IFC GoodPracticeHandbook CumulativeImpactAssessment PDF
IFC GoodPracticeHandbook CumulativeImpactAssessment PDF
IFC GoodPracticeHandbook CumulativeImpactAssessment PDF
List of Acronyms.......................................................................................................................................................... 3
Acknowledgements.......................................................................................................................................................4
Foreword...................................................................................................................................................................... 5
Executive Summary...................................................................................................................................................... 7
Introduction...............................................................................................................................................................13
IFC’s Context.............................................................................................................................................................15
Section 1. What is Cumulative Impact Assessment and Management, and Why is it Needed?..........................19
1.1 What are Cumulative Impacts?.................................................................................................. 19
1.2 What is Cumulative Impact Assessment and Management?....................................................... 21
1.3 Under What Conditions Should a CIA be Conducted?............................................................. 23
1.4 What are the Expected Outcomes of CIA?................................................................................. 25
1.5 How Does CIA Compare with Other Environmental and Social Risk Management Tools?............... 27
1.5.1 Comparing ESIAs and CIAs........................................................................................... 28
Section 3. What are the Challenges to Implementation of CIA? How can these Challenges Be Overcome?......... 51
3.1 Recommendation 1: Clarify Roles and Responsibilities............................................................... 52
3.2 Recommendation 2: Establish and Maintain a Constructive Relationship
with Government and Other Stakeholders................................................................................ 56
Section 4. Conclusions.........................................................................................................................................57
Table of Contents | 1
Boxes
1. Differentiated Approach: Impact Versus Leverage................................................................................................ 11
2. Demise of the Aral Sea........................................................................................................................................ 20
3 . Valued Environmental and Social Components................................................................................................... 21
4. Hydro Cascade with no Governmental Requirement for CIA.............................................................................. 26
5. Contrasting Views of the Need for Impact Management..................................................................................... 30
6. CIA When Different Project Components are Subject to Separate ESIAs............................................................ 31
7. Rules of Thumb – How to Set Geographical and Temporal Boundaries............................................................... 35
8. Establishing the Spatial Boundary for CIA.......................................................................................................... 36
9. Cumulative Impacts of Climate and Hydropower................................................................................................ 37
10. Strategic Approach to Assessing Multiple Small Developments (Scoping)............................................................ 38
11. Strategic Approach to Assessing Multiple Small Developments (Analysis)............................................................ 42
12. RCIA of Hydro Impacts on American Eel........................................................................................................... 44
13. Shared Responsibility for Management of Cumulative Impacts........................................................................... 48
14. Mitigation of Panama Hydroelectric Developments............................................................................................. 50
15. Regional Collaboration in CIA............................................................................................................................ 53
Appendixes
1. Examples of Indicators for Assessing Incremental Project Impacts and Cumulative Impacts.......................................59
2. Basic Logic Framework – Lessons from CIA Practice........................................................................................... 61
3. Standard Annotated ToR for an RCIA..............................................................................................................................65
References..................................................................................................................................................................71
List of Acronyms | 3
Acknowledgments
The drafting team was composed of Mauricio Athie, Lakhdeep Babra, Susan Botha, Pablo
Cardinale, Patricia Miller, Justin Pooley, and Eric Shayer from IFC, Lorne Greig and
Samantha Boardley from ESSA Technologies, and their consultants Peter Duinker, Robert
R. Everitt and M. Joan Freeman. In addition, this Good Practice Handbook benefited
significantly from extensive comments from an internal and external peer review process,
which involved diverse people and institutions—too many to acknowledge individually.
However, the drafting team is very thankful for their valuable and insightful comments
and hopes they find their input reflected in this final version.
Finally, we would like to thank the Environment, Social and Governance Department’s
knowledge management team, led by Reidar Kvam, and especially Susan Botha, Amelia
Hui Xin Goh, Dickson Tang, Fiorella Facello, and Rashanika Hayley Fowler, who
consistently and diligently accompanied and supported the development of this Good
Practice Handbook.
IFC prides itself on contributing to the continuing evolution in environmental and social
impact and risk management practices, as reflected in our Policy and Performance Standards
on Environmental and Social Sustainability and regular publications of good practice guidance.
One of the biggest risk management challenges currently facing project developers
in emerging markets is the appropriate assessment and management of cumulative
impacts and risks related to their business activities. Factors such as climate change and
unpredictability of climate patterns, increasing and competing water use demands, decline
of species biodiversity, degradation of ecosystem services, and changing socio-economic
circumstances all add complexity to risk assessment and management. Potential system-
wide consequences resulting from the combination of individual effects of multiple
actions overtime are particularly important to understand better.
This GPH recognizes the important role of governments in preparing cumulative impact
assessment frameworks to assist private sector companies in the identification and
management of cumulative impacts. However, the reality is that these frameworks are
rarely available in emerging markets, and more often it is left to the private developer to
try and take into consideration not only its own contribution to cumulative impacts, but
also other projects and external factors that may place their developments at risk.
IFC expects that the six-step process proposed in this GPH will foster the consolidation
of this evolving good practice globally, and assist private sector companies in emerging
markets to identify their contribution to cumulative impacts and guide them in the
effective design and implementation of measures to manage such cumulative effects.
I hope that this handbook will be found useful by practitioners and others having to deal
with cumulative impacts, and that it contributes further to IFC’s mission of promoting
sustainable private sector development.
William Bulmer
Director
Environment, Social and Governance Department
Foreword | 5
Executive Summary
Executive Summary
Executive Summary
Executive Summary
The International Finance Corporation (IFC), the private sector arm of the World Bank
Group, is committed to ensuring that the costs of economic development do not fall
disproportionately on those who are poor or vulnerable. This commitment is implemented
through the January 1, 2012 IFC Policy on Environmental and Social Sustainability and
its corresponding, comprehensive set of eight Performance Standards that define IFC
clients’ responsibilities for managing their environmental and social impacts and risks.
There seems to be significant debate and disagreement among academics, developers, practitioners,
and civil society organizations about whether CIA should be an integral component of a good
environmental and social impact assessment (ESIA) or a separate stand-alone process.
CIA is evolving and there is no single accepted state of global practice. What is important
is that during the process of identifying environmental and social impacts and risks,
developers or project sponsors (a) recognize that their actions, activities, and projects—
their developments1—may contribute to cumulative impacts on valued environmental
and social components (VECs)2 on which other existing or future developments may
also have detrimental effects, and (b) avoid and/or minimize these impacts to the greatest
extent possible. Furthermore, their developments may be at risk because of an increase in
cumulative effects over ecosystem services they may depend on.
Good practice requires that, at a minimum, project sponsors assess during the ESIA
process whether their development may contribute to cumulative impacts on VECs and/
or may be at risk from cumulative effects on VECs they depend on.
This Good Practice Handbook proposes as a useful preliminary approach for developers in
emerging markets the conduct of a rapid cumulative impact assessment (RCIA). The RCIA
can be an integral component of the ESIA or a separate process. It entails a desk review that,
1
The term development is used throughout this document to refer to projects, actions, or business activities
potentially subject to a CIA.
2
See Box 3 for definition of VECs.
Executive Summary | 7
in consultation with the affected communities and other stakeholders, enables the developer
to determine whether its activities are likely to significantly affect the viability or sustainability
of selected VECs. The proposed approach recognizes that, especially in emerging markets,
the many challenges associated with managing a good CIA process include lack of basic
baseline data, uncertainty associated with anticipated developments, limited government
capacity, and absence of strategic regional, sectoral, or integrated resource planning schemes.
Given the many challenges, this handbook recommends that developers:
Figure 1 illustrates the RCIA logical framework, which is an iterative six-step process: scoping
(Steps 1 and 2), VEC baseline determination (Step 3), assessment of the contribution of the
development under evaluation to the predicted cumulative impacts (Step 4), evaluation
of the significance of predicted cumulative impacts to the viability or sustainability of the
affected VECs (Step 5), and design and implementation of mitigation measures to manage
the development’s contribution to the cumulative impacts and risks (Step 6).
Assess cumulative impacts and evaluate their significance over VECs’ predicted future conditions
STEP 6
Design and implement: (a) adequate strategies, plans, and procedures to manage cumulative impacts,
(b) appropriate monitoring indicators, and (c) effective supervision mechanisms
3
For good practice, please refer to IFC’s Stakeholder Engagement: A Good Practice Handbook for Companies
Doing Business in Emerging Markets, available at www.ifc.org/HB-StakeholderEngagement
There is no fundamental conceptual difference between a RCIA and a CIA; the first is a
simplified version of the second. The preliminary screening exercise resulting from a RCIA
may evolve into a CIA. The only difference in practice is that typically an RCIA involves
only a desk review of available information, including existing ESIAs; strategic, regional,
and/or resource planning documents; and reports from nongovernmental organizations
(NGOs), the scientific community, and other interested actors. A CIA is likely to involve
a complex governance structure and consultation with several parties and stakeholders to
determine the VECs to assess, the baseline data requirements and sampling methodology,
acceptable future conditions of VECs, indicators and thresholds, mitigation measures,
monitoring protocols, and supervision mechanisms.
When a government-led CIA exists, or when there are clear requirements related to a
specific management unit (e.g., watershed, airshed, flyway, or landscape) resulting from
regional, sectoral, or integrated resource or strategic planning efforts, private sector actors
simply need to comply with the overarching requirements of the existing CIA.
Where resource inventories and plans do not exist, this GPH proposes that private sector
sponsors should at least perform a RCIA. The initial screening results of the RCIA will
provide several potential scenarios (Box 1):
4
Available at http://www.ceaa-acee.gc.ca/default.asp?lang=En&n=43952694-1&toc=show.
Executive Summary | 9
• Significant risk for cumulative impacts/significant leverage: The development under
consideration represents a significant contributor to the expected cumulative impacts or
will be the first of several future reasonably anticipated developments that will use the same
resource and/or potentially affect the same VECs. In these cases, through consultation with
stakeholders, the RCIA will help assess potential cumulative impacts that could be expected
over time, and guide the developer in defining the required mitigation measures. The private
developer can use Step 6 to design a strategy to appropriately manage cumulative impacts and
provide advice to the government on the appropriate governance structure to ensure other
developers will follow suit. This is an ideal case, where the private sector sponsor can capitalize
on the ESIA process, including baseline generation and stakeholder engagement, and the
RCIA may organically evolve into a more robust CIA process and contribute to leveraging
governments by outlining a strategic approach to managing cumulative impacts.
• Significant risk for cumulative impacts/limited leverage: The development under
consideration is immersed in an environment where the cumulative impacts are evident
but the issues are complex, many actors are already involved, and the solution is clearly
beyond any individual project sponsor. In this case, the RCIA will help the developer
(a) determine the significance of the overall cumulative impacts and its contribution
to these cumulative impacts, and (b) design environmental and social management
plans and procedures to appropriately mitigate those contributions. In this case, the
developer should be accountable only for the design and implementation of mitigation
measures commensurate with the magnitude and significance of its contribution to the
cumulative impacts. However, individual sponsors should use their best efforts to engage
other developers, governments, and other stakeholders in acknowledging the cumulative
impacts and risks and in designing coherent management strategies to mitigate them.
• Limited to no contribution to cumulative impacts: The RCIA determines that even though
there are clear cumulative impacts, the development’s contribution to the cumulative impacts
over the affected VECs are negligible or nil. In this case, no measures other than the ones
resulting from the ESIA process would be necessary. In this situation, however, if there are
cumulative impacts from other sources that are not being addressed, the developer may
consider it pertinent to draw this to the attention of the government or other stakeholders,
and assess whether its project may be at risk from the unmanaged cumulative effect.
This GPH emphasizes, therefore, that ultimately governments are responsible for preparing
CIA frameworks to assist private sector actors in the identification and management of
cumulative impacts. Because these frameworks rarely exist in emerging markets, this GPH also
recognizes that it is clearly still in the private developer’s interest to take into consideration not
only its own contribution to cumulative impacts, but also other projects and external factors
that may affect similar VECs. Not doing so may place the developer’s own efforts at risk and
also negatively affect its reputation. However, undertaking this process can be challenging and
requires the cooperation of government, other developers, and other stakeholders.
Significant Impact/High Leverage: The first project under consideration is a hydroelectric power plant in the
Kabeli River, which is currently requesting cofinancing from the International Development Association (IDA) and
IFC. It is a dual purpose peaking, run of river, 37.6 MW hydroelectric power plant, located about 620 km east
of Kathmandu. The Kabeli River is an important tributary in the Tamor River watershed. This is expected to be
the first power plant constructed in this remote area of the country, but twenty four other hydropower projects
are in various stages of consideration to be developed in the Tamor River basin. Six projects will be on the Kabeli
River and its tributaries; the remaining ones are to be constructed on Tamor River or its tributaries. All of the
projects planned within the Kabeli watershed, are located upstream of the project under IFC consideration. As
currently planned, hydroelectric power development of the Tamor River is likely to convert this natural habitat
into a fragmented river with regulated flows. Because this HPP is the first project to be constructed in the Tamor
River watershed and it is the one farthest downstream in the Kabeli before its confluence with the Tamor River,
consideration of cumulative impacts at the Tamor River watershed level is crucial. To proceed with financing,
IDA and IFC are working together as the World Bank Group to ensure a CIA is performed at the Tamor River
watershed level. This process is just beginning, but it is expected to be led by the government and involve a
wide range of stakeholders in the selection of the VECs to focus on, determination of indicators and thresholds,
management strategies, and monitoring indicators and supervision mechanisms. A potential management
solution includes consideration of an “intact river” approach in which another major tributary of the Tamor
would be left untouched. In addition, all projects in the watershed will need to follow design and operational
criteria and mitigation measures developed by the project under consideration in order to manage cumulative
impacts over the selected VECs.
Significant Impact/Limited Leverage: A very different case is the consideration for financing of another
HPP on the Upper Trishuli. This is a 216 MW plant located about 50 km directly north of Kathmandu. Two
other HPPs operate in the Trishuli River downstream from the proposed project. Two additional projects are
under construction, one upstream from the proposed project and the other between the proposed project
and an existing project downstream. The cumulative impacts are evident not only in terms of aquatic habitat
fragmentation but also in terms of overall degradation of the catchment area (e.g., deforestation, erosion,
multiple access roads, and transmission lines). In this case, for IFC financing to proceed, the company has
been asked to update the ESIA, strengthening the ecological and social baselines, improving the stakeholder
engagement process, and performing a RCIA to assess cumulative impacts and determine the project’s potential
contribution to the most significant cumulative impacts, namely fish migration, loss of aquatic and riparian
habitat, catchment erosion, and landscape fragmentation. The company will be required to include plans and
procedures to mitigate identified cumulative impacts as part of the environmental and social management
plan, and with the help of the IBRD, use best efforts to work with the government, other sponsors, the affected
community and other stakeholders to coordinate efforts to manage cumulative impacts at the watershed level.
Executive Summary | 11
12 | Good Practice Handbook: Cumulative Impact Assessment and Management
Introduction
Introduction
Introduction
Introduction
The U.S. Council on
Environmental Quality The major environmental and social management challenges that we face today—climate
(1997, Executive Summary change, loss of biodiversity, the decline of ocean fisheries, limitations on food security, the
page v) defines cumulative scarcity of usable freshwater resources, displacement of communities with consequent
effects assessment (CEA) increases in urban poverty, and inviability of traditional local livelihoods—are all the result of
as follows: “the impact
on the environment which cumulative impacts5 from a large number of activities that are for the most part individually
results from the incremental insignificant, but together have had regional or even global repercussions. The importance
impact of the action when of understanding the cumulative environmental and social impacts from multiple projects,
added to their past, present actions, or activities—or even from the same actions over an extended period of time—located
and reasonably foreseeable
future actions regardless in the same geographic region or affecting the same resource (e.g., watershed, airshed) has been
of what agency (federal acknowledged for decades. In some cases, the most ecologically devastating environmental
or non-federal) or person effects and subsequent social consequences may result not from the direct effects of a particular
undertakes such other action, project, or activity but from the combination of existing stresses and the individually
action.”
minor effects of multiple actions over time (Clarke 1994).
Hegmann et al. (1999,
Section 2, page 3) Consequently, although the environmental and social impact assessment (ESIA) process is
define cumulative effects essential to assessing and managing the environmental and social impacts of individual projects,
as “changes to the
environment that are caused it often may be insufficient for identifying and managing incremental impacts on areas or
by an action in combination resources used or directly affected by a given development from other existing, planned, or
with other past, present and reasonably defined developments at the time the risks and impacts are identified.
future actions.”
5
It should be noted that the terms “impact” and “effect” are used interchangeably throughout this handbook.
They both describe any change that a development may cause in a selected VEC.
Introduction | 13
Cumulative impacts are contextual and encompass a broad spectrum of impacts at
different spatial and temporal scales.6 In some cases, cumulative impacts occur because
a series of projects of the same type are being developed; for example, when several
hydroelectric projects are constructed or planned on the same river or within the same
watershed, when multiple oil and gas projects or mines are developed in close proximity,
or when a number of wind farms are constructed or planned within the same flyway or
region. In other cases, cumulative impacts occur from the combined effects over a given
resource of a mix of different types of projects; for example, the development of a mine
site, access roads, transmission lines, and other adjacent land uses.
This Good Practice Handbook is based on IFC’s experience in applying its Performance
Standards and is nonprescriptive in its approach. It should be used in conjunction
with the Performance Standards, their Guidance Notes, and the World Bank Group
Environmental, Health, and Safety Guidelines, which contain basic requirements
and good international practices to be followed when designing, developing, and/or
implementing projects. This document is not intended to duplicate requirements under
the existing IFC Sustainability Framework. Its purpose is to provide practical guidance
to companies investing in emerging markets to improve their understanding, assessment,
and management of cumulative environmental and social impacts associated with their
developments.
A given impact may be generated at a specific site or moment in time, but its consequences may be felt in a
6
different geographical area (e.g., downwind or downstream), or materialize sometime later (e.g., bioaccumulation,
attainment of a resilience threshold). This transcends the traditional “direct area of influence” (DAI) concept, and
underscores the need for analysis of indirect and cumulative effects, as well as the need to expand the geographical
boundaries of the impact assessment and/or the time frame used for the analysis.
For private sector management of cumulative impacts, IFC considers good practice to be
two pronged:
Defined in Performance Standard 1, paragraph 3, as the strategy to first anticipate and avoid impacts on
7
and risks to workers, the environment, and/or Affected Communities or, where avoidance is not possible,
to minimize impacts and risks. Acceptable options for minimizing will vary and include abating, rectifying,
repairing, and/or restoring. Finally, where residual impacts remain, these must be compensated for and/or offset.
It is important to note that compensation and/or offsets are the mechanisms proposed for managing residual
impacts, not cumulative impacts. This is an important clarification as it is impractical for a single sponsor to
offset cumulative impacts. However, regional offset of cumulative impacts could still be possible as part of a
collaborative CIA mitigation led by the government or a coalition of developers.
IFC’s Context | 15
Even though Performance Standard 1 does not expressly require, or put the sole onus on,
private sector clients to undertake a CIA, in paragraph 11 it states that the impact and
risk identification process “will take into account the findings and conclusions of related
and applicable plans, studies, or assessments prepared by relevant government authorities
or other parties that are directly related to the project and its area of influence” including
“master economic development plans, country or regional plans, feasibility studies,
alternatives analyses, and cumulative, regional, sectoral, or strategic environmental
assessments where relevant.” Furthermore, footnote 17 states, “the client can take these
into account by focusing on the project’s incremental contribution to selected impacts
generally recognized as important on the basis of scientific concern or concerns from the
Affected Communities within the area addressed by these larger scope regional studies or
cumulative assessments.”
Therefore, although the total cumulative impacts due to multiple projects typically
should be identified in government-sponsored assessments and regional planning efforts,
according to Performance Standard 1, IFC clients are expected to ensure that their own
assessment determines the degree to which each project under review is contributing to
the cumulative effects. This handbook acknowledges the importance of differentiating
between those actions over which a private sector sponsor has direct control and those
for which it may have leverage to influence others to achieve optimal cumulative impact
management as part of a multistakeholder effort—an effort that ideally should be led by
government agencies, but at a minimum must involve government agencies.8 Figure 2
illustrates the overall context and proposed approach that exemplifies general compliance
with Performance Standard 1.
8
For further details, see Franks, Everingham, and Brereton 2012.
Government and regional planners have the ultimate responsibility for CIA
Leverage Control
RCIA
Use best efforts to engage all relevant
Identify relevant VECs
stakeholders to agree on VECs, and on
each and all parties responsibilities in the: Are project’s incremental
(a) management of the expected impacts Cumulative impacts
contributions to
on VECs, and will occur regardless
cumulative impacts
of the project?
(b) monitoring and/or supervision of the significant?
(b.1) overall condition of the VECs and
(b.2) the appropriate implementation Follow mitigation hierarchy
of agreed mitigation measures.
Design management strategies that are
coherent with the expected impacts on VECs and
commensurate with the project’s contribution
IFC’s Context | 17
18 | Good Practice Handbook: Cumulative Impact Assessment and Management
Section 1. What is Cumulative Impact Assessment
and Management, and Why is it Needed?
Cumulative impacts are those that result from the successive, incremental, and/or
combined effects of an action, project, or activity (collectively referred to in this document
as “developments”) when added to other existing, planned, and/or reasonably anticipated
future ones. For practical reasons, the identification and management of cumulative
impacts are limited to those effects generally recognized as important on the basis of
scientific concerns and/or concerns of affected communities.9
Multiple and successive environmental and social impacts from existing developments,
combined with the potential incremental impacts resulting from proposed and/or
anticipated future developments, may result in significant cumulative impacts that would
not be expected in the case of a stand-alone development.10 Box 2 provides an example.
9
Affected communities are defined as local communities directly affected by the project (Performance Standard
1, paragraph 1).
10
See GN1, paragraph GN37.
The cumulative impacts have aggregated over the past 30 years. Source: NASA Earth Observatory, http://
By 1986, the Aral Sea had split into two water bodies, the earthobservatory.nasa.gov/Features/WorldOfChange/
aral_sea.php.
“Southern Aral Sea” and “Northern Aral Sea.” By 2002, the level
of the Southern Aral Sea had fallen by 22 m. By 2005, the Aral Sea
had shrunk to half of its former size and its volume had diminished by 75 percent. Kazakhstan built a dam between
the northern and southern parts of the Aral Sea. Completed in 2005, the dam was basically a death sentence for
the southern Aral Sea, which was judged to be beyond saving. All of the inflow from the Syr Darya now stays in the
Northern Aral Sea. The Southern Aral Sea continues to shrink. The shallow eastern basin all but disappeared in 2009
after four years of drought reduced and eventually stopped any inflow from the Amu Darya. In 2010, the drought
ended and water entered the eastern basin once again. But in 2011, less water entered the basin. Water levels in
2011 were lower than in any previous year except 2009.a
The magnitude of the cumulative socioeconomic impacts is almost unprecedented. The retreat of the Aral Sea
shoreline decimated former ports and fishing communities. The once abundant fishery has virtually ceased to
exist. The increasingly saline water of the rivers has become polluted with fertilizer and pesticides. The blowing
dust from the exposed seabed, contaminated with agricultural chemicals, is a public health hazard as it settles
onto fields, degrading the soil.b Much of the former Aral Sea Basin has now become desert. Rusted hulks of
boats and ships lie abandoned in the desert as a poignant reminder of this once great aquatic ecosystem.
One can argue that the demise of Aral is a trade-off against the socioeconomic benefits of irrigated agriculture.
Unfortunately, unsustainable land and water management practices combined with poor maintenance of
irrigation infrastructure has led to severe land degradation. Vast stretches of irrigated land in the Amu Darya
and Syr Darya river basins are now salinized or waterlogged, as are many other areas in Central Asia. Estimates
are that more than half of the irrigated land in Central Asia is salinized or waterlogged (ADB 2010, 154–56).
a
See “Our Amazing Planet,” http://www.ouramazingplanet.com/1805-aral-sea-continues-to-shrink.html.
b
See NASA Earth Observatory, http://earthobservatory.nasa.gov/Features/WorldOfChange/aral_sea.php.
CIA is the process of (a) analyzing the potential impacts and risks of proposed developments in
the context of the potential effects of other human activities and natural environmental and social
external drivers on the chosen VECs over time, and (b) proposing concrete measures to avoid,
reduce, or mitigate such cumulative impacts and risk to the extent possible.
The key analytical task is to discern how the potential impacts of a proposed development might
combine, cumulatively, with the potential impacts of the other human activities and other natural
stressors such as droughts or extreme climatic events. VECs are immersed in a natural ever-changing
environment that affects their condition and resilience. VECs are integrators of the stressors that affect
them. For example, periodic extremes of precipitation (droughts or floods), temperature (extreme cold
or heat), or fluctuations in predators all affect the condition of biological VECs. Today and into the
future, global warming (climate change) can be expected to have substantial impacts on the condition
of VECs. Box 3 provides a further explanation on VECs.
CIAs are complex, and cost time and money. For a CIA to be effective in supporting good overall environmental and
social risk management, its scope must be properly defined. Because it is unrealistic to think that every environmental
and social aspect that can be subject to cumulative impacts can be appropriately factored into a CIA, it is good practice
to focus the assessment and management strategies on Valued Environmental and Social Components (VECsa).
While VECs may be directly or indirectly affected by a specific development, they often are also affected by the
cumulative effects of several developments. VECs are the ultimate recipient of impacts because they tend to be at the
ends of ecological pathways. Throughout this handbook the acronym VECs refers to sensitive or valued receptors of
impact whose desired future condition determines the assessment end points to be used in the CIA process.
The identification of assessment end points is a critical step in any risk assessment. To guide subsequent analysis,
the identification of end points needs to be initiated during the scoping phase (Section 2, Steps 1 and 2) through
social and ecological scoping. Social scoping through participatory, meaningful, and transparent consultation and
good-faith engagement with affected communities and/or stakeholders is used to establish the terms in which
a
Acronym originally coined by Beanlands and Duinker (1983) to refer to “valued ecosystem components.”
cumulative impacts should be expressed (i.e., which environmental attributes or components of the environment
will be the subject of CIA). Ecological scoping is used to identify how impacts can be studied and predicted. VECs
should reflect public concern about social, cultural, economic, or aesthetic values, and also the scientific concerns
of the professional community (Beanlands and Duinker 1983). It is important that VECs build from existing
definitions of valuable environmental and social components described in the Performance Standards (e.g., critical
habitat in Performance Standard 6 and critical cultural heritage in Performance Standard 7). For VECs related to
biodiversity, GN6 provides explicit guidance on natural and critical habitat values.
Good CIA focuses on understanding whether cumulative impacts will affect the sustainability or viability of a VEC as
indicated by the predicted condition of the VEC. Consequently, the significance of cumulative impacts is judged in the
context of thresholds or limits of acceptable change, within which the VEC condition is considered to be acceptable but
beyond which further change in condition is not acceptable. If such thresholds are not established, the significance of
cumulative impacts cannot be determined. Step 5 in Section 2 better describes the importance of defining thresholds
for assessing the significance of cumulative impacts and designing effective management strategies.
The viability or sustainability of VECs depends upon both the forces that affect them and their social and
ecological vulnerability (sensitivity), i.e., the degree to which they are susceptible to and unable to cope with
injury, damage, or harm.
Defining thresholds of acceptable VEC condition involves social and ecological scoping informed by scientific
understanding. In setting them, one considers points at which there is an abrupt change in a VEC condition,
where small changes in a given environmental or social driver produce large responses in the condition of the
VEC (after Groffman et al. 2006). Ecological thresholds for physical VECs such as air, water, and soil quality are
often readily available in either government-established ambient quality standards or in international scientific
literature. Thresholds may in some cases be determined from Performance Standards and Guidance Notes (e.g.,
biodiversity-related critical habitat thresholds in GN6). See Appendix 1 for examples of indicators of cumulative
impacts that are required to be addressed in meeting the IFC Performance Standards.
1. Assess the potential impacts and risks of a proposed development over time, in the
context of potential effects from other developments and natural environmental and
social external drivers on a chosen VEC.
2. Verify that the proposed development’s cumulative social and environmental impacts
and risks will not exceed a threshold that could compromise the sustainability or
viability of selected VECs.
3. Confirm that the proposed development’s value and feasibility are not limited by
cumulative social and environmental effects.
4. Support the development of governance structures for making decisions and
managing cumulative impacts at the appropriate geographic scale (e.g., airshed, river
catchment, town, regional landscape).
5. Ensure that the concerns of affected communities about the cumulative impacts of a
proposed development are identified, documented, and addressed.
6. Manage potential reputation risks.
11
Government-led CIAs may differ on these objectives and focus on ensuring the future health of the VECs.
• when a series of mining developments occur within an area where they will impact
the same VECs (perhaps common water bodies or watercourses, wildlife populations,
community health, community loss of access to assets, or multiple land takings);
• when a series of hydroelectric developments occur within the same river or within
the same watershed with cumulative impacts in common on flora and fauna, on
downstream water availability or quality, on watershed sediment dynamics, on
navigation, on local communities’ livelihoods, or on adjacent land uses because of
increased access from associated roads; or
• When a series of agricultural developments occur that will cumulatively impact land use
patterns, having cumulative impacts on downstream water availability (from withdrawal
of water for irrigation), on downstream water quality, or on local community livelihoods.
Good CIA practice is not limited to assessing the impacts of developments of the same
type. For example, CIA might be needed for the development of a mine in association
with increased access from road construction that will bring further induced development
(perhaps in association with developments in adjacent forest management, hydroelectric
power developments, agriculture or other activities, all of which may affect local
communities, wildlife, or water availability and quality).
In some cases, CIA may be needed to assess and manage the impacts of several new
projects, activities, or actions that are being developed or planned. In other situations,
CIA of a single new development may be appropriate when it occurs in an area where
concerns exist about cumulative impacts—concerns that are either well documented or
identified through consultation with affected communities and other stakeholders. In
some situations, different components of the same development13 are assessed in separate
ESIAs, and the cumulative impacts from these components should be subject to CIA. The
key point in determining the need for CIA is that one or more VECs will be cumulatively
impacted by different developments, whatever they may be.
12
Cumulative impacts can occur (a) when there is “spatial crowding” as a result of overlapping impacts from
various actions on the same VEC in a limited area, (e.g., increased noise levels in a community from industrial
developments, existing roads, and a new highway; or landscape fragmentation caused by the installation of
several transmission lines in the same area) or (b) when there is “temporal crowding” as impacts on a VEC from
different actions occur in a shorter period of time than the VEC needs to recover (e.g., impaired health of a fish’s
downstream migration when subjected to several cascading hydropower plants).
13
Including associated facilities and other related infrastructure such as roads, ports, railroads, bridges, or terminals.
The expected outcomes of a good CIA can be summarized as follows (Section 2 provides
greater detail):
• Identification of all VECs that may be affected by the development under evaluation.
• In consultation with stakeholders, agreement on the selected VECs the assessment
will focus on.
• Identification of all other existing and reasonably anticipated and/or planned and
potentially induced developments,14 as well as natural environmental and external
social drivers that could affect the selected VECs.
• Assessment and/or estimation of the future condition of selected VECs, as the result
of the cumulative impacts that the development is expected to have, when combined
with those of other reasonably predictable developments as well as those from natural
environmental and external social drivers.
• Evaluation of the future condition of the VECs relative to established or estimated
thresholds of VEC condition or to comparable benchmarks.
• Avoidance and minimization, in accordance with the mitigation hierarchy, of the
development’s impact on the VECs for the life of the development or for as long as
the impacts continue to be present.
• Monitoring and management of risks to VEC viability or sustainability over
the life span of either the development or its effects, whichever lasts longer.15
14
As identified in diverse sources such as sectoral project inventories, regional or resources development plans,
and watershed management plans, among others.
15
Interactions with government and third parties should be included in risk management actions.
Because cumulative impacts often result from the successive, incremental, and/or
combined16 impacts of multiple developments, responsibility for their prevention and
management is shared among the various contributing developments. Because it is usually
beyond the capability of any one party to implement all of the measures needed to reduce
or eliminate cumulative impacts, collaborative efforts will likely be needed. Governments
can play a significant role in ensuring environmental and social sustainability by providing
and implementing enabling regulatory frameworks that guide and support the appropriate
identification and management of cumulative impacts and risks (See Box 4).
In one case, 37 hydroelectric projects (2 existing, 9 under construction, and 26 proposed) would occur
within a single river basin where the host country had no regulatory requirement for CIA. IFC supported
two clients who were involved with several projects—some in close proximity and others located in another
part of the basin. Despite the lack of a regulatory requirement for CIA, IFC worked with the proponents to
develop a collaborative CIA and coordinated impact monitoring program, which was implemented through
a steering committee composed of companies and government agencies. The CIA was not limited to the
specific projects of the two proponents but set the spatial context as the entire river basin. The CIA found
that without management there would likely be significant cumulative impacts on the water flow regime,
water quality, and the aquatic environment.
In addition, IFC collaborated with the IBRD to raise the awareness of the host country to the issue of
cumulative impacts. A workshop was organized at which the intensity of development and results of the CIA
were discussed with government representatives and consensus was reached that development of a formal
CIA requirement was imperative; that there was a clear need for basin management planning; and that
there was still time for effective CIA. In addition, it was proposed that when multiple small-scale hydropower
projects were being planned (which would not individually trigger an ESIA requirement), CIA for the overall
set of projects would be an appropriate alternative to project-specific impact assessment.
16
Combined impacts can be either additive (e.g., equal to the sum of individual effects), synergistic (e.g., total
effect is greater than the sum of the individual effects), or antagonistic (e.g., individual effects counteract or
neutralize each other).
1.5 How Does CIA Compare with Other Environmental and Social
Risk Management Tools?
CIA is one of several tools to consider as part of an overall process of environmental and
social risk assessment and management. These tools, identified in Table 1, have been
developed to inform decision-making processes in different project development and/or
sector planning contexts.
TABLE 1. TOOLS FOR ENVIRONMENTAL AND SOCIAL RISK ASSESSMENT AND MANAGEMENT
Environmental • Applies to the potential impacts of a particular development proposal
and Social Impacts • Done in the context of a well-defined development proposal for which the construction
Assessment (ESIA) and operational details of the development alternatives are known
• May include an assessment of the project’s contribution to a well-known accumulated
impact and propose standard mitigation measures (e.g., greenhouse gas emissions, airshed
pollution, depletion of wild fish stocks)
Strategic • Relates to potential impacts of governmentwide or sectorwide policies, plans, or programs
Environmental • Anticipates how instruments such as policies that are not specifically tied to a particular
Assessment (SEA)21 physical development may result in a variety of impacts at different times and places
Regional or Sectoral • Assesses the impacts of the potential developmental future of a geographic region or of an
Impact Assessment overall sector or industry (sometimes referred to as regional or sectoral SEA)
Cumulative Impact • Assesses the ecological and social impacts that determine the status of environmental
Assessment and components and affected communities (VECs)
Management (CIA) • Requires consideration of past, present, and future projects and natural drivers that affect them
• Assessment reflects the geographical and temporal context in which the effects are
aggregating and interacting (e.g., airshed, river catchment, town, landscape)
17
See http://siteresources.worldbank.org/INTFORESTS/Resources/OP401.pdf and http://web.
worldbank.org/WBSITE/EXTERNAL/TOPICS/CSO/0,,contentMDK:20064724~pagePK:220503~
piPK:220476~theSitePK:228717~isCURL:Y~isCURL:Y~isCURL:Y~isCURL:Y~isCURL:Y,00.html.
18
See http://web.worldbank.org/WBSITE/EXTERNAL/TOPICS/CSO/0,,contentMDK:20066691~page
PK:220503~piPK:220476~theSitePK:228717~isCURL:Y~isCURL:Y~isCURL:Y,00.html.
19
See World Bank, 2011, “Strategic Environmental Assessment in Policy and Sector Reform,” http://siteresources.
worldbank.org/ENVIRONMENT/Resources/244380-1236266590146/Policy_SEA_WB.pdf, World Bank,
2008; and “Strategic Environmental Assessment for Policies: An Instrument for Good Governance,” http://
siteresources.worldbank.org/INTRANETENVIRONMENT/1705772-1210788188539/21819527/SEA_
FOR_POLICIES.pdf.
20
See http://web.worldbank.org/WBSITE/EXTERNAL/TOPICS/EXTPSIA/0,,contentMDK:21717714~menu
PK:6145452~pagePK:148956~piPK:216618~theSitePK:490130~isCURL:Y~isCURL:Y~
isCURL:Y~isCURL:Y,00.html.
21
See World Bank, OP 4.01, footnotes 11 and 12.
ESIAs22 and CIAs share the same basic logical framework and analytical process and tools (see
Appendix 2 for a basic logic framework for a CIA); however, they take different perspectives.
The perspectives can be characterized as project-centered (ESIA) or VEC-centered (CIA).
As illustrated in Figure 3, in an ESIA the focus of analysis begins with the project. The area
where the project will have environmental and social impacts is identified as are the VECs
that will be affected. The impacts on the VECs are identified and a mitigation hierarchy23 is
applied to avoid them when possible and to minimize and mitigate them when avoidance
is not possible. Where residual impacts remain, impacts and risks to workers, affected
communities, and the environment are compensated or offset.
Indirect Impact
Impact 2
PROJECT
Impact
1
Impact
3
22
For further details on ESIA and good practices related to the resulting ESMS, please refer to Performance
Standard 1 and GN1 as well as Performance Standards 2–8 and their corresponding GNs.
23
Please refer to footnote 7.
• The anticipated future condition, which is the total effect of the other existing, and
predictable future developments and external natural environmental and social drivers, and
• The contribution of the development under evaluation to the cumulative impacts.
In the CIA context, the incremental impact of a development under review is the difference
between the condition of the VEC when impacted only by the other developments in the
future baseline and the condition of the VEC when impacted by both the development
under review and the future baseline impacts (Figure 5 ). In the context of ESIA and CIA,
a project’s incremental impacts are the same but are viewed differently—and the views can
give very different assessments of the need for impact management (see Box 5).
Proposed action’s
impact on the VEC + Other past, present, and
future impact on the VEC = Cumulative impact
on the VEC
The ESIA for a metals refining operation in an emerging market country concluded simply that because the
concentration of heavy metals in the discharge to a river would be lower than the country’s discharge standard
that the project should proceed as designed. No additional mitigation was identified. However, the river was
already badly degraded; the ambient concentrations of heavy metals already exceeded the ambient water quality
standards, human health was being compromised, and officials in the city downstream were struggling to find
ways to improve water quality. In this context, either project relocation or additional mitigation to reduce the
discharge of heavy metals to the maximum extent possible would have been appropriate, together with other
mitigations to reduce the loading from existing sources. This case illustrates the importance of informed strategic-
level resource planning, such as integrated resources plans, which often are critical to successful CIAs.
The different views can be seen in how indicators are used to characterize an impact. In
ESIA, indicators may be chosen to reflect the incremental change in a VEC, while in
CIA indicators are chosen to reflect the resulting condition of the VEC. Appendix 1 lists
comparisons of indicators that reflect an incremental project impact (a change in the VEC),
with indicators that reflect the condition of the VEC. During the CIA scoping stages
(Section 2 – Steps 1 and 2), the choice of VECs and their indicators is critical to the success
of the assessment (see Box 6).
The two different views are not always distinct, and as noted before, CIA can be fully
integrated throughout a good ESIA process. This approach has been advocated by many
practitioners (see Duinker 1994 or Duinker and Greig 2006). ESIAs should be conducted
in a manner that supports systematic CIA.
For a large mining project, under host-country regulatory requirements the proponent was required to submit
separate ESIAs for the various project components: the mine site, the transmission line that will provide power
to the site, and the road that was upgraded and extended to the site. The ESIAs were not only submitted
separately but also submitted in different years and did not address cumulative impacts.
At a later date, to meet the requirements of the Equator Principles and IFC Performance Standards, the proponent
was required to complete a CIA of the project’s components with other projects and activities in the area. This
included updating and filling gaps in baseline data.
The scope of the CIA was defined by the value and/or significance of the potential cumulative effect to
stakeholders (based on the valuation of the environmental and social elements that are relevant to the
stakeholders); the potential significance of cumulative impacts to biological receptors and/or habitats; and the
temporal and physical boundaries for potential cumulative effects for those elements.
Cumulative impacts were deemed to occur when the effects of project components, other projects, and/or
other land use activities (i.e., not just other mining projects) overlap with each other by affecting the same VECs.
For example, project components will eliminate important wildlife habitat, which will likely diminish the area’s
carrying capacity for key species. Together these project impacts will have a cumulative impact on the status of
the species, even though the impacts are of different types and result from very different activities.
Implementing a CIA
Process for
Implementing a CIA
Process for
The following six-step process and the appendices that follow lead users of this handbook from
the scoping phase to the management phase, providing key questions to consider along the
way. Additional relevant guidance may exist in the Performance Standard Guidance Notes.
Keep in mind that the process for CIA must be flexible; the steps may not proceed
in sequence and may need to be implemented iteratively, with some steps revisited in
response to the results of others. For example, in the issue identification (scoping) step,
consideration of potential effects is often repeated, with the findings and analysis refined
each time, until a final list of issues is produced.24
Objectives:
• Identify and agree on VECs in consultation with stakeholders.
• Determine the time frame for the analysis.
• Establish the geographic scope of the analysis.
Questions to answer:
• Whose involvement is key?
• Which VEC resources, ecosystems, or human values are affected?
• Are there concerns from existing cumulative impacts?
This step is critical to successful CIA because it establishes the scope of the analysis of
cumulative impacts. Critical to the success of scoping is that it appropriately characterizes
the context for the analysis (i.e., context scoping, as identified by Baxter et al. 2001). If not
already done, identification of the key participants should be completed early in this step
and updated as needed as the overall process proceeds. Best practice involves an open,
participatory, transparent, and meaningful consultation with affected communities and other
relevant interested parties as early in the scoping phase as possible. As described in Section 3,
this is one of the major challenges associated with a CIA process. For a description of an ideal
arrangement of stakeholder roles and responsibilities, please refer to Table 3 in that section.
24
The CIA (or RCIA) should include the entire list of potential effects that were identified during the scoping
process, identify any potential effects the CIA will not examine in detail, and describe the rationale for
eliminating them from further evaluation. At the start, all potential effects are identified but by the end, the
list of issues will have been reduced to a list of key issues to examine in detail in the CIA.
Appendix 1 contains an illustrative list of potential VECs identified for each IFC
Performance Standard.
Boundaries for the analysis need to encompass the geographic and temporal extent of impacts
(from other past, present, and predictable future developments) that influence VEC condition
throughout the time period during which project impacts will occur. This scope is likely to
extend beyond a project’s direct area of influence (DAI) as typically defined in ESIA (see Box 7).
This is typically an iterative process in which the first boundaries are often set by educated
guess but incrementally improved as new information indicates that a different boundary is
required for the analysis. Boundaries are expanded to the point at which the VEC is no longer
affected significantly or the effects are no longer of scientific concern or of interest to the affected
communities. For example, in the case of biodiversity values, habitat ranges or migration
pathways are often used as boundary-defining variables. By contrast, if landscape fragmentation
is at stake in a transportation project, the likely extension of secondary and tertiary roads, along
with population growth, are well-established risk factors to consider. In any case, the CIA should
explain the basis for the final delineation of the geographic and temporal boundaries. VECs
for which the project will have no direct or indirect impact do not need to be the subject of
CIA. Priority should be given to those VECs that are likely to be at the greatest risk from the
development’s contribution to cumulative impacts (see Box 8).
The suggested rules of thumb to determine the geographic boundaries for the analysis are as follows:
a. Include the area that will be directly affected by the project or activity (DAI - in the traditional ESIA sense).
b. List the important resources (VECs) within the DAI.
c. Define if these VECs occupy a wider area beyond the DAI.b
d. Consider the distance an effect can travel, and other impacts the VEC may be exposed to within its range.
The proposed basic rules of thumb to determine the temporal boundaries for the assessment are as follows:
I. Use the time frame expected for the complete life cycle of the proposed development.
II. Specify whether the expected time frame of the potential effects of proposed development can extend
beyond (I).
III. Use the most conservative time frame between (I) and (III).
IV. Using professional judgment to balance between overestimating and underestimating, and make sure to
document the justification or rationale.
V. Exclude future actions if (i) they are outside the geographical boundary, (ii) they do not affect VECs,
or (iii) their inclusion cannot be supported by technical or scientific evidence.
a
After CEQ 1997.
b
As an example, for biodiversity components, see the definition of discrete management unit in Performance Standard 6 and related
guidance in GN6, which emphasizes the importance of defining an ecologically relevant boundary. CIA boundaries should be defined by
the area occupied by the VEC. The spatial context for CIA can be a mosaic rather than a single area.
Through an evaluation of the regional cumulative impact, the scoping stage of CIA should
not only establish the dimensions of the cumulative impact study (VECs of concern,
spatial and temporal assessment scales) but also assess how well cumulative impacts have
already been identified and analyzed.
If the condition and trends of VECs are already known and the incremental contribution of
the development to cumulative impacts can be established quickly, then the emphasis for CIA
should be placed on cumulative impact management rather than impact assessment.
To assess the impacts of a regional oil pipeline development in an arctic environment, the study area for
the ESIA was defined as several kilometers on either side of the pipeline along its route. The CIA for the
project adopted the same study area. While it was well known that the pipeline would likely induce future
development of additional oil fields along the pipeline route, such developments would occur outside the
defined study area and thus were not included as reasonably predictable future projects for inclusion in the
CIA analysis. Few other existing or likely future projects were identified within the study area. Impacts on the
wide-ranging northern caribou herds and grizzly bear, whose ranges included the project study area, were
deemed insignificant in both the ESIA and CIA analyses.
Understanding that CIA analysis should be done in the context of the VECs ranges, the regulator that reviewed
the proponent’s ESIA and CIA required the proponent to redo the CIA analysis to include the potential impacts of
the likely future oil-field development along the pipeline route. These proposed developments fell largely within
the range of the VECs and would have had potential impacts both within the oil fields themselves and along
the routes of connector pipelines that would link to the regional pipeline. This analysis, done in the appropriate
context for analysis of cumulative impacts on the VECs, concluded that the cumulative impacts of the likely future
developments and those of the enabling regional pipeline resulted in a cumulative impact that would require a
regional cumulative impact management strategy. While this would not prevent approval of the regional pipeline,
it clearly created the opportunity for the development of a multiparty cumulative impact management program to
prevent significant impacts from future developments before they arise.
Objectives:
• Identify other past, existing, or planned activities within the analytical boundaries.
• Assess the potential presence of natural and social external influences and stressors (e.g.,
droughts, other extreme climatic events).
Questions to answer:
• Are there any other existing or planned activities affecting the same VEC?
• Are there any natural forces and/or phenomena affecting the same VEC?
The purpose of this step is to identify the totality of stresses that determine the condition of
VECs selected for CIA. Estimation of the magnitude of impacts will likely occur in step 4.
What is important in Step 2 is identification of the sources of stress—past developments whose
impacts persist, existing developments, and foreseeable future developments, as well as any
other relevant external social and/or environmental drivers (e.g., wildfires, droughts, floods,
predator interactions, human migration, and new settlements). Box 9 provides an example. In
making this determination, the key question is simply what environmental and social factors
may influence the condition of the VEC. In most cases, these factors should be known.
The ESIA for a hydropower development that would provide peaking power predicted no significant impacts on
lakes immediately downstream of the development. The ESIA analysis was based on the recent midterm flows
in the river system.
A separate CIA properly took into account the contribution of the natural driving force of longer-term climatic
variation in water availability reflected in the long-term records. Modeling analysis of lake levels in the region,
based on the long-term precipitation patterns showed that there could be a sharp decline in water levels
during extended periods of drought that historically had occasionally lasted for periods of 10 to 20 years. The
project effects at such times would significantly worsen an already difficult situation for some of the affected
communities, as during such extended droughts the shorelines of downstream lakes receded considerable
distances. While only a fraction of the drop in lake level would be attributable to the project impact this
additional impact was considered unacceptable.
The analysis highlighted the need for mitigation measures that could manage the lake levels during such
periods, providing a net benefit to the downstream communities and their fisheries during extended droughts.
Had the CIA not properly taken into account the natural driving impact of climate cycles on the hydrological
regime, the company might have been held accountable at some point for the unacceptable impacts.
An important part of this step is determining an appropriate strategy for identifying stresses
that result from activities other than the proposed development. Detailed identification
of other projects, activities, or actions that are likely to have significant impacts and
can play an important role in the management of cumulative impacts is appropriate.
However, in environments affected by a large number of small developments, creating an
inventory of all sources may not be the best approach; some form of statistically stratified
estimation of all development types involved may be appropriate. It may be helpful to
classify developments according to common characteristics of their impacts. The amount
of detail required is determined by what is needed to credibly estimate the types and
intensity of impacts that influence the condition of the selected VECs.
In addition to other human activities, natural drivers that exert an influence on VEC
condition should be identified and characterized. Natural environmental processes—for
example, drought or flooding—have significant impacts on a variety of environmental
and social components. Project impacts that discharge pollutants to lakes or rivers, or that
withdraw water for industrial or agricultural purposes are likely to be more significant
during periods of drought. The fire regime in forested areas is a major driver that shapes
social, ecological, and economic systems. For the purposes of CIA, identification of such
processes is not a question of new research, but is based on existing knowledge of the
ecology and/or natural dynamics of the selected VECs.
CIA may be relevant and considered appropriate even if a project is expected to have only a small impact,
whenever the project will contribute to the cumulative impact or be at risk from the cumulative effects of
existing projects, or a large number of other reasonably predictable projects.
A regional CIA approach was taken to assess cumulative effects for a region that is the traditional territory of
numerous aboriginal groups and which is characterized by extensive unconsolidated sands with dune complexes,
open grasslands, patches of trees and shrubs with several game species including species that are rare, threatened,
or endangered; and numerous areas of historical spiritual significance. The dominant activities within the region
included a high density of gas wells (approximately 70 percent of the area was leased for exploration) and
widespread livestock grazing. The development of a significant number of additional gas wells was highly likely,
so rather than a well-by-well approach a regional CIA was undertaken.
The CIA was done in three phases: baseline assessment; impacts and trends identification; scenario analysis
and recommendations. Aggregation of impacts by livestock grazing and gas well development was facilitated
by treating both as surface disturbances. The underlying objectives of the baseline assessment (Step 3 in this
handbook) were to identify activities that have the greatest potential for surface disturbance impacts on ecological
integrity and sustainability, and to identify key issues and concerns with biological, economic, and social VECs.
Whenever there is potential for a large number of similar developments a regional analysis should be considered.
This is not, however, the responsibility of an individual proponent. This strategy, if pursued, requires the engagement
of other proponents and government agencies to develop a coordinated and/or pooled analysis.
25
For a good logical framework of how to define other developments, including certain reasonably anticipated,
and/or hypothetical ones, refer to Box 10 of World Bank 2012.
In addition to other projects, actions, or activities that are known to be under development or
identified in planning documents, good practice also considers future developments that are
likely to be induced by the project under consideration. If experience has shown that projects
of the same type as the one being assessed cause further associated development to occur, then
such developments are reasonably predictable. Because induced development is not identified
on the basis of specific development plans, scenario analysis may be an appropriate approach for
examining the potential cumulative impacts that could be associated with such development.
Each scenario must be possible. The objective of scenario analysis is not to predict a most likely
future but to help to assess the consequences of uncertainty, so that the need for cumulative
impact management under different future conditions can be anticipated.
Objectives:
• Define the existing condition of VEC.
• Understand its potential reaction to stress, its resilience, and its recovery time.
• Assess trends.
Questions to answer:
• What is the existing condition of the VEC?
• What are the indicators used to assess such condition?
• What additional data are needed?
• Who may already have this information?
A common concern among developers is the level of effort, time, and resources required
to collect adequate data for appropriately assessing cumulative impacts. The availability
of relevant data is critical for the success of a CIA, and the methodology to be used to
determine VEC baseline conditions should be defined as early as possible.
Generally speaking, data requirements should be determined early on during the scoping
phases of the CIA process. A developer may use existing information when such information
provides a sufficient basis for a complete assessment of cumulative impacts. However, if during
the scoping phases a developer determines that the existing information contains significant
Typically, the new baseline data to be collected for a CIA will not be as detailed as that generated
during an ESIA, because of the larger area covered and/or changes in the type of data required for
the different scale of the assessment. Data that are needed focus on the most important VECs.
Collection of new baseline data tends to be limited and targeted to indicators that would allow
determination of any changes in VEC conditions. Practitioners must have a clear understanding
of the final use of the data, to be able to technically defend the analysis. It is not good practice to
embark on costly collection of new baseline data without careful consideration of the expected
cumulative impact to be assessed for specific and well-defined VECs. For instance, during an
ESIA, intensive and detailed field surveys of soil, vegetation, and fauna may be required in order
to assess direct impacts of a given development on biodiversity and land use. In contrast, because
CIA may require expanding the geographical boundary to thousands of hectares, the analysis
may rely on satellite imagery or existing vegetation or fauna studies on broader scales.
In some cases, the collection of data for some VECs, such as water quality, air quality, and
noise levels, provides a baseline condition that integrates the collective effects of all existing
developments and exogenous pressures. For example, to assess the cumulative ambient air
quality impacts of a proposal to site a fossil-fueled power plant in a given airshed, a developer
may need to collect data on the existing ambient air quality while calculating future impacts
where additional power plant capacity is anticipated to be installed in the same airshed.
Other illustrative examples: (a) the construction of an irrigation project that would alter the
volume and timing of watershed flows into an estuary, which may require the collection of
additional data to assess the cumulative change in flow regime at the estuary and resulting
impacts where other proposals would have similar effects, or (b) an expansion of the
geographical and temporal scales of data collection, in order to assess the cumulative impacts
of a proposed activity on the natural resource base that indigenous peoples, pastoralists,
forest dwellers, or other communities depend upon for their livelihoods.
Baseline (historical) information on the condition of VECs establishes the “big picture”
context for thinking about changes in VEC condition, can help developers avoid the pitfalls
associated with shifting baselines (Pauly 1995), and can be used in a variety of ways.
The determination of the trend of change in the baseline condition of a given VEC over
time may indicate the level of concern for cumulative impacts. If there is a history of a long
or steep decline in VEC condition, it may be inferred that there is an increased likelihood
that a threshold is being approached. As described in further detail in Step 5, threshold levels
Estimating the past condition of a VEC is often a challenging task, requiring the collection
of historical information about the VEC which can be difficult to obtain. Various sources
of information can be explored—reports from governments, NGOs, and MDBs; prior
ESIAs; knowledge from resident communities; biodiversity databases such as GBIF26 or
IBAT;27 information from “controls,” or areas with VECs in common that are exposed to
differing levels of impact (assessed relative to the impact history developed in Step 2), or
scientific literature. Hydro-Québec found that in most cases the best “state of reference”
was the time when information became available and when the condition of the VEC
could be considered more or less stable, which in its first 12 cumulative effects assessments
ranged from 10 to 20 years (Bérubé 2007).
26
See http://www.gbif.org.
27
See https://www.ibatforbusiness.org.
Objectives:
• Identify potential environmental and social impacts and risks.
• Assess expected impacts as the potential change in condition of the VEC (i.e., viability,
sustainability).
• Identify any potential additive, countervailing, masking, and/or synergistic effects.
Questions to answer:
• What are the key potential impacts and risks that could affect the long-term sustainability and/
or viability of the VEC?
• Are there known or predictable cause-effect relationships?
• Can these impacts and risks interact with each other?
Analysis of cumulative impacts on VECs involves estimating the future state of the VECs
that may result from the impacts they experience from various past, present, and predictable
future developments (see Box 11). The objective is to estimate the state of VECs as it
results from the aggregated stresses that affect them. In this context, in addition to the
stresses imposed by developments, the assessment should encompass the potential range
of environmental variation that may influence VEC condition and not be based solely on
expected average conditions (e.g., change in climate patterns and/or predictability).
The analysis for the regional CIA done for the multiple small gas developments referenced in Box 10 developed
three alternative GIS-based land use scenarios: business as usual; enhanced development; and conservation. Rather
than focusing on a fixed prediction about the most likely future impacts, emphasis was placed on developing a set
of plausible accounts of cumulative change under each scenario. This approach allowed decisions to be based not
only on past trends, but also on potential future trends, which may include a number of surprises.
Core biodiversity hot spots with a high priority for conservation were identified. Under the conservation
scenario, regional biodiversity hot spots would be maintained as protected areas. This would be done by
limiting the number of new gas wells in such areas. Production would be maintained, however, through
increased use of directional drilling near the biodiversity hot spots.
In CIA, impacts are measured not in terms of the intensity of the stress added by a
given development but in terms of the VEC response and, ultimately, any significant
changes to its condition. The methods used for analysis are specific to the characteristics
of the VEC (e.g., different methods are appropriate for analysis of impacts on physical,
environmental, biotic, and social VECs, and their resilience). A wide spectrum of methods
• Conceptual modeling, pathways, network analysis29 (Bernard et al. 1993; Brismar 2004;
Canter 2008; Cooper 2008; Perdicoúlis and Piper 2008; Tricker 2007).
• Cost-benefit analysis (Crookes and de Wit 2009).
• Decision support systems (King and Pushchak 2008).
• GIS analysis (Atkinson, Canter, and Mangham 2008; Atkinson and Canter 2011;
Blaser et al. 2004; Dutta, Mahatha, and De 2004; Great Sand Hills Scientific
Advisory Committee 2007; Houle et al. 2010; Johnson et al. 2005; MacDonald 2000;
MacDonald, Coe, and Litschert 2004; Quinn et al. 2004; Scrimgeour, Hvenegaard,
and Tchir 2008; Seitz, Westbrook, and Noble 2011; Squires, Westbrook, and Dubé
2010; Sorensen et al. 2008; Strimbu and Innes 2011; Tiner 2005).
• Habitat modeling (Cantor and Atkinson 2008; Canter and Atkinson 2011; Blaser et al.
2004; Houle et al. 2010; Johnson et al. 2005; Strimbu and Innes 2011).
• Information compilation with simple checklists, or more complex layered or matrix formats
(Canter and Kamath 1995; Canter and Torney 2008; Cooper 2011; MacDonald 2000).
• Indicators and indices of VEC condition (Cantor and Atkinson 2008; Dubé 2003;
Gonzales-Sanson and Aguilar 2010; King and Pushchak 2008; Mitchell and Parkins
2011; Seitz, Westbrook, and Noble 2011; Squires, Westbrook, and Dubé 2010).
• Landscape modeling30 (Great Sand Hills Scientific Advisory Committee 2007;
MacDonald, Coe, and Litschert 2004; Quinn et al. 2004).
• Population viability analysis (Jeffrey and Duinker 2002; Johnson and Boyce 2001).
• Quantitative and/or simulation modeling, including spatially explicit GIS-
based models (CEQ 1997; Dutta, Mahatha, and De 2004; Hegmann et al. 1999;
Krzyzanowksi 2011; MacDonald 2000; Van Damme et al., 2003, 2008; Weclaw and
Hudson 2004; Walters 1986; Yang et al. 2010).
• Scenario analysis (Blaser et al. 2004; CCME 2009; Cavalcanti and la Rovere 2011;
Crookes and de Wit 2009; Duinker and Greig 2007; Ehrlich 2010; Great Sand Hills
Scientific Advisory Committee 2007; Greig et al. 2004; Harriman and Noble 2008;
Hegmann and Yarranton 2011; Jeffrey and Duinker 2002; Johnson et al. 2011; Lindsay,
Svrcek, and Smith 2002; Mitchell and Parkins 2011; Noble 2008; Quinn et al. 2004;
Seitz, Westbrook, and Noble 2011; Strimbu and Innes 2011; Weclaw and Hudson 2004)
• Sustainability appraisal (Cooper 2010; Gibson 2011).
28
For a good overview, see Box 18 and Table 4.1 of “Sample Guidelines: Cumulative Environmental Impact
Assessment for Hydropower Projects in Turkey.” World Bank, 2012. https://www.esmap.org/node/2964.
29
See http://www.wcslivinglandscapes.org/WhatWeDo/ConservationStrategy.aspx and https://miradi.org.
30
See http://www.wcslivinglandscapes.org/WhatWeDo/LandscapeSpeciesAnalysis.aspx.
The American eel is a species that spawns in the Sargasso Sea and migrates to freshwater rivers and lakes
to grow and mature. When mature it migrates downstream and returns to the Sargasso Sea. In a northern
segment of its range this large, long-lived species declined substantially following construction of hydropower
dams and is now listed as endangered.
Human activities that affect the species include harvesting by fisheries, hydropower developments (inhibition
of upstream migration, mortality during downstream migration), barriers to migration by other water control
dams, habitat alteration, changes in water quality and contaminants. Natural drivers that impact the species
include: changes in the food web, parasites, and potential changes in ocean currents associated with climate
change. A published study indicated that of the various impacts, fisheries and hydropower development likely
had the greatest impact. As a consequence fisheries in the region were closed.
To develop a rapid estimate of the impact of the mortality caused by hydro developments during downstream
migration a RCIA was developed in the form of a quantitative spreadsheet model for one watershed
in the region where 11 hydropower developments were located on the main stem of the river, other
developments were located on tributary rivers. Without a detailed inventory of the distribution of eel habitat
in the watershed or specific studies of eel mortality at the individual stations, the model was designed to
permit scenario analysis to explore scenarios of habitat distribution (simply the proportion of habitat in the
watershed located in areas between the different developments) and estimates of the mortality rate for eels
passing through stations of similar size and design drawn from the scientific literature. The model simply
estimated the survival rate for the population of mature eels that would migrate downstream for spawning
as a result of the cumulative mortality from the 11 main stem developments. Although a better estimate of
impact could be obtained with a detailed habitat survey in the watershed, analysis of all developments, not
just those on the main stem, revealed that under reasonable assumptions of habitat distribution, the survival
rate would be less than 10 percent, an unsustainable impact.
As discussed previously, CIA analysis is futures oriented. The impact of the project is not assessed
as the difference between the expected future condition of VECs and that of a past baseline
condition. It is assessed as the difference between the estimated future condition of VECs in the
context of the stresses imposed by all other sources (projects and natural environmental drivers)
and the estimated VEC condition in the context of the future baseline plus the development
under evaluation.31 Of concern is not just estimation of the development’s impact, but
estimation of the future condition of VECs in the context of all stresses—which is the
cumulative impact—and can be evaluated in reference to an established threshold level of
acceptable condition, if known, or in reference to a past baseline.
The estimate of the cumulative project impact, together with ESIA results, indicates
the need for project-specific mitigation. By contrast, the estimated overall cumulative
impact indicates the need for mitigation to be implemented by the various project
owners or proponent parties to ensure that their respective contributions to the overall
condition of the VECs is coherent and/or compatible with what is mandated or required
by government-led—or government-agreed—regional cumulative impact management
initiatives, or as a minimum compliant with ambient quality standards for the desired use.
A key part of the assessment step is estimation of the effectiveness of project mitigation
and other cumulative impact management measures to reduce impacts, and this is done
iteratively between Steps 4, 5, and 6.
31
In CIA it is critical to not confuse past and future baselines (Bérubé 2007).
Objectives:
• Define appropriate “thresholds” and indicators.
• Determine impact and risk magnitude and significance in the context of past, present, and
future actions.
• Identify trade-offs.
Questions to answer:
• Do these impacts affect the sustainability and/or viability of the resource and/or VEC?
• What are the consequences and/or trade-offs of taking the action versus no action?
Significance determination is a normal component of ESIA and CIA and occurs near the
end of the assessment process. Significance is typically evaluated after project mitigation
measures are factored in.
In the ESIA process, components of impact significance (magnitude, spatial scale, duration,
frequency) are typically factors in deciding whether mitigation is necessary. Consequently,
the evaluation of significance and the design of management and/or mitigation are in reality
iterative. The significance of a cumulative impact is evaluated not in terms of the amount
of change, but in terms of the potential resulting impact to the vulnerability and/or risk
to the sustainability of the VECs assessed. This means evaluating cumulative impacts in
the context of ecological thresholds.33 Determining ecological thresholds for biological and
social VECs has proven to be difficult. In many cases, such thresholds may not be clearly
identified until they are actually crossed, at which point recovery may take a long time with
considerable cost or may simply not be possible. Consequently, a precautionary approach
that explicitly considers uncertainty in ecological and sociological relationships is essential
when thresholds of acceptable VEC condition are being established.34
32
Significance determination has been a challenge in ESIA and a rich literature has developed (Lawrence Environmental
2002). Little if any guidance for significance determination exists specifically for CIA, however a review of ESIA
significance determination in the context of sustainability was prepared for the Canadian Joint Review panel for the
Mackenzie Gas Project (Lawrence 2005). This work has since been expanded upon and presented in the primary
literature (see Lawrence 2007a, 2007b, 2007c). Experience with significance determination in 12 CIAs prepared by
Hydro-Québec (Bérubé 2007) was that application of significance determination methods normally used in ESIA
was very difficult. In the context of regional trends in VEC condition driven by multiple developments, the standard
matrix used in ESIA was found to be useless, and level of significance was not always determined in CIA.
33
Some Performance Standards and Guidance Notes offer a useful basis for such thresholds, for instance,
biodiversity-related critical habitat thresholds (see GN6).
34
Databases of ecological thresholds can be found at http://www.resalliance.org.
In reality, however, since such thresholds are not widely defined or available, the CIA is
often hindered. As described in the World Bank’s “Sample Guidelines for Cumulative
Environmental Assessment for Hydropower Projects in Turkey” (World Bank 2012) and
in Hegmann et al. (1999), there is not always an objective technique for determining
thresholds and professional judgment must usually be relied upon. Good practice implies
making attempts to estimate thresholds for VECs studied, and applying the mitigation
hierarchy to manage those impacts that may result in exceeding predicted thresholds.
Objectives:
• Use the mitigation hierarchy.
• Design management strategies to address significant cumulative impacts on selected VECs.
• Engage other parties needed for effective collaboration or coordination.
• Propose mitigation and monitoring programs.
• Manage uncertainties with informed adaptive management.
Questions to answer:
• How can cumulative impacts be avoided, minimized, and/or mitigated?
• How can the effectiveness of proposed management measures be assessed?
• What are the triggers for specific adaptive management decisions?
The management measures needed to prevent cumulative impacts will depend on both the
context in which the development impacts occur (i.e., the impacts from other projects and
natural drivers that affect the VECs) and the characteristics of the development’s impacts.
Since cumulative impacts typically result from the actions of multiple stakeholders, the
responsibility for their management is collective, requiring individual actions to eliminate
or minimize individual development’s contributions. At times, cumulative impacts could
transcend a regional threshold and therefore collaboration in regional strategies may be
necessary to prevent or effectively manage such impacts. Where cumulative impacts already
exist, as in the examples described in Box 13, management actions by other projects may be
needed to prevent unacceptable cumulative impacts.
Significant cumulative effects on a predatory wildlife species resulting from existing forest harvesting, mines,
oil and gas operations, and recreational activities (managed by the government) were revealed when the
CIA for a new mine proposal was completed. The proposed management response was the creation of a
“carnivore compensation program” to be jointly supported by the new mine, the dominant forestry company
in the area, some oil and gas interests, and the government.
In another case, concern for the cumulative effects of the biochemical oxygen demand from the discharge
of a proposed pulp mill together with the discharges of existing mills resulted in a requirement for a joint
monitoring program implemented by the operators of the existing mills together with the operators of the new
mill. In addition, should dissolved oxygen drop below a specified limit, immediate corrective action is required
to be taken jointly by the parties (Therivel and Ross 2007).
The analysis phase of the project CIA may indicate the need and/or potential for additional
mitigation measures beyond those identified in the project ESIA. The design of such additional
mitigation measures for the development, if needed, is an early part of the work in this step of
managing cumulative impacts. Iteration of the analysis (Step 4), significance evaluation (Step
5), and management (mitigation) design (this step) may be needed.
If specific project mitigation that will prevent unacceptable cumulative impacts can be
identified and implemented, then the developer may not need to initiate collaborative
engagement of others in impact management. When prevention of unacceptable
cumulative impacts by project mitigation alone is not possible, collaborative engagement
in regional management strategies will be necessary. In all cases, collaborative engagement
in regional efforts to manage cumulative impacts (e.g., design of project monitoring
to fit with regional monitoring programs where they exist) may help to reduce the
risk of additional unanticipated management commitments at a later time, as regional
development proceeds. Specific actions that may be needed to effectively manage
cumulative impacts include the following:
The first two points are clearly the responsibility of the project, the third point is the
responsibility of other project proponents to address their contribution to cumulative
35
Adaptive management strategies are not a panacea. A common misunderstanding that has emerged in some
ESIA practice is that adaptive management is primarily a post-hoc response to developing management
responses after problems emerge. In fact, it is a well-developed and rigorous discipline for experimental
management used for reducing uncertainty about how to manage effectively. Consequently, adaptive
management is not appropriate if impacts may not be reversible. In addition, it is best employed to assess
management strategies to which VECs are responsive over a relatively short term.
36
Hydro-Québec found this to be particularly important in CIA practice (Bérubé 2007).
Together with international and local lenders and other MDBs, IFC is financing the development of two cascading
hydropower projects on the Chiriqui Viejo River in Chiriqui Province in western Panama. These projects are
situated in the upper reaches of the watershed above approximately a dozen other cascading projects being
constructed or planned for development by other private sector sponsors. An RCIA was conducted with the
support of the lenders group. Results from the RCIA indicated that in addition to the barrier effect caused by
the dams, dikes, and levees, the reduced downstream flows between the different projects could significantly
impair aquatic habitat connectivity in the dewatered segments and jeopardize the ultimate viability of the
mountain mullet, a catadromous fish currently present in the river.
Because these two projects are the highest in the watershed, the natural movement of spawning fish
downstream and juveniles upstream would first be impacted by several projects under construction in the
lower reaches of the river. Lack of mitigation of this barrier effect by projects downstream from the IFC-
financed projects would likely compromise the viability of juvenile and adult fish populations in the higher
sections of the river.
To address this situation, these two projects have taken a two-tiered approach:
First, they have developed a comprehensive downstream ecological flow management plan that will ensure
that these two projects release enough water in the dewatered segments downstream, to maintain not only
aquatic habitat connectivity, but also enough usable habitat for key indicator fish and invertebrate species.
They are working with the group of lenders, other project sponsors, and the responsible government agencies
in Panama to tackle not only connectivity but also other cumulative issues (e.g., sediment load) at a watershed
level. These solutions are still being negotiated but include fish hatcheries, as well as catch-and-release of
juvenile and adult fish to repopulate the stream in the dewatered segments upstream from the different dams.
Implementing a CIA
Challenges to
Challenges to
Implementing a CIA
3. What are the Challenges to Implementation of
CIA? How can These Challenges Be Overcome?
This final section recognizes that the application of this six-step process entails many
challenges, as does the implementation of an effective strategy to manage cumulative
impacts and risk for multiple projects, actions, and activities. This section provides some
key recommendations to consider when trying to overcome such challenges.
CIA requires interactions with numerous organizations and individuals from government,
third parties, affected communities, and other stakeholders. Numerous groups have an
interest in CIA because of its wider geographic scope and focus on impacts from multiple
developments. But what should their role be in a project-level CIA? The type of interactions
that project proponents should have with interested parties will vary, depending on the
development and its location. In locations where third parties are organized (e.g., farmer
or industry association) and concerned about environmental impacts, third parties may
become very involved in some parts of the assessment (e.g., scoping, provision of data,
development of mitigation) or in ongoing management actions. Also, in locations where
What are the Challenges to Implementation of CIA? How can These Challenges Be Overcome? | 51
governments have established regional planning processes and means of managing natural
resources regionally, they too may become actively involved in parts of the assessment
(scoping, provision of data, determination of significance of impacts) or in implementation
of management actions (e.g., regional monitoring program).
Deciding why, when, and how to interact with government(s), third parties, and affected
communities is not straightforward; it requires considerable thought and expertise.37 To
determine the appropriate type and scope of interactions requires an understanding of
constraints on both governance and participants’ capacity.
A wide range of roles and responsibilities are possible. The principles and purpose for
involving different parties in CIA or RCIA should not change, no matter what the
circumstances of government, third parties, or affected communities are. The principles
are meaningful engagement of affected communities, involvement and collaboration
with governments, and interaction with third parties. At a minimum, interactions with
government, third parties, and affected communities should accomplish the purposes
that relate to a client’s project-specific CIA or RCIA. The ideal roles and responsibilities
of different parties and the purpose of these roles/responsibilities are listed in Table 3. See
also Box 15.
As illustrated in Table 2, significant gaps typically exist between the actual governance context
for a development and the ideal roles and responsibilities shown in Table 3. Gaps in roles
and responsibilities need to be explicitly identified and handled by different management
strategies in a CIA or RCIA.
For guidance, please refer to these IFC documents on good practice and guidance on stakeholder engagement,
37
Various groups have been working in different contexts to establish collaboration between developments for
regional CIA. For example, collaborative initiatives have been developed in Australia with regard to impacts of
the coal mining industry, including strategic and regional planning led primarily by government; information
exchange—networking and forums; pooling of resources to support CIA initiatives and programs; and
multistakeholder and regional monitoring (Franks, Brereton, and Moran 2010; Franks et al. 2010). These
approaches vary in complexity, with each demanding a different degree of maturity in the collaborative
relationship. Given the expected challenges of conducting CIA in emerging market contexts, collaboration
among project proponents offers the prospect of attaining efficiencies through information sharing and joint
management approaches that should improve CIA quality, thereby reducing risks associated with unmanaged
cumulative impacts while being more cost-effective. Such collaborative efforts represent one thrust in the early
development of enabling frameworks for CIA.
Gaps can be identified by comparing the ideal given in Table 3 with the actual situation
for a proposed development. In general, there are two approaches for managing
gaps in roles and responsibilities. First, clarify and gain acceptance for all roles and
responsibilities: clearly define the roles and responsibilities of the client as opposed to
those of government, third parties, affected communities, and the public, and ensure the
parties understand their roles. Second, as part of the CIA or RCIA engagement process,
make sure to communicate the established roles and responsibilities widely—inform
stakeholders, NGOs, and other potentially interested groups from within and outside the
project’s DAI and region.
What are the Challenges to Implementation of CIA? How can These Challenges Be Overcome? | 53
TABLE 3 . ROLES AND RESPONSIBILITIES OF PARTICIPANTS IN CIA UNDER IDEAL GOVERNANCE CONDITIONS
ROLES AND RESPONSIBILITIES BY PARTY SCALE PURPOSE
Government National, • Defines values and acceptable limits for resource development.
• Establish policy and legal framework for resource subnational, • Defines locations for acceptable types and limits of developments.
management and cumulative impact management. regional, • Identifies contribution of each development to cumulative
• Establish and lead regional planning structures and and/or local. impacts in region, gives public and proponent assurance that
collaborative mechanisms for managing and mitigating (e.g., proposed developments are within acceptable limits set by legal
aggregated offset strategies) resource developments and framework and regional plans and processes.
cumulative impacts. • Gives information on state of VECs in region and assurance that
• Implement permitting process that considers cumulative cumulative impact values and development objectives are being
impacts of all developments and pressures, and conforms met; provides database for project-level CIA, and makes sure this
to values and limits, given regional plans and national information is freely and publicly available.
frameworks.
• Design and conduct CIA study of geographic area which
includes the baseline (historical) conditions and predicts the
future baseline, based on the carrying capacity of the VECs
• Issues approvals to individual private sector projects to be
developed on the basis of this information.
• Lead development and implementation of regional cumulative
impact monitoring program that analyzes development
pressures and impacts at regional scale and compares results
to values and/or acceptable limits for resource development.
Private Sector Project Proponent Regional, • Gives financial institutions and decision makers information about
• Design and conduct CIA (or RCIA) study of the incremental local, and/or cumulative impact for evaluating the project.
impacts of the project building on the CIA study conducted site. • Conforms to CIA commitments and/or permit conditions;
by the government. manages development to prevent it from causing VECs to reach
• Monitor and manage cumulative impacts and risks related to limits.
the development for its life span. • Gives the government project-related cumulative impact data
Third Parties (existing and future developments and/or Regional, • Provides project proponents and other developers, decision
resource users) local, and/or makers, and regional monitoring program with details about
• Similar to proponent, but covering existing or future site. impacts of existing developments.
developments • Provides proponent and other developers, government, and other
• Assess and manage cumulative impacts of existing stakeholders with details about proposed developments (i.e.,
developments. project description, impact analysis, ESIA/CIA).
• Assess and manage cumulative impacts of any future • Provides project-level data needed for regional cumulative impact
developments; prepare ESIA and CIA for permit decision monitoring program.
makers if needed. • Enables effective regional management of cumulative impacts;
• Collect and provide data for regional cumulative impact supports collaborative, multistakeholder process.
monitoring program.
• Participate in regional planning structures and collaborative.
mechanisms for managing CIA at regional or larger scales.
Affected Communities and Public Regional, • Ensures regional resource development limits and conditions
• Public participates in value setting for policy and/or legal local, and/or reflect public values.
frameworks and regional resource management plans. site. • Allows values of affected people to be reflected in scoping and
• Affected communities participate in CIA of individual projects. valuation of project-level CIAs.
• Public participates in collaborative management of cumulative • Fosters public ownership of cumulative impact management
impacts. objectives and results.
What are the Challenges to Implementation of CIA? How can These Challenges Be Overcome? | 55
3.2 Recommendation 2: Establish and Maintain a Constructive
Relationship with Government and Other Stakeholders
Government Assessment – scoping, baseline Government leading collaborative Provide project proponent with
data collection, review of CIA program of planning, government standards, data,
impact findings permitting, monitoring, and views, expertise, concerns,
managing cumulative impacts and validation for assessment;
Management – collection and facilitate government role in
review of cumulative impact collaborative monitoring and
monitoring data management
Third Parties Assessment – informed about Provide information about existing Provide proponent with third-
CIA study and results and proposed projects; participate party information needed
in collaborative mitigation, for CIA; promote third-party
Management – informed about monitoring, and management participation in collaborative
cumulative impact monitoring monitoring and management
and management program and
relevant results
Affected Assessment – scoping As many steps in the CIA process Include values and concerns of
Communities as possible—e.g., data collection, affected people in CIA; gain
and the Assessment of Significance formulation of mitigation, public support and insights
Public ongoing monitoring during project planning and
Management – collection and operations
review of cumulative impact
monitoring data
Conclusions
Conclusions
While the expanded geographical and temporal scope of CIA (relative to ESIA) is often
a challenge, the most significant challenge to performing and implementing a good CIA
process lies in its multistakeholder nature. To facilitate the assessment and management
of cumulative impacts, practitioners have called for, and in some developed countries
governments are now beginning to develop, regional enabling frameworks for CIA. Such
frameworks would support CIA by:
However, these frameworks are generally not well advanced or widely available yet.
The creation of a regional enabling framework for CIA is beyond the capacity of
individual proponents. However, good practice for cumulative impact assessment and
management includes supporting the development of such frameworks. This may take
several forms: working to engage other parties in the CIA or RCIA process; sharing
the results of the project CIA or RCIA including recommendations for project-specific
and regional management actions needed by others to effectively manage cumulative
impacts; and supporting the implementation of collaborative approaches to cumulative
impact management through information exchange networking, pooling resources for
implementation of shared management initiatives, and participation in multistakeholder
and/or regional monitoring.38
38
Even when a project-specific CIA is not required, good environmental management practice supports
regional efforts to assess and manage cumulative impacts. This would include making project ESIA reports
and project impact monitoring results available to others who are working to manage cumulative impacts
within the regional context.
Conclusions | 57
Furthermore, because the basic logic framework for ESIA and CIA is essentially the
same39 and they share many common standard tools and analytical methods, the key
strategy needed in addressing the expanded scope of CIA is to ensure four conditions:
It is critical to the success of CIA or RCIA, as applicable, that the individual project mitigation
and, where needed, regional cumulative impact management strategies be implemented
as designed. At the same time, estimates of cumulative impacts are often uncertain. The
management approach to implementation thus needs to be adaptive, monitoring both the
impacts and the effectiveness of management approaches, and adjusting the management
to ensure avoidance of unacceptable cumulative impacts. As with management of impacts
identified in ESIA, this works best when management of cumulative impacts is integrated
into company business plans and strategies.
39
See Appendix 2, Basic Logic Framework for CIA.
Appendixes
Appendices
Appendix 1. Examples of Indicators for Assessing Incremental
Project Impacts and Cumulative Impacts
The following table provides examples of endpoints or indicators typically used on standard ESIAs vis-á-vis those that would
be recommended or used in a CIA. The second column represents indicators of incremental change while the third column
refers to those that would reflect cumulative impacts over selected VECs. The last column makes reference to the applicable IFC
Performance Standard for the impact type.
Appendix 1 | 59
PROJECT ASPECT INDICATOR OF INCREMENTAL INDICATOR OF CUMULATIVE PERFORMANCE
IMPACT (ESIA) IMPACT (CIA) STANDARD
Conversion or • Area and/or proportion of natural • Total area of lost habitat 6
degradation of and critical habitat converted and/ • Change in rates of habitat loss
natural and critical or degraded because of the project • Measures of habitat
habitat • Incremental change in habitat fragmentation
quality and/or condition
Regulation of • Percent reduction of downstream • River ecological integrity, 1,6
downstream flows flows as compared to average annual including natural flow regimes
flows (e.g., quantity, quality, seasonal
Reduction, • Percent reduction of wetted- variability, and predictability)
modification, and/ perimeter or of usable habitat in • Viability of migratory fish
or fragmentation of the impacted river reaches populations
riparian and aquatic • Connectivity from the river reaches
habitats upstream and downstream of the
dam or weir
Addition of mortality • Direct mortality caused by project • Change in rates of regional 6
to a wildlife operations over time and/or global population
population • Percentage of local population decline
(or range) lost with relation to • Measures of population (or
global and/or regional population range) fragmentation
numbers (or range)
CIA shares the same basic analytical process of an ESIA, and thus it involves the
following steps:
The experience of CIA practitioners reveals that good practice in CIA has the following
characteristics.40
Process Management:
40
Burris and Canter 1997; McCold and Holman 1995; Baxter, Ross, and Spaling 2001; Cooper and Sheate
2002; Antoniuk 2002; Kennett 2002; Duinker and Greig 2006, 2007; Bérubé 2007; Therivel and Ross
2007; Canter and Ross 2010; Franks, Brereton, and Moran 2010; Franks et al. 2010; Cooper 2011; Gunn
and Noble 2011; IFC Performance Standard 1.
Appendix 2 | 61
Consultation and Collaboration:
Scoping:
• Even though initially all relevant VECs must be evaluated for the CIA to be robust,
only some VECs are selected for analysis based on their importance, existing concerns,
and/or likelihood of significant cumulative impacts.
• Scoping establishes the environmental context for CIA, including the following:
−− Definition of clear temporal and spatial boundaries and documentation of the
rationale.
−− Identification of other developments that affect the chosen VECs, including other
types of development that have different but important effects on the selected
VECs.
−− Identification of natural drivers that affect the condition of VECs.
−− Identification of variation in natural environmental processes that will affect the
cumulative impacts.
−− Consideration of jurisdictional issues and overlapping legislation.
Analysis:
Impact Management:
• Effects monitoring needed to assess the realized cumulative impacts is clearly defined
and implemented. Monitoring recommendations may extend beyond what will be
done by the proponent to identify coordinated monitoring by other developers and
stakeholders.
• In addition to mitigation of the proposed project’s impacts, multiparty regional
mitigation and/or management (e.g., additional mitigation of other developments,
offsets, management programs) that may be needed to effectively manage cumulative
impacts is also identified and support from other stakeholders (governments,
developers and communities) is sought to implement it (e.g., by an existing authority
Appendix 3 | 63
such as a watershed coordinating agency, if it exists; or if no such agency exists, by a
collaborative initiative established by the various proponents—see Franks, Brereton,
and Moran 2010; Franks et al. 2010).
• The project’s monitoring of cumulative impacts is used to update its management
system and drive future management of impacts.
• Ideally, the government updates the CIA report to incorporate the results of the
project monitoring program to inform future decision making.
1. Introduction
These terms of reference (ToR) describe the requirements for rapid cumulative impact
assessment and management for < the project >
Even though Performance Standard 1 does not expressly require, or put the sole onus on,
private sector clients to complete a CIA, it states that the impact and risk identification
process “will take into account the findings and conclusions of related and applicable
plans, studies, or assessments prepared by relevant government authorities or other parties
that are directly related to the project and its area of influence” including “master economic
development plans, country or regional plans, feasibility studies, alternatives analyses, and
cumulative, regional, sectoral, or strategic environmental assessments where relevant.”
Furthermore, it goes on to state, “the client can take these into account by focusing on the
project’s incremental contribution to selected impacts generally recognized as important
on the basis of scientific concern or concerns from the Affected Communities within the
area addressed by these larger scope regional studies or cumulative assessments.”
41
Orange text on italics indicate where users may insert text according to project needs.
Appendix 3 | 65
Similarly, Performance Standard 1 GN1 states that “in situations where multiple projects
occur in, or are planned for, the same geographic area... it may also be appropriate for
the client to conduct a CIA as part of the risks and impacts identification process.”
However, it clearly recommends that this assessment should (a) “be commensurate with
the incremental contribution, source, extent, and severity of the cumulative impacts
anticipated,” and (b) “determine if the project is incrementally responsible for adversely
affecting an ecosystem component or specific characteristic beyond an acceptable
predetermined threshold (carrying capacity) by the relevant government entity, in
consultation with other relevant stakeholders.”
Therefore, although the total cumulative impacts due to multiple projects should be
typically identified in government-sponsored assessments and regional planning efforts,
to comply with Performance Standard 1, IFC clients are expected to ensure that their own
assessment determines the degree to which the project under review is contributing to the
cumulative effects.
3. Objective
• To determine if the combined impacts of: the project, other projects and activities,
and natural environmental drivers will result in VEC condition that may put the
sustainability of a VEC at risk (i.e., exceed a threshold for VEC condition which is an
unacceptable outcome); and
• To determine what management measures could be implemented to prevent
unacceptable VEC condition, this may include additional mitigation of the project
being assessed, additional mitigation of other existing or predictable future projects,
or other regional management strategies that could maintain VEC condition within
acceptable limits.
<In the following sections add additional text as needed to provide specific characteristic
of the RCIA ToR that are known at the time the ToR are issued. For example, where it is
already known that there are regional concerns for the conditions of one or more VECs, these
concerns should be identified.>
The following ToR sections provide a brief outline of the work to be undertaken in
conducting the RCIA for <the project>. Refer to the CIA GPH for additional guidance
regarding conduct of the following steps.
Tasks:
• Identify the VECs to include in the RCIA.
• Identify the spatial boundaries of the RCIA.
• Identify the temporal extent of the RCIA.
Note:
• VECs to include are those that would be affected by the project. Thus VECs for which
an impact was deemed insignificant in the ESIA are not to be included in the CIA.
• If the number of VECs is too large to conduct an analysis of all, then priority for
analysis should be given to those for which there is existing regional concern, as
reflected in the regional baseline information (see section 4.3).
Appendix 3 | 67
4.2 Scoping Phase II – Other Activities and Environmental Drivers
Tasks:
• Identify other existing and reasonably predictable projects and human activities that
do/would affect the VECs to be included in the RCIA.
• Identify natural environmental drivers that also impact the condition VECs identified
in section 4.1.
Note:
• Developments that could be reasonable expected to be induced by the projects are
considered to be reasonably predictable.
• Where there is a significant potential for further development, but not specific
development proposals in place, a scenario of potential development may be
considered.
Tasks:
• Collect available information on the impacts of the other activities and natural drivers
on the condition of the VECs.
• Collect available information on trends in VEC condition.
• Collect available information on regional thresholds for VEC condition.
Note:
• If regional thresholds for VEC condition have not been established, they may have
to be estimated based on estimates from other regions. When feasible, the estimation
should be peer reviewed.
Tasks:
• Establish indicators for expression of VEC condition. This may already be reflected
in the information collected on VEC baseline status (in Section 4.3). If not, then
indicators will need to be established that can be estimated from the baseline
information.
• Estimate the “future baseline” for condition of the VECs—i.e., the condition of VECs
as affected by the other projects, human activities, and natural drivers.
• Estimate the project impact on VEC condition. This estimation is done with the
effects of planned project mitigation included.
Note:
• A wide variety of methods have been used for CIA analysis, methods chosen for the
analysis should be chosen to be compatible with the information available for the
analysis and that can provide, whenever possible, a quantitative estimate of cumulative
impact.
• If qualitative estimates of cumulative impact are to be developed, they should be based on
the consensus estimate of a panel of experts rather than on the opinion of an individual
expert.
Task:
• Assess the significance of the foreseen cumulative impacts on the VEC.
Note:
• When the cumulative impact on VEC condition will approach, be near to, or exceed
a threshold, the impact is significant.
• The analysis may reveal that significant cumulative impacts will exist without the
project.
Tasks:
• Identify, when necessary, additional project mitigation (beyond that identified in the
project ESIA) to reduce an estimated unacceptable cumulative impact on a VEC to
an acceptable level (iteration with the tasks described in Sections 4.4 and 4.5 will be
necessary to assess the value of such additional mitigation). This should represent
effective application of the mitigation hierarchy42 in environmental and social
management of the specific project contributions to the expected cumulative impacts.
Defined in Performance Standard 1 as the strategy to first anticipate and avoid impacts on and risks to workers,
42
the environment, and/or affected communities, or minimize impacts and risks where avoidance is not possible.
Acceptable options for minimizing will vary; they include abating, rectifying, repairing, and/or restoring.
Residual impacts must be compensated for and/or offset. It is important to emphasize that offset is the last
resource option that should be used to compensate for residual impacts of a given action or project; it should
not be used to manage cumulative impacts on a selected VEC. However, regional offset of cumulative impacts
could still be possible as part of a collaborative CIA mitigation process led by the government or a coalition of
developers.
Appendix 3 | 69
• If necessary, identify the potential, or need for, additional mitigation of other existing
or reasonably predictable future projects.
• Identify the potential for other regional strategies that could maintain VECs at
acceptable conditions.
• Undertake best efforts to engage, enhance, and contribute to a multistakeholder
collaborative approach for the implementation of management actions that are
beyond the capacity of the project proponent.
Stakeholder engagement43 is critical to the success of RCIA. Engagement should start early
in the process, i.e., in Scoping (Sections 4.1, 4.2) and continue throughout the RCIA
process. It will be essential to collect the information needed for the RCIA analysis and
likely also to secure cooperation in implementation of mitigation of the impacts of other
projects, and or identification and design of regional cumulative impact management
strategies that may be needed to avoid unacceptable cumulative impacts.
The second point is essential when additional mitigation is needed for other projects.
Engaging in assigning blame for cumulative impacts is likely to be counterproductive.
Cumulative impacts are, by their multiparty nature, a collective responsibility and in this
regard maintaining a constructive relationship will be essential.
For further guidance, please refer to IFC published documents on good practice and guidance on stakeholder
43
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August 2013