Kyle Welburn, from WSP Environment & Energy, describes how an "interrogative" approach can ensure that non-technical summaries (NTS) are living up to their name
The Town and Country Planning (Environmental Impact Assessment) Regulations require the assessment of environmental effects to be reported in both an environmental statement and in a NTS document, to ensure that all interested parties can be fully informed of the implications of proposals prior to granting development consent.
The NTS is a key document because, as IEMA states in recent guidance, it “informs the reader of the findings of the assessment and consults them on the decision to be taken” and is therefore crucial in effective pre-application engagement.
The Environmental Impact Assessment (EIA) Directive stipulates that a NTS should include information on the proposed development, the key findings of the EIA, proposed mitigation measures and the alternatives considered. However, with limited guidance on how to approach this document, numerous formats, with a variety of styles have been adopted.
With this in mind, it is not surprising that these documents are often highlighted as one of the weaker areas of EIA. Furthermore, as a summary of the environmental statement, it is usually one of the last documents to be completed before submission because it has to contain information from all technical chapters and is often a document on which less emphasis is placed.
To address this, earlier this year IEMA published a short briefing note and has created an online library of NTSs. These tools can be used by EIA practitioners and should help to establish best practice and standardise the quality of summaries being prepared.
A new approach?
Based on the guidance available, WSP are now beginning to use an interrogative approach to the preparation of NTSs, such as the one for Project Dove. This method incorporates the required information about the proposed development, alternatives considered and key effects, but presents it through a series of questions and responses.
The benefits of this approach include the production of a document that is focused on the environment issues that matter most to the audience who will be reading it. The questions posed are based on queries and the main issues brought up by the general public during consultations undertaken during the EIA process. This also can allow the document to concentrate on potentially more significant effects while reducing the space given to those that are less insignificant.
The interrogative approach removes the potential inclusion of unnecessary and detailed information, by focusing on the topics that stakeholders have concerns about and providing concise answers to the questions set.
The use of questions also limits the amount of “copying and pasting” from the main body of the environmental statement and ensures the author considers the information and how best to present it. The approach, therefore, ensures a succinct summary of the key environmental information from the statement and reduces the length of the document, making it more accessible to both decision makers and the general public.
Furthermore, this interrogative method lends itself to the incorporation of visualisations, such as photomontages, in response to questions set out such as: “I live on X street, can I see the development?“ This can significantly aid understanding of what the development proposals will look like, and can be tailored to show the views from particular locations and local landmarks, providing interested parties with a tangible and engaging way to understand the development.
However, there are also challenges in using this approach, including the additional time required to present technical information in non-technical language and in an “answer” format, particularly with regard to areas such as air quality and acoustic effects which require complex language to describe the assessment of the significance of effects.
Discussion of local historic or landscape assets, which are often highly prized by the local community, but are considered to be of low value or importance, can also be difficult to write and need to be sensitively approached.
As a document which is crucial to effective engagement and in helping stakeholders to understand the potential effects of development proposals, NTSs need to be what they say they are.
Despite the additional time required to produce interrogative style NTSs, this approach can have significant advantages in furthering stakeholders understanding of developments.
This article was written as a contribution to the EIA Quality Mark’s commitment to improving EIA practice
Kyle Welburn is a senior consultant at WSP Environment &Energy