The Environmental Assessment we need

May 2021

With planning reform on the agenda in England, the spotlight has been on the best way to assess the environmental impacts of development. It’s now been more than six months since the Ministry of Housing, Communities and Local Government ended its consultation on the Planning White Paper and we are none the wiser about its plans for environmental assessment. Getting this right is crucial at a time of ecological and climate crisis. The G7 nations have recently acknowledged “with grave concern that the unprecedented and interdependent crises of climate change and biodiversity loss pose an existential threat to nature, people, prosperity and security.”

The RSPB has extensive experience of dealing with different types of assessment around the UK and beyond. While MHCLG deliberates, we have been developing our own thoughts on the environmental assessment we need.

Each year in England there are well over 400,000 applications for planning consent of one kind or another, including for ‘major’ or ‘nationally significant’ infrastructure under the different planning acts. A good number of England’s 330 local planning authorities will also be preparing local plans or other planning documents. That’s to say nothing of agricultural or forestry or other works which need consent.

Imagine there was no environmental assessment. How would you know what effect any of these plans or projects would have on the environment, whether it’s the built or the natural environment? How would you be able to take into account the impact of development, whether good or bad? It seems unthinkable.

We do have a sophisticated system of environmental assessment, built up since the 1970s and now comprising an array of different types of assessment, dealing with different types of impacts or different types of plans and projects. It includes everything from simple environmental information provided for a house extension to the complex information and process followed for a nuclear power station.

The system is not without its faults. This is not an exhaustive list, but problems can include:

• It can be a tick box exercise
• Consideration of alternative ways of doing things can be poor
• There can be hidden trade-offs and a lack of robustness, especially where social, economic and environmental impacts are bundled together in the same process
• Attention is sometimes given to irrelevant issues, or significant issues overlooked
• Environmental statements can be voluminous and impenetrable, suggesting that consultants are paid by the page rather than for quality
• It may have no real influence over the final decision
• There’s often a lack of robust environmental data
• Hard-pressed local planning authorities often lack the expertise to assess what they receive

However, a well-functioning system of environmental assessment for all kinds of plans and projects is essential if we truly aspire to a nature-positive, carbon neutral economy. We can’t keep on trading off environmental loss in favour of economic gains, which will turn out to be no gains at all. As the Dasgupta Review of the economics of biodiversity observed, “Our unsustainable engagement with Nature is endangering the prosperity of current and future generations."

What does an effective environmental assessment system need? I suggest there are at least 12 key principles. In no particular order:

1. It should apply to all levels of decision-making, from policy and programme to plan and project. That’s not to say that one size fits all, so …
2. … it should apply to all types and sizes of projects and plans which have the potential to affect the environment, but be proportionate to their scale and complexity or their impacts on the environment.
3. It should consider biodiversity in all its forms, including sites and species, designated or undesignated.
4. It must be done in a timely way, so that the results can inform the eventual shape of the plan or project.
5. There must be public participation, which is both timely and inclusive of civil society, whether community groups or other stakeholders.
6. Alternative options should be considered, particularly alternatives that are less damaging to the environment, and the reasons for rejecting any options should be made public.
7. Cumulative impacts must be considered.
8. It should be based on up-to-date and scientifically robust evidence, including evidence on the value of the natural environment.
9. Both the assessment, and its review by decision-making bodies, must be informed by expert advice.
10. It must have genuine influence over the decision, especially where there are significant environmental effects.
11. Implementation must be monitored to enable the mitigation of any unforeseen impacts and to provide learning for future plans and projects.
12. The environmental protection provided must be at least equivalent to the protection formerly given by relevant European Directives.

Here are three examples of good practice from the RSPB’s experience:

The Habitats Regulations Assessment of the Breckland core strategy was a rigorous assessment of the impacts of a proposed housing development on a vulnerable species, which enabled the local planning authority to meet its housing target in a sensitive way. It is also a good example of considering alternative options which are less damaging to the environment.

The monitoring programme of the Edinbane wind farm, Isle of Skye, shows that environmental evidence gathered before, during and after construction is invaluable in designing future developments so that their impacts on biodiversity can be minimised.

Strategic Environmental Assessment of the Tana River Delta Land Use Plan, Kenya, was used to combine robust scientific data and indigenous knowledge to design regulations to facilitate resource management and the protection of sensitive natural areas. Alternative land use strategies were scoped into the SEA process, including the status quo, a development-oriented strategy and conservation-oriented strategy.

Please contact Simon Marsh for more specific proposals for improving the implementation of Environmental Impact Assessment and Strategic Environmental Assessment, or to share other good practice examples of environmental assessment.

Simon Marsh is Head of Nature Protection, RSPB, and a trustee of Wildlife and Countryside Link.

Follow: @Natures_Voices and @RSPBEngland.

The opinions expressed in this blog are the author's and not necessarily those of the wider Link membership.