1. Conducting a Successful SEA Dr Steven Smith SEA in Practice, Malta, 11 November 2011

2. What is SEA?  How environmentally sustainable is our plan?

3. The SEA Directive  The SEA Directive is essentially procedural and sets out a series of steps that must be undertaken as part of an assessment; reflect these steps in the plan-making procedure to help ensure compliance  (Undertaking SEA does not offer any guarantee of a more environmentally friendly plan; SEA is decision-aiding not decision-making)

4. What makes for a successful SEA? Establish close links between the plan-making and assessment processes Scope out less relevant issues Work with plan-makers to develop reasonable alternatives Consider the best SEA methodology to adopt Identify significant effects Provide plan-makers with explicit recommendations for improving the plan Establish indicators for monitoring significant effects

5. Establish links between plan- making and SEA  “Many benefits of SEA may be lost if it is carried out as a completely separate work- stream or by a separate body. But it is also helpful to involve people, either within the Responsible Authority or outside, who are not directly concerned in producing the plan or programme and can contribute expertise or a detached and independent view”

6. Establish links between plan-making and SEA

7. Effective scoping  “Most practitioners scope in all issues rather than those that are just significant”  “it can take a bit of courage to scope things out”  “if issues are not significant these should be dropped as the assessment moves on” Quotes from research interviewees

8. Effective scoping  Begin by considering the issues identified in the SEA Directive…

9. Develop reasonable alternatives  “Where an environmental assessment is required… an environmental report shall be prepared in which the likely significant effects on the environment of implementing the plan or programme, and reasonable alternatives taking into account the objectives and the geographical scope of the plan or programme, are identified, described and evaluated…” SEA Directive, Article 5(1)

10. Develop reasonable alternatives  European Commission guidance on the SEA Directive defines an alternative as “a different way of fulfilling the objectives of the plan or programme”; very little further guidance  “It is essential that stakeholders are given the opportunity to consider genuine alternatives” UK Department for Communities and Local Government (2008) Spatial Plans in Practice: Supporting the reform of local planning

11. Develop reasonable alternatives  “Consideration of meaningful alternatives is not easy and plan makers are still at a relatively early stage on the learning curve”  “In some cases may be there aren’t any alternatives; but it needs to be explored”  “a lot of alternatives are not that realistic” Quotes from research interviewees

12. Develop reasonable alternatives  In March 2011, the UK High Court ruled that part of the Forest Heath District Core Strategy must be quashed because the Environmental Report failed to present… “an accurate picture of what reasonable alternatives there are and why they are not considered to be the best option”… in relation to an urban extension to the district’s main town Save Historic Newmarket Ltd v. Forest Heath District Council [2011] EWHC 606, a challenge under s.113 of the Planning and Compulsory Purchase Act 2004 to the adopted Forest Heath Core Strategy

13. Develop alternatives in relation to…

14. What do alternatives look like? Spatial Option 1Sustainable urban extensions to coastal towns Focus growth predominantly on the coastal towns of Bognor Regis and Littlehampton, through a combination of development within the existing built up areas, combined with planned sustainable urban extensions. Some development will be located in other parts of the District to meet local need. Spatial Option 2New settlement at Ford Concentrate growth at Ford, through development of a new settlement (Ford Eco-town) providing major housing, employment and community facilities. Spatial Option 3Expansion of inland settlements Focus a higher proportion of new development towards the larger inland settlements, particularly Barnham/ Eastergate/ Westergate and Angmering.

15. What do alternatives look like?

16. Alternatives can exist in a hierarchy

17. SEA methodology: ‘objectives-led’ Environmental objectives Option A: Locate the majority of new development in Settlement X Option B: Locate half of new development in an urban extension to Settlement Y and distribute the remainder between Settlements X and Z Option C: Locate the majority of development in Settlements Y and Z and provide for considerably higher densities in Y Objective 1 – reduce greenhouse gas emissions  Because…  Objective 2 – protect and enhance biodiversity  XXX Conclusions - Including the relative significance of the impacts, any assumptions made in undertaking the assessment, different impact dimensions, potential mitigation and monitoring measures

18. SEA methodology: ‘baseline-led’  For each topic (e.g. water, climate change) ask: What’s the policy context? What’s the situation now? What would be the situation without the plan? What are the key issues? What will be the situation with the plan?  Under Alternatives A, B, C and D How can we mitigate adverse impacts and enhance positive ones? How can we best monitor the plan’s implementation?

19. Identify significant effects  “Determining significance is the biggest single “process” problem identified by practitioners in SEA”  “analysis showed more significant adverse environmental effects identified for biodiversity (28%) and landscape (15%) and least on material assets (3%), air (6%) and soil (6%)”

20. Identify significant effects

21. Impact magnitude Sensitivity of the receiving environment LowMediumHigh LargeSomewhat significant SignificantVery significant MediumOf minor significance Somewhat significant Significant SmallNot significant Of minor significance Somewhat significant

22. Propose explicit recommendations SEA recommendationSecretary of State response Changes made to plan Green infrastructure Policy CC8 should be revised to explicitly require the preparation of Green Infrastructure Strategies for each of the 22 Regional Hubs We agree that the pursuit of Green Infrastructure will be particularly important in the 22 hubs as they are a main focus for development proposed in the draft RSS. However, we would stop short of explicitly requiring the production of Green Infrastructure Strategies as… Addition of a reference to the 22 hubs and Strategic Development Areas in the final sentence of the policy: “The provisions of this policy apply region-wide. However, the successful designation and management of Green Infrastructure will be particularly important in areas designated as regional hubs”

23. Monitor significant effects

24. Sustainability Appraisal  “sustainability appraisal covers wider social and economic effects of plans, as well as the more environmentally-focused considerations in the [SEA] Directive”

25. What do we mean by ‘successful’?  Makes a demonstrable difference to the plan’s environmental credentials? (NB SEA often plays a ‘fine- tuning’ rather than a ‘plan-shaping’ role)  Promotes a more structured approach to plan-making centred on alternatives?  Provides stakeholders with an enhanced understanding of the plan’s impacts?  Raises awareness of environment and sustainability issues amongst plan-makers?  Various possible indicators of success

26. Thank you Dr Steven Smith URS Scott Wilson | Environment 6 - 8 Greencoat Place London SW1P 1PL T: 44 (0)20 7798 5121 E: steve.smith@scottwilson.com