Environmental statements - unfriendly giants

Andrew Saunders and Nicola Hartley describe what has made environmental statements so cumbersome and what can be done to improve them

Environmental statements have become unwieldy, unmanageable and unreadable. They passed the point of compliance with the Environmental Impact Assessment (EIA) Regulations a long time ago and do considerably more than describe the three elements they are required to, namely:

  • the aspects of the environment likely to be significantly affected;
  • the likely significant effects of the development on the environment; and
  • the measures envisaged to prevent, reduce and where possible offset any significant adverse effects on the environment.

Often they include detailed descriptions of consultations, the background to and justification for the project, planning policy reviews, geological risk assessments, safety assessments, draft site waste management plans and convoluted assessments dealing with effects which aren't significant. But why has this happened?

In our view the reasons include:

  • the multitude of, sometimes conflicting, topic-based guidance and advice;
  • coordinators and specialists who slavishly follow guidance even when it is inappropriate;
  • legal teams requiring scheme development details to be included to demonstrate the iterative process;
  • legal precedents resulting in the need to err on the side of caution;
  • a large number of consultee responses and requirements - particularly for nationally significant infrastructure projects (NSIPs);
  • peer reviewers requesting additional detail rather than suggesting streamlining;
  • clients using the environmental statement as a reporting mechanism for all other project information;
  • the decision to report the assessment of multiple scenarios to allow flexibility in the application;
  • a lack of focus on significant effects; and
  • the provision of large amounts of generic text.

The inclusion of such elements is unhelpful for members of the public wanting to understand the impact of a project on them and their properties. Gaining an understanding the totality of the effects of development is particularly difficult unless a well presented cumulative effects assessment has been provided. Furthermore, environmental statements can be prohibitively expensive and difficult to download.

In completing a review of 100 UK environmental statements produced in 2010, IEMA found the main text of an average statement was more than 350-pages long, with those for NSIPs almost double that. In our own review of a selection of environmental statements currently with the Infrastructure Planning Commission (IPC) for examination, we found the average cost of buying a statement was £260 and the average length 4,200 pages (see table).

Review of environment statements lodged with IPC

Number of pages

Least

Most

Average

Non-technical summary

20

70

34

Main statement volume

300

2120

940

Entire statement

2400

8100

4200

Not only do environmental statements produced for NSIPs comply with discipline-specific advice they also have to comply with IPC advice notes and wide-ranging consultee requests. Arguably they represent the latest situation in terms of environmental statement reporting in England and Wales, with the likelihood of these practices filtering down to non-IPC project statements making them even longer.

IEMA's research also reports that practitioners do not have sufficient time to write concise statements with some commenting they view the non-technical statement as being aimed at a public audience rather than the environment statement itself.

In view of time pressures, resource constraints, the need for efficiency and to make environmental statements more readable, there are a number of options available to EIA practitioners to help reduce the size of statements while improving their quality, including:

  • Education - better training on how to improve reporting, streamlining statements and focusing content on the requirements of the EIA Regulations.
  • Scoping - clearly justifying at the scoping stage why effects can be scoped out and if requests for additional assessments are made carefully consider whether those effects are significant. Practitioners should revert back to the Regulations when being asked to include non-significant aspects and reporting.
  • Study area size - keeping a focus on the area most likely to be significantly affected. Large study areas can make presenting significant effects close to the project footprint difficult.
  • Reporting potential effects - considering whether it is necessary to present potential effects in the absence of mitigation when the mitigation is an inherent part of the scheme.
  • Cumulative effects - improving consideration and presentation of cumulative effects on individual receptors.
  • Summary tables, mapping and reports - using tools to better summarise effects on key receptors or scheme mitigation. These may be summary tables or graphics to represent cumulative effects on individual receptors, as recommended in the European Commission's Guidelines for the Assessment of Indirect and Cumulative Impacts (see diagram below).

So, what is a reasonable size for the environmental statement of a large project? We suggest 400-pages for the main volume, with diagrams and figures used to support the statement and explain the findings of the EIA. While there might not be a one-size-fits-all answer it's clear that there needs some bolder and pragmatic decision-making during the environmental statement preparation process if we are to reduce the burden placed on consultees, decision makers, the public and practitioners.

This article was written as a contribution to the EIA Quality Mark's commitment to improving EIA practice.

Andrew Saunders is director of environmental services at Hyder Consulting and Nicola Hartley is a principal environmental consultant.

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