Scott Johnson from Jacobs encourages environmental impact assessment (EIA) professionals to start thinking laterally about EIAs
There is a growing interest in how development projects interact with other proposals. Among a number of possible interactions, a key question to ask is, how confident can you be that it isn’t worth pursuing a particular issue in an EIA if you don’t know who else has been impacting on that issue lately or, indeed, who plans to in the near future?
You need only look so far as recent court cases on cumulative effects assessment (such as Brown v Carlisle City Council) to see a growing awareness of this issue, and a keenness on the part of stakeholders, and potential objectors, to get involved. However, there are other good reasons to consider a greater appreciation of the world around your EIA projects, including public endorsement and maximising sustainability.
Thinking laterally
An EIA practitioner might aim to tackle the interactions at the project level by employing what is termed “lateral integration”.
Rather than extending up to a strategic environmental assessment (SEA) or down to an environmental management plan, lateral integration extends sideways drawing on the results of other processes occurring at a similar level of detail to achieve better outcomes.
As a concept, lateral integration is perhaps more popular in the world of SEA, but it applies equally to EIA. Also, while it is most often applied to cumulative effects assessment, it should not be restricted to this element of EIA.
Guidance on lateral integration hints at the value of front-loading – incorporating the influence of other projects into your EIA at the screening or scoping stages – in order to take these projects into account in the baseline of your EIA.
This means that any impact predicted to occur in these other projects becomes part of the future baseline for each environmental topic. With this sort of approach, the days of “tacking on” cumulative impacts assessment may soon be over. However, the debate about how committed a development has to be before this kind of lateral integration is taken into account in an EIA is a difficult one.
Certain guidance on EIA has a very narrow definition of what should be included, such as permitted development only. While in many cases is correct, there are circumstances where the potential occurrence of another development is a consequence of your own development – for example where a new transport link makes viable the development of an adjoining site. In such cases a lack of planning permission may be inconsequential in the forecasting of future impacts, which doesn’t make completing EIAs any easier.
Operational developments
The issue with operational developments is almost a non-starter – but should it be? There is an expectation that once operational, the impacts of other developments are automatically and perhaps immediately absorbed into the base case.
While this may be comforting for the next developer, because it’s not their problem, for communities, this can be the fundamental bone of contention. Should we be surprised by anti-development sentiments if EIA only covers the next impact, and not previous ones?
This is not to suggest that EIA should be based on a historic baseline, but EIA could acknowledge environmental monitoring data, planning and permit conditions of other developments, which (if screened properly) may give valuable additional insight into the way the environment is changing in an area and adding the human element.
Challenges and opportunities
Alongside the positive impacts of lateral integration, there are also challenges to the approach including:
- the availability of information on other developments;
- achieving cooperation between developers;
- gaining planning authorities’ agreement on joint mitigation;
- a lack of clarity on what is “significant” among developments – particularly soft issues such as general amenity or tranquillity;
- a lack of definition on accounting for past development – how far back should an EIA look;
- a fear that future objectors will find something beyond reasonable limits of the project to drum up opposition; and
- incompatibilities between EIAs.
There are no easy answers to addressing these challenges, but there are many benefits to be gained when we address them. Ideally, a front-loaded, laterally-integrated EIA should:
- have a scope that includes the combined potential impact of proposed and, perhaps, recently completed developments;
- ensure each discipline (ecology, air quality etc) has considered the impacts of other developments into the baseline and projected trends;
- include a sense of the community’s response to recent impacts;
- ensure each discipline fully integrates cumulative effects; and
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build partnerships among those parties responsible for linked impacts in the area, sharing mitigation.
This article was written as a contribution to the EIA Quality Mark’s commitment to improving EIA practice.
Scott Johnson is head of SEA services and a senior environmental consultant at Jacobs
