A COMPARISON OF SIX ENVIRONMENTAL IMPACT ASSESSMENT REGIMES

This research paper compares the Environmental Impact Assessment (EIA) regimes of the United States, the Czech Republic, Slovakia, the European Community, the World Bank, and the EBRD. It analyzes these systems across the entire project lifecycle, from initial screening and scoping to preparation, public review, and final decision-making. Key distinctions are noted in who is responsible for preparing and paying for the assessments, the extent of public participation, and the requirement for post-decision monitoring, with NEPA (US) and the Czech/Slovak laws providing contrasting models of government versus proponent responsibility.

• The document compares six Environmental Impact Assessment (EIA) regimes: the United States (NEPA), the Czech Republic, Slovakia, the European Community (EC), the World Bank, and the European Bank for Reconstruction and Development (EBRD). It evaluates them across criteria such as activity types, screening, responsibility for preparation, costs, timing, scoping, review, decision-making, monitoring, and public participation.
• The U.S. National Environmental Policy Act (NEPA), signed January 1, 1970, is described as one of the most comprehensive regimes. It requires an Environmental Impact Statement (EIS) for every recommendation or report on proposals for legislation and other major Federal actions that significantly affect the human environment. Unlike some other regimes, NEPA applies to programs, policies, and proposals for legislation.
• The Czech Republic's EIA law (Act No. 244, effective April 15, 1992) is unique in that it can require EIAs for products already in circulation, whereas other regimes like NEPA apply only to new activities or changes to existing ones. Czech EIAs cover constructions, activities, technologies, policies and programs ('concepts'), and the distribution of products.
• The European Community's 1985 Directive applies to public and private projects likely to have significant environmental effects, specifically 'construction works' and 'other interventions in the natural surroundings and landscape.' It does not apply to policies and programs, though a new directive on that subject was being drafted at the time of the paper.
• The World Bank and EBRD regimes apply only to projects they finance. The World Bank categorizes projects into Category A (full EIA), Category B (environmental analysis), and Category C (neither). The EBRD uses a similar system: Category A (full EIA), Category B (Partial Environmental Analysis), and Category C (no apparent impact).
• Responsibility for preparing the EIA varies by regime. Under NEPA, the federal agency must prepare the EIS, though it may hire consultants. In the Czech Republic, Slovakia, and the EC, the project proponent or developer is responsible. In the Czech Republic and Slovakia, the document must be prepared by an authorized expert with specific certifications.
• Funding for EIAs differs significantly: the U.S. federal government typically pays for EISs even for private projects, while the Czech law makes the project applicant responsible for all costs. The World Bank requires the borrower to pay, though financial assistance may be requested from the Bank.
• Post-decision monitoring is identified as a general weakness across most EIA regimes. The Slovak draft law is an exception, requiring developers to monitor impacts regularly and take corrective measures if observed impacts differ from predictions. The World Bank suggests including a monitoring plan in the EIA document.
• Public participation levels vary. NEPA allows public participation in scoping and requires agencies to respond to public comments. The Czech and Slovak regimes provide for public review of the EIA document and public meetings, but the Czech law does not provide for citizen participation in scoping.
• Regarding the selection of alternatives, none of the six regimes strictly require the most environmentally sound alternative to be chosen. However, NEPA and the Slovak draft act require the decision-making body to explain the reasons for the selected alternative in the final record.

APA

Center for International Environmental Law (n.d.). A COMPARISON OF SIX ENVIRONMENTAL IMPACT ASSESSMENT REGIMES. https://www.ciel.org/wp-content/uploads/1995/01/AComparisonof6EnvReg.pdf

Chicago

Center for International Environmental Law. A COMPARISON OF SIX ENVIRONMENTAL IMPACT ASSESSMENT REGIMES. n.d. https://www.ciel.org/wp-content/uploads/1995/01/AComparisonof6EnvReg.pdf.

Wikipedia

{{cite report |author=Center for International Environmental Law |title=A COMPARISON OF SIX ENVIRONMENTAL IMPACT ASSESSMENT REGIMES |url=https://www.ciel.org/wp-content/uploads/1995/01/AComparisonof6EnvReg.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centerforinternationalenvironmentallawndcomparison, author = {{Center for International Environmental Law}}, title = {{A COMPARISON OF SIX ENVIRONMENTAL IMPACT ASSESSMENT REGIMES}}, institution = {Center for International Environmental Law}, url = {https://www.ciel.org/wp-content/uploads/1995/01/AComparisonof6EnvReg.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }