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