OCCASIONAL PAPER SERIES
NO 8 – December 2010

Cumulative Environmental Effects and the
Tyranny of Small Decisions: Towards Meaningful
Cumulative Effects Assessment and Management

By
Bram Noble

This paper is based on the Natural Resources and Environmental Studies Institute
Annual Lecture presented by Dr. Bram Noble, on 19 March 2010. Dr. Noble is
with the Department of Geography & Planning, School of Environment and
Sustainability, University of Saskatchewan, Canada.
The correct citation for this paper is:
Noble, B. 2010. Cumulative Environmental Effects and the Tyranny of Small Decisions:
Towards Meaningful Cumulative Effects Assessment and Management. Natural Resources
and Environmental Studies Institute Occasional Paper No. 8, University of Northern British
Columbia, Prince George, B.C., Canada.
This paper can be downloaded without charge from http://www.unbc.ca/nres/occasional.html

Noble  Towards Meaningful Cumulative Effects Assessment

ii

The Natural Resources and Environmental Studies Institute (NRES Institute) is a
formal association of UNBC faculty and affiliates that promotes integrative
research to address natural resource systems and human uses of the environment,
including issues pertinent to northern regions.
Founded on and governed by the strengths of its members, the NRES Institute
creates collaborative opportunities for researchers to work on complex problems
and disseminate results. The NRES Institute serves to extend associations among
researchers, resource managers, representatives of governments and industry,
communities, and First Nations. These alliances are necessary to integrate
research into management, and to keep research relevant and applicable to
problems that require innovative solutions.
For more information about NRESI contact:
Natural Resources and Environmental Studies Institute
University of Northern British Columbia
3333 University Way
Prince George, BC Canada
V2N 4Z9
Phone: 250-960-5288
Email: nresi@unbc.ca
URL: www.unbc.ca/nres

iii

Occasional Paper No 8
December 2010

CONTENTS
Abstract ........................................................................................................................................... 2
Introduction ..................................................................................................................................... 3
Cumulative Environmental Effects ................................................................................................. 3
The State of Cumulative Effects Assessment ................................................................................. 4
Not seeing the forest for the trees ................................................................................................... 5
Conflicting mandates ...................................................................................................................... 6
Matters of scale ............................................................................................................................... 6
Improved efficiencies at the cost of effectiveness .......................................................................... 8
Toward Meaningful Cumulative Effects Assessment..................................................................... 9
Rethinking our assumptions and approach to cumulative effects ................................................... 9
Integrating CEA silos .................................................................................................................... 11
A strategic framework for CEA .................................................................................................12
Developing capacity to act ............................................................................................................ 14
Conclusion .................................................................................................................................... 15
References ..................................................................................................................................... 17

1

Occasional Paper No 8
December 2010

Abstract
Recognizing that each additional disturbance
in a region can represent a high marginal cost
to the environment, there is an increasing
awareness of the need to better assess and
manage cumulative environmental effects.
Yet, cumulative effects are one of the most
perplexing issues in environmental assessment
and natural resource management, and the
practice of cumulative effects assessment has
been falling significantly short of its promise.
Practiced largely in the context of projectbased decision making, the current approach
to cumulative effects assessment does not
provide the results needed to understand
broader environmental change or to make
longer-term
decisions
concerning
the
sustainability of current and future
development actions. This paper attempts to
unpack the current approach to cumulative

effects assessment, and to identify a means to
move toward more meaningful practice. It
argues that cumulative effects assessment
requires a much more integrative and strategic
framework than what is currently practiced,
operating at a regional scale and both
informing and informed by higher level
policies and plans and lower level project
actions. In order for this to happen, we must
rethink our assumptions about the nature of
cumulative effects; move toward the
integration of assessment, science, and
management; and invest in the capacity
needed to implement and sustain cumulative
effects assessment systems and practices.

Noble  Towards Meaningful Cumulative Effects Assessment

2

Introduction
At least one of Canada‘s major western river
systems is more than 100% allocated for water
usage (Schindler and Donahue 2006).
Between 1966 and 1976, and 1996 and 2006
cumulative annual flow in the Athabasca
River decreased by more than 500 m3/s and
temperature increased by 1.4°C (Squires et al.
2010). There are more than 1,500 gas wells
and over 3,000 km of roads in a 1,900 km2
area of native prairie and active sand dunes in
southwest Saskatchewan (Noble 2008). In
hindsight, the cumulative effects of seemingly
small and isolated decisions are easily
recognizable. When planning for the present
and future development of the environment
and natural resources, however, cumulative
effects seem quite elusive.
The notion of cumulative effects is by no
means new, and cumulative effects assessment
(CEA) has been central to debate in Canadian
environmental assessment (EA) for more than
35 years. However, and notwithstanding the
volumes of academic literature on the subject,
numerous case studies, increased public
awareness, and evolving guidance and
regulation, cumulative environmental effects
appear to go ‗unchecked‘ when decisions are
being made about proposed development
actions.
The effects of human development on the
landscape, when assessed, continue to be
assessed and managed on a project-by-project
basis with little regard for desirable futures,
outcomes, assimilative capacity, or the effects
that might result from proposed initiatives in
combination with other past, present, and
future anthropogenic-induced disturbances. As
a result, recent reviews of the state CEA in
Canada suggest that CEA is simply not
working; it remains limited in spatial and
temporal scale, and reactive and divorced
from the broader planning and decisionmaking context (see Harriman and Noble
2008).

3

This paper attempts to ‗unpack‘ the current
practice of CEA in Canada, and proposes a
means to rebuild and move forward toward
meaningful CEA and management. In the
section that follows, the nature of cumulative
environmental effects is introduced. This is
followed by a critical analysis of CEA and the
factors contributing to its current state of
practice. Attention then turns toward
requisites for meaningful CEA, arguing the
need to: rethink our assumptions about
cumulative effects; integrate the current silos
of
CEA
assessment,
science,
and
management; and invest in the capacitybuilding requirements to implement and
sustain effective CEA systems and practices.

Cumulative Environmental
Effects
There is no universally accepted definition of
cumulative effects, and various definitions
have been proposed including:
 the accumulation of human-induced changes
in Valued Ecosystem Components (VECs)
across space and over time that occur in an
additive or interactive manner (Spaling and
Smit 1993);
 changes to the environment caused by an
action in combination with other past,
present and future human actions (Hegmann
et al. 1999);
 effects of a project under review in
combination with the effects of other past,
present or future human activities (US
NEPA CEQ Regulations); and
 the temporal and spatial accumulation of
change in environmental systems in an
additive or interactive manner (Spaling and
Smit 1995).
Peterson et al. (1987), Sonntag et al. (1987),
and Hegmann et al. (1999) further identify
four broad types of cumulative effects: i)
Occasional Paper No 8
December 2010

linear additive effects, that are incremental
additions to, or deletions from, a fixed storage
where each increment or deletion has the same
individual effect; ii) amplifying or exponential
effects, where each incremental addition to, or
deletion from, a resource base has a larger
effect than the one preceding; iii)
discontinuous effects, where incremental
additions have no apparent effect until a
certain threshold is reached, at which time
change occurs rapidly; and iv) structural
surprises, when changes occur as a result of
multiple stressors or activities in a defined
region. Simply put, cumulative effects are not
only additive in which individual actions
contribute incremental levels of disturbance,
but also synergistic in which the total effect of
interactions can be greater than the sum of
effects of individual processes (Seitz et al.
2011).
Now common terminology within the impact
assessment and environmental management
community, it was not until the mid-1980s, as
a priority of the Canadian Environmental
Assessment Research Council (CEARC)
(Duinker 1994), that cumulative effects and
CEA started to receive any real attention.
Cumulative effects assessment is broadly
understood to be the process of systematically
assessing impacts resulting from incremental,
accumulating, and interacting stressors over
space and time (Noble 2010, Squires et al.
2010). It refers to the process of analyzing
and assessing cumulative environmental
change (Spaling and Smit 1993)—that is,
identifying environmental effects, and
pathways that lead to those effects, in order to
avoid, wherever possible, the potential triggers
and stressors that lead to cumulative effects.
When CEA first emerged in Canada it was
largely concerned with stressor-based impact
prediction or predicting the direct, indirect,
and cumulative impacts and interactions
resulting from the actions of a single project
development (see Dubé 2003). The objective
was, and often still is under project-based EA,

to identify how stressors associated with a
proposed physical undertaking might affect
environmental components, and how such
impacts might accumulate or interact with
other environmental components affected by
the same undertaking within the local spatial
and temporal environment of the proposed
project.
The assessment of cumulative environmental
effects is now an accepted part of many
project-based EA systems and regulations
across Canada (see Hanna 2009). In 1995,
CEA became mandatory in Canada for all EAs
completed at the federal level under the
Canadian Environmental Assessment Act:
“Every screening or comprehensive
study shall include a consideration of
any cumulative environmental effects
that are likely to result from the project
in combination with other projects or
activities that have been or will be
carried out”. Sec. 16(1) (a)
In practice, however, reviews of the state of
CEA in Canada suggest that the practice of
CEA is falling significantly short of its
promise.

The State of Cumulative Effects
Assessment
Recent literature identifies several areas of
deficiency in how we approach and manage
cumulative environmental effects, including a
weak interpretation of cumulative effects and
a sustained focus on project approval rather
than sustainability (e.g., Baxter et al. 2001,
Dubé 2003, Noble 2005, Duinker and Greig
2006, Seabrook et al. 2006, Harriman and
Noble 2008). Seitz et al. (2011) point out
specific shortcomings concerning the lack of
due consideration of cumulative effects in
development decisions, arguing that amongst
the major shortcomings is the limited spatial
and temporal scale of assessment, the lack of a
sound scientific basis, and the lack of
consideration of the interacting effects of

Noble  Towards Meaningful Cumulative Effects Assessment

4

multiple stressors over space and time. As a
result, and for various reasons discussed
below, Duinker and Greig (2006: 153) suggest
that ―…continuing the kinds and qualities of
CEA currently undertaken may be doing more
harm than good.‖

Not seeing the forest for the trees
The first issue concerns the scope of current
EA practice and what doesn’t get assessed.
Cumulative effects are often characterized as
‗death by a thousand cuts‘, or the ‗tyranny of
small decisions‘; but cumulative effects are
rarely recognized as such in practice. For
many small projects (e.g., access roads,
culverts, oil exploration blocks), assessments
are too restricted in both time and resources to
effectively integrate CEA science – if such
projects are assessed at all (Seitz et al. 2011,
Noble et al. 2011).
In southwest Saskatchewan, for example, a
1,940 km2 land base, consisting of many rare
and endangered environmental features, and
landscapes of significant Aboriginal value
(Scientific Advisory Committee 2007), is
subject to the pressures of approximately
1,500 natural gas wells, cattle grazing, and
more than 3,000 km of roads and trails (see
Noble 2008). Natural gas development in the
region commenced in the early 1950s; current
production is estimated at over 180 billion ft3
with proven, probable and possible reserves
estimated at nearly 670 billion ft3 (see GLJ
Petroleum Consultants Ltd 2006). Gas leases
and land leased for future gas development
account for approximately 70% of the total
land base (Scientific Advisory Committee
2007). Of the 1,500 wells in the area, only 5
proposals were subject to full environmental
assessment (MacFarlane 2006), all of which
concluded non-significant environmental
impacts. There was no discussion of potential
cumulative effects.
Part of the reason for this type of cumulative
effects scenario is that in many EA systems

5

potential cumulative effects are simply
‗screened out‘; individual developments are
evaluated independently of other activities on
the landscape, and thus deemed ‗unlikely‘ to
cause significant adverse environmental
effects. There is no real opportunity for the
consideration of cumulative effects. Most
jurisdictions in Canada, and internationally,
allow for more or less ambitious streams of
assessment depending on the nature of the
proposed development and the potential for
unknown or significant effects. At the
Canadian federal level, for example, there are
four different types of assessment, each
addressing projects of increasing complexity
and significance: screening assessment,
comprehensive study, mediation, and review
panel. Approximately 99 percent of all federal
EAs are screening assessments – the most
basic level of assessment, designed for routine
undertakings where the level of uncertainty is
considered low (see Herring 2009), and
significant effects, in particular cumulative
effects, are seen as unlikely.
In 2007, for example, the Saskatchewan
Ministry of Highways and Infrastructure
received approval for an approximately 110
km highway-twinning project to improve the
transportation corridor between two of the
province‘s major urban centers. A permit was
granted for highway twinning in the absence
of any environmental assessment. The only
requirement for managing the project‘s
potential impacts was set out in the
construction permit, stating: ―wetland and
upland mitigation guidelines for road
construction‖ shall be adhered to (see Nielsen
2010). The project was approved in absence of
EA based on the notion that, should proper
mitigation be followed, significant effects
were unlikely. As of late 2009, approximately
23 km of highway have been twinned and are
in use. Nielsen (2010) has since shown that
more than 120 wetlands, wholly or in part
(50.08 ha), are located within the 31 m
highway right-of-way construction zone and
Occasional Paper No 8
December 2010

will be directly affected; 458 wetlands (1,115
ha) are located within 500 m of the highway
and considered at risk in terms of functional
loss due to project actions and other induced
actions (e.g., agricultural land drainage
practices) associated with new road and ditch
constructions (see Noble et al. 2011). Under
such approaches to project assessment,
potential cumulative effects are screened-out
of not only impact assessment, but also impact
management.

Conflicting mandates
The second issue concerns the oftenconflicting mandates of the processes in place
to assess and approve development projects,
and the intent of CEA. The goal of proponents
when entering into EA is to secure project
approval – to minimize the potential
environmental effects of their project, or at
least propose to do so, to the point of public
and regulatory acceptability (Gunn and Noble
2010). The focus of assessment is thus on
assessing and finding ways to minimize or
manage project stressors. Viewed in this way,
cumulative effects are understood to be
accumulated ‗environmental stressors‘ and
refer to the direct and incremental effects of
that project within the project‘s activity area,
in combination with other projects. The
proposed project serves as the focus of
assessment, and emphasis is often on
mitigating the additive contributions of the
project. Under this sort of practice, Seitz et al.
(2011) argue that scientific integrity in
assessing and evaluating cumulative effects is
typically limited to the extent necessary to
obtain project approval:
“Project proponents are required under
the
Canadian
Environmental
Assessment Act, and also under
various provincial EIA laws and
regulations, to include CEA in
evaluating the environmental impacts of
their projects; however, the ultimate
goal for proponents is to obtain project

approval. As such, CEA in practice
frequently operates in such as way that
meets the needs of project proponents
in securing project approval, rather
than assessing cumulative effects”
(Seitz et al. 2011)
In contrast, cumulative effects can be viewed
from the perspective of the environmental
response of a single receptor to total stressors
in a region. Under this view, CEA is focused
first on the ways in which an environmental
component or variable (e.g., water quality)
responds to the various contributions and
withdrawals of human actions (e.g., projects,
land disturbances, run-off), and then on
managing and directing current and future
developments
and
land-uses
(e.g.,
management strategies, targets, thresholds)
that may cause further impact on that
component or variable of concern (Canadian
Council of Ministers of the Environment
2009, Noble and Gunn 2010). Assessing and
managing the cumulative effects of all actions
from the point of view of the environmental
receptor is the key mandate - as opposed to
evaluating, and minimizing to the point of
acceptability, the individual stressors of a
single project.

Matters of scale
In practice, cumulative effects are typically
assessed at the spatial scale of the individual
project, which is characteristic of projectbased EA (Dubé 2003, Seitz et al. 2011). This
project scale alone, however, is highly
inadequate for capturing and managing
cumulative effects; individual projects
contribute only a small amount of impact or
disturbance to resources and ecosystem
functioning when considered next to the
interacting processes that occur among
multiple disturbances (Duinker and Greig
2006, Seitz et al. 2011, Noble et al. 2011). In
recognition of the complexity of pathways and
often-synergistic nature of cumulative
environmental effects, there is general

Noble  Towards Meaningful Cumulative Effects Assessment

6

agreement that CEA must go beyond the
evaluation of site-specific, direct and indirect
project impacts to encompass broader regional
understandings and considerations of the
sources of cumulative environmental change
(e.g., Kennett 2002, Dalal-Clayton and Sadler
2005, Duinker and Greig 2006, Canadian
Council of Ministers of the Environment
2009). This is recognized also by the
Canadian Environmental Assessment Act, at
least in principle, which states:
“The results of a study of the
environmental effects of possible future
projects in a region, in which a federal
authority participates, …may be taken
into account in conducting an
environmental assessment of a project in
the region, particularly in considering
any cumulative environmental effects
that are likely to result from the project
in combination with other projects or
activities that have been or will be
carried out.” (sec. 16 (2))
Adopting a regional approach to assessing and
managing cumulative effects under the current
constraints of EA practice is, however, overly
ambitious. Notwithstanding the intent, CEA is
often well beyond an individual project
proponents‘ capabilities, and requires the
participation and cooperation of regulators,
stakeholders, and developers to establish
environmental objectives and manage
development on a regional basis, guided by
broader
environmental
planning
and
sustainability goals. The problem, explains
Creasey (2002), is that effectively assessing
and managing cumulative effects requires
going beyond a proponent‘s responsibility to
manage incremental project effects, and
having to address impacts beyond its
immediately observable footprint. Problems
surface when proponents attempt to address
regional environmental management; that is,
the effects of activities other than the one(s)
that they have proposed. Assessing cumulative
effects beyond the project is a complex

7

undertaking that requires a level of
conceptualization, analysis, and coordination
that is beyond the knowledge, capacity, and
mandate of project proponents (Gunn and
Noble 2009a); unfortunately, neither is it
always within the purview of provincial or
regional authorities 1 . More regionally-based
approaches to CEA necessitates information
sharing and knowledge on a scale much
greater than what is traditionally practiced in
project-based EA; it requires knowledge of the
current actions and proposed development
plans of entirely different industries.
In the case of Cardinal River Coals (CRC)
Ltd.‘s Cheviot Coal Mine in west central
Alberta, for example, the proponent expressed
two valid concerns about its requirement to
assess potential cumulative effects: first, many
factors affecting the regional environment
were not solely the result of activities
associated with the proposed project; second,
information essential to understanding the
effects of other land uses within the region
was not available to the proponent (Kennett
2002, Logan and Ferster 2002). With no
formal mechanism in place to acquire regional
information, the proponent was left to depend
upon the goodwill of other industries and
organizations to support its assessment of
cumulative effects (Creasey and Ross 2009).
The message here is not that proponents
should not be required to consider the
implications of their projects in the larger,
regional context, but that the mandates of
project-based EA and of CEA do not always
align. What is needed and typically expected
of CEA is often beyond the scope and
mandate of an individual proponent; yet,
legislated project-based EA is currently the
1

See, for example, Creasey and Ross’ (2009)
discussion of the challenges to proponent-based
CEA at the Cheviot Coal mine, Alberta (also
discussed in this report); and Law et al.’s (2005)
analysis of CEA and monitoring under the
Cumulative Environmental Management
Association in Alberta’s Oil Sands region.
Occasional Paper No 8
December 2010

primary vehicle for CEA implementation.
Neither project-based EA nor the institutions
in place to manage the process operate at the
appropriate scale or hierarchy to address
cumulative environmental change (Horak et
al. 1983).

Improved efficiencies at the cost
of effectiveness
The third issue concerns the mantra of
efficiency, and the push toward making EA
faster, more predictable, less expensive, and
less intrusive. There either is a belief that ‗fast
EA is better EA‘, in the sense that it doesn‘t
get in the way of project timelines, or there is
a gross misunderstanding that process
efficiencies and outcome effectiveness are
necessarily related. Either way, fueled by a
stagnating economy, there is increasing
pressure to streamline or completely avoid EA
applications.
In March 2009, for example, a regulatory
reform package under the Canadian
Environmental Assessment Act provided
targeted adjustments to the federal EA process
for projects funded under the Building Canada
plan. The regulatory package exempts certain
developments from EA. Such projects are
deemed to have ‗insignificant‘ environmental
effects. The exemption is in effect until at
least March 2011. Examples of exempt
projects include a variety of buildings, roads,
bus and rapid transit systems, and new water
supply systems. Typically, such projects
involve less than $10 million in federal
investment. It is estimated that as many as
2,000 infrastructure projects over two years
may be exempted from the requirement for
federal environmental assessment. In the
absence of individual assessment, the
cumulative effects of these many small-scale
infrastructure projects on the landscape go
unchecked.
More recently, in March 2010, coinciding
with the Federal budget, the Minister of

Finance announced $11 million to support the
acceleration of the review process for resource
projects in the North and proposed several
new initiatives to improve the federal
regulatory system, reducing red tape and the
administrative burden for potential developers.
In his announcement the Minister noted: ―The
resource potential in Canada's North is world
class, yet potential investors in northern
resource projects face complex and
overlapping regulatory processes that are
unpredictable, costly and time consuming."
Similarly, in British Columbia, in October
2010, Premier Campbell announced a major
restructuring of ministries within the
provincial government with respect to the
management of natural resources 2 . The
restructuring would create a new ministry,
Natural Resource Operations, which would
take over many of the responsibilities of
current
resource
ministries
including
Agriculture,
Forestry,
Energy,
and
Environment. The premier noted: ―This new
structure
will
streamline
government
processes for critical natural resource
industries to ensure we can better attract
global investment and turn proposed projects
and investments into actual worksites and
jobs.‖ Concern has been raised by various
organizations over the reorganization and the
potential tradeoff of environmental precaution
in favour of efficient resource development
approvals3.
Neither the economy nor any industry is likely
to collapse due to the pressures of EA
(O‘Riordan 1982). This ‗get to yes‘ syndrome
for project approval may be at the cost of
doing effective EA, and the avoidance of
potential cumulative effects. There is far too
much attention on improving efficiencies in
2

See Government of British Columbia, Office of
the Premier, News Release 2010PREM0191001330, October 25, 2010 ‘Premier Campbell
announces cabinet changes’, available at
www.news.gov.bc.ca.
3
See http://greenpolicyprof.org/wordpress/.

Noble  Towards Meaningful Cumulative Effects Assessment

8

the EA process to ensure that EA gets done on
time and does not interfere with proposed
development timelines, and that consultation
obligations are being met, than there is on
ensuring that the best decisions are being
made in support of sound environmental
management. There is, of course, a need to ‗do
things right‘, and an efficient EA process is
important to timely and informed decision
making. At the same time, however, it is
necessary to ‗do the right things‘ and ensure
that EA, when applied, is a useful tool for
making informed decisions about proposed
development initiatives. Delays in EA are not
caused so much by EA itself as by the failure
of the planning and decision-making system to
accommodate its findings - the goal is simply
to prevent ―environmentally-idiotic‖ decisions
(O‘Riordan 1982).

Toward Meaningful Cumulative
Effects Assessment
If we are to advance CEA practice and
management beyond the current state, toward
meaningful CEA, then there is a need to: i) rethink our assumptions about cumulative
effects and about what we think we know
about complex environmental systems; ii)
integrate the current silos of assessment,
science, and management in CEA practice;
and iii) build the capacity to actually
implement and sustain CEA systems and
frameworks. ‗Good‘ CEA and management, at
a minimum, is:
 Futures-oriented: concerned about possible
futures and the means to shape sustainable
outcomes.
 Alternatives-based: focused on identifying
and systematically assessing alternative
development scenarios associated with
different initiatives, management plans, or
courses of action.
 Integrative: part of, and provides overall
guidance to, the development of regional
strategies and initiatives.

9

 Adaptive: expecting to modify and adapt
regional plans and development initiatives
as new knowledge is gained through
implementation, monitoring, and feedback.
 Valued ecosystem component (VEC)centered: focused on effects to VECs that
are of scientific relevance and public
concern.
 Multi-scaled: able to account for
perturbations and processes operating at
multiple spatial scales within and outside the
region.
 Ecosystem-based: defined by ecological
rather than political or administrative
boundaries, with attention to important
ecosystem relationships and pathways and
processes of change.
 Multi-sector: encompassing of the activities,
policies, and plans of multiple sectors that
may exist in a region or that may influence
regional processes of change and decisionmaking.
 Multi-tiered: informed by, and informs,
other existing or proposed policies and plans
influencing the region, and is deliberately
tiered toward downstream development
assessment and decision making processes.
 Opportunistic: embracing of the opportunity
to examine regional development through
broader stakeholder debate, and to create or
modify institutional arrangements in support
of sustainability.
(See Noble and Storey 2001, Dubé 2003,
Duinker and Greig 2006, Retief 2007,
Harriman 2009, Noble and Gunn 2010).

Rethinking our assumptions and
approach to cumulative effects
First, meaningful action in assessing,
preventing and managing cumulative effects
requires that we rethink our assumptions
about, and approach to cumulative
environmental effects (Table 1). As Ross
(1994: 6) points out, ―the environmental
Occasional Paper No 8
December 2010

effects of concern to thinking people are…not
the effects of a particular project; they are the
cumulative effects of everything.‖ In
particular, there is a need to think about limits
of environmental systems in terms of the
types, amounts and rates of development that
can be accommodated, rather than make
development decisions based on perceptions
of an abundant capacity to absorb incremental
human impact. As such, our focus must be
beyond the project level to encompass
regional-scale considerations of cumulative
environmental change (e.g., Dubé 2003,
Dalal-Clayton and Sadler 2005, Duinker and
Greig 2006, Harriman and Noble 2008).
This regional scale is defined by ecologically
significant boundaries, such as watersheds or
eco-regions, and not ones necessarily defined
in terms of project or administrative
boundaries. But, at the same time, it is
important in CEA to be sensitive to multiple
scales so as to not dismiss the significance of
smaller scale, and often seemingly slowerpaced change. In other words, when focusing
attention beyond the individual project at the

regional scale, local disturbances (e.g., project
specific perturbations) must not ‗fall out‘ as
broader landscape-scale disturbances become
the focus (Therivel and Ross 2007).
Appreciating the complexity of cumulative
effects, it is important to accept that direct
cause-effect linkages may not always be
discernable. There is a need to shift our focus
away from detailed impact predictions, and
following-up for accuracy, and focus foremost
on identifying spatial and temporal patterns
and trends of disturbance that can be projected
forward under different assumptions about
growth and development (Seitz et al. 2011).
This may require, for example, identifying
landscape metrics (e.g., edge density,
impervious surfaces, surface disturbance,
industrial footprint) (see Vos et al. 2001) as
indicators in regression and correlation
analyses to provide an indication of ‗causeand-effect‘ relationships between cumulative
change and cumulative effects.
The management of cumulative effects then
becomes the practice of avoidance and
minimization, as opposed to mitigation, and

Table 1. Characteristics of status quo cumulative effects assessment versus
requirements for effective cumulative effects assessment.
Status quo CEA

Required CEA

Assumptions

abundance

limits

Receptors

single media

environmental systems

Spatial context

project

multiple scales

Temporal context

past, present

past, present, future

Scope

regulated activities

all disturbances

Assessment

stressors or effects

stressors and effects

Futures

predicted impacts

possible outcomes

Management

mitigation

avoidance

Monitoring

regulatory compliance

thresholds and capacity

Responsibility

individual proponents

multi-stakeholder

Performance

increased efficiency

increased efficacy

Noble  Towards Meaningful Cumulative Effects Assessment

10

attention is focused on monitoring thresholds
and capacity as opposed to monitoring only
individual
development
projects
for
compliance
with
specified
regulatory
standards. Efficiency must become secondary
to efficacy if we are to become serious about
cumulative effects.

Integrating CEA silos
Second, the current state-of-the-art of CEA
operates in three silos. Project proponents
operate in the silo of stressor-based
approaches to identify and mitigate project
stressors, with governments as gatekeepers.
The scientific and academic community
operate in the silo of effects-based science to
understand ecosystem functioning and
environmental effects in response to landscape
disturbances. Land-use planners and managers
are focused on broader environmental
planning and social matters, while incremental
impacts at the project level continue to
accumulate. These silos need to be better
integrated if cumulative effects are to be
identified, assessed, and effectively managed.
Stressor-based approaches (see Dubé 2003)
occur within the silo of project assessment.
Impacts are analyzed on a stressor-by-stressor
basis, which are ‗summed-up‘ to determine
the total impact of a project. Environmental
components are considered only if they are
likely to be significantly affected by the
project. The problem is that many cumulative
effects are not directly associated with the
impacts of any individual project or stressor
per se.
As a result, environmental
components that are only indirectly affected
are not considered, regardless of the potential
for cumulative interaction (Baxter et al. 2001).
For small projects, assessments are too
restricted in both time and resources to
effectively integrate the science needed to
assess and understand cumulative effects – if
such projects are assessed at all (Seitz et al.
2011). Divorced from science and the broader
planning context, stressor-based approaches

11

offer little understanding of cumulative
environmental effects (Creasey 2002, Duinker
and Greig 2006, Harriman and Noble 2008).
Opposite stressor-based assessment is effectsbased science, concerned with measuring
actual environmental responses (see Dubé
2003). Emphasis is on understanding the
conditions of a particular environmental
parameter, as a function of all stressors in a
region, and comparing that condition to some
reference condition in order to determine
cumulative change. Effects-based approaches
have the potential to establish carrying
capacities or critical thresholds, and to assess
potential cumulative threats through regional
monitoring (Quinn et al. 2002, Seitz et al.
2011). In practice, however, effects-based
studies are often ―one-offs‖ with some, but
typically limited influence on development
decision-making and, in particular, on the
design
and
approval
of
individual
development projects (Noble 2008). Rarely is
there
authority
to
implement
recommendations (Spaling et al. 2000), and
the process itself is often focused on
measuring change in past and present
conditions, rather than also modeling potential
system response to different future scenarios
of disturbance (Harriman and Noble 2008).
The third silo concerns land-use planning and
management. There is considerable potential
at this high-level to integrate cumulative
effects into development planning and policymaking; however, as Schindler and Donahue
(2006) argue with reference to Canada‘s
waterways and watersheds, land managers and
policy makers seldom, if ever, consider the
cumulative effects of human activity. They go
on to say that there is little integrated planning
and that science is often poorly represented in
the planning process. Though challenging, the
science of CEA must be understood by landuse planners and managers and used to inform
land-use decisions and plans and policies for
future development (see Seitz et al. 2011).
This can be conflicting for those that must
Occasional Paper No 8
December 2010

Figure 1. Simplified regional strategic environmental assessment framework
Source: Gunn and Noble (2009b)

identify and translate strategic visions and
goals into operational mandates and decisions,
particularly when everyone‘s primary interest
is to deliver on their particular policy or plan
mandate (Harriman and Noble 2008).
A strategic framework for CEA
Each of the above silos is valuable in its own
right; however, the current piecemeal
approach is at odds with the pursuit of
effective CEA and management. There is a
need to better integrate assessment, science,
and planning and to do so at the regional and
strategic tier if any of these silos, individually,
is to be meaningful in facilitating the early
identification, possible avoidance, and
eventual
management
of
cumulative
environmental
effects.
Assessing
and
managing cumulative effects requires a
proactive and futures-oriented approach. It
requires a supporting strategic framework to
identify and systematically assess alternative
trajectories and future outcomes within a
region, prior to taking decisions and
implementing a predictive framework to
evaluate the impacts of project-specific
development activities (Harriman and Noble
2008).

In 2008-2009 the Canadian Council of
Ministers of Environment sponsored a
program of research to develop a more
integrative and strategic framework for
assessing
and
managing
cumulative
environmental effects – Regional Strategic
Environmental Assessment (R-SEA) (see
Gunn and Noble 2009b). The intent was not to
introduce a new layer of legislated assessment
for cumulative effects, but to re-conceptualize
the relationship between the current silos of
cumulative effects initiatives. The product was
a framework (Fig. 1) and methodological
guidance 4 to systematically evaluate the
cumulative effects of multi-sector land and
resource uses and surface disturbances in a
region – evaluating past, present and
alternative future scenarios and conditions of
development, asking ‗what if‘ questions about
cumulative change to inform regional
sustainable development (Gunn and Noble
2009b).

4

See CCME (2009) and appended background
papers, and Gunn and Noble (2009b), for a
discussion of R-SEA methodological guidance
and supporting tools.

Noble  Towards Meaningful Cumulative Effects Assessment

12

Table 2. Characteristics of regional-strategic environmental assessment
Typical proponent

Government; regional planning or administrative authority; public-private
partnership; group of industry partners

Trigger

Cumulative change; development of a sustainability strategy; large scale
resource development initiative; need for regional policy, plan or program
development or review

Alternatives
considered

Region-based alternatives or future scenarios driven by broader
sustainability or policy-oriented goals and objectives

Scope

Regionally relevant VECs and indicators of disturbance (e.g., species guilds,
ecosystem services, environmentally sensitive areas, fragmentation, surface
disturbances)

Temporal bounds

Past conditions, current conditions, and longer-term futures

Spatial bounds

Planning or resource region as defined by natural entities such as
watersheds or other eco-regions

Sources and
pathways of effects

Activities of multiple sectors and disturbances, including natural change

Impact analysis

Associations and relationships between VEC conditions (effects) and
stressors (e.g., surface disturbances); scenario-based and futures-oriented,
considering implications of and for other regional policies, plans, projects
and exogenous factors

Key CEA questions

What are the potential cumulative effects of alternative future scenarios?
What are the social, economic, and ecological opportunities and constraints
to current and future development plans and initiatives?

Planning orientation

Regional development, regional planning, regional environmental
sustainability
Identifying and monitoring ‘preferred’ land-use patterns and rates of
development (or conservation); enhancing regional sustainability; risk
reduction or avoidance; policy and plan development to direct future landuse activities and decision making; inform project-based EA inputs and
monitoring requirements

Management focus

As a strategic approach, R-SEA has different
features to other types of environmental
studies and assessments for cumulative effects
(Table 2), and recognizing this difference is
crucial to ensuring successful CEA and
management. R-SEA is intended to be an
integrative, regionally based assessment
process, operating above the project tier and
ensuring that knowledge and understanding
about the cumulative effects of future
development possibilities inform the creation
and implementation of regional planning and
conservation initiatives, and trickles down to
improve impact assessment efficacy and

13

project-based decision making (Gunn and
Noble 2009b).
Simply put, R-SEA is about setting an
appropriate pace for a range of regional
development options (e.g., by setting either
targets for development and/or limits on
development), based on knowledge of
ecological, social, and economic thresholds,
values, and capacities. This includes
determining an appropriate or acceptable mix
of types of development, including spatialtemporal configurations, and taking measures
to influence both the positive, by enhancing,
Occasional Paper No 8
December 2010

and the negative, by avoiding or mitigating,
the cumulative effects of development on the
environment. 5 The goal of adopting such an
integrative and strategic approach to CEA and
management is to ensure that planning and
development in a region occurs within the
context of the most desired rather than the
most likely outcomes, and potential
cumulative effects are treated or avoided at
their source.

Developing capacity to act
Good CEA means not only good science and
assessment methods, it also means sound
institutional arrangements and the capacity to
implement and sustain CEA systems and
frameworks (see Peterson et al. 1987, Dixon
and Montz 1995). Based on experiences with
floodplain management in the UK, for
example, Hughes et al. (2001) and Adams et
al. (2005) report that major challenges in
scaling-up from the project to the region lies
not solely in understanding ecological
interactions, but also in the additional
institutional complexity that is involved in
broader scale planning and management
processes and structures.
There has been limited attention to the
institutional and capacity requirements
necessary to support effective CEA and
management. Based on recent research by
Sheelanere (2010) for CEA in the South
Saskatchewan Watershed, recently validated
in the Athabasca, Lower Fraser, and Grand
River Basin watersheds6, a preliminary list of
requisites might include:
5

For an application of R-SEA for cumulative
effects assessment, see Noble’s (2008) report
on the Great Sand Hills lessons and experience.
6
The South Saskatchewan Watershed study is
part of a larger Social Sciences and Humanities
Research Council of Canada funded project at
the University of Saskatchewan to examine
requisites and capacity for watershed scale
CEA. Results from the South Saskatchewan
(Sheelanere 2010) have been validated by the

 A lead agency with the authority, mandate,
and the capacity to commission CEA, guide
monitoring programs, and influence
decisions about land use and project
development.
 Multi stakeholder collaboration, with welldefined roles and responsibilities for the lead
agency, project proponents, scientists, and
other interest groups in terms of establishing
the scope of CEA, identifying appropriate
indicators, informing assessment processes,
decision making, and implementing,
maintaining, and maintaining monitoring
programs.


The
establishment
of
regional
baselines and agreed-upon indicators and
thresholds to prioritize and identify areas of
concern, and to help trigger management
interventions before cumulative effects
exceed acceptable limits.

 Monitoring at the regional and project scale
to understand and manage cumulative
effects, and to feed back into management
plans and programs.
 Data management and coordination to
facilitate standardization and data sharing
amongst regulators, proponents, scientists,
and the public.
 Effective linkages between regional CEA
outcomes and inputs to project-based
assessment, monitoring and decisionmaking.
 Financial and human resources to implement
and sustain, over the long term, EA
programs and requirements (e.g., monitoring
programs, landscape modeling, reporting,
communication, data management and
coordination).
Though this list is demanding, so are
cumulative effects.

researchers in the Lower Fraser, Athabasca,
and Grand River Basin watersheds.

Noble  Towards Meaningful Cumulative Effects Assessment

14

Conclusion
Assessing
and
managing
cumulative
environmental effects has been a pressing
environment and resource problem in
Canadian EA for more than 35 years.
Notwithstanding the volumes of attention to
the subject, CEA seems to be progressing at
glacial pace – if not retreating. This paper set
out to ‗unpack‘ the current practice of CEA,
and identify a means to rebuild and move
forward toward meaningful CEA and
management.
Arguably, the knowledge needed to advance
the current state-of-the-art of CEA does exist,
but this knowledge is contained within the
individual silos of project assessment, regional
effects-based science, and land-use planning
and management. Current project-based EA is
simply the wrong scale at which to manage
cumulative effects, but, as the only legislated
process for CEA, it is an easy target. The
inability for project proponents to address
broader, regional scale cumulative effects as
part of their project assessments, and the
complexity of such an undertaking, has been
well demonstrated. Rather than acknowledge
this problem of scale, however, the knee-jerk
response appears to be increasing the
efficiency of EA by screening out small
projects, which may indeed be cumulatively
significant, rather than providing a larger
context for project developers in which to
adequately asses and manage the cumulative
contributions of their projects to the regional
environment.
Though advances have been made in effectsbased science for CEA understanding and
monitoring, the timing and nature of such
science is not always responsive to the needs
of proponents and regulators when making
decisions about individual project proposals.
What is important to science for evaluating
cumulative change is not always viewed as
important to the affected public or to
proponents and regulators in assessing project

15

impacts and securing project approvals.
Cumulative effects assessment requires more
than knowing the ‗what was‘ and ‗what is‘ in
the current baseline environment, it requires
also an inherently futures-oriented analysis of
‗what if‘ under different possibilities of
development, considering the impacts of
proposed projects.
There also appears to be a disconnect between
land-use planning and management and CEA
science and project impact assessment. There
is an opportunity at the level of policy and
land-use planning to integrate cumulative
effects science and considerations in the
development of land-use plans, strategies, and
visions for future regional development.
Based on experiences in Canada‘s prairie
region and western watersheds, this doesn‘t
appear to be the common practice. Moreover,
there appears to be limited direction, or
influence, from policies and plans in terms of
guiding project specific actions and approvals
downstream – particularly the acceptability of
project actions within a broader environmental
and cumulative effects context.
In order to move forward, and toward a more
integrative and more strategic approach to
CEA and management, there must exist
institutional capacity and the will for the types
of actions and collaborations necessary for
CEA advancement. Seitz et al. (2011) argue
that governments must assume leadership:
establishing objectives and thresholds based
on sound scientific guidance and social policy;
ensuring that point-specific project-based EAs
are relevant to evaluating and monitoring
cumulative effects at the broader regional
scale; and providing direction to development
decision making through terms of reference
set based on knowledge gained from broader
CEA programs. This means that project
proponents may have to bear an additional
cost, meeting not only their project obligations
but also being engaged in broader cumulative
effects monitoring programs. Scientists must
also do a better job of providing useful metrics
Occasional Paper No 8
December 2010

and tools for assessing and predicting effects
within time frames that suit both broad-scale
CEA and management, and point-specific
project proposals. Finally, land-use planners
and managers must give due consideration to
cumulative effects, and the implications of
CEA science, when developing broad policies
and plans, and these policies and plans must
be sufficiently informative to guide decisions
about the nature and acceptability of future
land use and project-specific developments.
In conclusion, the scope and requirements of
CEA and management are big; CEA is beyond
the reach of any single organization, and no
organization currently has the mandate to do
it. This mandate must come from government,
meaning that the current role of government in
facilitating
land-use
planning
and
development in support of sustainability, and
the relationship between government,
scientists, and proponents, may require some

significant change. Solving the cumulative
effects problem and the tyranny of small
decisions requires a much more integrative
and strategic framework – a framework that
can operate at the regional scale, both
informing and informed by higher level
policies and plans and lower level
development projects. This requires that we
rethink our assumptions about cumulative
effects; move toward integration of CEA
knowledge in the current silos of assessment,
science, and management; and invest in the
capacity-building requirements to implement
and sustain effective CEA systems and
practices. We do have the knowledge to do
this, but we have failed to act on it.
Unfortunately, far more attention has been
given to critiquing CEA and simplifying
processes than to advancing value-added CEA
systems and practices to ensure substantive
outcomes.

Noble  Towards Meaningful Cumulative Effects Assessment

16

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