Examining 'salami-slicing' in environmental impact assessment : towards a conceptual model

Abstract

Environmental Impact Assessment (EIA) is recognized as a tool and process carried out prior to project initiation to identify significant environmental impacts, with the aim of preventing, minimising, or rectifying said impacts. The effectiveness of EIA in reaching its purpose has, however, been subject to scrutiny and is threatened by a tactic used for EIA circumvention widely known as Salami-slicing (SS), project splitting, or project fragmentation. This tactic has been described as the splitting of a project into smaller segments (i.e. into phases or through territory), such that it does not meet the need for an EIA. While the literature on SS has noticeably increased over recent years, its occurrence within the Maltese Islands has not been documented. This research thus aims to characterize SS in the local context, drawing on inputs of various EIA stakeholders, to identify deficiencies and factors enabling its occurrence, and potential solutions for eradicating or minimising SS. To this end, 10 semi-structured interviews were conducted across four stakeholder groups, namely the competent authority, EIA practitioners and technical experts, developers and legal advisors, and ENGOs. Systems Thinking (ST) was used to frame the analysis, by outlining the different perspectives, distinctions, and relationships leading to SS. Through a hybrid approach of Thematic Analysis (combining deductive and inductive analysis), a thematic framework was developed and contributed to the establishment of a conceptual model, which was visualised using Plectica software. Four overarching themes were identified: understanding of SS (characterization, occurrence), factors or deficiencies enabling its occurrence, perceptions on informal discussions between authorities and developers, and means of addressing SS. The second theme was the most prominent and encompassed sub-themes including resistance from developers to EIA, issues in EIA practice, governance-related issues, weak public participation, political influence and culture, as well as a context-specific weakness pertaining to Local Plans. Recommendations for addressing SS and aforementioned deficiencies were centred on improving governance and regulation, increasing the effectiveness of screening, and enhancing the public participation process. This research identifies several avenues for further research, such as addressing public participation barriers, the application of SEA and its potential in enhancing cumulative impact assessment and reducing SS, and establishing criteria for SS detection and prevention during the screening phase of EIA.