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La Educación
Número: (115) II
Año: 1993

Impact Analyses and Assessments as Instruments of Policy

Several forms of policy analysis—assessment of environmental impacts, of risk, of technological effects, and of costs and benefits may be used to ascertain the probable consequences of a policy or program over and beyond its intended results. But the applicability of this information depends upon its projection against relevant environmental policies. Environmental impact assessments inform governments but do not necessarily result in environmentally responsible decisions. Of course, more than environmental effects must be considered in many public programs and decisions. Nevertheless, relatively objective science-based forms of analysis, if adopted and administered by cooperating governments, may be effective strategies for an international integration of national policies affecting environment and development. The European Community has already undertaken a move toward comparable national standards for environmental policy through a commission directive requiring environmental impact assessments.8

After recognition that there are persuasive reasons for the adoption of environmental impact analysis and technology assessment, the appropriate relationship of these techniques to policy remains to be considered. Four principles are fundamental to this relationship. First, these techniques are not ends in themselves; their practical value depends upon their appropriate role in the policy process. Second, improvement of the techniques, while desirable, does not assure their effectiveness in policymaking. Third, although they should form an important informational base for policymaking, they are not substitutes for value judgments. And fourth, their effectiveness requires a focus—a program or a proposition to examine and to assess in relation to specified values. This brings us back to the function of policymaking.

Assuming the existence of a substantive policy objective more explicit than “sustainable development,” we may identify six ways that the quality and reliability of analytic procedures may be made more effective. These would be applicable at any societal level at which they are undertaken, from local to international, but their value depends upon a policy consensus in which criteria for desired outcomes are made explicit.

The first and indispensable action is to obtain the honest commitment of the responsible authorities—political and administrative. The option of joining rhetorical commitment to practical evasion should not be available. Institutional arrangements should be established to make this form of dishonesty impracticable if not impossible. Second, and following from the first, would be the opening of the analytic process and its findings to public review. Informed public scrutiny is possibly the most effective method of maintaining official honesty. A third action, to facilitate public understanding, is to require the sponsors of proposals and their official patrons to make their assumptions explicit. Provision should be made for impartial testing or evaluation of these assumptions. Too often the promoters of development (both private and governmental) conceal or misrepresent their ultimate purposes. Too often they play down and dissemble costs and overestimate benefits. A fourth action is the assembling of analysts competent to assess all major facets of the proposition. They must form an interdisciplinary team capable of cross-disciplinary communication and comprehension. The team must develop the capability of presenting its findings in synthesizing decisionable propositions. The fifth action, which some observers might put first, is the focused search for better science. Obviously, a strengthened and expanded science is needed in achieving a more reliable analysis and assessment. I recognize this need as essential, but do not put it first because we must do the best we can with our present limitations, discovering thereby where our science base needs strengthening.

The sixth way to more effective impact analysis and technology assessment is through institutions with authority and resources for implementation. For such arrangements to be considered and consummated on an international scale, it is necessary to have a basis both of political legitimacy and the prospect of successful cooperation. For the Western Hemisphere, the Organization of American States provides such a base. There is a substantial record of agreement (chiefly regional) among Member States, but in some cases the effectiveness of implementation has been dubious. Although there are great differences among the states, they share in principle many of the basic problems of achieving sustainable development through an appropriate synthesis of environmental and economic policies. Impact analyses and assessment have the capability of discovering the factors that should be addressed to effect this synthesis.

The strategic use of the several forms of impact analysis is not in their procedures per se or even in their scientific findings. Obviously, the reliability of their findings depends upon valid methods and relevant scope. The scientific basis of assessment must either be dependable as a guide to action or, where inadequate, provide a warning against policies having uncertain outcomes and a high probability of serious risk. If the scientific basis of the assessment is adequate for policy purposes, the strategic question is how to incorporate the assessment findings into substantive public policies. Integrating the findings or caveats of impact assessment into policies, plans, and decisions is a strategy that is fundamental to achieving sustainable development.

At present, there appears to be no country in which this integrative strategy has been achieved. In the United States, in which environmental impact analysis became a mandate of law under the National Environmental Policy Act of 1969, efforts continue to be made to discover and apply strategies for integration.9 However, there may not be a “best way” or a “single way” to integrate environmental values, including sustainability, into policies and programs. Among the American states this problem might be approached experimentally but cooperatively. There is already an International Association for Impact Assessment, but an inter-American system for analysis, assessment, and policy formation might provide for cooperative learning and shared experience throughout the hemisphere.10

Even though this may be a feasible proposition, there are, nevertheless, formidable obstacles to its realization. Skeptics argue that: (1) joint or international environmental and technological impact assessment would be an affront to national independent policy and sovereignty; (2) countries are very unequal in their ability to institute or to apply these methods; (3) among the diversity of nations, the impacts of technology on the environment vary greatly; (4) an effect of these methods would be to retard or throttle economic growth; and (5) implementation of these sophisticated methods would impose an “elitist” environmentalist hegemony over ordinary people and would discourage technological innovation.

These arguments apply with less force against the concept of “internationalizing” impact analysis than they do as challenges to the construction of an acceptable, flexible, and reliable international cooperative system. Each nation can cope with some of its problems of environmental stress and technology transfer—but not with all of them. That there would be transnational impacts associated with the threatened “greenhouse effect” and the disintegrating stratospheric ozone layer is obvious, even though their consequences for particular nations are uncertain. Effects of the deterioration of the oceans, regional seas, and their living resources are multinational. Environmental issues pertaining to transboundary risks incurred through international trade and the transport of pathogens and pollutants already have led to a series of multilateral declarations and treaties.