Level of impact assessments in Greenland

7. Synthesis

This chapter synthesises and discusses the results from the research. Further details regarding the different analyses and their outcomes can be found in the papers in the second block of this thesis. The papers approach the research area from different angles and each paper feeds into discussions related to one or more topics, as described in paragraph 4.5 and illustrated in Figure 4.1. The findings presented are chosen with a focus on extracting the most interesting and the critical results.

7.1 Level of impact assessments in Greenland

The understanding and knowledge regarding the context of SEA in Greenland as investigated in this thesis is focused on the status of and the need for impact assessment in general and SEA in particular. The first result to which I would like draw attention in this regard is the necessity to increase the strategic level of impact assessments in Greenland. This is first pointed out in Hansen and Hansen (2008) where the benefits of the aluminium SEA are discussed, based on an overall description of the process of conducting the first and, so far, only official SEA in Greenland. The conclusion regarding the need for a higher strategic level in the assessments is supported by Hansen et al. (2008), which more specifically investigates the level undertaken in impact assessments in Greenland. The investigation of the strategic tiering of impact assessments is based on a scale with four categories; project, programme, plan and policy level. Policy is the highest strategic level and project the lowest. The results show that the policy and plan levels are not yet included in impact assessments in Greenland, and only a few impact assessments at the programme level (six known by the author) have been conducted while more (nine known by the author) have been conducted on the project level. Some of the assessments are very detailed, but still, the results show that the action to which they are applied and the reflections regarding cumulative impacts and alternatives place them in the lowest strategic categories. This means that the impact assessments do not carry the possibility of proactively and strategically including environmental concerns in decision-making regarding the planning and implementation of new industries.

Based on the ongoing developments, Hansen et al. (2008) discuss the need for considerations at the policy and plan levels with regard to the environment. The types of strategic questions which could be raised in this respect are shown in Table 7.1, which also points to the need for assessing alternatives and their impacts in terms of needs and capacities. The extension and the types of industries which can operate without significant negative and irreversible consequences for the Greenlandic environment, and the effect which this will have on other policy areas, like labour and commerce, needs to be defined. This discussion has not yet taken place in Greenland and decisions in this respect are yet to be made. Hansen and Kørnøv (2010) also support the assumptions regarding the need for higher level impact assessments in Greenland. By investigating the Greenlandic context from a value rational angle, letting the impact assessment professionals in Greenland themselves define the need and demand for impact assessment in Greenland, it is pointed out that impact assessments in Greenland should cover both the project level and strategic levels to secure proactive inclusion of environmental knowledge and thereby ensure that they lead to more sustainable decisions. A

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gap is found in relation to the strategic level of the impact assessments. The environmental laws, even those that are still not implemented, only require impact assessments at the project level. However, both impact assessment practice and the expressed need/demand show that there is an interest and willingness to take the impact assessments to the strategic level, including both the programme and plan level of impact assessment. The policy level is not yet included in practice, neither is it formulated as a clear wish from the respondents.

Tier Type of questions which need to be raised

Basis for alternative assessment

Policy Whether or not to promote the

development of mega industry in Greenland?

Societal development needs

Plan The extent to which mega industrial

development must take place in Greenland?

Societal capacity

Programme Where to locate the industrial development in Greenland?

Regional and local capacity Table 7.1: Higher level SEA required in the case of mega industry in Greenland.(Hansen et al.

2008)

A second result supported by more investigations which I would like to underline is a lack of consistence in the content of the environmental reports and hence in the concept of environment covered. This is identified in Hansen et al. (2008), which presents a comparison of the environmental parameters included in four environmental reports, representative of the variety of the impact assessments undertaken in Greenland, with the parameters recommended in the European SEA Directive. The comparison illuminates a wide variety in the environmental parameters included and hence a lack of consistence in the content and concept of environment they cover. The lack of consistence can be problematic when cumulative impacts of more projects are to be considered, and the transparency in relation to the process undertaken is vague as it is not possible to see how the parameters are chosen among others. The parameters included in the four cases are illustrated in Table 7.2. The variation could perhaps be explained by the scoping phase of the impact assessments, which has probably led to certain parameters being identified as irrelevant to include. As the scoping is not explained and the choice of the parameters included are not argued, however, the scoping and related reflections are not visible. The transparency and potential reflections behind the content are not visible and hence it is not possible to learn from the knowledge and experience related to this to apply in future situations. In Hansen and Kørnøv (2010) it is further shown how the legislative system in Greenland does not yet include the broad concept of environment, known from the EU Directive and other developed countries. But looking into practice in relation to the four impact assessment cases reviewed, it seems that more parameters than those prescribed in the law are taken into consideration. The variation in the parameters included can be explained as a consequence of the different and inconsistent laws in relation to minerals, on the one side, and industries on the other, as the different statutes require the inclusion of different parameters. Still the cases go beyond the

73 legal requirements in their descriptions, which could indicate the need for a broader concept of environment, to be able to give the full picture of the impacts of a certain project. The results from the analysis of values and interests of the professionals draw the same picture, as they show that all respondents find all the mentioned parameters relevant.

Environmental parameter

Case 1 Case 2 Case 3 Case 4

Biodiversity

Fauna/Flora √ √ √ √

Soil √

Water √ √

Air √ √ √

Population √

Human health (√) √ √

Climatic factors √ √

Material assets √

Cultural heritage √ √

Landscape √ √ √

Interrelationship √

Table 7.2: Illustration of the parameters recommended in international guidelines that are included in four impact assessments reviewed (Hansen et al. 2008).

The analysis in Hansen and Kørnøv (2010) thus shows a demand for impact assessments to include a broad range of parameters, covering more than the physical environment. However, the impact assessment practice shows great variation in the breadth of the parameters included and the depth to which they are assessed in the reports. It should be noted that Table 7.2 is changed for ‘Case 1’, which is the aluminium SEA. Since Hansen et al. (2008) was written, a closer investigation of the environmental report has revealed that, even though health is mentioned in the text, no issues are identified or mitigation recommended and hence no assessment in relation to health has been carried out. Therefore parenthesis is added to ‘health’ under Case 1. The lack of consistence in the environmental reports points to a lack of common legal requirements for environmental assessments carried out in Greenland, as there is no shared concept in the legal acts and guidelines used. This is also backed up by the public opinion expressed in interviews with members of the public, who expressed their worries in relation to environmental protection in the study conducted by Hansen and Vium (2009).

The third main result, which I will underline in relation to the status, need and function of impact assessment in Greenland, is that there are gaps between the needs expressed by

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professionals, legislation and practice in relation to the values and process for carrying out impact assessments. In Hansen and Kørnøv (2010) besides the results regarding impact assessment tiering and environmental parameters included, there are results that relate to values for impact assessment performance, responsibility and impact assessment involvement and access. All the gaps found are illustrated in Table 7.3. Remarkably, the gaps are mainly between the legislative framework and the needs/wants, while the practice and the needs/wants are closer to agreement. The exception is involvement in the process and access to the impact assessment results. Here the gap is related to both legislation and practice.

The needs/wants are actually a combination of the two others. The legislative system is focused on securing the environment through impact assessment, the large,international/multinational corporations interested in operating in Greenland conduct the impact assessments, and consequently the companies focus on conducting a good impact assessment to be able to gain permission to act. 16 Environmental professionals from Greenland find that the role of impact assessment is to balance the need for industrial development with the need for environmental protection.

Strategic level

legislation Needs and wants Impact assessment

practise

Table 7.3: Gaps between needs/wants, impact assessment legislation and impact assessment practice in Greenland (Hansen and Kørnøv 2010).

Regarding responsibility, the analysis shows overall coherence between needs/wants, legislation and practice.

The second main gap is found in relation to needs/wants regarding involvement in the impact assessment process and access to the impact assessment results. As presented, the respondents agree on the need for a broad inclusion of stakeholders in the process and that stakeholders in general must have access to the results. Legislation, however, lacks clear statutory guidelines securing involvement and access to information. Limited access to environmental information has also been experienced in practice when the authors were trying to obtain environmental statements in Greenland.

With respect to the assessment process and participation, both practice and legislation are inconsistent with the expressed needs and wants. The legislation did not demand or motivate

75 public participation early in the decision-making process, or secure access to the impact assessment statements, and due to confidentiality some statements were not accessible to the public. The public has now gained access to the environmental statements.,But still the public do not have the opportunity to participate in the early part of the process. The Bureau of Minerals and Petroleum plans to conduct SEAs on a mandatory level (Rusbjerg and Hesseldahl 2010). The newest case studied, the SEA of aluminium smelter, however, points to a development of practice bending towards the expressed wants. In this case, openness in the process and access to the statements were secured, so this is seen as a step towards closing this gap.

Summing up, the results point to a need for the safeguarding and enhancing of public participation and access to the environmental statements. Further, the current industrial development in Greenland, along with climate change, points to the need for a strategic impact assessment covering the plan and programme level of decision-making in order to reduce the gap between wants/needs and the reality. This includes assessing alternatives and their impacts against the needs and societal capacities, which leads to questions like: How intensive an industrial development should be allowed?, Which industries can operate without significantly negative and irreversible consequences for the Greenlandic environment? and, How will this affect the environment and society cumulatively? This discussion has just started and no decisions have been taken in this respect (Hansen and Kørnøv 2010).

Tier Type of questions which need to be raised Basis for alternative assessment

Policy Whether or not to promote the development of mega industry in Greenland?

Societal development needs

Plan The extent to which mega industrial development must take place in Greenland?

Societal capacity

Programme Where to locate the industrial development in Greenland?

Regional and local capacity Table 7.4: Higher level SEA required in the case of mega industry in Greenland.