Greening government
distribution of risk among different groups, yet this begs some important
political questions, such as whether a risk that is concentrated on certain
groups is more or less acceptable than one that is evenly distributed. There
are also wider environmental justice issues concerning the extent to which
socially and economically disadvantaged groups are exposed to higher lev-
els of risk. Certainly, in the USA, heavily polluting factories, incinerators
and waste disposal units appear disproportionately located in neighbour-
hoods populated by minority ethnic groups (Bullard 2000 ). Similarly, few
CBAs identify variations in the incidence of costs and benefits on different
groups (Pearce 1998 ). EIA, in theory, is more likelytopickupthesedistribu-
tional issues, provided the terms of reference are drawn sufficiently widely
tocover the full range of distributional impacts.
To assess whether these administrative techniques improve integration,
wecan return to the twofold case that they bring a more rational approach
toenvironmental decision-making and, in so doing, encourage policymakers
toconsider environmental factors more routinely. Clearly, in most countries,
techniques such as EIA are not yet a routine part of government decision-
making; few bureaucrats automatically consider environmental factors in
thewaythat they automatically check the financial cost of new proposals.
Indeed, the three techniques are still treated with ambivalence or hostil-
ity by many environmentalists: they promise a more systematic and rigor-
ous treatment of environmental factors, but they are frequently used (or
misused) to the detriment of the environment. Yet they are only admin-
istrativetoolsproviding information to improve the policymaking process.
Once certain methodological improvements are made these techniques are
not necessarily inherently biased against the environment. Instead, it is the
waythat powerful actors, particularly government agencies representing
economic interests, use and manipulate these tools to serve their own polit-
ical ends that can unfairly prejudice environmental interests. Despite their
flaws, these techniques, particularly EIA, can help introduce environmen-
tal considerations into the bureaucratic mindset and contribute to social
learning by policy elites (Bartlett 2005 : 54–6). Some positive environmental
outcomes will probably rub off on agency policies simply as a result of their
engagement in the preparation of EIAs, as several American studies confirm.
There may be a creative tension between EIA specialists and other bureau-
crats that contributes to greater environmental awareness among all staff.
Policymakers and developers may learn to anticipate certain environmental
objections and pre-empt a critical EIA by amending proposals accordingly
(Rosenbaum 1995 :212–15). At the very least, the techniques force policymak-
ers to think about the environment – even if they are only looking for ways
to defeat environmentalist objections to a project.
One wider problem is that all three techniques still tend to be used within
thetraditional paradigm in that they are applied to specific decisions rather
than the underlying policy. Thus, although several of the individual road
schemes that provoked anti-road protests in Britain during the 1990s were