Environmental Impact Assessment Review 30 (2010) 363–370

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Environmental Impact Assessment Review

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Evaluation of the environmental impact assessment system in Syria

F. Haydar a,⁎, K. Pediaditi b,1

a Rural Development Division, National Agricultural Policy Center, Ministry of Agriculture and Agrarian Reform, Airport Highway, 5th Bridge, Damascus, 4251, Syriab Department of Environmental Management, Mediterranean Agronomic Institute of Chania, Alsylion Agrokepion, Chania, P.O. Box 185, 73100, Crete, Greece

⁎ Corresponding author. Tel.: +963 11 5455372.E-mail addresses: firashaydar@yahoo.com (F. Haydar

(K. Pediaditi).1 Tel.: +30 28210 35000x576.

0195-9255/$ – see front matter © 2009 Elsevier Inc. Aldoi:10.1016/j.eiar.2009.11.003

a b s t r a c t

a r t i c l e i n f o

Article history:Received 15 September 2009Received in revised form 22 November 2009Accepted 26 November 2009Available online 19 January 2010

Keywords:Environmental impact assessmentSyriaImplementationEvaluation

Syria is a country experiencing rapid change, undergoing a process of political and governance decentralisation,opening its markets to the private sector, and experiencing a rise in infrastructure development. In light of theseeconomic growth targeted changes, knowledge of the status and capacity of the Syrian EIA system to ensureenvironmental protection becomes of paramount importance. Syriafirst introduced EIA as aDraft Decree in1995,which was not formally adopted until 2008. To date, no structured evaluation of Syria's EIA system has beenconducted, a knowledge gap addressed through this paper. The research presented herein comprises a reviewand comparative evaluation of Syrian legislation and procedures, to the EU EIA Directive and World BankOperational Directive, as well as a series of interviews with Syrian stakeholders involved in EIA implementation.The investigation concluded that the newEIA provisions provide a sound legal basis. From interviews however, itwas ascertained that EIA implementation faces a number of barriers such as, a lack of EIA integration into existingdecision making and licensing processes and persistent exclusion of public projects from EIA. A number ofrecommendations are proposed, perceived necessary for the enhancement of EIA implementation in Syria.

), kalliapediaditi@hotmail.com

l rights reserved.

© 2009 Elsevier Inc. All rights reserved.

1. Introduction

Syria is classified as a lower middle-income developing country(World Bank, 2009) with an average annual growth rate of 2.2% of theper capita GDP since 2000; and a population growth rate of 2.45% in2006 and 2007 (CBS, 2006, 2007). Since the early 90s, Syria has beenundergoing a transition from central to indicative planning, trying topromote a comprehensive development process. Consequently, theprivate sector has increasingly been allowed to engage in activitieswhich were previously solely under government control, such asinfrastructure development. Additionally, many incentives have beenprovided to promote private investments such as Investment Law No.10 of 1991, resulting in an increase in the number of developmentprojects taking place. In parallel, Syria has committed itself to the RioDeclaration and International Conventions (Biological Diversity, Com-bating Desertification, Climate Change). However, there has beenincreasing criticism with regard to the actual impact these commit-ments have had on the ground (MSEA, 2003). There are many social,economic, institutional, and cultural reasons which are promotingenvironmental degradation in Syria. Amongst others are the generallack of environmental awareness and sluggish economic growth,coupled with increasing population and urbanization trends, inade-quate cooperation amongst institutions and organizations, lack of

strategic planning for resource management, and lack of informationand instated procedures for the inclusion of environmental considera-tions during the preparation of development plans and programmes(MSEA, 2002).

EIA was first introduced in Syria as a Draft EIA Decree in 1995, andprogressively strengthened through laws outlined in Table 1. Yet itwasnot until 2008, that it was formally adopted through Decree No. 225.Even though EIA has been introduced for over 14 years, the increasingrate of environmental degradation in Syria (Pillet et al., 2004;Muawya,2008) gives rise to the question of the EIA system's effectiveness inSyria and actual status of implementation. It also highlights the need toinvestigate its actual capacity as a procedure, to enable the consider-ation of environmental issues in planning decision making processesto consider environmental protection, when taking into account theemphasis placed on social and economic priorities of the country.

In fact, the aims of the research conducted, whose results arepresented herein, were to obtain a comprehensive picture of the SyrianEIA system, evaluating its current status of implementation, its short-comings, aswell as the proposal of recommendations for improvement.Although the need for country EIA system review is widely acknowl-edged, and evaluation procedures to do so using established criteria areavailable (Wood, 2003), apart from an account by Mahayri (2003), thishas not taken place for Syria.

Therefore, in this paper, the results of research carried out, aimed atfilling this knowledge gap are presented. In Section 2 the methodologyused for the evaluation is described, followed by a description andanalysis of the evaluation results in Section 3. This paper concludeswithrecommendations for improvement both of the Syria EIA provisions

Table 1Historic outline of influential Syrian EIA legislation.

Year Legislation Article Main outcomes

1991 Legislative Decree No. 11 Art 3, P. 5 Instatement of the General Commission for Environmental Affairs (GCEA) who thereon is responsible for“Conducting environmental inspections of activities performed … The inspection shall also include facilitiesconsidered to be dangerous and harmful to environment safety, necessitating proposals for solutions requiredto clear away the emanating menace.”

1995 Draft EIA Decree Art. 4 This draft was created in preparation to legislate EIA, and was used up to 2008.2002 Environmental Law No. 50 Art. 4, P. 8 Legal requirement for project EIA instated, and authorization role of GCEA legislated2008 GCEA (2008), EIA Executive Procedures,

adopted through Decree No. 225Art. 3; Art. 4,P. 1, 2

List of projects requiring EIA specified in Annexes 1 and 2. Specifications and detailed requirements of EIAprocedure and Environmental Impact Statement (EIS), provided in GCEA 2008

364 F. Haydar, K. Pediaditi / Environmental Impact Assessment Review 30 (2010) 363–370

as well as measures for implementation effectiveness enhancement(Section 4).

2. Research design and methodology

Following a review of methods in country EIA system evaluation,Wood's (2003) proposed method and 14 criteria were adopted. Thesecriteria are effectively based on best practice EIA guidance, withquestions regarding the components and requirements of the countryEIA system, as well as the system's capacity to influence decisionmaking. Thus, an integrated research design, which included a reviewof the Syrian EIA legal provisions followed by a series of interviewswith identified key EIA stakeholders, establishing what is occurring inpractice, was adopted.

It is increasingly recognised that effective EIA system implemen-tation will not occur overnight and that longer established systemslike those in Europe and America serve a leading demonstration roleregarding procedural best practice (Glasson et al., 2005). It was thusdeemed appropriate to conduct a comparative evaluation of EU andWorld Bank EIA procedures using Wood's (2003) criteria as a basis,and juxtapose them against Syrian procedures, enabling the identi-fication of potential weaknesses and areas for improvement.

For the interviews, a stakeholder analysis using the GCEA (2008)provisions which specify stakeholders and their role in the Syrian EIAprocesswas conducted. Additional interviewswere determined througha process of co-nomination (Table 2). Including the GCEA, eleven out ofthe fourteen Syrian governorates' environmental departments respon-

Table 2EIA stakeholders interviewed and outline of questions asked.

Number of stakeholders interviewed Stakeholder EIA capacity Interview ques

General Commission forEnvironmental Affairs (1)

Responsible for EIA legislation,and implementation,coordination with otherministries, etc.

• Is EIA ensurin• Is EIA being e• Are existing l• Are all necess• Does your au• Is current cooimplement EIA• What do you• What is yourwhom, is it effe• What is your einvolved? Is thescoping proces• What are youmprovement)• Are there anyfor improveme• What is your eavailable for pu• What has beeused to revise E• What is your eproposals? (Wh• What is your ehave enough tim• SEA, is it need

Academic/scientific EIA experts (5) Syrian academic experts, withyears of experience in providingconsultations and expert opinionfor EIA's, and in the production ofEIS

Government representatives ofenvironmental directorates (11)

Responsible for EIAimplementation, review,monitoring, approval procedures

Engineering syndicate EIAcertifiers (2)

Responsible body for certifyingEIA consultants. Sole providers ofEIA training in Syria. Total of 65certified members.

Private EIA experts (6) Representatives from allcompanies conducting EIA inSyria

sible for EIA implementation were interviewed, as well as establishedrepresentatives from Syria's six main EIA consultancies. Two represen-tatives were interviewed from the Engineering Syndicate which is thesole certifier of EIA experts and the responsible body for EIA trainingprogrammes. Five academic experts, who have contributed to EIAconsultations as well as engaged in EIA report preparations, having thecapacity to express amore independent opinion, were also interviewed.From the above, it is ascertained that even though not exhaustive, theobtained sample is representative, robust, and covers all EIA decisionmaking capacities, bar the developers, who could not be reached. Semi-structured interviews were carried out containing both closed (Likertscale) and open-ended questions which where transcribed, translatedand analysed using descriptive statistics as well as content analysis foropen-ended questions (Sarantakos, 1993).

Thus, to summarise, the research design included the following:

• Identification of EIA relevant Syrian legislation and procedures sinceits introduction in 1995 and their translation from Arabic to Englishand analysis, to establish their performance against Wood's (2003)14 evaluation criteria (Section 3);

• A comparative review of EU Directive 97/11/EC, World Bank (1991)andSyrianEIA (2008), legalprovisions andprocedures; using thesamecriteria (Wood, 2003) as well as a juxtaposition of project screeningcriteria and lists;

• Semi-structured interviews with 25 key Syrian EIA implementationstakeholders (Table 2), establishing EIA status of implementation,perceived barriers, benefits and recommendations for improvement.

tion topics

g the minimization of environmental impacts of projects in Syria?ffectively implemented? (Why?)egal provisions sufficient, for the effective implementation of EIA?ary EIA implementation guidelines provided?thority have the capacity (time, resources, training) to effectively implement EIA?rdination/collaboration with other relevant planning authorities effective enough to?recommend for the enhancement of EIA implementation?experience and views regarding the screening procedure? (When is it undertaken, byctively implemented; publicly notified? What could be done to improve it?)xperience and views regarding the scoping procedure? (What, when, who isone-week decision approval period adequate? What could be done to improve thes?)r views regarding the quality of EI statements being submitted? (Recommendations for

issues regarding EIS preparation? (Data availability, time needed, recommendationsnt)xperience and views regarding the EIS review process? (Who is involved, is it madeblic consultation, what are the limitations, recommendations for improvement)n your experience in EIA public consultation? (Who usually takes part, are commentsIS?)xperience and views regarding alternatives consideration and mitigation measureat happens in practice, recommendations?)xperience regarding monitoring for EIA? (What does it involve in practice, do youe and staff, recommendations?)

ed, is it in the process of being developed?

365F. Haydar, K. Pediaditi / Environmental Impact Assessment Review 30 (2010) 363–370

3. Results of Syrian EIA system evaluation

A summary of the evaluation results using the criteria stipulated inWood (2003) is presented (Table 3) supplemented by interviewees'views regarding the effectiveness of the existing systems andperceived benefits. This is followed by a detailed description of theEIA system and analysis of each criterion, with regard to how itcompares to EU Directive (97/11/EC) requirements, as well as issuesand recommendations for improvement proposed by interviewees.

The review of the new GCEA (2008) procedures revealed thatthey are actually based on the World Bank Operational Directive OD4.00 and the amendment 4.01 (World Bank, 1991), and where judgedas adequate, addressing to a certain extent the majority of EIA criteria(Table 3). In fact, when juxtaposed to EUDirective requirements, Syrianprovisionswere in some casesmore demanding, for example stipulatingmandatory provisions for scoping, EIS review, and requirements for twopublic meetings, and long-term monitoring of impacts. Such require-ments are not mandatory in the EU Directive even though widelyacknowledged as best practice in the literature (Glasson et al., 2005;Weston, 2000).

However, Syrian provisions did not fare well with all criteria(Table 3), indicating room for improvement. Thus below, a compar-ative analysis of EU and Syrian legal provisions for each criterion ispresented (Table 3), followed by an overview of what is occurring inpractice based on interviews.

Table 3Comparative review of the Syrian EIA system and its juxtaposition to EU EIA Directive requ

Wood's (2003) evaluation criteria The Syria EIA System (derivedBank regulations)

1 — Is the EIA system based on a clear and specific legalprovision?

Decree No. 225, GCEA (2008) p

2 — Must the relevant environmental impacts of allsignificant actions be assessed?

Requirement for the considerasocio-economic impacts of a p

3—Must evidence of the consideration, by the proponentof the environmental impacts of reasonable alternativeactions for environmental significance take place?

Requirement of alternatives coEIA report

4 — Must screening of actions for environmentalsignificance take place?

Yes, but screening decision is n

5—Must scoping of the environmental impacts of actionstake place and specific guidelines be produced?

Mandatory scoping process, coparticipation required, includinpublication.

6—MustEIAreportsmeetprescribed content requirements,and do checks to prevent the release of inadequate EIAreports exist?

Detailed requirements of EIA r5 (GCEA, 2008).Mandatory EIS review

7 — Must EIA reports be publicly reviewed and theproponent respond to the points raised?

Requirement for EIS consultatiwithin two weeks of the one-mfor EIS review by environmenthas to respond to the points ra

8—Must the findings of the EIA report and the review bea central determinant of the decision on the action?

Not entirely.Planning approval for construcfollowing scoping report appro

9 — Must monitoring of action impacts be undertakenand is it linked to the earlier stages of the EIA process?

Ex- and post-project developmrequired, by both: the developdirectorates

10—Must the mitigation of action impacts be consideredat the various stages of the EIA process?

Provision of mitigation measur

11—Must consultation and participation take place priorto, and following, EIA report publication?

Publication of EIS.Two mandatory public meetina) after scopingb) after EIS reports submission

12—Must the EIA system be monitored and, if necessary,be amended to incorporate feedback from experience?

No.Only mandatory biannual scree

13 — Are the financial costs and time requirements of theEIA system acceptable to those involved and are theybelieved to be outweighed by discernible environmentalbenefits?

Procedure requires the evaluatbenefits of impacts, alternativeand monitoring planPerceptions of acceptability dis

14—Does the EIA system apply to significant programmes,plans and policies, as well as to projects?

Decree 225, requires only projSEA legislation or provisions to

3.1. Syria's EIA legal provisions (criterion 1)

The necessity for a clear and specific EIA legal provision is the firstcriterion used to evaluate a country EIA system proposed by Wood(2003). The review of the short history of EIA in Syria (Table 1)indicates that, up until 2008, and with the enforcement of Decree No.225, this was not the case even though the GCEA was established in1991 and had been empowered to monitor, evaluate, and control theenvironmental effects of development activities.

Based on the above, it can be concluded that until 2008, whenessentially the World Bank (1991) specifications were adopted, legalprovisionswere unclear andweak, and thus itwas considered importantto ask interviewees, what they perceived the implementation status ofEIA was. When questioned, it was encouraging that only 25% ofrespondents did not perceive the GCEA (2008) legislation provisionsto be sufficient. Regardless of opinion, all interviewees acknowledgedthe improvements brought through Decree No. 225, with regard to itsclarity and potential for implementation, but still pointed out somelimitations discussed further on.

However, when questioned whether they perceived EIA was beingimplemented effectively in Syria, interviewees' opinions differed,with 50% claiming that it was adequate and the other 50% claimingthat it was not. Further probing questions regarding existing barriersto EIA, revealed that all stakeholders perceived a number of issues tobe hindering effective implementation. Ranked according to stated

irements.

from the World The EU EIA system

rovisions Par. 1 of Article 2 of EIA Directive (85/337/EEC) and(97/11/EC)

tion of all physical androposal

Emphasizes the assessment of impacts on physical andbiological components of the environment

nsideration stipulated for Requirement for alternatives consideration and inclusionin EIA report mandatory

ot published Yes, and screening decision must be published

nsultation and publicg scoping report

Notmandatory but all Member States have to guarantee avoluntary scoping stage. Considered best practice.

eport are set out in Annex Minimum requirements of EIS Annex IV of Directive97/11/EC.Formal EIS review is not mandatory.

on and public reviewonth duration dedicatedal authorities, developerised

Requirements presented in Directive 2003/35/EC. Publicparticipation and concerned authorities consultation arerequired and timelines for response specified by Memberstates.Competent authorities should take the points raised intoaccount before decisionInformation gathered in EIA and resulted fromconsultation process should be used by decision makingauthorities prior to granting planning approval.

tion may be grantedval.ent monitoring of impactser and the governorates'

No mandatory requirement for monitoring of impacts,left to Member States to decide.

e plan is mandatory Consideration of mitigation measures mandatory

Directive 2003/35/EC. Publication of EISgs: Nature of Public consultation details specified by MS.

EIA system monitoring is required each 5 yearsning criteria review.ion of the costs ands, mitigation measures,

Not applicable

cussed in Section 3.11ect level EIA. There is nodate.

SEA Directive 2001/42/EC

366 F. Haydar, K. Pediaditi / Environmental Impact Assessment Review 30 (2010) 363–370

perceived significance, lack of expertise in EIA was considered to bethe greatest barrier followed by lack of resources and staff shortages,mainly expressed by governorate officials interviewed. Other men-tioned barriers included a current lack of developers' awareness, whoare not convinced of the need for EIA, and the lack of time necessary tocarry out EIA of sufficient quality. A number of recommendations forimprovement were also proposed which are presented in Section 4.

In light of the considerable demands of the GCEA (2008) provisions(Table 3), interviewees were questioned with regard to their capacityto fulfil tasks. Only four of the governorate directorates claimed to havethe capacity to do so; time availability and information shortageswerepresented as important barriers.

EIA's primary purpose is to ensure the minimisation of the envi-ronmental impacts of projects (Glasson et al., 2005). Thus intervieweeswere asked to state whether they perceived EIA in Syria to be fulfillingthis purpose. Encouraging is the fact that despite the aforementionedimplementation issues, the majority of interviewees (70%) believedin the theoretical value of having a process like EIA to minimiseenvironmental impacts. More critical responseswere obtained from theacademic experts and some government officerswho viewed the role ofEIAas a tool to aid planning authorizationdecisionmaking, as remaininglargely peripheral, stipulating the need for changes in the governanceand decision making processes described below.

3.2. EIA governance and its role in the development approval decisionmaking process (criterion 8)

The need to integrate EIA within existing governance processes, andin particular the development approval and licensing procedures, iswidely acknowledged (Leknes, 2001; El-Fadl and El-Fadel, 2004;Weston, 2002). For this reason, Syrian project licensing proceduresand EIA processes were reviewed and implementation practiceclarifications obtained from interviewees. The results are presented inFig. 1, in which the consequence of EIA steps and operation licensingprocedure, the time frame for each step, and the responsibility ofdifferent stakeholders and authorities are presented.

In Syria, the planning approval and licensing procedure is complexwith fragmented responsibilities residing in different levels of adminis-tration and authorities. Firstly sectoral permits are required from specificministries (e.g. Ministry of Agriculture, Tourism, Industry). A distinctoperational permit is required which is obtained from administrativeauthorities, which is the permit where the EIA approval is needed. TheEIA approval process is essentially disjoint from the overall planning andoperation licensing process which is conducted by different authorities,posing a significant integration barrier, as is expanded upon below.

EIA is linked to the operational licensing process in Syria which isbased on the Legislative Decree No. 2680, in effect since 1978. DecreeNo. 2680, Art. 1 states that: “It is prohibited to develop any dangerous,harmful to public health, or noisy industrieswithout a license accordingto this legislation”, and contains annexes of projects which require sucha license.

This operational licensing decision by law is taken by the governor,based on the recommendations of a specific licensing committee of Art7 (3). This committee provides opinion only with regard to approval ofoperations and not with regard to construction or installation works(Art. 9). As EIA and GCEA representatives are included only in thiscommittee,meaning that project construction can take place prior to EIAapproval. Since 2004 and the issuing of Decree No. 10, the licensingprocedure has been differentiated for projects within and outsideplanned areas, establishing two distinct committees, which GCEArepresentatives should take part in. It is the responsibility of these twocommittees to carry out screening and determine the need for an EIA.This takes place following a site visit, where preliminary planningapproval for construction is obtained, together with a report stipulatingoperation license obtainment requirements, including, when necessary,the need for scoping report submission and approval, in order for

construction to takeplace. So essentially, a temporary license to constructis granted, on the condition of approval of the scoping report, yet thepermanent operation license is granted following EIA report approval.

From the above, it is clear that the role of EIA in minimising theenvironmental impacts of projects is severely undermined. Duringinterviews, a question concerning whether this was considered aproblem was asked. All interviewees commented that commencingconstruction prior to EIA approval was effectively reducing the pro-cedures potential to minimise environmental impacts, for examplethrough improved project design and alternatives' consideration, andthus presently being considered, in particular by developers as yetanother layer of bureaucratic administration.

Moreover, the fragmentation of licensing procedures and authori-zation responsibilities, indicates the need for extensive coordinationand collaboration between different authorities and committees, for thesystem to be effective. Inter and intra agency collaboration andinstitutional coordination, has been established as a key element forthe effective implementation of EIA in general (Kennett and Perl, 1995,Saarikoski, 2000). However, interviewees, when questioned on thispoint, indicated that the existing status of collaboration betweengovernorates together with the GCEA and other stakeholders involved,was challenging. Eight of the interviewees did not wish to comment onthis issue, whereas its importance was underlined by environmentalgovernorate interviewees responsible for the EIA approval process, whocommented on their segregation and exclusion from key decisionmaking processes, reducing their capacity to ensure environmentalprotection through the EIA process. Some reported the phenomenon ofproject construction having already commenced, prior to screeningopinion being requested.

3.3. Extent and coverage of EIA (criterion 2)

Criterion 2 in Wood (2003) refers to the evaluation of the extentand coverage of the EIA system, in particular with regard to whetherthe relevant environmental impacts of all significant actions have to beassessed. According to GCEA (2008) procedures, EIA is required for allprojects likely to result in significant impacts regardless of whetherthey are public or private. In fact, unlike the EU Directives Art. 2(3),there is no exemption clause stipulated in the Syrian procedures.However, from the interviews, it was established that the greatestweakness in the implementation of the Syrian EIA system was thecontinuing exemption of government projects fromhaving to undergoEIA. One interviewee stated:

“As infrastructure development is still very centralized, with themajority of big projects, such as dams, roads, etc being carried outby the relevant ministries, their exemption from the EIA process isresulting in the inconsistent application of the procedures, and theexclusion of the projectswith the greatest environmental impacts.”

Evidence of this phenomenon, was confirmed by reviewing all theEIA applications (20) submitted since the issuing of the GCEA (2008),whereby no government project applications were identified.

With regard to the coverage of impacts assessed by the Syrian EIAsystem, it appears that the procedures (GCEA, 2008) require theexplicit assessment not only of the physical and environmentalimpacts, as is the case in the EU Directive, but also the socio-economicimpacts, something widely supported in the literature (Burdge, 2002;Glasson et al, 2005; Morris and Therival, 2001; Vanclay, 2003).Interviewees confirmed that socio-economic impacts were in factbeing considered, which is very encouraging.

3.4. Consideration of alternatives (criterion 3)

The new EIA procedures require the description of alternativesconsidered within the EIA report including the “no action” alternative

Fig. 1. Role and integration of EIA in project planning and operations licensing decision making processes.

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(GCEA, 2008, Annex 5). However, an issue which arises and wasconfirmed through the interviews is that current consideration ofalternatives is in fact superficial, as the “no action” cannot be considered,whenproject construction actually starts prior to EIA approval. The sameholds true, regarding genuine consideration of alternative sites. Thelatter problem, however, is not exclusive to Syria (Steinemann, 2001).

3.5. Screening of actions (criterion 4)

Criterion 4 questions whether screening of actions for environ-mental significance takes place (Wood, 2003). A threshold-basedscreening procedure, based on the World Bank (1991) guidelines isstipulated in the GCEA (2008) procedures. The authors conducted acomparative review of Annexes 1 and 2 of the Directive 97/11/EC,as well as the World Bank (1991) lists, and found few differencesregarding the projects requiring EIA. The main problem regardingscreening, was the persistent exclusion of government projects fromundergoing EIA, regardless of whether they are included in Annexes(see Section 3.3). Some interviewees proposed that in order toovercome this issue the role and capacity of the GCEA and itsenvironmental departments in the governorates would have to be

strengthened, something which requires political will and commit-ment to the process.

3.6. Scoping of impacts (criterion 5)

Criterion 5 questions whether, in the EIA system, scoping ofenvironmental actions of projects takes place and whether specificguidelines are produced. According to the GCEA (2008 Art. 5)procedures, scoping is mandatory in Syria and requires the developerto submit a scoping report, which is reviewed and put out for publicconsultation. Moreover, the developer by law has to respond tocomments raised, throughout the review and consultation prior toapproval. This is a positive development, which has yet to be includedin the EU Directive, even though the value of scoping has long beenrecognised and described as one of the most useful procedures in EIA(Weston, 2000). However, the GCEA (2008) prescribes a one-weekperiod for scoping report publication, consultation and regulatoryauthority opinion provision, raising questions regarding the effec-tiveness, feasibility and actual implementation of this procedure,considering the aforementioned fragmentation and coordinationissues identified (Section 3.2).

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Interviewees identified a number of shortcomings with regard toscopingpractice. Its necessitywasunderlined, as it is essentially the onlyprocess for consideration for environmental issues conducted prior toconstruction. However, some practitioners noted the phenomenon ofrepetition between scoping and EIS reports produced. Furthermore, theone-week scoping consultation periodwas considered too short, posinga barrier to the thorough examination of issues and consolidation ofconsultation opinions. Finally, a number of interviewees from theenvironmental governorates responsible for the review of the scopingreports, pointed out the need for written guidance on how to conducteffective scoping reviews.

3.7. Preparation and quality review of EIS (criteria 6 and 7)

Criterion 6 questions whether EIA reports must meet prescribedcontent requirements and whether checks to prevent the release ofinadequate EIA reports exist. Criterion 7 questions the existence ofa public review procedure (Wood, 2003). In Annex 5 of the GCEA(2008), detailed specifications regarding the content of EIS areprescribed and have been based on theWorld Bank (1991) guidelines.

The review of submitted EIA reports against those specifications bythe authorities is mandatory, as is their publication, fulfilling bothcriteria 6 and 7. Following submission of the EIA report, authoritieshave onemonth to conduct a public review of the EIA, and prepare theEIA review report containing: a) their assessment of the EIS and itsadequacy; b) a summary of monitoring measures and reporting waysas well as c) the principles upon which approval was granted and d)other statements and opinions raised. Should points be raised in thisreport, the developer is by law obliged to address them.

In practice however, as was established through interviews, itappears that despite this detailed mandatory review process, thequality of EIA reports remains unsatisfactory. Claims of two to three-page hand-written EIA reports being submitted and approved weremade by some interviewees. Moreover, the investigation showed thatno EIA had been rejected following review. Interviewees referred tomany reasons behind the poor quality of submitted EIA reports,including the lack of experience of EIA experts, lack of basic necessarydata and information, for example biodiversity inventories, not tomention the absence of land use and cover maps.

The failure of the review process was attributed by interviewees, inpart to the lack of experience and training of authorities in the reviewprocess. The absence of national standards or thresholds regardingdifferent types of impacts, for example soil contamination guidelinevalues, which could serve as significance thresholds and reasons forproject approval rejection, were also mentioned. Absence of socio-economic criteria and guidelines to evaluate significance were alsopresented as an issue.

3.8. Mitigation and monitoring of impacts (criteria 9 and 10)

Criteria 9 and 10 examine whether an EIA system stipulates themitigation and monitoring of project impacts throughout the variousstages. The Syrian EIA system fulfils both criteria, while GCEA (2008,Annex 6) procedures detail specifications for the development of amitigation strategy and an environmental management plan, whichmust also contain a long-term monitoring strategy.

The need for long-term monitoring is widely advocated in theliterature (Dipper, 1998;Marshall et al., 2005;Morrison-Saunders andArts, 2004; Wood G, 2000), yet still to be established globally, anindicator of this being its absence from the EU Directive. Monitoring ofimpacts is required to be carried out in Syria by the developer as wellas by the environmental governorates' investigation subdivision,during all phases of the project, including post-construction. A reviewof the monitoring specifications, reveal an ambitious agenda whichraises the question of how Syria with so many development prioritiesand limited public planning services is managing to enforce them.

From interviews it was established that the monitoring pro-grammes are executed by environmental directorates who do un-notified site inspections. There is the capacity for earmarking fundingfrom the developer for monitoring, however, this practice was notcommon. Actions which can be taken, in case of non-compliance withEIA conditions, can range from issuing a warning to closing downoperations. However, interviewees pointed out that implementationis proving difficult due to the lack of adequate staff and resources.They expressed the need for training and capacity building of the staff,for financial and technical support, as well as for the provision ofequipment and vehicles to enable them to do inspections. Neverthe-less, the status of EIA enforcement was perceived to have improvedfollowing the adoption of the GCEA 2008 procedures.

Regarding mitigation, interviewees pointed out that measureswere being proposed in EIA reports. The issue remained that impactminimisation measures were being implemented rather than avoid-ance measures, due to the aforementioned issue of constructioninitiation prior to EIA report approval.

3.9. Public consultation (criterion 11)

Wood's (2003), criterion 11 refers to whether consultation andparticipation must take place prior to and following EIA reportpublication. According to Art 6 and 8 and participation mechanismdescribed in Annex 4 of the GCEA (2008) procedures, both scoping andthe EIA report need to be made publicly available at the environmentalgovernorate offices for one and twoweeks accordingly, and be followedby public open meetings, thus theoretically fulfilling criterion 11.

However, as analysed in Shepherd and Bowler (1997) and Del Furiaand Wallace-Jones (2000), provision for public participation in theregulations is no guarantee for effective public involvement in terms of asubstantive process which incorporates its views in environmentaldecision making, but is rather often reduced to a procedural exercise.Thus interviewees were questioned with regard to their perceptions ofthe effectiveness of EIA public participation processes based on theirexperience. Experiences differed, between areas and governorates. Someinterviewees claimed never to have undergone such a process, whereasothers commented on a number of difficulties. Firstly, the short two-week consultation period was identified as an important barrier, whencombined with the provision of the EIA report only at the governorateoffices. Publicmeetingsweredescribed as beingpoorly attended, an issueoften described as the Achilles heel of participation (Owens and Cowel,2002), attributed by interviewees to the lack of public environmentalawareness and familiarity with such participation procedures. Indicativeof the limitations of the process is the fact that public access to the EIS isnot provided but rather only copies of the executive summary.

3.10. Monitoring of EIA system (criterion 12)

Regarding the monitoring of the EIA system, such requirementsare not stipulated in the Syrian provisions (GCEA, 2008), thus limitingthe potential for feedback and system improvement (Wood, 2003).However, the provisions in Art. 3, do stipulate a biannual review ofscreening criteria.

3.11. Acceptability of financial costs and time requirements ofEIA (criterion 13)

Wood's (2003) criterion 13 proposes the evaluation of whetherfinancial costs and time requirements of the EIA system are acceptableto those involved and whether they are believed to be outweighed bydiscernible environmental benefits. This criterion is very subjectiveand hard to evaluate. However, in Syrian provision, the requirement toevaluate costs of procedures and mitigation measures is incorporated,indicating that these issues have to be considered by those conductingEIAs. From the interviews it was ascertained that the need for EIA is

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appreciated. However, implementation barriers have minimised theperceived actual benefits occurring from the process. Accounts fromconsultants interviewed and some government officials was thatdevelopers are still doubtful of the value of EIA, yet described this as anearly teething process.

3.12. Strategic environmental assessment (criterion 14)

The final EIA system review criterion proposed in Wood (2003)examines thecomprehensivenessof activities covered, that is toprojects,programme plans and policies, which in Europe has been implementedthrough the Strategic Environmental Assessment (SEA) Directive 2001/42/EC. Although Law 50 in 2002 Art. 5 (see Table 1) makes reference tothe need to set principles and measures to assess environmental effectsin general, to date there has been no further progress in developinglegislation for SEA, of policies plans and programmes, and intervieweeswere not aware of any developments in this direction to be taking place.One of the main values of SEA is its potential for effective alternativesconsideration (Therivel, 2004; Alshuwaikhat, 2005). The significance oftheabsence of SEA in Syria is amplified,when considering the limitationsof the existing EIA alternatives consideration procedures mentionedin Section 3.3, undermining the capacity of EIA to be used as a tool forsustainable development.

4. Conclusion and recommendations

Syria has moved a significant step forward since 2008, with itsadoption of the GCEA procedures, establishing a sound legal frame-work for EIA enforcement. The Syrian EIA system is based on theWorldBank (1991) guidelines, and performed well against the majority ofevaluation criteria proposed byWood (2003). In some cases, the Syrianprocedures proved to be more demanding than the EU Directive, forexample stipulating mandatory scoping, EIS review and monitoringrequirements and provisions for post development environmentalmanagement plans. However, the results of the detailed review oflicensing procedures and interviews revealed a number of weaknesses,not only in the institutional framework but also regarding implemen-tation. The quality of EIA reports was perceived by interviewees to be ofpoor quality and public participation to be problematic in practice. TheEIA's influence on decisionmakingwas consideredweak, attributed to anumber of reasons, such aspoor institutional integrationwithin existinglicensing procedures, persisting exclusion of government projects fromthe process, as well as inadequate technical and financial resources. Theabsence of technical background and necessary guidance in EIA, as wellas baseline environmental information, was underlined as a key issue.However, a number of recommendations, summarised below, emergedfrom this research, which were considered feasible by interviewees,with the proviso that the necessary political will to introduce andimplement them is available.

A. Strengthen EIA integration into existing planning and decisionmaking processes by:• Revising the operation licensing procedure, to ensure that con-struction cannot take place prior to EIA approval.

• Strengthening the role and capacity of the GCEA and its envi-ronmental departments

• To ensure that government projects are not exempt from EIA.• Providing and implementing SEA legislation.

B. Improve the quality of EIA by:• Investing in capacity building and training in EIA methods forboth the public and private sector.

• Developing guidance on scoping review procedures and report-ing requirements

• Providing sufficient baseline environmental information en-abling informed EIA-related decisions.

• Enhancing data availability and information sharing systems.

• Developing clear environmental standards and methods.• Adding a clause to GCEA procedures stipulating EIA system reviewprotocols.

• Creating a database, providing access to EIS, for review and sharingof lessons learnt.

C. Improve effectiveness of public participation procedures by:• Increasing accessibility of EIA reports to the public.• Extending the two-week consultation review period.• Providing facilitation training to environmental departments.• Public awareness raising programmes.

D. Enhance monitoring and mitigation measure enforcement capac-ity by:• Providing governorate investigation subdivisions with the staffand facilities, equipment and requested training to conductinspections and stipulate mitigation measures.

• Providing environmental governorateswith the administrationalpowers and necessary independence to enforce the law andimpose fines on projects breaching environmental managementplan specifications.

To conclude, following the adoption of Syrian EIA procedures andthe growing awareness regarding environmental issues, along withthe reported improvements in EIA practice, there is scope to believethat, should the proposed recommendations of this study beembraced, EIA has a strong chance of fulfilling its role as an instrumentfor the environmental protection of Syria.

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Firas Haydar, is Chief of the Rural Development Division at NAPC and has worked forthe Ministry of Agriculture and Agrarian Reform in Syria since 1995. He has an MSc inEnvironmental Management from the Mediterranean Agronomic Institute of Chania,Greece, and BSc in Agricultural Engineering, from Tishreen University, Syria. His workhas involved rural policy development and his research interests lie in environmentalassessment, policy evaluation and development.

Kalliope Pediaditi is a Research fellow and EIA lecturer at the Mediterranean AgronomicInstitute of Chania, in Greece, who received her PhD Degree in the field of developmentsustainability appraisal and monitoring from the University of Surrey, Guildford, UK. Shehas worked as a strategic environmental planner in the UK, after receiving her MSc inTourism and Environmental Management at Oxford Brookes University and BSc inEnvironmental Science from the University of Greenwich. Her current research interestsinclude environmental assessment, decision making and environmental governanceprocess analysis and optimization.