Jamie Gleave offers a practitioner's view on the role of the planning appraisal in the environmental impact assessment (EIA) process
In the world of EIA, a question I frequently ask is whether something that has been done actually needed to be done in the first place.
I recently completed a number of interactive back-to-basics training sessions across several RSK Environment offices which sought to remind staff of what EIA is really about, why we have to do it, and how we can achieve greater consistency in our outputs.
Topics discussed were wide ranging in their scope and generated healthy debate about aspects of EIA. While explaining the outline reporting framework to be adopted for our future environmental statements (ES), one attendee interjected with a question: “Where does my planning chapter go?”
Rather than offer an answer to the question, my reply was: “Why do you need a planning chapter?”, which prompted many confused expressions.
What transpired was that inclusion of a planning chapter in an ES was deemed by several in attendance to simply be standard practice, with some believing that such a chapter is a formal requirement under the EIA Regulations.
The codified EIA Directive 2011/92/EU ensures that certain types of projects likely to have significant environmental effects are subject to EIA prior to approval or authorisation being granted. The outcomes of the EIA process, therefore, play an integral role in the planning and determination process.
A key test when determining planning applications is whether a proposal achieves compliance with overarching local, regional and national planning policy. It is therefore reasonable to conclude that some form of planning compliance appraisal should be presented as part of a planning application indicating how the developer considers their proposals perform in planning policy terms. The key question is where.
Planning statements
In the planning arena, this relationship is frequently presented in the form of a supporting planning statement – a document compiled to demonstrate how a proposal will contribute to the fulfilment and achievement of environmental, social and economic policy objectives at various levels.
These documents are often promotional in their reading, advocating the benefits of a proposal in an attempt to influence conclusions, improve the perception of acceptability, and increase the likelihood of securing development consent.
The planning statement provides a useful tool for capturing and conveying all planning related matters, including detailed schedules of individual policies and how a proposal performs against each.
Experience indicates, however, a growing trend for EIA consultants to incorporate detailed planning appraisals into their ES. This observation was verified by the training session feedback, and by virtue of the fact that some attendees were unfamiliar with the role and purpose of a planning statement.
Planning and EIA
A review of the EIA Directive and secondary legislation in the UK reveals there to be no formal requirement to consider planning matters as part of the EIA process, nor report them in the ES. Current practice suggests practitioners are including planning appraisals in EIA where there is no need to do so.
Further evaluation identifies a range of possible reasons and potential drivers behind inclusion of policy matters in an ES:
- Budget and resource constraints may drive a need for the ES to capture all relevant matters in a single cogent document, rather than covering aspects such as planning in a separate standalone report that inevitably requires time and money to prepare.
- A particular proposal may form a key role in the achievement of wider development aspirations or government targets, therefore requiring the political dimensions of the project to be clearly introduced. This may also tip into justifying the strategic political need for scheme progression.
- Planning can also emerge in an ES as a consequence of having to set out any policy considerations that may have influenced the final form of a development project, or the scope of individual technical assessments undertaken.
In EIA we frequently find ourselves scoping particular assessments in because we’re fearful of missing something important, often forgetting that the original purpose of scoping was a mechanism to remove topics, not add them in. In this regard, planning appraisals aren’t really any different.
We find ourselves including them in the ES because we feel there is an inherent need to do so, or that someone may pull us up further down the line if we neglect to consider the implications of the project on the wider planning sphere.
Policy compliance can therefore be established as part of, and in parallel with, the EIA process, but the overriding issue is whether the detailed appraisal of such should be reported under the cover of the ES.
The ES should always be open, transparent, impartial and non-promotional, although the policy framework of individual technical assessments should be presented in the document where relevant. My view is that the detailed appraisal of compliance with individual policies is usually a lengthy affair that sits better outside the main body of the ES.
The ES should not provide the vehicle for planning appraisals undertaken to simply promote a scheme to stakeholders and decision-making bodies.
This article was written as a contribution to the EIA Quality Mark’s commitment to improving EIA practice.
Jamie Gleave is a principal EIA consultant at RSK Environment. He is a Chartered environmentalist and Chartered scientist, a Full member of IEMA and a Full member of the Institution of Environmental Sciences.
