their predictions to improve future EISs, they have been unable to get either the money or time to develop audits. Despite these attitudinal and institutional barriers, some work in this field has been carried out in the United States, and it provides a place to start considering some of theproblems involved with audits. PROJECT MONITORING AND AUDITING IN THE UNITED STATES Between 1970 and 1979, the attention given to project monitoring as a part of the EIA process was limited. NEPA implied and Executive Order 11514 required "that monitoring be done by federal agencies to help ensure that planned mitigation measures are in fact carried out once a project begins" (Council on Environmental Quality 1976). However, the Council on Environmental Quality (CEQ) acknowledged at the time that despite this official backing for monitoring little attention was being paid to this aspect of EIA. A notable exception was the monitoring of mitigating actions undertaken for the Navajo generating station by the Bureau of Reclamation of the U.S. Department of the Interior (1974). In 1977, President Carter issued Executive Order 1191 giving CEQ the task of reforming EIA procedures to cut down paperwork, reduce delays, and improve the utility of EISs (Executive Office of the President 1977). In accordance with this mandate, CEQ issued regulations, which became effective in July 1979, and unlike earlier CEQ guidelines, are binding on federal agencies (Council on Environmental Quality 1978). The new regulations addressed the issue of project monitoring in more detail. Agencies that have produced EISs are required now to issue a "record of decision" containing an account of the factors considered in reaching a decision on the future of a proposed project. It must specify the alternatives considered, identify the environmentally preferable option, and explain the factors determining a decision, especially if the chosen option were not the environmentally preferred alternative. The "record of decision," furthermore, "must state whether all practical means of mitigating or preventing environmental harm have been adopted and if not, why not." To ensure that preventive/mitigating measures are introduced, agencies must monitor projects (Council on Environmental Quality 1979). Although "records of decision" EIA REVIEW 1/4

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have only been produced since 1979, statements made regarding mitigating action and monitoring seem likely to be implemented. Evidence is sparse, but judgments in recent legal cases arising from instances where mitigating actions failed to meet promised objectives have resulted in injunctions preventing continued project work until the objectives are satisfied. This experience ~611 undoubtedly encourage agencies to monitor their performance in mitigating or preventing impacts. With the prospect that monitoring will be carried out increasingly, it is important to begin considering the nature of different monitoring schemes and the information that can be obtained. At present in the United States, federal requirements for project monitoring relate to EIA only insofar as the monitoring is carried out to check that mitigating measures are implemented and that certain criteria for assessing the performance of these measures are met. There are no requirements for monitoring to perform audits and to improve the quality of future EISs. However, this situation has not precluded some audits being undertaken to test environmental predictions made in EISs.

Tile Barstow-Las

Vegas Motorcycle Race

One o f tile first attempts to carry out a comprehensive audit was undertaken by the Bureau of Land Management, U. S. Department of the Interior (1975). In 1973174 the bureau prepared an EIS of a politically controversial "off-road" motorcycle race, advertised as the world's largest, from Barstow in California to Las Vegas in Nevada. The course for the race traversed approximately 155 miles of desert terrain and, of these, 132 miles were located on National Resource Lands administered b y the bureau. As a result o f the widespread contention over the race, the bureau carried out an audit o f tile 1974 race that had two basic objectives: (1) to determine the degree to which the race organizers complied with mitigation measures derived from the EIS and stipulated in the race permit, and (2) to identify and measure environmental changes caused by the race. The bureau considered that such information was necessary before making decisions on the future of the race. The study used baseline data collected before tile race, monitoring data obtained during the race and special studies carried out afterwards. Monitoring for mitigation compliance took the form o f bureau staff checking oll the implementation of mitigating measures and their effectiveness. Various points along the route had been identified in the EIS for monitoring mitigation compliance, and personnel were stationed accordingly. Basically, this monitoring scheme was based on t h e subjective observations of agency personnel. In contrast, monitoring for impacts was carried out by more objective means including Environmental Sampling Photo (ESP) plots, aerial photography, soil sampling, wildlife trapping, air quality monitoring and participant/ spectator surveys. Soil changes, vegetation changes, wildlife changes, air quality effects, effects on cultural resources (archaeological and his382 EIA REVIEW 1]4

torical sites) and surface impact (extent of area affected b y race) were evaluated. Compared with most projects for which EISs are prepared (for example, highways, water developments, and industrial facilities), monitoring a one-day motorcycle race is relatively straightforward. The period for monitoring data acquisition is considerably shorter and thus less expensive, and the interpretation of data is also simplified. Nevertheless, the work carried out to audit the race exemplifies many o f the problems encountered whenever an attempt is made to analyse the effects of a development action and compare it with preoperational predictions. The studies for vegetation damage did not involve control monitoring to enable comparisons to be made between unaffected and affected sites. In this instance, it was unimportant as vegetation damage could be seen from the examination o f the same plots before and after the race. The monitoring of wildlife disturbance was implemented in a time-constrained fashion without control sites. An immediate prerace sample at two sites (later amalgamated as one site) was not sufficient to determine whether the numbers o f animals trapped were a reasonable guide to population numbers prior to tile race. In addition, the " b e f o r e " and "after" comparisons were not made at enough sites to give a useful indication o f disturbance and damage to wildlife. These monitoring studies were only directed at determining immediate consequences.

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One of tile first comprehensive audits was conducted by the Bureau of Land Management during the 1974 BarstowLas Vegas Motorcycle Race, which crossed 155 miles of desert terrain.

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Long-term effects, including irreversibility of damaged sites and wildlife numbers, could not be determined as there was no control monitoring at unaffected sites and also no long-term monitoring data at affected locations. The bureau realized the deficiences in their study and initiated longer-term monitoring to research these aspects. However, based on its immediate evaluation, tile bureau decided to refuse a subsequent permit application from tlle race sponsors. Impacts on air qu,-flity, cultural resources, soil characteristics, and land surface effects could all be determined adequately from tile monitoring schemes implemented. The air quality predictions in the EIS were confirmed insofar as California and Nevada air quality standards for suspended particulates were exceeded after the race. The EIS indicated that 590 tons o f particulates would be generated b y the race, which turned out to be an underestimation. However, the EIS overestimated the concentration levels. In contrast, the prediction that gaseous pollutants would be relatively insignificant was verified. The extent of the surface area affected b y the race course turned out to be greater, by a factor o f 31 percent, than predicted in the EIS. This resulted, in part, from an event which was unforeseen when the EIS was prepared. In past races, a large column o f smoke from 50 to 100 burning tires was used to direct racers to the beginning o f the marked course, but the San Bernardino County Air Pollution Control authorities would not grant a permit for this procedure in 1974. Therefore, six white smoke cannisters were used to mark the course. Unfortunately, the white smoke was not Visible to the first Wave o f racers, and they went outside the designated course, which increased the area affected. Not all environmental impacts predicted in the EIS could be asscsscd by amdysis o f monitoring data, and those that could were fotmd to be inaccurate to varying degrees. This applied, also, to the recreation effects predicted. Whether or not this general finding is applicable to other EISs can be ascertained only by examination of other audits. Other Audits There have been a nnmber o f other studies carried out in the United States to identify and examine environmental and social impacts arising from operational projects and, in some cases, to compare these impacts with those predicted in EISs. Tile U. S. Army Corps of Engineers has implemented an extensive audit concentrating on the regional socioeconomic impacts of tile McClellan-Kerr waterway in Arkansas. While there was no EIS for this project, predictions o f its likely effects had been made, and the audit has sbown tile socioeconomic benefits to be greater than expected. However, it is interesting to note that the mix of benefits is different from that used to justify the project.* It is more *James R. Hanchey 1980: personal communication. 384 EIA REVIEW 1/4

difficult to determine the accuracy of the environmental predictions because of incomplete information, though it is hoped that further information will be obtained in the near future. The U.S. Soil Conservation Service has sponsored an audit of the Horse Range Swamp Channelization Project in Georgia. The results are being used to develop a model to aid assessment of similar projects in the future. This study cost approximately $300,000 at 1977 prices and appears to have taken two to three years to complete.* Finally, in addition to the previously mentioned audit of the U. S. Department of the Interior for the Navajo generating station (1974), audits have been undertaken by Professor Rabel Burdge and his team at the University of Illinois, Champaign-Urbana, for the Lake Shelbyville project, and by the Institute for Environmental Studies, of the University of Wisconsin, for a coal-fired power station (1976). Apart from the studies mentioned above, there have been a series of studies concerned mainly with the aquatic effects of nuclear power plants. These studies have brought to light many of the prob, lems encountered in carrying out audits and have also indicated certain recommendations pertinent to the implementation of monitoring schemes and audits. Consequently, it is worth considering these studies, known as the Tech Specs studies, in some detail. Tile Tech Specs Studies Although it has been suggested that prior to the new CEQ regulations little attention was paid to monitoring, the U. S. Nuclear Regulatory Commission (NRC) was a notable exception. NRC required electric utilities operating nuclear power plants to conduct certain monitoring programs. Tile requirements were written into operating licences issued by NRC. These requirements were known as Environmental Technical Specifications, or Tech Specs, and encompassed ecological (aquatic ,and terrestrial), chemical, and hydrothermal monitoring. Tech Specs also include limits on the operation of plants. For example, at one site the Tech Spccs limited the quantities of corrosion inhibitors to be used and also the number of fish killed from impingement at cooling water intake screens (Muraka et al. 1976a). NRC sponsored research to assess the suitability of such limits and to determine the environmental impacts of operating Plants. Twelve nuclear plants were examined by research teams at Argonne National Laboratory, Battelle Pacific Northwest Laboratory, and Oak Ridge National Laboratory. The audits focused on aquatic effects of plant operation; little attention was paid to terrestrial effects or to prediction of noise and air pollutant levels and radiological effects. In many cases this resulted from omission o f such impacts in the Final Environmental Statements (FESs). Those Tech Specs monitoring programs that did cover terrestrial ecosystems usually lacked monitoring data with sensitivity to detect * Gary Margsheim 1980: personal communication. EIA REVIEW 1/4 385

langes in vegetation and animal populations (Muraka et al. 1976a). An :count is given below of the audits carried out by Argonne National tboratory for Prairie Island, Zion, and Kewaunee power plants ,Iurarka et al. 1976b) accompanied where appropriate with the sults of studies undertaken by the other laboratories. The audits trried out for aquatic ecological effects, characteristics of thermal umes, and chemical discharges will be considered in turn. quatic ecological effects ae audits of aquatic ecological impacts tried to determine actual apacts on phytoplankton, zooplankton, and fish of entrainment and 9apingement, and the consequences of thermal plumes on these biotic oups, and also on rotifers and benthos. In addition, information on apacts was compared with predictions made in the relevant FESs. The statistical analysis of monitoring data took the form of a :neral linear model approach (variance components). In this type of lalysis it is assumed that the effects of power plant operation are fixed, of constant but unknown magnitude, and equal for all stressed ,cations" (Murarka ct al. 1976a). Tile data analyzed covered one prcperational year and two postoperational years usually. For all three iants, tile FESs predicted that there would be effects on all biotic roups, but that these would bc minimal and unimportant. Analysis of le monitoring data showed that there was no evidence of signficant fleets of plant operation on the different biotic groups. However, it is tressed by Murarka et al. that analysis of the monitoring data did not eally prove anything apart from tile fact that no impacts were detected r the frame of tile available monitoring data and the statistical nalysis carried out. It was realized that long-term impacts could be ,ccurring, but appropriate monitoring data were lacking. For all three plants, problems involving lack of preoperational data and changes in nonitoring programs and sampling procedures made it difficult, if not mpossible, to detect man-made impacts and natural biological fluctuaions. Despite these flaws in tlle study and the interpretix;e limitations vhich must be placed on the conclusions, Murarka et al. are satisfied hat FES predictions for aquatic ecological effects were accurate. Similar results were derived from tile analyses carries out by he Oak Ridge National Laboratory and Battelle Pacific Northwest Laboratory. For example, in their analysis of three plants, Battelle ;taft could not attribute directly any changes in biotic communities :o plant operations, and this finding agreed with impact predictions ,-nadc prior to operation. However, Gore, Thomas, and Watson (1979) Joint out that several changes were qualitatively identified, b u t could lot be statistically validated, and in a few cases, statistically significant impacts were identified, but the influence of nonpower plant factors could n o t be ruled out. Despite this it is thought that significant impacts attributable to the plants would have bccn detected had they occurred. 386 EIA REVIEW 1/4

The Oak Ridge studies showed similar results. However, for one plant, impact monitoring data indicated that an FES prediction was inaccurate. It had been thought that fish catches would decline in the thermal plume caused by a particular station in summer because the fish would avoid an area of thermal stress. In fact, catch per unit effort in the thermal plume was higher in summer than in winter (Cunningham, Adams, and Kumar 1976). Thermal plume characteristics In this section the results of audits carried out by Argonne National Laboratory will be discussed. Audits were carried out for tile QuadCities, Kewaunee, and Zion power plants (Mariner and Policastro, undated). In the environmental assessments carried out for these plants, the utilities used the Pritchard analytical model for Zion and Kewaunee, and a hydraulic model for Quad-Cities to predict size, shape and temperature characteristics of a thermal plume. All predictions made indicated a wide range of plume characteristics due to environmental variability at the sites. Analysis of monitoring datacovering two operational years indicated that the predictions from the hydraulic model used for Quad-Cities were generally accurate. However, predictions covering tlae critical period of low water flow could not be tested. Tile predictions of the Pritchard model at Kewaunee were inaccurate in a number of respects. All plumes were directional (northward, lakeward or southward) depending on climatic and other environmental factors affecting

Quad-Cities, located on the Mississippi River, was one of the nuclear power plants audited to determine the accuracy of preoperational predictions of thermal plume characteristics.

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le receiving water of Lake Michigan. Monitoring data showed that the lree plume types were wider, shallower, and hotter than predicted. he monitoring data were not ideal, and winter plumes were not condered. Predictions using the Pritchard model for the Zion plant were greatly optimistic" (Marmer and Policastro, undated). It was found aat this model gave satisfactory forecasts for only 20 percent of the ases and only under certain conditions, for example, plumes resulting tom operation o f a single unit (discharge) and where the ambient cur_~nt in the receiving water is unidirectional for a long period with no _~circulaton or re-entrainment of heated water. When such conditions r e not met the predictions may be out by one order of magnitude. ,larmer and Policastro conclude that preoperational predictive modelag for Kewaunee and Zion was "rather poor." The models used were oo idealized and did not take account o f localized environmental con[itions. For example, the model used at Kewaunee ignored the effects ,f certain features of both lakeshore and b o t t o m topography. The nodel used for Zion incorporated an error in design estimates for the ize o f the discharge orifice and also made simplistic assumptions for c)cal current behaviour. In contrast the preoperational hydraulic modelng for Quad-Cities appeared to be "quite satisfactory." From this imited comparative study it would appear that hydraulic modeling is o be preferred to analytic modeling. However, more cases would have o be examined to enable this tentative conclusion to b e supported. 2hemical discharges Xmalysis of monitoring data relating to chemical discharges has verified ~redicitons made. It has been found that discharges of chlorine and leavy metals with certain organic compounds such as phenol, chlorinlted phenols, ethanes and other chemical compounds in amounts neeting regulatory standards (e.g., Tech Specs) seem to cause no ~etectable changes in the quality o f waters receiv!ng them (Pagano, Leshe, and Douglas 1979). 9

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Future Prospects Fech Specs monitoring indicates that waste heat discharges from nuclear ~lants have caused little damage to date (Committee on Energy and tile Environment of the National Research Council 1977)." Pagano, Leslie, and Douglas (1979) point out that this conclusion is not universally, accepted, but is "widely" acknowledged. This finding is in line with predictions made prior to the opel:ation o f the power plants studied. However, predictions on the structure and behaviour o f thermal plumes have not been borne out by monitoring data, admittedly of a more limited kind. As a result of monitoring experience under the Tech Specs program, attention has now shifted from monitoring lower trophic levels to analyzing organisms at tile top o f food chains. In addition, more i388 EIA REVIEW 1/4

attention is being paid to the effects of impingement and entrainment on fish populations. Also, it is n o w realized that monitoring single projects in environments likely to be affected by other factors is partial and does not help determine the combined effects o f all external influences on a variety o f local ecosystems. Consequently, efforts are being made to implement cumtdative monitoring schemes. Such programs cover entire ecosystems and attempt to focus on long-term trends. Such a scheme has been in operation in the lower reaches o f the Hudson River. This section of the river is affected by the effluents of a large number o f power stations. Plans are in motion to implement similar programs for Lake Michigan and the western and central basins of Lake Erie (Pagano, Leslie, and Douglas 1979). It is hoped that such work will aid in site selection for future developments, and help in the identification o f mitigating measures that might be taken to avoid harmful effects - for example, phasing of power station maintenance. PROBLEMS IN IMPLEMENTING AUDITS Although the implementation of audits appears, superficially, to be a conceptually simple exercise, experience shows it is fraught with difficulties. The problems involved have led some to argue that audits cannot be carried out in a scientifically acceptable manner.* For most projects with a long operational life, monitoring is a lengthy, expensive, and time-consuming business; Operational monitoring is required for at least two years, and in most cases longer, before trends can be identified. To compare operational monitoring data with preoperational data, monitoring must be carried out for a considerable period prior to operation. Most commentators consider that baseline data should cover more than one year to determine seasonal variations and natural longer-term fluctuations. Achieving this is difficult as there is often no time available to obtain the requisite preoperational data. Attempts to overcome this problem have involved the use of control monitoring stations which exhibit similar environmental characteristics to stressed stations (that is stations likely to be affected b y a project). Frequently, in some complex environments such as estuaries, these control monitoring stations cannot be located in the vicinity of the actual stressed stations, and this can result in controls that are not environmentally similar and may be subject to externally induced factors not affecting the stressed stations. Should this occur it might b e difficult to interpret the project effects because they may be masked b y the influence of factors only affecting the controls. Assuming monitoring has been undertaken over an adequate period to allow audits, still the suitability of the data can be an unknown factor. Data can be subject to a variety of contingent factors, which might render conclusions at worst irrelevant or at best only indicative of a particular result. To audit properly, it is necessary to determine in *Dr. Raj Sharma 1980: personal communication. EIA REVIEW 1[4 389

dvance likely impacts, their geographic coverage, and the types of hanges in environmental parameters or processes that are expected. It telps, also, if certain degrees or sizes of change were established as 'benchmarks" to be identified by monitoring schemes (Thomas 1977). ~Tith this knowledge, monitoring must be devised to enable statistically alid analyses of both pre- and postoperational data. Past experience in he United States has shown that monitoring schemes have rarely been esigned in this manner (Gore, Thomas, and Watson 1979; Muraka et 1. 1976b; Adams et al. 1977). In the Tech Specs studies, monitoring chemes were established haphazardly and it is possible to detect a 'measure everything" philosophy. As a result, much of the data were Lot suitable for the application o f statistical techniques to interpret heir meaning. Thomas (1977) states that the " p o w e r " of the statisical techniques used by Battelle in tile Tech Specs studies was low. In implementing audits it is vital to have monitoring data that rave been obtained consistently through time. For example, data on 0hytoplankton biomass collected preoperationally should be comparble with data collected during operation. It would be useless if other spects of phytoplankton were monitored halfway through a program. ;imilarly, data have to be collected in a standardized manner. Sampling t)cations and techniques must not be changed, otherwise statistical .nalysis is rendered speculative. The Tech Specs studies suffered from ome of these drawbacks and consequently their conclusions are less tseful than might have been tile case (Pagano, Leslie, and Douglas 1979). Such events may occur for a variety of reasons.-As monitoring or audits is a long-term c o m m i t m e n t constant institutional frameworks .re required to complement monitoring programs. It is best if personnel stablishing a monitoring program remain to carry it out, thereby mainaining consistency. However, it is difficult to ensure consistency of ~ng-term monitoring because of staff turnover in both companies and egulatory authorities. Such staff changes can result in the irivalidation ~f monitoring data unless adequate supervision is exercised.* Often, :xperts disagree on the target parameters to be monitored to detect an mpact, or even that a particular impact is important enough to be nonitored. Also, there can be a temptation to apply new sampling techfiques. Supervision is not easy to maintain over the time periods reluired for monitoring because of the career structures and employment :haracteristics of organizations responsible for monitoring. Another factor that might affect audits is the behaviour of those 'esponsible for constructing and operating a project. Impact predictions tre made on the basis o f facts about the characteristics of a project. )ften, such facts are obtained from discussions with those only distantly 9esponsible for the day-to-day management o f construction and operaion. Information on projects obtained prior to construction and operttion can become easily outdated due to rapid technological change. ?rojects with long lead times, such as power stations, or with multiDr. Raj Sharma 1980: personal communication. 90 I

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phase construction periods can be subject to technical changes that may not have been considered in an EIS. These alterations may invalidate predictions as the causal factors assessed may have been changed after the assessment was completed. Unless there is an attempt to keep track of technological changes, assessments of predicitons may be misleading. Not only do technical changes have to be monitored to assess their influence on audits, but also on-site construction and operation has to be checked. Often predictions of impacts and consequent identification of mitigating measures depend on assumptions that work will be carried out in a certain way. For example, there may be an agreement that construction work on one part of a site will not occur during the nesting season of a nearby bird colony, but there can be difficulties in ensuring that such an agreement is carried out. Channels of communication can break down and result in actions being carried out which cause impacts not incorporated in an EIA.* However, unless the existence of these events is known, testing the accuracy of impact predictions becomes impossible. As few audits have been undertaken, a problem exists in obtaining knowledge on project impacts and on the accuracy of predictions. The location of stressed stations depends on predictions of impacts, for example, area likely to be affected and target organisms. Results from these stations are, unfortunately , t h e only way of testing predictive accuracy. However, there is a "catch-22" situation; if the predictions were inaccurate, t h e monitoring data would provide a false impression o f actual impacts and predictive accuracy. This situation can be altered if the characteristics of an impact can be identified readily, for example, visually. Subsequently, stressed stations could be changed and accurate information obtained, but this would require a further commitment o f captial and manpower. In cases when impacts are not detectable except by statistical analyses of monitoring data, it is possible that impacts may be missed entirely and a false impression gained about the accuracy of predictions. This wotfld u n d o u b t e d l y be the case where an impact was only apparent after a considerable time lapse in a location geographically distant from the source. If these problems could be overcome or if it could be determined that their effects would be minimal in a particular case, there would still be problems in testing the accuracy o f impact predictions. It could be ascertained that there has been a change similar to that predicted, but whether a predictive technique is accurate or not depends on an interpretation of the significance of the difference between the actual impact and the predicted impact. For example, if noise lcvels wcre expected to rise b y 10db from 07.00 to 19.00 hours at a school near a project and it were found that they increased b y 7db or 12db, it could be argued that the differences were or were not significant in terms of the accuracy of the predictive technique used. Such decisions arc easier when the discrepancy is o f a greater magnitudc. *Dr. Pam Merry 1980: personal communication. EIA REVIEW 1[4 391

[PLICATIONS OF C U R R E N T AUDITING EXPERIENCE has been shown that developments often change their characteristics ce an EIA has bccn carried out. This is not to deny the utility of hav,~ an assessment to aid initial decision making on tile future of projts, but only serves to indicate the limits of the approach. There can little d o u b t that "traditional" EISs would be o f limited utility in 9ms of environmental protection if impacts were different from that edicted because of technological changes. There is a clear need to link gether EIA and monitoring to form a continuous process of project ;essment and management to ensure that the effects of technological 9anges and other factors, such as changes in construction activities, are nsidered and that appropriate actions are taken to 9 or minimize rmful effects. EIA becomes a process of assessment constantly tuned project development throughout the construction and operational rases. This type of EIA approach has been advocated forcefully b y )lling (1978) and his colleagues at tile University of British Columbia d at tile International Institute for Applied Systems Analysis. The oblems for auditing caused b y technical and other changes would em to support the view that this type o f EIA approach should be ore widely adopted. With this type of EIA there has to be a fcedback link b e t w e e n onitoring, analysis of impacts arising from a project, and tile implecntation of appropriate mitigating measures. This link is assumed b y ose who advocate the use o f EIA as a continuous pi-_occss, but the lancial and manpower commitments needed for such an approach tve yet to be determined. The limited experience with auditing sugsts that it is an expensive undertaking whose results are suspect un~s stringent controls are exercised on both impact prediction, monitorg, and project implementation. Consequently, the arguments favoring tdits must be considered seriously. There can be no d o u b t that EIAs ill become increasingly prevalent throughout tile world in response to lblic pressure for comprehensive assessment of major developments. ~isting experience with EIA procedures has shown that public atten3n i n conjunction with the concerns of administrators, planners, and ~e scientific c o m m u n i t y focuses on assessment prior to decision makg and ignores the postdevelopment situation. Consequently, it can be gitimately asked whether the benefits to be gained from undertaking ~dits, in terms of increased knowledge of impacts, improved predictive chniques, and more effective mitigating measures, can outweigh the ~sts. Since the costs are high in relation to perceived benefits, a case m only be made for a carefully coordinated and planned limited :ries of audits for major projects in a variety of environments. It would :em appropriate that such a scheme should be initiated and organized g an international organization such as the Commission of the Euroean Economic Communities or the United Nations Environment Procamme. Only in this way can most of the problems involved in imple-

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menting audits be tackled. EIAs should be carried out in a systematic manner using best available methods and techniques, devising appropriate monitoring schemes, and checking imponderable and unpredictable factors that might affect the audit analysis. A recent report issued by the U.S. Fish and Wildlife Service indicates the type of EIA method that will help greatly to formulate impact predictions which can be checked (Fritz, Rago, and Murarka 1980). This method, although developed for aquatic ecological impacts, can be used for a wide variety of impact types. Basically, systems modeling is used to produce a hierarchy of predictions in the form of impact hypotheses. These are testable statements on the consequences of a proposed project. This method also gives guidance on environmental parameters that should be monitored to enable the impact hypotheses to be tested. In addition, the U.S. Geological Survey has issued a report which indicated how monitoring programs should be designed and implemented to detect and measure impacts and to compare actual impacts with predictions in EISs (Marcus 1979). These two reports demonstrate that there is an increasing realization 6f the importance of audits for the integrated development of environmental resources. Tile recipients of audit results, for example, governments, would be in a good position to disseminate information on the utility of predictive techniques to those organizations responsible for EIA work. In this way, the maximum benefit could be derived from audits and the present situation, in which audits are extremely difficult to locate and when obtained prove to be partial in their coverage, could be avoided. It should not be thought, however, that an international series of audits which attempted to eliminate or control the difficulties would be able to avoid all existing problems and provide answers to all questions relating to impact characteristics and predictive accuracy. Gaps in our knowledge would still remain, but it is likely that considerable advances would be achieved. An increase in knowledge on environmental impacts and appropriate predictive techniques might lead to better decisions, more appropriate mitigating actions, and, sut~sequently, less environmental deterioration. In the long-term, substantial financial savings might accrue, to offset the initial cost of the audit series.

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zknowledgrnents le research d e s c r i b e d in this p a p e r was u n d e r t a k e n as p a r t o f a N a t u r a l l v i r o n m c n t R e s e a r c h Council s p o n s o r e d p r o j e c t in t h e U n i t e d King)m. T h e a u t h o r also wishes to t h a n k t h e following o r g a n i z a t i o n s hich c o n t r i b u t e d to his U. S. s t u d y t o u r : the U n i v e r s i t y o f A b e r d e e n , .e Carnegie T r u s t for the Universities o f S c o t l a n d , and t h e N A T O 9 m m i t t e e o n the Challenges o f M o d e r n S o c i e t y . Finally, I a m g r a t e f u l , m y colleagues for t h e i r s u p p o r t a n d to Ms. Pearl Allan, for t y p i n g te manuscript.

References Adams, S. M., Cunningham, P. A., Gray, D. D., Kumar, K. D., and Whitten, A. J. 1977. Critical Evaluation of the Nonradiological Environmental Technical Specifications: Program Description, Sztmmary and Recommendations. ORNL/ NUREG/TM-69-Vol. I. Oak Ridge National Laboratory, Oak Ridge, Tennessee. Committee on Energy and the Environment, of the National Research Council 1977. Implications of Environmental Regulations for Energy Production and Consumption Analytical Studies for the U.S. Environmental Protection Agency. Vol. VI. National Academy of Sciences, Washington, D.C. Council on Environmental Quality 1976, Environmental Impact Statements: An Analysis of Six Years' Experience by Seventy Federal Agencies. Washington, D. C. --. 1978. National Environmental Policy Act: Implementation o f Procedural Provisions; Regulations. Federal Register 38:55978-56007. ~. 1979. Environmental Quality: Annual Report of the Council on Environmental Quality. Report 10. Washington, D. C.: U. S. Government Printing Office. Cunningham, P. A., Adams, S. M., and Kumar, K. D. 1977. Evaluation of Environmental Impact Predictions. CONF770516-7. O~ik Ridge National Laboratory, Oak Ridge, Tennessee. Environment and Consumer Protection Division 1980. Proposal for a Council Directive Concerning the Assessment of the Environmental Effects of Certain Public and Private Projects. Commission of the European Communities, Brussels, Belgium.

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Executive Office of tile President 1977. Executive order 11991. Protection and enhancement of environmental quality. Federal Register 42:26967-8. Friesema,M. P. and Culhane, P.J. 1976. Social impacts, politics, and the environmental impact statement process. Natural Resources Journal 16 (2):339-56. Fritz, E. S., Rago, P. J. and Murarka, I. P. 1980, Strategy for Assessb~g Impacts o f Power Plants on Fish and Shellfish Populations. Paper No. FWS/OBS-80/34. Fish and Wildlife Service, U.S. Department of the Interior, Washington, D.C. Gore, K. L., Thomas, J. M., and Watson, D. G. 1970. Quantitative Evaluation of Environmental Impact Assessment Based on Aquatic Monitoring Programs at Three Nuclear Power Plants. Journal of Environmental Management

8(1):1-7. tIolling, C. S., ed. 1978. Adaptive Environmental Assessment and Mm, agement. Chichester: John Wiley. Institute for Environmental Studies 1976. Documentation of Environmental Change Related to the Columbia Electric Generating Station. Report 62. University of Wisconsin, Madison, Wisconsin. Marcus, L. G. 1979. A Methodology for Post-EIS (Environmental lmpact Statement) Monitorbzg. Geological Survey Circular 782. U.S. Geological Survey, Arlington, Virginia. Marmer, G. J. and Policastro, A. J., undated. Evaluation o f Utility Monitoring and Pre.operational llydrothermal Modelbzg at Three Nuclear Power Plant Sites. Argonne National Laboratory, Argonne, Illinois. Murarka, I. P., Ferrante, J. G., Daniels, E. W. and Pentecost, E. E. 1976a..,In Evaluation of Environmental Data Relating to Selected Nuclear Power Plant Sites: Prairie lsland Nuclear Generating Plant Site. ANL/EIS-6. Argonne National Laboratory, Argonne, Illinois. Murarka, I. P., Ferrante, J. G., Daniels, E. W., and Pentecost, E. E. 1976b. An Evaluatim, of Environmental Data Relatbzg to Selected Nuclear Power Plant Sites. ANL]EIS-1 (Kewaunee). ANL/EIS-2 (Quad Cities). ANL/EIS-6 (Prairie Island). Argonne National Laboratory, Argonne, Illinois. Pagano, R., Leslie, b,l. and Douglas, R. 1979. Monitoring the Aquatic Environment at Steam-Electric Power Plants. McLean, Virginia: Mitre Corporation. Thomas, J. M. 1977. Factors to Consider in Monitoring Programs Suggested by Statistical Analysis of Available D a t a . In Proceedings of the Conference on' Assessing the Effects o f Power-Plant-Induced Mortality on Fish Populations, ed. W. van Winkle, pp. 243-255. Oxford: Pergamon Press. U. S. Department of the Interior, Bureau of Reclamation 1974. Navajo Project - Status Report on Environmental Gommitnzents. Boulder, Colorado.

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U. S. Department of the Interior, Bureau of Land Management 1975. 1974 Barstow-Las Vegas Motorcycle Race: Evaluation Report. Sacremento, California. U. S. Environmental Protection Agency 1980. Evaluation o f EPA's EIA Program for Wastewater Treatment Facilities. Office of Environmental Review, U. S. Environmental Protection Agency, Washington, D. C.

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