Barbara Carroll and Ruth Thomas discuss and reflect on how SEA and SA practice has evolved and is continuing to change in the light of the real world experience of IEMA members.
When the Strategic Environmental Assessment (SEA) Directive was transposed into UK legislation in July 2004 there was much discussion about what the effects of this new legislation might be.
How many plans that might previously have passed through the planning process without specific environmental scrutiny, would be ‘caught' by the new legislation?
How would plan makers with growing appraisal requirements and increasing scrutiny pressures cope with these demands?
How would planners and environmentalists address the new requirements and did they have the requisite skills to effectively handle the consultative and integrative requirements of SEA?
At the same time we saw changes brought through the Planning and Compulsory Purchase Act (2004) requiring the broader based Sustainability Appraisal (SA) process for spatial development plans in England and Wales.
Again the practitioner community started to question how they would deal with the more integrated approach necessary to meet the requirements of both processes.
Is an integrated assessment more effective or do environmental factors become diluted within the wider approach? Scotland, through the Environmental Assessment (Scotland) Act 2005, chose to require SEA, rather than SA, of all its plans, programmes and strategies.
In the context of these changes, there was, however, a sense that overall the requirement for SEA offered the potential for capacity building and could lead to better plan making overall with enhanced protection for the environment.
Since implementation of the legislation, IEMA has offered workshops, conferences and specific courses on SEA to inform the ongoing debates and contribute to liaison with government.
This article reports the findings of IEMA's bespoke SEA/SA training day on 2 June 2010 for experienced practitioners and designed to improve practice (see: www.iema.net/cpd for further information).
Developments in SA/SEA and plan making
How, then, has plan making and the process of SA/SEA developed over the past six years? How have the professional assessors contributed to more effective practice?
It is useful to remember some of the historical perspectives of SEA. The strategic process was considered to offer opportunities for addressing some of the key weaknesses known to be inherent to project level Environmental Impact Assessment (EIA). SEA is proactive, can better deal with alternatives, can better address cumulative effects, and promotes sustainable development. We also need to remember that SEA/SA sets the context for EIA and subsequently Environmental/Sustainability Management (EM) such that with an effective strategic process, the project level and monitoring stages should be more effective and efficient.
Whilst there is case law to guide project level EIA and standards/auditing processes for EM, similar benchmarking is more difficult for strategic assessment. However, a number of studies have been undertaken to explore progress with SEA/SA.
An early study1 using questionnaires to local authorities carrying out SA/SEAs of development plans found that 75 per cent agreed SEA/SA improved the sustainability of plans with 37 per cent reporting significant changes to the plans; 47 per cent agreed that SA/SEA was an effective use of time and resources.
Four key challenges facing SA/SEA were reported through IEMA2, namely cross-sectoral working, linking with other tools, implementing monitoring, and addressing the big issues such as climate change.
By 2008 and several years' experience of SEA/SA in the UK, a similar study3 concluded that more than 50 per cent of respondees agreed that SA/SEA improves plan making and consideration of plan options. However, by this time there was anecdotal evidence that SA/SEAs were not being implemented in an efficient way and were perhaps more driven by a risk-averse culture with concern to avoid costly challenge at Examination in Public or Judicial Review. A formulaic approach with excessive detail (and expansive reports!) was limiting the opportunities for SEA to be creative.
Research4 undertaken for DCLG confirmed that SA/SEA was not being implemented in an efficient way. Key issues to improve effectiveness included better focusing of the evidence base and tailoring of scoping, clearly articulated alternatives, and that the level of detail of the assessment should be appropriate to the level of the plan in the hierarchy.
Other issues mentioned were the difficulties of Cumulative Effects Assessment (CEA) and engaging with the public, including improving the quality of Non-Technical Summaries. IEMA's response to the CLG study was reported in the EA News section of issue 97 of ‘the environmentalist' and raised concern over its lack of consideration of the need to enhance the skills and knowledge of all those involved in SEA/SA.
The need to review and reflect on practice is further evidenced by the ongoing international studies by IAIA (and to which IEMA has contributed) into the effectiveness of Environmental Assessment, to be published next year.
Speaking from experience
Six years on, these were some of the questions and topics that attendees at IEMA's training course for experienced SEA/SA practitioners (led by Enfusion Ltd) came to discuss and work through together. Attendees came from across IEMA's membership spectrum and included representatives from local and central government, consultancy, industry, regulatory agencies and the third sector. Working in small groups they engaged in a series of exercises followed by wider whole group debates, that covered some of the more difficult issues in SA/SEA including: dealing with cumulative effects assessment; the consideration of alternatives; and the format and role of scoping in the overall appraisal process.
Over the course of the training session a number of key issues and themes emerged that reflected the challenges, and sometime the frustrations, of delivering SA/SEA in ways that make it meaningful and valuable for plan making - and more effective for promoting sustainable development (see boxes below).
The nature and the energy of the debate suggests to us that an established bedrock of practice and experience is now allowing practitioners to critically reflect on and really challenge the approach to SA/SEA, and the final product that emerges. It suggests a groundswell of ideas in the professional community and an appetite for change.
So how might change come about and what do these reflections say about the skills and competencies that we as practitioners need to develop? Whilst there is a role - and this was emphasised by a number of IEMA members - for sound, well grounded technical environmental and sustainable development competence, there are also a set of skills that relate to the application of this knowledge that should be developed and promoted.
Communication, engagement and wider education competencies will be core in enabling environmental professionals to interact and effectively communicate key messages to professionals in other disciplines.
We actively need to hear and address criticisms that technical language excludes and confuses the audiences that we are trying to engage. Future development and training goals may need to focus more on interdisciplinary working including the connections and relationships between professions, rather than on pure technical competence for its own sake.
It is clear that many of the issues raised and debated by IEMA workshop participants have also emerged as core findings in the recent study produced on behalf of DCLG. The real hope is that these findings and the issues raised by practitioners across the profession are actively translated in more effective practice that recognises and responds to the issues raised through experience.
We as practitioners hold the key to better practice, by having the courage to make bolder decisions and to speak with clarity across professional boundaries about the techniques we use. This way we can ensure that we deliver more creative and engaging SA/SEA in support of future plan making.
Acknowledgements - our thanks go to all the participants who have attended IEMA's ‘SEA for experienced practitioners' training course and contributed to the learning and debate on this subject. For more information on this CPD course and IEMA's other training courses: www.iema.net/training
1. Keeping SA/SEA strategic and timely
Appraisal is most effective when it is in tune with the timetable and the development of the plan itself. IEMA members were clear that the best appraisals, in their experience, provided information from the outset, informing, and being informed by, the plan making process. However, playing catch up, or even the retrofitting SA/SEAs were not uncommon scenarios for some appraisers, and there was a view that this approach undermined the value of the appraisal process overall.
2. Scoping should be relevant
The danger of ‘too much detail' was a key theme in the practitioner debate. Whilst the need for rigour and substance is important, it was considered that the obsession with detail and process often clouded the potential for clarity and creativity.
IEMA members felt strongly that the focus in scoping should be on the really significant issues. However, their experience was typified by a culture of risk-aversity that is driving SA/SEA to cover everything, rather than telling a focused story addressing the impacts and effects that really matter.
3. Assessing alternatives effectively
Attendees reflected that the consideration of alternatives was frequently poorly executed in SA/SEA. The reasons for this were varied, but included practicalities, such as a lack of funding, as well as more fundamental issues about plan makers not understanding how SA/SEA could usefully help in the evaluation of plan options.
It was considered that as practitioners we have a core role in ensuring that policy and plan makers understand the requirement for alternatives assessment (particularly in SEA) and that we use this process to integrate environmental and broader sustainable development issues into decision-making.
4. Cumulative effects assessment
By exploring the range of cumulative effects methods at their disposal, IEMA members were able to reflect on the challenges of undertaking this element of the assessment process. Interestingly, some of the simplest methods were also considered the most effective.
For example, using checklists at the start of any assessment/appraisal process and undertaking stakeholder panels and workshops for the more complex/interactive elements of the assessment often produced the most robust results. Overall there was a view that achieving a holistic approach to the consideration of cumulative effects remains a challenge - but that this was a key element of any strategic assessment process.
1Therivel & Walsh, 2006, ‘The Strategic Environmental Assessment Directive in the UK , one year on', The Environmental Impact Assessment Review, Volume 26, Issue 7, October 2006, Pages 663-675
2Fry C, 2007, Towards the next wave of SEA ‘the environmentalist'
3SDRN, LUC & RTPI, 2008, ‘Spatial Plans in Practice: SA/SEA'
4DCLG, 2010, ‘Towards a more efficient and effective use of Strategic Environmental Assessment and Sustainability Appraisal in spatial planning', Scott Wilson Ltd
