Public participation is one way of helping to ensure good quality SEA; another is the use of SEA review criteria. These are a series of questions (or statements which can be used as questions) which provide a check on whether the SEA report/process has been done fully and well. They can provide a self-test for SEA authors, or they can be used by outside auditors to critically analyse the SEA. The criteria are typically organised by heading (e.g. baseline, alternatives).
The UNECE (2006) has compiled a list of SEA review criteria:
- Institute of Environmental Management and Assessment (IEMA) Environmental Report (ER) Review Criteria
- Verheem et al. 2000. Strategic Environmental Assessment Performance Criteria
- Bonde and Simpson 1999. Environmental Appraisal Review Package For Development Plans
- Office of the Deputy Prime Minister UK (ODPM) 2005. A Practical Guide to the Strategic Environmental Assessment Directive. Appendix 9.
Review criteria focus on the SEA report, and help to ensure that it discusses everything that it should, e.g. 'Is information presented so as to be comprehensible to the non-specialist?' 'Is there a non-technical summary?'. The criteria cannot really cover the detailed technical aspects of SEA, e.g. whether the right models have been applied, or the right assumptions and scenarios have been used. And they can only test whether the SEA process has been carried out to a very limited extent, e.g. 'Have the right people been involved at the right time?'. Verheem et al.'s (2000) criteria are probably the best test of the SEA process, but they are quite broad-brush and subject to personal interpretation.
It is perfectly possible to carry out an excellent SEA process but for the quality of the SEA report to be poor. Do you think that the opposite is possible: poor process but good report?
SEA report audit
SEA reports can be subject to a formal audit. This is a formal review carried out by an outside organisation, typically an 'independent' consultant, a government body such as the Netherlands Environmental Impact Agency, or a non-government organisation such as the UK Institute of Environmental Management and Assessment. The audit could be commissioned either by the competent authority as a preemptive 'self-check', or as a critical analysis 'against' the competent authority, e.g. by a non-government organisation.
Audits typically look at
- whether the SEA report (and process where appropriate) fulfils legal minimum requirements and, if not, what else it requires;
- whether it has been broadly done in accordance with current best practice and, if not, what else it could include.
Below is an example of part of an SEA audit, carried out by a consultant for the competent authority. Please consider the audit table and in terms of decision-making, legal context, recommendations and tiering relevance.
(Click on the link below the table to see the answers/ authors view)
|SEA requirement||Covered by SEA report?||Suggestions for improvement||Schedule 2, Regulation 12(3), Information for environmental reports|
|1. An outline of the contents and main objectives of the plan or programme, and of its relationship with other relevant plans and programmes
||p. 13 describes the background and objectives of the plan. Maps show various options for the relief road and housing development.||
|Appendix 3 shows links to a wide range of other plans and programmes.|
|2. The relevant aspects of the current state of the environment/ sustainability and the likely evolution thereof without implementation of the plan or programme.
||aspect of the environment||current state||specific to plan area?||likely evolution w/ out plan|
|(a) biodiversity||yes, p. 15||yes||yes||Include maps of designations, ponds, hedgerows etc.|
|(b) population||yes, p. 17||yes||partial||
|(c) human health||yes, p. 19||yes||yes||
|3. The environmental/ sustainability characteristics of areas likely to be significantly affected.||This section could really use some maps, e.g. showing designated areas, floodplain, agricultural soil quality etc.||
|4. Any existing environmental problems which are relevant to the plan or programme.||Yes: identified as being lack of affordable housing, maintaining and enhancing the natural environment, maintaining and enhancing the historic and built heritage, traffic congestion.||See A. environmental problems in main text|
|green shading||Done fine|
|blue shading||Done fine, but could be improved with small changes|
|yellow shading||Probably done to a level that would survive an Inquiry, but could be a problem|
|orange shading||Likely to be picked up as a problem at Inquiry|
A. Environmental problems. The Environmental Assessment of Plans and Programmes Regulations require that the SEA report must describe "any existing environmental problems which are relevant to the plan or programme including, in particular, those relating to any areas of a particular environmental importance" (Schedule 2.4). The analysis of paras. 99-110 may not be adequate for this. For instance, it does not discuss reduction in tranquility over time, declining biodiversity, increasing traffic levels (as opposed to congestion) and associated air quality problems. All have been identified as problems for X county in the SEA of its transport plan, and all could arguably also apply to Y district. These points matter because the options appraisal section should really refer back to these problems to help support its analysis. For instance, if air quality is already a problem, then increases in air pollution should particularly be avoided, more so than if it was not already a problem.
In key, reference to inquiry: Shows clear links to the decision-making process, and why good SEA is important to planners
"Schedule 2, Regulation...": Shows clear links to legal SEA requirements
Suggestions for improvement: Clear suggestions for improving the SEA report and process.
"All have been identified as problems for X county": Links to higher level SEA brings in concept of tiering.