Comparative practice - Introduction to Environmental Impact Assessment - page 314

part is mandatory. If, after reviewing the EIA, the Ministry considers that the project will
have significant environmental impacts, it can also require the EIA to address some of the
aspects in the second part:
Part I EIA contents
1. executive summary;
2. antecedents (e.g. applicable legislation);
3. introduction (project description and estimated cost);
4. project area description (general information about location, geological and biotic
components, etc.);
5. project description (e.g. estimated volume of water used, wastewater and wastes
produced, energy demand, employment, etc.);
6. predicted impacts (human health, flora and fauna, ecosystems, etc.);
7. control and mitigation (e.g. measures to control noise and dispose of wastes);
8. cost—benefit analysis.
Part II Additional information
1. project alternatives (description, justification of chosen alternative);
2. affected environments (detailed studies of continental and marine waters, etc.).
Every EIA must include an environmental management plan which lists the activities and
programmes to be implemented before and during the project to guarantee the fulfilment
of existing environmental standards and practices. It must also include a programme to
incorporate new technologies and alternative measures into mining activities so as to
reduce emissions or discharges.
The resulting EIS is reviewed by the Ministry's environment directorate. In theory,
this review should be carried out within 45 days, or else automatic consent is granted. In
practice, since the ministry has 45 days “after receiving the EIS and/or additional
information”, and since the relevant directorate only has eight officers, who also have to
deal with other matters, the officers often request additional information so that they have
longer time to review the EIS. Until 1996, only the EIS's non-technical summary was
publicly available; the main body of the EIS was felt to be commercially sensitive and
thus confidential. However, Ministerial Resolution 335-96-MEM/SG requires that a
public inquiry should be held before a decision is made.
Once a project is approved, the developer must carry out programmes of management,
control and monitoring throughout the operations to ensure that the environmental
management plan is adhered to. The developer has to contract a registered auditing
consultancy to inspect its activities twice a year. The consultancy must prepare a report
on activities at the site and submit it to the Ministry, which can apply sanctions for non-
compliance.
Peru's EIA system is typical of that of many South American countries in its relative
lack of public participation or sectoral integration, and frequent preparation of the EIS
after the project construction has begun (Brito & Verocai 1999). A survey of
environmental consultants showed that almost two-thirds of EISs are begun after the
project planning is “more than 50 per cent completed”, with the sections on control,
mitigation and cost-benefit appraisal being particularly difficult to carry out. Early