NJL Consulting's Chris Garratt discusses the aims of scoping in environmental impact assessment (EIA), the barriers to effectiveness and what can be done to improve practice
Although EIA scoping is not mandatory under the Town and Country Planning EIA Regulations, it is considered best practice in the UK. The aims of scoping are:
- a focused and cost-effective EIA;
- an EIA informed by specialist local knowledge;
- agreement of assessment methodologies; and
- reduced risk and delay.
Barriers to effective scoping
Through research and experience, we have identified a number of barriers to effective scoping:
1. Scoping requests
Sometimes the information submitted by the applicant is not adequately detailed to enable officers and consultees to make an informed decision on the scope of the EIA.
There are also situations whereby a large amount of technical work is undertaken and the results are then submitted to the local planning authority. This approach is effectively consulting on initial EIA findings, rather than determining the scope of the environmental statement, and results in additional time and cost implications for the applicant and pressure on resources at the local planning authority and consultees to review and respond within the five-week deadline.
2. Local planning authority officers
The amount of experience in dealing with EIA developments varies between local authorities. Where officers are inexperienced in responding to EIA scoping requests this can influence the quality of the scoping process.
Officers are also under political pressure and this has the potential to influence the content of scoping opinions. This is particularly the case with comments made by the public, which may be ill informed.
3. Consultees’ responses
The quality of consultees’ responses still varies greatly and often they are significantly delayed or not received at all. Sometimes, where a response is received, this can be non-site-specific and includes generic text relating to issues that might not be relevant to the project.
Another issue is that consultees’ responses sometimes complicate the process by including comments on topics that are outside of their remit or refer to topics that are not relevant to EIA, such as built sustainability.
4. One-off approach to scoping
Scoping is a continuous process and the EIA scope can change at any point prior to determination. Topics deemed likely to be significant at first may prove not to be once further work is carried out.
Alternatively, following formal scoping and the progression of surveys and technical work, it may be that a topic previously scoped out is deemed likely to be significant and should be scoped in, or assessment methodologies need to be revised.
Effective EIA scoping
There are a number of ways in which EIA scoping can be carried out more effectively to overcome these barriers, these include:
1. Scoping requests
Early scoping avoids the potential for unnecessary work, or work being undertaken using a different methodology to that preferred or required by officers and consultees.
Early scoping also helps to avoid unnecessary cost and time implications for the applicant, local planning authorities and consultees.
Although the scoping report should include overviews or summaries of technical information and likely significant effects, it should be focused on agreeing the topics to be included in the EIA and the methods of assessment. It should not be overly long or a baseline report for the environmental statement.
2. Discussions with the local planning authority and consultees
It can be useful to discuss the project and the proposed EIA methodology with the local planning authority officers and consultees (if necessary) before the scoping request is submitted. This helps to ensure they understand the project and the likely significant environmental impacts, before the formal scoping request is submitted.
3. Review of draft scoping opinion
One way of speeding up the scoping process is to ask officers to send copies of consultees’ responses as they arrive so that queries can be dealt with promptly. If possible, it is also helpful to review a draft copy of the scoping opinion to enable its content to be discussed before it is formally issued.
4. Continuous EIA scoping
EIA scoping is a continuous process and should be updated as findings or circumstances change, especially as EIAs can be undertaken over a long period of time. One example of this is cumulative impacts with other developments. There may not have been a requirement to include a cumulative impact assessment at the initial scoping stage, however, if another development is initiated which could result in cumulative impacts then this would need to be included in the EIA.
This article was written as a contribution to the EIA Quality Mark’s commitment to improving EIA practice
Chris Garratt is a senior consultant at NJL Consulting. This article follows on from an IEMA webinar which took place on 28 September 2012, for more information please contact 0845 362 8212 or [email protected]
