The following blog has been written by Nick Giesler, the Guest Editor of Volume 24 of the ISEP Impact Assessment Outlook Journal, Delivering proportionality in Impact Assessment.
Proportionate assessment. It seems this phrase has been echoing around discussions on Environmental Assessment forums for at least the last 20 years. And yet Environmental Assessment practice remains too often steeped in detail, with reports that are unwieldy and impenetrable. Why does this matter and, if it does, what do we need to do to overcome it?
Proportionate assessment addresses both process and product, and for each is about doing only as much as required by regulation and national policy to deliver sustainable development. The collection of articles in this journal looks at several aspects of the issue: the causes, challenges and possible solutions.
It provides perspectives from various custodians in the EIA process, outlines opportunities for Environmental Assessment practices to support proportionate assessment, considers how change might be implemented, and gives a forward look to how a future assessment regime (in the form of Environmental Outcomes Reports – EORs) might help us get there.
The additional depth of analysis and quantum of words that we see in contemporary Environmental Assessment reflects some impressive investment. But there’s a problem – who really understands it? We would expect comprehension from technical specialists on both sides of the table, but the majority of people potentially affected by or interested in the outcome – most importantly, the general public – are left scratching their heads. If we give the impression that this stuff is all too complicated for general understanding, we engender mistrust and reinforce opposition. As Angus Walker writes in his article, the more words we offer up, the greater the risk of inconsistencies that lie at the heart of many a legal challenge.
In addition, with complex process, excessive detail and enormous reports, comes a corresponding scale in cost. And while environment has unjustly borne the brunt of recent criticism for planning delay, big assessment can, with other planning processes, lengthen time to consent.
Accusations by both this Government and its predecessor, are that over-complicated EIA is a deterrent to swift planning decisions. The 2020 Planning White Paper, Planning for the Future, was replete with criticism, referring to the ‘shackles of burdensome assessment’, while the new Government has recently referred to ‘… voluminous and costly documents that too often support legal challenges rather than the environment.’ While we might rebut the link to EIA and planning delay, the writing is clearly on the wall. Might the mooted EOR regime be what is needed to instil proportionality to the process?
The thing is, we know how to do better. In particular, we know that bold and decisive scoping is critical to focus assessment on the things that matter and excise those that don’t. But consultees need the skills and resource, backed by robust evidence, to support this approach. Rob Brydges and Clare Siemers make this point clearly in their articles.
Elsewhere, Ursula Stevenson discusses the ways that the two stages of assessment (SEA and EIA) should work better together to avoid duplication, while Ellen Smith outlines how better reporting skills and techniques can help deliver more succinct reports. I can endorse this point: by appointing a skilled product team to the recent Cambourne to Cambridge ES, rather than amalgamating the work of multiple authors, we have conveyed all necessary EIA information for this major infrastructure project in less than 150 pages, keeping the more technical detail within topic reports.
Other good practice is emerging. Jo Wootton and Peter Bruce offer a case study that demonstrates a way forward, while Catherine Anderson shows how EIA for major infrastructure projects can exemplify efficiencies. At WSP, we are implementing several measures to expedite proportionate assessment, including omission of planning policy, excising climate resilience as an ES topic (while retaining its wider application in supporting design and other assessments), and embedding mitigation through collaborative design and within assessment assumptions.
What is clear is that proportionate assessment requires collaboration at all levels in EIA. Perhaps we can look to the Government to help us all play nicely, through both regulation and statutory guidance. But equally, the Government really needs to build on our industry experiences if they want to deliver the proportionate outcomes we mutually seek.
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Please note: the views expressed in this blog are those of the individual contributing member and are not necessarily representative of the views of ISEP or any professional institutions with which ISEP is associated.
