2.10 Limitations of EIA
A 2009 review of the EIA Directive by the European Commission (EC, 2009) noted that while EIAs have been innovative in helping to integrate environmental considerations and public opinion into projects and development, a number of problems remain relating to:
- the appropriate use of screening criteria to determine if EIAs are needed
- quality control of the data and data gaps
- quality of the process and methodological rigour
- lack of harmonised procedures for involving the public
- focus on site boundaries
- trans-boundary problems involving more than one member state
- lack of coordination between EIA and other directives.
The focus on site boundaries is particularly important, as noted in the earlier discussion on differences between organisational boundaries and impact boundaries.
The last point is also noteworthy as the review makes clear that climate change is, for all intents and purposes, excluded from EIAs, as the following extract explains:
The EIA Directive does not expressly address climate change issues. Most of the [Member States] recognise that climate change issues are not adequately identified and assessed within the EIA process. Any review of the impacts of climate change is often limited to CO2 and other greenhouse gas emissions from industry and from increases in transport as part of air quality studies or as indirect impacts. The EIA assessment will often not go beyond evaluating existing emissions and ensuring that ambient air quality standards are met. In addition, the effects on global climate, the cumulative effects of an additional project and adaptation to climate change are not sufficiently considered within the EIA.
This leads to a concern as to whether the EIA can be claimed to be innovative as a way of understanding and making sense of the connections between an organisation and the natural and human environments. It also raises a concern as to whether the EIA is a useful approach in assessing eco-innovations claimed as part of a development.
Partly in response to these kinds of concerns, as well as political changes and an emphasis on growth and developments in other appraisal tools, in late 2012, the European Commission signalled its intention to review and streamline the EIA Directive by reducing administrative burdens and making it easier to assess the potential impacts of major projects (see EC, 2012).
The newly amended Environmental Impact Assessment (EIA) Directive (2014/52/EU) entered into force on 15 May 2014 to simplify the rules for assessing the potential effects of projects on the environment and reduce administrative burdens. Greater attention is also given to resource efficiency, climate change and disaster prevention (EC, 2014).
The fine details of these changes are beyond the scope of this course. But it is particularly noteworthy that the newly amended directive adopts the language of ecosystem services, which is explored next.