Environmental impact assessments as a mechanism of regulatory intermediation: the case of Israeli wind energy

Abstract

The environmental impacts of infrastructure projects are widely assessed through a procedure known as environmental impact assessments (EIAs). In many regulatory systems, EIAs are carried out by third-party intermediaries. However, their roles and effectiveness within public policy and regulatory governance remain understudied. This study addresses this gap by examining 24 wind energy projects deliberated in Israeli planning committees between 2003 and 2024. Specifically, we ask: (1) What intermediary roles do EIAs and those responsible for their implementation play? (2) What are the strengths and weaknesses of EIAs as an intermediation mechanism? (3) How do these strengths and weaknesses shape their effectiveness? Our analysis identifies five key intermediary roles: two formal roles, which are legally defined—providing advisory services and facilitating enforcement and compliance—and three informal roles, which extend beyond strict regulatory mandates—interpretation, dialogue facilitation, and advocacy. The formal roles ensure compliance with regulatory guidelines and advance environmental expertise, thereby meeting regulatory requirements and contributing to high procedural effectiveness. However, challenges persist, particularly regarding informal roles, which are often influenced by intermediaries’ alignment with developers’ interests. These challenges contribute to relatively low substantive effectiveness, as planning committees frequently find EIAs insufficient for informed decision-making, leading them to seek external consultants for validation. The gap between EIAs meeting regulatory requirements and planning committees’ inability to fully rely on them highlights weaknesses in EIA governance as a mechanism of regulatory intermediation. We argue that formalizing informal intermediary roles with clearer guidelines could improve EIA effectiveness, enhance objectivity, and strengthen decision-making in the EIA framework.

Sustainable infrastructure projects play a pivotal role in shaping the energy transition, mitigating greenhouse gas emissions while providing a significant amount of energy (Thacker et al., 2019). Yet, they may also entail environmental risks: Wind farms can endanger animals and wildlife, hydropower may interfere with water sources, and solar panels may harm the landscape (Vezmar et al., 2014). Evaluating these trade-offs necessitates a structured assessment mechanism known as environmental impact assessment (EIA), which provides a reliable evaluation of environmental impacts and has been institutionalized globally (United Nations, 2018). EIA has emerged as a vital tool facilitating a comprehensive understanding of how infrastructure initiatives can harmonize with or potentially disrupt the delicate balance of ecosystems and natural resources (Morgan, 2012).

This study focuses on EIAs as mechanisms for balancing the benefits and costs of green projects. EIAs represent a form of process-based regulation, where compliance is achieved through systematic methodologies and stakeholder engagement rather than prescriptive outcomes (Gilad, 2010). EIAs aim to ensure that regulatory objectives are integrated into decision-making processes, providing a structured foundation for environmental accountability (Wang et al., 2024). While EIAs may be conducted by either regulators or regulated entities, many regulatory systems rely on third-party intermediaries, which are the focus of this study (Wood, 2013). This approach is widely common around the world in both developed countries, such as the United States, the United Kingdom, the Netherlands, and Australia (Wood, 2013), and developing countries, such as Kenya, Peru, South Africa, and Indonesia (United Nations, 2018).

This study conceptualizes and theorizes EIAs as a mechanism of regulatory intermediation (Abbott et al., 2017a). By doing so, this study provides a deeper understanding of their role beyond technical environmental tools (Andersson et al., 2016; Finnveden & Moberg, 2005), positioning EIAs as prominent policy instruments that may shape decision-making, enhance legitimacy, and influence environmental governance (Abbott et al., 2017b). This approach enables us to contribute both to the literature on regulatory governance (Bowers, 2020; Brès et al., 2019; Kourula et al., 2019) and to the literature on EIAs (Loomis & Dziedzic, 2018; Petts, 2009).

The intermediaries conducting EIAs are positioned between rule-makers (regulators) and rule-takers (regulatees), acting as independent evaluators who ensure that projects comply with environmental regulations while addressing broader stakeholder concerns (Abbott et al., 2017a). Through thorough assessments, EIAs support regulatory bodies in deciding whether to approve, modify, or reject projects based on environmental impacts (Wood, 2013).

The effectiveness of EIAs has been extensively discussed in the literature. Recent studies have shifted the focus from procedural effectiveness—centered on meeting regulatory requirements related to structure and methodology (Arts et al., 2012)—to substantive effectiveness, which prioritizes informed decision-making and considers the institutional design of EIA actors, their responsibilities, and the influence of their reports on policy processes (Caro-Gonzalez et al., 2023). Despite being crafted to meet stringent regulatory standards, EIAs often exhibit a puzzling disparity between procedural and substantive effectiveness: If EIAs are successful in adhering to regulatory requirements, why do they sometimes fall short of providing the solid foundation necessary for confident decision-making (Loomis & Dziedzic, 2018)? This research gap prompts critical questions as to whether formal understanding of the EIA alone is sufficient to understand the decision-making process.

To address this research gap, the study empirically examines the following research questions: (1) What intermediary roles do EIAs and those responsible for their implementation play? (2) What are the strengths and weaknesses of EIAs as a mechanism of regulatory intermediation? (3) How do these strengths and weaknesses influence the effectiveness of EIAs? While prior research has explored intermediary roles individually (Fischer & Guy, 2009; Marques, 2019; Owen, 2021), this study advances the discourse by organizing these roles into a unified framework, specifically applied to EIAs. This framework provides a structured lens to analyze the effectiveness of intermediaries in environmental governance, particularly in the context of EIAs.

To achieve its aim, this study examines the role of intermediaries in EIAs within the Israeli wind energy decision-making process (see  Appendix A). The analysis includes 24 wind energy projects promoted between 2003 and 2024, with capacities ranging from 10 to 20 MW. Israel’s reliance on third-party intermediaries for EIAs reflects a global trend in regulatory governance (United Nations, 2018), making it a representative case for exploring procedural and substantive effectiveness. Wind energy projects in Israel involve a complex network of stakeholders and multifaceted environmental impacts, providing a valuable platform to analyze how intermediaries navigate diverse interests (Eitan & Fischhendler, 2022).

With regard to the first research question, our findings show that EIAs rely on intermediaries fulfilling two formal roles—providing advice and facilitating enforcement—and three informal roles—interpretation, dialogue facilitation, and stakeholder advocacy. Formal roles are structured within regulatory frameworks, while informal roles rely on decentralized networks and interpersonal influence, leading to variability in practice (Brès et al., 2019). With regard to the second research question, while both formal and informal roles have strengths and weaknesses, EIAs’ strengths align more with formal roles, particularly in providing professional environmental evaluations. Conversely, informal roles are more closely associated with challenges, particularly because intermediaries hired by project developers may compromise the credibility and trustworthiness of the EIA process. With regard to the third research question, the EIAs in the case study exhibit strong procedural effectiveness but limited substantive effectiveness. This stems from formal roles that ensure EIAs meet regulatory requirements, as evidenced by their high approval rates in planning committees, but these roles do not necessarily enhance informed decision-making. Informal roles, however, being more dynamic and stakeholder-driven, introduce bias and credibility concerns, leading planning committees to rely on external consultants, who are perceived as more independent and legitimate than the EIAs and those who conduct them.

The gap between EIAs meeting regulatory requirements and planning committees’ inability to rely on them reveals a regulatory shortfall in the governance of EIAs as a mechanism of intermediation, particularly regarding informal roles. The findings of this study, therefore, extend beyond the Israeli case, as many countries rely on third-party intermediaries for EIAs and may thus face similar challenges, including misaligned incentives, insufficient regulatory guidance for informal roles, and a disconnect between procedural and substantive effectiveness (United Nations, 2018). Accordingly, we argue that addressing this issue requires considering the formalization of informal intermediary roles while preserving flexibility and mitigating bias, ultimately enhancing the effectiveness of EIAs in supporting informed decision-making. To achieve this, policymakers should establish clearer regulatory guidelines for third-party intermediaries, ensuring their roles are well defined yet adaptable when necessary. This approach can prevent conflicts of interest, strengthen legitimacy, and improve informed decision-making, particularly in the context of EIAs and environmental governance.

The following section discusses EIAs as a notable mechanism of intermediation, offering a distinction between procedural and substantive effectiveness. Subsequently, we focus on EIAs in the Israeli context. The third section introduces the qualitative methodology employed in this study, following which the study’s findings are elucidated, addressing the three research questions. The final section discusses the results in light of the literature and illuminates the contributions of the study while offering suggestions for future research directions.

Conceptual framework: EIAs as a mechanism of regulatory intermediation

Process-based regulation focuses on designing and implementing structured procedures to achieve compliance, prioritizing systematic methodologies over specific outcomes, as seen in outcome-based regulation (Gilad, 2010). This approach emphasizes methods such as risk assessments, stakeholder engagement, and mitigation planning to address diverse risks and ensure accountability (Deighton-Smith, 2008). EIAs exemplify this regulatory approach by providing a systematic framework for evaluating compliance, assessing environmental risks, and fostering stakeholder participation. These procedural elements ensure that environmental considerations are integrated into decision-making processes, thereby balancing development objectives with sustainability goals (Wang et al., 2024).

Indeed, EIAs are often designed as a comprehensive tool to evaluate the potential environmental, social, and economic consequences of proposed projects, policies, and activities. EIAs provide a structured framework via which decision-makers, stakeholders, and the public can assess the likely impacts of a project before its implementation, thereby potentially facilitating informed choices and responsible development (Morgan, 2012). EIA methodologies have significantly advanced over the years, enhancing their comprehensiveness (Petts, 2009). Key improvements include environmental baseline studies, predictive modeling, risk assessments, cumulative impact assessments, and a broader focus on ecosystems, biodiversity, social and health impacts, as well as cultural and heritage considerations (Anjaneyulu, 2007). Concurrently, countries have updated legal frameworks to expand the scope of projects requiring EIAs, ensure public involvement, streamline processes, appoint authorities, enforce compliance, and integrate EIAs into broader environmental laws and international agreements (Arabadjieva, 2016; Bekhechi & Mercier, 2002; Morgan, 2012).

While EIAs may be conducted by either regulators or regulated entities (United Nations, 2018), many regulatory systems increasingly delegate this function to third-party intermediaries, making regulatory intermediation a central mechanism in environmental governance (Wood, 2013). Unlike regulatory systems where regulators oversee and execute assessments, or where regulated entities commission and conduct EIAs themselves, intermediaries are designated to act as independent entities that translate regulatory requirements into actionable assessments (Morgan, 2012). These intermediaries ensure compliance with environmental standards, provide technical expertise, and, in some cases, mediate between stakeholders to balance competing interests (Tosun et al., 2023). By operating in complex regulatory environments, intermediaries utilize process-based regulation, which emphasizes structured procedures, stakeholder engagement, and risk assessment to navigate diverse regulatory challenges. Their role extends beyond basic compliance to actively shaping the interpretation, credibility, and legitimacy of EIAs as a governance tool (Morgan, 2012).

Regulatory intermediaries may play various critical roles in governance and compliance, aiming to facilitate the implementation of regulations, while serving as a bridge between regulators and the regulated (Abbott et al., 2017b; Sharkey et al., 2023). First, they can act as interpreters and communicators, helping to bridge the gap between complex regulatory frameworks and the individuals or businesses subject to those regulations (Fischer & Guy, 2009). These intermediaries may also offer guidance and advisory services, assisting stakeholders in complying with regulatory requirements and avoiding legal pitfalls (Owen, 2021). In addition, they can facilitate dialogue and collaboration between regulators and the regulated, fostering a more cooperative approach to regulatory compliance (Marques, 2019). They can also serve as advocates for industries and individuals, offering insights and feedback to regulators on the practical implications of their policies (Fransen & LeBaron, 2019). They may also play a role in enforcement, helping to monitor and report noncompliance, which can aid in maintaining the integrity of regulatory systems (Brès et al., 2019). While the literature has discussed these roles separately, this study deepens the understanding of these roles by synthesizing them into a cohesive framework, specifically within the context of EIAs.

Through these various roles, regulatory intermediaries offer distinct advantages in governance and compliance, particularly in the EIA domain, where they serve as an alternative to regulator-driven or regulated entity-driven processes. One key advantage of intermediation is regulatory efficiency. Regulator-driven processes can face bureaucratic inefficiencies that slow down assessments and approvals, while regulated entity-driven processes may prioritize expediency over comprehensive oversight. By contrast, intermediaries streamline regulatory procedures, facilitating smoother communication between oversight bodies and regulated actors, thereby reducing administrative bottlenecks (Kearl, 1983). Another significant advantage is sector-specific expertise. Regulators may lack specialized industry knowledge, while regulated entities tend to focus on securing project approvals. Intermediaries bridge this gap by providing more independent, in-depth assessments informed by technical expertise, ensuring more rigorous and well-substantiated evaluations (Abbott et al., 2017b). Intermediation also fosters innovation and best practices. Regulatory agencies often struggle with bureaucratic inertia, making it difficult to adapt to emerging challenges. Intermediaries, by contrast, operate with greater flexibility and adaptability, guiding both regulators and regulated entities in integrating best practices into compliance strategies (Sovacool et al., 2020).

Another advantage of intermediation is enhancing transparency and accountability. In regulated entity-driven processes, decision-making may prioritize commercial interests, reducing public oversight. Intermediaries introduce an additional layer of scrutiny, helping ensure regulatory compliance while maintaining public trust (Abbott et al., 2017a). Additionally, intermediaries facilitate broader stakeholder participation, which regulated entity-driven processes often deprioritize due to commercial considerations. By ensuring diverse stakeholder perspectives are incorporated, intermediation strengthens the legitimacy of regulatory decision-making (Sharkey et al., 2023). Inclusive governance enhances public trust and contributes to socially accepted regulatory outcomes (Bunea & Chrisp, 2023). Finally, regulatory intermediaries contribute to improving regulatory quality and supporting informed decision-making. Given their professional expertise and regulatory knowledge, intermediaries are often better positioned than both regulators and regulated entities to conduct thorough, unbiased evaluations, ensuring long-term policy effectiveness (Abbott et al., 2017b; Senninger & Blom‐Hansen, 2021).

The agents acting as intermediaries in EIAs can be categorized into formal and informal intermediaries, each playing distinct roles in the regulatory process (Brès et al., 2019). Formal intermediaries are those legally defined within regulatory frameworks, such as state-affiliated agencies or consultants directly appointed by project proponents. Their primary function is to facilitate compliance with regulatory requirements, conduct impact assessments, and produce reports that align with legal and procedural standards (Wood, 2013). Informal intermediaries, by contrast, emerge in less structured, voluntary, or ad hoc frameworks and operate outside direct regulatory mandates. These may include independent consultants, academic experts, and environmental NGOs, which contribute by providing specialized knowledge, fostering stakeholder engagement, and addressing gaps in credibility and accountability (Morgan, 2012). This dual-layer intermediation, involving both formal and informal actors, reflects the evolving complexity of regulatory governance as part of the EIA framework (Wood, 2013).

Beyond their classification as formal or informal, intermediaries also take on distinct functional roles within the EIA process. In this context, intermediaries may engage in both formal and informal roles (Brès et al., 2019). Formal roles are well defined within regulatory frameworks, ensuring that EIAs meet the necessary legal and procedural standards (Christiansen & Piattoni, 2003). Informal roles, by contrast, are not explicitly mandated by regulation but are frequently practiced in reality. These roles operate in a more ambiguous space, where the absence of strict governance can lead to inconsistencies in execution. Notably, even formal intermediaries may engage in informal roles, such as fostering dialogue between stakeholders or interpreting regulatory guidelines in ways not explicitly defined by law. Informal roles often rely on interpersonal connections, decentralized policy networks, and informal channels of influence, shaping the way EIAs are conducted beyond their formal regulatory structure (Christiansen & Piattoni, 2003).

The way intermediaries perform these roles significantly influences the effectiveness of EIAs. Historically, EIA effectiveness focused on procedural aspects related to legal and regulatory compliance, based on criteria such as methods and documentation (Caldwell, 1988). The effectiveness of EIAs in this context is often measured by their ability to meet formal requirements, including the identification and assessment of environmental impacts (Arts et al., 2012).

However, the literature increasingly questions whether adherence to these formal roles alone provides a robust foundation for effective decision-making (Loomis & Dziedzic, 2018). In response, there has been a shift toward emphasizing the substantive effectiveness of EIAs, focusing on their contribution to informed decision-making, associated with a more dynamic, political process that involves various stakeholders as part of the broader decision-making framework (Loomis & Dziedzic, 2018). This approach highlights the legitimacy of the EIA process by incorporating aspects such as community involvement, objectivity, transparency, inclusivity, fairness, and consideration of cumulative impacts (Banhalmi-Zakar et al., 2018). The emerging understanding of EIAs’ effectiveness includes additional components (Fischer & González, 2021), such as assessing both their process and content/outcomes, focusing on actual environmental and social impacts, mitigation quality, sustainability, resilience, long-term well-being, and, most notably, decision-making effectiveness (Caro-Gonzalez et al., 2023).

This evolving understanding has greatly affected the execution of infrastructure projects, particularly in the realm of renewable energy (Bevan, 2012). Renewable energy projects, such as solar farms, wind turbines, hydropower installations, and geothermal plants, play a vital role in combating climate change and promoting sustainability, given their significant energy production combined with minimal emission of greenhouse gases and other pollutions (Ren21, 2022). As the demand for clean energy grows, EIAs have adapted to provide a holistic approach to renewable energy project planning (Hugé et al., 2011), covering site selection, environmental factors, and technology comparisons (Rahman et al., 2017). This shift also emphasizes stakeholder engagement, sustainability principles (Larsen, 2014), cumulative impact assessment (Caine, 2020), and post-construction monitoring (Zwart et al., 2015).

The existing literature acknowledges the potential intermediary role of EIAs, specifically in the renewable energy realm (Gliedt et al., 2018; Wood, 2013), highlighting how they can evaluate potential environmental consequences (Yang, 2017), guide project proponents, ensure compliance with laws, facilitate collaboration (Leknes, 2001), support economic development and environmental protection (Morrison-Saunders & Bailey, 2009), and help enforce regulations for environmental sustainability (Cilliers et al., 2020). However, scholars have yet to conduct a comprehensive exploration of the underlying mechanism via which EIAs and those responsible for them influence the dynamics between regulatory authorities and the regulated, ultimately shaping the effectiveness of EIAs. Accordingly, the next section introduces the Israeli wind energy sector, which we examine to shed light on the intermediary mechanism of EIAs and those responsible for them.

Table 1 summarizes the key concepts presented in this conceptual framework and their relevance to EIAs.

EIAs as a mechanism of intermediation in the Israeli context

The EIA process was initially regulated in Israel by the Environmental Protection (EIA) Regulations, introduced in 1982 as part of the National Planning Law. This was later updated, with the current regulations established in 2003 under the Planning and Construction Laws (Ministry of Environmental Protection, 2023). The EIA process in Israel applies to various outline plans at the local, district, or national levels, including industrial facilities, transportation projects, infrastructure developments, and other endeavors of potential environmental significance (Israeli Government, 2003). In accordance with legal regulations, the project’s developer is obligated to submit an EIA to the appropriate local planning committee. In the case of larger projects, the submission may be directed to the national planning committee (“The Committee for National Infrastructures”). According to law, one-third of a planning committee’s members represent government ministries, another third represent local authorities, and the remaining third are public representatives and planning and construction professionals (Israeli Government, 2023).

The EIA itself must be conducted by a qualified and recognized environmental expert who is selected and compensated by the developer, such as an academic professional, a dedicated consulting firm, or an environmental NGO (Ministry of Environmental Protection, 2023). The Israeli case is, therefore, highly representative of regulatory governance. Like many countries, Israel employs third-party intermediaries to conduct EIA reflecting a model that aligns with widely adopted global regulatory practices (United Nations, 2018). As such, the findings from this study are both context specific and broadly applicable, offering insights that are relevant and generalizable to regulatory systems worldwide.

The EIA in the Israeli case plays a pivotal role in the planning committee’s decision-making concerning the project’s future. It is evaluated alongside other planning considerations, and the committee possesses the discretion to accept, reject, or request additional assessments and modifications based on the EIA’s recommendations. Nevertheless, the conclusions and recommendations presented in EIA reports submitted by the developer are not binding. The planning committee retains the discretion to accept all, some, or none of the recommendations (Ministry of Environmental Protection, 2021).

Regulations meticulously outline the EIA’s structure and methodology, which focus on the formal roles of providing scientific advice to planning committees and supporting their enforcement mechanisms. The EIA should include an overview of the existing environmental conditions prior to the project’s implementation, examine various alternatives and the factors that led to the selection of the preferred option, offer a detailed description of the project, its environmental repercussions, and mitigation measures to address potential adverse effects, and finally draw conclusions based on the preceding assessments and provide recommendations for program regulations (Ministry of Environmental Protection, 2023). The representative of the Ministry of Environmental Protection on the planning committee functions as the committee’s environmental advisor, ensuring that the EIA report submitted by the developer aligns with governmental regulations. The representative has the authority to approve, reject, or request modifications to the report as necessary. This decision primarily hinges on the EIA’s alignment with regulations, mainly in terms of structure and methodology (Israeli Government, 2023).

With regard to wind energy projects, in 2020 the Israeli government announced renewable energy targets as part of an official government decision, promising that by 2025, 20% of electricity production would be based on renewable energy, to rise to 30% by 2030 (Eitan, 2023a). Consequently, the government has directed planning committees to support and actively advance renewable energy projects, including wind energy initiatives (Eitan, 2023b). While most of these targets are to be achieved by solar facilities due to Israel’s sunny climate (Eitan et al., 2023a), preliminary licenses have also been issued for the construction of wind turbines with a total installed capacity of 730 MW. However, in practice wind turbines with a capacity of less than 300 MW have been installed. Consequently, as of 2023, wind energy accounted for less than 1% of Israel’s total energy consumption (Eitan et al., 2023b).

Methods and data

This study surveys 24 wind energy projects promoted in Israel between 2003 and 2024. Of these, 4 were completely rejected by the planning committees, 7 remain under consideration, and 13 received approval, with 4 already operational. The average time to reach a decision was 1,948 days, ranging from 176 days for the quickest rejection to 4,953 days for the longest approval. The dataset includes seven intermediaries, with approximately 70% of the EIAs conducted by a single player, Geo Teva (see  Appendix B). This concentration highlights the significant influence of Geo Teva on the practices and outcomes of EIAs within the Israeli wind energy sector.

This study draws on a combination of multiple data sources to validate the findings, also known as triangulation, a widely used method in qualitative studies (Flick, 2017). In our case, this includes the following clusters of sources, as indicated in Table 2.

Our analysis comprised several steps, aiming to address the three research questions. To address the first research question (see the section “The role of intermediaries in Israeli EIAs”), we identified key events in the promotion of 24 wind projects within planning committees, focusing on EIA-related activities and those responsible for implementation (Langley, 1999). These events were analyzed using interpretive sense-making—an approach that immerses researchers in the data to contextualize actors’ interpretations (Welch et al., 2011; Yanow & Schwartz-Shea, 2015). This involved an extensive review of interviews, regulations, planning committee protocols, EIAs, and position papers to extract insights into the roles of EIAs and their conductors. From this analysis, we identified five overarching intermediary roles in EIAs. While prior studies examined these roles separately, we integrate them into a cohesive framework that highlights their interaction, specifically in the EIA domain. This synthesis follows scholarly practices of unifying dispersed concepts (Ravitch & Riggan, 2016). Finally, based on their recognition in Israeli regulations, these roles were categorized as formal or informal, reflecting their institutional status and degree of regulation (Brès et al., 2019).

To address the second research question (see the section “Strengths and weaknesses of the Israeli EIA as a mechanism of intermediation”), we analyze the strengths and weaknesses of each identified intermediary role using a narrative research approach (Adams, 1989; Andrews et al., 2004; Squire et al., 2014). This approach captures how stakeholders involved in the EIA process perceive these roles, providing a structured framework for exploring social and political dynamics (Andrews et al., 2013). By integrating multiple data sources—planning committee protocols, stakeholder interviews, official EIA documents, and other relevant materials—we ensured data triangulation. This method allowed us to trace how intermediary roles functioned across various projects, identify patterns, and contextualize stakeholder perceptions within the broader regulatory landscape (Polkinghorne, 2007).

To execute the narrative research approach, we applied thematic and discourse analysis across the dataset presented earlier. Thematic analysis identified key themes such as “formal vs. informal roles,” “benefits and drawbacks of intermediation,” and “EIA credibility and trust,” revealing how EIA conductors facilitate compliance, influence decision-making, and navigate stakeholder expectations (Braun & Clarke, 2012). Discourse analysis examined how actors such as regulators, planning committee members, developers, and EIA conductors articulate the advantages, challenges, and perceived objectivity of EIAs (Johnstone & Andrus, 2024). The findings first highlight the strengths of each intermediary role, illustrating how stakeholders perceive their advantages within the EIA process. They then examine the associated challenges and limitations. This analysis, grounded in qualitative data triangulation (Flick, 2017), is reinforced with direct citations from primary sources to ensure empirical depth and credibility.

To address the third research question (see the section “EIA effectiveness”), we quantitatively assess EIA effectiveness based on established literature, which defines effectiveness through two interrelated dimensions (Arts et al., 2012; Caro-Gonzalez et al., 2023). To evaluate procedural effectiveness, we analyze whether EIAs meet regulatory standards by examining the proportion of submissions approved for discussion by planning committees. Approval, however, does not imply acceptance of recommendations but confirms adherence to legal requirements (Arts et al., 2012). To assess substantive effectiveness, we examine how often planning committees rely on EIA reports for environmental decisions versus seeking additional input from external experts. EIAs are considered substantively effective when decision-makers rely primarily on their assessments, demonstrating trust in their findings (Caro-Gonzalez et al., 2023).

Beyond measuring effectiveness, we explore its underlying drivers by analyzing how intermediary roles shape both procedural and substantive effectiveness. Using semi-structured interviews, particularly with planning committee members, we capture stakeholder perceptions of the relationship between intermediary strengths, weaknesses, and EIA effectiveness. The narrative research approach (Adams, 1989; Andrews et al., 2004; Squire et al., 2014) provides a structured framework (Andrews et al., 2013) for understanding how intermediary mechanisms influence both procedural effectiveness—by following regulatory requirements—and substantive effectiveness—by supporting informed decision-making. By combining quantitative assessment with qualitative insights, this approach offers a comprehensive evaluation of EIA effectiveness and its underlying drivers.

The role of intermediaries in Israeli EIAs

This section addresses the first research question, exploring the intermediary roles of EIAs in implementing process-based regulation, particularly in the context of Israeli wind energy projects. Building on existing literature that has traditionally addressed intermediary roles separately, below we synthesize them into an organized framework specific to the EIA process. As seen below, these roles can be categorized into two groups: formal roles, mandated by regulatory frameworks and therefore more structured in terms of execution, and informal roles, which, while not explicitly required by regulation, are executed in practice, involving personal relationships and nonhierarchical policy networks. The formal roles include providing professional guidance and advisory services as well as facilitating effective enforcement and compliance. In contrast, the informal roles encompass interpretation and communication, promoting dialogue and collaboration, and advocating for specific interests. This distinction highlights how EIAs function both within the bounds of regulatory requirements and beyond, influencing decision-making processes in multiple ways.

First, an important formal role of intermediation vis-à-vis wind energy is providing scientific guidance and advice regarding environmental aspects to various stakeholders, including regulators, project developers, environmental NGOs, and the general public. The EIA serves as the factual environmental foundation upon which the planning committee bases its decisions (Israeli Government, 2003, 2023). The developer, the planning committee (as the central regulator), and the public affected by wind projects often lack the expertise needed to assess comprehensively the environmental implications of wind energy projects (Interviews 7, 8, and 10). Recognizing that other stakeholders lack the expertise to assess environmental impacts fully, the intermediary role of guidance and advice in the Israeli EIA process is, therefore, essential. EIA documents establish standards, best practices, and specific methodologies, providing a structured framework for assessing environmental impacts. They advise on a wide range of environmental topics, including those related to bird migration, breeding grounds for animal species, ecological corridors, scenic landscapes, light pollution, noise, vibrations, and more (Interviews 1 and 3; Israeli Government, 2003).

Furthermore, EIA reports, conducted by professionals acting as intermediaries, play another formal role: They facilitate effective enforcement and compliance within the Israeli regulatory framework, particularly concerning wind energy projects (Interviews 3, 7, and 8; Israeli Government, 2003). In this context, one of the crucial responsibilities of planning committees in Israel is facilitating the enforcement of (and compliance with) planning and construction laws, particularly in the context of environmental considerations, which are highly relevant to projects such as wind energy ventures (Interviews 4 and 8). Hence, the environmental information disseminated to different stakeholders within the EIA framework acts as a crucial intermediary tool, facilitating robust and well-informed enforcement and compliance measures (Interviews 3 and 4). First, it enables developers to comply with environmental regulations before, during, and after the establishment of the wind energy project (Interview 10; Israeli Government, 2023). Second, it empowers authorities to enforce environmental guidelines during the project’s lifespan, providing them with the knowledge necessary to impose penalties and corrective actions in instances of noncompliance or violations (Geo Teva, 2017; Interviews 3, 7, and 8).

Interpretation and communication constitute an informal role in the Israeli EIA process, specifically concerning wind energy (Interviews 3, 5, 7, and 10). The EIA process involves a diverse array of stakeholders, among them project developers, government agencies (e.g., Ministry of Environmental Protection, Ministry of Energy, Ministry of Justice, Ministry of Finance, Ministry of Agriculture, Ministry of Defense, municipalities, and local authorities), environmental organizations and experts, and the public (Israeli Government, 2023; Ministry of Environmental Protection, 2023). Effective interpretation and communication of environmental regulations and assessments regarding the wind projects, through the EIA process, enable the translation of complex technical information into accessible language for different audiences, ensuring transparency, enabling meaningful public participation, resolving conflicts, promoting compliance, and facilitating adaptive management (Geo Teva, 2017; Interviews 1, 3, and 8).

Another informal role in the Israeli EIA process is facilitating dialogue and collaboration, bringing together a diverse array of stakeholders to create a structured platform for effective communication and consensus-building (Interviews 2, 3, 7, and 10). This role is instrumental in engaging stakeholders, enabling them to resolve conflicts and work toward mutually acceptable solutions. The EIA serves as a reference point, allowing stakeholders to engage in constructive conversations as part of planning committee meetings, whether they align with the report’s findings or challenge them (Interviews 3, 8, and 9; The Planning Committee-North District, 2018d). The EIA’s function as a reference point for stakeholder engagement highlights its ability to combine structured regulatory processes with the facilitation of interactions among regulators, developers, and stakeholders, supporting compliance and fostering meaningful dialogue and collaboration. These interactions also serve as an avenue for community members to voice their concerns, which often center on issues such as noise generated by wind turbines, potential landscape damage, and vibrations (Interviews 3, 4, and 9).

Finally, the EIAs and the intermediaries responsible for them serve as advocates for industries and individuals, helping to support wind energy projects in Israel (Interviews 7, 8, and 10). As part of this informal role, EIAs often highlight the favorable consequences of wind projects, including their positive contributions such as generating clean energy, reducing greenhouse gas emissions, and aligning with the Israeli government’s objectives in this regard. The EIAs further emphasize the economic benefits of wind energy, including job creation, revenue generation, and clean energy production, underscoring its role in reducing greenhouse gas emissions and promoting sustainability (Amir, 2017; Interviews 7 and 10).

Strengths and weaknesses of the Israeli EIA as a mechanism of intermediation

This section addresses the second research question, focusing on the strengths and weaknesses of EIAs as mechanisms of intermediation. It examines their role in implementing process-based regulation, with particular attention to the involvement of third-party intermediaries, as illustrated by the Israeli case.

Guidance and advice

Planning committees’ discussions reveal a relatively positive approach to the EIA’s formal guidance and advisory role as part of the Israeli wind energy sector. EIA reports are unequivocally recognized as professional documents that help committee members delve into the environmental dimensions of a project, relying on specified regulations (Interviews 3–5). This stems from the fact that EIAs are produced by professional entities well versed in environmental issues and committed to maintaining a positive reputation (Interviews 1, 3, 7, and 10; Israeli Government, 2023). The acknowledgment of the EIAs’ professionalism is further substantiated by the Ministry of Environmental Protection’s reference to the wind project in Bet Alfa: “In general, the ministry’s standpoint is that the environmental report presented by the developer is a well-balanced document, encompassing a precise analysis of diverse environmental elements and their associated impacts. While there were instances where we deemed it necessary to conduct more thorough tests in specific chapters, the report itself constitutes a solid scientific foundation and even surpasses expectations” (The Planning Committee-North District, 2017a).

However, a contrasting awareness among committee members arises regarding the limited responsibility of the intermediaries who produce EIA reports. In practice, the intermediaries draft the reports and actively participate in the committee’s discussions. Yet, these intermediaries do not shoulder a level of responsibility comparable to that of the developer or the regulatory authorities, such as the Ministry of Environmental Protection, which is responsible for ensuring and evaluating environmental standards over time (Interviews 1, 3, 4, and 8). This aspect is notably reflected in the Ministry of Environmental Protection’s statements concerning the wind project in Ein Hashofet, further fueling skepticism about the responsibility of the intermediary: “Our examination indicates that the turbine noise levels, given the distance from the settlement, exceed advisable limits. Notably, the consulting firm responsible for the submitted EIA will not be available to address this issue. They will be gone when the discussions here are over. Ultimately, our office will bear the responsibility for managing the repercussions, alongside the affected residents” (The Planning Committee-North District, 2015).

Facilitating enforcement and compliance

The EIA plays an important formal role in facilitating enforcement and compliance as part of the Israeli wind energy sector. In this context, the EIA process identifies pertinent environmental regulations and necessary permits, ensuring that all legal prerequisites are met prior to project implementation (Interviews 3 and 8; Israeli Government, 2003). The EIA process in Israel, therefore, mandates that developers must adhere to specified conditions, serving as a strong compliance mechanism that relies on official regulations (Interviews 2, 4, and 7; Ministry of Environmental Protection, 2023). This was evident when the representative of the private developer involved in the wind project in Yatir acknowledged: “Ultimately, it’s crucial to recognize that we unequivocally consider the findings of the EIA report binding for us. This commitment is comprehensive in every sense. As you are aware, the initial plan included the construction of additional wind turbines. However, in response to the report’s identification of potential environmental harm, we proactively scaled back the plan. Vigilance regarding the environmental aspects of the program remains a top priority” (The Planning Committee-South District, 2018).

However, different concerns raised by various stakeholders highlight the gap between the EIA conductor, the intermediary, and the entities responsible for actual environmental enforcement. Some claim that this gap hinders the ongoing monitoring and inspection of projects, primarily under the remit of the Ministry of Environmental Protection, regarding issues such as noise levels, air quality, and the incorporation of bird-friendly turbine designs (Geo Teva, 2017; Interviews 2–4 and 8). Given that intermediaries responsible for EIAs do not directly execute enforcement actions, the potential for different interpretations of instructions by developers or authorities becomes a significant challenge (Interviews 1, 3, and 9; Ministry of Environmental Protection, 2023). This challenge is particularly pronounced following the implementation of a project: The risk is that differing interpretations may undermine enforcement (or compliance) efforts and result in a failure to apply environmental regulations rigorously (Interviews 3, 4, and 6). This concern is echoed in a statement made by the representative of the NGO Society for the Protection of Nature in Israel regarding the wind project in Kisra: “Committee members should bear in mind that as the project commences, the EIA report serves as the binding document for the developer, in its perspective, alongside the project’s official instructions. The company representatives responsible for the report will not be present to ensure the protection of birds. This responsibility falls upon the authorities. Consequently, we urge that guidelines pertaining to the turbines’ operational procedures be explicitly incorporated into the program instructions. This will facilitate robust enforcement measures, rather than relying on vague statements derived from these reports” (The Planning Committee-North District, 2019b).

Such inadequacies can lead to flawed enforcement of the EIA and the wind project’s instructions. This problem is exacerbated by the disconnect between those responsible for producing the EIA, who do not play an enforcement role, and the Ministry of Environmental Protection personnel, who bear the actual responsibility for enforcement (Interviews 3, 4, and 8; Ministry of Environmental Protection, 2023). An illustrative case is the Emek Habacha wind energy project; in this case, a post-establishment debate arose concerning the operational practices of wind turbines to minimize harm to birds. Environmental organizations approached the Ministry of Environmental Protection to enforce guidelines on the project developer. However, the vague environmental instructions posed made it challenging for the ministry to implement enforcement. Subsequently, legal action was needed to ensure adherence to environmental guidelines (M. Gilad, 2021; Interviews 1 and 3).

Interpretation and communication

The informal intermediary role of interpretation and communication is characterized by a significant advantage in the Israeli wind energy sector. By conveying the assessment findings and potential impacts to all relevant parties, the intermediaries’ interpretation and communication as part of the EIA contribute to informed decision-making, minimizing environmental and social impacts and advancing the goals of sustainable development (Interviews 3, 5, 7, 8, and 10). This is evident in a statement made by the representative of the Ministry of Energy regarding the wind project in the Northern Golan Heights during the discussion of the National Infrastructure Committee: “From my perspective, the EIA report clearly highlights environmental concerns, which are evidently present. Based on the report, local residents have the opportunity to voice their reservations. Nonetheless, I hold the view that this project is indispensable within the broader context of Israel’s energy considerations. This stance takes into account the surrounding factors and considerations integral to the overall environmental consideration” (National Infrastructure Committee, 2019a).

However, this informal role also has notable limitations, apparent in light of the lack of clear regulations in this matter (Israeli Government, 2003). Making the information accessible to audiences with varied characteristics proves challenging, often involving a level of professional language that may be too complex for the general public. EIA reports, integral for evaluating the environmental effects of projects, are often overflowing with technical jargon and complex methodologies essential for professionals but daunting for the general public. The challenge lies in balancing the precision required by legal and regulatory standards with the imperative of communicating effectively to varied audiences (Interviews 1, 3, 7, 9, and 10). Furthermore, because intermediaries are hired and compensated by the developer, they often closely align with the developer’s interests. This reduces their incentive to make reports accessible to other stakeholders, such as the general public (Interviews 3, 4, and 8). The cultural and linguistic diversity of the audience adds another layer of complexity, necessitating not merely translation but also cultural sensitivity in conveying information (Interview 2 and 7; The Planning Committee-North District, 2018e). This is reflected, for example, in cases of wind projects on the lands of Druze communities in Israel. For instance, as the representative of the NGO Adam Teva VeDin noted regarding a possible wind project in the Druze community of Yanuh-Jat Hurfiesh: “As a professional, I comprehend the intricacies outlined in the report. However, it’s crucial to recognize that the residents of Yanuh-Jat Hurfiesh may not possess the expertise to decipher these documents. They are unaware that their lives are on the brink of significant disruption, encompassing the loss of tranquility, scenic views, and the pastoral essence of their surroundings. The impending changes are poised to obliterate these aspects. Noise reports are not within the grasp of these residents” (National Infrastructure Committee, 2019b).

Facilitating dialogue and collaboration

The intermediary’s informal role of facilitating dialogue and collaboration is highly significant within the EIA process. Beyond constituting a comprehensive document evaluating environmental impacts, the EIA report regarding wind energy serves as a foundation for deliberations within planning committees (Interviews 2, 3, and 9; The Planning Committee-North District, 2018d). The EIA constitutes a reference point, enabling stakeholders to engage in constructive conversations as part of the planning committees’ meetings, whether they align with the report’s findings or challenge them. The EIA’s role as a reference point for stakeholder engagement emphasizes its capacity to integrate structured regulatory processes with the facilitation of interactions between regulators, developers, and stakeholders, ensuring compliance while promoting constructive dialogue and collaboration (Interviews 7, 8, and 10; The Planning Committee-North District, 2018d). This is reflected in a statement by the representative of a private consulting firm that was responsible for the EIA regarding the wind project in Emek Habacha: “Our primary aim is twofold: to portray the overall situation accurately and to propose strategies that address environmental concerns voiced by residents and other concerned parties. We acknowledge instances in which the Ministry of Environmental Protection holds differing views, but it’s crucial to note that such disagreements are intrinsic to the report’s purpose. We are here to foster continued dialogue on the findings, with the ultimate goal of reaching the optimal environmental solution. Our team remains at your disposal for further discussions with all relevant players, the committee’s members, local residents and environmental organizations” (The Planning Committee-North District, 2014).

However, in practice, this informal role also suffers from a significant weakness in the case of Israeli wind energy in light of the lack of clear regulations in this regard. Numerous complaints have been voiced concerning public participation during the preparation of EIAs regarding wind energy in Israel (Interviews 1–4, 8, and 9). Various stakeholders, including environmental organizations, the Ministry of Environmental Protection, local residents, and members of planning committees, argue that the voices of community residents and environmental organizations are not adequately considered during the preparation of such reports. According to these complaints, the primary phase of the public participation procedure occurs during the discussion of EIA reports in the planning committees rather than during the preparation process itself (Interviews 1, 3, 4, and 9; The Planning Committee-North District, 2018e). This issue is all the more salient in light of the perception that the agents responsible for conducting EIAs seek to promote wind projects despite possible environmental concerns, given their association with the developers (Interviews 1, 8, and 9). Such participation is especially important in the case of wind energy: Public acceptance has been proven to pave the way for a faster and more efficient diffusion of relevant projects (Devine-Wright et al., 2017). This is reflected in a letter of objection to the Kisra wind project from a local resident: “Regrettably, information regarding the environmental procedure was not shared with us. The evaluation process appears geared towards promoting the project at all costs, as evidenced by the reports. I was not approached to assess potential harm from the turbines, and, to my knowledge, no other residents in the community were contacted either. There seems to be a disregard for a population that is likely to face significant impact” (The Planning Committee-North District, 2019a).

Advocating for industries and individuals

A notable advantage of the EIA’s informal role of advocacy is its ability to shape positively committee members’ perception of wind energy projects (Interviews 1–3 and 4). EIAs frequently emphasize the beneficial outcomes of wind projects, as evident in a statement made by the representative of a private developer regarding the wind project in Mesilot: “When engaging in discussions about the aforementioned project, it’s essential to bear in mind the numerous environmental and energy benefits it offers, along with the broader advantages associated with the wind industry. Aligned with the government’s commitment, the entire country is rallying to decrease greenhouse gas emissions, addressing the urgent need to combat the climate crisis. This project constitutes a significant step in that direction, emphasizing the importance of fostering more wind energy initiatives to align effectively with the government’s objectives and minimize setbacks” (The Planning Committee-North District, 2018b). Indeed, influenced by EIA advocacy efforts, the planning committees’ basic approach toward wind energy projects in Israel is positive, particularly when compared to other infrastructure endeavors such as natural gas-powered plants, regarding which the standpoint is often more complex (Interviews 1, 2, 5, 8, and 9).

However, the intermediary role of advocacy as part of the EIA process entails a considerable drawback. In addition to endorsing the establishment of wind energy projects for their environmental benefits, committee members acknowledge the potential conflict of interest faced by the intermediaries responsible for the EIA (Interviews 3, 4, and 8; The Planning Committee-North District, 2017b; The Planning Committee-North District, 2018c). Given that they are appointed by project developers, they may face conflicts of interest that compromise their professional integrity; indeed, many assessments tend to lean toward conclusions favoring the implementation of the project. Criticism from various committee members underscores concerns about the perceived bias in EIA reports, leaning heavily toward the wind energy industry, which could raise doubts concerning their credibility (Interviews 1–4 and 6). Thus, to a significant degree, the appointment and compensation of EIA conductors by wind energy project promoters may impede their efforts to present a project’s benefits objectively, driven by concerns regarding a conflict of interest. This dynamic is exemplified in a letter of objection to the project in Ein Harod by a local environmental activist: “The EIA was assembled by a private company. The planning committees’ environmental consultants consistently identified shortcomings in the reports submitted by the company. Surprisingly, or not, they always serve the interests of the developer. The Ministry of Environmental Protection also provided negative feedback on the adequacy and thoroughness of the company’s evaluations, particularly evident in their examinations of the noise levels produced by the turbines. Despite this, EIAs conducted by this company continue to be submitted to the authorities” (The Planning Committee-North District, 2018a).

Certainly, the identification of EIA conductors with the developer highlights a significant challenge within the Israeli EIA process, and this concern is voiced by various stakeholders. The core problem stems from the appointment of the intermediaries by the developer and the financial compensation they receive from the same party. This relationship raises questions concerning their ability to maintain professional objectivity while simultaneously serving the interests of the developer (Interviews 1–4 and 6). While the law requires that the EIA will address all environmental issues comprehensively on behalf of the developer (Ministry of Environmental Protection, 2021), criticism persists regarding the tendency to downplay the severity of environmental problems arising from assessments and to handle certain report sections minimally and inadequately (Interviews 3, 4, and 8). A member of the North District Planning Committee acknowledged and addressed the issue, stating, “Ultimately, we cannot overlook the fact that the EIA report presented to us represents the developer’s perspective. It’s crucial to note that I don’t perceive the report as unprofessional or untruthful. I simply believe that it has the inherent potential to adopt a particular standpoint. The matters we are grappling with are intricate, involving various stakeholders, diverse interests, and evolving environmental impacts” (National Infrastructure Committee, 2017).

This perspective prompts committee members to seek additional professional expertise in certain instances. When faced with uncertainty or unclear information, the committee may appoint an independent expert, such as an academic researcher, to review specific environmental concerns (Interviews 2, 3, 5, and 8; The Planning Committee-North District, 2018c). Unlike formal intermediaries—the original EIA consultants hired by the developer—these appointed professionals function as informal intermediaries, as they are not legally mandated within the EIA framework and are instead engaged on an ad hoc basis at the discretion of the committee. These experts submit their findings directly to the committee. However, unlike the original consultants, they do not receive remuneration from the developer; instead, their fees are covered by the committee (Interviews 2–4 and 8; The Planning Committee-North District, 2018e).

In several cases, the reports from these external consultants have contradicted the original EIA assessments, particularly in the interpretation of findings rather than the findings themselves. Such contradictions have, at times, led the committee to oppose a project based on the updated information (Interviews 7, 8, and 10). Committee members tend to place greater credibility and responsibility on professionals appointed on their behalf, perceiving them as more impartial than developer-hired consultants (Interviews 1–4 and 8). Their independence from project developers—being directly compensated by the committee—enhances their perceived trustworthiness and credibility among regulators and stakeholders. This dynamic fosters greater reliance on their input for critical decision-making, particularly when their findings challenge or complement the original EIA reports (Interviews 1–4 and 8).

Summary

The analysis of the EIA’s intermediary roles in the Israeli wind energy sectors highlights a clear distinction between formal and informal roles, each with its own strengths and weaknesses. Formal roles, such as providing guidance and advice and facilitating enforcement and compliance, are tightly governed by regulatory frameworks, providing a robust legal and regulatory structure that planning committees rely upon heavily for decision-making. The professional expertise of the EIA reports and their strict adherence to environmental regulations underscore the importance of these formal roles. However, the responsibility of intermediaries within these formal roles can be somewhat constrained; often they do not bear the same accountability as developers or regulatory authorities.

Informal roles—such as interpretation and communication, facilitating dialogue and collaboration, and advocating for industries—involve a different set of strengths and weaknesses. Their ability to engage stakeholders and provide a broader context for decision-making is a significant strength, fostering consensus and inclusivity. However, these roles are less strictly governed by regulations and, consequently, planning committees perceive them as a less integral part of EIAs. The lack of strict regulatory guidance can lead to inconsistencies in how these roles are executed, making them more vulnerable to scrutiny. This ambiguity also paves the way for potential conflicts of interest, particularly when those responsible for EIAs are perceived as aligned with developers’ interests, which can further undermine the objectivity and credibility of the EIA process. As a result, planning committees often turn to external consultants for independent evaluations, seeking to mitigate these challenges and ensure a more balanced decision-making process.

EIA effectiveness

This section addresses the third research question: How do the strengths and weaknesses of the intermediation mechanism shape EIAs’ effectiveness? As noted earlier, in performing diverse functions as part of the EIA process, intermediaries demonstrate numerous strengths, particularly in their formal roles. The EIAs and the intermediaries responsible for them promote environmental and energy expertise and specialization (Interviews 2–4 and 6; Israeli Government, 2003) while supporting enforcement and compliance efforts (Interviews 1, 5, and 8; Israeli Government, 2023). Several committee members attribute these strengths to the intermediaries’ proficiency: They possess expertise and are committed to delivering high-caliber work in the environmental domain (Interviews 1–6 and 8). This proficiency results in EIAs’ significant procedural effectiveness. Indeed, as Figure 1 demonstrates, of the 24 examined projects, only in 2 cases (8.3%) were the EIAs disqualified due to noncompliance with governmental regulations, with subsequent instructions for revision and resubmission. However, their associated projects are still under consideration. Out of the EIAs that met the regulatory requirements (91.7%), 13 of their associated projects were approved (54.2% of the total projects), 4 were rejected (16.7%), and 7 are still under consideration (20.8%). Committee approval of the EIA in this regard does not necessitate accepting its recommendations; it indicates that the committee acknowledges the EIA’s adherence to regulatory requirements. Hence, based on this indicator, it seems that the procedural effectiveness of EIAs is high and they adhere to the necessary governmental regulations; otherwise, the rejection rate by the committee would have been higher.

Nevertheless, the intermediary roles within EIAs also demonstrate notable weaknesses, mostly reflected in their informal roles. The intermediaries’ ties to developers undermine the credibility of the EIA process regarding Israeli wind projects, questioning its legitimacy and impartiality (Interviews 1–4, 8, and 9). In this context, committee members observed that EIA reports often downplay environmental issues, impeding their understanding of environmental aspects (Interviews 3, 4, and 8). In other cases, intermediaries also fell short of facilitating public participation and demonstrating accountability (Interviews 1, 2, 8, and 9). These weaknesses result in a relatively low substantial effectiveness, making it difficult for planning committees to rely on EIAs in their decision-making. To address these gaps, planning committees increasingly turn to external consultants as informal intermediaries, leveraging their independence and specialized expertise for targeted evaluations. This dual-layered intermediation underscores the necessity of supplemental assessments to enhance credibility and ensure more robust decision-making (Interviews 2, 3, 5, and 8; The Planning Committee-North District, 2018c). Indeed, as Figure 2 indicates, of the 24 examined wind energy projects, 14 (58.3%) required planning committees to address external experts, given the inadequate work of the EIAs and their editors. Furthermore, 9 of the projects accompanied by external consultants were eventually approved (37.5% of the total projects), 4 were rejected (16.7%), and one is still under consideration (4.1.%). At the same time, 4 of the projects that were not accompanied by an external consultant received approval (16.7%), while 6 are still under consideration (25%)—adding up to a total of 10 projects (41.7%).

The need to address external experts may also partly explain the considerable time needed to reach decisions regarding wind energy projects, regardless of whether they were approved or rejected: 1,948 days on average, ranging from 176 days for the swiftest rejection to 4,953 days for the longest approval. Figure 3 presents the distribution of days taken to reach decisions regarding the wind projects, while indicating whether they have been rejected or approved (excluding projects still in progress). In 22.2% of the projects, a decision was made in less than 1,000 days; in 33.3% of the projects, this took 1,000–1,999 days; in 27.8% of the projects, it took 2,000–2,999 days; and in 16.7% of the projects, it took more than 3,000 days.

Thus, there is a clear disparity between the procedural and substantive effectiveness of EIAs in the case of Israeli wind energy. Procedurally, EIAs meet legal requirements and adhere to comprehensive methodologies, ensuring their acceptance by planning committees. However, substantively, they often fall short in providing planning committees with reliable and actionable information needed for independent decision-making, leading to reliance on external experts. This issue reflects a broader trend wherein EIA effectiveness is increasingly judged not merely based on procedural adherence but on substantive outcomes that support informed decision-making (Banhalmi-Zakar et al., 2018; Loomis & Dziedzic, 2018).

Formal roles, governed by regulatory frameworks, ensure compliance with legal requirements. Informal roles, though practiced, operate without clear regulatory guidance, often leading to inconsistencies that may compromise the objectivity and credibility of EIA findings. The absence of a regulatory requirement for objectivity within the intermediation process, specifically in the context of informal roles, undermines the credibility and legitimacy of the EIA process in the eyes of planning committees. This is particularly evident given the association between intermediaries and project developers. This lack of mandated objectivity can lead to biased or insufficiently critical evaluations, reducing stakeholders’ trust in EIA findings. Consequently, the substantive effectiveness of decision-making based on EIAs is diminished, as evidenced by the case of Israeli wind energy. The reliance on external experts to validate or supplement EIA findings illustrates the practical challenges that planning committees face, underscoring the need for regulatory frameworks that ensure both procedural rigor and substantive reliability in EIAs.

Discussion and conclusions

This study investigates EIAs as mechanisms of intermediation, focusing on the Israeli wind energy case. The Israeli case constitutes an example of the use of third-party intermediaries in EIAs, highlighting their role in environmental governance (Wood, 2013). This case, therefore, serves as a representative of global trends in regulatory intermediation, making the findings broadly applicable. Many regulatory systems worldwide rely on third-party intermediaries for environmental assessments and may thus face similar challenges, including misaligned incentives, insufficient regulatory guidance for informal roles, and a disconnect between procedural compliance and substantive outcomes (United Nations, 2018). However, in other contexts where regulators or regulated entities conduct EIAs, the intermediation role may be less pronounced. This variability reflects the broader adaptability of process-based regulation frameworks to different governance structures (Gilad, 2010).

Our findings contribute both to the literature on regulatory governance (Bowers, 2020; Brès et al., 2019; Kourula et al., 2019) and to the literature on EIAs (Loomis & Dziedzic, 2018; Petts, 2009). Recent EIA literature has increasingly emphasized the importance of substantive effectiveness—evaluating the ability of EIAs to inform and shape decision-making—alongside procedural effectiveness, which ensures compliance with legal and regulatory frameworks. However, as highlighted by this study’s research gap, EIAs often reveal a striking disparity between procedural and substantive effectiveness: Although they consistently adhere to regulatory requirements, they frequently fail to provide a solid foundation for confident and informed decision-making (Loomis & Dziedzic, 2018).

The study’s findings show that regulatory intermediation in EIAs requires intermediaries to fulfill both formal and informal roles, each shaping effectiveness differently (Brès et al., 2019; Christiansen & Piattoni, 2003). Formal roles, such as advisory services and enforcement facilitation, ensure that EIAs meet regulatory requirements and uphold procedural effectiveness. Informal roles—such as interpretation, collaboration, and advocacy—foster trust, inclusivity, and stakeholder engagement, contributing to substantive effectiveness and informed decision-making. While formal roles are well regulated, informal roles often lack oversight, making them vulnerable to inconsistencies and conflicts of interest, particularly when intermediaries align too closely with developers.

This distinction is crucial: Formal roles support EIAs in meeting regulatory requirements, whereas informal roles provide the flexibility to integrate diverse stakeholder perspectives and enhance substantive outcomes through informed decision-making. However, strong procedural effectiveness in EIAs does not always translate into meaningful impact. In the Israeli case, even though planning committees mostly approve EIAs as meeting regulatory requirements, they frequently rely on external consultants to validate findings, revealing a regulatory gap where meeting formal requirements does not ensure actionable insights or informed decision-making. We argue that in order to bridge this gap, formalizing informal roles while preserving their adaptability should be considered. Clear guidelines and standardized practices, combined with independent validation, can enhance transparency and strengthen the credibility of EIAs, enabling more informed decision-making while maintaining flexibility.

The gap between procedural rigor and substantive effectiveness in EIAs can also be understood through process-based regulation, which emphasizes structured procedures—such as stakeholder engagement and risk assessments—to ensure compliance (Wang et al., 2024). In Israel, while these processes meet regulatory requirements, they do not always yield actionable insights for decision-making, particularly when intermediaries, often appointed by developers, navigate conflicting interests or fail to address stakeholder concerns effectively. Process-based regulation can enhance consistency and transparency, but its effectiveness depends on enforcement, oversight, and standardization (Deighton-Smith, 2008). Since it prioritizes procedural adherence over uniform outcomes, flexibility in implementation can lead to inconsistencies. This flexibility also allows for confidential agreements, such as nondisclosure agreements, which may reduce public transparency. Without clear oversight and trust in intermediaries, EIAs risk becoming procedural formalities rather than tools for informed decision-making. Addressing this requires strengthening procedural frameworks while ensuring intermediaries operate independently and align with broader public and environmental objectives.

In this context, this research also contributes significantly to the literature on regulatory intermediaries by developing a unified framework that categorizes intermediary roles and illustrates their interconnectedness. Previous research has often analyzed these roles in isolation, focusing on discrete functions (Fischer & Guy, 2009; Marques, 2019; Owen, 2021). By integrating these roles within the EIA context, this study offers a structured approach to understanding how intermediaries navigate complex regulatory environments and balance procedural compliance with broader stakeholder engagement. Specifically, the roles discussed—advisory services, enforcement facilitation, interpretation and communication, fostering collaboration, and advocacy—are central to understanding how intermediaries mediate relationships between regulators, developers, and other affected actors.

This integration, however, exposes systemic risks when intermediaries align with developers, undermining objectivity, trust, and regulatory impartiality (Bowers, 2020). Such alignment erodes stakeholder confidence, exacerbates power imbalances, and risks reducing regulation to procedural formalities, sidelining public and environmental concerns. In Israel, informal intermediaries like external consultants emerged to bypass original EIA conductors, enhancing reliability through independence and specialization. However, without formal regulation, such informal intermediaries may introduce inconsistencies and delays, underscoring the need to balance adaptability with regulatory coherence and efficiency. Therefore, the use of informal intermediaries should be carefully considered to ensure they enhance rather than weaken the integrity and effectiveness of environmental governance.

While this study provides significant insights, it has limitations that warrant further research. The dataset includes only seven intermediaries, with one, Geo Teva, conducting approximately 70% of the analyzed EIAs. While this focus allowed for an in-depth exploration of a dominant intermediary, it also limited the diversity of practices reflected in the findings. Additionally, while the study’s focus on Israel illustrates global trends, it may not fully reflect variations in regulatory frameworks and cultural contexts elsewhere.

Given these limitations, several research avenues emerge. Comparative studies could explore how institutional factors shape EIA design and effectiveness across jurisdictions. For example, while Israel relies on planning committees and third-party intermediaries, other systems may regulate intermediaries differently or adopt EIA models led by regulators or regulated entities. Future research could, therefore, examine how different institutional structures impact the effectiveness of EIAs, with a focus on their credibility and legitimacy. In this context, quantitative analyses could broadly identify key factors influencing EIA effectiveness, such as intermediary independence, stakeholder engagement quality, and regulatory oversight.

As our findings suggest that intermediaries’ close ties to developers may undermine trust, future studies could systematically compare cases where intermediaries maintain autonomy versus those embedded within the industry, such as in the Israeli case. Moreover, expanding beyond wind energy, future research could examine EIAs in hydropower, solar energy, and urban development to identify sector-specific intermediation dynamics. For instance, hydropower projects may present different ecological and social challenges than wind energy, requiring tailored regulatory approaches. Future research should also explore the formalization of informal intermediation roles such as interpretation, collaboration, and advocacy. While these roles shape how EIAs function, their lack of clear guidelines creates inconsistencies. Investigating whether regulatory codification enhances EIA credibility without sacrificing flexibility would be valuable. Finally, longitudinal studies could assess whether EIA recommendations translate into long-term compliance and environmental outcomes. Tracking projects post-approval would provide insights into intermediaries’ roles in monitoring and enforcement beyond initial assessments.

Conflict of interest

None declared.

References