Creativity in impact assessments
Strategic environmental assessment (SEA) is a type of impact assessment (IA) that is meant to be almost a step back from project-based IAs. They are often described as being “broad” assessments that take place at the program or policy level (so before specific projects are proposed), thus giving them the potential to consider the environment early in the planning or development process. Because of this they also, in theory, have the potential to better consider broader and longer term issues like cumulative impacts and climate change, areas that project assessments have long struggled with.
I recently attended a training led by Maria Rosário Partidário (offered by the International Association of Impact Assessment). Partidário is a well known scholar of SEAs and has developed guidance for conducting SEAs that use strategic thinking rather than formats that mirror effects-based IAs. Over the course of this training she talked about how SEAs focused on strategic thinking are creative rather than reactive. That is, instead of being organized as a response to project proposals and the need to assess their impacts (something that requires the traditional emphasis on baseline conditions, VECs, impacts, and mitigation) the focus is on long term visions and goals and finding collaborative and creative ways of achieving these goals. Baseline conditions, which form a significant part of effects-based IAs may play a backseat role in this approach, if they are included at all. Rather, she stressed the need to understand the complexity of the systems and contexts in which a decision is made/an SEA is being done and using that to plan for more sustainable futures. In other words, you start at the end, with the future you want, and then work backwards to figure out how to get there.
This idea of “backcasting” has always been the appealing aspect of SEAs to me, especially as a method that could be used to help address and plan within the context of the current climate crisis. We know the future we want and need—one in which oil production winds down and more sustainable sources of energy are used—but we need to think outside the box and find creative ways to get there.
SEAs are intended to be more flexible than project-based IAs, which typically involve legislated guidelines for how they should be carried out and what factors should be included. This flexibility can be a good thing as it means that an SEA can take many forms and be conducted and organized in ways that fit the particular context. Despite this, in reality, they often look very similar to project-based IAs, which are focused on assessing impacts and suggesting mitigation. These effects-based SEAs, as we may think of them, are similarly organized around predicting the impacts of activities, just at a stage in development before specific projects are proposed.
My PhD work on the SEAs used for offshore oil exploration in Newfoundland and Labrador (NL) highlighted how this type of SEA can be limiting. NL’s SEAs are conducted by the oil regulator in the province and are meant to assess the potential impacts of exploration drilling in a region prior to the issuance of exploration licenses there—so before specific drilling projects are proposed and assessed. They follow a project/effects-based IA format, laying out existing baseline conditions, the potential impacts of exploratory drilling, and generic mitigation strategies. The point is for the regulator to use this information to inform its decisions about issuing exploration licenses. However, there isn’t space within these processes to question whether oil development (which is the purpose of exploration after all) should even be developed in the area covered by the SEA. Yet this moment—before licenses are issued and projects have been proposed—is exactly when these questions should be asked. And these questions need to be asked when considering future oil development if we are to take the climate crisis seriously.
As critical scholars, we are trained to analyze and critique, and in the context of IAs, this means pushing how we think about and understand the current and future role of these processes. For instance, incorporating a life cycle analysis of oil (including downstream emissions) in IAs may be challenging, but it is still a conversation we need to have as it forces us to confront key temporal and spatial aspects of development and policy that can’t be ignored in addressing climate change and climate injustices. As one of the few participants in the SEA training who was not an IA practitioner/consultant, it was valuable to hear the other participants’ experiences of conducting IAs and SEAs and their desire to implement more strategic versions—to find creative ways of working around and through the challenges of implementing this approach in the real world in order to work toward more sustainable futures.
As part of my work with the NEDIA project, I am continuing to explore the use of IAs in NL, specifically how regional assessments are being used in the province’s evolving offshore energy planning and development. The new Impact Assessment Act in Canada (2019) puts more emphasis on regional assessments than previous legislation and we are now seeing them in practice, particularly in NL, where one regional assessment has already been completed for offshore oil exploration drilling and another was recently started for offshore wind. With these two cases in NL, we are not only getting an early glimpse into the use/potential of this type of assessment but also how they fit into both provincial and federal energy and energy transition planning and development.