The 1970 effective date of the NEPA in the United States signaled the beginning for many countries to adopt laws analogous to the NEPA. Over seventy-five countries now have laws requiring impact studies on proposed development projects. While the resultant reports are not always referred to as EISs, they do represent the documentation of studies similar in concept to those conducted in the United States. Terms other than EIS used by other countries include environmental impact assessment reports, environmental assessment reports, environmental impact documents, and environmental impact reports.
From a global perspective, the following observations relate to countries or portions of the world that have adopted EIA legislation. In North America, Canada, the United States, and Mexico have EIA laws. Some Central American countries have also adopted EIA legislation, and the majority of countries in South America have done similarly. Some larger countries with major development projects, such as Brazil, Argentina, and Venezuela, have active programs related to EIA.
In the European context, the European Community (EC) has a directive on EIA which must be met by all member countries. In addition, these countries also have their own EIA legislation which can be more stringent than the EC directive. The Scandinavian countries such as Sweden, Denmark, and Finland have EIA legislation and are active in the application of the EIA process. Many of the east European countries which were in the former Soviet Union are in the initial stages of adopting EIA legislation.
With regard to the African Continent, several countries in the northern tier, most notably Morocco and Egypt, have EIA legislation. South Africa also has such legislation. Other countries in the African Continent are in various stages of development of EIA legislation. In the Middle East, several countries have legislation or expressed inter est in the EIA process; examples include Kuwait and Saudi Arabia.
In Asia and Southeast Asia, most countries have adopted EIA legislation; examples include India, Sri Lanka, Thailand, Malaysia, and Indonesia. Both Taiwan and the People's Republic of China have EIA legislation, as does Japan. Finally, Australia and New Zealand have active programs in planning and conducting impact studies.
For those countries that have not adopted their own EIA legislation, most are involved in some fashion in impact studies through the auspices of international lending agencies, such as the World Bank or Regional Development Banks, or through requirements of bilateral donor agencies providing funding for development projects. While the specific EIA requirements of donor countries may vary, the general concepts are applied throughout the developing world.
Both substantive and emphasis differences exist between the EIA processes of other countries and that in the United States. For example, in the United States, analyzing alternatives and choosing the one that balances environmental impacts and economic efficiency is emphasized. Most other countries emphasize alternatives analysis less than the EIA process in the United States does. In other words, detailed analysis in most other countries is for the proposed project.
A second difference is that many countries have highly structured land-use planning systems. In this context, the EIA process is often incorporated within the overall planning system. This incorporation causes procedural differences compared to the practice in the United States where an overall land-use planning system is absent.
A major difference between EIA practice in the United States and that in lesser developed countries is the limited availability of environmental data in the latter. Numerous extant environmental monitoring systems exist in the United States, and this information can be used to describe the affected environment or baseline conditions. In many developing countries, such environmental data are either absent or only minimally available. Accordingly, monitoring baseline conditions in the EIA practice is emphasized in many countries.
EIA practice in the United States has typically focused on the preparation of an EA or an EIS. Follow-on activities are only minimally addressed. In contrast, post-EIS activities are emphasized in many countries. These activities include collecting monitoring data and using this information in project management to minimize negative environmental consequences.
As a final point of comparison, the United States practice is often characterized by litigation, wherein opponents to projects can file a lawsuit against project sponsors on the basis of not satisfying the spirit and intent of the NEPA. This litigative concept is essentially absent in most other countries.
In summary, the international EIA practice throughout the world is largely patterned on the principles used in the United States. Future activities related to EIA suggest further coordination and integration of EIA requirements on a worldwide basis, with emphasis on both procedures and methodology. In addition, transboundary impacts, in which the impacts of development projects in one country may be manifested in other nearby countries, are being emphasized. These concerns will facilitate greater coordination between countries regarding the EIA process.
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