And in conclusion...
The government's positive approach to planning evokes the early days of EIA and the need for environmentalists to reintroduce sustainability into "sustainable development", argues Trevor Turpin.
It has long been my conviction that “conclusions” have no place in environmental statements (ES). The ES is an aid to decision making and its function is to report the facts and the findings of the environmental impact assessment (EIA). Having provided such information, the decision to approve or reject the planning application is taken by others – usually politicians, sometimes acting on advice from advisors.
In the past, as a member of IEMA’s technical subcommittee, I reviewed numerous ESs. Some were good, but many were woefully inadequate and often inappropriate. Going back 20 years there were many that explained the ES was provided to “support” the planning application, when of course it was not – ESs “accompany” applications they do not, under any circumstances, “support” them.
In those days there were still development-motivated planners who were accustomed to writing aggressive supporting documents, a hangover from before the EIA Regulations were introduced. They worked both expecting and preparing for a public inquiry into the development and so would draw the battle lines within their supporting documents in anticipation of arguments and confrontation further down the line.
These planners struggled to understand the role of EIA and I am a grateful that through IEMA we managed to eradicate such approaches in the main. However, I wonder if it is appropriate that, as environmentalists, we should continue to maintain this moral high ground and ignore the fact that often in the ES we submit, we simply detail the loss of habitat, the impact of noise or disturbance on a community.
I sometimes wonder when I see that “there will be a 5% loss of hedgerows”, whether we should be saying “and if we carry on like this the cumulative effect will be...” Surely the approach should be “5% will be lost and replaced by 10%”, in short creating a net improvement rather than a loss.
I was amazed to read recently of a road that was closed in India because elephants kept crossing it at night and causing accidents. The article explained that the elephants’ habitat had been fragmented by the road and there was insufficient food in the parcel of land left so they had to search in what had been their range – now planted fields and gardens.
It should hardly have been a surprise then that the elephants began to cross the road! It could have been predicted, but perhaps cumulative effects assessments are, if you’ll forgive me, the elephant in the room?
A similar example is the vast trouble and expense of assessing the effects of new roads on bats, to conclude the best way forward is to install bridges for them. If so much mitigation is needed then it might just be that the scheme is ill conceived, even if the findings of the ES would have said the bats will survive.
To cap it all off we then leave it to a politician or civil servant to decide whether the scheme should go ahead. Should they have that responsibility? Do they have the knowledge or expertise? Should we really leave it to them or should we environmentalists be bolder and spell it out: “We don't actually need a new road. We need less cars and to be content to get our goods a little later.”
I was reading the diaries of a politician recently, who said he knew his time in any ministerial post was limited and could be ended tomorrow on the whim of the prime minister, so he decided to focus on small targets. He tried to tackle issues such as Leyland Cypress hedges and night flights at Heathrow, but then he was moved to another brief and even these “small” issues didn't get resolved.
This case demonstrates perfectly that planning decisions should be based on clear expert advice from those that prepare ESs, so that, even in the fleeting attention span of busy politicians, the decision makers can see the cumulative effects of their judgements.
An approach which clearly spells out the environmental and social effects of development proposals is even more paramount now that the business department has instructed the Environment Agency and Natural England to consider the impact of their decisions on sustainable economic growth.
The battle lines are back and with the impending replacement of the Infrastructure Planning Commission and the transfer of its powers to the planning inspectorate, we environmentalists must, now more than ever, fight our corner. Perhaps the time has come to include our expert conclusions in ESs.
This article was written as a contribution to the EIA Quality Mark’s commitment to improving EIA practice.
Dr Trevor Turpin is a Director at Nicholas Pearson Associates, a Fellow of IEMA and co-author of the EIA Handbook.