The Scottish Government

« Previous | Contents | Next »

Listen

Environmental Assessment of Development Plans: Interim Planning Advice

The approach to assessment

Key elements of the process

18. The Directive requires that the assessment must include a number of specific elements, the more important of these include:

• a screening process to determine whether alterations and plans for small areas at local level should be subject to assessment;
• the collation, forecasting and presentation of baseline environmental information;
• deciding the scope and likely level of detail for the assessment i.e. the likely significant environmental effects of the plan;
• the opportunity for designated consultation authorities to influence the assessment from an early stage;
• the carrying out of an environmental assessment during the preparation of a plan and before its adoption;
• the publication of an environmental report with the consultation draft plan;
• the publication of an environmental report (or revised report) with the submission of a structure plan to the Ministers or the deposit of a finalised local plan;
• an early and effective opportunity for the public (see glossary) to comment on the environmental report, as well as the plan, before the plan is adopted;
• taking into account the environmental report and the results of consultations in decision making;
• provisions for considering the transboundary effects of the plan and consultation with those affected;
• establishing a monitoring procedure for the plan; and
• publication of information about the adoption of the plan.

Integrating the assessment with the development plan process

19. It will be apparent from paragraph 18 above, that the environmental assessment process must be integrated into the development planning process. It is not simply an "add-on" or separate process. The method explained below is intended to fit the environmental assessment process into the existing stages of development plan making and revision, as shown particularly in Table 1 below. It is unlikely that any new stages will need to be introduced into the development plan procedures. Nevertheless, it will be important for planning authorities to anticipate where the requirements will fit in and to check that each step required in the environmental assessment process is accommodated, at an appropriate time, in the preparation or modification of every development plan. It is never too early to start the assessment process. Some Councils have started by assessing their existing plans so they can build on their strengths, fill gaps and otherwise improve their weaknesses.

Structure and local plans

20. An environmental assessment must be part of both structure and local plan preparation (including subject local plans), and the method can be adjusted to recognise that local plans are site specific and structure plans, generally, are not. The approach set out below is designed to be suitable for both types of plan. Ideally, structure plans should be assessed before local plans, though this may not always be possible. Whatever the order, assessments of the two levels of plan should, wherever possible, use the same or very similar methods and share common objectives in respect of sustainable development. Local plans are required to conform to the approved structure plan, so a local plan assessment should not result in policies counter to those in the structure plan. However, it could raise questions or provide information of importance to the next structure plan review.

Team approach and expert advice

21. Carrying out an environmental assessment involves decision making based not just on hard information but also on values. Whether a particular policy is thought likely to have a positive, neutral or negative effect can depend on the values held by the assessor(s) and the knowledge they have of the policy area and the environment. An assessment can be undertaken by an individual or a team. An individual is likely to take less time but a team approach is more likely to give results that are based on shared values and a common understanding. A small team would bring a range of resources to the task, including staff with a particular expertise, and could debate the potential effects of policies and proposals amongst itself. If a team is not used in the assessment, the draft results should ideally be critically reviewed by someone who was not directly involved in the plan making process. For example a senior member of staff, a colleague from another section or an expert from outwith the authority.

22. During the process of assessment, including scoping, preparation of a methodology and the assessment itself, planning staff may feel that their work would be enhanced if they sought expert advice. The most easily accessible sources will probably be current literature or other professionals working for the same authority, but it will be important for the assessment to be seen as impartial, with results that are credible and realistic about the likely effects of the plan, both positive and negative. Key stakeholders should be involved in the process. Bodies such as Scottish Natural Heritage (SNH), the Scottish Environment Protection Agency (SEPA), Historic Scotland and some interest groups may also be able to contribute and, in any event, most of the statutory bodies are likely to be selected as the designated consultation authorities required by the Directive. ¹ There may also be opportunities where experts could be brought together in a workshop. The public must also be consulted at specific stages, defined in the Directive to include non-governmental organisations. ²

23. The methods of consultation and the range and number of locally selected consultees will need to be considered in light of the wider development plan consultation processes. Again, it is emphasised that the assessment process should be fully integrated with the development planning process and additional consultation stages should not normally be necessary.

Choice of method

The Highland Structure Plan Sustainability Appraisal 1999, included an appendix listing the participants in the assessment process. This included Council officers covering a wide range of interests (Chief Executive, Housing, Planning and Development, Property and Architectural, Protective Services, Roads and Transport Services, and Social Work Services) plus officers from Highlands and Islands Enterprise, Northern Constabulary, Scottish Homes, SEPA and SNH. Choice of method

24. Before deciding on a method, practitioners may find it helpful to refer to the sources and examples given in the bibliography. It is important to be alert to the resource implications of an over-complex method and the consequent risk of introducing delay into the plan preparation. There is a range of issues to consider but the method should be:

a. compliant - with the requirements of the Directive;

b. straightforward - in concept, in its relationship with working practices and the planning process;

c. clear - in its assembly and presentation of information;

d. comprehensive - considering all relevant aspects of the environment and the plan;

e. adaptable - capable of being started at any stage in the process, and of evolving as the process unfolds;

f. economic - in the use of skills, knowledge and other resources available, especially by fully integrating the assessment process with the development plan making process;

g. flexible - capable of informing decision making in a changing policy context; and

h. progressive - able to embrace new information, predictive techniques and ideas as knowledge and experience develop.

25. In its application the method should also be:

• systematic - thorough and rigorous in its assessment of all aspects of the plan, in an even-handed way or, if focused, concentrating on the environmental effects that are likely to be most significant;
• transparent - so that the users of the plan can understand how and why it has been influenced by the assessment;
• objective - so that bias and subjectivity are minimised, the assessment is seen to be honest, for example, by conceding deficiencies or uncertainties in the assessment process or outcomes and acknowledging adverse effects where these are likely to be significant and the plan cannot avoid or further reduce the effects by mitigation measures; and
• internally consistent, the assessment should demonstrate strong links between the plan and the assessment process, for example, wherever possible, the criteria used to test the plan should be explicitly and directly related to the fundamental principles of sustainability on which the plan itself should be founded.

Overview of assessment method

26. The method and assessment process set out in Part 2 of this advice has been prepared by David Tyldesley and Associates based on their experience of environmental (and sustainability) assessment and taking account of other UK and international examples. Like all assessments of development plans in Scotland to date, it uses a series of simple matrices and checklists to assess the policy coverage of the plan and to compare a plan's aims, locational strategy, policies and proposals with the environmental objectives of sustainable development. The matrices list the plan's policies/proposals on one axis and the environmental objectives on the other, as shown in Figure 1. The assessment is recorded in the cells, usually using symbols. Thus the matrix provides a structure for assessing environmental effects and recording the results. Nevertheless it will not always be easy to decide on what the environmental effects of the plan are likely to be. Part 2 and the Appendices provide detailed advice.

Figure 1 Illustration of a matrix using simple symbols

Key:

Close compatibility/Major beneficial effect
Partial compatibility/Beneficial effect
? Uncertain effects/Lack of adequate information
Blank No interaction/no effect/no relationship/neutral
X Incompatible - potential policy conflict/Adverse effect

27. Obviously, the fewer the objectives and criteria, the less time will be needed to carry out the assessment but, if an assessment is to be comprehensive, fewer criteria tends to mean that each criterion has to cover more issues and becomes more complicated, and therefore more difficult to apply. The number of environmental objectives and criteria in Appendix B Table B1 below would adequately cover the key issues in most plans. Some may not be applicable to some plans, some could be amalgamated but others may need to be divided to adequately test particular plans. Many local authorities will already have their own statement of sustainable development and environmental objectives, though these may need to be restated to be in a form suitable for environmental assessment.

28. The method in Part 2 is designed to identify the general direction set by the policies and proposals and not to show whether specific environmental targets will be met. Those carrying out the assessment have to make an informed judgement. For example, they may ask "is the plan aim, policy or proposal compatible with each environmental objective of sustainable development?" The answers are entered in the matrix using symbols, words or a combination of both. To appraise the effects of site specific proposals a matrix or checklist can be used, also completed using symbols.

29. As an alternative to using symbols the entries made in the matrix could instead simply be "yes", "no" or "no interaction". The symbols could be elaborated with short explanatory notes, in an end column, as shown in Appendices D - F.

30. The important point is that the entries in a matrix or checklist should not purport to be more sophisticated than the judgements on which they are based. It would be wrong and misleading, for example, to use an elaborate numerical grading.

« Previous | Contents | Next »