Mitigation is a critical component of the EIA process. It aims to prevent adverse impacts from happening and to keep those that do occur within an acceptable level. Opportunities for impact mitigation will occur throughout the project cycle.
The objectives of mitigation are to:
- find better alternatives and ways of doing things;
- enhance the environmental and social benefits of a proposal;
- avoid, minimise or remedy adverse impacts; and
- ensure that residual adverse impacts are kept within acceptable levels.
Early links should be established between the EIA and project design teams to identify mitigation opportunities and incorporate them into consideration of alternatives and design options. In practice, mitigation is emphasised in the EIA process once the extent of the potential impact of a proposal is reasonably well understood. This typically takes place following impact identification and prediction, and recommended measures for mitigation will be an important part of the EIA report. Usually, these measures will be incorporated into the terms and conditions of project approval and implemented during the impact management stage of the EIA process.
The objectives of impact management are to:
- ensure that mitigation measures are implemented;
- establish systems and procedures for this purpose;
- monitor the effectiveness of mitigation measures; and
- take any necessary action when unforeseen impacts occur.
The adverse impacts and consequences of a proposal can occur far beyond the site boundaries of a project. In the past, many of the real costs of development proposals were not accounted for in economic analyses of project feasibility, particularly in the operational and decommissioning phases of the project cycle. As a result, these costs were borne by the community affected or the public at large rather than by the proponent.
Stricter requirements are now being imposed on proponents to:
- mitigate impacts through good project design and environmental management;
- provide benefits to the community affected by the proposal;
- prepare plans for managing impacts so these are kept within acceptable levels; and
- make good any residual environmental damage.
The responsibility of proponents to â€˜internaliseâ€™ the full environmental costs of development proposals is now widely accepted. In addition, many proponents have found that good design and impact management can result in significant savings. This outcome is similar to that found in industries applying the principles of cleaner production to improve their environmental performance. Like cleaner production, mitigation measures are more expensive in capital outlay but have been found to be cost effective over the long run.
The sustainability agenda is placing new demands on proponents with regard to mitigation and impact management. For example, increasing attention is being given to the principle of â€˜no net loss of natural and social capitalâ€™. Under the polluter pays principle, the application of this principle could require the proponent to make restitution for unavoidable residual damages. In this case, mitigation would include in-kind compensation measures, comprising equivalent, comparable or suitable offsets for all residual environmental impacts of a proposal.
EIA stage for considering mitigation measures
In the EIA Report the section for mitigation measures is often located after the evaluation section, that is after the analysis and comparison of alternatives has been reported. This gives the impression that first a preferred alternative has been selected, then second mitigating measures have been added to the project. This process may seem to be appropriate, but unless there has been a subsequent review of the alternatives the chosen one, with mitigation measures, may be a worse option. In particular the mitigation measures will add costs to the preferred alternative. It could be that in total the cost becomes greater than a second alternative that had less impact on the environment. In this situation the second alternative would have been preferable to the one chosen â€“ having both less impact and being less cost.
Consequently, the stage for thinking about mitigation measures should be before there has been a comparison of the alternatives. The point of considering safeguards before comparision is to encourage the analyst to think about the “extras” that may have to be added onto the basic proposal, before the evaluation of the proposal is undertaken. This will help to ensure that the comparison, or evaluation, of alternatives is conducted when all the relevant information and costs are included.
A crucial point to remember is that after safeguards are added to a proposal, the alternatives may become more attractive (eg cheaper).