Regional Strategic Environmental Assessment in the Southeast of England: Background Information (1)

EFTHYMIS ZAGORIANAKOS

Tutor of Hellenic Open University, MSc Course: Environmental Design of Cities and Buildings, Module: Design, Environmental Effects and Methods for their Evaluation

18 Papaskreka str., 173 42 Athens

GREECE

Abstract: - This is the first of two papers that trace SERPLAN[1]’s efforts to put Sustainability Appraisal (SA) – a Strategic Environmental Assessment (SEA) methodology - into practice through the English statutory regional planning process. The discussed attempt was undertaken during an era when SEA was seeking its way from the land-use planning to the regional policy level of British decision making. The integration of SA into the Sustainable Development Strategy for the Southeast of England, which is looked upon in detail throughout the second Conference Paper, is viewed here within the background documentation set by similar environmental appraisal and Sustainability initiatives in various levels of British regional policy and planning system. Particular attention is drawn to the dynamic course of the British environmental planning system throughout the last 20 years of its evolution and to its future methodological alterations in view of the recently enacted EC Directive on the ‘Assessment of the Effects of Certain Plans and Programmes on the Environment’ [2].

Key-Words: - Strategic Environmental Assessment (SEA), Sustainable Development, Regional Planning, SEA Directive, Sustainability Appraisal.


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1.  Introduction

The focus of this first of twin papers, is the presentation of the research regarding the application of a Strategic Environmental Assessment (SEA) methodology called Sustainability Appraisal (SA) to the Sustainable Development Strategy for the South East of England (SDS).

An ‘all-purpose’ and by all means simplistic, although widely accepted, definition of the SEA term is the ‘environmental assessment, evaluation and monitoring of the impacts of human strategic actions such as Policies, Plans and Programmes (PPPs) on the environment’ [23], [24], [25]. SEA, by forecasting and mitigating the negative environmental impacts of Policies, Plans, Programmes [and ultimately Projects, becoming then Environmental Impact Assessment (EIA], it is thought to contribute to the promotion of Sustainable Development (SD) throughout the entire decision-making cycle [19], [1].

Although SEA’s validity as an environmental management tool is recognised in the literature (e.g. [13], [26], [22], [16], [21]), its application worldwide is not widespread as it is mainly restricted to land-use development planning. At a regional planning level in particular, and especially at a European Union level, only a few cases of SEA application have been examined. Recently, through the enforcement of the EC Directive on the ‘Assessment of the Effects of Certain Plans and Programmes on the Environment’ [2], SEA is also making its regulatory way into the European regional planning system.

Within the United Kingdom (UK) where this case study originates, the non obligatory requirement of undertaking an SA of Regional Planning Guidance (RPG) has only recently being put forward by government guidance on regional policy [14] and most Regional Planning Authorities are currently in the process of undertaking one.

The following sections will provide the basic background information about the regional planning and SEA context in the Southeast of England. A brief presentation of the documentation relevant to the topic under examination, with a particular reference to the SA, follows the introduction. The third part, discusses the evolution of the environmental appraisal methodologies in Britain. The Paper concludes with a specific reference to the recently adopted SEA Directive and its relevance to and influence that this has exerted on the preparation of the SA of the Sustainable Development Strategy for the South East of England which is further discussed in the second Conference Paper.

2  The basic documentation

2.1  Regional Policy Guidance for the South East of England

The preparation of the Regional Planning Guidance for the South East (RPG 9) [12] was the responsibility of the then British Secretary of State for the Environment, Transport and the Regions and covers the period up to 2016. Its purpose is to provide a regional framework for the preparation of local authority development plans and the spatial framework for other strategies and programmes in the region. These include the preparation of local transport plans by local authorities, the regional strategies of the Southeast and East of England Development Agencies, and the strategies prepared by the Mayor of London including those for economic development and transport.

This institutional canvas sets out a procedure which includes a number of rounds of consultation and specifically a Public Examination hearing, its main purpose of which is to provide an informal opportunity for the discussion and testing, in public and before an independent Chair, and a Public Examination Panel, appointed by the Secretary of State, of selected matters arising from consideration of the draft guidance. It is at this strategic level of regional development where issues of national importance will be ‘translated’ into local level implementation measures. By eliminating the most negative environmental impacts of policies at this stage of decision-making, will result in less effort and resources potentially put on environmental protection measures at a local level [12].

2.2  The Sustainable Development Strategy (SDS)

The Sustainable Development Strategy for the Southeast of England (SDS) [17] is a broad policy document that provides the sustainability context for strategic planning decisions. It was issued in December 1998 and was the subject of a Public Examination[2] procedure held by an independent Public Examination Panel, whose report was published in October 1999. After due consideration of the Panel’s recommendations as well as of all the representations made on the Draft RPG 9, the Secretary of State issued his ‘Proposed Changes to Draft RPG 9’ and ‘Reasons for the Proposed Changes’ documentation in March 2000. These were the subject of public consultation over a twelve week period, as a result of which the Secretary of State made further changes which were incorporated in the final draft of RPG 9 [12].

Similar to having a public participation role, the SDS is also a consultation mechanism that brings together a wide range of organisations in order to influence the formulation and implementation of regional policies.

Similar to having a public participation role, the SDS is also a consultation mechanism that brings together a wide range of organisations in order to influence the formulation and implementation of regional policies. In relation to transport policy, its overriding aim is ‘ to produce a more sustainable pattern of development, focused on making better use of the urban areas in the region, and to promote a switch from unnecessary use of the private car to greater use of public transport.’ [17, p. 1). The SDS sets three overriding objectives:

- the ‘environmental enhancement and natural resource management’ which has an urban and rural branch: (a) the promotion of ‘urban renaissance’ ‘in a physical sense’ and also by helping the development of more balanced urban communities with proper social and educational facilities, and (b) the moving towards a prosperous and multi-purpose countryside (i.e. protection of the wider countryside and designated areas),

- the encouragement of economic success (maintenance of the region’s competitiveness), and

- the promotion of opportunity and equity (especially in the provision of affordable housing) [17].

In order to achieve the above objectives, the SD Strategy focuses on three policy themes:

- the regeneration and renewal theme (identification of Priority Areas for Economic Regeneration),

- the concentration of development (reuse of existing buildings and previously developed land and its relation to transport), and

- sustainable transport.

In relation to transport, the SD Strategy recognises the lack of accessibility and its consequences to the economic environment. It suggests:

- the implementation of demand management measures (i.e. congestion charging, tolling and parking levies),

- better integration of transport and spatial planning (i.e. less peripheral development ‘as this has given rise to particularly unsustainable travel patterns’ in the past),

- the maintenance and management of existing networks (road, rail, bus, pedestrian and cycle),

the encouragement of walking, cycling and the use of local services, and

- the funding of key investments in public transport by potential investors.

It is characteristic that one of the eight headline targets of the SD Strategy is to achieve an aggregate regional car mileage in 2016 below that of 1998.

2.3  The voluntary Sustainability Appraisal

In England, the arising SA was first put forward in the institutional arena through the public consultation draft of Planning Guidance 11 [6] and incorporated into its final version. There, SA’s role was seen to be the appraisal of potential impacts of different strategic options in order to integrate sustainable development objectives in the formulation of regional policies [6]. The SA process requires that policies be appraised against a range of criteria representing the four objectives of sustainable development in national policy:

- Maintenance of high and stable levels of economic growth and employment

- Social progress which recognises the needs of everyone

- effective protection of the environment

- prudent use of natural resources

According to the relevant government guidance [14], [15], the undertaking of a SA, results in the production of a revised SDS of RPG. Once the Regional Planning Bodies have submitted the draft RPG and SA to the Secretary of State, the Government Offices, with the co-operation of the Regional Planning Bodies, will arrange for its publication and a three month period of consultation [6]. The Guidance also put emphasis on appraising alternative development options of the SDS and suggests an iterative and continuous process in which the SA will need to be integrated throughout the whole of the RPG process, including:

- the very earliest preparatory stages through the setting of objectives, (led by the Regional Planning Bodies),

- development and selection of options (led by the Regional Planning Bodies),

- public consultations, policy development and preparation of draft RPG, (led by the Regional Planning Bodies),

- Public Examination and Public Examination Panel report),

- Modifications to RPG (led by the former Department of Transport, Local Government and the Regions and the Government Offices of the Regions) and further public consultations; and

- Implementation, monitoring and review [14].

The practice, however, has shown that not all regional authorities abide by the government guidance on SA. In particular:

- only a limited number of SAs, had until 2001 produced separate reports on the early stages of the SA,

- in only two, out of eight Regions for which an SA was undertaken were alternative development options appraised,

- the impact of SA was not influential to the RPG-making (i.e. the wording was changed rather than the substance of RPG policy),

- a number of SAs was not properly integrated in the RPG process, and

- in certain instances, SA preparation had come too late to influence the decision-making process since the most potentially controversial choices on the crucial 'development options' stage had already been made [14].

The drafting of the SA methodology did not occur in a methodological vacuum. It was influenced by:

a) the existing British sustainability context and the experience gained with the application of Policy Appraisal and the government guidance on the Environmental Appraisal of Development Plans (EADP),

b) the EU legislative framework of the then proposed, now adopted SEA-Directive, and

c) the enduring research work on Sustainability SEA in the UK.

Before embarking on the examination of the role of SA within the above parameters of current British regional environmental policy making, a brief discussion on the characteristics of each of these SEA methodologies will be interjected.

3  The British Environmental Appraisal Context

Part of the research work on SEA that was elaborated in the UK more than a decade ago, adopts a view of the Sustainability role of SEA that involves its application at all levels of Policy, Plan and Programme decision-making process. This role advocates that in order that SEA fulfils its sustainability credentials, the regional level of planning would have to be linked with the other intermediate tiers that are at the receiving and supplying ends of plan and policy making, i.e. with similar appraisals undertaken at a national and local level of planning.

3.1  Guidance on the Environmental Assessment of Development Plans (EADP)

As far as the lower development planning level is concerned, there are indications for a widespread use of a type of SEA called ‘Environmental Appraisal of Development Plans’ (EADP) [4], [20], [19], [5]. Although concerns have been expressed in relation to EADP application about the narrow focus on environmental criteria to the exclusion of social and economic issues, about the lack of consultation, and a lack of integration with the plan making process [23], [12], [4], [20], [19], it is documented that by 1997, about three quarters of all local authorities in England and Wales had undertaken or were in the process of undertaking an Environmental Appraisal for their Development Plans [19]. This wide implementation of SEA throughout local authority planning was encouraged by the publication of technical guidance that has been developed through past experience [27] and, most influentially, by the publication of the UK government guidance on the ‘Environmental Appraisal of Development Plans’, which was available since 1993 [10]. This guide suggested a minimalistic three-step process and in particular a) characterise the environment, b) scope the plan, and c) appraise the plan through determining the consistency of policies against objectives.

The recent advice on the SA [14] attempts to build on the strengths of EADP theory and practice. In that respect, the EADP methodology has progressively evolved in time to incorporate Sustainability concerns. This evolution involved its terminology (i.e. Sustainability Appraisal), rationale (i.e. integrated approach which aims at promoting Sustainable Development), methodology (e.g. it is based on indicators for assessment, monitoring and public participation), process (e.g. it is a more iterative and ‘objectives led’ approach), and geographical scope (i.e. it is extended from a land-use development planning to a regional planning and possibly to government policy level as well as to sectoral areas such as transport).

It can be assumed that, as a result of the rich experience gained throughout the implementation of EADP and the close connectivity of local authority planning with regional planning, government guidance on EADP have influenced the development of guidance on SAs. Indeed, the Government Office for the South East [12] links directly the evolutionary process of EADP with that of the SA’s by noting that EADP publication was a direct precursor to subsequent SAs. This strong influence becomes apprehensible when considering the fact that early SAs (such as the one carried out on the original draft RPG for East Anglia), used EADP-similar methodologies.