Proportionate environmental impact assessment – a Temple approach
Research by IEMA has indicated that the main text of many environmental statements run to more than 350 pages, while those relating to nationally significant infrastructure projects are often nearer double that figure. Furthermore, EIA can often be seen as a regulatory hurdle required for development consent rather than a vehicle to achieve truly sustainable design. So how can proportionality be achieved at key stages of the environmental impact assessment (EIA) process and what are the perceived barriers to delivering an effective, concise and proportionate EIA?
In our recently published article in the environmentalist, Pete George and I seek to answer some of these questions. Some of the key themes are summarised below.
Many EIA environmental statements (ESs) have become large, information repositories and feedback from stakeholders reveals that this can lead to a perception of impenetrability which can often make them inaccessible to the reader. Reasons for the ever-expanding ESs seem to vary but can include:
- the fear of challenge or the risk of litigation;
- a temptation to scope in topics with little consideration of whether the anticipated impacts are significant;
- legal teams insisting an expanded scope;
- a normal or traditional approach scoping in the environmental topics normally associated with a development rather than the specifics of what being proposed;
- inflexible guidance documents and a lack of professional judgement; and
- failing to recognise that scoping is a dynamic process which should be continually reviewed.
As a result many ESs become less effective at communicating a clear, concise message to inform interested stakeholders and decision makers. It is accepted that the non-technical summary (NTS) should be the first point of contact for many stakeholders (technical or otherwise) but even NTSs can become a listing exercise of significant effects with little rationale given for the conclusion.
Effective scoping has to underpin a proportionate approach to EIA, whilst also increasing efficiency and reducing the potential for unnecessary work and creating value for our clients.
So what about proportionality in the application of design and mitigation? The design and mitigation response should also be proportionate and based on the scale of anticipated impact to effectively mitigate, without entailing excessive costs. In our experience an iterative approach using emerging results of the assessment backed up with experienced professional judgement has delivered demonstrable value and efficiencies whilst also achieving successful consent and a more robust sustainable design for our clients.
The traditional model is to undertake EIA at key points in the design – for example, when the design is sufficiently developed to understand the effects of the development on the environment. The design needs to be sufficiently “fixed” for its impact to be assessed effectively. However, this approach can result in the mitigation being “shoe-horned” into an advanced and inflexible design.
We have found a more integrated approach, which embeds the environment professional in the design team is more beneficial. This approach can truly integrate the initial environmental findings and the approach to mitigation into the design. In this way, environmental assessment is not viewed as a process that merely reports back at the end of the process, rather, EIA is considered as a fully integrated and iterative process that is interdependent with the evolution of the design.
The EIA coordinator has a central role in the development cycle and they must be able to communicate effectively with stakeholders, the design and wider project teams. This relationship is crucial to avoid and reduce the project’s effects on the environment, whilst also ensuring that the mitigation response is proportionate and integrated into the design.
The benefits of having an embedded EIA coordinator in the core development project team, include:
- better communication within the project team of environmental impacts;
- better understanding of the key issues relating to the environment;
- design management – a thorough understanding of the environmental implications of design decisions;
- design advice – an ability to influence the design and advise on emerging results of the assessment; and
- impartiality – an ability to challenge conventional thinking or status quo design assumptions.
We have found this approach has delivered demonstrable value to our clients whilst also gaining consent and successful outcomes for their developments.
The implementation of the new EIA Directive has a requirement for the EIA manager or coordinator to be an “appropriate person”. Whilst it is uncertain how this will be interpreted or defined, Temple’s EIA coordinators are experienced professionals with relevant professional qualifications – such as registered EIA practitioners, MIEMA and Chartered Environmentalists. Temple is also one of the founding members of the IEMA Quality Mark registration. As such, Temple is well-placed to respond effectively to the changes associated with the implementation of the new Directive whilst also delivering consistently successful outcomes for our clients.
The full article can be found on the following link can be found here. N.B. please note you will need to be an IEMA member with a username and password to access the article. Alternatively, you can take a free trial.
For further information on how Temple can successfully deliver EIA in relation to your development opportunities please contact the below:-
Tom Smeeton – Principal EIA Consultant email@example.com 02073943700
Peter George – Technical Director firstname.lastname@example.org 02073943700