FCSB LECTURE SERIES NO.

Environmental Impact Assessment

(EIA) Input to Sustainable Forest
Management (SFM) of the Tropical Rain
Forests of Malaysia: Some Fundamental
Considerations

By

BORHAN Mohd,
ForestCare Sdn Bhd (FCSB),
No. C6672 Km 11, Jalan Air Molek – Tiang Dua, Melaka 75460,
Malaysia.
Tel: +6016 2880050; +673 8641355; email: Forestcare2002@yahoo.co.uk;

January 2015
 INTRODUCTION:
REQUIREMENTS FOR GOOD SFM
1. Sound ecological / scientific/ technical foundation;
2. Sound database from MRI of forest products & services;
3. Ecosystem- & species-level prediction tool (inc. g & y,
EI, SI, market trends, etc);
4. Economic viability & technical feasibility of management,
silvicultural operations & environmental protection
measures
5. Stable land-use strategy, resource mgt
objectives & long-term tenure;
6. Integrated strategic & tactical planning for V-added
multiple-use forestry (incl. downstream processing);
7. Stakeholders’ consultation & involvement;
8. Managerial competence & commitment
to SFM & SD.
 BACKGROUND & ROLE OF EIA
IN SFM CERTIFICATION &
ECOLABELLING

 Benefits of SFM certification

 Many schemes & standards developed: local, regional &
international
 FSC P & C set out the technical, economic,
environmental & social requirements for
“good forest management”
 FSC’s principle no. 6 on EI -- EIA & EMP necessary
 ISO 14001 EMS, ISO14020s Environmental Labelling,
LCA, CBA
 EA is more focused on environment per se.
Issues & considerations….

1.0 EIA Process

 Definition of EIA: The systematic
identification & evaluation of the potential impacts of
proposed projects, plans, programmes or legislative
actions relative to the physical-chemical, biological, cultural
& socio-economic components of the total environment.

 An ideal EIA should

(i) apply to all projects & address all significant impacts;
(ii) compare all possible alternatives;
(iii) result in clear EIS;
(iv) involve public consultation & stringent review procedure;
(v) be timely;
(vi) be enforceable;
(vii) include monitoring & feedback procedures.
Issues & consideration … …EIA Process..
Problems:
(i) poor/ wrong timing;
(ii) enforcement & monitoring;
(iii) poor attitude on EIA;
(iv) interpretation & application of Section 6 of EQO 1987
(Prescribed Activities – EIA) w.r.t Forestry.

Section 6 of EQO 1987

a. Conversion of hill forest land to other land uses covering an area of 50 ha or more
b. Logging covering an area of 500 ha or more
c. Logging or conversion of forest land into other land uses within the catchment
d. Area or reservoirs used for municipal water supply, irrigation or hydro-power
generation or areas adjacent to national and state parks and national marine
parks
e. Conversion of mangrove swamps for industrial, housing or agricultural uses
f. Covering an area of 50ha or more
g. Clearing of mangrove swamps on islands adjacent to national marine parks.
 Issues & considerations…
2.0 EIA Methodologies
 Activities in EIA (i) impact identification; (ii) description of the affected
environment; (iii) impact prediction & evaluation; (iv) selection of actions
from proposed alternatives to meet identified needs; (v) summarisation &
communication of information

 7 types of methodologies (I) interaction matrices; (ii) networks; (iii)

checklists; (iv) ad hoc; (v) overlays; (vi) quantitative or index; (vii)
modelling.

 Matrices most popular due to perceived better value in impact

identification and display of comparative information on alternatives

 There is no universal methodology for all project types in all

settings.

 Methodologies can be useful through not specifically

required throughout the impact assessment process.

 It is not necessary to use a methodology in its entirety in an impact

study; it may be instructive to use portions of several methodologies
for certain requisite activities.
Issues & consideration…
3.0 Writing & Reviewing
3.1 Format
 General format:
Chapter 1 – Introduction;
Chapter 2 – The site and surroundings;
Chapter 3 – About the project;
Chapter 4 – Environmental effects of project
operation;
Chapter 5 – Evaluation and analysis of impacts;
Chapter 6 – Environmental management plan
(EMP);
Chapter 7 – Environmental monitoring programmes.
 A sound EIA should have at least three analytical
functions: identification, prediction, and
evaluation.
Identification:
- Description of existing environment
- Determination of project components
- Definition of the environment modified by the project
- Information on the environmental impacts of proposed
activity & its alternatives, incl. an environmentally
friendly alternative
- Comparison of all (relevant) alternatives
Prediction:
- Identification of significant environmental modification
- Forecasting of the quantity and/ or spatial dimensions
of impacts identified
- Estimation of the probability that the environmental
change will occur (time period)
Evaluation:
- Determination of costs and benefits incidence to
stakeholders
- Comparison of the trade offs between alternatives
- Survey of gap of knowledge
- Compare impacts with environmental objectives and
standards
Issues & considerations…
3.2 Scientific Contents

Need for a clear scientific basis for:

(a) scientific boundaries;

(b) quantification;

(c) modelling;

(d) prediction;

(e) study design.

Issues & considerations…
3.2 Scientific Contents
a. Boundaries: time & space boundaries (i) administrative
boundaries; (ii) project boundaries; (iii) ecological
boundaries; (iv) technical boundaries.
b. Quantification: Main constraint is the extreme variability in
natural ecosystem. This affects true experimental control
under field conditions – sampling programme – confidence
limits
c. Modelling: Conceptual and quantitative modelling useful.
But ecological effects modelling problematic.
d. Prediction: EIA is about prediction. Generalised & vague
statements. Lack of confidence in predictions increases with
time and distance form source of impact. Distinguish between
firm prediction; forecast based on experience, professional
judgment; outright guess.
e. Study design: No direction on study strategy/ framework for
investigation. Use experience from other similar projects.
May consider project in an experimental context around the
need to verify hypotheses.
Issues & considerations…
3.3 Reviewing & approval

 Good science is one which is acceptable to the scientific

community as determined by peer review, thus giving basis
for assessing impacts in EIA.

 But, time & political constraints always preclude the adoption

of more rigorous scientific approaches to EIA.

 Main issues considered during review

process: is the document adequate?
Are all impacts of proposed actions
addressed? Is EIA report scientifically
& technically sound?
– credibility of study !
Issues & considerations…
3.3 Reviewing & approval
 Review process in Malaysia:
(a) Preliminary assessment report reviewed by DOE internal
committee --- 1 month
(b) Detailed assessment report reviewed by ad hoc review
panel --- 2 months.

 DOE maintains a list of experts in the review panels

 Issue: Peer review done too late, at end of process. Its utility
questioned.

 Proposed solutions: (1) external scientific evaluation during

conceptual & design phases of IA studies. (2) Independent
body to prepare draft guideline, review reports, impartial &
serves as info. Desk to improve overall performance of EIA.
Issues & considerations…..
4.0 Monitoring
 Monitoring & surveillance by project owner

 Monitoring provides early warning of

adverse impact (predicted or not) are occurring.

 3 types of post-implementation monitoring:

(i) Implementation audits: recommendations implemented?
(ii) Project impact audits: assess actual impacts of project
(iii) Predictive techniques audits: assess predictions in EIA, to
aid in future studies.

 Issues: (I) frequency of monitoring; (ii) manpower; (iii)

enforcement.
Issues & considerations…
5.0 Coordination & Communication
 Project initiator should submit EIA report to DOE at project
identification stage.

 Late submission reduces the value of EIA

– increase environmental costs; delay
implementation.

 Problems in Communicating EIA findings

(I) policy & decision makers not technically
trained (ii) Expectation gap between
decision makers & realities.

 EIA users should: (I) understand the probabilistic nature of

science; (ii) accept uncertainty in environmental science; (iii)
manage adaptively & plan for surprises; (iv) avoid tight
timetables; (v) participate in assessment process; (vi) prepare
to pay for quality and wait for it.
Issues & considerations ….
6.0 Emerging Developments in EIA
 Many aspects of EIA which were earlier considered
as a section of an EIA have now emerged and
developed into specific area in their own right.

 Examples:
(i) cumulative effects assessment to assess
regional impacts (CEA);
(ii) strategic level EIA to assess the impacts of
policies (SEA);
(iii) social impact assessment (SIA);
(iv) environmental risk assessment (ERA); and
(v) environmental health impact assessment
(EHIA).
Issues & considerations …
6.1 Cumulative effects assessment (CEA)

 CEA refers to the accumulation of changes in

environmental systems over time and across space
in an additive or interactive manner

 CEA: a process of systematically

analysing and assessing cumulative
environmental change which may
originate from actions that are single
or multiple, and similar or different
in kind.
Issues & considerations…
6.2 Sectoral environmental assessment
(SEA)

 For adequate evaluation of alternatives & impacts

which cannot be fully considered at project level.

 E.g. “macro-EIA” covering a wider area than a

single logging block, such as a forest reserve or
even an entire state as a single FMU

 SEA may cover cumulative impacts

between projects, policies &
programmes.
Issues & considerations …
6.3 Environmental risk assessments (ERA)

 The qualitative & quantitative evaluation of environmental

status to determine the risk posed to human health and the
environment by the presence, potential presence, or use of
specific pollutants

 ERA attempts to address 3 basic questions: (I) what can go

wrong with the project? (ii) what is the range of magnitude of
the adverse consequences? (iii) what can be done and at
what cost to reduce unacceptable risk and damage?

 2 disciplines of ERA: (I) human health risk assessment

(HHRA); (ii) ecological risk assessment (EcoRA).
 Issues & considerations …
6.4 Environmental health
impact assessment (EHIA)

Factors to consider:
 Regulatory criteria

 Institutional information

 health effects at individual & population levels;

 Evidence

 Level of confidence in dose-response relationships

 Level of confidence in exposure estimates;

 Public perceptions related to the health effects.

Issues & considerations …
6.5 Social impact assessment (SIA)
 To identify and quantify the impacts
on human populations resulting
from changes to the natural
environment;

 People should have the opportunity

to participate in designing and
determining their future

 Investors & developers have duty to

fulfill their public obligations & social
responsibilities, I.e not enough to
just comply with relevant laws.
1.0 EIA is a dimension of the planning process
2.0 Environmentally friendly alternatives create
possibilities of breaking new grounds:
e.g. RIL technologies through re-tooling
& re-designing of harvesting methods;
erosion control; slope stabilisation;
re-forestation techniques, etc.
3.0 Sustainability paradigm has caused re-thinking of
scientific & institutional framework in response to
sustainability ideas & imperatives. These had benefited
certification & eco-labelling.
4.0 Can FMP (Forest Management Plan) take the place of
EIA report ? How about coordination? Legislative
framework? Review procedures? Etc.?
5.0 Future EIA must consider new emerging areas
6.0 EQA & EIA regulations & enforcement need
strengthening in order to play a more meaningful role in
SFM