Alternatives in EIA: fool’s gold?

 Environmental Impact Assessment (EIA) has been described as a tool to limit the impacts of a project on the environment. However, by demanding the consideration of alternatives, it aims for more by finding the best way to achieve the desired result. Furthermore, in Bram Noble’s words,  “the consideration of alternatives is a central element to good-practice EIA and is described by the US Council on Environmental Quality as the heart of the EIA process” (Noble 2010, p85). However, is the inclusion of alternatives in EIA fool’s gold? This will be discussed using for case study the Keystone Pipeline XL project being proposed by Canadian Pipeline giant TransCanada.

When analyzing the EIA prepared for the Keystone pipeline XL, it is hard to find many faults. Overall, it was well prepared by the consulting team, in good faith, and seems to go above and beyond what is often found for other projects. In term of overall quality, it is without a doubt one of the strongest EIA’s to have been prepared. However, when reading the sections on alternatives, one is left scratching his head. First of all, these mostly focus on alternate routes for the pipeline, rather than actual alternatives to the project (Figure 1).

Most of the alternatives in the EIS focused on various routes rather than different ways to transport the oil

Most of the alternatives in the EIS focused on various routes rather than different ways to transport the oil (EIS, 2011)

These are important, but are not the main objective of the section. As Noble defines it, “alternatives to a project are functionally different ways of meeting the need and purpose of the described project” (Noble 2010, p85). The consideration of different routes does not meet this standard. However, when the EIA does discuss different means to transport the oil (Image 2), it is evident that these options were never seriously considered. Instead, these alternatives were included in the report solely to satisfy the government and were quickly dismissed using mostly economic arguments rather than environment based reasons as would be expected for EIA.

An option that should have been more seriously considered by TransCanada to meet the definition of alternatives in EIA

Oil transport by train: an option that should have been more seriously considered by TransCanada to meet the definition of alternatives in EIA (National Geographic, 2012)

As unethical as this may seem, it is difficult to blame TransCanada for their lack of emphasis on alternatives. TransCanada is a pipeline company, and this is where its business and expertise lies. It is unreasonable to expect it to develop or seriously consider a different way to transporting oil. This entire smoke-screen of alternatives in EIA is a huge issue. Not only does it undermine the rest of the entire analysis, it gives credence to those who argue that EIA is a tool to silence critics under the name of science. By expecting the proponent to write a section that it cannot honestly do in good faith, the report as a whole loses value. Of course, there are certain situations where alternatives are viable. For example, a proponent can consider alternatives when it has no vested interest in the method but solely the end goal. However, when the proponent wants the project to be developed in one way over another, the alternatives section becomes tainted.

Overall, policy makers would do well to revisit what alternatives can be reasonably demanded from a proponent. Only when proponent has no vested interest in one option over the other should he propose alternatives. If this is not the case, the proponent will surely frame the alternatives section as to favor one option over the other. In doing so, the report but also the field of EIA are undermined and appear to be biased and untruthful.

References :

EIS (2011). “Final Environmental Impact Statement for the Proposed Keystone XL Project”. United States Department of State. PDF (www.keystonepipeline-xl.state.gov/)

Noble, B. (2010). “Introduction to Environmental Impact Assessment”. Oxford University Press. Don Mills, Ont. 2nd edition.

LaGesse, David. “Oil Train Revival: Booming North Dakota Relies on Rail to Deliver Its Crude.” National Geographi c. National Geographic Society, 30 Nov. 2012. Web. 19 Mar. 2013

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