Susan Evans and Helen North consider how Environmental Statements can be more accessible and understandable
There has been much focus on the length of Environmental Statements (ES) in the UK and a growing recognition that they have generally been increasing in length and becoming more complex year on year. The recent policy paper ‘Nationally Significant Infrastructure: action plan for reforms to the planning process’ highlights this trend.
EIA practitioners have never been more constrained in having time to write, edit, or review ESs; staff resource constraints within the environmental consultancy sector are well documented. Nor has there ever been a more compelling and urgent need to deliver and often attempt to ‘fast-track’ developments through the consenting process in order to help us fulfil our obligations to achieving net zero and climate change adaptation/mitigation. The drivers and aspirations for proportionality are therefore crystal clear.
Delivering Proportionate EIA - A Collaborative Strategy for Enhancing UK Environmental Impact Assessment Practice, was published in 2017 and included a ‘call to action’ for the EIA community to “facilitate a suite of activity that converts the clear enthusiasm for proportionate EIA into positive and co-ordinated initiatives”. Four key themes to embrace change highlighted were “people, scoping, collaboration and innovation and digital”.
Digital EIA is being embraced, making it easier to access the parts of an ES that are of specific interest to stakeholders, and enabling interested parties to interact in new ways with submitted information. But has this guidance had the impact it intended? More importantly, how can EIA practitioners accelerate the pace of change?
When leading an EIA, there are a plethora of boxes that must be ticked to satisfy an EIA coordinator’s responsibilities. First and foremost, ESs must be technically sound, coherent and entirely consistent between topics and across the application documents. Each ES must able to withstand scrutiny from a wide range of stakeholders and decision makers to fulfil its primary purpose i.e. to inform decision makers of the likely significant effects of the scheme on the environment.
However, ESs must do a lot more. They must facilitate, and not inhibit the detailed design of a development, including construction and operation without incurring repeated consent variations. The Rochdale Envelope approach is often used to provide proportionate flexibility. Here there is a delicate balance to be maintained – an appropriate degree of flexibility needs to be agreed, but not so much flexibility that an EIA starts to assess potentially significant effects that would never occur in practice.
Much has already been written on the importance of scoping in proportionate EIA to remove insignificant issues from ESs, whilst also providing the necessary assurance of technical competency for this purpose. Those topics where there are standard practice mitigation/management methodologies available, and commonly implemented control measures (such as a construction environmental management plan) should be agreed to be routinely scoped out. This would ensure the proposed scope and final ES focuses on those disciplines of key importance.
The introduction of recommended page limits for ‘core’ ES text (i.e. a main ES volume) would focus attention on proportionality and provide a document that focuses on the assessment results and is therefore far more accessible. Further materials would be provided as supplementary information, for example, setting out the detailed methodology and approach undertaken within appendices, available for those with a specific interest. This would not get in the way for those wishing to obtain an overview in the core ES text.
Looking to the largest national infrastructure project the UK has ever seen, High Speed 2, good use of supporting baseline information and data reports and accompanying detailed map books was used and has set a clear precedent. Other options include provision of sign-posting documents tailored to certain stakeholders, which set out where relevant information relating to a specific topic is located.
There are many other examples of how EIA practitioners aim to streamline ESs and to make them more accessible and understandable. The drive towards digital ESs and the future role of Environmental Outcome Reports are all moving in this direction. The role of IEMA is to galvanise the combined skills of clients, consultants, regulators and stakeholders in order to modernise the EIA process, with proportionality being central to making EIA more accessible and transparent.
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