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ELSEVIER ORGANIZATIONAL CHANGE AND ENVIRONMENTAL IMPACT ASSESSMENT AT THE ELECTRICITY GENERATING AUTHORITY OF THAILAND: 1972-1988 Anne Shepherd Georgia Institute of Technology Leonard Ortolano Stanford University This study examines the influence of leadership, political entrepreneurship, and organizational change on the institutionalization of environmental impact assessment (EIA). The Electricity Generating Authority of Thailand (EGAT) initiated EIA activities earlier and more comprehensively than most developing countries. How and why were EIA activities pursued? Part of the explanation for EGAT’s EIA activities involves external controls exerted by the World Bank, the Thai government, and concerned citizens. However, an explanation based on external factors alone overlooks the significant influence of internal forces and entrepreneurial activities within EGAT. Our analysis of EIA adop- tion at EGAT reveals three factors that can contribute to the successful imple- mentation of EIA: (I) mutually reinforcing support for EIA from both inside and outside a development agency, (2) political entrepreneurship by agency staff that are concerned about the environment and (3) the transformation of power relationships within the agency by environmentalprofessionals. 0 1997 Elsevier Science Inc. Introduction Environmental impact assessment (EIA) is required in more than half the countries of the world. However, in the early 197Os, relatively few devel- oping countries had any form of EIA program. It was during this time that Address requestsfor reprintsto: Professor Anne Shepherd, City Planning Program, Georgia Institute of Technology, Atlanta, GA 30332-0155. ENVIRON IMPACT ASSESS REV 1997;17:329-356 0 1997 Elsevier Science Inc. All rights reserved. 655 Avenue of the Americas, New York, NY 10010 0195.9255/97/$17.00 PI1 SO195-9255(97)00025-5

Organizational change and environmental impact assessment at the electricity generating authority of Thailand: 1972–1988

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Page 1: Organizational change and environmental impact assessment at the electricity generating authority of Thailand: 1972–1988

ELSEVIER

ORGANIZATIONAL CHANGE AND ENVIRONMENTAL IMPACT ASSESSMENT AT THE ELECTRICITY GENERATING AUTHORITY OF THAILAND: 1972-1988

Anne Shepherd Georgia Institute of Technology

Leonard Ortolano Stanford University

This study examines the influence of leadership, political entrepreneurship, and organizational change on the institutionalization of environmental impact assessment (EIA). The Electricity Generating Authority of Thailand (EGAT) initiated EIA activities earlier and more comprehensively than most developing countries. How and why were EIA activities pursued? Part of the explanation for EGAT’s EIA activities involves external controls exerted by the World Bank, the Thai government, and concerned citizens. However, an explanation based on external factors alone overlooks the significant influence of internal forces and entrepreneurial activities within EGAT. Our analysis of EIA adop- tion at EGAT reveals three factors that can contribute to the successful imple- mentation of EIA: (I) mutually reinforcing support for EIA from both inside and outside a development agency, (2) political entrepreneurship by agency staff that are concerned about the environment and (3) the transformation of power relationships within the agency by environmentalprofessionals. 0 1997 Elsevier Science Inc.

Introduction

Environmental impact assessment (EIA) is required in more than half the countries of the world. However, in the early 197Os, relatively few devel- oping countries had any form of EIA program. It was during this time that

Address requests for reprints to: Professor Anne Shepherd, City Planning Program, Georgia Institute of Technology, Atlanta, GA 30332-0155.

ENVIRON IMPACT ASSESS REV 1997;17:329-356 0 1997 Elsevier Science Inc. All rights reserved. 655 Avenue of the Americas, New York, NY 10010

0195.9255/97/$17.00 PI1 SO195-9255(97)00025-5

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330 ANNE SHEPHERD AND LEONARD ORTOLANO

the Electricity Generating Authority of Thailand (EGAT)’ initiated EIA activities, even before the Thai government established EIA requirements.

We examine how and why EIA procedures were actively incorporated into the planning process at EGAT. To do this, we investigate the opportu- nities and pressures for EGAT to conduct EIAs, and we examine the organizational changes that occurred. Our analysis of EIA activities at EGAT considers both internal forces within EGAT, and external forces exerted by project lenders, the Thai government, and concerned citizens. The internal forces reflect what Wandesforde-Smith and Kerbavaz (1988) refer to as political entrepreneurship: individuals who use opportunities to combine resources, political circumstances, and their skill in relating the two, to bargain more effectively than others and thus to shape the evolution of policy.2 There is little question that EIA activities flourished at EGAT due to entrepreneurial leadership. The importance of leadership is also demonstrated by the diminution of EIA’s stature at EGAT after EIA’s principal supporters left the scene.

We first develop a theoretical framework for analyzing organizational forces related to EIA implementation at EGAT. This is based on several prior studies of EIA and organizational change. Next, we examine the development of the EIA system within Thailand and EGAT, focusing on the period from 1972, when EGAT conducted its first EIA, to 1988, when EGAT’s environmental unit appeared to lose its influence. Then we analyze how entrepreneurial activities and organizational changes influenced EIA implementation at EGAT. Two case studies, Srinagarind hydropower and Mae Moh lignite mining and thermal power, illustrate the forces that influ- enced EIA studies. We analyze how and why EIA was adopted at EGAT, and we suggest several implications for successful insitutionalization of EIA.

Framework for Analysis

Our framework for analyzing organizational change at EGAT is based on prior studies of the forces that shape the implementation of environmental programs and policies. We relied heavily on the literature that links organi- zational theory and environmental impact assessment, which is high- lighted below.

Taylor (1984), in his analysis of U.S. natural resource development agen- cies, suggests that EIA is institutionalized through a dual system of support from inside and outside an organization. He distinguishes between “insid-

‘The Electricity Generating Authority of Thailand is a state enterprise, created in 1969, for generating, acquiring. and distributing electric power. It also engages in the production and sale of lignite and lignite by-products. EGAT is regarded as one of the most well-managed Thai state enterprises, winning recognition by both the Thai people and international agencies (World Bank 1982). EGAT’s operating efficiency “can be favorably compared with most of the better run utilities in the developing world” (World Bank 1982, p. 14).

?As demonstrated by Wandesforde-Smith and Kerbavaz (1988, p. 161), entrepreneurship has been an important factor in the evolution of EIA at the federal level in the United States and in California.

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ers,” environmental analysts on the staff of the agency proposing develop- ment projects, and “outsiders,” particularly environmental non-governmen- tal organizations (NGOs) and other agencies with environmental protection responsibilities. This dual system is the basis of Taylor’s redundancy hypoth- esis: the EIA process works because insiders and outsiders, together, are more reliable than either one alone (Taylor 1984, p. 262). Similarly, Taylor’s mutual dependency hypothesis suggests that insiders and outsiders can find ways of exchanging what each has, in return for what the other lacks (Taylor 1984, pp. 2.59-261). For example, insiders (the agency’s environmental ana- lysts) can provide information to outsiders (NGOs and other agencies), which enables the outsiders to expose environmentally deficient projects and to demand more careful analyses in the agency’s environmental impact statements. This, in turn, helps the insiders to promote environmentally sensitive decision-making. Taylor also notes that informal incentives and relationships, if they receive institutionalized support and reinforcement, can be a more powerful impetus for coordination than formal rules and responsibilities. Taylor’s study leads to four conditions for successful adop- tion of EIA: a group inside the organization committed to environmental values, clear goals held by insiders that provide guidance for their actions, autonomy and power for the inside group so that they can protect the environmental values and outside support for the inside group’s goals.

Ortolano (1993) examines relationships between the effectiveness of EIA and the existence of organizational controls. An organizational control is an external or internal force that motivates project proponents to conduct EIAs. Examples of controls include: procedural control (national EIA requirements); development aid agency control (a lending institution re- quires an EIA before it funds a project); professional control (environmen- tal analysts’ professional standards lead them to conduct an EIA); and direct public control (citizens apply pressure on project proponents to incorporate environmental concern in their decisions).

Wandesforde-Smith and Kerbavaz (1988) investigate the entrepreneurial origins of changes in environmental policy. They point to the importance of an individual-a political entrepreneur-who seizes opportunities, takes risks, and uses available resources and political circumstances to implement environmental policy.3 This individual forges the relationships between

‘Political entrepreneurship, as used by Wandesforde-Smith and Kerbavaz, is related to what the organiza- tional change literature refers to as organizational leadership. Organizational leadership is defined by Brian (1989, p. 895) as “the art-science of managing the technical, leading the social, and melding the two in such a way as to integrate organizational and individual ends and means that will optimize their utilization toward the organization’s purposes.” Research on organizational leadership has focused principally on understanding what characteristics leaders exhibit (the traits) and apply to the organization (the situation). The traits include: personality skills, behavior. The situation includes: structures and processes (the manage- ment system) and interpersonal relationships (leadership behavior). The reader is referred to Argyris (1964), Brian (1989), Etzoni (1961), Guest, Hersey, and Blanchard (1986) for perspectives and theories on organizational leadership.

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332 ANNE SHEPHERD AND LEONARD ORTOLANO

actors in the EIA process that, according to Taylor (1984) can be a more powerful force in EIA than formal rules. The findings of Wandesforde- Smith and Kerbavaz debunk “a central tenet of the EIA literature that impact analysts, and even assessment project managers and authors of manuals and guidelines, have no entrepreneurial function” (1988, p. 191). They maintain that “[wlithout the enthusiasm, initiative, and drive of entre- preneurial actors in the political system there is no engine to turn the wheels of analytical competition that Taylor identifies as the primary cause of the development of EIA” (1988, pp. 165-166).

Gariepy and Henault (1994) studied the evolution of EIA activities in two major development agencies in Quebec. They found that an organiza- tion will use opportunities that confront it to try to maintain or enlarge its sphere of influence. EIA is one such opportunity. Within the EIA process, various actors of an organization will evolve strategies to adapt to obstacles, to improve their performance in subsequent projects and to make the setting of EIA for future projects more predictable.

The work of Crozier and Friedberg (1977) is particularly instructive in its examination of the interplay between power relationships and organiza- tional change. They suggest that power relationships are the causes of change, the obstacles to change and the ends of change. Power is an indis- pensable preprequisite to action, and no change is possible without trans- forming the existing system of power (Crozier and Friedberg 1977, p. 247). New relations of power require the development of collective capacities: a greater number persons must be allowed to “join in the game” and be granted greater autonomy and power (Crozier and Friedberg 1977, pp. 248-249).

Mazmanian and Nienaber (1979) examined organizational changes in a large U.S. federal agency in response to EIA requirements. They proposed that the cycle of organizational change begins when external groups, or others who are important to an agency, voice new demands. Some insiders will become sensitive to the need for change, and some may see the need for substantial overhaul of practices or programs. To adopt new missions, an agency’s traditional patterns of behavior must be modified. Reorganiza- tion is used to accomplish this by disrupting the established chain of com- mand, status ordering, and communications patterns. A new equilibrium is established that requires a process of mutual accommodation between an agency and the public (Mazmanian and Nienaber 1979, pp. 191-194).

From the above-noted studies, we identify three main factors that can promote EIA implementation in an organization: (1) a mutually reinforcing system of internal and external support for environmental values in general and EIA in particular; (2) one or more political entrepreneurs within the organization who see advantages in seizing opportunities to implement environmental policy; and (3) internal environmental advocates who are able to enlarge their influence and thereby transform existing intra-agency

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power relationships to accommodate new environmental requirements. These factors provided our framework for analyzing the EIA activities at EGAT.

Our study of EGAT rests on two different forms of data: documentary evidence related to EIA activities within EGT and interviews with approxi- mately 75 people familiar with internal operations of EGAT during the study period (1972-1988).4 By their nature, interview data are subjective. To improve reliability we used multiple sources of information to resolve discrepancies in facts and interpretations and to suggest alternative explana- tions of observed outcomes. Such analyses are, by necessity, subjective, but our hope is to stimulate interest in what we view as an important and understudied aspect of EIA: how internal and external forces affect the way an organization integrates environmental factors into planning and decision-making.

Evolution of EGAT’s Environmental Activities

Early Concern for Environmental Protection In the early 1970s many developing countries viewed environmental protec- tion as a concern of highly industrialized nations. The past 2 decades, however, have seen a significant reversal in this attitude. Many developing countries now have national programs to protect the environment.5 In addition, several development aid agencies now require EIA for projects they fund.

Thailand incorporated environmental factors into its national develop- ment program earlier and more comprehensively than most countries in the Asia-Pacific region (Tu 1993) (Table 1). In 1972, EGAT started the first environmental studies in Thailand. Two years later, Thailand’s national constitution, perhaps the most democratic in Thai history, established a commitment to environmental protection (Keyes 1987, p. 87). This constitu- tion contained several provisions for environmental protection, for exam- ple: to conserve the balance of environment and natural beauty, to keep the environment clean and eliminate pollution that jeopardizes human health and to ensure the principles of conservation when resources are exploited (The Royal Thai Government 1974, Chapter 5, Sections 77-79).

‘A case study protocol was carefully designed to perform the study. Data sources included: one-on- one interviews, correspondence, historical records, published and unpublished reports, and numerous consultations with citizens, Thai agency staff, and other experts. An extensive set of interviews were conducted by our colleague, Dr. Shih-Liang Tu, over a period of 6 years (1987-1992) with approximately 75 people: 20 in EGAT, 14 in Thai agencies, 13 in international lending agencies, 15 academics and 10 consultants in Thailand, and 3 in non-governmental organizations. Many of the references below to Tu (1993) are based on these interviews. Dr. Tu had intended to co-author this article, but he was not able to, as explained in the acknowledgments.

‘A study by Sammy (1982), as cited by Abracosa (1987, p. ll), showed that 54% of 72 developing countries surveyed had a legal requirement for the use of EIA on major projects, even though many of them simply copied their EIA laws from the developed countries.

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334 ANNE SHEPHERD AND LEONARD ORTOLANO

TABLE 1. Major Events in EIA Evolution in Thailand: 1972-1988

1972 1974 1974

1975

1978 1979 1981

EGAT started the first EIA in Thailand (Srinagarind Dam project). National Constitution established a commitment to environmental protection. Technological and Environmental Planning Division created under the National

Economic and Social Development Board (NESDB). Improvement and Conservation of National Environmental Quality Act

(NEQA) passed, establishing the National Environment Board (NEB), and the Office of National Environment Board (ONEB) as the executive arm of NEB.

NEQA amended. ONEB published a Manual of NEB guidelines for Preparation of EIA. National policy on environmental development was adopted; Thai government

issued first official notification of types and sizes of projects and activities which require EIA reports.

Spurred on by recommendations of the United Nations Conference on the Human Environment (UNCHE) Stockholm Declaration and the Asian Plan of Action (United Nations 1973) the Thai Government created a Technological and Environmental Planning Division under the National Economic and Social Development Board (NESDB) in 1974.‘j

This relatively early attention to environmental factors in Thailand can be attributed, in part, to Thai politics. Since 1932 Thailand has had a multi- party, coalition government under a constitutional monarch. Thai politics are characterized by different parties coming in and out of the coalition. Diversity in political statements and demands are incorporated readily into development policies. As we will see below, this Thai approach toward development also is reflected in the way that environmental institutions were accommodated in Thailand’s national development scene.

In 1975, the Thai government passed the Improvement and Conservation of National Environmental Quality Act (NEQA). This established the National Environment Board (NEB) as an advisory body in environmental affairs, and the Office of National Environment Board (ONEB) as the executive arm of NEB. A national program for EIA emerged in Thailand in response to policy mandates in the 1975 NEQA. The ONEB published a detailed Manual of NEB Guidelines for Preparation of EIA in April of 1979 (NEB 1979). In 1981, the Thai government issued its first official “notification” (in the government gazette) of the types and sizes of projects and activities that require EIA reports (NEB 1981). This marked the official adoption of EIA requirements by the Thai government. By 1988, over 2,000 environmental assessment documents had been filed with the government based on the 1981 notification (ONEB 1989).’

“For an overview of the Thai EIA program, see Yap (1994) and Tongcumpou and Harvey (1994). ‘Although our analysis considers events up to 1988, notable changes in EIA in Thailand have taken

place since then. A new environmental law was passed in 1992 (“The Enhancement and Conservation of Natural Environmental Quality Act”) that contained key provisions for: (1) the establishment of a well-

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EIA and Organizational Changes at EGAT

Initial efforts to develop EIA capabilities at EGAT preceded, and were independent of, the EIA initiatives of the Thai government. EIA first appeared at EGAT in 1972, when the organization conducted an unprece- dented ecological investigation of one of its major hydropower projects, the Srinagarind Dam (detailed below). This was in response to the request of the principal project lender, the World Bank. In 1974, EGAT appointed a Project Engineer to be in charge of EGAT’s environmental and ecological studies. In 1975, a new Ecological Evaluation Section was formally created under the Planning Division within the Planning Department (see Figure 1). At EGAT, the organizational hierarchy includes sections within divisions and divisions within departments. In tracing where EIA units were situated in EGAT, important shifts include changes between section and division status, changes between division and department status, and changes in the environmental unit’s access to EGAT’s top management. Table 2 provides an overview of the environmental unit’s evolution at EGAT; key items in the table are elaborated below.

In 1976, 1 year after the Ecological Evaluation Section was established in the Planning Division, the Section was expanded into the Environmental Division and moved from the Planning Department into the Public Commu- nications Office, which reported directly to EGAT’s General Manager (see Figure 2). (During the early 1980s the Public Communications Office was elevated to “department” status.) The new Environmental Division was responsible for all ecological and environmental studies associated with plans for new power plants and major expansions of existing plants, primar- ily hydropower and thermal power.

The Environmental Division’s 1976 move from the Planning Department to the Public Communications Office was significant, and may be interpreted in two ways. First, shifting environmental functions from the Planning Department to a nonsubstantive, public relations role in the Public Commu- nications Office could be viewed as a reduction in responsibilities for the environmental unit. This is because the Environmental Division was iso- lated from EGAT’s project planning and decision-making cycle. From this viewpoint, the environmental unit is seen primarily as a cosmetic, public relations unit, rather than an operational, action-oriented unit.

endowed environment fund, and (2) the revision of EIA procedures, including the authority to appoint expert committees to review EIAs. The expert committees have changed the nature of EIA review because now, for major EIAs, it is not just the government agency and the project proponent reviewing the EIA, but also a more independent panel of outside experts. The Office of the National Environment Board has been disbanded (although not under this new environmental law) and placed within a new ministry, called the Ministry of Science, Technology and Environment (MOSTE). The two main environmental units within MOSTE are: (1) the Office of Environmental Policy and Planning (OEPP), which is responsible for EIA review and supports the National Environment Board (NEB); and (2) the Pollution Control Department (PCD), which administers the environment fund and sets pollution control standards. NEB is still the primary political body for making environmental policy and management decisions, and it is headed by the Prime Minister (personal correspondence between the lead author and Greg Browder, April 15,1997).

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336 ANNE SHEPHERD AND LEONARD ORTOLANO

Chairman / Board of Directors

1 Genera: Manager 1

I I I

I

I --

FIGURE 1. Partial organizational structure of EGAT as of 1975 (Source: Annual Report, EGAT, 1976, as cited by Tu 1993).

A second, more plausible interpretation of the shift is that the creation of an Environmental Division in the Public Communications Office gave the environmental unit an elevation in status and a chance to improve itself. The Division could grow freely and independently within EGAT, with more direct access to power than it enjoyed in the Planning Department (see Figures 1 and 2). For example, the Director of the Environmental Division was able to access top management (the General Manager) without bureaucratic interference from management units concerned with thermal power and mining development or hydropower and transmission system development. In addition, because management may have viewed EIA as having a significant public relations component, the shift to the Public

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TABLE 2. Evolution of Environmental Units (and Somvonk’s Role) at EGAT: 1972-1988

1969

1972

1974

mid-1970s

1975

1976

1976

Early 1980s

1985

1987

1987

mid-1987

EGAT created. Somvonk was Chief of the Planning Division within the Planning Department.

Somvonk responded to the World Bank’s request to conduct an ecological study for the Srinagarind Dam.

EGAT appointed a project engineer (in the Planning Department) to be in charge of environmental studies.

Somvonk organized the Ecological Evaluation Section, using his authority as Chief of the Planning Division.

Ecological Evaluation Section was created in the Planning Division within the Planning Department; it was responsible for environmental studies.

Ecological Evaluation Section was expanded into the Environmental Division, and moved from the Planning Department to the Public Communications Office (reporting to the General Manager).

Somvonk was promoted as Head of the Public Communications Office (and, later, Director of the Public Communications Department). Somvonk brought the Environmental Division with him (out of the Planning Department) and built up the Environmental Division’s resources and EIA activities.

Public Communications Office was promoted to Department status (still re- porting directly to the General Manager).

Environmental Division was renamed Ecology and Environment Division, re- maining under the Public Communications Department.

Ecology and Environment Division was renamed Ecology and Environment Division, remaining under the Public Communications Department.

Ecology and Environment Division was moved out of the Public Communica- tions Department (renamed the Public Relations Department) and moved into the Survey and Ecology Department, (under Hydropower Development, several layers below the General Manager’s office).

Two successive General Managers that had supported Somvonk’s build-up of the Environmental Division retired. Somvonk’s support from top management diminished.

Communications Office would allow the environmental unit (composed of primarily technical personnel) to bolster EGAT’s public relations capa- bilities.

After the 1976 shift, the Environmental Division grew into a larger unit (from a staff size of less than 20 to over 70) with a highly regarded record of accomplishment (over 30 EIAs in 12 years) and a renowned professional reputation within Thailand. Between 1976 and 1987, the Environmental Division was charged with implementing EGAT’s ecological and environ- mental planning investigations as well as its environmental monitoring. Environmental studies were given considerable support by EGAT’s leaders in part because environmental assessment documents had good public rela- tions value. They helped promote EGAT’s image as a progressive, environ- mentally sensitive agency, well-positioned to respond to future government mandates for EIA.

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338 ANNE SHEPHERD AND LEONARD ORTOLANO

Other

/

Public Planning Departments Communications

OffkdDepartment Department

I

FIGURE 2. Partial organizational structure of EGAT between 1976 and 1987 (Source: Annual Reports, EGAT, as cited by Tu 1993).

Although top managers at EGAT viewed the Environmental Division’s work as “window dressing’@ intended to improve relations with those out- side of EGAT, the Division developed an internal agenda of its own. The Division’s experience in conducting sophisticated environmental studies led to introduce (in the mid-1980s) the Environmental Development Plan (EDP) for EGAT. The EDP required pre-construction, construction, oper- ation, and post-project evaluation EIA work for EGAT’s projects, and included: ecology and environment investigations, environmental impact mitigation plans, environmental monitoring, post-project environmental monitoring, post-project environmental mitigation plans and post-project environmental evaluations. Adoption of the EDP allowed EGAT to be viewed as an environmentally sensitive organization that was well-equipped to integrate environmental considerations into planning. Indeed, the Envi-

8Personal Interview, conducted by Shih-Liang Tu with EGAT’s former General Manager, Bangkok, September 20, 1988, as given in Tu (1993, p. 197).

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ronmental Division’s work was so highly regarded that the ONEB used EGAT as a model agency on several occasions.’

By the mid-1980s the Environmental Division had transformed itself from a cosmetic unit into a substantive, project-oriented division and a leader in EIA implementation among all Thai agencies. With the introduc- tion of EDP and other exercises of internal power, the Environmental Division succeeded in modifying existing rules and operating procedures at EGAT. Similarly, Mazmanian and Nienaber (1979, p. 192) note in their study of organizational changes within the U.S. Army Corps of Engineers that “the accumulation of rules and regulations must be modified if [an] organization is to change to an appreciable extent. Those persons seeking to change the organization must emancipate it from the web of rules and regulations that has enveloped it.” An indication of the Division’s growing influence is that other EGAT departments sometimes viewed its work as unwelcome “interference.“” As Crozier and Friedberg (1977, p. 249) sug- gest, new relations of power within an organization do not “naturally” come into existence following restructuring. Restrictive groups can “monopolize leadership functions by making access to such positions quite difficult.”

In 1987, EGAT went through another major restructuring, and the Ecol- ogy and Environment Division (the new name given to the Environmental Division in 198.5) was moved into the newly created Department of Survey and Ecology (see Figure 3). Afterward, the environmental unit was no longer an independent entity within EGAT; it was under one of the techni- cal functions, hydropower development. This left the environmental unit with less overall influence within EGAT than previously.

Comparison of EGAT’s Organizational Changes We can compare the expansion of environmental activities at EGAT to changes in two other large development agencies that have been studied carefully: the U.S. Army Corps of Engineers (Mazmanian and Nienaber 1979; Taylor 1984) and Hydro-Quebec in Canada (Gariepy and Henault 1994). While “hiring” environmental specialists is not the same as “lis- tening” to them (Taylor 1984, p. 6) these agencies both hired and listened: as illustrated below, the new environmental specialists went on to make substantive changes to institutionalize environmental concerns in planning and decision-making.

Faced with new environmental demands and societal pressures in the 1970s the U.S. Army Corps of Engineers expanded environmental activities

‘Such occasions included the ASEAN-UNEP Workshop on EIA for Water Resources Development Projects held at the Srinagarind Dam, Thailand, in February 15-20, 1981; and the Deutsche Stifung fur Internationale Entwicklung (DSE)-UNEP International Seminar on EIA for Development in Feldafing, Germany, April 9-12, 1984.

‘“As reported by Tu (1993, p. 200) based on his personal interviews with several officers in EGAT’s System Planning Department, Bangkok, September 1988.

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340

Other I I Departments

ANNE SHEPHERD AND LEONARD ORTOLANO

I I

1 Assistant General Other Assistant Manager of General Hydropower Development

Manager

Survey and Ecology Department

Other Departments

Ecology and Environment Division

FIGURE 3. Partial organizational structure of EGAT as of August 1988 (Source: Annual Report, EGAT, 1989, as cited by Tu 1993).

and changed its formal structure. The agency hired several hundred environ- mental professionals: in 1969 the agency had approximately 7.5 environmen- tal professionals; in 1977, 7 years after EIA requirements were adopted, the agency employed about 575 (Mazmanian and Nienaber 1979, p. 183). The Corps formed advisory boards of planning and environmental profes- sionals and representatives of interest groups and created environmental units in all district and division offices. In contrast to the period before 1970, these offices “now have a distinguishable unit whose primary purpose is to provide environmental input in the agency’s planning process” (Maz- manian and Nienaber 1979, p. 183).

Similarly, EIA-related activities also affected organizational structure and behavior at Hydro-Quebec. During the 1980s Hydro-Quebec faced substantial opposition to some of its proposed hydroelectric projects. As reported by Gariepy and Henault (1994), the organization responded to the opposition and to new EIA requirements by reorganizing and aug- menting EIA activities. EIA was integrated into the organization’s planning by: expanding programs of public participation, conducting EIA concurrent

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with other planning activities, co-opting project opponents by allowing them to participate in some decision processes and elevating the status of environmental activities within the organization. For instance, during the late 1970s EIA was introduced as a project planning task at Hydro-Quebec. By the early 1990s EIA’s status was much enhanced; indeed a full vice presidency focused on “environment” and on integrating EIA into cen- tral planning.

EGAT’s environmental unit’s growth, elevation, and subsequent decline during 1972-1988 are linked closely to the leadership activities of a key individual and to the support he received from two successive General Managers. The influence of leadership and political entrepreneurship on environmental work at EGAT is examined below.

Changes in the Influence of EIA at EGAT

The Rise of Somvonk’s Environmental Unit at EGAT The origins of EIA at EGAT are found in the organization’s response to the World Bank’s call, in 1972, for an ecological investigation of the proposed Srinagarind Dam, a major hydropower project. Mr. Somvonk Poshyananda, a British-trained electrical engineer, helped to initiate EIA activities within EGAT.” When EGAT was created in 1969, Somvonk was Chief of the Planning Division within the Planning Department (see Table 2). The World Bank’s request to conduct an ecological study for the Srinagarind Dam provided Somvonk with an opportunity to make EIA an integral part of EGAT. Somvonk was designated by EGAT to manage preparation of the study which later would be widely recognized as the first of its kind in Thailand.12 In addition to being outspoken on the need for ecological studies for EGAT’s projects, Somvonk, using the authority of his position as Chief of the Planning Division, was responsible for organizing the Ecological Evaluation Section in the mid-1970s.13

Somvonk exemplifies what Wandesforde-Smith and Kerbavaz (1988) call a political entrepreneur: one who recognizes opportunities, takes initiatives and risks and is able to organize internal resources to effect organizational changes. Somvonk waged a spirited campaign in the mid-1970s to convince EGAT’s top management of the importance of ecological studies. He did so by “first impressing the third party [that is, the World Bank] with the work quality of [his] staff before trying to convince EGAT’s management of the importance of environmental works, or the fact that EGAT was

‘I Correspondence between Shih-Liang Tu and the Principal Investigator, Cowater International (a Cana- dian consulting firm), for the 1972 Srinagarind Dam Ecological Reconnaissance, November 24, 1992.

“Personal interview, conducted by Shih-tiang Tu with EGAT’s Deputy General Manager of Hydropower and Transmission System Development, Bangkok, August 9, 1988, as reported in Tu (1993, p. 200).

“Personal interview, conducted by Shih-Liang Tu with a staff member of EGAT’s Ecological and Environmental Division, and with officers in EGAT’s System Planning Department, Bangkok, August, 1988, as reported in Tu (1993, p. ZOO).

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already doing a good job.“14 This approach is consistent with observations made by Taylor’s analysis of changes in agencies in response to the federal EIA program in the United States. Taylor (1984, p. 126) notes that, “[envi- ronmental] analysts gain greater influence when the top leadership favors environmental values . . . and when outsiders with political influence and analytical sophistication pay attention to the agency’s environmental choices.”

Somvonk was promoted in 1976 to Head of the Public Communications Office (and later Director of the Public Communications Department) reporting directly to the General Manager. When he moved to his new post, Somvonk brought the Environmental Division with him (out of the Planning Department) and actively built up the Division’s professional staff and EIA activities. He had the support of the General Manager’s office (up to 1987) which allowed him to acquire resources to build the Environmental Division (later renamed the Ecology and Environment Division) into a leader in EIA studies, in terms of experience and expertise, among all Thai state agencies.

Somvonk’s actions during the mid-1970s came when the World Bank was beginning to pay more attention to the environmental aspects of projects it funded. This also was when the National Environmental Quality Act was promulgated in Thailand. Somvonk was able to position the Environmental Division such that the World Bank depended on it to carry out the Bank’s environmental policy goals during the early 1970s. At that time, the World Bank began to screen development projects on a systematic basis for their environmental and health effects, in attempts to protect or restore environ- mental quality (Le Prestre 1989, p. 28). In addition, other EGAT depart- ments depended on the Environmental Division to conduct EIAs to facili- tate approval and funding of projects by the Thai government.

In mid-1987, the Ecology and Environment Division consisted of environ- mental engineers, environmental scientists, and specialists in forestry, re- sources management, sociology, economics, and air and water quality. Its growth and increased importance within EGAT reflected Somvonk’s ability to gain the backing of the World Bank and to obtain resources and increased influence within EGAT.

The Decline of Sornvonk’s Environmental Unit at EGAT In mid-1987, the two successive General Managers that had supported Somvonk’s build-up of the environmental unit retired. The Ecology and Environment Division was moved into a newly created Department of Survey and Ecology, which reported to the Assistant General Manager of Hydropower Development. The Public Communications Department was

“Per~onal interview, conducted by Shih-Liang Tu with Somvonk Poshyananda at EGAT, Bangkok, May 23, 1988, as reported in Tu (1993, p. 201).

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renamed the Public Relations Department, still reporting directly to the General Manager, but with a much smaller range of responsibilities. After 1987, the unit in charge of environmental studies was part of a technical, line operation, several layers below the General Manager’s office (see Figure 3).

There are at least four explanations for the changes in 1987. One explana- tion, offered by the General Manager newly appointed in 1987, was that the Ecology and Environment Division’s placement, under the Assistant General Manager of Hydropower Development, would better integrate the environmental and planning functions at an earlier stage of project development, at least for hydropower projects. Some believed the Public Relations Department did not have adequate capabilities to understand the technical aspects of environmental work, and thus, could not support properly the Ecology and Environment Division. According to the new General Manager, “The system [i.e., the overall organizational structure] is more important than individual persons.” He emphasized that “some public communications people can just talk but [they] may not work.“lS The new General Manager’s remarks reflected top management’s growing distrust of the Public Relations Department personnel to carry out EGAT’s environmental work. It was evident that much of Somvonk’s control over the Ecology and Environment Division diminished after the retirement of General Mangers that had supported him.

A second explanation is that the hydropower unit and other units such as thermal power and mining tried to gain control of the Ecology and Environment Division. Placement of the Ecology and Environment Divi- sion within the hydropower unit implied that hydropower won the struggle. The hydropower unit gained staff, budget, resources (such as data analysis and project evaluation capabilities) and more political clout within EGAT. In addition, hydropower projects were facilitated by improved coordination among environmental and engineering staff who were now in the same unit. In some ways, the gains to hydropower came at the expense of the thermal power and mining units. Projects in these units suffered delays, due to inadequate coordination with environmental staff. However, this second explanation for the reorganization is not entirely convincing, be- cause there is little evidence that the Thermal Power Department at EGAT was much interested in having the responsibility for the Ecology and Envi- ronment Division. Some at EGAT believe the thermal power and mining sectors would have opposed accepting the Ecology and Environment Divi- sion if it had been assigned to them; they considered the environmental unit as more trouble than it was worth.16

“Personal interview, conducted by Shih-Liang Tu with EGAT’s General Manager, Bangkok, May 27, 1988, as reported in Tu (1993, p. 203).

‘OPersonal interview, conducted by Shih-Liang Tu with staff in EGAT’s Ecology and Environment Division, Bangkok, May, 1988, as reported in Tu (1993, p. 203).

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There is a third view of the 1987 reorganization: assigning the environ- mental unit to the hydro unit was a strategic decision by EGAT management to buffer the thermal power and mining units from intervention by the environmental unit. In 1987, several major thermal projects were scheduled to go on stream in the 1990s.17 The reorganization may have been intended to focus the attention of the Ecology and Environment Division on hy- dropower and transmission development activities, thus to limit the influ- ence of environmental specialists on thermal power and mining projects.

Finally, a fourth explanation relates to extraordinary challenges being faced by EGAT’s hydropower projects in the late 1980s. During this period, a series of citizen-based protests against EGAT’s proposed Nam Choan dam caused the Thai government to halt the project. It can be argued that Nam Choan dam was the main issue on EGAT’s environmental agenda in 1987, and that EGAT knew that it soon would be starting another major hydro project with high potential for being controversial: Pak Moon dam. In these circumstances, moving the Environmental Division under the hy- dropower unit appears to be a sensible organizational response to the public opposition to EGAT’s hydropower agenda.18

A few observations hold true regardless of which explanation, or combi- nation of explanations, is valid. One is that Somvonk’s support from top management diminished following the retirement of the two successive General Managers that had backed him. As a result, the environmental unit was vulnerable. Another is that top management was dissatisfied with the location of the environmental unit within the Public Communications Department. This, together with diminution in Somvonk’s power, explain why the reorganization left the environmental unit with less overall influ- ence within EGAT. In its new, lower position in the organizational hierar- chy, the environmental unit did not enjoy the access to top officials that it had prior to 1987 (compare Figures 2 and 3). Together, these points illustrate the importance of the support Somvonk received from EGAT’s leaders before 1987.

We now present two case studies that highlight the importance of internal entrepreneurial activity on EIA-related events at EGAT. These case studies also illustrate how the environmental unit worked and the influence it had on specific projects.

The Srinagarind Hydropower Project

The Srinagarind Multi-Purpose Hydropower Plant Project (referred to hereafter as the Srinagarind Project) was the first project at EGAT to

“Personal interview, conducted by Shih-Liang Tu with an advisor to EGAT and Vice Rector for Planning, National Institute of Development Administration, Bangkok. October 4, 1988, as reported in Tu (1993, p. 204).

‘“The reader is referred to Phantumvanit and Nandhabiwat (1989) and Sluiter (1992), pp. 61-64, for perspectives on citizen opposition to Thailand’s proposed dams.

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implement an ecological study (i.e., a partial EIA) during the planning process. The Srinagarind Project was the largest hydro-electric project in Thailand. It is located approximately 190 kilometers northwest of Bangkok, and it has a potential generating capacity of 578 mw. The World Bank was the primary project lender, contributing 1,537 million Thai baht, or US $75 million, 41.1% of total project costs (World Bank 1974, p. 11). Construction of the Srinagarind Project began in March 1973; operations began in 1980.

EIA-Related Activities The EIA process of the Srinagarind Project began in 1972 with an ecological reconnaissance commissioned by EGAT (and prompted by the World Bank’s suggestion that an ecological study be conducted). EGAT sought a highly respected group to carry out the study: The Asian Institute of Technology (AIT). AIT concluded that there were no ecological conse- quences important enough to “deter or preclude” construction of the project (AIT 1972, p. 169). The 1972 reconnaissance set a precedent for EGAT’s subsequent environmental impact assessment activities. EGAT organized the study voluntarily at a cost, paid by EGAT, of US $18,000. After re- viewing the 1972 study report, the World Bank concluded that it had been “exceptionally well prepared” (World Bank 1974, p. 14).

During the study, Somvonk Poshyananda, then Chief of EGAT’s Plan- ning Division within the Planning Department, was facilitator for the study team. EGAT initiated the environmental impact assessment activities and supported the study team, but with some trepidation that the project might be impeded by the study’s results. However, the project went forward and the study was lauded. In retrospect, the pioneering EIA activities conducted by AIT encouraged, rather than discouraged, EGAT’s future EIA activities.

In response to the recommendations of the 1972 ecological reconnais- sance, EGAT decided to conduct a second ecological study and once again solicited AIT to do the work. The World Bank played a key role in EGAT’s decision to conduct the second ecological study as well. To secure the project loan from the World Bank, EGAT agreed that the Srinagarind Project implementation would give due consideration to ecological and environmental factors as well as AIT’s recommendations (World Bank 1974).

In 1973, EGAT proposed constriction of the Tha Thung-Na Regulating Dam to be located 28 km downstream of the Srinagarind dam site. Because the Tha Thung-Na Regulating Dam was not included in the original project plans, the project’s ecological and environmental impacts had not yet been evaluated. EGAT conducted an internal, preliminary environmental inves- tigation of the project in 1976, and solicited South East Asia Technology Co., Ltd. (SEATEC) in 1977 to follow up on EGAT’s preliminary investiga- tion. The study concluded that “no individual effects or combination of

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effects would be of an extent too serious to jeopardize the potential of the proposed project” (SEATEC 1978, p. ii).

In 1986-1987, EGAT authorized SEATEC, in association with the Na- tional Institution of Development Administration (NIDA), to prepare a post-environmental evaluation (PEE) of Srinagarind Dam, an extension of the previous Srinagarind EIA studies, that would be far more comprehen- sive in scope. A total of 25 environmental components (e.g., water resources management, electric power production benefits, and environmental eco- nomics) covering four levels of environmental resources and values (physi- cal, biological, human use, and quality of life) were included in the PEE study (NIDA-SEATEC 1987).

The NIDA-SEATEC team made various recommendations in the PEE, including calls for an additional pumping turbine unit, wildlife management programs, health center upgrades, waste disposal, and safety regulations. Notably, the study team emphasized the importance of EGAT’s main- taining congenial relationships with environmental NGOs and local citizens’ groups, during its project development.

The Srinagarind PEE process reflected EGAT’s efforts to integrate envi- ronmental concerns into project development and operations. In 1985, EGAT had adopted the EDP, which established internal operating proce- dures for including environmental analyses within EGAT’s project planning and development cycle. These internal procedures had been created by the Ecology and Environment Division, under Somvonk’s leadership. EGAT conduced a PEE for Srinagarind, in part, because the Environmental Devel- opment Plan called for post-project environmental studies.

Reasons for EIA Activities Why did EGAT agree to begin an EIA process in 1972? There were no government EIA requirements in Thailand; moreover, as of 1972, the Thai National Environment Board had not yet been created, there was little professional sensitivity toward the environment among EGAT’s project staff, and public pressure for EIA had not yet emerged in Thailand.

The most plausible explanation was that EGAT had received unequivocal guidance from the World Bank to conduct EIA activities. EGAT’s response to the World Bank’s suggestion (or, mandate, as some EGAT officials put it19) demonstrated the World Bank’s influence over EGAT’s project planning and implementation process. The result of the initial EIA work was that EGAT became more sensitive and aware of environmental issues related to its project development activities. Without the World Bank’s request as a catalyst, EGAT probably would not have conducted the ecolog- ical study for the Srinagarind project, and it is doubtful that EGAT would

“‘Personal interview, conducted by Shih-Liang Tu with EGAT’s Deputy General Manger of Hydropower and Transmission System Development, Bangkok, August 9, 1988, as reported in Tu (1993, p. 200).

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have made EIA an integral part of its work so far in advance of the Thai government’s formal EIA requirements of the late 1970s.

The World Bank was not alone in advocating the consideration of envi- ronmental impacts of the Srinagarind Project. By the mid-1980s as the Srinagarind project was nearing completion, Somvonk’s environmental unit had acquired considerable influence within EGAT, and environmental pro- fessionals in the unit were advancing their own agenda. The Environmental Division (later the Ecology and Environment Division) pushed for a PEE for the Srinagarind project and helped to ensure that a reasonable budget was available for the study. The impetus for the PEE was entirely internal to EGAT; the PEE was required neither by the World Bank nor the National Environmental Quality Act.

Mae Moh Lignite Mining and Thermal Power Project

In early 1972, EGAT’s Mae Moh Lignite Mining and Thermal Power Project plan (hereafter referred to as Mae Moh) was approved. Mae Moh, a small town in northwest Thailand, is 50 miles from Chiang Mai. EGAT’s surveys revealed proven lignite reserves of over 500 million tons, almost 10 times more than originally predicted in 1972 (EGAT 1985). Conse- quently, the number of generating units planned for Mae Moh was increased from 10 to 19 units.

The first stage of the Mae Moh project (Units l-3) started construction in 1973 and began operating in 1978. The Thai government approved a second stage (Units 4-7) in 1978 and a third stage (Units S-9) in 1985. In 1988, two additional plants (Units 10-11) were approved for construction, and a site selection study for Units 12-19 was completed. Lignite mining operations expanded at Mae Moh to keep up with the phased growth in generating capacity.

EIA-Related Activities During the 1980s a series of environmental studies were conducted during various stages of the Mae Moh project. In 1982, EGAT’s Ecology and Environment Division conducted a preliminary EIA, without the assistance of external consultants. As a follow-up to the 1982 study, EGAT hired SEATEC in 1984 to conduct an extensive EIA, following carefully both the terms of reference prescribed by the 1982 Preliminary EIA and the NEB’s Guidelines for EIA preparation. Results from the study included a list of parameters that required in-depth investigation.20

The 1984 EIA study by SEATEC indicated that the World Bank guide- lines for ambient air quality would be commonly exceeded (EGAT 1984;

2”Other environmental investigations were conducted for the Mae Moh project before, during, and after the 1982-1984 EIA studies noted here. However, they were conducted in an ad hoc manner and were not well coordinated with other studies (Tu 1993, p 247).

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p. 38). Without any effective mitigating measures, inhabitants in the Mae Moh area were “likely to develop chronic respiratory diseases” (EGAT 1984, p. 40). Consequently, the SEATEC report recommended six mitiga- tion measures to control air pollution. In 1986, a follow-on study by Environ- mental Science and Engineering Inc. (EGAT 1987) developed more special- ized mitigation measures.

To mitigate adverse effects of lignite production, EGAT employed tall chimneys on Units l-l 1 (at a cost of over 300 million Thai baht) to disperse air pollutants. In addition to using tall stacks, EGAT installed electrostatic precipitators to collect particulates for Units 1-9. Also, in the mid-1980s EGAT carried out air quality and water quality modeling monitoring stud- ies. EGAT also resettled approximately 350 families (at a cost of approxi- mately 27 million Thai baht) to areas away from Mae Moh.

In 1987, EGAT evaluated potential sites for Units 10-13 for the Mae Moh project. An internal study was prepared by the Ecology and Environment Division to investigate and rank alternative sites for the expansion scheme. The site adjacent to existing Units 4-9 was ranked most favorable among all candidates. The major disadvantage of this site, however, was the air quality impacts that would result from having all four units in the same basin, close to the existing nine units. Results of the study suggested that no matter which site was chosen for Units 10-13, there would be some portion of the affected area in which the ground level concentration of SO, would exceed NEB’s ambient air quality standard (Sombutsiri 1987). Nevertheless, the government-approved Units lo-11 for construction at the “preferred site” (adjacent to existing Units 4-9).

In an effort to prevent further air quality degradation by Units l-11, the Ecology and Environment Division of EGAT suggested that the site originally proposed for Units 12-15 be moved further away from Units l-11. This was based on the potential air quality impacts of the proposed Units 12-19, which could exceed NEB’s environmental quality require- ments. The Division argued that building the additional units at the origi- nally proposed site would damage health of the local people.

EGAT’s management accepted the Division’s suggestion. In 1988, it was decided that Units 12-19 would be moved to a site in a different airshed. That suggestion, developed internally, was based on the professional judg- ments of staff in the Ecology and Environment Division regarding the air quality impacts of alternative projects (Tu 1993, p. 252).

The decision was significant, because the Ecology and Environment Divi- sion was able to convince EGAT’s leaders to accept the more environmen- tally sound alternative, despite higher costs. Even though the environmental unit had been envisioned as a public relations operation, by early 1987 it had reached a high level of professionalism and had learned how to influence project design decisions. After almost 2 decades of implementing EIA- related activities, environmental professionals had become a strong force

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within EGAT. This was evidenced by their size and position in the organiza- tion, their EIA studies’ sophistication and the fact that EGAT’s manage- ment accepted their (more costly) suggestion to move the Mae Moh units.

Reasons for EIA Activities Why did EGAT undertake EIA studies for Mae Moh, and why did those studies lead to changes? These questions can be analyzed in terms of EGAT’s need to adapt to external forces: the Thai government require- ments for EIA, and the increasingly influential protests of individual citizens and environmental groups. EGAT’s decisions regarding EIA also reflect the growing influence of environmental specialists within the organization.

First, consider the way government requirements affected EIA for the Mae Moh project. The official ONEB notification of projects requiring EIA (1981) meant that EGAT had little choice; an EIA for Mae Moh had to be conducted. The EIA work in 1982 reflects EGAT’s response to the notification. In contrast to the Srinagarind project, EGAT did not conduct an EIA until if was formally required by ONEB. A plausible explanation for this relates to risks that project proponents assume when EIA require- ments are imposed. The process of identifying impacts often provides infor- mation that detracts from the overall attractiveness of a proposal, and this information can be used by project opponents to stall or derail a project. Sometimes information on adverse impacts leads to delays, particularly if elaborate mitigation measures must be formulated and designed. In the case of Mae Moh, risk in delaying the project was to be avoided because of the project’s significance: by the late 1980s Mae Moh’s planned electricity generating capacity amounted to more than 20% of Thailand’s total capac- ity. 21 EGAT responded quickly and decisively to the 1981 EIA notification, and avoided having the project delayed because of failure to comply with procedures. In addition, EGAT responded to the 1984 EIA (by SEATEC) by designing recommended mitigation measures.

A second part of the explanation for EIA-related activities concerns the growing citizen opposition to the Mae Moh project. By the mid-1980s citizens living near the project site had suffered a series of adverse project- related impacts, including air pollution, water shortages, and blasts from mine explosions. In addition, citizens were upset with EGAT’s lack of assistance to more than 300 families who were forced to resettle to accom- modate the project. The air pollution caused by Mae Moh incited nationally publicized demonstrations by increasingly influential environmental groups in Thailand. The prospect of having the project expand was met by further protests. EGAT saw the need to accommodate these critics and it did so, in part, by adopting a substantial and costly set of air pollution control measures.

“The Economist Intelligence Unit 1992.

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The final element of the explanation for EGAT’s EIA-related activities for Mae Moh concerns the influence of the Ecology and Environment Division within the organization. The Division’s staff were very concerned about potential air pollution in the project vicinity, and it engaged in exten- sive internal lobbying to have Units 12-19 located farther away from the sites of Units l-11. The Division’s recommendations eventually were ac- cepted. That acceptance reflected the Division’s influence within EGAT, and its transformation from a public relations tool to a professionally re- spected force. Somvonk, together with the support of the two General Managers that served prior to 1988, were able to create a working environ- ment that allowed the Division’s staff to make their recommendations without undue interference from project advocates within EGAT.

However, after the Ecology and Environment Division was moved under the hydropower development line in 1987, things changed. The staff under the Deputy General Manager for thermal power and mine development seemed content not to interact with the Division closely. (After all, it was the Division’s suggestion that led to a revised and more costly scenario for the Mae Moh project expansion.) Soon after the move, the thermal power and mining sectors had little interaction with the Ecology and Environ- ment DivisioiP.

Analysis of EIA Activities at EGAT

We use the framework introduced at the beginning of this study to analyze the case studies, the organizational changes, and the influence of Somvonk’s leadership on EIA implementation.

Internal and External Forces for EIA EIA implementation at EGAT presents a redundant system: it faces both external controls to conduct EIAs and internal forces for environmental studies. The case studies demonstrate the influence of the external controls of the World Bank and public pressure to conduct EIA and the internal force of Somvonk’s environmental unit.

In the Srinagarind project, the World Bank prompted EGAT’s unprece- dented EIA activities. EGAT perceived the World Bank’s recommendation that EGAT conduct an ecological study as a condition for project funding. However, the World Bank was not alone in advocating a consideration of environmental impacts. As the project neared completion, environmental professionals in Somvonk’s unit, which had gained considerable influence within EGAT, encouraged a post-environmental evaluation of the project.

~‘Personal interview, conducted by Shih-Liang Tu with staff of EGAT’s Environmental and Ecological Division, Bangkok, August 28, 1988, as reported in Tu (1993, p. 255).

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The Mae Moh project also was shaped by internal and external forces that promoted EIA: Thai government EIA regulations, public protests, and EGAT environmental professionals’ concern. First, the government’s official EIA notification in 1981 required EGAT to prepare an EIA for Mae Moh. EGAT’s EIA work in 1982 reflects their timely response to the notification. Second, the air pollution from Mae Moh incited both citizen opposition and protests by influential Thai environmental groups. EGAT responded to those critics by adopting a costly set of air pollution mitigation measures. Third, the growing group of environmental professionals in Som- vonk’s unit were concerned that the proposed expansion of Mae Moh would exacerbate local air pollution. They recommended a plan that was more environmentally sound, but also more expensive: the relocation of the proposed sites. Top management at EGAT accepted that recommendation, which demonstrates the environmental unit’s influence within EGAT.

The interactions among Somvonk’s environmental unit, EGAT, and the World Bank reveal mutual dependencies. Somvonk gained the support of the World Bank through the quality of EIA work that his unit performed. The Bank’s support increased the environmental unit’s prestige and author- ity within EGAT, and thus enabled Somvonk to acquire resources to build his Division. The World Bank depended on the environmental unit to incorporate environmental considerations in project planning and develop- ment. In addition, EGAT depended on the environmental unit to promote EGAT’s image as an environmentally sensitive agency: EGAT depended on the World Bank to continue to fund EGAT’s projects, and EIAs helped to win funding because they demonstrated EGAT’s capacity to conduct environmental studies.

Although EGAT conducted the initial EIA studies hesitantly, the first EIAs encouraged, rather than discouraged, EGAT’s future EIA activities. EIA helped both outsiders and insiders to pursue their agendas. EGAT’s experience with EIA demonstrates what Wanderforde-Smith and Kerbavaz (1988, p. 189) have also noted: some agencies no longer resist EIA nor do they merely tolerate EIA just to lay a pro forma paper trial before implementing a decision that they have already made. Instead, some agen- cies welcome EIA and its opportunities.

Political Entrepreneurship and Leadership Somvonk’s entrepreneurship left an imprint on the history of EIA imple- mentation and organizational change at EGAT. His efforts led to the restructuring that allowed elevation of the environmental unit in EGAT. With the World Bank’s suggestion in 1972, Somvonk seized the opportunity to make EIA a part of EGAT. He wielded support from the World Bank to convince EGAT’s management of the importance of EIAs. With manage- ment’s support, he gained influence and resources within EGAT to build

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up the Environmental Division. Just as it is hard to imagine how EIA would have flourished at EGAT without Somvonk, Wandesforde-Smith and Kerbavaz (1988, p. 190) also note, “It is hard to imagine EIA in California surviving so long and being accepted as useful by so many without the creative imagination and entrepreneurial hard work of people like Nicholas Yost [former Deputy Attorney General of California] and Norman Hill [former Assistant Secretary of the Resources Agency for California Environmental Quality Act (CEQA) issues].” The case studies emphasize the influence of Somvonk’s leadership and entrepreneurship in EIA imple- mentation at EGAT.

In the Srinagarind project, the success of EGAT’s environmental studies demonstrated the success of Somvonk’s leadership. Formal EIA procedures did not exist within EGAT at the time of the preliminary studies. Somvonk’s responsiveness and adherence to the terms of the World Bank catalyzed EIA activities at EGAT. Somvonk’s activities in implementing environmen- tal policy reinforces the view of Wandesforde and Kerbavaz (1988), who emphasize the importance of a political entrepreneur who sees opportuni- ties for implementing EIA and comes forward to do the political and analytical work. Later in the Srinagarind project, EGAT conducted a PEE. The PEE was prompted by the Environmental Development Plan, which institutionalized environmental investigations in EGAT’s project planning and development cycle. Under Somvonk’s leadership, the Ecology and Environment division had created these internal procedures.

Somvonk’s Division was also instrumental in the EIA process for Mae Moh. This is demonstrated by EGAT’s decision to accept the suggestion made by the Ecology and Environment Division to locate the additional units at a site far from the existing units. The Division had become a powerful, sophisticated, professionally recognized force within EGAT, and it had the confidence to assert this power.

The two major organizational shifts during 1972-1987 also highlight Som- vonk’s leadership and promotion of environmental studies. In 1976, Som- vonk led the Environmental Division through an organizational shift. This shift gave the Division both direct access to top management and the ability to conduct EIAs-and influence projects-with less interference from other divisions at EGAT. In 1987, Somvonk’s environmental unit was moved. This move revealed the importance of the support Somvonk received from EGAT General Managers before 1987, and the support he lost when those two General Managers retired. As Taylor (1984, p. 270) notes, informal relationships between actors in the EIA process can be a powerful impetus for coordination and support-even more so than formal rules and responsi- bilities.

Transformation of Organizational Power Relationships During 1976-1987, the environmental unit at EGAT went from being per- ceived as a cosmetic unit to a project-oriented division with clout. The

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Environmental Division staff tripled in size; they hired environmental engi- neers, environmental scientists, and specialists in forestry, resources man- agement, sociology, economics, and air and water quality. The Environmen- tal Division became the Thai leader in EIA implementation. In fact, the Division’s work motivated the Office of the National Environment Board to showcase EGAT as a model agency.

The organizational changes during this period reflect the growth in influ- ence of the environmental unit. In 1976, the Environmental Division moved from the Planning Department to the Public Communications Office, which gave the environmental unit an elevation in status and a chance to improve itself. The Division could grow freely and independently within EGAT, with more direct access to top management than it had had in the Planning Department. With the introduction of the Environmental Development Plan and other exercises of its internal power, the Environmental Division was able to modify EGAT’s rules and operating procedures. This is consis- tent with the findings of Mazmanian and Nienaber (1979; p. 193) and Crozier and Friedberg (1977; p. 248): if new missions are to be adopted, traditional power relationships must be modified. The development of new relations of power requires the development of new capacities within the organization (e.g., additional environmental analysts for the environmental unit) to transform the established chain of command.

In 1987, the power balance shifted again when the environmental unit was relocated within EGAT. EGAT’s new top management had become dissatisfied with the location of the environmental unit within the Public Communications Department and moved it to a position of considerably less power and influence. This move, together with the diminution in Som- vonk’s support from top management, left the environmental unit vulnera- ble and with less overall influence.

Conclusions

The change in the status of EIA at EGAT between 1972 and 1988 demon- strates the importance of leadership and political entrepreneurship in shap- ing an organization’s response to changing environmental requirements. The conditions for innovation were present: a request from the World Bank for EIA, pressure from increasingly vocal environmental groups, and EIA regulations imposed by the Thai government. But these opportunities might not have been seized if Somvonk were not able to combine his own skills as a manager with the support of two General Managers to transform a fledgling EIA section into a nationally recognized leader in EIA work. A change of General Manager in 1987 and a change in position for Somvonk diminished Somvonk’s influence in EIA activities.

Somvonk was effective in promoting EIA for two reasons: he had support of top management, and top management recognized that EGAT needed to clear environmental regulatory hurdles to meet its organizational objec-

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tives. Satisfying all environmental regulations in a timely way was also necessary to avoid possible project delays caused by increasingly influential environmental groups. EGAT’s EIA activities also promoted its image as a progressive, environmentally sensitive agency. Somvonk exploited oppor- tunities provided by external and internal organizational forces to establish EIA in EGAT’s project planning and decision-making.

The analysis of EIA adoption at EGAT reinforces the importance of three factors that explain how and why EIA is institutionalized: mutually reinforcing support for EIA from both inside and outside a development agency, political entrepreneurship by agency staff that are concerned about the environment, and the transformation of power relationships within the agency by environmental professionals.

When plans for this article were first made, our colleague Shih-Liang Tu was to be a co- author. However, Dr. Tu’s current employer has frequent interactions with EGAT. To avoid any awkwardness, Dr. Tu chose not to participate in developing this article. We acknowledge Dr. Tu’s many contributions to our understanding of EIA at EGAT, and we are grateful for his permission to use materials from his Ph.D. dissertation (Tu 1993), which was carried out at the Department of Civil Engineering at Stanford University. We also thank Greg Browder of Stanford University for his very helpful comments and additions to the study, and Sally Anne Lichtenwalner for her review of a draft of the article.

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