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A proposal for further strengthening science in


environmental impact assessment in Canada
a b
Lorne A. Greig & Peter N. Duinker
a
ESSA Technologies Ltd , 77 Angelica Avenue, Richmond Hill , ON , Canada , L4S 2C9
Phone: 001 905 7706334 Fax: 001 905 7706334 E-mail:
b
School for Resource and Environmental Studies , Dalhousie University , 6100 ,
University Avenue, Halifax , NS , Canada , B3H 3J5 E-mail:
Published online: 20 Feb 2012.

To cite this article: Lorne A. Greig & Peter N. Duinker (2011) A proposal for further strengthening science in
environmental impact assessment in Canada, Impact Assessment and Project Appraisal, 29:2, 159-165, DOI:
10.3152/146155111X12913679730557

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Impact Assessment and Project Appraisal, 29(2), June 2011, pages 159–165
DOI: 10.3152/146155111X12913679730557; http://www.ingentaconnect.com/content/beech/iapa

Professional practice

A proposal for further strengthening science in


environmental impact assessment in Canada

Lorne A Greig and Peter N Duinker


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We observe ongoing weaknesses in the quality of science underpinning environmental impact


assessment (EIA) in Canada. This is frustrating because approaches for strong scientific practice in
EIA were published decades ago. A major failing has been the lack of scientific support from outside
the EIA practitioner community. We argue for a re-conception of science associated with EIA that
includes a rigorous scholarship of application inside EIA and a vigorous scholarship of integration
outside it. Cases of exemplary organizational structures and science applications in the Canadian forest
sector are given. To turn EIA from the often bitter battleground of shallow impact debates to an
enterprise of strong accumulation of effects knowledge, we urge the relevant communities of
researchers and practitioners to become embedded communities of practice and reform the way science
contributes to EIA.

Keywords: science, environmental impact assessment, EIA, environmental assessment, Canada

I N THE EARLY 1980s, the Federal Environmen-


tal Assessment Review Office (FEARO, prede-
cessor to the Canadian Environmental
Assessment Agency) and Environment Canada to-
gether sponsored a major study on how to improve




Define a context for impact significance.
Establish boundaries for the analysis.
Develop and implement a study strategy.
Specify the nature of predictions.
Undertake monitoring.
the scientific basis of environmental impact assess-
ment (EIA) in Canada. The project’s final report The Beanlands and Duinker (1983, 1984) proposals
(Beanlands and Duinker, 1983) contained a series of have been widely cited in both scientific and practi-
six so-called requirements for conducting ecological tioner literatures in Canada and abroad, and in in-
studies in EIA: numerable EIAs. The claim in almost every EIA that
cites the work is that the EIA follows the sugges-
 Identify the valued ecosystem components on tions on implementation of stronger ecological sci-
which the analysis will focus. ence. No doubt there have been substantial
improvements in the scientific basis for EIA over the
past couple of decades, but to our knowledge no one
Lorne Greig is at ESSA Technologies Ltd, 77 Angelica Avenue, has undertaken the empirical research to confirm
Richmond Hill, ON, Canada L4S 2C9; Email: lgreig@essa.com; this. However, our professional observations over
Tel: 001 905 7706334; Fax: 001 905 7700197. Peter Duinker is the past quarter century of EIA practice in Canada
at the School for Resource and Environmental Studies, Dalhou- suggest that implementation still lags significantly
sie University, 6100 University Avenue, Halifax, NS, Canada
B3H 3J5; Email: peter.duinker@dal.ca.
behind the ideal. We observe ongoing weaknesses in
We extend hearty thanks to two anonymous referees, and scoping (Mulvihill and Jacobs, 1998; Mulvihill,
other readers of earlier versions of the manuscript, for their in- 2003), time and space bounding (Duinker and
valuable assistance in improving the paper. Baskerville, 1986), effects experimentation (Walters

Impact Assessment and Project Appraisal June 2011 1461-5517/11/020159-7 US$12.00  IAIA 2011 159
Professional practice

and Holling, 1990), impact prediction (Culhane et EIA is all science, even good science, it will fail.
al, 1987), monitoring and follow-up (Morrison- If EIA is all politics, even the good politics of
Saunders and Arts, 2004), and adaptive management principled negotiation (Lee, 1993), it will fail. Our
(Duinker and Trevisan, 2003). interest in this paper is to help further a stronger
Both of us have been EIA practitioners (one from science contribution to EIA, notwithstanding
a consulting platform, the other from academia) for scholarly advisories about taking this too far
nearly three decades. Together and singly, we have (Cashmore et al, 2004; Gregory et al, 2006). Our
taught, written about, and researched EIA extensive- aim is to help EIA practitioners — scientists, pro-
ly. We have served government, private sector and ponents, regulators, environmental advocates, and
non-government organization (NGO) clients in de- other participants — move the science to greater
signing and reviewing EIAs, and we have served rigour (generating more-reliable knowledge) and
EIA panels in their work to review EIAs and make utility (generating decision-useful information).
recommendations about projects and the associated 5. Our approach in developing the ideas in this paper
science needed to create reliable impact knowledge is not one of conventional science itself. We have
during project implementation. In this paper, our ob- taken no new observations and collected no new
jective is to draw on these experiences and some fur- data specifically to test the proposal’s hypothesis.
ther reflections to propose an approach to making Our observations and views are based on decades
further improvements to scientific practice in EIA. of practitioner experience and involvement, re-
Some starting points for our observations and search experience, the literature, and deductive
arguments are in order: reasoning.
6. We take the position that EIA practitioners in
1. Cashmore (2004) has argued that appropriate Canada are still struggling with scientific practice.
roles for science in EIA depend on one’s assump- This position is contrary to the findings of Morri-
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tion about the substantive purpose(s) of EIA. For son-Saunders and Bailey (2003), who surveyed
the purposes of this paper, we rely on the follow- EIA practitioners and reported that they were in
ing conception of EIA: ‘In general, environmental large measure happy with the quality of science in
assessment is a process to predict the environmen- EIA but unhappy with the importance placed on
tal effects of proposed initiatives before they are science in many stages of the EIA process. Morri-
carried out…An environmental assessment: iden- son-Saunders and Sadler (2010) confirmed this.
tifies possible environmental effects; proposes Such a finding should not be surprising, given that
measures to mitigate adverse effects; [and] pre- the science practiced in EIA is indeed the direct
dicts whether there will be significant adverse en- purview of those very practitioners. Most profes-
vironmental effects, even after the mitigation is sionals would defend the quality of their work,
implemented’ (CEAA, 2010). We must add to this and would naturally lament that others might not
the imperative that EIA ought also to contribute to see their work as important as they would like.
ongoing learning about environmental effects For this paper, we stand by our position that
through rigorous follow-up and monitoring significant improvements can and should be made
(Morrison-Saunders and Arts, 2004). in scientific work in EIA, and we posit that our
2. Adopting this conception of EIA demands a key proposal below will, if implemented, be of
role for science in predicting environmental tremendous help.
effects. Other types of knowledge are indeed rele-
vant in impact prediction (e.g. the traditional eco- What we address in this paper is not the balance of
logical knowledge of Canada’s Aboriginal people), scientific considerations in EIA in the context of
but few would argue that impact prediction is a socio-political or other decision-making considera-
non-scientific matter. tions; the data of Morrison-Saunders and Sadler
3. We limit our analysis to the realm of biophysical (2010) make it clear that practitioners acknowledge
science. Social science also has a huge role to the fundamental importance of supporting EIA deci-
play in EIA, and whether its protocols match sion-making with good science. What we do address
those of biophysical science or not, we make no is the notion of what makes for good science in this
specific claims here about our proposal applying context. To the degree that we might see EIA prob-
to social science, although it may have some lems as wicked problems (and surely they often
applicability. are), we propose that scientific inquiry associated
4. Cashmore (2004) has described five models of with EIA should be set into the context of the
scientific practice in EIA. We see examples of all transdisciplinary imagination (Brown et al, 2010).
five of Cashmore’s (2004) models in Canadian
EIA experience. We prefer to see EIA in the con-
text of Lee’s (1993) conception of processes for A framework for science in/for EIA
the pursuit of environmental sustainability: sci-
ence and politics must be integrated, and the ap- To achieve the benefits that should accrue from de-
propriate model for science is that of adaptive signing environmentally sustainable developments,
management (Holling, 1978; Walters, 1986). If strong science in EIA is imperative. In our view,

160 Impact Assessment and Project Appraisal June 2011


Professional practice

scientific practice in EIA is still inadequate. Key fac-  Science inside the EIA process is needed to make
tors behind this situation are inadequate expectations specific impact predictions to inform decision-
on how the scientific community should contribute makers of the potential ecological consequences
to EIA. On one hand, the scientific community out- of development alternatives, as well as to measure
side the regulatory confines of EIA is not being mobi- environmental responses following development
lized sufficiently to support EIA needs. On the other, start-up for the purpose of model evaluation and
the science done within EIA is being unfairly ex- refinement.
pected to make up for the lack of scientific support
from outside EIA. Boyer’s (1990) categorization of academic scholar-
These observations suggest that it is helpful to see ships is relevant here. Boyer (1990) suggested that,
the science associated with EIA in two domains that besides the scholarship of teaching, professors
are distinguished by their position vis-à-vis formal can/should also be engaged in (a) the scholarship of
project-specific EIAs required by governments as discovery, which has to do with establishing basic
part of development approvals (Figure 1). Science relationships between variables within a discipline;
outside EIA is needed to provide knowledge for use (b) the scholarship of integration, which investi-
inside EIA processes. Thus, it feeds the science in- gates relationships among variables from several
side EIA with robust assessment tools and requisite disciplines; and (c) the scholarship of application,
data sets. It is appropriately sponsored and undertak- where scientific relationships are applied in the
en by a variety of organizations such as govern- search for good solutions to practical problems. On
ments, universities, EIA regulatory agencies, and the premise that EIA practitioners dealing with bi-
environmental NGOs. The science inside EIA is ophysical impact issues are engaged, or should be
sponsored and undertaken by development propo- engaged, in scientific scholarship, then Boyer’s
nents to provide information for making decisions (1990) scholarships of discovery and integration
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on specific developments, both before approval and comprise the kind of science most needed in sup-
while developments exist/operate. In addition, the port of EIA but outside EIA activities within the
science inside EIA provides case materials in the regulatory framework. The scholarship of applica-
form of testable effects hypotheses and project- tion is appropriate inside EIA.
specific monitoring data — it feeds the science out- What scientific protocols are contained in the
side EIA. The actual developments to which EIA scholarship of integration that are not in the scholar-
science is applied serve as case-study opportunities ship of application? Why is project-specific EIA not
for furthering the creation of general effects an appropriate home for the scholarships of discov-
knowledge. ery and integration? It comes down to motivations
Thus, in summary: and time frames. EIA is a process of development
approval that must be accomplished in short time
 Science outside the EIA process is needed to cre- frames that are inconsistent with those associated
ate, test, and refine robust models for predicting with creation of reliable knowledge of ecological ef-
ecological effects of development; and fects of development. In a nutshell, the central chore

Figure 1. Relationships between science and EIA, with recognition of appropriate forms of
scholarship from Boyer (1990)

Impact Assessment and Project Appraisal June 2011 161


Professional practice

for analysts in EIA is to develop impact predictions. Cases of exemplary practice in Canada
Such predictions are statements outlining how a val-
ued ecosystem component might be expected to re- Instances of promising progress in Canada suggest
spond — in the future — to specific development that practical implementation of the proposed
alternatives, including no development (the null al- framework is feasible. Of particular interest in this
ternative) (Duinker and Baskerville, 1986). To make context are Canada’s Networks of Centres of Excel-
credible impact predictions, as testable (usually lence, instituted around disciplinary themes, which
quantitative) hypotheses, analysts need predictive exemplify the sort of organizational construct need-
models. Such models can either be built from scratch ed to develop the science outside EIA that could en-
inside the EIA process, in which case their basis in able good practice within. Project EIAs can, and
observations is likely to be weak because of the limi- have, taken such science and applied it to illuminate
tations of time and resources in EIA, or they can be future environmental consequences of development
developed in scientific work outside EIA. In the alternatives. Our examples are from the forest sector
second case, there should be opportunity to work at of Canada because it is in that sector that we have
the appropriate time and space scales that allow our greatest collective expertise and experience re-
proper understandings, through field measurement, lated to science both inside and outside EIA. Exam-
of variations in the state/condition of valued ecosys- ples from other resource management and
tem components across space and through time. development sectors (e.g. fisheries or hydro-electric
Moreover, scientists outside EIA can mount experi- power generation) may also exist, but in this short
ments and process studies, with all the caveats at- paper we have room for only one such theme.
tending them in large ecosystems (Hilborn and
Walters, 1981), that can provide critical data for Networks of Centres of Excellence
model building and testing. However, complex
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models developed outside EIA that require large Begun in 1992, the Networks of Centres of Excel-
amounts of data to parameterize for a particular cir- lence (NCE) program is supported by Canada’s three
cumstance could be infeasible to apply at the scale national granting councils — the Natural Sciences
of an individual EIA. Consequently, to enable up- and Engineering Research Council, the Social Sci-
take by the EIA community, the predictive science ences and Humanities Research Council, and the
developed outside EIA must pay attention to the Canadian Institutes of Health Research — as well as
practicality of application at the scale of individual the federal department known as Industry Canada.
EIAs. Until recently, the program financed NCEs for up
To enable the learning needed to improve predic- to 14 years of operation; now, for new NCEs the
tive models over time, the need for monitoring of funding horizon is ten years. Each NCE is a unique
relevant environmental variables during develop- partnership of universities, governments, businesses,
ment is clear (Duinker, 1989; Morrison-Saunders and non-profit organizations focused on ‘turning
and Arts, 2004). What is still debated in EIA prac- Canadian research and entrepreneurial talent into
tice is who should be responsible for it. Participants economic and social benefits for all Canadians’
in EIA processes often disagree as to whether pro- (Networks of Centres of Excellence, 2008). In es-
ponents ought to monitor or whether government sence, each NCE brings non-university partners
should. Regardless whether the assignment falls to together to drive a university-based research agenda
scientists outside or practitioners inside the EIA that delivers knowledge needed by the partners.
process, the monitoring must get done or else relia- Of particular relevance here, and consistent with
ble knowledge will not, over time, be developed. personal involvement by one of us (Duinker), is
Our experience indicates three things. First, the ve- one NCE associated with natural resources and the
racity of impact predictions must be tested with environment: the Sustainable Forest Management
targeted monitoring. Second, monitoring programs Network (SFM Network).
must be designed to assist in the linking of causes Since its inception in 1995 (SFM Network, 2008),
with effects; monitoring only variables directly as- the SFM Network has been instrumental in improv-
sociated with valued ecosystem components may ing the scientific basis for SFM in Canada. This out-
not yield sufficient insight to explain variation in come has been realized through development of
their behaviour, particularly when causes are nu- basic cause–effect relationships between forest
merous (a situation of cumulative effect). Third, practices and ecological/social variables, provision
both the predictive and empirical elements of of improved models for forecasting broad-scale,
impact science proceed best when scientists/ long-term effects of alternative forest-management
practitioners both inside and outside EIA processes regimes, and training of hundreds of graduates for
are embedded in each other’s work (Van Damme et employment in the sector.
al, 2008). In this regard, other aspects of EIA prac- What is critical in the NCE structure is the man-
tice, for example evaluation of alternatives and agement-relevant focus of the research programs
post-decision follow-up work, may well be further driven by the needs of resource managers. For ex-
enabled by a similar collaboration with work done ample, the first work on criteria and indicators (C&I)
outside EIA. of SFM in Canada was undertaken by the Canadian

162 Impact Assessment and Project Appraisal June 2011


Professional practice

Council of Forest Ministers (CCFM, 1995, 2003), and EIA process to develop temporally and spatially
initially as a way to communicate into international explicit predictions of responses of various facets of
fora how Canada is progressing with SFM. Among biodiversity (e.g. habitat use by migrating birds).
several organizations in Canada to pick up the torch, The work was accomplished as part of the overall
the SFM Network adopted the C&I framework to process of LP Canada meeting its own corporate as-
guide research aimed at practical, on-the-ground im- pirations for sustainability as well as forest-
provements in SFM across the country. Below, we management and EIA approvals of the Government
describe an example where the SFM Network has of Manitoba. The synergies here in terms of combin-
been influential in improving the scientific basis for ing the best talent from the consulting, research, and
EIA in the context of forest-management planning. forest-management communities are outstanding.
These initiatives are in no small part attributable to
Forest management the deeply held belief by the resource managers that
sound science is central to sustainably managing
Industrial forest management takes place across natural resources.
Canada in hundreds of large forest-management
units. Most are owned by provincial governments
and managed under license by commercial enter- Conclusions
prises. Management plans for such forests are sub-
ject to formal EIA requirements in four provinces: Perhaps the greatest incentive for making the chang-
Saskatchewan, Manitoba, Ontario, and Newfound- es we advocate here are the consequences of not do-
land & Labrador. In Saskatchewan and Manitoba, an ing so. The fundamental rationale for doing EIA is
EIA accompanies the forest-management plan when to prevent unacceptable impacts to the environment
the plan is submitted for government approval. In to help society achieve a sustainable pattern of de-
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Ontario and Newfoundland & Labrador, the plans velopment. Sound science is a necessary, if indeed
themselves, along with the planning process, are wholly insufficient, component of EIA endeavours.
cleared through a Class EIA process. Through a To raise the quality of science in EIA to what is
range of mechanisms including regulatory require- needed, two key things must occur. First, there must
ments and forest certification, forest-management be acceptance that the situation needs to change:
planning in Canada’s other provinces has evolved regulators, proponents, and other practitioners have
toward a state where all forest-management plans to want improvement. Second, the expectations for
are themselves EIAs in every technical sense. how good EIA science will develop need to be ex-
A superb example is the forest-management plan- plicitly reformulated into a new framework, as
ning work of LP Canada Ltd (LP), operating on pub- summarized above (see Figure 1). This entails both
lic land — Forest Management License #3 — in continued high but realistic standards for the quality
west-central Manitoba. The SFM Network was in- of scientific practice within EIA, and a ramping up
volved here as a leading research organization. In of coordinated networks of centres of excellence to
addition, researchers at the Centre for Northern For- generate the needed knowledge.
est Ecosystems Research (CNFER) in Thunder Bay, Developing the models required to enable strong
Ontario, through Lakehead University and with par- impact analysis needs a broad view that cuts across
tial funding from the SFM Network, have been in- developments rather than being mired in the specific
volved. Path-breaking integrative work at CNFER details of any one EIA. The Networks of Centres of
on forest biodiversity assessment (Rempel, 2007; Excellence Program in Canada has demonstrated
Rempel et al, 2007), funded partly by the SFM that this approach can deliver the sort of science re-
Network, was used as a basis for assessment of the quired. To put EIA in Canada on a solid scientific
biodiversity-related effects of alternative forest- footing, the networks need to be expanded. Addi-
management strategies (Rempel et al, 2006). tionally, they should be complemented with research
The links to EIA in this example are exquisite. centres or institutes focused on supporting EIA ac-
Research at CNFER was initiated as part of the On- cording to: (a) specific types of developments (e.g.
tario Ministry of Natural Resources’ promises to the SFM Network), (b) specific types of valued eco-
support planning for non-timber values in associa- system components (e.g. the Canadian Water Net-
tion with the Class Environmental Assessment for work), or (c) regional contexts (e.g. Canada’s
Timber Management on Crown Lands in Ontario. Maritime Provinces). A key focus in this context
As adjunct professors at Lakehead University, would be cumulative impacts (Duinker and Greig,
CNFER researchers can access SFM Network funds 2006). The centres would engage EIA practitioners
to augment their normal research funding from the associated with regulatory agencies and proponents
Government of Ontario. Combining these, the Spa- together with university and other researchers in
tial Ecology Program at CNFER has developed ad- scoping the targeted research programs needed to
vanced integrated modelling tools for biodiversity provide the necessary models for impact assessment.
assessment in association with forest-management In this targeted effort to support EIA, designing
planning in Ontario (Rempel, 2008). The models models to enable their application within the EIA
were applied in the LP forest-management planning community is a high priority.

Impact Assessment and Project Appraisal June 2011 163


Professional practice

two-fold: the literature, and our experiences in EIA


research, teaching, and professional practice. These
On the practical side, EIA should be sources have their limitations, especially the experi-
able to experience gradually reduced ential evidence because of its potential bias and the
small sample size of two persons. If on these
costs with implementation of strong grounds our arguments are deemed hypothetical, or
science in reducing impact uncertainty perhaps even untruthful, we would gladly be shown
to be wrong if someone can generate compelling
data to the contrary.

On the practical side, EIA should be able to expe-


rience gradually reduced costs with implementation References
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