B7 Extractive industries - International Association for Impact

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Working Draft
Application of Regional-Sectoral Assessments (RSA) to Extractive Industries
Introduction
While experience with strategic environmental assessment (SEA) is increasing on
numerous fronts (Dalal-Clayton and Sadler, 2004), extractive industries are among the
sectors that stand to benefit from early planning and analysis. This paper considers the
application of regional-sectoral assessments (RSA) – a process which resembles SEA - to
extractive industries, reflecting on current practice as well as areas for further
development. This paper will present some experience with RSA from the petroleum
industry and is intended to initiate further consideration and discussion on the usefulness
of the process and the need for further developments in this area at the Prague
conference.
What do we mean by Regional–Sectoral Assessment?
For the Prague session, RSA is employed as an inclusive term to describe all assessments
of extractive industries beyond the single project level1. As implied by the name,
regional-sectoral assessments are focussed on the development of specific industrial
sectors in a defined area (e.g., petroleum development offshore UK). While RSAs may
be employed for a number of reasons; several potential objectives are listed below.
 To determine if an area under consideration is appropriate for the development of a
specific industry sector, taking into account sustainability criteria. To determine the
conditions under which development scenarios could be deemed appropriate.
 To facilitate the canvassing of public opinions, so that they can be taken into account
in decision-making.
 To integrate environmental, social and economic factors.
Unlike SEA, RSAs generally do not take into account alternatives to the development of
the industry sector involved. For example, an RSA might examine the appropriateness of
metal mining in a given area, but not occupy itself with the larger, strategic questions of
whether there are preferential alternatives to mining (e.g., increased recycling) (as
discussed by Noble [2000]). This implies that RSAs are distinctly different from SEA,
but nonetheless can play an important role in facilitating the consideration of
environmental and socio-economic factors in the planning process.
State of Current Experience
An increasing number of RSAs are being conducted. For example, the offshore oil and
gas industry has considerable and increasing experience with RSAs (e.g., SEA UK, REIA
Norway, SEA Brazil, SEA Atlantic Canada, Programmatic Review US). The
environmental implications of petroleum activities are considered at the regional level, in
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The term SEA is not used, recognizing that certain criteria for SEA (IAIA, 2002) are unlikely to
be met by RSAs. A discussion of terminology is welcomed at the Prague conference.
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some cases before areas are “opened” to development (Kirstein and Jeffrey, 2004). In
other cases, assessments with similarities to RSA are being conducted, although not
formally labelled as such. For instance, the province of Saskatchewan (Canada) has
conducted assessments of 20-year forestry management plans (Noble, 2004)2.
RSAs may be conducted for a variety of reasons. For example, in Norway the limitations
of project-assessments catalyzed the design of a regional environmental impact
assessment (REIA) process for the offshore petroleum industry. With revisions to the
Petroleum Act in 1997, offshore areas are now subject to REIAs, which contemplate the
acceptability of particular development scenarios (Kinn, 2004). It is likely that between
the coming into force of legislation and directives (e.g., EU SEA Directive 2001/42) and
recognition of the merits of broad-scale assessments (e.g., World Bank, 1996), the
ensuing experience with RSAs will increase over the coming years.
Elements of RSA for Further Consideration
As RSAs of extractive industries are becoming more common, questions on the quality
and effectiveness of current experience follow. Advantages and challenges of SEA have
been documented (e.g., Dalal-Clayton and Sadler, 1999; UNDP REC, undated); which
merit further consideration. As with any assessment process, RSAs must be “fit for
purpose” (i.e., have the quality needed for the decision to be taken) in order to realise
process benefits. Elements of RSAs are presented below in conjunction with some
examples of current practice.
Tiering – By informing project-specific assessments, RSAs could result in a number of
benefits such as protection of environmentally sensitive areas and net process
efficiencies. As an example, efficiencies have been realized as a result of the Norwegian
REIA process for offshore petroleum development. In this jurisdiction, some offshore
activities are exempted altogether from project assessment, providing they are consistent
with an REIA (Kinn, 2004). However, in other jurisdictions, similar exemptions are not
possible (e.g., in the UK, SEA should inform project assessment, but does not remove the
need for an EA [ODPM, undated]).
Participation - Participation has been identified as a fundamental principal of SEA
(IAIA, 2002). Incentives for stakeholder participation include clear process definition
and an understanding of how stakeholder input will be used (Gibson, 2004). It is
postulated that the role and definition of stakeholder engagement currently varies within
RSAs and may need to be further developed. The SEA process for offshore petroleum
activities in the UK is an example of a process that places an emphasis on public
participation. It is lead by a multi-stakeholder steering committee and includes an SEA
website, workshops and multiple opportunities for public input (DTI website).
Sustainability - Strong sustainability or keeping the sum of natural capital intact may not
be attainable for many extractive industries. Weak sustainability, on the other hand, is
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This list is not intended to be comprehensive. The authors welcome notification of other
examples of EI/SEAs –either at the Prague conference or beforehand.
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defined as the depletion of non-renewable resources at a rate equal to the development of
renewable substitutes (El Serafy, 2003a, b in Goodland, in press). We invite notification
of any RSAs that have considered the application of weak sustainability as part of the
assessment process.
On another level, there are further opportunities to consider sustainability in RSAs of
extractive industries. IAIA criteria indicate that SEAs should be sustainability-led (IAIA,
2002), further defined as the “identification of development options and alternative
proposals that are more sustainable” (IAIA, 2002). Although strategic decisions about
alternatives may not be part of RSAs, assessments should be able to take sustainability
into account by being structured on the basis of regional sustainability goals (e.g.,
environmental protection objectives, socio-economic goals).
Environmental Protection - From an environmental perspective, both opportunities and
challenges are offered by RSA. For example –
 Management provisions to guide development in a given area (e.g., technology,
timing, spatial scale) can be among useful outcomes of an RSA.
 Early environmental analysis can allow for the identification of sensitive areas, in
which development may require special management or could be prohibited
altogether, depending on the nature of the interaction.
 In considering a maximum level of activity, RSA can be the ideal forum to address
the cumulative environmental effects of an industry in combination with other
environmental pressures.
 RSA can be the framework within which baseline data can be collected as needed to
assess potential impacts, or simply a tool to push for the development of regional
strategies to fill data gaps, as necessary.
Benefits in Project Development - Benefits of RSAs from the perspective of industry
could include increased efficiencies at the project assessment stage (e.g., REIA in
Norway) and agreement on fair share approaches to the management of cumulative
effects. In addition, industry stakeholders would theoretically support RSAs due to the
investment certainty they may provide in areas under consideration.
Key Issues for Consideration
While new RSA processes are emerging, others continue to evolve and be refined over
time (Kirstein and Jeffrey, 2004). Taking into consideration the elements noted above,
the Prague session will reflect on current experience with RSAs of extractive industries,
focusing on the success of these assessments in meeting their objectives. Questions with
respect to the benefits and challenges of RSA will be discussed in concert with an
accounting of current practice.
Call for Papers
A session will be organized to examine the experience of extractive industries with
regional-sectoral assessments (RSAs). For the purposes of the session, RSA is employed
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as an inclusive term to describe all assessments of extractive industries beyond the
project level. The objectives of the session will be: (1) to account for experience with
RSA to date; (2) to highlight benefits and challenges of this experience; and (3) to reflect
on innovative practice and lessons learned. Discussions on the logistics of current
experience (e.g., Where is RSA being done? Why? How?), will be complemented by a
consideration of the success of RSA in meeting its objectives. Questions and themes for
discussion will include:
o experience of RSA with respect to tiering (links with project-EA and
SEA)
o experience of RSA in facilitating stakeholder involvement
o consideration of alternatives in RSA
o experience- or potential of RSA to consider sustainability
o benefits of RSA in project development
o benefits of RSA for environmental protection
o decisions being made on the basis of RSAs and the information required
to support these decisions
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References
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