Was the Environmental Assessment Adequate? - Mining and the Environment: From Ore to Metal - page 499

an internal project review, international i nancial institutions rely on external independent
experts to conduct environmental project reviews. Each type of review has its own approach,
review criteria and review documentation. The following text is predominantly concerned
with the independent third party review process.

Identifying Review Criteria

An EIA review does not set
out to refute fi ndings of the
environmental assessment or
to develop new conclusions
regarding potential impacts.

While the approach, methods and criteria differ, formal EIA reviews focus on a number
of common aspects. These include the 'triple A-test' of appropriateness (coverage of key
issues and impacts), adequacy (of impact analysis) and actionability (does the report pro-
vide the basis for informed decision-making?) (Sadler 1996). It is also important to realize
that an EIA review does not set out to refute i ndings of the environmental assessment
or to develop new conclusions regarding potential impacts. The focus of the review is on
identifying areas of strength and weakness, omission, or inaccuracy.
An EIA review needs to be based on specii ed review criteria, best developed on a case-
by-case basis by reference to the following questions (UNEP 2002).

Are Terms of Reference or other Guidelines Available and
Applicable for the Review?
Most national EIA guidelines require a terms of reference for EIA work, which provides
a useful framework for EIA review. If terms of reference do not exist, generic criteria to
guide the EIA review can be derived from some or all of the following information: (1)
legal EIA requirements; (2) relevant environmental guidelines and standards; (3) princi-
ples of EIA good practice as summarized in the Equator Principles; and (4) knowledge of
the type of mining project and its typical impacts and their mitigation. It is clearly impor-
tant that, at a minimum, the EIA must comply with the laws and regulations of the host
country. In addition most international i nancial institutions adopt the Equator Principles
as EIA good practice to complement national EIA guidelines.

Are Any Reviews of EIA Reports or Environmental Audits of Comparable
Proposals in Similar Settings Available?
EIA reviews of similar mining projects in similar environmental settings provide help-
ful insight to the main environmental issues associated with the project under review.
It is particularly useful if environmental audits on similar existing operations are avail-
able, since environmental audits may help to identify problems experienced during actual
implementation and operation.

EIA reviews of similar mining
projects in similar environmental
settings provide helpful insight
into the main environmental
issues associated with the project
under review.

When is a Comprehensive Review Appropriate?
At the outset of a review, particular attention can be directed to the executive summary,
which is intended to explain the key i ndings accurately and in a non-technical manner.
The quality of the executive summary may provide a i rst indication of the quality of the
EIA documentation. The presentation of the documents and the information contained,
may also provide some indication of the quality of the EIA. A comprehensive review of
the EIA extending into an independent analysis may be necessary in situations where seri-
ous dei ciencies in the information become apparent. The EIA review then becomes a
mini-EIA to supplement the EIA under review.

The quality of the executive
summary may provide a fi rst
indication of the quality of the
EIA documentation.