Shouldn't EIA be more farsighted?
Martin Hendry from Adams Hendry argues that environmental impact assessments (EIA) for infrastructure projects must better consider long-term impacts
Dealing on a daily basis with proposals for large-scale physical infrastructure leaves me increasingly pondering at the fragile and confused relationship that exists between the EIA and strategic environment assessment (SEA) processes and strategic decision-making.
There is a huge disparity between the limited horizons of environmental assessments and the lifetime effects of major infrastructure works. The latter are the structural supports for modern civilisation and have implications far beyond the immediate, with repercussions for spatial planning potentially for many generations to come.
The hundreds, occasionally thousands, of pages now routinely served up as EIAs for new roads, sewers, airports, railways and ports, record in great detail proposals submitted for consent, but provide few insights into the longer-term environmental ramifications of what is being proposed.
EIA professionals, it seems, may have honed their ability to judge whether an impact is marginally significant, slightly significant or just a little bit significant, but they don’t have a great deal to contribute to the bigger, strategic picture.
Regrettably, it’s much same with SEAs, too many of which appear to have morphed into standard checklists. These can also be of doorstep proportions, but essentially lacking the cogent analysis of strategic options and their environmental consequences that you would expect.
Of course, strategic planning is currently in the doghouse. Regional spatial strategies have been on the verge of being abolished for some time.
Their fault appears to have been that they focused on an uncomfortable truth; namely that some matters, including major regional infrastructure, really do need to be dealt with top-down.
For the moment at least, strategic planning appears to have been replaced by ad hoc announcements about individual items of infrastructure – often with an eye to voter opinions and to financial, rather than environmental, consequences – and left-field ideas such as islands in estuaries.
Then there is the plainly absurd proposition (see section 111 of the Localism Act) that regional development strategies can emerge from the ground up, once local communities get together and realise what is required.
History shows that the insertion of large-scale structural improvements to overloaded infrastructure may be game-changing, enabling and forming patterns of development for decades to come. These difficult decisions deserve more than increasing volumes of detailed impact data.
Infrastructure planning demonstrably requires an overview strategy and (whisper it quietly) is complex and inevitably time-consuming. There are no quick fixes.
Government announcements of future schemes, unsupported by more than a few paragraphs in a national policy statement, leaves subsequent infrastructure promoters with the unenviable retrospective task of demonstrating their scheme is the preferred environmental option.
The most dependable way to approval through any consent system is the promotion of schemes that are well-thought out and demonstrably the most appropriate environmental solution when measured against other options.
No-one pretends this is a straightforward matter, but where are EIA and SEA in all this? Shouldn’t they be amongst the first response tools for the job, helping to formulate strategy and analyse options rather than simply recording (in increasingly impenetrable language) the effects of proposals in ever increasing detail?
This article was written as a contribution to the EIA Quality Mark’s commitment to improving EIA practice.
Martin Hendry is a director at Adams Hendry Consulting