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Environmental Assessment of Development Plans: Interim Planning Advice

82. Many recent development plans in Scotland have contained a vision, and/or a set of aims, which the planning authority aspires to achieve through the preparation, adoption and implementation of the plan. These aspects of the plan are often focused on the goal of sustainable development. Most plans explicitly state that these aspects underpin the plan as a whole. It is, therefore, vital that these aspects are tested specifically in the assessment, as soon as they are derived, or transferred or adapted from another plan.

83. This part of the assessment process is a straightforward test of the consistency of the plan's vision and aims with the environmental criteria. This is obviously a very general test, at a broad level, to see if the plan is inherently consistent with the environmental objectives set by the planning authority and to highlight any potential areas of conflict or tension between the overall aims of the plan. At this broad level of assessment it is likely that the plan's vision and aims will be generally compatible with each other and with the environmental objectives, but there may be some potential areas of conflict or uncertainty.

84. As with the subsequent assessment of policies and proposals, to keep the assessment process systematic, structured, transparent and manageable in its method, it is usually best to use a matrix to steer the assessment. To ensure the results are understandable and not unduly complex, it may be best to use symbols in the presentation. Alternatively, brief standard word descriptions could be used but they tend to lead to considerable duplication. Although marginal notes can be helpful explanation, lengthy text is rarely needed to express the general findings of an assessment of this kind. Indeed, there is a danger of complex presentations or prolix tables or texts, giving the impression that the assessment is more sophisticated than it is. This would be misleading.

85. Examples of symbols that may be used to express the judgement made in respect of each criterion are shown in Case Studies 5 to 7 above and in the Appendices. It will be noted that the ? symbol is used. This is intended to indicate uncertain or unpredictable effects and/or some potential for policy divergence or conflict with environmental objectives; it might indicate a high level of reliance on cross compliance in the application of the policy, or the outcome of the assessment of the specific proposals promoted by the policy.

86. Assessment of aims and visions is necessarily general in nature. It is not like the later stage of assessing specific proposals. As with the assessment of policies it is a judgement, preferably a consensus judgement of an informed group of professionals, who know the area, and its environment and the plan.

87. Sometimes the plan's vision or aims will be referred to as the plan's "strategy" but, in this context, we define the "strategy" as the overall pattern of development locations - the spatial strategy, which will deliver the vision and aims of the plan. Whilst terminology differs between planning authorities, the aspects of the plan to be examined in this stage will normally be readily identified.

88. Examples of an assessment of a plan's vision and aims are given in Appendix D.

89. Transboundary effects means effects on other Member States. They are likely to be rare in Scottish development plans. The planning authority should consider whether there are, or are likely to be, any significant transboundary environmental effects arising from the plan. If there may be such effects as a result of policies or proposals in a development plan the planning authority should consult the Scottish Executive as soon as possible who would consider any necessary consultations (with the designated consultation authorities and other Member States) and advise the planning authority how to proceed, in compliance with Article 7. Normal consultations with adjacent planning authorities are not included here but will be part of the normal plan making procedures.

90. This important element of the assessment process is intended to identify, describe and assess reasonable alternatives for the plan's policy framework and the plan's spatial strategy and choices about general locations of development. It is to ensure compliance with Article 5.1 of the Directive as defined in Article 5.2 as "information that may reasonably be required taking into account current knowledge and methods of assessment...". Specific policies and allocations will not normally be assessed at this stage because they will not have been identified until the spatial strategy has been selected.

91. The significant effects have to be identified and assessed including likely secondary, cumulative, synergistic, short, medium and long-term, permanent and temporary, positive and negative effects on the environment (as listed in the footnote to Annex I). It should also reflect the Directive's requirement to report on factors such as those listed in Annex I (f). See the glossary below for an explanation of these terms, including some examples.

92. Whilst planning authorities will normally have considered alternatives to policies and spatial strategies or allocation options in preparing development plans in the past, it will now be necessary to be more explicit about the alternatives considered. They will need to be identified, defined, described and assessed. It is unlikely that there will be no alternative approach to consider but alternatives must be reasonable. They should be realistic, practicable and relevant. In many cases policy and spatial options will be quite limited in the light of policies in higher tier plans such as structure plans and in SPPs/NPPGs and the National Planning Framework. There is no expectation on planning authorities to assess options that would be incompatible with national planning guidance or the structure plan. Neither is there any expectation that options or alternatives must be generated merely for the sake of assessment. In practice, few plans in Scotland have considered more than three alternative policy approaches or alternative spatial strategies.

93. However, all alternatives spanning the range of reasonable options should be identified and assessed, even those rejected at an early stage because they were considered feasible but inappropriate. The environmental report should include an outline of the reasons for selecting the alternatives dealt with so there is the opportunity to indicate why some apparently reasonable options were not included in the assessment. The Directive does not require the assessment of each and every alternative policy wording.

94. However, the Directive is unclear about whether, in the context of a development plan, it would be reasonable to limit assessment of alternatives to the main, overall policy approach and spatial strategy, or whether alternative policy approaches for each main topic require to be assessed, eg housing, employment, retailing etc. In any particular case a judgement will need to be made but, on balance, it is considered that, in the context of a development plan in Scotland, reasonable compliance with the Directive would be assured by the planning authority assessing the alternatives to the main spatial strategy of the plan and alternatives to the main policy approaches rather than each and every policy or policy topic. Examples of assessments of alternative policy approaches are discussed in case studies 11 and 12.

95. This step emphasises the desirability of subjecting alternative approaches to the plan's overall strategies to assessment as soon as they emerge. They can then be used to generate and underpin the plan's more detailed policies and proposals confident in the knowledge that they are compatible with the environmental objectives, or at least potential conflicts are recognised at an early stage, can be considered throughout the remaining stages and are more likely to be avoided or reduced.

96. The planning authority will select the preferred policy framework and spatial strategy and set out the justification for that decision. The justification is likely to need to refer to socio-economic issues, as well as environmental issues.

97. Whilst the need to balance socio-economic and environmental objectives is fundamental to the plan-making process, it should normally be evident in this decision that the best environmental option has been selected, unless there is a clear and well justified reason for not doing so. Where a policy or spatial option that could have significant environmental effects is chosen, or likely to be chosen, it should be examined with great care and tested rigorously and impartially in comparison with less environmentally harmful options.

98. It is also possible that the planning authority will need to choose between potentially conflicting environmental objectives. For example, the best location for development from the point of view of travel reduction may be an area valued for its landscape character or wildlife habitats. Choices should be explained and justified. In cases of potential policy conflict, priority should normally be given to the protection of environmental resources which are rare, or of the highest quality, or irreplaceable, often characteristics reflected in international and national designations. The precautionary principle may need to be applied.

99. It is important to check the development plan to see if all of the environmental issues and objectives are covered by policies, before assessing the policies themselves. In part, this helps to ensure the plan is consistent with higher tier policy frameworks such as SPPs, NPPGs and structure plans. In assessments carried out previously, it has often been this stage that proved to be of greatest value. This is because the range of policy issues is so wide that it is highly unlikely that any plan will have complete coverage before this check is completed.

100. The method is straightforward. A list of all potentially relevant policy topics is prepared, for example, as shown in Appendix C. The list may be derived from a variety of sources including, as in the case of Appendix C, the expectations of SPPs and NPPGs but there are other sources such as published good practice guides (including PANs) and policies drawn from a selection of other recent development plans.

101. A checklist is then developed such as the one shown in Appendix C. Using either the existing plan (where it is being reviewed) or the draft plan (where it is being generated as a new plan) the policies in the plan are checked to make sure that each topic is adequately covered. If there is a policy, which fully meets the checklist entry, the policy reference is recorded, if not the absence, or inadequacy of the policy is recorded. Comments can be added in the end column.

102. It follows that gaps in policy range should be filled by amending or adding new policies.

Assessing the plan's policies

103. In this part of the assessment the object is to assess each policy in the plan if it is likely to have significant effects on the environment. These may, of course, be either positive or negative effects. Equally, many policies will have no effects on the environment or only a benign or neutral effect. In many cases there may be uncertainty about the effects, for example because there is insufficient information or understanding about the likely effects, or about the environmental resource, or because the effects may depend on how the policy is implemented. However, it is again emphasised that the assessment should focus on the significant effects likely to be generated by the plan and under planning control. It is not possible, or necessary, for the assessment to try to assess every conceivable environmental effect, especially those that are outwith the planning system and controlled by other statutory bodies such as SEPA.

104. The wording of policies is also important. They must, of course, follow the established principles required by legislation and government policy. However, policies should be clear and unambiguous (see SPP 1 paragraph 27 and PAN 49) and minor changes may be needed to ensure that they fully meet the environmental objectives set out for the assessment.

105. It should also be emphasised that, whilst all the potential effects must at least be considered it is only significant effects that need to be fully assessed and recorded, that is, effects that are significant in the context of the development plan. It is probable that an initial consideration will identify policies which are unlikely to have significant effects. Also, to be practical, the assessment can only consider likely effects that, reasonably, may be predicted. There is little point spending a lot of effort considering obscure, highly uncertain or unpredictable effects.

106. The actual effects of a policy cannot, of course, be assessed in the assessment because any effects will depend on how the policy is applied in relation to any planning applications made. It is a predictive, case by case judgement and the question in the assessor's mind may need to be: "if a planning application is made and determined in accordance with this policy, what, if any, will be the significant environmental effects?" The criteria in Table B 1 refine this question in respect of each environmental objective.

107. Policies, or parts of them, which merely reiterate policies in higher tier plans in the policy hierarchy and which have already been subject to assessment, may be omitted from the assessment matrix at the lower tier, unless different significant effects would be likely. In these cases an explanation for the omission should be included in the environmental report. However, policies that enlarge on, or further or interpret policies in higher tier frameworks should be assessed even if broadly in accordance with SPP and NPPG.

108. While all the potential effects have to be considered (see paragraph 105) the report should reflect the Directive's requirement for the assessment to report on "the likely significant effects on the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors" ( Annex I (f)). In accordance with Annex I the assessment should include any likely significant "secondary, cumulative, synergistic, short, medium and long-term, permanent and temporary, positive and negative effects" on the environment (as listed in the footnote to Annex I. An example of a policy assessment and matrix are given in Appendix E below.

109. It is to be expected that almost all policies in the plan will be consistent with environmental objectives and criteria. Rows of symbols indicating compliance with environmental objectives will not be surprising, given the traditional regard planning authorities have for the environment in drawing up their plans. Most development plans will be strongly consistent with the principles of environmental sustainability. It is counter-productive to apply the criteria unrealistically severely. It should be assumed that all policies would be applied consistently with the obvious intent and thrust of the policy (see Examples below). The assessment should not seek to exploit every possible loophole in policy wording, but only draw attention to obvious ambiguity or inadequacy where policies are inconsistent with paragraph 27 of SPP1.

110. Policy conflicts should not be created unnecessarily because it obscures those policies that really need to have attention drawn to them. An example of a matrix assessing plan policies is given in Appendix E below.

Assessing the plan's proposals

111. This step involves the assessment of the effects on the environment of the plan's site or location specific proposals. The level of detail in the assessment will depend on the nature of the plan, the nature, scale and locations of the development proposals and the information available. However, all proposals should be assessed for significant effects and included in the environmental report.

112. Criteria are drawn up, similar to those in the policy assessment but usually requiring some modification, and applied to the proposals, usually in a matrix. However, a checklist could be used instead, similar to that shown in Figure 3 below. Matrices or checklists help to keep the process structured, systematic and manageable. They also help in presentation. Again symbols are usually the best way of presenting the judgements on the effects. The effects to be considered should be all of those listed in the footnote to Annex I(f), including the effects on issues such as those listed in Annex I(f). Appendix F provides an example of an assessment matrix for plan proposals.

113. This stage may be the only opportunity to assess the likely effects on the environment of housing, employment, retail and other development proposals, which will not be subject to any other form of assessment until an application for planning permission is received. Thus, an analysis of the proposals assessment matrix may show a number of symbols indicating uncertainty or potential adverse effects in respect of either particular types of development (eg housing) or in respect of particular environmental criteria. These will also indicate cumulative pressures arising from the plan implementation.

114. Cumulative and synergistic effects must be assessed (see glossary for definitions and examples). In many cases the most effective form of cumulative and synergistic assessment may be a simple analysis of how many proposals potentially may affect particular environmental resources of importance, for example, ancient or semi-natural woodlands, monuments, peatlands, wetlands or villages displaying a distinctive architectural character. This type of approach highlights any environmental resources, which may be under stress from a series of small but cumulatively significant or synergistic changes than from one major impact.

115. An example of a Cumulative Assessment Schedule is provided in Appendix G below. In the hypothetical example given it will be seen that there is a potentially significant cumulative effect on wildlife habitats caused by a series of housing and road proposals only one of which would have a major effect on nature conservation. However, this one major effect is compounded by the combined effects of a series of smaller impacts which on their own, individually, would not be significant.

116. This is an assessment to see whether there are any fundamental problems in the allocation of land for development. It is not equivalent to a series of detailed project environmental impact assessments. It is necessary in this part of the assessment to make certain assumptions. It should be assumed that the proposal would be implemented in accordance with all of the policies of the plan. Unless it is clear that the proposal is likely to create a conflict with one or more policies, it should be assumed that the development plan would be implemented as a whole (see the boxed example at paragraph 109 above). Policy divergence should not be created for the sake of it because it obscures those proposals that really need to have attention drawn to them.

117. The assessment of proposals will highlight whether the objectives of the policies are actually being applied in practice, through the proposals of the plan and the local authority's own programmes. Are the proposals consistent with the policies in the plan and with the environmental objectives? This is called "policy convergence". Inconsistency between the aims, policies and proposals is called "policy divergence". In some cases the assessment of a proposal may be dependent on the way in which particular policies would be applied to any planning application that was made to implement the proposal. This indicates a reliance on "cross-compliance" (see the glossary for an explanation of these terms). Again, it should not be necessary to look in meticulous detail at every conceivable effect on the environment. Rather, the process is looking out for "warning lights", important indications that the plan is moving away from sustainable development, and could harm the environment.

118. This is an assessment to see whether there are any fundamental problems in the allocation of land for development. It is not equivalent to a series of detailed project environmental impact assessments. It is necessary in this part of the assessment to make certain assumptions. It should be assumed that the proposal would be implemented in accordance with all of the policies of the plan. Unless it is clear that the proposal is likely to create a conflict with one or more policies, it should be assumed that the development plan would be implemented as a whole.

119. The assessment should consider cumulative effects of the plan because these are specifically required to be assessed in the Directive and also because these kinds of effects are difficult to assess in project EIA, on a case-by-case basis.

120. Inevitably, plan proposals are likely to record a series of uncertainties and occasionally adverse effects, especially where their effects on the environment have not yet been fully investigated. The matrices are likely to have more symbols indicating uncertainty or potential policy divergence than the policy matrix. This is one of the important roles of assessment, to act as an early warning of potential problems or cumulative effects in plans or programmes that may not otherwise be assessed together. It does not necessarily mean that the schemes will actually be damaging to the environment when they are finally implemented, because there may be opportunities for the issues to be addressed and harm avoided or reduced.

Identifying uncertainties and mitigating adverse environmental effects

121. Before proceeding further with the assessment it is useful at this point to draw together the potential negative significant environmental effects and the key uncertainties. Article 5.1 and Annex I(g) requires that the environmental report must include "the measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan."Annex I(h) requires the environmental report to include "any difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the environmental information".

122. It is important in this context to appreciate that the requirement of the Directive is not to mitigate every conceivable adverse effect but to report on the measures to mitigate and compensate any significant adverse effects. As explored in stage 3 above, "significant", in this context means significant in light of the nature and scale of the plan.

123. The planning authority should consider how any significant adverse environmental effects could be mitigated or compensated for. Here, we use the terms "mitigation" and "compensation" in the way that they are defined in the glossary, which itself draws on the approach to planning decisions and biodiversity set out in "Planning for Biodiversity Good Practice Guide" published by the Royal Town Planning Institute in 1999. This set out the five-point approach to decision making summarised in Table 4 below. Following this approach would directly reflect the requirements of Annex I(g) as illustrated in Table 4.

124. The environmental report should include a description of the mitigation and compensation measures introduced to avoid, reduce or offset any significant adverse environmental effects and should provide an indication of the anticipated effectiveness of the measures in achieving the mitigation and compensation. One of the more important mitigation measures to consider in the report will be the way in which the plan itself has been modified as a result of the environmental assessment process.

125. The planning authority should prepare the environmental report, which must be made available with the consultation draft plan. The environmental report must comply with the requirements of Article 5 and Annex I of the Directive. The environmental report is the main vehicle by which consultation is to be achieved. Its contents are prescribed by Annex I of the Directive and the revised report must be placed on deposit again with the submitted or finalised plan. In all cases, the public must be invited to comment on the report as well as the plan. However, although important, the environmental report should not be seen as the only or principal output of the assessment process. The report and the plan should refer to each other and it should be clear how the assessment process has influenced the plan especially its policies and proposals. Annex I(h) requires the environmental report to include "any difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the environmental information". A suggested outline of the contents of an environmental report for a development plan is given below.

Developing proposals for monitoring

126. When preparing the environmental report planning authorities should set out their preliminary proposals for the monitoring of the plan in respect of its significant environmental effects. Whilst this process cannot be completed until the final contents of the plan are known, near to the time of adoption/approval, planning authorities, nevertheless, have to provide at least preliminary and reasonably comprehensive proposals for monitoring in order to comply with the Directive.

127. Article 5.1 and Annex I(i) require that the environmental report should include "a description of the measures envisaged concerning monitoring in accordance with Article 10". This implies it is recognised that the monitoring proposals cannot be fully developed when the environmental report is written but the measures envisaged at that stage should be included. The monitoring of the implementation of the plan, as required by Article 10.1, should be designed to "identify at an early stage unforeseen adverse effects, and to be able to undertake appropriate remedial action". Article 10.2 provides for a planning authority to use existing monitoring arrangements (which may not necessarily be monitoring undertaken by the planning authority itself) if appropriate, to avoid duplication. Stage 14 below provides further guidance on monitoring,

128. It will be necessary for planning authorities to consider what effects, or possible effects, may need to be monitored, how they may be monitored, whether existing arrangements would be sufficient and appropriate to achieve the required monitoring and thus whether any new monitoring arrangements need to be put in place.

129. The planning authority will take account of public representations on the consultation draft plan but this stage will now need to include consideration of the comments on the environmental report. There will be important interactions between the comments and these should influence consideration of changes to both the plan and the report. Representations about the findings of the environmental report and/or about the plan may suggest deletion of policies or proposals or new policies or proposals, or significant modifications, to those in the consultation draft. The changes should be assessed.

130. Any revised or new policies will need to be assessed against the environmental policy criteria and new or revised proposals assessed against the criteria used to test the proposals. It will be necessary to consider whether deletion of policies or proposals would have significant environmental effects. The planning authority should also consider whether any new or different significant environmental effects can be mitigated and if so include appropriate mitigation measures in the next version of the plan.

131. The environmental report will need to be revised accordingly. If changes are extensive a new report is likely to be the most appropriate way forward. However, if modifications to the plan and changes to significant environmental effects are limited it may be sufficient to produce a supplementary environmental report, so long as the original report is still available for the public.

132. The planning authority will finalise the plan in preparation for deposit and submission to the Scottish Ministers in the case of a structure plan or for deposit in the case of a local plan. The revised environmental report must also be submitted to the Ministers and placed on deposit. The environmental report must comply with the requirements of Article 5 and Annex I.

133. It is anticipated that the existing statutory requirements for consultation and publicity for finalised plans in the 1997 Act and the Structure and Local Plan Regulations will be adequate to meet the requirements of Article 6.1 and 6.2 of the Directive. Planning authorities should particularly ensure that the environmental report is included in all deposits and reference to it made in all publicity. They should also ensure that the designated consultation authorities receive a copy of the environmental report with the submitted/deposited plan.

134. Under Article 8 of the Directive there is a duty to take account of the environmental report, consultation responses, opinions expressed by the public and the results of any transboundary consultations during the preparation and before the plan's adoption/approval. For structure plans the duty appears to be a continuing one up until approval of a plan by Scottish Ministers. Similarly, a planning authority (as advised by a Reporter where a Public Local Inquiry has been held to hear objections to a local plan) shall take account of the environmental report, consultation responses, opinions expressed by the public and the results of any transboundary consultations during the preparation, and before adoption, of a local plan.

135. It follows that the consideration of the results of the assessment process may require the plan to be modified before approval/adoption and the planning authority or Scottish Ministers, as the case may be, will need to consider whether any such changes arising from this requirement should be placed on deposit/publicised as proposed modifications to the plan

136. Thus the planning authority, and Scottish Ministers as appropriate, will need to continuously bear in mind the environmental report, consultation responses, opinions expressed by the public and the results of any transboundary consultations at every stage following the deposit of the plan. In particular, with regard to a local plan, for example, these results of assessment should be taken into account when considering pre-inquiry modifications to the plan, during the Public Local Inquiry to hear objections to the plan, when considering the Reporter's report and recommendations and post inquiry modifications (and any further representations received).

137. Where any modification to the plan is proposed (after the deposit of the finalised plan and environmental report) that would be likely to have significantly different environmental effects it will be necessary for the planning authority or Scottish Ministers as appropriate to review and if necessary, supplement, revise and re-consult/re-publicise the environmental report at the same time as the modifications are publicised. In deciding whether to revise the environmental report, planning authorities should have regard to any representations made by the designated consultation authorities as to the continuing validity of the environmental report in light of the proposed modifications.

Prepare Article 9.1(b) statement

138. The Directive requires a statement to be prepared in accordance with Article 9.1(b) which shall summarise:

a] how environmental considerations have been integrated into the plan or programme;

b] how the environmental report, consultation responses and public opinions have been taken into account in accordance with Article 8; and

c] the reasons for choosing the plan as adopted/approved in light of the other reasonable alternatives dealt with.

As this statement must be made available to the designated consultation authorities and the public when the plan is approved/adopted, it will be necessary to start its preparation in sufficient time. The Directive does not specify whether this statement should, or may, be included in the adopted plan.

Finalise proposals for monitoring

139. It should now be possible for the planning authority to finalise its proposals for monitoring in accordance with Articles 5 and 10. The reason why it would not be possible to finalise before this stage, and include in the environmental report only preliminary measures envisaged for monitoring is because the full and final content of the plan's policies and proposals would not be known until this stage. The requirement of Article 9.1(c), to make available the measures decided about monitoring at the time of adoption of the plan, must recognise that the measures included in the environmental report may not be the final monitoring measures. Further guidance on monitoring is given in Stage 14 below, Appendix I (paragraph 23) and Appendix H.

Adopt/approve plan and make information available

140. On adoption/approval the planning authority must also comply with Article 9 and ensure that the designated consultation authorities and the public are informed. Pre-existing publicity arrangements are expected substantially to provide adequate compliance for this notice of adoption/approval. A statement in accordance with Article 9.1(b) and a statement as to the measures decided concerning monitoring shall be made available to the public and the consultation bodies.

141. Upon adoption/approval of the plan the monitoring should be commenced. However, often in practice, the process of monitoring, review and potential adjustment and revision of the development plan will already have been started.

142. Articles 9 and 10 require planning authorities to monitor the significant environmental effects of implementing development plans to identify the effects, whether anticipated or unforeseen and to take remedial action if necessary.

143. The 1997 Act already places a duty on every planning authority to keep under review the matters which may affect the planning of development (Section 4), to justify structure plan policies and proposals with survey results (S7(2)) and to keep local plans under review (S.13). Advice on monitoring and review is given in PAN 37 Structure Planning and PAN 49 Local Planning.

144. Where the monitoring information indicates that significant environmental effects arising from a local plan need to be remedied, that should be regarded as a consideration under S.13(2)(a) and could lead the planning authority to consider reviewing and, if necessary, altering or replacing the plan under S.13(1) (see also SPP 1 paragraph 38). Similarly for a structure plan, monitoring could lead an authority to consider preparing an alteration or replacement plan under S.9.

145. Monitoring is an essential part of the development planning process and particularly important for assessment. Indeed, it is a requirement of the Directive. Furthermore, assessment can make a major contribution to wider monitoring programmes, for example by allowing limited resources to be focused on key areas of uncertainty or potential policy divergence which the assessment has highlighted.

146. Planning authorities already monitor some aspects of the development plan, eg population change, housing completions and employment, but these will not be the best indicators of change for the environment. To be effective, monitoring of development plans should be based explicitly on specific indicators and targets that help to inform the understanding of environmental change in the area and how that may be influenced by the development plan.

147. Ideally, the effectiveness of the plan's policies and proposals needs to be monitored in combination with other environmental, social and economic monitoring, in an integrated way. It is the cumulative effects of change in the area that should be the principal object of monitoring. This may need to include environmental change that is outwith the direct control of the planning system and the direct influence of the development plan, for example, in respect of agriculture and forestry.

148. Monitoring has not received a high priority until quite recently, so there is relatively little work to draw upon in considering the monitoring stages of assessment. However, it is very likely that only limited resources will be available for monitoring so priorities need to be identified.

149. Whilst almost all aspects of the plan could be monitored in some way, this is unlikely to be either feasible (from a resource point of view) or necessary (there would be little advantage in monitoring issues that would not be likely to lead to significant changes in the plan review). Environmental monitoring could be focused on three key aspects:

a] Reducing uncertainty;

b] Sustaining irreplaceable environmental assets that if lost can never be recreated; and

c] Improving environmental assets such as landscape, townscape, water or air, which are degraded and require restoration or enhancement.

150. The Development Plan could cross reference relevant policies with possible indicators and targets, where applicable. Monitoring of these indicators, therefore, would show where specific targets are being met or missed and provide a guide as to how well the plan is performing its part in achieving the environmental objectives.

151. Monitoring should be a useful and cost effective process. It should be comprehensive without being unmanageable; rigorous without being complicated and meaningful without being complex, esoteric or inaccessible. Preference should be given to indicators that may monitor more than one aspect of environment. Different aspects of the environment may be grouped to reduce the monitoring effort, without reducing its inclusiveness or effectiveness. Lessons should be learned from other monitoring projects, elsewhere, but monitoring projects need to be developed that reflect local priorities, issues, pressures and environment.

152. It is also important to accept that a full scale monitoring programme is not likely to be feasible at the start. A modest beginning, with a small number of effective indicators, is better than no monitoring at all. Any programme can be extended, modified and refined with experience and as more information becomes available. The frequency of monitoring can be increased as more experience or resources become available.

153. Targets may be set so that monitoring can check to see whether they have been met or missed, and why. Targets should be demanding and worthwhile, clearly beneficial and meaningful, but they should also be feasible and realistic. Nothing is gained by setting targets that can never be achieved, because they are out of reach. However, not every indicator needs to have a specific target. Sometimes there are important indicators of trends and directions that do not necessarily have specific stages or measurements, but nevertheless clearly point to whether the plan is helping to sustain or diminish the environmental resource.

154. Finally, indicators and any related targets should always reflect the values, aspirations and attitudes of all sections of the community. As many people as possible, representing as many views as possible, should have an opportunity to contribute to the selection of indicators and the setting of targets. This is very much in line with the inclusive approach of the Directive.

155. Crucially, development plan monitoring needs to concentrate on the effects of development plans and the planning process. It may be tempting to select indicators that are easily tracked, because they are collated and published by others, such as headline indicators. However, these may reveal nothing about the performance of the plan. It is likely to be much more useful to the plan review process if indicators and targets are more like those in Figure 4 below.

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