How accurate are EIAs? Particularly concerning the impacts of surface mining on groundwater? If the UK is anything like the US, the answer is not very; in fact, mostly not at all.
Major developments, as damaging to the environment as Aggregate Industries’ plan for Straitgate Farm, need EIA. It is a statutory process governed by UK and European Law. An Environmental Statement sets out the results of the EIA process.
The aim of Environmental Impact Assessment is to protect the environment by ensuring that a local planning authority when deciding whether to grant planning permission for a project, which is likely to have significant effects on the environment, does so in the full knowledge of the likely significant effects, and takes this into account in the decision making process.
The aim of Environmental Impact Assessment is also to ensure that the public are given early and effective opportunities to participate in the decision making procedures.
Experts are drafted in to produce these environmental assessments, but invariably it seems councils are told that any impact will be insignificant or minor or can be mitigated away and that everything will be fine. Friends of the Earth bemoan the fact that:
In practice, the ES is often a sales document for the applicant and there have been increasing calls for an independent commission of EIAs to take them out of the hands of those with a vested interest in seeing schemes approved.
The quality of ES can be surprisingly poor, with developers often keen to do the least possible to get the application through, so it is vital local people go on asking critical questions of the applicant and local authority planners.
A paper titled: Myth and Momentum: A Critique of Environmental Impact Assessments complains:
EIAs are now often contracted to the lowest bidder, with a focus often more on achieving mandated deadlines, rather than on product quality. In some cases, more expertise and resources may be put into winning a contract than completing it, with the important scientific work being done cheaply by newly graduated bachelor’s degree holders or inexperienced interns.
In the case of Straitgate Farm, where plans for surface mining bring risks to groundwater, flooding and a whole host of other things - we’ve already found that AI’s EIA has been riddled with a catalogue of fiction. Consultants Amec Foster Wheeler (now Wood), bankrolled by the world’s largest cement multinational, have produced an assortment of hydrological assessments likewise predicting that everything will be fine:
By working the quarry above the highest known water table and therefore dry, there is not expected to be any direct impact on any groundwater dependent features. 6.2.1
However, despite apparently being "defined with confidence", some of Amec’s predictions have already failed. Reason no doubt why Amec has so far refused to put a number on that level of confidence – even to the EA. Some of Amec’s reports have also been whitewashed.
In the US the equivalent of EIA is the Environmental Impact Statement. In 2006 a study was published – with the support of Earthworks, a nonprofit organisation in Washington DC "dedicated to protecting communities and the environment from the adverse impacts of mineral and energy development while promoting sustainable solutions":
Comparison of Predicted and Actual Water Quality at Hardrock Mines: The reliability of predictions in Environmental Impact Statements. Kuipers, J.R., Maest, A.S., MacHardy, K.A., and Lawson, G. 2006.
The overall purpose of this study is to examine the reliability of pre-mining water quality predictions at hard rock mining operations in the United States. To our knowledge, no effort has previously been made to systematically compare predicted and actual water quality for mines in the U.S. or elsewhere.
The report found that:
... nearly all the mines that developed acid drainage either underestimated or ignored the potential for acid drainage in their EISs. 7.1.1
... most case study mines predicted no impacts to surface water quality after mitigation are in place, but at the majority of these mines, impacts have already occurred. 7.1.2
... most mines predicted no impacts to groundwater quality after mitigation were in place, but in the majority of case study mines, impacts have occurred. 7.1.3
Furthermore, when surface mining was in close proximity to groundwater - as it would be at Straitgate:
Of the 15 mines with close proximity to groundwater and high acid drainage or contaminant leaching potential, all but one (93%) have had mining-related impacts to groundwater, seeps, springs, or adit water. p184
Straitgate Farm would obviously not be a mine with "high acid drainage or contaminant leaching potential", but the point to take away from all this is that the EISs, and those highly qualified consultants in the pockets of their mining friends, had made predictions – and 93% of them were wrong!
Read that in conjunction with Amec’s "there is not expected to be any direct impact" – and no wonder local people have no faith in AI’s house of cards.
Of course, UK consultants might claim to work to a higher standard than their US counterparts or might claim to have fewer conflicts of interest. But what we do know is that Amec is not infallible; we have already seen that. What we do know is that another well respected hydrogeologist disagrees with Amec’s conclusions.
It is for these reasons that caution should prevail at Straitgate - when there are so many people reliant on the site for their drinking water. It is for these reasons that AI’s so-called trigger levels for 'emergency winter working' – which would have failed this year with a dry winter followed by a very wet spring – are a nonsense. It is for these reasons that, if quarrying were to be permitted at Straitgate, there should at the very least be - as originally intended and as standardly deployed elsewhere - a 1m unquarried buffer maintained above the maximum water table; it is the very least that local people relying on wells and springs for their drinking water deserve - given the propensity for consultants to be wrong.
