LTP3 and Strategic Environmental Assessment – Adding Value
European Directive 2001/42/EC ’on the assessment of the effects of certain plans and programmes on the environment’ came into force in July 2004. Although it does not use the term ‘Strategic Environmental Assessment’ or ‘SEA’ it has become known as the SEA Directive. The objective of the Directive is “to provide for a high level of protection of the environment and to contribute to the integration of environmental considerations into the preparation and adoption of plans and programmes with a view to promoting sustainable development” (Article 1). In this article Sean Nicholson explores how SEA can add value to the LTP3 process.
The danger areas
Experience with LTP2 and SEA was mixed. The timing of the legislation coming into force meant that many LTPs had already commenced and the SEA was a bit of a bolt-on. This time around there are no excuses for not integrating the two processes. The resource intensive nature of parts of the SEA process does however mean that a lot of effort could be expended with very little value added to the plan making process.
Several tasks in the SEA process are designed to enable the process to meet the requirements of the SEA Directive. These include the need to consider links with other plans and programmes, the need to consider the baseline situation and the need to consider reasonable alternatives (options). Key danger areas are discussed below.
Links with other plans and programmes
The objective of this task is to identify linkages between the plan that is being appraised and other relevant plans and programmes. There is a plethora of potentially relevant documents at the international, European, national, regional, sub-regional and local levels. The natural inclination, perhaps driven by the fear of not conforming with the SEA Directive, is to review them all; but there is a need to be selective for two reasons. First, some of the directives that have emanated from Europe relating to the environment are not directly related to the plan making process. Second, much of the documentation at the international or European level has already been transposed into policy at the national level, for example the commitments set out in the Kyoto Protocol are reflected in the UK Government’s climate change programme or even a local Climate Change Adaptation and Mitigation Strategy.
In an attempt to be comprehensive, the review of plans and programmes can become shallow, in terms of the depth of analysis of each document and its relationship to the plan that is being appraised. An alternative approach would be a more selective and more detailed analysis of relevant plans and programmes, perhaps focusing on documents at the local and regional level – on the grounds that these should be in compliance with higher tier policies. There may be exceptions where policy at the national level is known to have just been reviewed. This approach is summarised in Figure 1.
Focusing on key documents such as the Community Strategy, Local Development Framework, Regional Spatial Strategy etc will enable the review of plans and programmes to consider potential linkages with LTP3 in a deeper and more considered way, thereby adding value to the plan making process. This must be preferable to having a list of documents that runs to many pages but says very little.
Information needs to be provided on:
· the current state of the topic under consideration, for example air quality, and how it is likely to evolve if the plan that is being appraised is not implemented;
· the environmental characteristics of areas likely to be significantly affected by the plan that is being appraised; and
· any existing environmental problems that are relevant to the plan or programme that is being appraised.
The topics that need to be considered to satisfy the requirements of the SEA Directive are: biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors.
In addition, a range of social and economic topics might also be considered as part of an SEA – e.g. deprivation, unemployment, employment. As with the consideration of linkages to other plans and programmes there is a danger that the collection of information can get out of hand, perhaps the danger is even greater given the amount of data that is out there just waiting to be downloaded. The collection of data needs to be planned – think about the topic, its relationship to LTP3 and the ‘zone of influence’ of the plan you’re appraising. If something is included on the grounds that it provides contextual background, the question then becomes ‘where do you draw the line?’ Figure 2 illustrates a universal truth – there comes a point in any process when you have too much information; this applies to SEA.
Another useful way of approaching the collection of baseline information is to apply the ‘so what?’ test. When presented with a particular piece of information think carefully about what the implications are for LTP3; maybe there are none immediately apparent, in which case why include it?
The review of baseline information should add value to the SEA process and can also help contribute to the evidence base for LTP3. The collection of data should not be seen as an end in itself.
There is a need to consider reasonable alternatives (or options) taking into account the objectives and geographical scope of the plan that is being appraised. The question again arises ‘where do you draw the line?’ How many options is it appropriate to assess? The key test to apply is the reasonableness of the options – would they be compliant with policy established at the local level or a higher tier of policy the national level for example. If the answer is no the option is not reasonable and can be discarded. Options should not be generated for the sake of it.
The evaluation of options also exposes the limits of SEA. The objectives used in the assessment process are at a high level. Evaluating options against objectives may not be the best way to examine their impacts. For example assessing a range of initiatives based around travel planning as a collective group will probably tell you as much about their potential environmental effects as assessing three or four individual initiatives but will be more efficient.
The use of matrices is established practice in SEA. There is no requirement to use matrices and they have pros and cons. On the plus side they encourage transparency. On the negative side they can add to the weight of SEAs. One of the issues that is highly relevant to LPT3 is how to break down the assessment. This will influence how many matrices need to be produced. It can be a case of ‘less is more.’ Thinking about how the plan will be broken down in order to assess it will be time well spent. If the structure of the plan is known it would be reasonable to consult on the proposed methodology at the
The assessment of effects should also focus on outcomes. The temptation when using high level objectives is to score the extent to which parts of the plan being assessed accord with the objectives being used. A focus on outcomes is fundamentally different. The SEA objectives are used to direct attention to a particular issue with the question “if this policy is pursued what will it mean for ….?”
Habitats Regulations Assessment (HRA)
LTP3 will also need HRA screening. Lessons can be learned from the HRA of land-use plans and HRAs undertaken for such plans in the area can be a useful source of information if they are available. Work undertaken for the Regional Spatial Strategy will also be useful. Key lessons include:
· HRA Screening should be reported separately from the SEA;
· Start early and consult with Natural England as soon as possible on the scope of the Screening exercise;
· Consider sites outside your administrative boundary;
· Screen individual elements the LTP3, suggesting mitigation and/or avoidance measures where issues are identified.
SEA can add value to the plan-making process but there is a danger of getting too embroiled in the process of gathering information. The key danger areas are the review of other plans and programmes, the collection of baseline information and the review of reasonable alternatives. The challenge is to plan the process, stay focused and critically review inputs along the way. Integrating the SEA and LTP3 will bring benefits to both documents.
HRA is another form of assessment that LTP3 will need to be subjected to this time around. Lessons learned from the assessment of land use plans should help smooth the process.
LTP3 and SEA – Adding value
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