Citation: Sharon Beder, 'Environmental Impact Statements - The Ethical Dilemma for Engineers', paper delivered to the National Engineering Conference, Canberra, April 1990.

This is a final version submitted for publication. Minor editorial changes may have subsequently been made.

Sharon Beder's Other Publications

Engineers who are involved in putting together Environmental Impact Statements are often faced with an ethical dilemma. The dilemma arises when there is a conflict between an engineer's duty to an employer or client and a duty to the welfare of the wider community. Although the Institution's Code of Ethics is quite unambiguous that the duty to the public should always come first, there is no institutional or professional support available to the engineer who loses a job or business as a result of putting that interest first. Environmental protection should not depend on the willingness of individual engineers to sacrifice career and prospects when such a conflict arises. Yet this is the situation in Australia at present.


The first problem is that environmental impact statements are done by or commissioned by the proponent of a project or development. The engineer working on that impact statement is therefore, either directly or indirectly, employed by a party whose interests may differ in significant ways from the public interest. The immediate objective of their employer will be to get approval for their project to go ahead even though that project may have an adverse impact on the environment and on local residents.

Because the environmental impact statement is done rather late in the planning process the project proponent will almost certainly have committed considerable financial resources to a particular option at a particular site. From their point of view they will have balanced the community costs against their benefits and decided the project should go ahead. The environmental impact statement at this stage becomes another obstacle in a field of bureaucratic hurdles on the way to their end goal. But on top of this it is a public document that will be scrutinised by local residents, bureaucrats, politicians and environmentalists.

Naturally, they will want that document to emphasise the advantages of the project to the community and to downplay the disadvantages. To a large extent that environmental impact statement becomes a sales document for the project. Any expression of possible adverse environmental effect or even any mention of uncertainty will certainly be grabbed by opponents of the project, magnified and used against them. 

i) Careful Use of Language

The EIS is therefore carefully worded to avoid any impression that anything is uncertain even though real world engineering is fraught with uncertainties. 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.1

These sentences were omitted from the final version of the EIS as published and the following inserted:

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.2

ii) Favourable Interpretation of Data

Environmental impact data is, of course, interpreted in the most favourable light. This can be taken to extremes however. The Sydney Water Board reported on the results of a 1973 fish contamination study in their 1979 EIS's for their proposed extended ocean outfalls. The study showed that heavy metals exceded maximum residue limits in 10 out of  18 organisms (including fish and mussels) taken near the outfalls (see Table 1). At the time the study was done the Board's consultants, Caldwell Connell Engineers, felt these results were a cause for concern. They reported in October 1973 that:

A meeting of personnel involved in various aspects of the study was held at the Australian Museum on the morning of October 18, 1973 to discuss the findings and develop recommendations... 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... Examination of the gut contents of a number of species of fish in the outfall areas shows that they derive a large percentage of their diet from food particles in the sewage. These fish, in turn, may constitute a significant proportion of the diet of persons who regularly fish in these areas.3

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... 4

iii) Omission of Data

Even more reprehensible than glossing over uncertainties and giving overly favourable interpretations of scientific findings in EIS's is the omission of relevant findings altogether. But this also happens. In the same Water Board EIS's at least two other studies of contamination of fish undertaken by the Fisheries Research Institute of fish in the vicinity of the ocean outfall sites were omitted.

In one study seven out of eight blue groper sampled from Manly waters were above the NH&MRC maximum residue limits for mercury and one red morwong out of eight was also over. In the other study red morwong and blue groper caught near the sewage outfalls were found to be accumulating dieldrin and DDT and of the 58 red morwong sampled, ten exceeded NH&MRC limits for dieldrin and five exceeded those limits for DDT. Several more were just under these limits for dieldrin and DDT.5


Engineers are put in a difficult position when they are expected to put together an EIS in a way that may not represent the situation properly. Yet if they refuse they risk their career or business. An engineer's career prospects are even more dependent on an employer's assessment of their loyalty and reliability than their technical skills or engineering knowledge. The employee/employer relationship is necessarily one based on trust. The employer's judgement in this regard crosses organisational boundaries through the referencing system for job applicants. Engineers seldom have the sort of independent reputations that scientists build up through publications and therefore lack the autonomy that scientists and self-employed professionals have.

Even as consultants, engineers are dependent on the judgement of clients and that judgement is based on whether they are perceived to be able to deliver what is required by the client. Consultants with overdeveloped consciences, who do not put the client's priorities first, are less likely to be given work in future. In many fields the number of potential clients is very limited and consultants with troubling tendencies toward social responsibility will soon be well known.

The options for an engineer who feels the full environmental costs of a project are not being honestly reported are usually constrained by conditions of employment or an unspoken agreement that they do not reveal information about the project to the public or confer with  community groups opposed to the project without permission.

Even outside engineers who speak against engineering projects can suffer retribution from other engineers, employers and potential clients. I myself have been  accused of attacking the integrity and good reputation of the engineering profession for criticising the Sydney Water Board's sewerage system and threatened with a complaint being made against me for breaching the Code of ethics. This threat came to nothing but an engineer in Coffs Harbour has had formal complaints made against him for breaching the Code of Ethics for criticising a proposed ocean outfall for Look-At-Me-Now headland.6 The Code of Ethics is clearly being used to silence engineering critics rather than to ensure that engineers put the public interest first.

It is naive to maintain that an engineer working on an EIS can be objective or neutral under these circumstances. It is also unfair that engineers should be put in the position of choosing between their career and environmental protection. Yet as the situation stands, many engineers have to tie their own advancement to that of developers and as a result they are increasingly identified, by the public, as being part of the ugly face of development and environmental despoilation. The solidarity of engineers in defence of each other's projects does not help this image. Engineers would be better respected by the community if they were often represented on both sides of a controversy, like scientists, than always to be on the developers side.


The most obvious need is for EIS's to be done independently of project proponents. This does not mean that project proponents would not pay for environmental impact statements. Nor that there would not be close consultation between engineers working for the project proponents and those doing the environmental impact statements. But the key decisions about which consultant firm would be employed to do the EIS would be made independently and a firm which compiled an EIS that lead to the abandonment of a project would not be penalised for doing so by being denied EIS work in the future. Of course such a body which allocated EIS work would have also to be independent from government because of the prevalence of government projects that would have to be assessed.

There is also a need for engineers to receive an education which will allow them to know when the environment is being endangered, will give them a respect for the environment and will foster a heightened sense of social responsibility so they will act on what they know. Environmental education should permeate engineering courses - not be sectioned off as a specialist environmental engineering course (although there is a place for these as well). Ignorance may be bliss - the ethical dilemma does not arise if you don't know there is a conflict - but it is not conducive to good engineering and only perpetuates an image of engineers as environmental vandals.

Finally, there is a need for the Institution of Engineers to support engineers who do choose to jeopardise their careers in fulfilling the first tenet of the Code of Ethics - that the welfare, health and safety of the community should come before their responsibilities to the profession, to employers or to other sectional interests. Such engineers should be applauded by the profession, not condemned. Contrary to old-fashioned beliefs, such engineers enhance the image of the profession and elsewhere they are honoured. For example the Institution of Electrical and Electronics Engineers in the US give annual awards for engineers who blow the whistle to protect the public interest.

If engineers want to improve their public reputation and attain high standing in the community then they must break away from their crippling dependence on employers and create a separate identity, a separate set of values, a separate status system. Autonomy is the hallmark of professionalism which engineers lack. It should be the goal of the Institution of Engineers for the next decade so that engineers can enter the new century with their heads held high.


1. Byron Shire Council, ‘Byron Bay Sewerage Augmentation Environmental Impact Statement’, draft, December 1987, pp. 5,12.

2. Byron Shire Council, Byron Bay Sewerage Augmentation Environmental Impact Statement,  December 1987.

3. Caldwell Connell Engineers, Reconnaissance Survey of Heavy Metal and Pesticide Levels in Marine Organisms in the Sydney Area, October 1973.

4. MWS&DB, Environmental Impact Statement Bondi Water Pollution Control Plant, 1979.

5. Sharon Beder, Toxic Fish and Sewer Surfing, Allen & Unwin, 1989, chapter 3.

6. Ibid., p.142.