SEA in the UK: Successes and Failures Riki Therivel Costs and benefits of SEA Issues around effectiveness and efficiency My wish list for a ‘British sovereignty’ SEA system

Procedural Directive … which aims to… “provide for a high level of protection of the environment” “contribute to the integration of environmental considerations into the preparation and adoption of plans…” “promote sustainable development” Write report on env/sust impacts of plan Consult on report Take report and consultation into account Document and monitor

Move away from regional & towards neighbourhood planning Brexit Training, guidance etc. Accumulation of practice & data NGO/stat. cons./public input Legal challenges Politics (large and small) Move away from ‘evidence based’ & towards more political policy making

Definite costs of SA/SEA process (v. roughly) Neighbourhood plan: £15k Local plan: ~£50k National level plan: >£50k

Possible benefits of SEA Based on Morrison-Saunders et al. 2015 Tangible Intangible Strategic Improvements to plan Accumulation of env’al awareness/knowledge Operational Provides evidence of plan sustainability Self check, ‘mock EIP’, higher acceptance of plans Managerial Stakeholder engagement Organisa-tional Institutional & other benefits

Changes to plans due to SA/SEA IMPROVEMENTS TO PLAN RE. SUSTAINABILITY Changes to plans due to SA/SEA Time

SA/SEA helps to ‘balance’ an economic/socially oriented plan-making process

OTHER IMPROVEMENTS TO PLAN, SELF CHECK, MOCK EIP Is this the best way of dealing with the problem? Will this stand up to scrutiny? Is this the best wording? Is this implementable? Could this be misused by developers? Have we got enough evidence on this? Have we missed anything?

PROVIDES EVIDENCE OF PLAN SUSTAINABILITY Gr Norwich CS

STAKEHOLDER ENGAGEMENT DCLG, 2008ish

ISSUES LEGAL CHALLENGES 2007 Northern Ireland – 2 SEAs do not fulfill all SEA Directive requirements 2009 ‘St Albans’ – reasonable alternatives not considered for Green Belt release 2011 ‘Save Historic Newmarket’ – SEA alternatives must be revisited if substantial change to context of plan 2012 ‘Greater Norfolk’ – all ‘reasonable alternatives’ must be considered 2013 HS2 – Lord Adonis note ‘requires’ HS2, alternatives etc. Etc.

ISSUES LEGAL CHALLENGES 2007 Northern Ireland – 2 SEAs do not fulfill all SEA Directive requirements 2009 ‘St Albans’ – reasonable alternatives not considered for Green Belt release 2011 ‘Save Historic Newmarket’ – SEA alternatives must be revisited if substantial change to context of plan 2012 ‘Greater Norfolk’ – all ‘reasonable alternatives’ must be considered 2013 HS2 – Lord Adonis note ‘requires’ HS2, alternatives etc. Etc.

Length/cost of SA/SEA reports Time

Length/cost of SA/SEA reports OAN, ongoing changes to planning system etc. Length/cost of SA/SEA reports legal challenges (‘cover your tail’ reports) Time

DOES SEA provide for a high level of protection of the environment contribute to the integration of environmental considerations into the preparation and adoption of plans promote sustainable development

NOT GOOD IN CONTEXT OF Recession Government ‘austerity budgets’ Slow house building rates, high housing demand

Local Plans Expert Group 2016 appointed by Government to improve plan-making “SA have become an industry in their own right, fueled by the … threat of legal challenge” “SA tends to be ‘self serving’, capable of being adapted to any outcome and often of little genuine assistance to decision making”

BUT SEA DOES provide for a high level of protection of the environment contribute to the integration of environmental considerations into the preparation and adoption of plans promote sustainable development

Effectiveness of SA/SEA National Neighbour- hood

Effectiveness of SA/SEA SA is good plan-making Effectiveness of SA/SEA politics rule we know it all already National Neighbour- hood

OMAR EZZET: SUMMER 2016 SURVEY 224 planning authorities, 35 responses (15%) Open question (n=15) 40% improved plan 40% made plan more sustainable 36% improved organisation’s awareness of sustainability 27% identified ways of reducing negative impacts 27% improved transparency of plan-making 42% burden on developer 40% costs of consultants or staff

Procedural Directive … which aims to… “provide for a high level of protection of the environment” “contribute to the integration of environmental considerations into the preparation and adoption of plans…” “promote sustainable development” Write report on env/sust impacts of plan Consult on report Take report and consultation into account Document and monitor

MY WISH LIST FOR A ‘BRITISH SOVEREIGNTY’ SEA SYSTEM (ha ha ha) It exists SEA report (incl appendices) <200pp Plan impacts tested against env standards; plan must help to achieve them Assessment of cumulative impacts key part of SEA Explanation required if plan ≠SEA findings Scrutiny of SEA statement info required at EIP