The role of alternatives analysis in proponent decision-making about hydropower

The alternatives analysis section in ESIA reports has both a procedural function of providing information to support statutory and financial decision-makers and a substantive function of prompting proponents to select lower impact alternatives that avoid or minimise negative environmental and social impacts. The contribution of the alternatives analysis section in ESIA reports to these procedural and substantive aims was tested through examination of ESIA reports for 19 hydropower proposals. Hydropower projects present difficult trade-offs between the benefits of reliable, lower-carbon energy and the environmental and social impacts of acquiring land, blocking rivers, and altering flow regimes. The reports showed little evidence of structured, systematic approaches to either identification or analysis of alternatives by proponents, limited consideration of environmental and social criteria, and often unsound justifications for the preferred alternatives. Notably, in almost of the cases, the ESIA reports were summarising results from earlier engineering feasibility studies indicating that major decisions had already been made well before commencement of ESIA. In 13% of cases, alternatives analysis undertaken as part of the ESIA had some influence on proposal design, and two of the nineteen proposals documented earlier involvement of environmental and social professionals in design optimisation. These findings call into question the utility of the alternatives analysis in ESIA reports in providing information to statutory decision-makers and other stakeholders. While training and guidance for practitioners may help to improve the quality of analysis and reporting, it is possible that poor quality reporting is masking broader issues around ESIA's substantive purposes particularly in realising opportunities to avoid and reduce impacts through design modifications. Lack of agency of ESIA practitioners to challenge decisions made by proponents before commencement of the ESIA process may also be a contributing factor warranting further investigation. Refocussing ESIA procedure on the range of decisions being made by proponents rather than simply informing a final ‘approval’ decision would also likely improve proponent accountability.