پژوهشنامه شماره ۵: ارزیابی اثرات زیست محیطی و اجتماعی و کسب و کار مسئولانه در ایران

THE PRACTICE

1. EIA Regulations Are Not Followed

   • In practice, EIA requirements are infrequently met in Iran. Understanding of environmental impacts is limited to direct effects on the soil, water or air in the immediate area (and even those are not rigorously addressed), with little if any reference to broader concepts of pollution, indirect or cumulative impacts, or impacts on communities farther afield.
   • Social impacts are typically either ignored or assessed ineffectively.
   • Standards and benchmarks are not part of the regulatory framework, undermining impact assessment and the preparation of Action Plans to address concerns tagged in the EIA.
   • President Rouhani has publicly noted the deficiencies in Iran’s EIA process and called for greater transparency. To date there has been little progress in these areas.

2. Low Levels Of Expertise

   • In a 2012 article, the Deputy Director of the Department of Environment’s EIA bureau noted the lack of expertise among the consultants enlisted by companies to prepare the reports, their practice of submitting reports that are copies of previously approved reports, and the lack of these consultants’ independence from the project holders. He also noted the lack of expertise among the Department’s reviewers, their minimal knowledge of sector specific issues or local conditions, and the lack of reliable sources to which they can refer.
   • There is no indication there has been any significant change. In a 2017 article, another EIA bureau official noted persistent problems of lack of knowledge and relevant guidelines for the assessment process as well as the lack of independence of the consultants.

3. Use Of Outdated And Inaccurate Data

   • Due to deficiencies in the approval process, there is insufficient evaluation of the accuracy of the data, and government reviewers, who may not be apprised of local conditions, typically accept such data. For example, required references on water or soil conditions may be drawn from studies that were done a decade earlier, referring to conditions that no longer exist.
   • Once an EIA is approved, there is no requirement to initiate a reappraisal even if conditions have changed significantly during the period between approval and initiation of the project.

4. Deficient Regulatory Procedures And Monitoring

   • Iran’s regulatory framework does not require that EIAs be completed early in the process, and they are typically one of the last reports submitted. This can create pressure for approval as the project may already be underway. Officials at the EIA bureau have also noted pressure to approve certain projects favoured by the government, even when members of the bureau have recommended to refuse permission for those projects due to environmental concerns.
   • Despite general references to monitoring in Iran’s EIA regulatory framework, there is no effective monitoring. Enforcement and penalties are selective and only occasionally imposed, undermining deterrence.

5. Some Local Initiatives Attempting Progress

   • In a unique local initiative that began in 2008, the Tehran Municipality requires projects undertaken with the municipality to submit an SIA to address social impacts and provide “solutions” for managing impacts. In contrast to Iran’s EIA regulations, Tehran’s SIAs require public input during the assessment and review. The municipality also provides a list of qualified experts to conduct and evaluate the SIAs.
   • However, only 10% to 30% of Tehran Municipal projects submitted SIAs during the 2008-2014 period, indicating implementation is lacking. Moreover, although the regulations state the reports are to be accessible to the public, IBR was unable to locate any reports to review.