Analysis
From SEA.unu.edu/wiki
SEA of the Strategic Defence Review Emma Dolman, Defence Estates
Introduction
This paper aims to describe the process and critically assess the Strategic Environmental Appraisal (SEA) of the Strategic Defence Review (SDR) which has been undertaken by the Ministry of Defence (MOD) over the last 18 months and is due to be published in mid April 2000.
The framework for the paper is that set out by Therivel and Partidario (1996). This framework will act as a form of 'Terms of Reference' for the SEA to ensure that all available information is captured.
The Action
This SEA has been undertaken following a commitment made in the SDR White Paper (July 1998) to carry out 'environmental appraisal wherever appropriate'. Fundamentally, SDR was an initiative to modernise and reshape the Armed Forces in the light of the end of the Cold War and was an opportunity to focus on where, when and how the Services should operate and at what level. Clearly, this involved policy decisions not only across the Services but indeed the Foreign Office had an important part to play in deciding what level of activity the UK would participate in overseas, given the role of organisations such as NATO etc. Therefore, this wide-ranging Review had diverse impacts right across MOD. This is groundbreaking work, since, it is the first time that environmental appraisal has been undertaken across virtually all aspects of MOD business. Certainly, it is the first time that the Government has undertaken an SEA of this type, scale and complexity.
Type, Subject and Scale
SDR is to be implemented through 454 separate activities, which are aimed at improving performance and efficiency. Whilst some of the activities are related to changes in the training of the Services and procurement of future equipment, many of the activities are concerned with improving the quality of life for Service personnel in an attempt to increase retention and redress the current under-manning issues. Retention of personnel not only requires better training and enhanced career structures but also improvements to the conditions experienced by their dependents.
Policy appraisal was not undertaken as the SEA commenced after SDR was published. Therefore, where the Government has defined its requirements for weapons, equipment, personnel levels or strategic patterns of deployment, these policies were accepted and used as the starting point. The boundaries for the SEA extended to all 454 programmes and plans arising from SDR but did not include overseas. The SEA did not consider pre-SDR plans or indeed any decisions made post SDR. Although, this may appear to be straightforward, the boundaries were inevitably unclear, as some decisions made pre-SDR contained elements that were subsequently identified as actions within SDR. This meant that some of the 454 activities were plans and others programmes.
Level of decision-making
Defence Estates (DE) were tasked with carrying out the SEA. Ministerial approval for the project came through the Defence Estate Board which comprises the MOD Green Minister, the Chief Executive DE and Senior Service Chiefs. DE set up a team which had close liaison with the Services, especially Headquarters Land Command who occupy the largest proportion of the Defence Estate. The progress of the SEA was reported to the Minister via the Board and significant decisions (for example the Army basing plot) and direction were given through this medium.
There was considerable stakeholder interest which included focal points for the Services, MOD Agencies, Central MOD departments (for example the SDR Implementation Team), Statutory Bodies (see Appendix 1) and the Voluntary Sector (see Appendix 1).
Confidentiality
Once the team had ascertained the nature of each project and an assessment had been made, the individual project teams were asked to security clear their proposed entries. The Government aims to deliver business in the most open and transparent manner, therefore, any activity which the project team wanted to remove from the publication list, had to have clear reasons for doing so, by the end, the MOD SDR Implementation Team had confirmed 50. Nevertheless, these projects all went through the screening and where recommendations have been made they will be carried through into the project.
Timing
The SEA commenced in September 1998 and is to be published in mid April 2000. It was accepted that the timescale was short for such a comprehensive SEA and there was concern from the Statutory Bodies. However, there were time pressures related to the necessity of implementing projects especially those related to Army training and garrisoning (the latter involving spend in excess of £500m) which will require Notices of Proposed Development. Effectively, the SEA was running in parallel with the development of certain major projects and was not an ideal situation.
SEA PROCESS:THE CONTEXT
Guidelines and Regulations
As discussed above, the SEA was a commitment made through the SDR White Paper. The publication of Policy Appraisal and the Environment (PAE) by DETR in early 1998, made explicit the Government's requirements and this SEA has attempted to follow these guidelines. The Labour Government in delivering its manifesto commitments has set up a strengthened Cabinet Office network of Green Ministers. Each Government Department has one. These Ministers support the new Cabinet Committee on the Environment and the Green Ministers are the focal point for their Department on setting up and 'acting as an advocate for the consideration of the environmental impacts of their Department's policies and programmes' DETR, PAE (1998). The Minister responds to enquiries from the Parliamentary Audit Committee and this particular SEA has been and will continue to be, scrutinised by the Committee, so far it has stood up well to detailed questioning.
Links to policies, actions and plans
There are a plethora of environmental policies and plans which have been taken into account in the exercise, in particular the EU Habitat Directive. It is interesting that DETR's PAE commits the Government to go further than the Draft EU SEA Directive 1999 which excludes both policy appraisal and the Defence sector. The MOD is one of the largest Government Departments and therefore, there are many internal projects and actions that the team became aware of during the process which, in turn, had to be considered.The MOD was determined to be open and transparent in the process, demonstrating a clear audit trail of decision-making, showing how conclusions were reached and the extent to which alternatives had been considered. There has often been a perception that MOD through its planning clearance procedure (which mirrors the Local Authority Planning Application process) merely tells the Local Authority its intention and expects its developments to be rubber- stamped. This is not the case and the SEA had a clear remit to follow the open Government policy.
DE was required under SDR to develop an Estate Strategy in order to demonstrate competence in managing the Defence Estate (asset value £14 Bn). This study has been running in parallel with the SEA and many of the SEA recommendations for enhancement and mitigation (especially on the Training Estate) will have a direct impact on the management of the Estate. These will be developed through the implementation of the Estate Strategy. This will become an important feature in the future management of the SEA.
Screening process/methodology
There were no precedents for an SEA of this size and complexity and Land Use Consultants (LUC) had to draw up a methodology to fit the circumstances. The study was assisted by the consultation process particularly DETR, RSPB and the Environment Agency who had experience in devising SEA methodology. The screening had to be at a strategic level so that decision-makers were aware early on of potentially significant environmental impacts. The SEA aimed to support to project managers identifying alternative options and possible mitigation measures. The SDR programme evolved so some projects at the start were already awaiting Ministerial decisions and these had to be fast-tracked through the process. Other projects had little clarity. As the SEA continued several projects for various reasons were withdrawn, possibly due to budget cuts etc.The methodology had to provide for:
- Fragmented nature of decision-making processWeighting of environmental factors at an early stage in the processPragmatic approach which could accommodate decisions that had already been or were in the process of being madeLevels of uncertainty relating to the impacts of SDRHigh degree of flexibilityScope for iterations to improve the Estate Strategy over time
- Requirement for monitoring and review
Extract from SEA of SDR Main Report 2000
The SEA methodology was flexible and tiered in approach, involving a framework for a progressively more detailed review of areas of activity. Activities were identified at screening and scoping stage as having potential for significant environmental impacts. LUC carried out the first screening which examined the White Paper in detail. The Report of this was completed in February 1999. This set out a list of 43 activities which were likely to cause potentially significant environmental effects. In the light of the Preliminary Findings, the consultancy teams then carried out their own screening and scoping exercises which were appropriate to their study. For example, Entec used the criteria listed in Appendix 1 to screen the potential impacts of the 36 Built Estate proposals.
The Review of All Activities ascertained the nature of the 454 projects. At high level these were screened through sieving exercises. This included screening the activities examined in the 2 lower level Higher Level Environmental Assessments (HLEAs) and interestingly, the HLEAs combined, covered only 20 projects. The flowchart at Appendix 2 illustrates the whole process.
Criteria
For the purposes of this study, "environment" was defined as wide as possible to include social and economic factors. Criteria that were developed for the assessments were derived from sustainability indicators used in the environmental appraisal of development plans and other sources. There are 14 criteria, see Appendix 1.
Due to the time pressures, size and complexity of the SEA, it was agreed that a 'snap shot' in time (Autumn 1999) was taken, where SDR activities were appraised as they stood, with as much information as was available at that time. Inevitably, there are many changes to projects over their lifecycle so a line must be drawn. This left a commitment with the project managers to contact the SEA team now or in the future if their projects alter significantly.
SEA PROCESS: THE STEPS
Who prepared the SEA?
The responsibility for delivering the SEA belonged to DE. Since the task was so far reaching it was decided to employ 3 sets of consultants, DE also looked for skills transfer for their own staff. LUC were selected to set up the overarching SEA methodology, however, no framework existed for a project of this size and diversity. They were chosen as they had significant experience in this new area of environmental appraisal and their lack of experience with the MOD enabled them to have less preconceived views. The project was divided into 3 areas, which allowed work to be handled in manageable chunks, this aimed to produce more objectivity.At a very early stage in the process, it was realised that there would be major impacts on both the UK Army Training Areas and the Army Built Estate. It was decided to set up 2 HLEAs to consider in parallel and in much more detail, the potentially significant effects of SDR proposals on the Defence Estate. Clearly, there is considerable linkage between the 2 HLEAs, for example where you accommodate your troops both in living quarters and storage of equipment (eg vehicles) will have a bearing on where they subsequently train. These Studies are reported in separate documents but they are synthesised along with the strategic level Review of All SDR Activities in the 'overarching' SEA Main Report.The Review of All Activities was undertaken with support from LUC. It is important to note that this Report is strategic due to the enormous number of activities assessed. Much of the information about activities was uncertain and indeed, several have incurred major changes in their nature and scope over the life of this project and have had to be reassessed just before publication.
The HLEAs were undertaken by RPS on the Training Estate (since they had detailed knowledge of Army training requirements and considerable experience with the Army Training Estate.) Entec undertook the work on the Built Estate. They also had prior knowledge of the Estate, as Term Consultants for MOD. Both consultants worked in close conjunction with the Army.
Sustainable Development and carrying capacity
The SEA process has examined the degree to which principles of sustainable development are incorporated into;
* The planning and design of new buildings/structures,Allocation of land for training purposes (either new or altered requirements), * Other associated activities.
The principles related to;
* Protection and enhancement of biodiversityAppropriate use of energy and natural resourcesEfficient use of transport * Enhancement of quality of life for military personnel and local communities etc
Carrying capacity was only considered in a basic form in the HLEA Training Estate (HLEA TE). The new training requirements had to be translated into potential use of the Army Training Estate and this was then matched against current use and current constraints which in most cases were significant as the Training Estate although diverse, has many conservation designations with a large number of International designations. Little scientific research to inform carrying capacity has been undertaken on the Estate. This area of work is to be considered in more detail in the Estate Strategy.
Identification and scoping of impacts
As discussed above once the initial Preliminary Findings had been written each consultant worked on the project following their own methodology. This was overseen by LUC, as they were to produce the final synthesised SEA document. Appendix 3 shows the main steps that were undertaken in the SEA.The review of All Activities was the most strategic level approach and involved 2 further screening exercises. These were done by telephone due to time versus number of projects to be assessed! Each activity was assessed against sustainability criteria which if the threshold was exceeded, required scrutiny at a lower level. Broadly the criteria used fell into the following areas:
* Human resourcesBuilding worksBuilt environmentRural/urban environmentInfrastructure/energy and raw material * Pollution
This produced the third level screen which included 114 activities which then passed through a more detailed assessment. Both positive and negative impacts were assessed as in a few cases there were positive environmental benefits. Their overall significance was recorded and recommendations were made to ensure that environmental issues raised were built into the projects.
The findings showed that many of the activities were unlikely on their own to produce significant environmental concerns, cumulatively there was much more potential. Consequently a database was set up to record them.
Baseline Information
The MOD is one of the largest landowners in the country. If put together all of its property would just fit inside the M25. It has a primary function to ensure that the Armed Forces are garrisoned and trained to the required readiness states to defend UK interests at home and abroad.DE in its function as managers of the Defence Estate keeps records of the Estate. Both RPS and Entec were familiar with the Estate and this made their tasks easier at the lower level, in knowing where and how to gain information. The HLEA TE needed to elicit the impact of SDR proposals in terms of effects on the Army structures and training under the proposed systems and RPS were in a good position to move quickly due to their knowledge of the Estate and Army systems. Entec having worked on garrison plans in the past understood the Army Estate management system which was essential for the project to proceed quickly.LUC had no experience of the Estate and it took some time to brief them on where the baseline information was kept and how the Estate was used by both civilians, MOD Agencies and the Services. The Review of Activities and the Main SEA Report required less urgent intimate knowledge of the Estate functions. The Estate has many competing interests apart from training which include; nature conservation designations, archaeology, public access and recreation, agriculturally tenanted land and listed buildings. Also, the Service personnel provide important income streams into the local economy.
The Estate information held by DE is gradually being built into Integrated Land Management Plans on the Rural Estate. This is a critical area needing development as it carries forward findings from the SEA, (currently partially GIS based) and will be examined in more detail in the Estate Strategy.
Alternatives
It was made clear at the outset that alternatives must be considered in all cases, where appropriate, in an open and transparent manner. This was especially important in the HLEA TE, as for example, equipment such as tanks on Salisbury Plain are considered to be the only suitable training location. This is indeed accurate as the chalk on Salisbury Plain is the only area that can support tanks but decision-making must be explicit. However, the Otterburn Public Enquiry was continuing and had a bearing on the SEA. Otterburn is a long running Public Enquiry where the Army wish to develop the Otterburn training area which is situated in a National Park. This meant that there was even more need to demonstrate openness and transparency in the SEA by showing how the alternatives were considered. On the Built Estate, in some cases, the timing allowed more consideration of alternatives than usual. Generally, Entec found that the Army were able to show that alternatives and often the environment had been considered in their decision-making process, although not explicitly.
During the telephone questionnaire in the All Activities Review, alternatives were elicited and hence built into the process at the earliest possible stage.
Consultation
The Statutory Bodies and Government Agencies listed in Appendix 1 were consulted through a specially formed Working Group. This was a key feature of the SEA. The NGOs (also listed) were a representative sample, which formed a separate Working Group. Again this approach demonstrated an open and clear audit trail by MOD in the process and allowed valuable expertise gained by these bodies to be incorporated into the SEA. These groups were able to see exactly how decisions were formed in the SEA and the Statutory Bodies were given a chance to comment on the draft.Consultation provides the SEA team with external validation and some confidence in the methodology. It may well be that some of the detailed findings and decisions made are not exactly what they wanted but the way the decisions have been made is clear to everyone. The Statutory Bodies, by joining the process, have reduced potential conflict that could arise at the end of the project and it is a clear example of joined up Government. The Statutory Bodies seemed to find it difficult to accept that some information was strategic and they tended to focus on the detail of the lower level HLEAs.The NGO consultation was successful but it took time to build trust and explain MOD structures. There were also some confidentiality issues and the interface with the Otterburn Public Enquiry had to be managed. Since they were a representative sample it was unclear to what extent they were successful at cascading down some of the complex issues, to the groups they were representing.
Local Planning Authorities were consulted at a later stage, due to MOD confidentiality early on, Entec found this confidentiality, unhelpful to the process. They were consulted once more specific site details were available.
Mitigation
Mitigation was explicitly built into the process. The SEA especially in the HLEA TE had to be careful that mitigation was not driving the decisions and alternatives were thoroughly examined and documented. Entec found that in some cases mitigation was the factor which supported only one choice of site. Mitigation was essential in some areas and commitments have been made to ensure it will be implemented.
Review of SEA
The recommendations from the SEA include specific reference to the need to monitor, manage and support the SEA. The Minister will be launching the document and so there will be Ministerial commitment to ensuring that the work is implemented according to the recommendations. MOD intends to resource the development of the SEA through DE and this will involve maintaining the current database and reviewing potential cumulative impacts at sites. DE will co-ordinate the Army activities on the Built and Training Estates as their decisions impinge on each other. The boundary between the 2 HLEAs, Entec found to be too arbitrary and felt some of the cumulative impacts were lost in the process.
The Working Groups of external consultees will continue to meet and review the SEA.
Presentation of SEA
The SEA is to be launched by the Minister (mid April) and will contain 5 separate elements. These are;
- Executive Summary,SEA Main Report, the overarching SEA which draws together the findings and recommendations of the 3 studiesSEA of SDR Review of All Activities, the strategic level technical report of 454 activities arising from the White PaperHLEA Army Training Estate, a detailed investigation of potential SDR impacts on the Army Training Estate
- HLEA Army Built Estate. A detailed investigation of proposed SDR changes to the Army Built Estate
These reports comprise over 1000 pages and so will be distributed by CD Rom and will be available on the MOD Web page.
RESULTS/EFFECTIVENESS OF SEA
The Preliminary Findings were shown to have influenced the nature of subsequent planning and programming by the Services with major benefits to the environment. Examples include possible changes on the location of live firing exercises, recommendations on location change for an Engineering Regiment and detailed recommendations on how to incorporate the environment into the design of SDR activities. Overall, the national picture remains unchanged but possible environmental issues may be raised by some intensification in the use and levels of training areas over the current levels. A major factor emphasised by the SEA was that low level training carried out by the Army has the most potential to create environmental problems and an improved system for anticipating the demand for this type of training must be identified. Training should in the future be given more direction linked to possible studies on carrying capacity. Again this area will be taken forward through the Estate Strategy.The Minister, DE and the Services will sign up to the 65 recommendations, especially the Army, where the HLEAs provide very detailed pointers. Action is now being taken to either implement these or examine the most effective way of doing so. As discussed, the Defence Estate Strategy will provide a very effective vehicle for taking forward substantial issues not addressed in detail in the HLEAs.The recommendations have put responsibility onto the projects to incorporate the findings and if these are not adhered to, as the projects develop, then there is sufficient senior MOD backing. The fact that SEA has been brought to the notice of 454 projects is a major step forward. DE can now build on the SEA and develop their own internal expertise following the successful skills transfer from the consultants. They are now being resourced to undertake the management, monitoring and support recommendations contained in the report.There is a commitment to introduce SEA across MOD formally and this will be done via an SEA/EIA Committee which will form part of the Environmental Committee structure, it is anticipated that DE will chair this, following experience gained from this SEA. DE are commissioning a handbook for SEA/EIA which will be promulgated across MOD and DE will provide advice and support where necessary.The result of the process is not only that environmental issues have been heightened but also that the SEA contains a commitment for MOD to consider policy appraisal and hence follow PAE guidelines, in future work. Policy appraisal was not undertaken and this left a gap. LUC felt that this meant some options and locations could have been influenced earlier. Another flaw was where troops are being relocated in the UK from Germany and the SEA did not look cross-boundary at the effects on the German economy. It has to be recognised that this was a pilot and despite its size, the SEA did leave out some key areas.
There will be a continuing need to monitor the recommendations to check whether predictions about levels of use and potential impacts occur and also to monitor cumulative impacts. The development of Integrated Land Management Plans is key to establishing better baseline data across the Estate. Also, the recommendations from the SEA are being built into the targets and performance indicators in the Defence Estate Strategy.
CONCLUSION
Finally, the feedback so far has shown that external bodies are impressed with the openness of MOD by having been given the opportunity to participate in the development of such a complex SEA. This external validation of the methodology has been critical to the success of the project. It can be seen from the evidence above that the SEA has made a significant difference to the way programmes and plans have been considered under SDR. The process has raised the profile of SEA in MOD to Ministerial level and indeed, across all MOD business and ironically for the MOD, the Environmental Audit Committee has praised the work, thus far.In reviewing the process with the consultants, Entec and LUC felt that the flexible and iterative methodology was the key feature which enabled modifications to be made during the SEA process. This was essential as MOD has large and complex structures and lines of communication.
The proof of the SEA is in monitoring and review to ensure recommendations are implemented, however, MOD has made commitments through resourcing and setting up systems to facilitate the process. MOD is a vast Department and there will undoubtedly be problems of implementation but the key factor is that policies will be appraised in the future as a direct result of this work and the environment is placed on the 'agenda' for decision-making at every level, alongside operation and financial decisions, this step forward for MOD cannot be underestimated.
Appendix 1. Statutory Bodies and other government agencies consulted
* English Heritage * English Nature * Environment Agency * Scottish Natural Heritage * Countryside Council for Wales * Association of National Parks * DETR * Countryside Agency
Non-governmental organisations/voluntary sector
* RSPB * Council for National Parks * Open Spaces Society * CPRE * Council for British Archaeology * National Farmers Union * Tenant Farmers Association
Appendix 2. Sustainability criteria used in the screening process
* Climate change * Biodiversity (Habitat/Species) * Local Environmental Capital * Land and Building * Townscape/Landscape * Water * Air * Cultural Heritage * Access and Recreation * Transport/Traffic Impacts * Tranquillity (Noise) * Socio-economic Factors * Community Welfare * Economic welfare * Infrastructure
Appendix 3. Basic Steps in the SEA Process
- Confirm the scope of the SEADevelop the methodology and approachConsult relevant statutory bodies and environmental interestsExamine, at a strategic level, the environmental assets and resources (Environmental Capital) making up the Defence Estate (built and rural).Review the different programmes and activities of the three services arising form the Strategic Defence ReviewUndertake preliminary screening to identify the need for Higher Level Environmental Assessments (HLEAs) and Environmental Assessments (EAs)Assess the potential of the different elements of the Defence Estate to contribute to and support the various SDR programmesCarry out an evaluation of the interactions between the SDR programmes and the environmental capital of the Defence EstateDefine areas of potential environmental significancePropose mitigation and enhancement measuresMake recommendations to decision-makersPropose monitoring and evaluation
- Prepare reports of findings
Adapted from SEA of SDR Report Findings (1999)
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