Henry Le Brecht, James Montgomery and Phil Le Gouais outline a new IEMA guide for climate change resilience and adaptation in EIA
The storms that have hit the UK in recent winters have cost lives, flooded large tracts of the country, and devastated homes and businesses, causing billions of pounds worth of damage – more than £5bn in 2015-16 alone, according to one forecast. How to take account of variations in our climate that trigger such events is a significant challenge for environmental impact assessment (EIA) practitioners.
EIA Directive
Recognising this, the revised EU EIA Directive (2014/52/EU), which is due to be transposed into domestic legislation by spring 2017, places more emphasis on assessing the threats and challenges arising from climate change. It requires:
- developers to ensure projects are resilient to climate variations;
- EIA practitioners to assess the impacts of developments on future climate; and
- for them to take account of climate variation when assessing the impacts of the development on the environment.
In response, IEMA has produced guidance on including climate variations in impact assessments and how to take into account the resilience of a proposed development. Tackling impacts on the climate from developments will be the subject of future guidance.
The IEMA EIA Guide for Climate Change Resilience and Adaptation was published in November 2015 and provides a framework for the effective consideration of climate change in line with the revised directive.
Along with a discussion on legislative and policy drivers, the guide has been produced to assist practitioners by giving prompts on which issues to consider and when in the EIA process. The guidance is the first step to improve assessment practice, with a future version planned for when the new UK regulations are implemented next spring. This will build on lessons learned from assessments conducted in the interim.
The early release of the guidance is intended to kick-start inclusion of climate change in assessments, and builds on the initial work carried out on those already completed, such as for phase one of the HS2 rail link.
IEMA believes early adoption of the guidance will ensure that developers minimise the risk of regulators requiring late inclusion of climate change in EIA at planning approval and encourage developers and practitioners to anticipate what will be required from next spring. As such, the guide advocates that practitioners and competent authorities begin to give enhanced consideration to climate risks in the assessment process now so that they are well managed for projects being considered and to support the evolution of sound practice before the regulatory regime changes.
An environmental statement produced in line with the IEMA guide would:
- always make reference to climate change;
- provide a concise explanation of how the project’s resilience to climate change was considered;
- set out clearly how effects related to climate change have been assessed; and
- define the significance of effects by taking a pragmatic account of the knowledge base used in the assessment.
Five underlying principles
There are five key principles in the guide:
1. Resourcing EIA to assess climate change effects
To integrate climate properly into the assessment process, it is important for informed advice to be available to EIA technical specialists on future climate conditions. Projections published by the Met Office (currently based on 2009 publications, and called UKCP09) are available to practitioners, but the information is complex and should be used with care.
It is the role of EIA co-ordinators to ensure the developer is aware of the need to properly account for climate change under the revised directive: both to guarantee a scheme is resilient and in terms of assessing its impact.
To assist the co-ordinator, EIA teams require a practitioner who is knowledgeable about future climate change models (a climate change co-ordinator), and is experienced in using and interpreting future projections. This person does not have to be a climate specialist but they should be able to:
- access available information sources, such as regional climate patterns and national datasets, and make recommendations to the EIA co-ordinator based on these projections; and
- write the background on climate change in the environmental statement.
2. Identifying the future climate
There is uncertainty about how the future climate might evolve and affect extreme events as well as average conditions. Such uncertainties make it difficult to assess the impacts of change in relation to a project. It is the role of the climate change co-ordinator to ensure the developer and the various topic specialists properly understand the uncertainties.
Climate change predictions are based on global models for a range of greenhouse-gas emission scenarios (called climate change projections) and look generally at regional responses. It is worth noting that developments with short lifetimes, up to 2040, are not particularly affected since the potential variation in climate is small.
After 2040 the projections diverge, and it is likely that the EIA will have to consider a range of conditions, depending on the lifespan of the project. A project with a long life, such as major transport infrastructure, would have to consider a wider range of climate conditions than one with a shorter lifespan.
Precisely how the assessment covers the array of possibilities will require practitioners to examine the resilience of environment receptors in their specialism to climate change. If the project could have an impact on a significant number of climate-sensitive receptors, a more robust examination of future climate variation would be justified.
The source of climate projections and the range of those used in the EIA (and project design) must be clearly described in the environmental statement.
3. Building climate resilience
Developers and scheme designers must carry out a risk assessment of a project to ensure it is resilient to future climate change.
Performing a risk assessment not only makes economic sense, but the revised directive requires the environmental statement to confirm that the scheme is future-proofed against changes in the climate.
This should be included in the section of the statement that discusses the options considered in developing the scheme design.
It is also possible that the EIA will identify climate change risks to the project. These should be communicated to the design team to ensure they are aware of potential residual issues.
4. Integrating climate change adaptation into the EIA
The guide sets out the considerations that should be given to climate adaptation at key stages in the assessment process, with examples of the actions that are likely to be required at each stage. Emphasis is placed on scoping the assessment since this is when broad principles must be translated into tangible plans for addressing climate adaptation issues. The guidance covers the following steps required during the EIA:
- scoping climate resilience in or out of the environmental statement;
- defining the boundaries of the climate change assessment;
- consulting about climate change;
- defining a future baseline;
- identifying climate change vulnerability and sensitivity of receptors;
- identifying future impacts;
- assessing ‘in-combination’ impacts of the scheme and an evolving baseline; and
- assessing significance.
5. Developing mitigation plans through adaptive management
EIA practitioners will have to embrace uncertainty in the development of mitigation measures to deal with significant effects on receptors to ensure they are properly accounted for.
This will be a big challenge to EIA practitioners, regulators and developers, given that assigning responsibility and agreeing how and when possible future mitigation should be adopted is not something that is generally dealt with under current planning and approval processes. If the scheme is unlikely to have an impact on a receptor until the climate has changed in, say, 30 years, the regulators and developer will need to agree whether this is something to be considered now, or included in planning conditions and land titles for future land owners to cover. This process is described as adaptive management.
The guide discusses the issues associated with defining mitigation for future impacts and the steps required to develop an effective adaptive management plan.
Henry Le Brecht is a senior environmental planner, James Montgomery is the environment divisional manager, and Phil Le Gouais is a principal environmental planner at Mott MacDonald. They are joint authors of IEMA’s EIA Guide for Climate Change Resilience and Adaptation. The authors would like to thank the publication’s working group for its support. The guide lists all those involved in producing, reviewing and commenting on drafts and is available at iema.net/eia-climate-change.
