Environmental Impact Assessment Review 30 (2010) 312–318

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Environmental Impact Assessment Review

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Environmental justice, impact assessment and the politics of knowledge: Theimplications of assessing the social distribution of environmental outcomes

Gordon WalkerLancaster Environment Centre, Lancaster University, Lancaster, LA1 4YQ, UK

E-mail address: g.p.walker@lancaster.ac.uk.

0195-9255/$ – see front matter © 2010 Elsevier Inc. Aldoi:10.1016/j.eiar.2010.04.005

a b s t r a c t

a r t i c l e i n f o

Available online 16 May 2010

Keywords:Environmental justiceImpact assessmentConflict

Claims of environmental injustice have increasingly become part of environmental conflicts, both explicitlythrough the work of environmental justice campaigning groups and implicitly through the argumentsdeployed about the rights and wrongs of a given situation. Such claims can centre on different notions ofjustice, including those concerned with questions of distribution and procedure. This paper focuses ondistributional or outcome justice and explores what implications follow when the distributional concerns ofenvironmental justice are included in the practice of impact assessment processes, including through socialimpact assessment (SIA). The current use of impact assessment methods in the UK is reviewed showing thatalthough practices are evolving there is a little routine assessment of distributional inequalities. It is arguedthat whilst this should become part of established practice to ensure that inequalities are revealed andmatters of justice are given a higher profile, the implications for conflict within decision making processesare not straightforward. On the one hand, there could be scope for conflict to be ameliorated by analysis ofinequalities informing the debate between stakeholders, and facilitating the implementation of mitigationand compensation measures for disadvantaged groups. On the other hand, contestation over how evidence isproduced and therefore what it shows, and disagreement as to the basis on which justice and injustice are tobe determined, means that conflict may also be generated and sustained within what are essentially politicaland strategic settings.

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1. Introduction

Questions of justice and fairness can often be at the centre ofconflict over decisions with significant environmental consequences.Discourses of procedural justice (the fairness of decision makingprocesses) and distributional justice (the social patterning of costsand benefits) have been shown to run through many cases ofenvironmental contestation, including those related to transportinfrastructure, energy generation and waste disposal (Schweitzerand Valenzuela, 2004; Grimes, 2005; Watson and Bulkeley, 2005;Dodds and Hopwood, 2006; Wolsink, 2007). In the US in particularsuch discourses have been central to the environmental justicemovement which emerged in the 1980s as a challenge to establishedenvironmentalism and to practices which it was claimed imposedtoxic and polluting facilities in ethnic minority and poor communi-ties to a disproportionate degree (Capek, 1993; Harvey, 1996;Bullard, 1999; Taylor, 2000). The use of the environmental justiceframe has now extended beyond the US, to emerge in a diversity ofplaces and contexts around the world and at different scales, butmaintaining a central focus on the justice of current environmentalconditions, access to environmental resources, decision making

processes and policy outcomes for different social groups (Byrneet al., 2002; Walker and Bulkeley, 2006; Schroeder et al., 2008; Szeand London, 2008; Walker, 2009).

In principle the use of impact assessment tools (broadly defined),including social impact assessment (SIA) (Vanclay, 1999; Burdge,2003), could have a role in better addressing questions ofenvironmental justice in decision-making settings (Connelly andRichardson, 2005). This is first through impact assessment processesenabling inclusive stakeholder participation and thereby contribut-ing to procedural justice (something that is particularly important inSIA; Buchan, 2003), and second through impact assessmentproviding for the systematic analysis of the social patterning ofimpacts and benefits from projects, plans and proposals. This seconddimension, concerned with the justice of substantive outcomes, isthe primary focus of this paper, although as we shall see it is difficultto entirely disentangle from matters of process and participation(Schlosberg, 2007). The aim of the paper is to explore theimplications that follow when the distributional concerns ofenvironmental justice are substantially included in the practice ofimpact assessment processes. In particular the paper seeks to assesswhether or not conflicts over the inequality and injustice ofenvironmental outcomes are likely, as a consequence, to beproductively addressed or ameliorated. Is an impact assessmentprocess that focuses on understanding the distribution of impacts

313G. Walker / Environmental Impact Assessment Review 30 (2010) 312–318

across different social groups, such as can be achieved within an‘equity-focused’ SIA (Wells et al., 2007), likely to reduce contesta-tion; or is this a presumption which runs counter to the politics ofknowledge and justice that are involved when contentious environ-mental decisions are at issue?

In order to work towards this evaluation, the paper first reviewsthe extent to which, in a UK context, current practice in the use ofimpact assessment methods provides for the effective analysis of thedistribution of environmental outcomes for different populationgroups. It is shown that, although UK practice is evolving, there is alittle routine assessment of distributional issues in the use of impactassessment methods, in part because of the particular profile ofmethods that are included and excluded from the UK institutional andregulatory system. Current practice could therefore be developed tobe more inclusive of questions of distributional inequalities. Theimplications of so doing are then considered, focusing on the ways inwhich undertaking distributional analyses – which explicitly identifypatterns of ‘winners and losers’ and especially vulnerable or burdenedsocial groups – might help to reduce or address conflict betweenstakeholders. Conclusions are drawn which seek to balance thepossibilities for achieving more consensual outcomes, with processeswhich may serve to generate or sustain difference and disagreement.

Table 1Sixteen forms of impact assessment, their status in the UK and the profile given to distribu(Source: Walker et al., 2007).

Impact assessmenttool

Focus of assessment

Environmental OrientationEnvironmentalimpactassessment

Environmental effects of a development proposal, and potentialmitigation options

Strategicenvironmentalassessment

Environmental and sustainability implications of strategic policies,programmes and plans

Social orientationSocial impactassessment

Impacts a proposed action will have on the life of individualsand communities

Health impactassessment

Health effects, positive and negative, of a project,programme or policy

Health equity audit Impacts on health inequalities of a project, programme or policyWell-being powerand WB impactassessment

Impact of a local plan or project on community well-being

Gender impactassessment

Relative impact of a policy or practice upon men andwomen respectively

Equality impactassessment

Impact of a policy on different groups in relation to religiousbelief, political opinion, racial group, age, marital status, sexualorientation and disability and dependency

Economic orientationRegulatory impactassessment

Impacts of policy options in terms of costs, benefits and risksof a proposal.

Green bookguidance

The combined economic, financial, social and environmentalimpacts of a policy, programme or project involving public investm

Assessment ofimpacts of spatialinterventions

The combined economic, financial, social and environmentalimpacts of spatially targeted interventions

Consumer impactassessment

Whether markets and public services are working in theconsumer interest.

Transport analysis The prioritisation of transport investment proposals bycomprehensive analysis of the full range of impacts

Integrative orientationSustainabilityappraisal

The extent to which the implementation of a plan or strategy woulachieve the environmental, economic and social objectives by whicsustainable development can be defined.

Integrated policyappraisal

All the potentially significant impacts of a policy proposal addressinthese at the same time

2. Distributional analysis in impact assessment in the UK

There is a wide range of impact assessment and policy appraisaltools that are currently applied in the context of environmentallysignificant decision-making. The profile of tools that are used variesconsiderably from country to country and across different levels ofgovernment. In research undertaken for Friends of the Earth in a UKcontext, a total of 16 different forms of impact assessment (seeTable 1) were identified as potentially relevant to environmentaljustice concerns (Walker et al., 2005; Walker, 2007). This number ofdifferent tools reflects the breadth with which environmental justicehas been interpreted in the UK, incorporating a wide range ofinequalities in both the distribution of negative environmentalimpacts and in access to environmental resources and benefits(Bulkeley and Walker, 2005).

Connelly andRichardson (2005:402) comment that ‘while progressmay have been made towards integrating environmental justice insome environmental assessment areas, it does not appear to havebecomemainstream practice’ and this is confirmed by the assessmentof Walker et al (2005). Based on an evaluation of the guidancedocuments for each of the sixteen impact assessment methods threekey conclusions were reached. First, that only three of the methods

tional analysis.

Statutoryrequirement

Officialpolicy

Advisorypolicy

Profile fordistributionalanalysis

Guidance ondistributionalanalysis

Yes Low None

Yes Low Little

Medium Some

Yes Yes High Substantial

Yes High SubstantialHigh Little

Yes Medium Some

Yes (inNorthernIreland)

High Substantial

Yes Yes Medium Some

entYes Yes Medium Substantial

Yes Yes Medium Some

Yes Medium Little

Yes Yes Medium Substantial

dh

Yes (in England) Yes Yes Low Little

g Medium Substantial

314 G. Walker / Environmental Impact Assessment Review 30 (2010) 312–318

gave a significant explicit profile to distributional analysis; HealthImpact Assessment, Health Equity Audit and Equality ImpactAssessment. In each of these cases there was a strong ethic orprinciple underlying the method which focuses on analysing andaddressing inequalities, but not necessarily environmental ones.Second, that the three methods with a statutory status at the timeof the research gave only a low profile to distributional analysis. EIAwas most fundamentally lacking any inclusion of distributionalelements, a conclusion highlighted in other research on the treatmentof socio-economic aspects in UK implementation (Glasson andHeaney, 1993) and specifically on the analysis of distributional effects(Chadwick, 2002). It should also be noted that SIA, which doesexplicitly analyse patterns of impact on people and communities in itsestablished methodologies (Burdge, 2003), has no statutory statusand is used very rarely at all in the UK (in contrast to countries such asCanada and Australia where it is far more established). Third, whilstfor several tools substantial and fairly detailed guidance on how to dodistributional analysis was available, this rarely provided examples ordiscussed issues involved in undertaking distributional analysis inrelation to environmental impacts. Overall the conclusion of thisresearch was that there was a ‘distributional deficit’ in the policy andimpact appraisal tools being applied to environmentally significantdecision making in the UK.

Developments in the UK since this review have to some extentbegun to recognize the need to develop policy and practice to includedistributional concerns. In Scotland specifically there was a debatearound the implementation of Strategic Environmental Assessment(SEA) and the translation of the EU Directive into national legislation,which focused on the extent to which the EU requirements could beextended to include environmental justice concerns. As Connelly andRichardson (2005) discuss there was no recognition of the need toconsider distributional issues in the EU SEA legislation or relatedguidance. However the Scottish political context has been distinctivein recognizing environmental justice as a cross-government objective(Scandrett et al., 2000; Scandrett, 2007), giving the possibility ofmoving beyond the bare minimum of the EU requirements. Inconsultation on the implementation of the SEA Directive Friends ofthe Earth Scotland (2004b: 1) argued that:

“Robust implementation of SEA can play a critical role in thedelivery of sustainable development and environmental justice inScotland. Central to this implementation must be …full con-sideration given to human health and distributive effects”

The Scottish Executive to some degree proved sympathetic to sucharguments, and as part of an implementation of the SEA Directivewhich extended its application and scope (Jackson and Illsley, 2006),the need for SEA to contribute to environmental justice has beenexplicitly recognised. Jackson and Illsley (2007: 620) however notethat whilst procedural dimensions of environmental justice areprovided for, principles of distributive or substantive justice ‘haveyet to be adequately articulated’ and consequently ‘Scotland will notbe able to use its innovative system of SEA to deliver substantiveenvironmental justice’.

In England andWales the profile of environmental justice in policyhas been less strong and hasn't featured as explicitly in debates aboutimpact assessment and policy appraisal, despite some lobbying on thistopic by Friends of the Earth. Some local planning authorities haveexperimented with including distributional analysis as part ofSustainability Appraisals of local development plans, and the HealthProtection Agency has routinised the inclusion of rudimentary healthinequality assessments when they provide comments on the healthimpacts related to applications for regulatory and project permits —

for example for Integrated Pollution Prevention and Control sites(Ahmad et al., 2005). Arguably also health related assessments in theUK, for example of air quality impacts (Harrop, 1999) do take some

implicit account of inequalities, in that when undertaking exposureassessments the most vulnerable members of the population areusually assessed (e.g. dioxin assessments assessing risks to breast-fedinfants). However this is an implicit assessment of vulnerability, notan explicit mapping of patterns of inequality.

Another example is the appraisal process related to decisions oninvestment in flood protection carried out by the Environment Agencywhich has evolved to take some account of the particular vulnerabilityprofiles of residents at risk from flooding — although the proceduresused have been criticized for still having the likelihood of being unfairto different at risk populations (Johnson et al., 2007). Such develop-ments have been piecemeal however and the key environmentaldecision processes are still typically lacking any systematic appraisalof distributional issues.

This gap was recently highlighted by campaigners protestingagainst proposals to further expand Heathrow airport near to London,through the building of a further runway. This has been deeplycontentious on a number of grounds, including both local impactsfrom noise, pollution and congestion as well as the global implicationsfor carbon emissions from increasing the number of flights to andfrom the airport. Local protest groups from the Asian community,which features strongly amongst the population closest to the airport,in collaboration with Friends of the Earth activists, argued that aproper assessment and consultation on the ‘equality’ implications ofthe development had not be carried out, and lodged legal proceedingsagainst the Department of Transport to this effect (New EconomicsFoundation, 2009). The legal case rested on the obligation on all publicauthorities, under the extension Race Relations Act 2000, to ensurethat their policies do not have disproportionate impacts on ethnicminority groups. The response was an initial ‘Equality ImpactAssessment’ (EqIA) screening which concluded that a full assessmentshould be undertaken due to potential impacts of noise on age groups(particularly children and young people) and areas with a highproportion of Black and Asian minority ethnic (BAME) groups(Department for Transport, 2009a). The full assessment undertakenfor various potential expansion options for the airport, concludedthat:

“Each development Option could result in both positive andnegative noise, air quality and economic impacts on equalitypriority groups. BAME groups, children, young people, olderpeople, women/carers, disabled people and those with lowincomes are likely to be differentially affected by the developmentproposals. Additionally, BAME groups, children, older people andthose on low incomes could also be affected due to theirdisproportional representation in particular areas around theairport” (ibid: xii)

The final decision to go ahead with airport expansion noted theseresults, but did not see them as sufficient to significantly modify whatwas planned, although intentions to further investigate the potentialfor mitigation measures for ‘equality priority’ groups were made(Department for Transport, 2009b).

3. Bringing distributional analysis into impact assessment

The discussion so far has shown that, in a UK context, there is littleroutine assessment of the social patterning of impacts of environ-mental decisions in impact assessment processes. For those concernedwithmatters of inequality and justice this is a significant omission andvarious possibilities exist for how environmental justice issues couldbecome further institutionalized into decision processes.

Looking to the US for guidance appears sensible in that there theenvironmental justice agenda is far more advanced. Over a 30 yearperiod there has been grassroots environmental justice mobilizationand protest, often focused on the outcomes and consequences of

315G. Walker / Environmental Impact Assessment Review 30 (2010) 312–318

public policy measures. Much of this activity has been concerned withthe distribution of waste, pollution and risk in relation to patterns ofethnicity, including accusations that ‘environmental racism’ has led toa disproportionate exposure of minority groups to threats to theirhealth and well being (Bullard, 1999). Because of this length andintensity of attention given in the US to matters of distributionalinequality, there are specific methods of environmental justice orenvironmental equity appraisal that have been developed for use bythe Environmental Protection Agency (EPA) and other federal bodies.These are applied in implementing Executive Order 12898 passed in1994, which required all federal bodies to make environmental justicepart of their working principles and practices. Executive Order 12898specifically refers to the need for each Federal agency to ‘analyzeinformation on the race, national origin, income level, and otherreadily accessible and appropriate information for areas surroundingfacilities or sites expected to have a substantial environmental, humanhealth, or economic effect on the surrounding populations’ andguidance was accordingly developed by the EPA for how thedistribution of environmental impacts should be assessed (Environ-mental Protection Agency, 1998). These appraisals have been typicallyundertaken in relation to the location of industrial and waste facilitiesor transport infrastructures, and guidance lays out the approach to beused for analysing community characteristics and patterns of‘disproportionate impact’. They are routinely used, but only for arestricted range of environmental concerns, and have been criticizedfor the limited and inconsistent way in which environmental justiceissues and communities are defined (Holifield, 2004; Office of theInspector General, 2004).

In a UK context such forms of analysis could be integrated within arange of impact assessment methods that are already currently beingused — recognizing the wide range of methods already in place andthe diversity of EJ concerns across different policy areas. It has beendemonstrated in the Heathrow case that Equality Impact Assessmentcan be applied to environmental concerns, providing a methodologythat is explicitly focused on identifying differential impacts ondifferent population groups. SEA also provides a potentially produc-tive vehicle for assessing environmental justice concerns (as arguedfor in Scotland) given that it has both a statutory status and flexibilityin being used in a range of different decision making contexts, andcould address the wider scale distributional implications of policiesand programmes, rather than just individual projects. Connelly andRichardson (2005) make a strong argument for what they call ‘value-driven’ SEA which focuses on the justice of outcomes that areproduced, and not only the carrying out of a fair and inclusive process.This leads them to argue that:

‘Good SEA … takes into account the distributional consequencesof the assessment process, with decisions driven by the recogni-tion that certain groups tend to systematically lose out in thedistribution of environmental goods and bad.’ (ibid: 393)

They follow on to argue that ‘good SEA’ should have role inredressing these systematic imbalances particularly for the mostvulnerable and disadvantaged, explicitly recognizing that the public isnot a homogenous group and that participatory processes cannotgenuinely give equal access and influence to different public voices.Environmental justice, they conclude, should feature at every stage ofthe SEA process, from the scoping of who is likely to be affectedthrough to the post-auditing of the ‘actual distribution of environ-mental goods and bads’ (ibid: 405). A similar case is made by Jacksonand Illsley (2007) who see SEA as potentially contributing to reflexiveforms of sustainability governance in which normative values aremore explicitly articulated and thereby a potentially more equitableset of environmental outcomes delivered.

In principle also a move towards the use of SIA in the UK couldprovide for an approach to impact assessment that readily involves

distributional analysis. SIA is inherently concerned with impacts ofpeople and communities, and guidance on how to undertake SIAexplicitly refers to matters of equity and distribution. The InternationalAssociation for Impact Assessment principles of SIA (2003) areparticularly clear about the importance of equity concerns (Vanclay,2006), stating that ‘The goal of impact assessment is to bring about amore ecologically, socio-culturally and economically sustainable andequitable environment’ and the first Principle of SIA practice is stated as‘Equity considerations should be a fundamental element of impactassessment and of development planning’. However, as noted earlier,despite the lengthof time forwhich SIAhas beenused in other countriesand the strong advocacy for its application in a range of contexts(including climate change; Burdge, 2008), UK institutions, regulationsand practice have resolutely resisted moving in this direction.

4. Evidence of distribution and its potential role in addressingconflict

Whether through SEA, EqIA, SIA or another route, the questionposed at the beginning of the paper was what consequencesintegrating distributional analysis into impact assessment processesmight have for patterns of conflict and contestation. If impactassessment methodologies are used to produce evidence on the socialdistribution of environmental benefits and burdens, does this in someway enable conflicts to be addressed, informing debate betweencompeting interests and moving towards finding more consensualoutcomes?

There are a number of lines of reasoning that do head in thisdirection. Each of these are centred on the notion that moreinformation is intrinsically a ‘good thing,’ providing for a dispassionateassessment of the evidence of distributional inequalities and therebyenabling an informed and reasoned debate about the rights or wrongsof a given situation and how impacts on particular communities can beaddressed. Here part of the rationale is that conflict arises from a lackof reliable evidence. If that evidence is made available, better debatecan then follow and all parties can negotiate on the basis of somedegree of shared understanding. Depending on the nature of theevidence produced, different responses may then follow.

If distributional analysis is undertaken for a series of alternativeproposals or scenarios (as would be expected within a comprehensiveSEA), then questions of who is benefiting or losing, and to whatdegree, can be explicitly assessed as part of the evaluation andselection of ‘better’ or ‘worse’ scenarios. Identifying some scenarios asmore socially progressive than others can arguably help to structuredebate and represent the interests of those who are not necessarilygoing to be present or influential in decision making fora. Althoughnot within an actual impact assessment context, Mitchell (2005)provides an example of such an analysis forecasting the environmen-tal equity implications of patterns of exposure to air pollution for arange of transport planning scenarios in the city of Leeds in the UK.This shows that depending on the chosen management scenario, forexample road network development or congestion charging, theequity implications in terms of impacts on socially deprivedpopulations could be substantially different. The Heathrow EqIA alsodemonstrated that depending on the airport expansion scenarioadopted implications for population subgroups would vary signifi-cantly (Department for Transport, 2009a), although this did not figurein the justification of the chosen option.

Where particular impacts on vulnerable or disadvantaged commu-nities are identified, mitigation measures might also be developed andnegotiated in order to try and address the imbalance in benefits andburdens that are involved. Suchmitigation can take different forms. TheUSDepartmentof Transport FederalHighwayAdministration (forwhomExecutiveOrder 12898 applies), has reported on various caseswhere thenegotiation of mitigation measures has been linked to the results of adistributional analysis in impact assessment (US Department of

316 G. Walker / Environmental Impact Assessment Review 30 (2010) 312–318

Transportation Federal Highway Administration, 2000). For example, animpact statement undertaken for an expressway in Durham, NorthCarolina highlighted its adverse impacts on a poor African-Americanneighborhood. This then led to the development of a mitigation andenhancement plan focused on preserving community cohesiveness,reported to have involved close interaction between residents andtransport and planningprofessionals. TheHeathrowEqIA also identifiedpotential mitigation options focused on the most vulnerable groups tonoise and air quality impacts, although no commitments to implementthese options have been made. Good Neighbour Agreements have alsobeenadvocated as awayof addressing local community concernswhereenvironmental justice issues have been identified (Lewis and Henkels,1998; Illsley, 2002; Friends of the Earth Scotland, 2004a). Theseagreements provide a formal and sometimes legally-backedmechanismfor negotiating, usually between an industrial site operator and localresidents, the standards of operator performance that are to bemaintained in terms of, for example, emission or noise levels, accessto information and thehandling of complaints. Such agreementsmaybeall the more powerful where an impact assessment has formallyrecognised that a particular community is unduly burdened, orespecially vulnerable to harm, providing a foundation for the negotia-tions that may then follow.

The outcome of a distributional analysis may also provide anevidence base for the negotiation of compensation rather thanmitigation or performance measures. Compensation mechanisms havebeen long advocated as a way of addressing conflicts over the siting ofnew development projects (Lesbirel and Shaw, 2005; Nieves et al.,2006) and specifically where environmental justice is at issue (Fieldet al., 1996). Compensation does not seek to address directly theenvironmental burden being taken, but rather provides other benefitswhich in some way provide a counterbalance. In the US compensationhas de facto become part of the policy response to the identification of‘environmental justice communities’ living near to both new andexisting industrial and waste sites (Foreman, 1998). Here ‘compensa-tion’ typically takes a number of different possible forms including theprovision of local job programmes, education and training initiativesand investment in community facilities (Holifield, 2004). The EPAencompasses such measures under the labels of ‘partnership working’and ‘community revitalization’ and has promoted integrated models inwhich the ‘environmental, public health, economic and social concernsof distressed communities’ are simultaneously addressed as a responseto locally based protest (US Environmental Protection Agency Office ofEnvironmental Justice, 2000). In this way local environmental justiceactivists are brought into collaborative processes that seek to develop‘proactive’ and ‘positive’ plans for the future.

5. The politics of knowledge and justice

Whilst such opportunities and possibilities exist for using evidenceof distributional patterns as a positive catalyst for responding to conflictand progressively addressing inequalities, there are other more criticallines of reasoning which head in a different direction. These suggestthat the dynamics and parameters of environmental contestation andof knowledge productionmight be quite different and less conducive toreducing conflict between different interests. This is for a number ofreasons.

First, rather than reducing conflict, evidence which highlightsdifferences in the social patterning of impacts that were previouslyhidden or unknownmay add a new controversial current into a debateand become a new focus for dispute and contestation. For groups suchas Friends of the Earth in the UK, their interest in pushing fordistributional analysis is precisely because it has the potential toprovide additional ‘protest capital’ and ameans of galvinising resistance.This was clearly the intention in Friends of the Earthworkingwith localgroups affected by theHeathrowexpansion plan to force the productionof an EqIA that did indeed show that local negative impacts would be

focused on the minority ethnic community and particularly vulnerablesubgroups. Intense arguments were as a consequence generated, asnoted in the government's decision statement (Department forTransport, 2009b). Furthermore, in such contexts, it may well be thatmitigation measures or the provision of compensation are notwelcomed but rather seen as insufficient and inappropriate, serving toantagonize rather than ameliorate resistance. Certainly this has beensomeof the experience of thewindenergy industry in theUK,where theattempted negotiation of ‘benefit packages’ for local communities hasbecome commonplace, but local public reactions have sometimes beenadverse with accusations of bribery and attempts to ‘pay off theopposition’ (Cass et al., 2009). In the US also various commentators andactivists have been critical of how the EPA have interpreted theirlegislative obligations and responded to the identification of environ-mental justice communities through superficial attempts at mitigationand community participation (Murphy-Greene and Leip, 2002; Bullardet al., 2007). Holifield (2004: 286), for example, argues that the EPA'sincorporation of environmental justice has become part of a widerneoliberal agenda in which, instead of efforts to redistribute risk morejustly, the emphasis has been simply on ‘mechanisms for building trustand managing political activity’.

Second, it is necessary to problematise the notion that producingevidence on distributional patterns is simply about establishing ‘thefacts’ of the situation. Evidence within any form of impact assessment isconstructed and produced, with the attendant selections, contingenciesand uncertainties this entails (Lawrence, 2000). As Shrader-Frechette(2002: 194) comments in the context of environmental justice disputes‘facts alone never determine all aspects of a situation. Facts are alwaysincomplete and saddledwith implicit interpretations’. Establishingwhogets what in terms of benefits and burdens, and who is more or lessvulnerable to harm, typically calls for some form of measurement,analysis and comparison. However there are many methodologicalcomplexities involved in undertaking a statistical analysis of environ-mental inequalities. Many studies analyse distributions in spatial terms,a geographic approach using the technology of Geographical Informa-tion Systems (GIS)which conceptualises the impact of the environmenton health and well being typically in terms of where people live and insome studies where children go to school (Sexton et al., 2000). Thisbrings into play complexities related to the adequacy and comparabilityof the areal units for which data is available, the type of spatial relationthat is conceived between people and environmental phenomenon andthe scale at which analysis is undertaken (Liu, 2001). Such methodo-logical complexities have been examined and debated at length in theenvironmental justice literature (e.g. Brown, 1995; Weinberg, 1998b;Most et al., 2004; Buzzelli, 2007) and are summarised in Table 2.

The fact that methodological decisions have to be taken means thatthere is great scope for critique and disagreement about whatconstitutes a ‘good’ or sufficiently robust analysis (however thosecriteria are defined). Bowen (2002) for example undertook a systematicanalysis of 42 environmental justice studies in the US, identifying asignificant number as ‘poor quality’ which had:

“… substantial enough flaws to be judged useless in terms ofcontributing anything to scientific knowledge, and… the studyconclusions should therefore not be considered as having any meritwhatsoever for public policy and management decisions” (ibid: 3)

In such a light it is clear that the evidence produced on patterns ofsocial distribution may itself become the focus for contestation aroundthe way it has been undertaken, and therefore the outcomes that havebeen produced. This has been the case in the US where sometimesintense debates have opened up around the methodologies used tomake environmental justice assessments in particular cases (Weinberg,1998a; Mohai and Saha, 2006) and legal challenges have also beeninvolved.

Table 2Methodological complexities in GIS based environmental inequality studies.

Category Explanation

Selection of studypopulation

What is to be the population under study, in terms of itsrelevant socio-demographic or cultural characteristics, andits boundaries?

Impact on health orwell being

What is the assumed relationship between environmentalparameter and good or bad impacts on people living inparticular areas?

Data availability andquality

What environmental and social data is available, how goodis the coverage, how is it sampled, what reliability issues arethere, does it directly measure what is of concern or provideonly a proxy or surrogate?

Spatial analysis What spatial units are to be used for aggregating social dataand by what method(s) is the association between peopleand environmental phenomenon to be analysed?

Comparison areas What areas are to be used to make comparisons thatdetermine the extent to which patterns and associations aresignificantly different or disproportionate?

Statistical methods What methods are to be used to establish the statisticalsignificance of patterns of spatial association between socialand environmental variables?

317G. Walker / Environmental Impact Assessment Review 30 (2010) 312–318

Third, a related but distinct point relates to the expert mode ofknowledge production that is inherent to established impactassessment processes. For environmental justice advocates thisprocess itself can be problematic and open to challenge, bringingquestions of process and procedural justice into close connection withthe distributional (Stephens et al., 2001; Schlosberg, 2007). Foreman(1998) argues in a US context that environmental justice activism haschallenged technocratic ways of thinking that rely on the tools ofpositivist methodology to the point that ‘activists and angrycommunity residents are disinclined to allow epidemiologists,toxicologists and statisticians to define the premises of theirmovement’ (ibid: 29). Bryant (1995) and Delemos (2006) makesimilar arguments in calling for participatory approaches to researchdesign which can at least place the tools of scientific analysis within aless top down and expert-determined process. Participatory methodshave been argued to improve the quality of distributional analysis thatcan be undertaken with interaction between different forms ofknowledge (Grineski, 2006). Lay epidemiology, carried out by localpeople and drawing on their knowledge of patterns of illness anddisease rather than only on collected health statistics, has been apowerful approach in particular cases (Corburn, 2002, 2003).

Fourth, there is the necessary distinction to be made between theproduction of evidence of patterns of distribution and the evaluation ofthis evidence as a matter of justice or injustice. There is a very longintellectual tradition which ably demonstrates that expecting universalagreement on what constitutes justice and injustice is deeply problem-atic. What is unequal will not be considered always and everywhereundesirable, bad, unfair or unjust. Some form of judgement or claimneeds to be made about the severity, consequences or morality of theinequality and such judgements or claims will be and often are open tocontest and challenge by those with different perspectives and values.There have been various attempts to apply different forms of justicetheory to environment questions, to define what makes a situation andan inequality unjust — with distinctions made between justice in andjustice to the environment (Low and Gleeson, 1998), between differentconcepts of distributional justice (Dobson, 1988; Bell, 2004) andbetween deontological (process) and consequentialist (outcome)modes of reasoning (Ikeme, 2003). Schlosberg (2007) emphasizes theplurality involved arguing that “justice is a concept with multipleintegrated meanings”, that there are overlapping circles of concern andcomplex equalities involving interconnected forms of reasoning andjudgement. Such a view of justice finds necessary diversity in the criteriaof distribution to be applied as ‘there are many different social goods(and evils) whose distribution is a matter of justice, with each kind of

good having its own particular criterion of distribution’ (Miller, 1995: 2),an argument readily applied to the wide array of environmental goodsand bads that are at issue.

The implication is therefore that even where an analysis ofdistributional patterns is not controversial methodologically i.e. theevidence itself is not challenged, this does not mean that conflict willnot still materialize around how this evidence is interpreted andevaluated. As Harvey (1996) emphasizes justice concepts as politicallyand strategically deployed in environmental justice contests will notbe absolute and universal given that “Different groups resort todifferent conceptions of justice to bolster their position” (ibid; 398).Various case studies of siting conflicts have accordingly shown howstrategic actions are involved in actors constructing, adapting andshifting the nature and focus of justice arguments (Kurtz, 2002;Shrader-Frechette, 2002; Davies, 2006). Under such analysis theevidence of distributional impacts produced as part of an impactassessment process becomes simply another resource to be utilized,framed and positioned within the strategic interactions of differentactors, rather than something that inherently will promote dialogueand negotiation.

6. Conclusion

It has been shown that in the UK attention is only rarely given to thesocial distribution of environmental outcomes in impact assessmentprocesses. This is partly because of the limited profile of methods thathave become institutionally embedded in the UK, with SIA wellpositioned to address distributional issues but excluded from the UKprofile; but also because of the ways in which the better recognisedassessment methods, such as EIA and SEA, have been implemented.Consequently who is to benefit and who is to be burdened as a result ofproject, plan and programme decisions, are rarely explicitly analysed inenvironmental terms. There are strong arguments however thatdistributional or environmental justice concerns do matter and thatthese should be an explicit part of impact assessment processes.Perhaps most convincingly these arguments centre on the need topursue values that protect the most vulnerable and that ensure thatdisadvantaged and politically marginalised social groups are notsystematically burdened in environmental terms (Connelly andRichard-son, 2005). The consequences of a move in this direction, through SEA,EqIA, SIA or other forms of impact assessment, could potentially be toproductively inform decision making processes, such that impacts onparticular groups or communities are identified and addressed throughthe choice of alternatives, mitigation, negotiated agreements orcompensation measures. In this way conflicts focused on the injusticeof outcomes for different parties potentially might be reduced orameliorated.

It has though been argued that such outcomes will not necessarilyor unproblematically flow from simply making impact assessmentmore sensitive to questions of social difference. Rather, givingattention to questions of distribution may serve to sustain or generateconflict around environmental decisions — because hidden patterns ofdisproportionate impact on particular groups may be revealed andbecome politicised; because evidence of distributions is not uncon-troversial either in the methods or in the processes of its production;and most fundamentally because there can be quite differentinterpretations of ‘what is just’ embedded in different values andunderstandings of what is at stake. Such possibilities make it clear, asmany others have argued, that environmental decision making is notjust a technocratic process, there is an inevitable normative politicsinvolved. Incorporating distributional analysis of winners and losers,benefits and burdens, might make a key part of this normative politicsmore explicit, but in so doing the result may be to emphasise differenceand disagreement rather than enable negotiation and consensusbuilding.

318 G. Walker / Environmental Impact Assessment Review 30 (2010) 312–318

References

Ahmad B, Pless-Mulloli T, Vizard C. HIA and pollution prevention control: what they canlearn from each other. Environ Impact Assess Rev 2005;25:714–22.

Bell D. Environmental justice and Rawls' difference principle. Environ Ethics 2004;26:287–306.

Bowen W. An analytical review of environmental justice research: what do we reallyknow? Environ Manage 2002;29:3-15.

Brown P. Race, class, and environmental-health — a review and systematization of theliterature. Environ Res 1995;69:15–30.

Bryant B. Pollution prevention and participatory research as a methodology forenvironmental justice. VA Environ Law J 1995;14:589–611.

Buchan D. Involving communities: buy-in and social capital: by-products of socialimpact assessment. Impact Assess Proj Apprais 2003;21:168–72.

Bulkeley H, Walker G. Environmental justice: a new agenda for the UK. Local Environ2005;10:329–32.

Bullard RD. Dismantling environmental racism in the USA. Local Environ 1999;4:5-19.Bullard R, Mohai P, Saha R, Wright B. Toxic wastes and race at twenty: 1987–2007.

Cleveland OH: United Church of Christ; 2007.Burdge RJ. The practice of social impact assessment background. Impact Assess Proj

Apprais 2003;21:84–8.Burdge RJ. The focus of impact assessment (and IAIA) must now shift to global climate

change. Environ Impact Assess Rev 2008;28:618–22.Buzzelli M. Bourdieu does environmental justice? Probing the linkages between

population health and air pollution epidemiology. Health Place 2007;13:3-13.Byrne J, Glover L, Martinez C, editors. Environmental justice: discourses in international

political economy. New Brunswick NJ: Transaction Publishers; 2002.Capek SM. The “environmental justice” frame: a conceptual discussion and an

application. Soc Probl 1993;40:5-24.Cass N, Walker G, Devine-Wright P. The purposes, perceptions and politics of community

benefits: Views of stakeholders in renewable energy project development andapproval, Paper presented at workshop on Ownership and stakeholding in the windenergy debate: A mechanism for social mobilisation, social acceptance or socialjustice?. Cardiff University; 2009. Feb.

Chadwick A. Socio-economic impacts: are they still the poor relations in UKenvironmental statements? J Environ Plann Man 2002;45:3-24.

Connelly S, Richardson T. Value-driven SEA: time for an environmental justiceperspective. Environ Impact Assess Rev 2005;25:391–409.

Corburn J. Environmental justice, local knowledge, and risk: thediscourse of a community-based cumulative exposure assessment. Environ Manage 2002;29:451–66.

Corburn J. Bringing local knowledge into environmental decision making: improvingurban planning for communities at risk. J Plann Educ Res 2003;22:420.

Davies AR. Environmental justice as subtext or omission: examining discourses ofanti-incineration campaigning in Ireland. Geoforum 2006;37:708.

Delemos JL. Community-based participatory research: changing scientific practice fromresearch on communities to research with and for communities. Local Environ2006;11:329–38.

Department for Transport. Adding capacity at Heathrow airport: equality impactassessment. London: Department for Transport; 2009a.

Department for Transport. Britain's transport infrastructure adding capacity at Heathrow:decisions following consultation. London: Department for Transport; 2009b.

Dobson A. Justice and the environment: conceptions of environmental sustainabilityand dimensions of social justice. Oxford: Oxford University Press; 1988.

Dodds L, Hopwood B. BAN waste, environmental justice and citizen participation inpolicy setting. Local Environ 2006;11:269–86.

Environmental Protection Agency. Final guidance for incorporating environmental justiceconcerns in EPA's NEPA compliance analyses. Washington DC: US EPA; 1998.

Field P, Raiffa H, Susskind L. Risk and justice: rethinking the concept of compensation.Ann Am Acad Polit SS 1996;545:156–64.

Foreman CH. The promise and perils of environmental justice. Washington DC:Brookings Institution Press; 1998.

Friends of the Earth Scotland. Love thy neighbour? The potential for good neighbouragreements in Scotland. Edinburgh: Friends of the Earth Scotland; 2004a.

Friends of the Earth Scotland. Strategic environmental assessment consultation onproposed legislative measures to introduce strategic environmental assessment inScotland: response from Friends of the Earth Scotland. Edinburgh: Friends of theEarth Scotland; 2004b.

Glasson J, Heaney D. Socioeconomic impacts: the poor relations in British environmentalimpact statements. J Environ Plann Man 1993;36:335–43.

Grimes M. Democracy's infrastructure: the role of procedural fairness in fosteringconsent. Goteborg: Goteborg University; 2005.

Grineski SE. Local struggles for environmental justice: activating knowledge for change.J Poverty 2006;10:25.

Harrop DO. Air quality assessment. In: Petts J, editor. Handbook of environmentalimpact assessment, vol.1. Oxford: Wiley-Blackwell; 1999.

Harvey D. Justice, nature and the geography of difference. Oxford: Blackwell; 1996.Holifield R. Neoliberalism and environmental justice in the United States environmental

protection agency: translating policy into managerial practice in hazardous wasteremediation. Geoforum 2004;35:285–97.

Ikeme J. Equity, environmental justice and sustainability: incomplete approaches inclimate change politics. Global Environ Change 2003;13:195–206.

Illsley BM. Good neighbour agreements: the first step to environmental justice? LocalEnviron 2002;7:69–79.

Jackson T, Illsley B. Strategic environmental assessment as a tool of environmentalgovernance: Scotland's extension of the European Union SEA directive. J EnvironPlann Man 2006;49:361–83.

Jackson T, Illsley B. An analysis of the theoretical rationale for using strategicenvironmental assessment to deliver environmental justice in the light of theScottish Environmental Assessment Act. Environ Impact Assess Rev 2007;27:607–23.

Johnson C, Penning-Rowsell E, Parker D. Natural and imposed injustices: the challenges inimplementing “fair”floodriskmanagementpolicy inEngland.Geogr J 2007;173:374–90.

Kurtz HE. The politics of environmental justice as the politics of scale: St James Parish,Louisiana and the Shintech siting controversy. In: Herod A, Wright M, editors.Geographies of Power: Placing Scale. Oxford: Blackwell; 2002.

Lawrence DP. Planning theories and environmental impact assessment. Environ ImpactAssess Rev 2000;20:607–25.

Lesbirel SH, Shaw D, editors. Managing conflict in facility siting. Cheltenham: EdwardElgar; 2005.

Lewis S, Henkels D. Good neighbor agreements: a tool for social and environmentaljustice. In: Williams C, editor. Environmental Victims. London: Earthscan; 1998.

Liu F. Environmental justice analysis: theories, methods and practice. Boca Raton: LewisPublishers; 2001.

Low N, Gleeson B. Justice, society and nature: an exploration of political ecology.London: Routledge; 1998.

Miller D. Equality in post-modern times. In: Miller D, Walzer M, editors. Pluralism,justice and equality. New York: Oxford University Press; 1995.

Mitchell G. Forecasting environmental equity: air quality responses to road usercharging in Leeds. J Environ Manage 2005;77:212–6.

Mohai P, Saha R. Reassessing racial and socioeconomic disparities in environmentaljustice research. Demography 2006;43:383.

Most MT, Sengupta R, Burgener MA. Spatial scale and population assignment choices inenvironmental justice analyses. Prof Geogr 2004;56:574.

Murphy-Greene C, Leip LA. Assessing the effectiveness of executive order 12898:environmental justice for all? Public Admin Rev 2002;62:679–87.

New Economics Foundation. Tackling climate change, reducing poverty: the first reportof the roundtable on climate change and poverty in the UK. London: NewEconomics Foundation; 2009.

Nieves LA, Himmelberger JA, Ratick SJ, White AL. Negotiated compensation for solid-waste disposal facility siting: an analysis of the Wisconsin experience. Risk Anal2006;12:505–11.

Office of the Inspector General. EPA needs to consistently implement the intent of theExecutive Order on Environmental Justice: Report No. 2004-P-00007. WashingtonDC: US Environmental Protection Agency; 2004.

Scandrett E. Environmental justice in Scotland: policy, pedagogy and praxis. EnvironRes Lett 2007:045002.

Scandrett E, Dunion K, McBride G. The campaign for environmental justice in Scotland.Routledge 2000:467–74.

Schlosberg D. Defining environmental justice: theories, movements and nature.Oxford: Oxford University Press; 2007.

Schroeder R, Martin KS, Wilson B, Sen D. Third world environmental justice. Soc NatResour 2008;21:547–55.

Schweitzer L, Valenzuela Jr A. Environmental injustice and transportation: the claimsand the evidence. J Plann Lit 2004;18:383.

Sexton K, Greaves IA, Church TR, Adgate JL, Ramachandran G, Tweedie RL, et al. Aschool-based strategy to assess children's environmental exposures and relatedhealth effects in economically disadvantaged urban neighborhoods. J Expo AnalEnviron Epid 2000;10:682–94.

Shrader-Frechette K. Environmental justice: creating equality, reclaiming democracy.New York: Oxford University Press; 2002.

Stephens C, Bullock S, Scott A. Environmental justice: rights and means to a healthyenvironment for all. Swindon: ESRC Global Environmental Change Programme; 2001.

Sze J, London JK. Environmental justice at the crossroads. Sociol Compass 2008;2:1331–54.Taylor DE. The rise of the environmental justice paradigm: injustice framing and the

social construction of environmental discourses. Am Behav Sci 2000:508–80.US Department of Transportation Federal Highway Administration. Transportation and

Environmental Justice Case Studies, Report No. FHWA-EP-01 010. Washington DC:Federal Highway Administration; 2000.

US Environmental Protection Agency Office of Environmental Justice. IntegratedFederal Interagency Environmental Justice Action Agenda. Washington DC: USEnvironmental Protection Agency; 2000.

Vanclay F. Social impact assessment. In: Petts J, editor. Handbook of environmentalimpact assessment, vol. 1. Oxford: Wiley-Blackwell; 1999.

Vanclay F. Principles for social impact assessment: a critical comparison between theinternational and US documents. Environ Impact Assess Rev 2006;26:3-14.

Walker GP. Environmental justice and the distributional deficit in policy appraisal inthe UK. Environ Res Lett 2007:045004.

Walker G. Globalising environmental justice: the geography and politics of framecontextualisation and evolution. Global Soc Issues 2009;9(3):355–82.

Walker G, Bulkeley H. Geographies of environmental justice. Geoforum 2006;37:655–9.Walker GP, Fay H, Mitchell G. Environmental justice impact assessment: an evaluation

of requirements and tools for distributional analysis. London: Friends of the EarthEngland and Wales; 2005.

Watson M, Bulkeley H. Just waste? Municipal waste management and the politics ofenvironmental justice. Local Environ 2005;10:411–26.

Weinberg AS. The environmental justice debate: a commentary on methodologicalissues and practical concerns. Sociol Forum 1998a;13:25–32.

Weinberg AS. The environmental justice debate: new agendas for a third generation ofresearch. Soc Nat Res 1998b;11:605–14.

Wells VL, Gillham KE, Licata M, Kempton AM. An equity-focused social impact assessmentof theLowerHunterRegional Strategy.NSWPublicHealthBull 2007;18(9–10):166–8.

Wolsink M. Wind power implementation: the nature of public attitudes: equity andfairness instead of ‘backyard motives’. Renew Sust Energ Rev 2007;11:1188–207.