The Un-Environmental Review
August 30, 2021

I feel the need to preface complaining about something, which at face value seems to be for the good of the environment, by stating I am not anti-environmental. I rinse and sort my recyclables. I have not owned a car for 6 years and live in an urban area. I try to put my money where my mouth is when it comes to purchasing everything from our mattress to replacing our windows to buy locally manufactured products. I am one of those weirdos that buys organic food, when possible (which is debatable if it is actually better for the environment.) Our household is not perfect, but I feel we are having a lower impact than most people living in the United States. So, when I complain about something that seems to be environmental, you cannot say we are a household that does not care about our environmental impact by eating every meal off Styrofoam plates and driving a gas-guzzling hummer.

In the past, I have written about how the eco-llusion of suburbia, that is, this fully paved over traditional city where most of your life can be done within a 15 minute walk;


People enjoying coffee in the sun in a piazza in Cervara di Roma, Lazio, Italy. better for the environment, than car-dependent suburbia, where everyone has their own patch of grass and tree, but needs to consume several gallons of gas a day just to get around their own community;


Suburban houses in Glendale, Arizona.

Every time there is an infrastructure project or large development going on, the first thing you hear about is the environmental review. Depending on who is talking, this might be called an environmental study, impact study, or impact assessment. These studies can cost millions of dollars and take many years.

At face value, how can you complain against something that has 'environmental' in its name? If someone wants to open a stone quarry, should not we understand the impact on the landscape and have a mitigation plan to restore the eco-system after? Yes, you will not have any objection from me, if environmental review was actually about the natural environment.

Here are some stories that pop-up in the news about environmental review:

Do these costs and delays actually help the environment?

Studying the effect projects have on the natural ecosystem is not bad, but our current implementation of environmental review is very bad because of the following negative effects;

  1. Environmental reviews can delay projects by years and lead to cost over-runs.
  2. When money has been earmarked for a specific project, alternatives get 'studied' and discredited.
  3. We allow bypassing environmental reviews for non-environmental (often political) reasons.
  4. Passing environmental approval gives a false sense of security that the project is good for the environment.

Requiring an Environmental Impact Statement and hundreds of pages of supporting documentation to subdivide a lot into four is just clown bureaucracy.


A property in Roslyn, New York that needs to go through environmental review to subdivide the lot into 4.

I would hate to imagine the countless billable hours this family has spent on engineers and lawyers to subdivide a lot within a city's borders. What benefit to the natural ecosystem is there in requiring this family to do a comprehensive environmental study for a small subdivision that is no different to the millions of other built up areas in the region?

Environmental studies often study alternatives. Does this have any meaningful impact?

I asked the following question on Facebook, Twitter, and the Strong Towns Slack:

Can anyone share an example of an environmental impact statement that caused either:
1) a project to be cancelled for environmental reasons (not because they ran out of funding doing the study!) Or,
2) an alternative that was studied was found to be better than the original proposal and was picked instead?

Nobody got back to me with a concrete example of a project where someone said "We planned to do this thing, but an alternative was found during the environmental study that was better for the environment, so we are changing course and doing that thing instead". If you know of an example, please e-mail me.

The money has already been earmarked so the studied alternatives, even if they are better than the original proposal, will not get selected. For example, New York Governor Andrew Cuomo announced he wanted to build an AirTrain to La Guardia airport. It would be slower than the existing bus services, many people I talk to would prefer a direct subway line than to pay an extra fare and extra transfer (which $17 million was already spent "studying" back in the 1990s!)


Manhattan is to the left. The blue line is a proposal to extend the subway to the airport. The red line is the current AirTrain proposal that will be slower, and require an extra fare.

The environmental study for the AirTrain did actually look at alternatives, but none of the alternatives ever had a chance, even if they were good alternatives, because the governor's instructions were for an AirTrain and the agency's money was earmarked for an AirTrain.

If our mind is made up that this is what we want to do, why would we ever study alternatives, if they have no chance on ever being selected? The only reasons I can think of are to:

We can discredit better alternatives by cherry-picking data. People cherry pick data all of the time. For example, I do not agree with everything about Australia's approach to handling Covid-19, especially requiring exit visa, which means my parents are going to miss the birth of our first child. But, this tweet, which has hundreds of re-tweets and over a thousand likes, shared the following graph, which makes it look as if the virus is out of control and the accumulating lock-downs are doing nothing:


Australia's Covid-19 cases and the start of state-wide lock-downs.

Nothing on this graph is a lie, but they selected what data to show. The graph does not show that most of the lock-downs were temporary (the latest lock-down in my home-state of South Australia, which gets two lines on the above graph, lasted a week). Nor, does it show that the massive increase is confined to a few regions, not the entire country. As of August 29th, of Australia's 1,033 7-day average cases, 1,008, or 97.6%, are from New South Wales.


Positive Covid cases in South Australia. The virus is virtually non-existant outside of New South Wales.

You can dispute cherry-picked data with more data. So, it is even more powerful if you instead have a convincing narrative to explain why the data is in your favour. Let's say that you are working on a website that gives you the weather, and you change the layout that visitors see when they search for their city. If there are 50% fewer clicks after visitors see the weather page you can argue that people are getting all the information they need, so you are saving them time and this is a good thing. If there are 50% more clicks, you can argue that you made it easier for visitors to discover where to go next, so they are spending more time on your website and this is also a good thing.

Say any narrative confidently enough and people will believe it. Fewer people riding the bus? We have made it easier to get things done in fewer trips! Even without explicitly cherry-picking data, if we are being paid to build an AirTrain, bring all the data you want, and we will come up with a narrative to explain why the AirTrain is better than the faster subway.

Seattle's East Link light rail extension studied 24 alternative routes, but somehow the people initially proposing the project magically knew their route was the optimal before any studying was done.

If studying alternatives do not actually change the outcome, what is the point? For when the alternative is brought up as a community meeting, we can confidently shut down the suggestion by saying "we studied that, and here are our reasons why our idea is better."

Environmental reviews do indirectly stop projects, but not for the environmental reasons. It is common for the money to run out during environmental review, the elected official who was pushing the project finished their term and so support for the project fizzles out, or the project gets sued, with the plaintiffs hoping that between the lawsuits and spending millions of dollars and many years of more studies, funding and support for the project will eventually run out.

Environment reviews did not stop us from doing things that we know are destructive for the environment, such as building 160,955 miles of highways, hollowing out cities for parking lots, paving over the country-side for endless suburbia and strip malls.


Did environmental review stop us from approving these highways leading to this sea of parking lot?


A road is Saddle River, New Jersey with commercial uses that are unreachable by anyone not in a motor vehicle.

Getting the stamp of approval after environmental review can give us a false confidence that by marking all the check-boxes and getting approval, we are being good stewards of the environment, despite that the countless freeway expansions and greenfield subdivisions that pass environmental approval today are testimony that the system is broken. Yet, a hotel needs to produce a 7,000+ page environmental impact report on whether redeveloping a hotel in the middle of a city will harm the environment? Our environmental approach is penny-wise but pound-foolish. We fine residents for removing trees, but continue to clear land to widen roads.


The current state of River Road in Sarasota County, Florida being approved for widening.


The rendering of the future state of River Road. Much more land consumed, asphalt laid, trees cleared, and cars on the road.

Environmental studies are important, especially for projects that impact fragile ecosystems. If we are building a desalination plant, we probably want to understand the effect of discharging brine back into the ocean. But, it should not take many years and millions of dollars to study the impact of a new rail line, that essentially runs parallel to existing rail lines, tunnels, and bridges that have been there for a century. Nor should we delay projects by spending time and money studying alternatives when we know it is busywork because the money and political will has been earmarked for a specific project.

If environmental review is really about the environment, why does California's SB 35 allow apartment buildings to bypass environmental review if at least half of the units are below market rate, and you pay contractors reasonable wages? How does any of that affect the natural ecosystem?

The system is broken. We have real environmental issues in the world such as micro-plastic pollution in the oceans, climate change, deforestation, and decreasing bio-diversity yet we slap the word "environmental" onto a review process that has little to do with the protecting the environment.