TEP's Amy Longmore discusses how practitioners could ensure that environmental statements are more proportionate
The environmental statement (ES) is produced from the input of many professional specialists: the environmental impact assessment (EIA) coordinator; the technical specialists; peer reviewers; the legal advisor; and the client.
Each has their own idea about what should go into an ES. The client may want to err on the side of caution and go above and beyond compliance to secure planning consent, but still want to control costs of producing the document.
Meanwhile, the technical specialist may lack focus on significant effects; the legal reviewer may require over-detailed project descriptions to show the iterative process; and the peer reviewer may request additional detail rather than suggesting streamlining.
The aim to ensure the ES is proportionate becomes a difficult task when trying to incorporate ideas from everyone involved in the process. This is also usually combined with producing the ES under time pressures and with resource constraints.
The ES can, therefore, become a larger-than-life document that is unmanageable and unreadable. Such a document is unhelpful to members of the public, consultees and the consenting authority attempting to understand the significant effects the development may have on the environment.
IEMA’s Quality Mark Forum 2013 brought to life how imperative it is to produce a proportionate ES that can be understood by everyone. While the EIA coordinator must ensure this focus is achieved, it should also be the emphasis for everyone involved in producing and inputting into an ES. A few ways everyone could ensure they are working with a “proportionate focus”, include:
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Staying focused – it is much more difficult to produce a well-written and succinct ES than it is to produce an ES full of too much information. Revisit the wording of the EIA Regulations and ensure you focus on the main elements, namely:
i) the aspects of the environment likely to be significantly affected;
ii) the likely significant effects of the development on the environment; and
iii) the measures envisaged to prevent, reduce and where possible offset and significant adverse effects on the environment.
- Early and on-going engagement – start discussions with consultees early in the EIA process. This will aid with scoping and benefit the focus of the ES.
- Scoping – all EIA practitioners know the importance of scoping out effects that are not likely to be significant, yet many are still afraid to do so. Be brave and justify your reasons for scoping out effects. Revisit the scope of the EIA as the project develops.
- Presentation – use different presentation styles to report significant effects. Break up long descriptions of baseline information and project descriptions. Tables, bullet points, figures, diagrams and appendices are all ways that information can be presented clearly and succinctly.
- Be a strong EIA coordinator – prepare clear guidance for the topic specialists regarding your aims of the ES. Make sure everyone involved is aware of what an ES should present and the need to be proportionate. This includes those, such as the client, who have an input to the ES but may not be directly involved and those new to EIA.
As we produce proportionate ES documents we will soon start to appreciate benefits, such as:
- Time savings – time will not be spent on unnecessary assessments and collating of information.
- Client savings – costs will be reduced as less time is spent on EIA.
- Aiding the decision maker – a proportionate and focused ES will help the decision maker understand the effects of the development and lead to quicker determination time.
- Developing best practice – producing proportionate ES documents will become habit.
It is inevitable that, at times, those involved in preparing information for an ES will go off-piste. Specialists may become bogged down in information, authorities may be highly conservative in scoping and the client may get worried about the risk of not gaining consent if the document feels “too light”.
EIA coordinators play a vital role to keep everything in check and put everyone back on the “proportionate track”. It is necessary to clearly communicate to those involved in the EIA process your aims and the intended methods of producing a proportionate ES.
We are all aware that ES documents need to be proportionate and we are becoming more open to the different ways this can be achieved. We now need to put it into practice and begin to reap the benefits.
This article was written as a contribution to the EIA Quality Mark’s commitment to improving EIA practice.
Amy Longmore is a senior environmental planner at TEP
