1. 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

2. 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

3. 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

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

5. Possible benefits of SEA
Based on Morrison-Saunders et al
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

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

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

9. 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?

10. PROVIDES EVIDENCE OF PLAN SUSTAINABILITY
Gr Norwich CS

11. STAKEHOLDER ENGAGEMENT
DCLG, 2008ish

12. 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.

13. 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.

14. Length/cost of SA/SEA reports
Time

15. 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

16. 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

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

19. 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”

20. 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

21. Effectiveness of SA/SEA
National Neighbour-
hood

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

23. 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

26. 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

27. 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