Multi-project environmental impact assessment

Impact Assessment and Project Appraisal

ISSN: 1461-5517 (Print) 1471-5465 (Online) Journal homepage: http://www.tandfonline.com/loi/tiap20

Multi-project environmental impact assessment: insights from offshore oil and gas development in Brazil Cristiano Vilardo & Emilio Lèbre La Rovere To cite this article: Cristiano Vilardo & Emilio Lèbre La Rovere (2018): Multi-project environmental impact assessment: insights from offshore oil and gas development in Brazil, Impact Assessment and Project Appraisal To link to this article: https://doi.org/10.1080/14615517.2018.1475615

Published online: 24 May 2018.

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IMPACT ASSESSMENT AND PROJECT APPRAISAL https://doi.org/10.1080/14615517.2018.1475615

Multi-project environmental impact assessment: insights from offshore oil and gas development in Brazil Cristiano Vilardo

and Emilio Lèbre La Rovere

Energy Planning Program, Graduate School of Engineering, Federal University of Rio de Janeiro (PPE/COPPE/UFRJ), Rio de Janeiro, Brazil ABSTRACT

ARTICLE HISTORY

Despite being adopted worldwide, environmental impact assessment (EIA) is under pressure in many countries, while perceived (rightly or wrongly) as an ineffective and inefficient process. Strategic environmental assessment (SEA) is thought to help address some of EIA’s shortcomings, but it is absent in many jurisdictions and sectors. In this paper, we argue that multi-project EIA can, in some contexts, simultaneously deliver greater effectiveness and process streamlining. To illustrate our claim, we present a case study from offshore petroleum production in Brazil, where the development of the pre-salt giant reserves is being licensed through a multi-project EIA approach, in a non-SEA planning environment. The analysis provides interesting insights on the strengths and challenges of that strategy, focusing on five aspects of practice: cumulative impacts, efficiency, approach to authorizations, follow-up and political issues. Proper scoping was found to be essential to consistent EIA processes and shorter review times. Finally, we suggest that multi-project EIA approach should be revisited by practitioners and regulators to identify opportunities for deployment, especially in jurisdictions where strategic assessments are not in place.

Received 28 February 2018 Accepted 8 May 2018

Introduction Offshore hydrocarbon exploration has been a source of environmental concern over the past decades, especially in the wake of disasters like the Macondo well blowout in the Gulf of Mexico in 2010. Recently, the oil and gas (O&G) industry has shown a global tendency to explore deeper waters, leading to new challenges for environmental conservation (Kark et al. 2015) and sparking calls for deep-ocean protection (Barbier et al. 2014; Mengerink et al. 2014; Cordes et al. 2016). The most disseminated instrument for dealing with the impacts and risks of offshore O&G developments is environmental impact assessment (EIA), being used in nearly all countries worldwide (Morgan 2012). However, despite the widespread adoption and practice improvements over time, project-level EIA presents long acknowledged limitations and shortcomings (see, for instance, Lee and Walsh 1992; Lawrence 2013). O&G assessments are not exception: the performance of O&G EIAs has been criticized in different parts of the world (Barker and Jones 2013; Wright et al. 2013; Anifowose et al. 2016; Prideaux and Prideaux 2016). Many authors suggest that strategic environmental assessment (SEA), in its different approaches and practices (Noble and Nwanekezie 2017), can help overcome some of the project-EIA limitations (Abaza et al. 2004; Alshuwaikhat 2005). Today, several oilproducing countries use SEA in the planning for

CONTACT Cristiano Vilardo [email protected] de Janeiro (PPE/COPPE/UFRJ), Rio de Janeiro, Brazil © 2018 IAIA

KEYWORDS

Environmental impact assessment (EIA); multiproject (EIA); offshore oil and gas; cumulative effects assessment; scoping; effectiveness

O&G exploration, but there is some criticism whether it is reaching its strategic objectives (Fidler and Noble 2012; Lamorgese et al. 2015). Other countries have been using marine spatial planning approaches and developing integrated management plans that involve the petroleum sector (Ottersen et al. 2011; Jones et al. 2016). Unfortunately, making the connections between strategic-level assessments and project-level assessments (‘tiering’) is still a major challenge in most contexts (different sectoral examples can be found in Fischer 2001; Sánchez and SilvaSánchez 2008; Phylip-Jones and Fischer 2015; Malvestio et al. 2018). However, an even harder challenge may be how to improve project EIA when those strategic tiers of assessment are missing. This has been an important debate in countries like Brazil – that does not have SEA requirements in place – especially in times when pressures for streamlining and simplifying EIA are high in Brazilian society (Bragagnolo et al. 2017; Fonseca and Rodrigues 2017; Fonseca et al. 2017). In this context, one important question becomes how to simultaneously deliver (1) improvement of EIA effectiveness and (2) process streamlining? If we expect EIA to be an effective tool to steer potentially harmful activities – like deep-water offshore O&G development – towards a more sustainable path, we need to address that question properly.

Energy Planning Program, Graduate School of Engineering, Federal University of Rio

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C. VILARDO AND E. L. LA ROVERE

In this paper, we argue that a well-known approach to EIA and SEA, the multi-project approach, can be of great value in the offshore O&G sector (and hopefully, elsewhere). To demonstrate it, this paper explores the case of a multi-project EIA approach for the development of the massive deep-water O&G reserves recently discovered in the region called the ‘pre-salt province’ in Brazil. We believe that some aspects of this case study can be insightful for other contexts and sectors, as we discuss some of the strengths and challenges of the multi-project approach.

Methodology This study stems from the first author’s experience as an analyst in the Brazilian federal EIA office, where he worked from 2002 to 2014, leaving to develop his doctoral research. When selecting the research topics, the O&G multi-project EIA experience was deemed worth analysing from an academic point of view. The case of the deep-water exploration depicted in this study was not the first use of multi-project EIA in the Brazilian O&G practice. In 2006, the Brazilian federal environmental agency Brazilian Institute of the Environment and Natural Renewable Resources (IBAMA) pioneered the approach with the ‘Parque das Baleias’ integrated development. However, the ‘Pre-salt Phases 1 and 2’ multi-project EIAs were considered particularly relevant because they represented a much greater challenge for the EIA process administration due to their size and economic importance. In that sense, we felt that an intensive study of that case could help ‘shed light on a larger class of cases’ (Gerring 2006). Such an in-depth understanding of the case usually requires using a variety of data sources (Creswell 2013). In this study, we used essentially qualitative data that were sequentially collected and triangulated to properly describe, understand and evaluate our case. Data were acquired through literature review (peer-reviewed and grey literature), content analysis and, to some extent, participant observation. The latter means that some aspects in the case descriptions are based on recollections of the first author’s experience during the process and would probably be unavailable for an external researcher. Nevertheless, we strived to base our analysis on published and public data, grounding the discussion on the academic literature, to minimize the potential bias of the participant-observation condition (Drake and Heath 2011). The non-systematic literature review was done through online databases like ScienceDirect. As needed, other search engines were also used to dig for specific reports or academic thesis. The resulting review was used both to delineate the issue of multiproject approaches in EIA and to ground the discussion derived from the case study analysis.

To enable a deeper understanding of the cases being studied, we performed content analysis of the environmental licencing (EL) processes for Pre-salt Phase 1 and Phase 2. The analysed documents were (1) terms of reference, (2) environmental impact studies – EISs, (3) public hearings summaries, (4) technical review reports and (5) licences issued. Other EL processes were also analysed to gather information on timelines. All documents are available in the IBAMA’s EL office in Rio de Janeiro. Most part of the documentation is also available online through IBAMA’s website. The case discussion was organized in five themes – cumulative impacts, efficiency, approach to authorizations, follow-up and political issues – as we believe they presented the most interesting insights derived from the studied multi-project EIA experience. Of the five themes, four represent widely acknowledged challenges for EIA practice and one – approach to authorizations – draws on a specific feature of the Brazilian framework considered of potential interest for new or revised regulations elsewhere. The paper is further organized in a section that discusses multi-project approaches in SEA and EIA practice and then a section showing how the approach fits in the Brazilian EL practice. After setting the context, the paper presents the case study itself, followed by a section of discussion and insights organized in the five themes already mentioned. In the conclusion, the main takeaways are summarized.

Multi-project approaches in EIA and SEA Multi-project environmental assessments are neither new or unusual: they can be found both in the EIA and in the SEA practice, with contrasting perspectives. In SEA practice, multi-project assessments are typically undertaken in a programmatic context, at the lower end of the policy–plan–programme (PPP) scale, and frequently make use of what Noble and Nwanekezie (2017) call EIA-like approach to SEA. In this approach, the options are normally ‘limited to alternative means to carrying out or implementing the proposed PPP, as opposed to exploring fundamentally different PPPs, futures, or facilitating the creation of new PPPs’ (Noble and Nwanekezie 2017, p. 168). Fischer TB (2007) adds that usually what a programmerelated SEA does is to help identify priority projects within a determined policy and planning context. Examples vary from groups of a few projects, like the 11 land development projects in the City of Santa Rosa Master EIR, in California (cited in Bass and Herson 1999), to the astounding 1600 projects gathered in the German FTIP – Federal Transport Infrastructure Plan – as mentioned by Fischer (2006). In programme-SEA practice, the decision-making is usually about the scope and format of the programme – individual projects inside

IMPACT ASSESSMENT AND PROJECT APPRAISAL

the programme normally still undergo project-level EIA. Wherever a tiered decision-making context is in place, project-level EIA can become very streamlined. In EIA practice, multi-project assessments are also performed around the world, in situations where projects have a strong connection – normally sharing geographic, technologic and temporal attributes. Typical cases would be industrial complexes, when different types of activities are intrinsically linked (e.g. a petrochemical complex or a portuary complex), or modular initiatives, when multiple individual projects of the same type are co-located in a region (e.g. multiple hydropower plants in the same river or multiple mining sites in the same basin). From a technical point of view, assessing simultaneously a group of initiatives co-located in time and space potentially enables better appreciation of cumulative effects and several other process improvements, like public participation rationalization, cost reduction and integrated monitoring initiatives, tackling some classical difficulties of individual project assessments. Multi-project EIA practice appears to be rarely stipulated in regulation, generally depending on caseby-case decision by the responsible authority or the proponent. A survey involving 20 countries in the European Union found that only Germany and Poland had specific regulations regarding multi-project EIA (Graggaber and Pistecky 2012). In many cases, the multi-project EIA is enforced to avoid the ‘salamislicing’ strategy, used by proponents to keep projects sizes below screening thresholds and escape the need of EIA process (Enríquez-de-Salamanca 2016). In other situations, like the case discussed in this paper, the main driver to multi-project EIA is process

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optimization. Process optimization is usually welcomed by overloaded agencies (what is very common) and in contexts where EIA process is accused of being too slow and bureaucratic (what is also very common). Different from the SEA programmatic practice, in most cases, the EIA multi-project decision-making is part of the permitting or licencing process (as in Brazil). This means that multi-project EIA needs to discuss the projects in greater detail, assessing the specific design options, in order to format the appropriate mitigation and monitoring frameworks that will become requirements of the licence/permit. While the differences on the decision-making objectives explain why EIA multi-project assessments normally dive into more details than in SEA multiproject practice, it is interesting to acknowledge that both practices share a common niche in the decisionlevels continuum – right above single-project EIA and at the lower level of the ‘strategic’ tiers of decisionmaking (PPPs); see Figure 1, adapted from Partidário (2000). In this paper, we argue that EIA practice would benefit from a more consistent use of the multi-project approach, especially in contexts where SEA-type assessments are missing. This is exactly the case of Brazilian O&G offshore development.

Brazilian O&G EL: EIA in the absence of SEA In Brazil, the absence of a strategic-level assessment of the areas to be offered in O&G bidding rounds has elicited calls for SEA implementation for several years (Malheiros and La Rovere 2000; Mariano and La Rovere 2007; Teixeira 2008). Following those calls, in 2012, the

Figure 1. Multi-project EIA/SEA ‘niche’ in the schematic decision-making levels. Adapted from Partidário (2000). The image was prepared by the authors, based on a published illustration by Partidário (2000). Reproduced with permission.

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Brazilian federal government created a SEA-like instrument called Environmental Assessment of Sedimentary Areas (AAAS, in the Portuguese acronym). However, despite being welcomed in the literature (Oberling et al. 2013; Silva et al. 2014), the AAAS process has not been implemented so far. Around 2006, when the significant O&G discoveries in Brazilian deep waters were first announced, project-EIA was (and still is) the main environmental instrument in place to protect the deep sea (and coastal habitats) from the potential harmful effects of that development. The Brazilian project-EIA practice is embedded in the EL process. The Brazilian EL is typically a threephased permitting process: preliminary licence (LP), installation licence (LI) and operation licence (LO). The LP assesses the viability of the proposal, based on the review of an EIS; the LI authorizes the construction or commissioning of the facility and the LO is the final permit that will have to be kept valid throughout the life of the project (Sánchez 2013; Cardoso et al. 2014; Pereira et al. 2014; Fonseca et al. 2017). The responsible authority for the EL of offshore O&G activities is the federal agency IBAMA. The EL process usually involves a single development project – in the offshore O&G production case, normally one platform and the associated underwater equipment (lines, wells, pipes, pumps, valves etc.). Regular practice was to integrate the assessment of more than one platform if they were all part of the same field development project (e.g. Roncador field, involving platforms P-55 and P-62).

As will be shown with the case study, the multiproject EIA approach for the pre-salt developments took that integrative practice further, leveraging the discussions to a regional scale and filling, at least partially, some gaps left by the absence of SEA or SEA-type assessments in early stages of planning.

Case study: EIA of the pre-salt offshore O&G development in Brazil The pre-salt province The pre-salt province comprises a region of roughly 800 by 200 km offshore southeastern Brazil, along the coast of the states of Espírito Santo, Rio de Janeiro and São Paulo (Figure 2). In 2006, Brazilian state-controlled company Petrobras discovered large accumulations of high-quality light oil in deep waters, geologically trapped below a thick layer of salt, thus the name ‘pre-salt’. Jones and Chaves (2015) estimated the total volume of recoverable accumulations in the pre-salt province ranging from 119 billion barrels (P90) to 217 billion barrels (P10), what ranks the pre-salt discoveries among the largest discoveries of the last decades worldwide (Sauer and Rodrigues 2016). The impressive productivity of the pre-salt fields and the high success rate of the exploration led to a fast-paced development over the past 10 years. From 41,000 barrels a day in 2010, the pre-salt production jumped to a million barrels a day in May 2016 – less than 10 years after the first discovery and only 2 years

Figure 2. Location of Pre-salt Phases 1 and 2 initiatives. Source: authors, upon data from BDEP (2017), ICF International (2010) and Mineral Engenharia e Meio Ambiente Ltd (2013).


after reaching 500,000 barrels/day in July 2014 (Petrobras 2017).

The multi-project approach – Pre-salt Phase 1 and Phase 2 In early 2009, Petrobras was already going through the EL of the first pre-salt project, a production system in the Tupi area (later re-baptized as Lula field). It consisted of a single floating platform named FPSO Cidade de Angra dos Reis and the licencing process was running without significant controversy. Then Petrobras presented to IBAMA a package of 15 projects that were to be submitted to appraisal later that year, as they had reached sufficient maturity to be described and assessed in an EIS. All projects were located in the pre-salt province of Santos Basin, at a depth of over 2000 m and at least 230 km from the nearest shore (Figure 2). The package consisted of 3 individual production systems (platforms and associated underwater equipment, like connection pipelines) and 12 extended well tests (EWT). The production systems have expected lifespan of over 30 years, while the EWTs are 6-month well tests used to assess the reservoir in greater detail before designing the definitive production systems that can stay active during decades. Facing the concrete situation described above, IBAMA decided to go for a single assessment process for the whole package, instead of any other approach that would involve splitting the proposed initiatives. This became known as ‘Pre-salt Phase 1’. In early 2012, during the licencing process of Presalt Phase 1, Petrobras presented a new and even larger package of projects in the pre-salt area in Santos Basin. This time, the company presented to IBAMA 13 production systems and 7 EWT, in what became known as Pre-salt Phase 2. Considering the comparative parameters described in Table 1, one can consider the Phase 2 being 4–5 times larger than Phase 1. The formal licencing stories for both Phases 1 and 2 were similar: the EIS review supported a single LP for each package, then separate LI and LO for each individual project. However, a more detailed analysis reveals that some significative differences existed between the processes, as exemplified in Table 2.

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Table 2. Comparative aspects of Phase 1 and Phase 2 EIA processes.

Duration of scoping phase (days) Interagency consultation in scoping phase? EIS terms of reference size (pages) Duration of EIS review phase (days) Initial EIS size (pages) Major EIS revision? Public hearings Total public hearings attendance (persons) Total duration of EIA process (days from notice of intent to first operation licence) Licenses (LP + LI + LO) issued as of 31 December 2017

Phase 1 92 No 30 823 2798 Yes 5 1619 1191

Phase 2 391 Yes 65 339 6539 No 10 2604 1006

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Source: Environmental licensing processes for Pre-salt Phases 1 and 2.

Most differences can be explained by the inherent learning progression as the multi-project EIA approach was being developed, in a typical ‘learning-by-doing’ situation. In that context, Pre-salt Phase 1 pioneered the multi-project approach and suffered from the absence of earlier lessons or guidelines. The terms of reference for the Phase 1 EIS were almost identical to all the other guiding documents issued by IBAMA in 2009 for offshore O&G production projects. This led to an EIS that was perceived as narrow scoped by the public, being too focused in the offshore environment and ultimately failing to present a wider understanding of the potential consequences of the pre-salt development for the coastal communities. The harsh critique received during the public consultation led the agency to ask for a ‘major revision’ of the EIS: a complete reformulation of the document, with a considerably broader geographic scope and several new analytical requirements. The process underwent a new public consultation phase, resulting in a cumbersome and time-consuming process for both proponent and agency. Some lessons were quickly learned as Phase 2 assessment started. A fit-to-purpose scoping document was drafted and sent to interagency consultation before a final version could be published. The longer scoping phase seems to have enabled a more consistent EIS and a shorter review time – less than half the time needed for Phase 1, even with twice as many public hearings and a more comprehensive study.

Discussion and insights on multi-project EIA Table 1. Comparative parameters between Phase 1 and Phase 2 initiatives. Production systems Extended well tests Pipelines (km) Peak oil production (bpd) Peak gas production (MM m3/d) Declared total investment (US$ billions)

Phase 1 3 12 104 365,000 12.4 9.6

Phase 2 13 7 314.5 1471,500 56.9 52.3

In this section, we discuss some insights on multi-project EIA practice, derived from the case analysis. Considering the purpose and aims of this paper, we chose to cover a broader spectrum of themes rather than diving deeper in a few issues. This means that each of the following topics (cumulative impacts, efficiency, approach to authorizations, follow-up and political issues) can be further explored in future research.

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In this context, the brief discussion presented here is intended to showcase some of the strengths and challenges of the multi-project EIA approach in simultaneously improving effectiveness while streamlining the process.

Multi-project EIA can help address cumulative and regional issues The importance of properly assessing cumulative effects in EIA has been debated in the literature for over 30 years now (e.g. Dickert and Tuttle 1985; Contant and Wiggins 1991) and is explicit in many national EIA legislations around the world (Wärnbäck and Hilding-Rydevik 2009). However, continued reports of implementation shortcomings (e.g. Duinker and Greig 2006; Foley et al. 2017) show that ‘understanding remains weak, practice wanting and progress slow’ in cumulative effects assessment (Sinclair et al. 2017, p. 183). It is widely accepted that, while the assessment of cumulative effects can be done in project-level EIA, a more effective and systematic practice emerges when undertaken in regional or strategic contexts (Harriman and Noble 2008; Duinker et al. 2013). That poses a challenge for jurisdictions and sectors with no formal environmental assessment in the strategic levels of planning, as the Brazilian O&G sector. The multi-project EIA case studied in this paper started as a pragmatic decision by the agency (the individual assessment of all the pre-salt’s projects would have overwhelmed the installed capacity of IBAMA) but ended having the effect of creating a ‘programme’ that was not organized as such by the proponent. In that sense, it added a regional and programmatic perspective to the assessment that would not be possible otherwise. This placed the experience somewhere midway between project-EIA and programme-SEA, enlarging the scope of assessment and potentially enabling a better consideration of cumulative issues in the process. However, the case analysis shows that proper assessment of cumulative effects is not an automatic outcome of regional and programmatic approaches but depends greatly on careful scoping and public participation openness. The importance of the scoping stage to the assessment of cumulative effects is well documented in the EIA and SEA literature (e.g. Baxter et al. 2001; Cooper and Sheate 2002; Therivel and Ross 2007). Snell and Cowell (2006) frame the challenge of proper scoping as the tension between ensuring precaution and promoting efficiency in the EIA decision-making process. In that sense, while there is evidence that careful scoping can contribute to prevent delayed reviews (Borioni et al. 2017), that same desire to avoid delays can generate a tendency

to scoping issues in, leading to lengthy, ‘encyclopaedic’ studies (Hansen and Wood 2016). Looking at how cumulative effects were treated in both cases provides a very eloquent contrast. In Phase 1, with minimum scoping effort and standard terms of reference, the first EIS version contained no specific discussion on cumulative issues, only an extra attribute of ‘cumulativity’ when classifying the identified impacts. This was object of harsh critique during the public hearings, joining local politicians, governmental institutions, NGOs, fishermen associations and the broad public against the proponent’s EIS. This eagerness to discuss cumulative and synergistic effects of offshore oil production (and the proponents’ tendency to narrow the scope of assessment) was previously reported in the Terra Nova project, in Canada (Harriman and Noble 2008). In the Brazilian Pre-salt Phase 1 case, a rich debate over the adequate scope for assessing cumulativity in a multi-project context was triggered. How to define where the project ‘ends’? Are the ancillary activities (like supplies transportation) subject to assessment? How to approach activities that are linked to oil production but are currently screened out of EL requirements, like crude oil transportation? These questions are not usually brought to debate when considering a single offshore platform but become unavoidable once the scale of assessment was augmented. This mismatch between societal expectations on cumulative issues and a narrow scoped EIS resulted in a major revision request and unforeseen delays in Phase 1 process. In Phase 2, on the other hand, a more careful scoping exercise was undertaken by the agency, which included the preparation of a revised terms of reference and consultation with different governmental agencies before issuing the final scoping document. The main changes in the Phase 2 Terms of Reference (ToR) seemed aimed at adjusting the EIA to a programmatic level of assessment, leveraging scope and scales of different aspects of the study. One relevant change was the requirement for a specific section called Environmental Prognosis, containing the discussion involving the no-activity scenario and a cumulative and synergistic effects assessment. This requirement resulted in a 148-page EIS chapter that became possibly the first Brazilian O&G EIA experience of a structured cumulative effects assessment. An indepth discussion of the quality and effectiveness of that cumulative effects assessment is beyond the boundaries of this paper, but the contrast between the consideration of those issues in Phase 1 and in Phase 2 is illustrative of the importance of proper scoping in tapping the full potential of multi-project EIA approaches in addressing regional and cumulative issues.


Multi-project EIA is more efficient An efficient EIA process is one which ‘impose the minimum cost burdens in terms of time and finance on proponents and participants consistent with meeting accepted requirements and objectives of EIA’ (Senécal et al. 1999, p. 3). Undoubtedly, economy of time and costs is one of the major benefits that can be expected from a multi-project EIA approach, once several bureaucratic processes are merged into one single process. One can also expect this single process to be more comprehensive and complex than average, but chances are that the difference in resources and time consumption makes it worthwhile – from a simple efficiency point of view. In historical comparison with other O&G production projects in Brazil, as shown in Figure 3, the process durations of the pre-salt cases are well within the dispersion pattern of the data. The overall average review time for the sample is 807 days, making Presalt Phase 1 process 28% longer and Phase 2 process 31% shorter than the average, but falling within the standard deviation of the sample. Bearing in mind that these 2 individual EIA processes assessed 16 production systems, 19 EWTs and almost 420 km of pipelines, the fact that they had a process length compatible with those of regular (individual) projects confirms the expectation of economy of time in a multi-project EIA approach. Reduction of bureaucratic load is not, however, the only factor leading to greater efficiency. Multi-project EIAs tend to rank high in priority to all involved parties. The size of the investment assures that the process is prioritized by the proponent, which is especially relevant in cases where the proponent has more than one project being licensed at the same time. The same is true for the environmental agency, due to the

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processual economies of scale involved: in the pre-salt case, IBAMA assigned a team of exclusive dedication to the project, enabling zero ‘shelf-time’ for the EIS and the additional information reviews. It appears that, by raising the priority to all concerned actors, multi-project EIA can reduce or eliminate the ‘dead’ times in the process, where no action is being made and scarce resources are being used elsewhere. Besides time, the other efficiency component of EIA is cost, in its financial meaning. Data on costs of the EIA process are hard to obtain and the research literature is very limited (e.g. Retief and Chabalala 2009). While we were not able to obtain data on the direct costs of the Pre-salt Phases 1 and 2 EIA processes, it seems agreeable that it should have costed less to prepare and review 2 multi-project EISs than undertaking between 30 and 40 individual assessments, corresponding to the individual projects in the packages. The ability to keep the process within reasonable boundaries of time and costs – i.e. an efficient EIA – seems crucial for resisting the growing pressures for streamlining and simplification. The multi-project approach may help achieve higher process efficiency through reduction of bureaucratic load and high priority for all stakeholders.

Phased approach to authorizations enables continued and flexible follow-up The term follow-up has been used as an umbrella notion meaning various EIA activities taking place after the project is authorized (Morrison-Saunders and Arts 2004) and can be simply defined as ‘the monitoring, evaluation, management and communication of the environmental performance of a project

Figure 3. Simplified timelines for oil/gas production development projects according to the following criteria: (1) licencing based on Full EIS, and (2) operation licences granted in the 2007–2016 period. ‘Total review’ is time spent from ToR issuing to first installation licence granted. Source: Environmental licencing processes.

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or plan’ (Morrison-Saunders et al. 2007). It is also widely recognized as a highly deficient area in EIA practice (Sadler 1996; Abaza et al. 2004; Arts et al. 2012; Glasson et al. 2012). In Brazil, there is also evidence of follow-up practice being substandard (Dias and Sánchez 2000; Lima and Magrini 2010; Agra Filho et al. 2012), although Sánchez (2013) claims that ‘improvements have been observed’ recently in Brazil. One of the examples of successful follow-up schemes is depicted in Gallardo and Sánchez (2004) and Sánchez and Gallardo (2005). In that context, follow-up practice in offshore O&G EIA has been regarded in a positive way by a series of academic thesis and dissertations in recent years (Serrão 2012;Bredariol 2015; Mendonça 2015; Cruz 2016), mainly for having structured procedures and considerable effort in post-decision follow-up. One specific feature of Brazilian licencing framework, however, offers an interesting platform for optimizing follow-up in multi-project EIA. The typical three-phased licencing framework –LP, LI and LO – provides sequential check-points in which environmental agencies are mandated to ‘check compliance with terms and conditions of one license in order to grant the next license’ (Sánchez 2013). In the multiproject EIA approach, this characteristic is maximized, as there are several licences being issued sequentially after a first LP. This generates a fertile field for a continued and flexible follow-up practice, where the conditions for operation are being re-evaluated constantly and the post-decision phase of one licence is merged with the pre-decision phase of the next one. In the Pre-salt Phases 1 and 2 cases, IBAMA took advantage of this phased approach to (1) incrementally improve programmes and requirements that could evolve from earlier concepts to mature frameworks while being revisited at each new licence; and (2) use the ‘next’ licence as a new pressure point to ensure implementation of programmes, sometimes conditioning the new authorization to certain performance landmarks. While this phased approach to authorizations seems characteristic of the Brazilian EIA system, the benefits for a continued and flexible follow-up are evident (especially in a multi-project context). In this sense, the idea of sequential compliance check-points can be useful for regulations being prepared or revised elsewhere.

Follow-up: larger scale leads to greater programmes A multi-project EIA approach is typically characterized by the amplification of the geographic and temporal scales of assessment, potentially enabling a better prognosis of cumulative effects during the EIS review phase. Later, that amplified scale is also carried into the post-decision phase, influencing follow-up

programmes and initiatives. To effectively mitigate and monitor the more complex set of impacts arising from the multi-project initiative, there is a need for designing robust, area-wide follow-up programmes. Regional monitoring and mitigation programmes can be quite expensive. However, in a multi-project context, cost-sharing ensures that they become comparatively cheaper than would be if individual initiatives were to be deployed. Ideally, this economy of scale should be turned in favour of bolder approaches in terms of methodological and scope choices for those programmes. This potential is well documented in the present case study. In Pre-salt Phases 1 and 2 cases, IBAMA demanded Petrobras to implement several regional monitoring and mitigation programmes that are not usually required in individual O&G production licences (Table 3). Most of those examples are basin-wide initiatives, only made possible by the scale of the multi-project assessment. Naturally, there are challenges associated to the proper coordination and supervision of such regional programmes, due to their size and complexity. For example, the Beaches Monitoring Program for the Pre-salt Phase 2 involves coordinating 15 executing institutions that monitor daily more than 1500 km of shoreline, recording and performing rehabilitation of stranded fauna. Nevertheless, the ability to design, implement and follow-up to an array of region-wide monitoring and mitigation programmes seems an added strength of the multi-project EIA approach. These programmes can be larger and more complex than those of individual EIA processes, with the extra benefits including a long-term vision of cumulative effects on the environment.

Higher stakes usually mean raised political pressure Departing from the early rationalist model of decisionmaking (Lawrence 2000), there is increasing recognition of the political nature of the EIA process (Cashmore et al. 2010; Morgan 2012; Hansen et al. 2013). Recent research has focused in specific issues related to power Table 3. New monitoring programmes in Santos Basin region, not usually demanded for individual platforms, made possible by the multi-project EIA approach. New regional monitoring programmes Pre-salt Phases 1 and 2 Operation of production and offloading systems Utilization of access ways to installation sites Fisheries activities Socioeconomic indicators Submarine acoustic landscape Cetaceans Beaches Avifauna Vessel traffic Cumulative impacts Source: Environmental licensing processes for Pre-salt Phases 1 and 2.


in EIA, like manipulation (Enríquez-de-Salamanca 2018) and corruption (Williams and Dupuy 2017). In Brazil – and elsewhere, especially in developing countries (McCullough 2017) – EIA process is very permeable to political will (Glasson and Salvador 2000). The fact that decisions over a project being licensed in Brazil can go forward despite contrary technical and public opinion is well documented in academic literature (e.g. Hochstetler 2011; Hanna et al. 2014; Pereira et al. 2014; Fearnside 2015). Therefore, once the stakes are higher in a multi-project EIA approach – larger investments, more stakeholders, increased priority – the risk of political interference is also raised. The forms of power exertion and their potential consequences are as vast as the diversity of decisions made in an EIA process, as each one of them can be biased in favour of the strongest power coalition. However, the study of power and political influence in EIA is still very limited and methodologically challenging (Cashmore and Axelsson 2013), despite the long tradition of the political sciences. In this context, considering the economic relevance of the Pre-salt Phases 1 and 2 cases, there is some evidence that political interference may be occurring. A manifesto written by IBAMA’s workers association (ASIBAMA-RJ 2015) claims that implementation of some of the monitoring/mitigation programmes is severely delayed – but subsequent licences are being granted despite technical advice suggesting that they should be halted until proper implementation of the programmes. Analysis of technical documents in the processes confirms poor performance by the company and lack of enforcement by the higher hierarchical spheres of the agency. This is yet another point of concern when dealing with multi-project EIA approach: as the monitoring and mitigation programmes get larger and more complex, weak implementation or non-compliance can affect environmental performance throughout an entire region. A potential strategy to counter this risk would be to increase transparency and public participation during all phases of EIA, including the long follow-up. Present practice, in Brazil and in many other countries, is that public participation (if any) is concentrated in the pre-decision stages. Strategies that open spaces of participation and external performance auditing in the follow-up phase could increase the social accountability of the proponent and the agency, leaving less room for political interference in decisions.

Enabling conditions and other settings We acknowledge that the case presents some favourable enabling conditions for the development of a multi-project EIA: single proponent, single responsible

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authority, relatively homogeneous environmental conditions and the projects are to be commissioned close enough in time to assume that they are part of the same intervention package. However, other arrangements seem possible as well, depending on the specific legal constraints of each jurisdiction. A multi-proponent multi-project EIA, for example, may be possible if there are clearly defined responsibilities regarding the projects. Or there can be multi-project EIA in more heterogeneous environments, such as terrestrial landscapes, if that diversity is properly acknowledged and dealt with in the process. Nevertheless, the deep-sea oil exploration case provides an insightful model to the potential benefits and caveats of the multi-project approach.

Conclusion Aiming to contribute to the advancement of the ‘interminable issue of effectiveness’ (Cashmore et al. 2004), in this paper, we argue that the multi-project EIA approach – as shown in the Brazilian deep-water O&G offshore sector – offers a potentially sound framework for both effectiveness improvement and process streamlining. In that sense, we suggest that this well-known approach should be revisited by practitioners and regulators to identify opportunities for deployment, especially in jurisdictions where strategic assessments are not in place. While not aimed at a comprehensive assessment of the drivers of effectiveness in multi-project EIAs, our case analysis provided some insights that can be useful or inspiring to other contexts: ● Where SEA is missing in strategic levels of plan-

ning, multi-project EIA can help provide a regional and programmatic perspective to impacts assessment, enabling a more qualified consideration of cumulative effects. However, proper cumulative effects assessment depends on careful scoping and openness to public input. Greater attention to the scoping phase seems to enable a more consistent EIS and shorter review times. ● Multi-project EIA is more efficient than individual projects assessments, not only because merging processes reduces bureaucratic load but also by raising its priority to proponent, agency and other stakeholders. ● The scale of a multi-project EIA approach can justify the design and implementation of regional mitigation and monitoring programmes, with bolder methodological and scope choices. ● A phased approach to authorizations provides sequential compliance check-points, enabling a continued and flexible follow-up practice. This, of course, is contingent to the regulatory context of

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each jurisdiction but can be insightful for regulations being prepared or reviewed. ● As the stakes are higher in a multi-project EIA, political interests can raise the pressure over decision-making in more permeable contexts, putting at risk the enforcement of technical advice or the addressing of public concerns. The multi-project EIA approach is a fertile field of research – a multitude of methods and theoretical lens can be used to explore the complexity presented in those cases – as it is a fertile field for practice innovation. In the Brazilian case, as illustrated in this paper, the multi-project O&G experience is pushing the advancement of cumulative effects assessment, scoping, follow-up schemes and more. The Pre-salt Phase 3 EIA is undergoing at the time of writing. Although there is always room for further enhancement, we believe that cases that portrait EIA good practices need to be highlighted and discussed, especially when reforming pressures are on the rise worldwide (Bond et al. 2014; Bragagnolo et al. 2017). The lessons and insights from the Brazilian O&G multi-project experience are hopefully of great value elsewhere.

Acknowledgements The authors would like to express gratitude to Guilherme Carvalho (IBAMA) for the valuable help with the EL processes data. We also thank all the IBAMA oil and gas EL team for showing that, despite all challenges and constraints, the public service in Brazil can be a place for innovation and excellence. Finally, we are grateful for the constructive feedback from the reviewers and editors that helped improve this paper.

Disclosure statement No potential conflict of interest was reported by the authors.

ORCID Cristiano Vilardo

http://orcid.org/0000-0002-8089-4635

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