Whatever happened to environmental assessment?
I am sorry to be banging on once again about what I used to do once. But there was a time, not long after I arrived in Canada, when I first got involved in environmental assessment. It was a departure for me, since up until that time I had done economic appraisals of projects using social cost benefit analysis. These did not, as some assert, ignore externalities but attempted to evaluate them using a similar metric to other variables. In the same way that we converted time to money – and put a value on life and noise – we attempted to produce as fair an appraisal of projects as we could – and it was much broader than the simple cash flow spread sheets used by P3 projects today. In Ontario in the early 1990s new legislation required an EA of every new major project to be funded by government. Cynics in the press called this the Consultants Relief Act – since it seemed that much more was spent on project appraisal than actually building things. In some respects this was no bad outcome. For instance, I helped the Township of Clarington fight a gargbage dump. I thought it was about the impact of trucks on neighborhoods – but I was given a very fast lesson in the effectiveness of citizen involvement – and the effects of leachate on water quality (neither something they taught me at LSE).
Ontario used to have a very thorough EA process – I managed a study of the a proposed extension of the TTC subway yards, and in order to get an approval all our site criteria changed so that we could avoid the need for massive impact studies. We simply did not have the budget to do them. I was also around when BC adopted an EA process and was on the steering committee of one of the first projects that fell to it – the proposed new town at Bamberton.
In BC our EA process was gutted by Kevin Falcon, as part of his short reign as Minister of Deregulation. The political direction was simple – anything that gets in the way of the private sector making money must go. And that is pretty much what happened. While major projects are still subject to an EA process, the outcome is never in doubt. It will happen – and the only thing that gets discussed at all is how “mitigation” is going to get the project through. Even if the sites offered in mitigation are already in use as mitigation for other projects (which was the case on Highway #1) or are completely inadequate (SFPR). Incredibly the SFPR evaluation also recorded the impacts on human health from diesel exhaust as an economic benefit because it would create more jobs for health care workers!
I did not know until today that Ontario’s EA process has been similarly undermined. I was sent a link to Railroaded by Metrolinx by its author. I read with increasing dismay how the EA process has been distorted there – and for similar reasons. The outcome of the assessment is predetermined by government. In this case an expansion to Toronto’s commuter rail system – which will be by continuing to use diesel trains. It would appear that the option of electrification was not given serious thought. The author is clear about her point of view – she is one of the people called NIMBYs who is personally going to be impacted. But she is right in thinking that politicians who want to seen to be effective quickly forget that they are supposed to have a broader view of their responsibilities than having a ribbon to cut.
It reminded me forcefully of how the Canada Line suddenly appeared to be Translink’s greatest priority. Prior to that Translink staff (not me actually) had been looking at the Evergreen Line – and had actually completed an objective assessment of its routing and technology choice. That was pushed aside by one man. Ken Dobell, former City Manager for Vancouver and subsequently Deputy Minister to the Premier, wanted a subway under Cambie to the airport. And that was decided before any studies were done – and all studies subsequently were designed to support that conclusion – even if the data had to be bent to fit. For example it was stated that the slope up Cambie past City Hall was “too steep” for light rail – even though some simple use of the City’s own GIS maps showed the average grade was within spec (less than 6%) and I had pictures of ancient Lisbon trams climbing 10% grades. And of course the Arbutus Corridor was rejected out of hand – not enough “attractions” on it – as though Queen Elizabeth Park and Langara Golf Course would bring in lots of commuters.
Distance changes the view, of course, and from the perspective of Toronto our electric train to the airport looks a lot better than their diesel trains. Which, of course, is the whole point about the assessment process. Almost any study can be predetermined if you chose the terms of reference carefully enough. So, for example, with P3 power projects, no one is allowed to question need – or to ask if conservation might provide a lot more usable power more cheaply. With the Port Mann Bridge there was no option other than the project examined at all. Only a “do nothing” scenario – and later some “paper tiger” transit options designed to fail. When I started using CBA, in Britain, we used it to compare a whole long list of projects – and then only the top few actually got funded and built. It was a way of prioritizing within a programme. Even then I got a lot of stick from my engineer colleagues when I started doing comparisons of traffic management schemes to road building: traffic management rates of return on capital employed were always far ahead of road building.
What is happening now, nearly everywhere, is that all sorts of projects are being rushed to become “shovel ready” so they can get stimulus funds. As usual crisis management is a handy excuse to push through all sorts of half baked pet projects. Economists are in most places now pariahs, due to their complicity in the financial chaos – though that may be unfair on many in the profession. There is not much time or consideration given to analysis when “something must be done”.
One of the reasons people make bad decisions – or rather make decisions which turn out to have unforeseen consequences – is that reason often has very little to do with the process. This is as true of major government and business choices as it is about household choices about major purchases. Emotion always plays a much bigger part than people are willing to acknowledge - but is the reason why there is such a huge growth in the persuasion industry. And the same skill set is used by marketers, advertisers, communications specialists and lobbyists. None of them deal objectively with facts and figures – it is all spin and sound bites, determined by polls and focus groups. No one in the establishment wants to see this change. They think they can control the process – and on the evidence of the last BC election they seem to be winning. But that is going to be short term, hollow victory – and we will all be paying the cost, as our planet rapidly becomes uninhabitable. Simply because we did not care enough to do the job of evaluating our options properly.