Cumulative and synergistic effects are not included. Many questions are not addressed. There is an inherent bias in the composition of the assessors, given their almost exclusive background in engineering. The engineering perspective is largely interventionist with an orientation given to command and control rather than accommodating to the conditions of the natural environment. There is questionable expertise in their designated responsibility field.
Engineers are responsible for the assessment of ecology, hydrology, geology, and geography.
According to their names, the assessors are without representation from the minorities who will be impacted. Pesticide use is integral to the project design. Not all the pesticides to be used are identified. The major pesticides are dipterex, rogor, furandan, phoxim, etc The main pesticides are bavastin, etc. Their impact is not addressed in terms of type of pesticide or concentration.