Principle 10: Rule of law in environmental enforcement

Re-Evaluating and Continuous Assessment of Biodiversity Issues and the EIA: The Case of Vietnam

Date posted: 
Nov 20 2009

The Environment Impact Assessment is ideally an integral component of a project's planning process. It identifies potential risks given the present scenario and the perceived impact of the project's activities. Given this, the EIA gives recommendations given the set of information available during the time of the assessment. However, once the project takes place, a review of the EIA is seldom made. There is a need to revisit the EIA especially if perceived environment conditions change.

Responsible Party: 
Enforcement Agency
I. Objectives or Impact: 

There is a tendency for the Environment Impact Assessment (EIA) process to focus primarily on technical aspects (e.g. pollution created, emission). However, the process sometimes misses on actual environment concerns will surely be affected by the project, like relocation or biodiversity. Worse, concerns on economic development often takes the prime seat while issues related with conservation and biodiversity are placed aside. The problem is that environmental damages might prove to be irreversible. Also, biodiversity issues that seem to be trivial at initial glance might become big risks as an economic activity or project progresses. The case of cement manufacturing in Ha Tien Plane in Vietnam, a critical ecosystem, displayed the need to continually assess impacts of economic activities on biodiversity. A change in the treatment of the EIA, from being a mere procedural step in project implementation to a guide that advises and gives warning to potential impacts, is highlighted.

II. Description of the Good Practice (Outputs): 

A Swiss-based cement company, Holcim, approached the International Finance Corporation (IFC) about a proposed greenfield cement plant in Hon Chong in 1993. Around that time, Vietnam was experiencing economic growth, and was opening its country to foreign investment. Specifically in the cement industry, the supply of cement from two initial operators was already being overtaken by demand. The proposed site of Holcim was highly scenic, which actually supports tourism activities. However, the view then was that the area appeared to be unproductive. In fact, the site did not appear to meet the IFC’s natural habitat standard. Interestingly, the initial EIA undertaken for the proposed cement factory noted that there is little wildlife in the area and lack of birdlife. The EIA also focused on technical issues (e.g. emission), with modest attention to biodiversity. Issues on biodiversity were raised but it was concluded that the need for cement was of prime importance relative to conservation. With the operation of the cement plant, it was realized that construction and related costs were higher than expected. Also, the production volumes were lower compared with the projected volumes. At the same time, the Asian Crisis halted the growth of the cement industry. Around that time as well, stakeholders slowly learned and realized the biological value of the affected area. Simultaneous with the cement plant’s operation, the IFC revisited the adequacy of the earlier EIA. It was learned that the landscape of the area is one of the world’s most threatened karst landscape. The biodiversity value of the area also changed due to what was happening in the other parts of the region. Grassland habitats were lost throughout the region due to the expansion of shrimp farming and rice cultivation. As grasslands slowly disappear in other areas, the endangered Eastern Sarus Crane (the world’s tallest flying bird), congregated in larger numbers in other areas, specifically the Holcim Vietnam site.

III. Outcomes or Results: 

Given the “change” in the biodiversity value of the site, Holcim and the government were placed in a predicament. The government’s priority was still economic development. At the same time, Holcim holds mineral rights on the limestone of the site. In 1999, the IFC commissioned a biodiversity assessment of the site, and the entire Hon Chong region. The assessment recognized the need for an integrated conservation initiative, encompassing the adjoining limestone, wetland, and sandstone. Though Holcim recognized that the concern is region-wide and not limited to its site, it realized that its corporate image could be affected. The biodiversity issues that emerged prompted Holcim Vietnam and the IFC to form a partnership with the International Crane Organization. Their primary aim was to demonstrate that maintaining the natural habitat could be more economically valuable than pursuing competing activities like shrimp and rice cultivation. An area (Phu My) was finally identified as an area for conservation management. It showed to be economically viable for the area. Other small-scale industries from conservation management also emerged like handicrats-making. The development of the area won the financial support from the World Bank Development Marketplace. Local government support is also strong for the conservation management efforts in the area. The linkage between IFC and the Industrial Bank started in 2004, with the IFC’s initial investment of US$ 52 million on the bank. The first-phase of the risk-sharing arrangement in 2006 made possible the creation of a facility that has been used to leverage a portfolio of US$ 65.7 million of energy efficiency equipment and project loans for small and medium-scale projects. Projects typically pursued were industrial boiler retrofitting, wasted heat recovery, co- and tri-generation projects for district heating, power saving, and optimization of industrial energy use. The initial efforts of the IFC and Industrial Bank attracted two prominent international co-investors, namely the Hang Seng Bank of Hong Kong and Singapore’s GIC Special Investments. In March 2008, participating banks in the CHUEE program approved 70 energy efficiency loans, with a loan portfolio of US$ 243 million. Interestingly, projects financed by the loans contribute to a net annual reduction of greenhouse gases of 4.3 million tons.

A. Policy Framework: 

There is a strong need to review how the EIA is conducted, particularly on the issue of securing commitment to the measures prescribed by the EIA. Also, regulatory and implementation polices that make the review of EIAs possible should be in place, with the fact that economic activities can surely have unforeseen impacts.

B. Budgetary and Financial Requirements: 

The concerned government agency needs to set up a fund that will finance regular review of selected EIAs, particularly large-scale and huge-impact projects.

C. Human Resources: 

There is a need to have a strong monitoring staff that traces whether the stakeholders comply with the measures identified by the EIA and the commitments given by respective parties. Also, given that economic activity could have irreversible consequences, the environment agency should have skills that would allow them to take preventive actions.

D. Material Resources: 

Given that a preventive action is the ideal stance, resources that would enable the regulator to track commitments and performance are necessary. A sole unit, equipped with a good data base system, is required in tracking industry actions.

E. Institutional Support: 

Partnerships with the local government and other stakeholders (NGOs, civic groups) are required to continuously keep track of biodiversity concerns. In the case of Holcim, the clamor for a review of the EIA came from the scientific community.

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