Environmental Impact Assessment Process Criticized By Civil Society Groups – New Bloom Magazine

Report on Taiwan’s Environmental Impact Assessment (EIA) Process and Alignment with Sustainable Development Goals (SDGs)

Introduction

An analysis of Taiwan’s Environmental Impact Assessment (EIA) process reveals significant shortcomings in transparency, public participation, and institutional accountability. Civil society organizations have raised concerns that the current framework fails to align with key principles of the Sustainable Development Goals (SDGs), particularly SDG 16 (Peace, Justice and Strong Institutions), and undermines environmental protection goals outlined in SDG 14 (Life Below Water) and SDG 15 (Life on Land).

Deficiencies in Institutional Accountability and Public Participation (SDG 16)

The EIA process has been criticized for functioning as a rubber-stamp mechanism for development projects rather than a rigorous evaluation tool. This practice contravenes SDG Target 16.6, which calls for the development of effective, accountable, and transparent institutions at all levels.

Barriers to Inclusive and Participatory Decision-Making

Recent procedural changes have further limited public engagement, moving away from the principles of responsive and inclusive decision-making (SDG Target 16.7).

• Under new regulations, dialogue between civil society groups and developers has been replaced with a restrictive three-minute questioning period for each group.
• Developers are not obligated to respond to the concerns raised, rendering the participation of civil society largely performative.
• Public notification methods for EIA hearings are inadequate, relying on communications to borough chiefs and township offices, which limits broader public awareness and involvement.

Composition of the EIA Board and its Implications for Sustainable Development

The composition of the EIA review board is heavily skewed, compromising its ability to conduct holistic and ecologically sound assessments. This imbalance directly impacts the safeguarding of biodiversity and ecosystems, which are central to SDG 14 and SDG 15.

Imbalance in Expertise and Representation

The board’s membership reflects a prioritization of technical and engineering perspectives over ecological and social considerations.

1. Engineering Dominance: 10 of the 14 expert members have an engineering background, creating a bias towards technical solutions over environmental conservation.
2. Lack of Ecological Expertise: The board includes only two members with a background in ecology, a historic low for Taiwan’s EIA committees.
3. Exclusion of Key Sectors: Representation from the public health and medical sectors has been removed, and there are no members from civil society groups.
4. Conflicts of Interest: The past conduct of some board members has been criticized, including accusations of attempting to limit civil society’s access to review meetings for major energy projects.

Recommendations for Aligning the EIA Process with SDG Principles

To address these deficiencies, civil society groups have proposed reforms aimed at strengthening institutional integrity and fostering genuine multi-stakeholder partnerships (SDG 17).

Enhancing Public Participation and Sustainable Planning (SDG 11, SDG 17)

Recommendations focus on creating a more inclusive and transparent process consistent with sustainable urban and community planning (SDG 11).

• Expand public notification systems for EIA hearings through modern communication channels, such as text messages, to ensure wider public participation.
• Increase the time allocated for civil society groups to present their findings and engage in meaningful dialogue with developers.
• Implement new technologies, including AI, to produce accessible and transparent meeting minutes for public review.

Reforming Institutional Frameworks (SDG 16)

A comprehensive overhaul of the EIA system is required to ensure it functions as an effective instrument for sustainable development.

• Restructure the EIA board to ensure a balanced representation of experts from ecology, public health, social sciences, and civil society.
• Strengthen the legal standing of the EIA process to prevent development projects from proceeding when they fail to secure approval.
• Address the lack of political will to implement systemic reforms, moving beyond the politicization of environmental issues to a consensus-based approach focused on long-term sustainability.

Analysis of SDGs, Targets, and Indicators

1. Which SDGs are addressed or connected to the issues highlighted in the article?

• SDG 16: Peace, Justice and Strong Institutions
• SDG 11: Sustainable Cities and Communities
• SDG 15: Life on Land
• SDG 17: Partnerships for the Goals

2. What specific targets under those SDGs can be identified based on the article’s content?

1. SDG 16: Peace, Justice and Strong Institutions
   • Target 16.6: Develop effective, accountable and transparent institutions at all levels.
     
     The article directly critiques the Environmental Impact Assessment (EIA) process in Taiwan for being an ineffective and non-transparent institution. It states that the process is “accused by environmental groups for being insufficiently transparent and serving as a rubber-stamp process,” where “Most EIAs are passed, and it is relatively rare for EIAs to be rejected.” This points to a lack of effectiveness and accountability.
   • Target 16.7: Ensure responsive, inclusive, participatory and representative decision-making at all levels.
     
     The article highlights the exclusion of civil society and the public from the EIA process. It mentions that under new regulations, “civic groups were only given three minutes each to question developers,” and there were “no representatives from civil society groups” on the EIA committee. The composition of the board, with “10 of the 14 members” having an engineering background and only two with an ecology background, shows a lack of representative decision-making. The call to use “text messages and other means of communication to boost public participation” further underscores the need for more inclusive processes.
2. SDG 11: Sustainable Cities and Communities
   • Target 11.3: By 2030, enhance inclusive and sustainable urbanization and capacity for participatory, integrated and sustainable human settlement planning and management in all countries.
     
     The EIA process is a core component of sustainable planning for development projects. The article’s focus on the flaws within this process—such as it being a “rubber-stamp process” where “development projects go ahead anyway” even when an EIA is turned down—indicates a failure in sustainable planning and management. The demand for more public participation directly relates to the “participatory” aspect of this target.
3. SDG 15: Life on Land
   • Target 15.9: By 2020, integrate ecosystem and biodiversity values into national and local planning, development processes, poverty reduction strategies and accounts.
     
     The purpose of an EIA is to integrate environmental and ecosystem values into development planning. The article criticizes the EIA board’s composition, noting that “there are only two members of the EIA committee who have a background in ecology,” which is the “lowest in the history of EIA committees in Taiwan.” This bias towards “technical viewpoints and the perspectives of engineers over ecology” suggests a failure to properly integrate ecosystem values into the development process.
4. SDG 17: Partnerships for the Goals
   • Target 17.17: Encourage and promote effective public, public-private and civil society partnerships.
     
     The article describes a breakdown in the partnership between the government, private developers, and civil society. It notes that previously, civil society groups “were allowed to dialogue with developers,” but this has been restricted. The current process, where developers are “not obligated to respond to concerns from civil society groups,” demonstrates an ineffective and non-collaborative partnership model.

3. Are there any indicators mentioned or implied in the article that can be used to measure progress towards the identified targets?

1. For Target 16.6 (Effective, accountable, transparent institutions):
   • Implied Indicator: The proportion of EIA applications that are rejected or require significant modification. The article states it is “relatively rare for EIAs to be rejected,” implying that a change in this rate could measure institutional effectiveness.
   • Implied Indicator: Public availability and accessibility of meeting minutes. The suggestion to use “New tools using AI… for accessible meeting minutes” implies that the current accessibility is a measurable issue.
2. For Target 16.7 (Responsive, inclusive, participatory decision-making):
   • Direct Indicator: The number of civil society representatives on the EIA committee. The article explicitly states there were “no representatives from civil society groups.” An increase from zero would be a direct measure of progress.
   • Direct Indicator: The amount of time allocated for civil society groups to speak at hearings. The article specifies the current limit is “three minutes each,” which serves as a baseline for measurement.
   • Implied Indicator: The proportion of the public notified about EIA hearings. The call to use “text messages and other means of communication to boost public participation” suggests that the reach of current notification methods (borough chiefs and township offices) can be measured and improved.
3. For Target 15.9 (Integrate ecosystem values):
   • Direct Indicator: The proportion of EIA committee members with a background in ecology. The article provides a clear baseline: “only two members of the EIA committee who have a background in ecology.” This number can be tracked over time.

4. Table of SDGs, Targets, and Indicators

Source: newbloommag.net