Problem definition

An EIS requires that the proposed project be justified and alternatives considered. Both justification and the framing of alternatives will be shaped by the way the problem is defined that the project is supposed to be solving. For example, in the Sydney Harbour Tunnel EIS, the problem was said to be traffic congestion. Traffic built up and slowed down on the approaches to the Sydney Harbour Bridge, causing delays to people trying to cross the Harbour by motor vehicle. A second crossing was therefore justified, and alternatives framed, in terms of providing better road access across the Harbour.

Opponents to the Tunnel did not perceive congestion to be a problem at all. Ted Mack, Mayor of North Sydney at the time the EIS was displayed, argued that congestion shaped a city by encouraging the movement of people and businesses to other parts of the metropolitan area so that new centres of activity were established. Ross Blunden, emeritus professor of traffic engineering, argued that congestion encouraged people to change their journey times or take public transport. Both concluded that a second crossing, far from removing congestion, would merely attract more car traffic and that congestion on both crossings would be the eventual outcome.

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Scope—Impacts to be covered in EIS

The scope of what is to be covered in the EIS is also a matter of judgement and the way it is decided varies from state to state. In NSW, the proponent decides on the scope of the EIS after receiving some direction from the Director of the Department of Planning. In Victoria, the scope is decided in consultation with the public. A narrow scope can make a project appear more desirable. Using the previous example of the Sydney Harbour Tunnel, one can see that, whilst the proponents could argue that pollution would be reduced in the immediate vicinity of the Harbour because of the smoother flowing traffic, a broader scope would have ensured that the wider impacts of increased car usage were also taken into account.

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Data collection and analysis

The design of an EIS study requires judgements of what types of impacts will be significant and the collection of data requires decisions about the time period and area over which samples are collected, the species to be studied and the quantities of individual specimens to be collected, and more generally the scale of study. Such decisions are not made only on the basis of what might be considered by a scientist to be appropriate, but will also be affected by considerations of cost, time availability, previous studies and perhaps even likely outcome.

Similarly, methods of analysing data can vary in the sorts of results they produce and data they require and those preparing an EIS will choose the methods using many criteria, apart from the 'purely scientific'. Even where the method of analysis is uncontroversial, assumptions and judgements will need to be fed into the analysis. For example, a cost-benefit analysis for a road project will require estimates of the value of time saved and may require estimates of the value of bushland or open space lost to the community. Most EISs require some form of forecasting of population numbers or other human activities and this requires assumptions such as where people are likely to live and work and what their habits will be in the future.

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Data interpretation

Data collected and the results of analyses can be interpreted in a number of ways. Naturally an EIS is likely to present the most favourable interpretation that is available. Again Sydney Water Board EISs provide the most blatant examples. The results of a 1973 fish contamination study were reported in their EISs for the deepwater ocean outfalls. The study showed that heavy metals exceeded maximum residue limits in ten out of eighteen organisms (including fish and mussels) taken near the outfalls. At the time the study was done an internal memo states that the Board and its consultants were concerned about the results:

It was agreed that, while the data only represented analyses of individual specimens, levels of heavy metals and pesticides detected in this small number of samples were such as to suggest that a potential public health threat or environmental hazard might exist within the study area...

Yet when the EIS for the Bondi outfall was published in 1979, the Water Board actually stated that

"Whilst the statistical significance of the 1973 survey is not able to be clearly established the results are encouraging in that they indicate that no serious environmental problem existed even prior to the full implementation of source control of restricted substances..."

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Presentation

Even though real world engineering is fraught with uncertainties an EIS can be carefully worded to avoid any impression that anything is uncertain. For example, a draft environmental impact statement prepared by Byron Shire Council at the end of 1987 was given to me the week before publication. It contained the sentences;

" There should be little, if any, impact from the development, upon the S.E.P.P. 14 wetland within the site...

A less than satisfactory result in the performance of the works and associated artificial wetlands would result in a forced abandonment of the wetlands disposal option and cause Council to again pursue the ocean outfall option with its inherent high cost and public opposition."

These sentences were omitted from the final published version of the EIS and the following inserted in their place:

" Monitoring results indicate no effect on the adjoining wetland areas...

A close monitoring programme will enable Council to assess the performance of the proposed ponds and to determine the need for additional wetland areas."

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