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This thesis describes a comparative evaluation of the environmental impact assessment (EIA) systems in four countries, including the UK as a developed Western nation and Taiwan, Malaysia and Indonesia as examples of differing rapidly developing countries in South-East Asia. In order to carry out this evaluation, a conceptual framework for analysing an EIA system has been developed. This defined framework provides an uniform basis for examining the insights and effectiveness of the individual EIA systems. The study results showed that ETA has been implemented in the UK through secondary regulations. Guidelines on the ETA procedure are available. Nevertheless, public consultation prior to the submission of an environmental statement (ES) with a planning application is a recommendation only, rather than a statutory requirement. Post-EIA monitoring is required through planning conditions, but not defined in the EIA regulations. Formal appraisal of plans is required for local/structure plans and is undertaken informally for other plans. It was found that EIA implementation by various competent authorities has been inconsistent across the country. In Taiwan, various EIA general and technical guidelines are introduced. A formal requirement for ETA of government policies is included in the 1994 ETA Law. The procedure appears to be quite comprehensive with public participation at the early stage of ETA, i.e. scoping and public presentationlhearing, but not formal channels for appeals. EIA compliance monitoring and enforcement is conducted by an independent Task Force. However, the effectiveness of ETA implementation in practice still needs to be strengthened. Malaysia has devoted considerable effort to improving indigenous ETA capabilities through, for example, EIA training, developing an EIA tracking system and a central database of ETA reports. However, a number of aspects of ETA, including guidance availability, public involvement, ETA compliance monitoring and enforcement, and the effectiveness of implementation in practice, need to be strengthened. In Indonesia, the requirements for an EIA report are quite strict and clear. The linkage of ETA and spatial use management has been established since 1993. There have been considerable technical and financial inputs from Canada. However, aspects, such as guidance availability, public participation, EIA enforcement and implementation in practice, should be enhanced. Based on the study findings, an EIA Evaluation Model and a conceptual framework for a comprehensive ETA system have been developed. It is suggested that competent national authorities can apply the EIA Evaluation Model to identif' the strengths and weaknesses of their ETA systems. The proposed conceptual framework for a comprehensive ETA system can be used as a reference model. Competent national authorities could, then, set out priorities and devote resources to overcome shortcomings and strengthen ETA effectiveness, so that the performance of the ETA systems can be improved. 2

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