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Enhancing the Value and Validity of EIA: Serious Science to Protect Australia's Great Barrier Reef

Enhancing the Value and Validity of EIA: Serious Science to Protect Australia's Great Barrier Reef Great Barrier Reef; environmental impact The unique values of Australia’s Great Barrier Reef (GBR) are under threat assessment; peer review. from environmental change and the unforeseen, cumulative consequences Correspondence of coastal development. Development decisions are underpinned by Environ- Marcus Sheaves, James Cook University, mental Impact Assessments (EIAs) but these are plagued by inconsistent meth- Townsville, QLD 4811, Australia. ods and a lack of independent evaluation, leading to perceptions of inadequate Tel: +61 (7) 47814144; scientific rigor. To be credible and effective, EIAs should be subject to inde- fax: +61 (7) 47251570. pendent peer review, the yardstick applied in the normal process of science. E-mail: Marcus.Sheaves@jcu.edu.au Without it, decisions based on EIA are at best contestable and potentially in- Received valid. Peer review should be applied to the whole EIA process from project 31 August 2015 development to reporting and auditing approval requirements. It should be Revised based on rigorous, standard protocols, and produce standardized and publicly 26 October 2015 available data. Securing the future of the GBR and other global natural as- Accepted sets requires refocusing EIA so it becomes a tool for strategic environmental 30 November 2015 protection rather than ad hoc permitting of development. doi: 10.1111/conl.12219 mental and cultural values of the GBRWHA, and puts at Introduction risk the $5.7 billion economic value of the Great Barrier The Great Barrier Reef World Heritage Area (GBRWHA) Reef (GBR) (Deloitte Access Economics 2013) to the Aus- is not just a jewel in Australia’s National Estate but an tralian economy. outstanding part of the world’s natural heritage; it is the The recently completed marine and coastal strategic world’s most extensive coral-reef ecosystem and one of assessments of the GBR highlight many of the factors con- the few biological features visible from space. Inscribed tributing to declines in its ecosystems and species (DSDIP on the World Heritage List in 1981, it fulfils criteria vii- 2013). Some, such as tropical cyclones, are unpredictable; x for World Heritage inclusion (UNESCO 2015) based others are large-scale factors like climate change that are on superlative natural beauty, intactness, ecological sig- outside the control of local regulators. However, another nificance, unique geomorphological features and natural class of factors relate to the negative consequences habitats. However, a long succession of contested devel- of decisions about coastal planning and industrial de- opment decisions has led to a series of negative environ- velopment throughout the GBR catchment, covering mental outcomes for the GBRWHA estate (Grech et al. some 424,000 km or 23% of the state of Queensland. 2013), all of which were unstated or understated in En- Approximately 10% of the GBR’s 2,300 km coastline is vironmental Impact Assessments (EIAs). The accumula- already affected by coastal development and industrial tion of these developments, an example of the tyranny expansion (Waltham & Sheaves 2015), with the cumu- of small decisions, now threatens the unique environ- lative impact of many small and large developments Conservation Letters, September/October 2016, 9(5), 377–383 Copyright and Photocopying: 2015 The Authors. Conservation Letters published by Wiley Periodicals, Inc. 377 This is an open access article under the terms of the Creative Commons Attribution License, which permits use, distribution and reproduction in any medium, provided the original work is properly cited. Science to protect the Great Barrier Reef M. Sheaves et al. resulting in extensive habitat modification or loss, and in of development proposals prior to major decisions being the exclusion of biota dependenxt on coastal ecosystems taken and commitments made” (IAIA 2009). Considered from extensive tracts of critical habitat (Sheaves et al. closely, these two definitions represent contrasting views 2014). of EIA’s role. The first highlights environmental protec- At the centre of most major development decisions are tion, while the second emphasizes enablement of devel- Environmental Impact Statements (EISs) based on EIAs. opment (Brown & Hill 1995). Although EIAs are “scientific” studies, they have been The question for any particular development is: Which plagued by both perceived and functional problems since of these interpretations is most relevant? Undoubtedly, their first introduction. At the most fundamental level development is important and inevitable, but just as EIA is a “...procedure for evaluating the likely impact of clearly there are cases where the environmental asset is a proposed activity on the environment” (UNECE 1991); so valuable that protection should be paramount. In the a procedure developed to balance three societal influ- case of protecting natural assets of international signif- ences: (i) environmental concerns, (ii) the need for more icance, such as the GBR, it is critical to minimize the objective decision-making; and (iii) greater public in- chance of failing to detect the potential for damage to volvement in decision-making (Weston 2004). However, the asset (i.e., Type II error) (Legg & Nagy 2006), mak- there is a common perception that EIAs are of dubious ing rigorous scientific assessment of the likely impacts, validity; serving the interests of proponents of devel- and the evaluation of the effects of cumulative impacts, opment rather than their ostensible purpose of assess- of paramount importance. This is all the more impor- ing the status and vulnerability of ecosystems (Cash- tant given the undeniable record of environmental de- more 2004). Consequently, the EIA process is often cline in the GBR resulting from the cumulative effects of viewed as simply a bureaucratic step in obtaining de- catchment land uses, coastal developments, and climate velopment approval (Brown & Hill 1995), driven by big change (De’ath et al. 2012). business and political pressure (Beanlands & Duinker In this situation, strong procedures aimed at min- 1983) with an emphasis on appearance over substance; imizing the chance of Type II error—failing to act to with being seen to conduct an EIA more important protect the environment when action is warranted—are than meeting the in-principle requirements of the science required. This emphasis is needed even at the expense (Cashmore 2004). of Type I error—taking action when none is warranted, Whether or not these concerns are well-founded, there or unnecessarily preventing development (Type I error). are functional weaknesses in EIA processes. Potential Type I error results only in additional management inter- conflict of interest is intrinsic to most EIAs because the vention, representing a financial cost to the proponents EIA operator or consultant is invariably selected by the of the development but no cost to the environmental development proponent (Brown & Hill 1995), or because asset (Legg & Nagy 2006). The cost of Type II error in the the proponent is also the regulator (Grech et al. 2013). GBR is local and perhaps wider adverse impacts, adding Moreover, what can be achieved in an EIA is limited to the already large cumulative impact of development by time and budgetary constraints (Morrison-Saunders & across the region (Grech et al. 2013). Bailey 2003), and the specific terms of reference (ToRs) The GBR is managed under the Great Barrier Reef Ma- (Grech et al. 2013), adding to the appearance of scientific rine Park Act 1975, with the stated main objective of pro- incompleteness. These weaknesses are reinforced by in- viding for “ . . . the long term protection and conservation consistencies in some EIAs, such as the selective inclusion of the environment, biodiversity and heritage values of of information and incomplete coverage of assumptions the Great Barrier Reef Region” (GBRMPA 1975). In ac- and caveats (Fairweather 1994), leading to an impression cordance with the Act, EISs are mandatory for “complex of tokenism and questionable ethics, and to the possibility or large scale” projects. However, the requirements for that the proposed development is cast in the most favor- review of the EISs, and the EIAs that underpin them, able light possible rather than evaluated independently are not stipulated. Although guidelines generally include and scientifically (Fairweather 1994). a statement such as “A copy of all data and the sam- pling methodologies must be made available for the pur- pose of peer review on receipt of a written request ...” Problems (SEWPaC/GBRMPA 2011), there is no obligation for in- While EIA in essence evaluates “ . . . the likely impact of a dependent peer review. When an EIS is approved for proposed activity on the environment” (UNECE 1991), public release, in-house experts from relevant govern- in practice it is usually seen by regulators as “ . . . the ment agencies, consultants engaged by government agen- process of identifying, predicting, evaluating and miti- cies, and the public can make submissions, although gating the biophysical, social, and other relevant effects time-frames can be as short as a few weeks. However, 378 Conservation Letters, September/October 2016, 9(5), 377–383 Copyright and Photocopying: 2015 The Authors. Conservation Letters published by Wiley Periodicals, Inc. M. Sheaves et al. Science to protect the Great Barrier Reef this process does not pass the test of independent review. The timing of assessment is often inappropriate (Brown Independent peer review is a documented, critical review & Hill 1995). The most useful input to a development performed by one or more persons with technical exper- proposal comes at the design stage (Bos et al. 2014), fa- tise in the subject matter and independent of the work cilitating the identification of existing data to help as- being reviewed (Council 1997). The lack of independent sess temporal change, as well as allowing modifications peer review of Australian EIAs is pervasive, extending to improve designs and methods. Moreover, assessment from a lack of review of initial tender submissions and at the end of the EIA process is often too late to influence proposals to a lack of review of draft reports and recom- project planning because irreversible decisions (such as mendations (Fairweather 1994). land acquisitions) have been made and funding commit- Although the EIA process used in Australia seems com- ted (Brown & Hill 1995), emphasizing the token nature prehensive, it has proven ineffective at preventing either of some assessments. environmental degradation of the GBR or controversy Perhaps most important is the issue of scientific va- (see Supplementary Information 1). A number of fac- lidity. The legitimacy of EIA depends on its systematic, tors contribute to this (Table 1). The process of individ- scientific basis (Weston 2004) but, as early as 1994, ual proponent-driven EIAs leads to many independent it was recognized that the standard of science in Aus- studies resulting in an immense volume of assessments tralia’s EISs was far below that found in published jour- that lack consistency of standards or methods. For in- nals (Fairweather 1994). This perception of poor rigor stance, since 1993, there have been at least 28 impact persists (Kampf ¨ & Clarke 2013). The lack of standard, assessments relating to a single component of the Hay transparent, rigorous, and independent peer review of Point port development (see Supplementary Information project designs, results, and conclusions inevitably lays 2), and over 600 reports and data sets related to the con- the foundations for skepticism because the conclusions of troversial Gladstone Port development (Llewellyn et al. EIA have not been evaluated using the yardstick applied 2013). Such developments thereby generate a volumi- in the normal process of science (Beanlands & Duinker nous “gray” literature, with limited distribution making 1983; Fairweather 1994). As a consequence, decisions them difficult to obtain, and short time-frames available based on studies lacking independent peer review are at for review limiting scrutiny by the scientific community. best contestable and potentially invalid. Review by “rel- The process of selecting EIA operators by each develop- evant government departments” does little to dispel the ment proponent for each new project introduces the po- doubts because of public suspicions that government de- tential for a lack of independence, and the likelihood of partments have inherent conflicts-of-interest (DiMento & undetected cumulative impacts. It also creates the poten- Ingram 2005). For instance, “review by government de- tial for inconsistency, because even when standard meth- partments” raises a clear question of conflict-of-interest ods are employed, the use of different survey operators in the case of the controversial Gladstone Port that is can lead to conflicting results (Kearney 2002). This result owned by a Queensland Government entity, the Glad- is a mass of individual data sets that differ in methods stone Ports Corporation. of collection and sampling design, and suffer from incon- sistent taxonomic identification (Hutchings et al. 2007). Solutions These inconsistencies greatly reduce the opportunities to integrate data sets, and limit the potential for synergis- While development decisions will remain contentious, tic advantages that accrue from cross-study integration because views among the Australian public span the spec- and the ability to consider spatial differences and tem- trum from pro- to anti-development, it is possible to sub- poral changes (Beanlands & Duinker 1983). The prob- stantially strengthen the validity of the EIA studies that lem is compounded by many data sets being considered underpin decisions, limiting the need to re-do studies, commercial-in-confidence, making them generally un- providing greater surety of quality outputs, greater trans- available. The lack of integration also has substantial costs parency, minimizing the risk of Type II error, and gener- for the proponents; they cannot take advantage of the ally increasing confidence in resulting decisions. Most of cost savings that would result from accessing integrated, the actual and perceived problems with EIA can be ad- consistent data sets, so must often commission new stud- dressed by instituting comprehensive, independent peer ies that repeat work already done. Moreover, unlike the review (DiMento & Ingram 2005) that goes beyond as- situation in other jurisdictions, there is no central data sessment of the final product by extending also to in- repository for GBR data from EIAs that would enable in- fluence the direction, design, rigor, and consistency of formation from previous surveys to be accessed to inform the whole EIA process. This coordinated approach would new studies. have the added advantage of increasing the breadth and Conservation Letters, September/October 2016, 9(5), 377–383 Copyright and Photocopying: 2015 The Authors. Conservation Letters published by Wiley Periodicals, Inc. 379 Science to protect the Great Barrier Reef M. Sheaves et al. Table 1 Summary of some major problems stemming from current EIA practice in the Great Barrier Reef World Heritage Area and its catchment Problem Explanation Process-focused EIA is largely focused on required process rather than on substantive outcomes for the environment Voluminous assessments EISs are voluminous, unwieldy documents that are difficult for the public, and even experts, to evaluate Proponents select EIA Provides the potential for conflict-of-interest and lack of coordination among studies operators The proponents can also be Further scope for conflict of interest the regulator in the case of the Queensland Government Short review periods Short periods of time available for review of large documents Poor integration Proposal-by-proposal commissioning of EIAs produces many independent assessments that are poorly integrated Commercial-in-confidence The data from many EIAs are commercial-in-confidence or unavailable. Consequently, the synergies that would be data available from meta-compilation of huge data sets are not possible. There is also a major cost impost, with each new study potentially redoing existing data collections Lack of consistent, There is rarely rigorous, transparent, and independent review of the project design, results, or conclusions. transparent, and Consequently, many studies are of doubtful value because their scientific validity is untested independent oversight A lack of coordination among A lack of consistent standards for sampling methods, sampling design, replication, analysis, or reporting, leading to studies and no standard inconsistent data, outputs, and interpretations. In addition, a lack of consistent oversight means there is usually little set of methods consistency in the way data are collected, the level of replication, or the spatial and temporal resolution of coverage. In effect, even studies focusing on the same biological or physical component are likely to be measuring different variables in different ways Lack of a centralized The lack of even a centralized compilation of metadata means there is no way of knowing what data exist, and no database with free access information on the details of those data. This reinforces the difficulty of developing synergies among studies Differing ToRs Most EIAs have had tightly constrained terms of reference (ToRs), restricting the scope of the work conducted and the conclusions made, and limiting compatibility with other studies and thereby the utility of the data for meta-compilation A lack of consistent There is no standard accreditation of operators who conduct EIAs. Lack of surety of operator competence undermines accreditation of credibility and compatibility consultants Fragmented development of The operators conducting EIAs change from project to project, meaning that the opportunity is missed for development expertise of detailed expertise in key areas (e.g., identification of benthic infauna). This severely limits the ability for consistent identification of fauna and often restricts identification to high (imprecise) taxonomic levels, reducing the ability to identify change due to developments and leaving many, possibly unique, species unidentified EIA conducted in relation to Timing, duration, and scope of EIAs are usually determined by logistical and budgetary considerations, so often fail to project logistics not consider the spatio-temporal requirements of scientifically valid assessments scientific necessity usefulness of data available, leading to the ability to detect logical requirement for ensuring alignment of EIA with cumulative and large-scale impacts, optimizing the value scientific understanding, and ensuring that scientific of monitoring and enabling adaptive management-type understanding takes precedence over short-term benefits learning. and political considerations—ensuring EIA serves public, If the substantive purpose of EIA is to ensure minimum not private, interests (Fairweather 1994). damage to natural assets of national and international As well as ensuring the EIA process is transparent importance, effective consideration of likely environ- (Brownlie 2005), and that uncertainty is recognized and mental impacts needs to conform to the norms of addressed early in the project cycle (Beanlands & Duinker scientific research. These norms are: a basis in fact (Bean- 1983), independent peer review is important for mitigat- lands & Duinker 1983), valid sampling and statistical ing risk where uncertainty, and therefore the potential design aimed to produce unequivocal results (Under- for controversy, is high. For instance, a well-accepted, wood 1990), unbiased and comprehensive reference to well-understood, and transparent process that acknowl- published research (Fairweather 1994), and a clear un- edges and incorporates uncertainty is important in decid- derstanding of uncertainty and risk (Harris & Heathwaite ing the acceptability of a proposal under the precaution- 2012). Comprehensive, independent peer review is a ary principle (Harris & Heathwaite 2012). 380 Conservation Letters, September/October 2016, 9(5), 377–383 Copyright and Photocopying: 2015 The Authors. Conservation Letters published by Wiley Periodicals, Inc. M. Sheaves et al. Science to protect the Great Barrier Reef What might a comprehensive, independent funded by development proponents. Making data pub- peer-review process look like? licly available need not be expensive. For instance, the repository could be linked to the Open Science move- To be as effective as possible, while handling the large ment (http://www.openscience.org/). The benefits of in- volume of environmental assessments generated within tegrating data and making them available via a data man- the GBR, an independent peer-review process would agement system have already been demonstrated in one need to be centrally organized and funded. Similar pro- area of the GBRWHA, with the mass of literature pro- cesses have proved effective in Canada and the Nether- duced over the last 40 years of intense development lands, where EIAs are controlled by independent EIA of Gladstone Harbour assembled in a data repository to commissions. provide historical benchmarks for monitoring (Llewellyn A likely model for the GBR is a proponent-funded (e.g., et al. 2013). Bos et al. 2014) peer-review process governed by an in- dependent expert panel that directs assessments to ex- Would peer review work? pert peer reviewers in the field (Figure 1). To be most effective, peer review should include the initial advice Comprehensive, independent peer review is recognized statement (including ToR), a statement of acceptable risks as vital in related areas; a key component of well- from the project, EIA design, and the draft final report. managed monitoring programs (Legg & Nagy 2006) and Evaluation of the EIA design is critical (Bos et al. 2014) to central to the success of environmental offsets programs ensure EIA studies are as well directed as possible and to (Bos et al. 2014). Peer review has a history of successful allow the development of an acceptable project plan be- application to the GBR, with Great Barrier Reef Marine fore money is spent or commitments made (Brown & Hill Park Authority’s use of external referees in the 1980s– 1995). 1990s leading to substantially higher-quality monitoring For maximum effectiveness and cross-study integra- than seen elsewhere in Australia (Warnken & Buckley tion there needs to be a set of standard protocols and 2000). guidelines (Beanlands & Duinker 1983) that take due Peer review is also supported by many EIA practition- regard of issues such as statistical power (Legg & Nagy ers who see it as a positive step towards improving project 2006), and the use of standard study and sampling design, methods, the quality of information, and report- methods. The standard protocols then become the cri- ing (Morrison-Saunders & Bailey 2003). Some practi- teria against which the EIA design is judged. To ensure tioners also see a strong peer-review process as helping consistent quality, all operators contracting for impact free them from reconciling the extent of work they be- assessment studies should be accredited through a certifi- lieve needs doing with the constraints of limited bud- cation process overseen by the independent expert panel. gets and time-lines. Under peer review, time and budgets The use of standard methods would make extensive would need to fit scientific necessity rather than arbitrary data integration feasible. Consequently, there should be constraints. mandatory, full public access to data. Currently a large body of data is claimed as commercial-in-confidence with Managing the cost little justification. For instance, there seems no reason why all biological data relating to the GBR should not The comprehensive process of peer review outlined in be publicly available, because the public, including re- Figure 1 might be seen as prohibitively expensive. But searchers, has an interest in the organisms and habitats is this true? Such a model would be more expensive investigated that may be at least as great as that of devel- than the current EIA process, but should that be an im- opment proponents (Costanza et al. 2006). Scientific re- pediment to the protection of a natural asset of interna- search programs funding under the Australian Research tional significance? If independent peer review of EIAs Council are required to make all collected data available; contributed to halting the continual degradation of the this same level of transparency should also apply to EIA. GBR and helped safeguard it for future generations, that Integrated information management systems are the in itself would seem to justify the extra expense. How- key to synthesized outcomes (Ayles et al. 2004), and the ever, there are likely to be more tangible economic ben- ability to access a large body of data can provide sub- efits. In contrast to the current fragmented approach to stantial benefits in increased effectiveness and relevance, EIA, with different proponents commissioning studies and provides the opportunity to put an EIA into broad that often repeat previous work, the ability to freely ac- spatio-temporal context essential for understanding cu- cess the results of previous studies and confidently uti- mulative outcomes (Ayles et al. 2004). To make full use lize them would reduce the need for new studies, provide of publicly available data and ensure their availability larger, more valid data sets for assessment and decision- for public scrutiny, a managed data repository should be making, and lead to substantial savings. There is also the Conservation Letters, September/October 2016, 9(5), 377–383 Copyright and Photocopying: 2015 The Authors. Conservation Letters published by Wiley Periodicals, Inc. 381 Science to protect the Great Barrier Reef M. Sheaves et al. Accredited EIA operator accept/reject Dra Report when a ccepted report on a dequacy of dra  report evaluate adequacy choose independent Independent Expert peer reviewers Peer Reviewers Final Report Panel bas ed on required skill s ets report on a dequacy of final pla n ada pve review of plan to assure alignment with Fully funded public standard protocols access database covering all aspects develop s tanda rd protocols in study type- of the project consultaon with experts speci fic s tanda rd Detailed EIA Plan possess ing protocols speci fic s kills-sets Accredited EIA operator Figure 1 Framework for a comprehensive, independent peer-review process. benefit to governments and proponents that a more outcomes and controversy, while environmental degra- transparent process, with results presented in a readily dation continues. understood way, would increase public acceptability of the results. Additionally, getting assessments right in the Acknowledgments first instance would limit the need for proponents or the R.L.P. acknowledges the financial support of the Aus- Australian public to fund costly remediation exercises, as tralian Research Council. has often been the case in the past (Grech et al. 2013). Supporting Information Conclusion Additional Supporting Information may be found in the The condition and resilience of the GBRWHA—and other online version of this article at the publisher’s web site: global natural assets—justify the most strenuous efforts to ensure that long-term preservation overrides the pragma- Supplementary Information 1. Examples of doc- tism of short-term financial accounting. Decisions about umented instances of major problems stemming from development of the GBR coast and hinterland need to current Environmental Impact Assessment practice in be based on serious science. In the case of environmen- the Great Barrier Reef World Heritage Area and its tal assessment, that means subjecting EIAs to the same catchment. rigorous standards demanded of other applications of Supplementary Information 2. List of reports for science—applying the yardstick of scientific quality af- Hay Point port development activities. forded by independent peer review. Independent peer re- view might appear difficult and problematic for regulators References to deploy, but precedents indicate its feasibility. More im- portantly, without peer-reviewed EIA, the GBRWHA is Ayles, G.B., Dube, ´ M. & Rosenberg, D. (2004). Oil sands likely condemned to a continuing cycle of unsatisfactory regional aquatic monitoring program (RAMP) scientific peer 382 Conservation Letters, September/October 2016, 9(5), 377–383 Copyright and Photocopying: 2015 The Authors. Conservation Letters published by Wiley Periodicals, Inc. M. Sheaves et al. 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Enhancing the Value and Validity of EIA: Serious Science to Protect Australia's Great Barrier Reef

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Abstract

Great Barrier Reef; environmental impact The unique values of Australia’s Great Barrier Reef (GBR) are under threat assessment; peer review. from environmental change and the unforeseen, cumulative consequences Correspondence of coastal development. Development decisions are underpinned by Environ- Marcus Sheaves, James Cook University, mental Impact Assessments (EIAs) but these are plagued by inconsistent meth- Townsville, QLD 4811, Australia. ods and a lack of independent evaluation, leading to perceptions of inadequate Tel: +61 (7) 47814144; scientific rigor. To be credible and effective, EIAs should be subject to inde- fax: +61 (7) 47251570. pendent peer review, the yardstick applied in the normal process of science. E-mail: Marcus.Sheaves@jcu.edu.au Without it, decisions based on EIA are at best contestable and potentially in- Received valid. Peer review should be applied to the whole EIA process from project 31 August 2015 development to reporting and auditing approval requirements. It should be Revised based on rigorous, standard protocols, and produce standardized and publicly 26 October 2015 available data. Securing the future of the GBR and other global natural as- Accepted sets requires refocusing EIA so it becomes a tool for strategic environmental 30 November 2015 protection rather than ad hoc permitting of development. doi: 10.1111/conl.12219 mental and cultural values of the GBRWHA, and puts at Introduction risk the $5.7 billion economic value of the Great Barrier The Great Barrier Reef World Heritage Area (GBRWHA) Reef (GBR) (Deloitte Access Economics 2013) to the Aus- is not just a jewel in Australia’s National Estate but an tralian economy. outstanding part of the world’s natural heritage; it is the The recently completed marine and coastal strategic world’s most extensive coral-reef ecosystem and one of assessments of the GBR highlight many of the factors con- the few biological features visible from space. Inscribed tributing to declines in its ecosystems and species (DSDIP on the World Heritage List in 1981, it fulfils criteria vii- 2013). Some, such as tropical cyclones, are unpredictable; x for World Heritage inclusion (UNESCO 2015) based others are large-scale factors like climate change that are on superlative natural beauty, intactness, ecological sig- outside the control of local regulators. However, another nificance, unique geomorphological features and natural class of factors relate to the negative consequences habitats. However, a long succession of contested devel- of decisions about coastal planning and industrial de- opment decisions has led to a series of negative environ- velopment throughout the GBR catchment, covering mental outcomes for the GBRWHA estate (Grech et al. some 424,000 km or 23% of the state of Queensland. 2013), all of which were unstated or understated in En- Approximately 10% of the GBR’s 2,300 km coastline is vironmental Impact Assessments (EIAs). The accumula- already affected by coastal development and industrial tion of these developments, an example of the tyranny expansion (Waltham & Sheaves 2015), with the cumu- of small decisions, now threatens the unique environ- lative impact of many small and large developments Conservation Letters, September/October 2016, 9(5), 377–383 Copyright and Photocopying: 2015 The Authors. Conservation Letters published by Wiley Periodicals, Inc. 377 This is an open access article under the terms of the Creative Commons Attribution License, which permits use, distribution and reproduction in any medium, provided the original work is properly cited. Science to protect the Great Barrier Reef M. Sheaves et al. resulting in extensive habitat modification or loss, and in of development proposals prior to major decisions being the exclusion of biota dependenxt on coastal ecosystems taken and commitments made” (IAIA 2009). Considered from extensive tracts of critical habitat (Sheaves et al. closely, these two definitions represent contrasting views 2014). of EIA’s role. The first highlights environmental protec- At the centre of most major development decisions are tion, while the second emphasizes enablement of devel- Environmental Impact Statements (EISs) based on EIAs. opment (Brown & Hill 1995). Although EIAs are “scientific” studies, they have been The question for any particular development is: Which plagued by both perceived and functional problems since of these interpretations is most relevant? Undoubtedly, their first introduction. At the most fundamental level development is important and inevitable, but just as EIA is a “...procedure for evaluating the likely impact of clearly there are cases where the environmental asset is a proposed activity on the environment” (UNECE 1991); so valuable that protection should be paramount. In the a procedure developed to balance three societal influ- case of protecting natural assets of international signif- ences: (i) environmental concerns, (ii) the need for more icance, such as the GBR, it is critical to minimize the objective decision-making; and (iii) greater public in- chance of failing to detect the potential for damage to volvement in decision-making (Weston 2004). However, the asset (i.e., Type II error) (Legg & Nagy 2006), mak- there is a common perception that EIAs are of dubious ing rigorous scientific assessment of the likely impacts, validity; serving the interests of proponents of devel- and the evaluation of the effects of cumulative impacts, opment rather than their ostensible purpose of assess- of paramount importance. This is all the more impor- ing the status and vulnerability of ecosystems (Cash- tant given the undeniable record of environmental de- more 2004). Consequently, the EIA process is often cline in the GBR resulting from the cumulative effects of viewed as simply a bureaucratic step in obtaining de- catchment land uses, coastal developments, and climate velopment approval (Brown & Hill 1995), driven by big change (De’ath et al. 2012). business and political pressure (Beanlands & Duinker In this situation, strong procedures aimed at min- 1983) with an emphasis on appearance over substance; imizing the chance of Type II error—failing to act to with being seen to conduct an EIA more important protect the environment when action is warranted—are than meeting the in-principle requirements of the science required. This emphasis is needed even at the expense (Cashmore 2004). of Type I error—taking action when none is warranted, Whether or not these concerns are well-founded, there or unnecessarily preventing development (Type I error). are functional weaknesses in EIA processes. Potential Type I error results only in additional management inter- conflict of interest is intrinsic to most EIAs because the vention, representing a financial cost to the proponents EIA operator or consultant is invariably selected by the of the development but no cost to the environmental development proponent (Brown & Hill 1995), or because asset (Legg & Nagy 2006). The cost of Type II error in the the proponent is also the regulator (Grech et al. 2013). GBR is local and perhaps wider adverse impacts, adding Moreover, what can be achieved in an EIA is limited to the already large cumulative impact of development by time and budgetary constraints (Morrison-Saunders & across the region (Grech et al. 2013). Bailey 2003), and the specific terms of reference (ToRs) The GBR is managed under the Great Barrier Reef Ma- (Grech et al. 2013), adding to the appearance of scientific rine Park Act 1975, with the stated main objective of pro- incompleteness. These weaknesses are reinforced by in- viding for “ . . . the long term protection and conservation consistencies in some EIAs, such as the selective inclusion of the environment, biodiversity and heritage values of of information and incomplete coverage of assumptions the Great Barrier Reef Region” (GBRMPA 1975). In ac- and caveats (Fairweather 1994), leading to an impression cordance with the Act, EISs are mandatory for “complex of tokenism and questionable ethics, and to the possibility or large scale” projects. However, the requirements for that the proposed development is cast in the most favor- review of the EISs, and the EIAs that underpin them, able light possible rather than evaluated independently are not stipulated. Although guidelines generally include and scientifically (Fairweather 1994). a statement such as “A copy of all data and the sam- pling methodologies must be made available for the pur- pose of peer review on receipt of a written request ...” Problems (SEWPaC/GBRMPA 2011), there is no obligation for in- While EIA in essence evaluates “ . . . the likely impact of a dependent peer review. When an EIS is approved for proposed activity on the environment” (UNECE 1991), public release, in-house experts from relevant govern- in practice it is usually seen by regulators as “ . . . the ment agencies, consultants engaged by government agen- process of identifying, predicting, evaluating and miti- cies, and the public can make submissions, although gating the biophysical, social, and other relevant effects time-frames can be as short as a few weeks. However, 378 Conservation Letters, September/October 2016, 9(5), 377–383 Copyright and Photocopying: 2015 The Authors. Conservation Letters published by Wiley Periodicals, Inc. M. Sheaves et al. Science to protect the Great Barrier Reef this process does not pass the test of independent review. The timing of assessment is often inappropriate (Brown Independent peer review is a documented, critical review & Hill 1995). The most useful input to a development performed by one or more persons with technical exper- proposal comes at the design stage (Bos et al. 2014), fa- tise in the subject matter and independent of the work cilitating the identification of existing data to help as- being reviewed (Council 1997). The lack of independent sess temporal change, as well as allowing modifications peer review of Australian EIAs is pervasive, extending to improve designs and methods. Moreover, assessment from a lack of review of initial tender submissions and at the end of the EIA process is often too late to influence proposals to a lack of review of draft reports and recom- project planning because irreversible decisions (such as mendations (Fairweather 1994). land acquisitions) have been made and funding commit- Although the EIA process used in Australia seems com- ted (Brown & Hill 1995), emphasizing the token nature prehensive, it has proven ineffective at preventing either of some assessments. environmental degradation of the GBR or controversy Perhaps most important is the issue of scientific va- (see Supplementary Information 1). A number of fac- lidity. The legitimacy of EIA depends on its systematic, tors contribute to this (Table 1). The process of individ- scientific basis (Weston 2004) but, as early as 1994, ual proponent-driven EIAs leads to many independent it was recognized that the standard of science in Aus- studies resulting in an immense volume of assessments tralia’s EISs was far below that found in published jour- that lack consistency of standards or methods. For in- nals (Fairweather 1994). This perception of poor rigor stance, since 1993, there have been at least 28 impact persists (Kampf ¨ & Clarke 2013). The lack of standard, assessments relating to a single component of the Hay transparent, rigorous, and independent peer review of Point port development (see Supplementary Information project designs, results, and conclusions inevitably lays 2), and over 600 reports and data sets related to the con- the foundations for skepticism because the conclusions of troversial Gladstone Port development (Llewellyn et al. EIA have not been evaluated using the yardstick applied 2013). Such developments thereby generate a volumi- in the normal process of science (Beanlands & Duinker nous “gray” literature, with limited distribution making 1983; Fairweather 1994). As a consequence, decisions them difficult to obtain, and short time-frames available based on studies lacking independent peer review are at for review limiting scrutiny by the scientific community. best contestable and potentially invalid. Review by “rel- The process of selecting EIA operators by each develop- evant government departments” does little to dispel the ment proponent for each new project introduces the po- doubts because of public suspicions that government de- tential for a lack of independence, and the likelihood of partments have inherent conflicts-of-interest (DiMento & undetected cumulative impacts. It also creates the poten- Ingram 2005). For instance, “review by government de- tial for inconsistency, because even when standard meth- partments” raises a clear question of conflict-of-interest ods are employed, the use of different survey operators in the case of the controversial Gladstone Port that is can lead to conflicting results (Kearney 2002). This result owned by a Queensland Government entity, the Glad- is a mass of individual data sets that differ in methods stone Ports Corporation. of collection and sampling design, and suffer from incon- sistent taxonomic identification (Hutchings et al. 2007). Solutions These inconsistencies greatly reduce the opportunities to integrate data sets, and limit the potential for synergis- While development decisions will remain contentious, tic advantages that accrue from cross-study integration because views among the Australian public span the spec- and the ability to consider spatial differences and tem- trum from pro- to anti-development, it is possible to sub- poral changes (Beanlands & Duinker 1983). The prob- stantially strengthen the validity of the EIA studies that lem is compounded by many data sets being considered underpin decisions, limiting the need to re-do studies, commercial-in-confidence, making them generally un- providing greater surety of quality outputs, greater trans- available. The lack of integration also has substantial costs parency, minimizing the risk of Type II error, and gener- for the proponents; they cannot take advantage of the ally increasing confidence in resulting decisions. Most of cost savings that would result from accessing integrated, the actual and perceived problems with EIA can be ad- consistent data sets, so must often commission new stud- dressed by instituting comprehensive, independent peer ies that repeat work already done. Moreover, unlike the review (DiMento & Ingram 2005) that goes beyond as- situation in other jurisdictions, there is no central data sessment of the final product by extending also to in- repository for GBR data from EIAs that would enable in- fluence the direction, design, rigor, and consistency of formation from previous surveys to be accessed to inform the whole EIA process. This coordinated approach would new studies. have the added advantage of increasing the breadth and Conservation Letters, September/October 2016, 9(5), 377–383 Copyright and Photocopying: 2015 The Authors. Conservation Letters published by Wiley Periodicals, Inc. 379 Science to protect the Great Barrier Reef M. Sheaves et al. Table 1 Summary of some major problems stemming from current EIA practice in the Great Barrier Reef World Heritage Area and its catchment Problem Explanation Process-focused EIA is largely focused on required process rather than on substantive outcomes for the environment Voluminous assessments EISs are voluminous, unwieldy documents that are difficult for the public, and even experts, to evaluate Proponents select EIA Provides the potential for conflict-of-interest and lack of coordination among studies operators The proponents can also be Further scope for conflict of interest the regulator in the case of the Queensland Government Short review periods Short periods of time available for review of large documents Poor integration Proposal-by-proposal commissioning of EIAs produces many independent assessments that are poorly integrated Commercial-in-confidence The data from many EIAs are commercial-in-confidence or unavailable. Consequently, the synergies that would be data available from meta-compilation of huge data sets are not possible. There is also a major cost impost, with each new study potentially redoing existing data collections Lack of consistent, There is rarely rigorous, transparent, and independent review of the project design, results, or conclusions. transparent, and Consequently, many studies are of doubtful value because their scientific validity is untested independent oversight A lack of coordination among A lack of consistent standards for sampling methods, sampling design, replication, analysis, or reporting, leading to studies and no standard inconsistent data, outputs, and interpretations. In addition, a lack of consistent oversight means there is usually little set of methods consistency in the way data are collected, the level of replication, or the spatial and temporal resolution of coverage. In effect, even studies focusing on the same biological or physical component are likely to be measuring different variables in different ways Lack of a centralized The lack of even a centralized compilation of metadata means there is no way of knowing what data exist, and no database with free access information on the details of those data. This reinforces the difficulty of developing synergies among studies Differing ToRs Most EIAs have had tightly constrained terms of reference (ToRs), restricting the scope of the work conducted and the conclusions made, and limiting compatibility with other studies and thereby the utility of the data for meta-compilation A lack of consistent There is no standard accreditation of operators who conduct EIAs. Lack of surety of operator competence undermines accreditation of credibility and compatibility consultants Fragmented development of The operators conducting EIAs change from project to project, meaning that the opportunity is missed for development expertise of detailed expertise in key areas (e.g., identification of benthic infauna). This severely limits the ability for consistent identification of fauna and often restricts identification to high (imprecise) taxonomic levels, reducing the ability to identify change due to developments and leaving many, possibly unique, species unidentified EIA conducted in relation to Timing, duration, and scope of EIAs are usually determined by logistical and budgetary considerations, so often fail to project logistics not consider the spatio-temporal requirements of scientifically valid assessments scientific necessity usefulness of data available, leading to the ability to detect logical requirement for ensuring alignment of EIA with cumulative and large-scale impacts, optimizing the value scientific understanding, and ensuring that scientific of monitoring and enabling adaptive management-type understanding takes precedence over short-term benefits learning. and political considerations—ensuring EIA serves public, If the substantive purpose of EIA is to ensure minimum not private, interests (Fairweather 1994). damage to natural assets of national and international As well as ensuring the EIA process is transparent importance, effective consideration of likely environ- (Brownlie 2005), and that uncertainty is recognized and mental impacts needs to conform to the norms of addressed early in the project cycle (Beanlands & Duinker scientific research. These norms are: a basis in fact (Bean- 1983), independent peer review is important for mitigat- lands & Duinker 1983), valid sampling and statistical ing risk where uncertainty, and therefore the potential design aimed to produce unequivocal results (Under- for controversy, is high. For instance, a well-accepted, wood 1990), unbiased and comprehensive reference to well-understood, and transparent process that acknowl- published research (Fairweather 1994), and a clear un- edges and incorporates uncertainty is important in decid- derstanding of uncertainty and risk (Harris & Heathwaite ing the acceptability of a proposal under the precaution- 2012). Comprehensive, independent peer review is a ary principle (Harris & Heathwaite 2012). 380 Conservation Letters, September/October 2016, 9(5), 377–383 Copyright and Photocopying: 2015 The Authors. Conservation Letters published by Wiley Periodicals, Inc. M. Sheaves et al. Science to protect the Great Barrier Reef What might a comprehensive, independent funded by development proponents. Making data pub- peer-review process look like? licly available need not be expensive. For instance, the repository could be linked to the Open Science move- To be as effective as possible, while handling the large ment (http://www.openscience.org/). The benefits of in- volume of environmental assessments generated within tegrating data and making them available via a data man- the GBR, an independent peer-review process would agement system have already been demonstrated in one need to be centrally organized and funded. Similar pro- area of the GBRWHA, with the mass of literature pro- cesses have proved effective in Canada and the Nether- duced over the last 40 years of intense development lands, where EIAs are controlled by independent EIA of Gladstone Harbour assembled in a data repository to commissions. provide historical benchmarks for monitoring (Llewellyn A likely model for the GBR is a proponent-funded (e.g., et al. 2013). Bos et al. 2014) peer-review process governed by an in- dependent expert panel that directs assessments to ex- Would peer review work? pert peer reviewers in the field (Figure 1). To be most effective, peer review should include the initial advice Comprehensive, independent peer review is recognized statement (including ToR), a statement of acceptable risks as vital in related areas; a key component of well- from the project, EIA design, and the draft final report. managed monitoring programs (Legg & Nagy 2006) and Evaluation of the EIA design is critical (Bos et al. 2014) to central to the success of environmental offsets programs ensure EIA studies are as well directed as possible and to (Bos et al. 2014). Peer review has a history of successful allow the development of an acceptable project plan be- application to the GBR, with Great Barrier Reef Marine fore money is spent or commitments made (Brown & Hill Park Authority’s use of external referees in the 1980s– 1995). 1990s leading to substantially higher-quality monitoring For maximum effectiveness and cross-study integra- than seen elsewhere in Australia (Warnken & Buckley tion there needs to be a set of standard protocols and 2000). guidelines (Beanlands & Duinker 1983) that take due Peer review is also supported by many EIA practition- regard of issues such as statistical power (Legg & Nagy ers who see it as a positive step towards improving project 2006), and the use of standard study and sampling design, methods, the quality of information, and report- methods. The standard protocols then become the cri- ing (Morrison-Saunders & Bailey 2003). Some practi- teria against which the EIA design is judged. To ensure tioners also see a strong peer-review process as helping consistent quality, all operators contracting for impact free them from reconciling the extent of work they be- assessment studies should be accredited through a certifi- lieve needs doing with the constraints of limited bud- cation process overseen by the independent expert panel. gets and time-lines. Under peer review, time and budgets The use of standard methods would make extensive would need to fit scientific necessity rather than arbitrary data integration feasible. Consequently, there should be constraints. mandatory, full public access to data. Currently a large body of data is claimed as commercial-in-confidence with Managing the cost little justification. For instance, there seems no reason why all biological data relating to the GBR should not The comprehensive process of peer review outlined in be publicly available, because the public, including re- Figure 1 might be seen as prohibitively expensive. But searchers, has an interest in the organisms and habitats is this true? Such a model would be more expensive investigated that may be at least as great as that of devel- than the current EIA process, but should that be an im- opment proponents (Costanza et al. 2006). Scientific re- pediment to the protection of a natural asset of interna- search programs funding under the Australian Research tional significance? If independent peer review of EIAs Council are required to make all collected data available; contributed to halting the continual degradation of the this same level of transparency should also apply to EIA. GBR and helped safeguard it for future generations, that Integrated information management systems are the in itself would seem to justify the extra expense. How- key to synthesized outcomes (Ayles et al. 2004), and the ever, there are likely to be more tangible economic ben- ability to access a large body of data can provide sub- efits. In contrast to the current fragmented approach to stantial benefits in increased effectiveness and relevance, EIA, with different proponents commissioning studies and provides the opportunity to put an EIA into broad that often repeat previous work, the ability to freely ac- spatio-temporal context essential for understanding cu- cess the results of previous studies and confidently uti- mulative outcomes (Ayles et al. 2004). To make full use lize them would reduce the need for new studies, provide of publicly available data and ensure their availability larger, more valid data sets for assessment and decision- for public scrutiny, a managed data repository should be making, and lead to substantial savings. There is also the Conservation Letters, September/October 2016, 9(5), 377–383 Copyright and Photocopying: 2015 The Authors. Conservation Letters published by Wiley Periodicals, Inc. 381 Science to protect the Great Barrier Reef M. Sheaves et al. Accredited EIA operator accept/reject Dra Report when a ccepted report on a dequacy of dra  report evaluate adequacy choose independent Independent Expert peer reviewers Peer Reviewers Final Report Panel bas ed on required skill s ets report on a dequacy of final pla n ada pve review of plan to assure alignment with Fully funded public standard protocols access database covering all aspects develop s tanda rd protocols in study type- of the project consultaon with experts speci fic s tanda rd Detailed EIA Plan possess ing protocols speci fic s kills-sets Accredited EIA operator Figure 1 Framework for a comprehensive, independent peer-review process. benefit to governments and proponents that a more outcomes and controversy, while environmental degra- transparent process, with results presented in a readily dation continues. understood way, would increase public acceptability of the results. Additionally, getting assessments right in the Acknowledgments first instance would limit the need for proponents or the R.L.P. acknowledges the financial support of the Aus- Australian public to fund costly remediation exercises, as tralian Research Council. has often been the case in the past (Grech et al. 2013). Supporting Information Conclusion Additional Supporting Information may be found in the The condition and resilience of the GBRWHA—and other online version of this article at the publisher’s web site: global natural assets—justify the most strenuous efforts to ensure that long-term preservation overrides the pragma- Supplementary Information 1. Examples of doc- tism of short-term financial accounting. Decisions about umented instances of major problems stemming from development of the GBR coast and hinterland need to current Environmental Impact Assessment practice in be based on serious science. In the case of environmen- the Great Barrier Reef World Heritage Area and its tal assessment, that means subjecting EIAs to the same catchment. rigorous standards demanded of other applications of Supplementary Information 2. List of reports for science—applying the yardstick of scientific quality af- Hay Point port development activities. forded by independent peer review. Independent peer re- view might appear difficult and problematic for regulators References to deploy, but precedents indicate its feasibility. More im- portantly, without peer-reviewed EIA, the GBRWHA is Ayles, G.B., Dube, ´ M. & Rosenberg, D. (2004). Oil sands likely condemned to a continuing cycle of unsatisfactory regional aquatic monitoring program (RAMP) scientific peer 382 Conservation Letters, September/October 2016, 9(5), 377–383 Copyright and Photocopying: 2015 The Authors. Conservation Letters published by Wiley Periodicals, Inc. M. Sheaves et al. 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