SEA in Central Europe

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Riki Therivel

published in Project Aprpaisal 12(3), September 1997, pp. 151-160.

Contents

1. Introduction

At a time where the European Commission has -- after years of wrangling and watering down -- agreed on a draft Directive on strategic environmental assessment (SEA) which could apply to a limited range of plans and programmes1, several Central European countries have actively embraced the concept of SEA for all strategic levels, and are beginning to routinely carry out SEAs in practice. This article reviews some of these important SEA activities, which have been relatively unpublicised to date. In particular, it discusses how SEA is carried out in the Czech Republic, Hungary, Poland and the Slovak Republic.

The article begins with a review of relevant legislation and of SEAs carried out to date in Central Europe. It continues with three SEA case studies: for an express motorway network in Hungary, agricultural ownership transformation in Poland, and drinking water policy in East Slovakia. It concludes with a discussion of the strengths and weaknesses of these SEA systems, and of their relevance for other countries and contexts. The article draws heavily on the results of three NATO/CCMS-funded workshops on SEA2, organised by the University of Antwerp.

2. Regulatory context, and SEA examples

Table 1 summarises the SEA regulatory context of the Czech Republic, Hungary, Poland and the Slovak Republic, and Table 2 lists examples of SEAs carried out to date in these countries. They are discussed further below.

Table 1. SEA regulations and guidelines

Country

Regulation/guideline

Czech Republic

  • Czechoslovak Federal Act 17/1992
  • Czech Legal Act 244/1992
  • Guidelines for landscape assessment in territorial planning 1995

Hungary

  • Act No. LIII. of 1995 on the General Rules of the Protection of the Environment
  • 2/2005 Decree on Environmental Assessment

Poland

  • Land Use Management Act 1994
  • Executive order on forecasts concerning land use plans 1995
  • Guidelines on SEA for local land use plans 1996
  • Guidelines on preparation of protection plans for landscape and national parks 1996

Slovak Republic

  • National Council of the Slovak Republic Act No. 127/1994 on Environmental Impact Assessment
  • Draft guidelines for SEA of sectoral PPPs and generally binding legal directions 1996
  • Draft guidelines for land use plans 1996

Table 2. SEA examples

Country

Examples of SEA

Date of SEA

Type, scale and tier of PPP*

Proponent of PPP/SEA

Czech Republic

- Landscape protected area Zelezne hory (Iron Mountains)

- Landscape protected area Moravsky kras (Moravian Karst)

- Litomericko region

- Landscape protected area Jizerské hory (Isere Mountains)

1996

1996

1996

ongoing

a,r,plan

a,r,plan

a,r,plan

a,r,plan

Min. of Environment

"

"

"

Hungary

- Express motorway network

1993

s,r,programme

UVATERV

Poland

- Green Lungs management

- Privatisation of industry

- Privatisation of agriculture

- Privatisation of energy

- National transport policy

- National motorway network

- Bogdanka coalfield area

- New local plans and plan modification (20-30/year)

1992

1993

1995

ongoing

1996

ongoing

1996

1992-present

a,r,plan

s,n,policy

s,n,policy

s,n,policy

s,n,policy

s,n,programme

a,l,plan

a,l,plan

Inst. for Sustainable Devel.

"

"

"

"

National Fund for Env'al Protection/PHARE

Bogdanka Coal Mine

local authorities

Slovak Republic

- Territorial development policy

- Water management policy

- Drinking water policy for Eastern Slovakia

- Actualization of energy policy 1995-2010

- Spatial planning strategy: Zahorsha, Bystica, Bratislava,Zilina, Lucenec

1994

1994

1995

1995

ongoing

a,n,plan

s,n,policy

s,r,policy

s,n,policy

a,l,plan

Min. of Environment

Min. of Land Mgmt.

Water Mgmt. State Co.

Min. of Economy

Min. of Environment

 * type: a= area-wide PPP which applies to all activities in the area scale: 
 l= local tier: policy, plan or programme
 s= sectoral PPP which applies to a specific sector r= regional (see Box 1)
 n= national
   carried out separately from the decision-making process

2.1 Czech Republic (Dusik, 1995; Kasparová et al., 1996; Lipsky, 1996)

SEA in the Czech Republic was first required by the Czechoslovak Federal Act No. 17 of 1992, which states that

"Basic principles of environmental protection and environmental impact assessment are also (to be) adequately applied to the preparation of development programmes, conceptions and proposals for legal acts" (Article 20, part 2).

The Czech Legal Act No. 244 of 1992, which deals with environmental impact assessment for projects, elaborates on the term "conceptions" (i.e. policies, plans or programmes):

"A conception is... a conception submitted and approved by the central state authorities, namely in the sphere of energy, transportation, agriculture, waste management, mineral extraction and processing, recreation and tourism. Territorial plans (physical and spatial plans) and directive plans for water management are also considered to be conceptions".

Article 14 of the act lays down requirements for the SEA process: essentially it is a simplified process based on environmental impact assessment of projects, with limited participation and quality review.

Thus SEA is required in the Czech Republic at the national and regional level, and for a wide range of sectors. However, the term "conception" is not well-defined, allowing agencies to avoid carrying out SEAs, and accounting for the relative dearth of formal SEA examples to date. On the other hand, SEAs have been carried out on a preliminary, non-obligatory basis for the Czech agricultural policy, territorial plans for some large areas (eg. the National Park Krkonose), large industrial agglomerations, and two former military training sites.

In an effort to improve SEA implementation, the Ministry of Environment has asked the Czech Institute of Applied Ecology to prepare methodological guidelines for SEA. Draft guidelines were proposed in 1995 which recommend that the competent authority3 carry out the following process:

0. Environmental components are identified as being: air, water, soil, geology, fauna and flora, ecosystems, landscape, settlements, historical monuments, tradition, health, convenience and economy.

1. The relationship between the proposed PPP (the "conception") and the environmental components is assessed on a basis of I (no relationship) to IV (key relationship).

2. The magnitude of the PPP's impacts on each environmental component is assessed, from -3 (very negative) to 3 (very positive). Different PPP alternatives can be compared on the same matrix or graph.

3. The significance of the PPP's impacts on each environmental component is assessed from -3 (very negative) to 3 (very positive). The significance is a function of both the impact magnitude (from step 2.) and the sensitivity of the environmental component.

4. The time factor is then identified: when the impact would be expected (in months or years) after the PPP is implemented.

5a. A compatibility analysis is carried out, where sub-components of the proposed PPP are analysed to determine whether they support or limit the development of other PPPs subject to SEA. Table 3 shows a hypothetical example of such an analysis, in bold typeface.

5b. Finally, the impacts that the relationship between the subcomponents of the proposed PPP and other PPPs subject to SEA (i.e. the results of step 5a.) could have on landscape and ecology are assessed, from 3 (strong positive impact on landscape/ecology) to -3 (strong negative impacts). Table 3 shows an example in plain typeface.

Table 3. Example of compatibility analysis in step 5 of the proposed SEA guidelines for the Czech Republic

Proposed PPP sub-components

Other PPPs subject to SEA

energy

transport

agriculture

waste management

mineral extraction and processing

recreation and tourism

A1

2

1

1

-1

A2

-3

-2

...

A3

...

   3 sub-component strongly supports the development of the other activity
  0 indifferent relationship
  -3 sub-component strongly limits the development of the other activity
   3 relationship between sub-components and other activity has strong positive impacts on landscape and ecology
  0 relationship has unimportant impacts on landscape and ecology
  -3 relationship has strong negative impacts on landscape and ecology

These guidelines have not yet (as of early 1997) been approved by the Ministry of Environment, possibly because they seem quite complicated. Specific guidelines do exist for landscape assessment in territorial planning, but for the most part SEA in the Czech Republic is carried out in a manner similar to project environmental impact assessment.

2.2 Hungary (Mondok, pers. comm.)

Act No. LIII. of 1995 on the General Rules of the Protection of the Environment ("Environmental Protection Act") provides the basis for SEA in Hungary. Article 43 of the act clarifies which PPPs require SEA:

"(1) The proponent of an act or other proposed regulation related to environmental protection, national socio-economic plans, or decisions with regional impact is required to investigate and assess the measure's impacts on the environment and summarise these in an investigation analysis.

(2) When employing paragraph (1) a regulation related to environmental protection is an act, government decree, or ministerial decree or decision which may affect the environmental media, the quality of the environment, and human health in relation with the environment.

(3) The investigation analysis should be carried out in every case where economic regulatory tools related to environmental protection (e.g. customs, taxes and other fees) are introduced or significantly modified."

Article 44 explains what the contents required from such an SEA would be:

"(1) An investigation analysis shall include the following:

a) to what extent the proposed measures may affect or improve the state of the environment
b) what damage would be caused to the environment or the population if the proposed measures are not introduced
c) the extent to which Hungarian conditions are suited for the introduction of the proposed measures
d) the extent to which administrational organisations are prepared to execute the proposed measures
e) whether the state, financial, organisational and procedural conditions are readily available to execute the proposed measures
f) the extent to which the proposal differs from internationally accepted solutions.

(2) Proposals defined in 43(1) and the investigation analysis should be sent to the National Environmental Council and the Council's opinion should be sought prior to the submission to the decision-making organisation. From delivery, thirty days should be provided for giving this opinion."

The act does not propose a methodology for how SEAs should be carried out, nor does it explain how the SEA results should be used in decision-making. At least one SEA has been carried out in Hungary; this is discussed further in Section 3.1.

2.3 Poland (Rzeszot, 1996; Rzeszot, pers. comm.; Woloszyn, pers. comm.)

In Poland, SEA is primarily carried out for local land use plans, but some unofficial SEAs have also been prepared for national-level sectoral PPPs. SEAs for land use plans are required as a result of the Land Use Management Act of 1994, which requires a forecast (or "prognosis") of the plan's environmental consequences. The act was implemented in 1995 by an executive order of the Minister of Environmental Protection, Natural Resources and Forestry, which lists the contents expected of such an SEA: it should evaluate and assess the environmental consequences of the proposed action, consider previous land uses, describe the baseline environment (including total environmental capacity), consider the maintenance of biodiversity and the potential environmental effects of the proposed activity, and propose alternatives if the proposed activity is unsatisfactory. Requirements for the SEA report's presentation are also listed.

The executive order does not specify the form that such a forecast should take, nor does it recommend methodologies. However, a range of (not formally agreed) methodological guidelines have been published, which have been to a large extent inspired by the British guidelines on development plan appraisal. They suggest that the SEA results should be summarised in a matrix form as shown at Table 4, and also include provisions for public consultation. Unfortunately, local authorities are given no direction regarding when an SEA is needed, so even minor modifications to plans have been subject to SEA: to date, several dozen SEAs have been carried out for new plans and plan modifications. The average length of these SEAs is about 10 pages.

No official SEAs have yet been completed for national-level sectoral PPPs. However, a draft regulation has been prepared which would require environmental forecasts to be prepared for all government actions and decisions for a range of sectors (e.g. industry, forestry, water, transport). In the meanwhile, several sectoral SEAs have been prepared since 1993: for the national motorway network (by the National Fund for Environmental Protection and PHARE), the management of Poland's "Green Lungs", and the ownership transformation of the industry, agriculture, and energy sectors (all by the Institute of Sustainable Development). The latter are particularly interesting because they are, to the author's knowledge, the world's first SEAs for privatisation. The SEA for ownership transformation of agriculture is discussed further at Section 3.2.

2.4 Slovak Republic (Belcaková, 1996; Belcaková, pers. comm.; Kozová, pers. comm.)

Like in the Czech Republic, in the Slovak Republic SEA was originally required by the Czechoslovak Federal Act No. 17 of 1992. This was superseded by the National Council of the Slovak Republic Act No. 127/1994, which states that:

"A proposal for

a) a basic development project, especially in the area of energy supply, mining, industry, transport, agriculture, forestry and water management, waste management and tourism,

b) regional planning documentation for the entire territory and the residential settlement of selected places, especially the centre of a region, urban conservation areas, spas and particularly polluted localities must contain an evaluation from the point of view of its presumed impacts on the environment and, if necessary, also a proposal for measures to eliminate or reduce the adverse impacts." (para. 35)

Paragraph 35 also requires the competent authority to discuss the SEA findings with the Ministry of Environment, and to notify the public about the policy at least 2 months before it is discussed with the Ministry.

The act will be implemented and elaborated through three sets of regulations and associated guidelines: for land use plans, sectoral PPPs, and legislation. Draft regulations and guidelines for land use plans and sectoral PPPs were completed in December 1996 and are expected to be approved in late 1997. The draft guidelines are structured as follows:

1. Initial provisions

2. SEA of policies, plans and programmes

3. SEA of land use plans

4. SEA of legislation (for all Acts which would be approved by the National Council of the Slovak Republic that may have an adverse environmental impact)

5. Final provisions

Annexes:

1. Requirements of development policies regarding their presumed environmental impacts and, if necessary, a proposal for mitigation measures

2. Public information requirements regarding preparation of a development policy

3. List of particularly polluted localities

4. Requirements of regional/territorial planning documents regarding their presumed environmental impacts and, if necessary, a proposal for mitigation measures

5. General principles of sustainable development for development policies, regional/territorial planning documents and generally binding legal directions

6. General criteria and indicators of sustainable development for development policies and generally binding legal directions

7. General criteria and indicators of sustainable development for regional/territorial planning documents.

The guidelines are quite specific, with details on procedural steps and how to prepare the SEA documentation.

Examples of SEAs carried out in the Slovak Republic to date include SEAs for a national territorial development plan, a national water management policy, a regional drinking water policy for Eastern Slovakia, and the actualization of a national energy policy, as well as several informal SEAs for land use plans. The SEA for the drinking water policy for Eastern Slovakia is discussed at Section 3.3.

3. Case studies

This section considers one case study each from Hungary, Poland, and the Slovak Republic. An effort was made to choose diverse examples, and also examples at the national and policy level, since few such SEAs exist in other countries. The case studies aim to show some of the SEA techniques used, their effectiveness, and their influence on decision-making.

3.1 Extension of Hungary's express motorway network (Mondok, 1996; Mondok, pers. comm.)

Hungary's existing express motorway network, which was built in the 1960s, consist of four motorways, each 80-130 km long, extending radially from the capital of Budapest. Traffic on the network is increasing rapidly, due in part to the Balkan war which has displaced traffic from the former Yugoslavia into Hungary. As a result, Budapest is subject to severe traffic problems which are expected to grow in the future. The extension of the motorway network -- by lengthening the existing roads towards the border and through circular links between the radials -- was the focus of this SEA.

The idea of carrying out an SEA for the motorway network first arose in 1993 when UVATERV (a planning and scientific institute affiliated with the Ministry of Transport, Water Management and Telecommunications: U stands for "road", VA for "railway", and TERV for "planning") asked the opinion of ÖKO (an environmental consultancy) regarding a proposal to extend the four motorways. Early discussions raised several issues: Was expansion of the network justified by traffic forecasts? Should expansion be radial, circular or both? Should the regions crossed by new motorways be further developed or not? Were there conflicts between regional and national interests? The resulting SEA was carried out by ÖKO in the absence of any regulatory requirements or methodological guidance.

The 150-page SEA report begins with a discussion of the historical development of motorways in Hungary and the importance of motorways in national and international transport. The SEA notes that improvements to the centralised road networks of the Central European countries are a priority because of future transport pressures from Western countries: Westerners want to go to capital cities first. The report notes that road transport is more expensive, more dangerous, less economic and more polluting than public transport, but recognises that it cannot be banned. The aims of a motorway network are thus identified as meeting international expectations for long-distance freight transport, providing good national connections, and minimising the disturbance, pollution, and cost of construction and maintenance.

The SEA then compares four alternatives:

1. building a ring road around Budapest and extending the existing four radials from Budapest to the Hungarian border

2. 1. above plus an "outer" circular route linking three of the radials near the southern edge of Hungary (the government's preferred option, proposed in 1991)

3. extending two of the radials to the border, partial extension of the other two radials, and an "inner" circular route linking all four radials nearer Budapest (a hypothetical alternative which aimed to minimise the length of new motorway)

4. no action.

The alternatives are compared according to the following assessment criteria:

- How much new motorway would need to be built?

- Is the construction of all sections justified by traffic forecasts, or can traffic flows be improved by upgrading the existing road network?

- Does the alternative avoid Budapest? If so, to what extent, in order not to worsen traffic-related problems there?

- How well does the alternative connect other cities?

- What consequences will new routes have on the development of regions that they cross? Is it desirable or not?

- What are the advantages and drawbacks of the alternatives at the local, regional and national levels?

The SEA then considers transport demands and how the railway could help to meet these. It reviews how future freight and international traffic could be shifted to rail, as well as considering the capacity of the existing road network. The existing road network (alternative 4) is then compared to the preferred government alternative (alternative 2) in terms of environmental costs and benefits, both for construction and operation. This involves the use of checklists and an "impact process flow chart" which shows the causes of direct and indirect impacts, as well as how these impacts are related. Finally, the SEA includes requirements which subsequent project-level environmental impact assessments should fulfil as a form of "tiering".

The SEA took 2-3 months to complete. Unfortunately, it had no discernable impact on the decision-making process, and the ring road is being built around Budapest despite its environmental impacts and the fact that it is not expected to alleviate traffic within the city.

3.2 Ownership transformation of Poland's agricultural sector (Karaczun and Grzeszkiewicz, 1996)

In October 1991, Poland's Parliament passed an act on the management of agricultural property belonging to the State Treasury. The radical changes in Poland's social and economic climate triggered by the collapse of the Communist regime in 1989 had led to the withdrawal of plans and guidelines for Poland's state-owned farms and their subsequent rapid economic deterioration: by the second half of 1991, 70% of State farms had lost their credit-worthiness. The act charged the State Treasury Agricultural Property Authority with the task of taking over 1666 defunct state farms and 4.5 million hectares of land (13% of Poland's land area, 22% of its farmland), restructuring them, and privatising them through sale or lease. By the end of 1994, when the SEA was being carried out, 3% of the land had been sold and 45% leased; by the end of 1995, it was expected that 80-90% would have been disposed of. The SEA, which was carried out by the Institute for Sustainable Development, was thus able to make recommendations based on early experiences with the restructuring process. The SEA was carried out independently from the authority, and did not involve any public participation.

Part I of the SEA reviews, primarily in a descriptive form, the role of agriculture in the natural environment, focusing particularly on the impacts of state farms. These farms were characterised by their large scale, particularly high inputs of pesticides and fertilisers, and resultant problems of water pollution, erosion and loss of biological diversity. The SEA maps the general location of these farms against the proposed national ecological network, underground water basins and protected catchment areas, and concludes that correct environmental management of the formerly state-owned land will be of crucial importance for the achievement of national environmental policy priorities. Essentially this first part is a form of scoping and description of the baseline environment. Part II of the SEA describes the process of ownership transformation to 1995.

Part III appraises the past and likely future impacts of the ownership transformation, and suggests mitigation measures. It considers, in turn, the impacts of property sale and lease, financial liabilities, environmental protection regulations, fish farms, protected areas, and forests. For each subject, it considers the impacts of the actions of 1992-1995, and recommends future changes to the transformation process. For instance, the report notes that sale of property takes place primarily through verbal auctions: "From (an) environmental point of view, this is a very unfavourable form of deciding upon the choice of property buyer, because the only criterion for selection is the financial one... It is necessary to introduce a tender of offers -- replacing an auction -- as the basic form of selection of buyers... It is necessary to impose an obligation... to accompany the submitted offers with information concerning the forecast environmental impact of the planned activity".

The 80-page SEA report did not directly affect decision-making, since the proponents did not request it and it was not legally required. Some policy changes did occur, primarily as a result of the extensive dissemination of the SEA results -- for instance, a copy was sent to every member of Parliament -- and subsequent lobbying efforts.

3.3 Regional drinking water policy for Eastern Slovakia (Kozová and Spácilová, 1995; Kozová et al., 1996)

The SEA for the regional drinking water policy for Eastern Slovakia was part of a three-tier planning and SEA process: a national water management policy with a partial SEA set the context for the SEA for the drinking water policy for Eastern Slovakia, which in turn led to environmental impact assessments (EIAs) for projects to implement the regional policy. Here all three tiers are briefly described to show the linkages between them, with a particular focus on the middle tier.

The first, national-level tier of SEA took place in 1994. In parallel with the Ministry of Economy's preparation of a national water managemetn policy (the "governmental" policy), non-government organisations (the Slovak Network and the Slovak Association for Sustainable Living) devised an alternative, more environmentally-friendly policy entitled "Water for the Third Millennium". The Ministry of Environment asked 15 external experts to review the environmental impacts of both of these policies in a form of partial SEA, and reviewed the results with the competent authority. As a result, a public discussion of the national water management policy was organised, where ministry officials met with external experts and members of non-government organisations to discuss the advantages and limitations of both policy proposals.

Subsequently, the Ministry of Environment determined the scope of the EIA for alternatives for supplying drinking water to the Presov and Kosice areas to 2015, and as part of this required the proponent to work out alternative regional drinking water supply policies for Eastern Slovakia. The second tier of SEA was thus an introductory part of the third, project-level tier. In August 1994, two variants for the regional policy were proposed:

- The first alternative, based on the "governmental" national water management policy, would increase the percentage of the region's population served by drinking water from 72.4% in 1994 to 87% in 2015, by building new reservoirs.

- The second alternative, based on "Water for the Third Millennium", would increase the percentage of population served by drinking water to 90% without any new reservoirs.

The alternatives were reviewed by representatives from local government bodies, professional organisations, universities and non-governmental organisations in autumn 1994.

The SEA for the regional policy was carried out between December 1994 and June 1995. It began with basic principles, criteria and indicators for the SEA. The goals of the regional policy were discussed, as well as the present status of drinking water supply in the area and conflict situations. The two alternatives and a "no action" alternative were then compared, primarily in a descriptive manner, based on how well they achieved the policy objectives and their impacts on, for instance, nature protection, environmental policy goals, and socio-economics. Risks and uncertainties were discussed for both variants: these included demographic development, conflicts between economic and ecological interests, assumed climatic changes, and uncertainty regarding the implementation of waterworks and canalization. The SEA recommended mitigation measures such as the need to decrease water consumption, improve the application of ecological measures in the catchment area, and determine ecological limits for each water resource. It also made other recommendations, including the need to analyse the use of groundwater and elaborate a programme to minimise groundwater use, and the need to improve environmental education and public participation. A non-technical summary of the SEA was also prepared.

In the third tier, between June and December 1995, a project-level EIA was prepared based on the regional-level SEA. This considered four alternatives: changing the functions of the existing Vel'ka Domasa reservoir from water retention to provision of drinking water, and three proposals for new reservoirs in the upper Torysa catchment area. This EIA and the SEA for the region were then submitted to the Ministry of Environment. In early 1996, public hearings were held in all the affected municipalities which, inter alia, considered the results of the SEA and EIA, and in mid-1996 the SEA and EIA were formally reviewed by qualified experts. Finally, in November 1996, the Ministry of Environment prepared a final statement on the basis of the assessment documents, expert review, public hearings, and statements of the affected local and regional authorities, non-governmental organisations and general public. The final statement recommended that, on environmental grounds, the best solution would be the "no action" alternative: the construction of a new reservoir was deemed to not be so urgent and a more environmentally sound way of achieving the drinking water supply policy was felt to be possible.

4. Issues regarding SEA in Central Europe

As the previous sections indicated, this is a period of enormous change in Central Europe, with major new infrastructure projects being developed, widespread privatisation of formerly nationalised sectors and industries, and the establishment of new administrative structures. The Central European countries are trying to implement these changes without (all of) the related environmental costs that the Western countries have suffered. Government departments for environmental protection have been established, SEA requirements are in place, SEA guidelines are being developed, and SEAs are being carried out for some of the wide-ranging physical, social and economic changes. This section aims to summarise some of the unique characteristics of these SEA systems, in broadly the chronological order of the SEA process, and discuss their relevance for other countries.

Clearly, the number and type of SEAs carried out in Central European countries is linked to the underlying regulatory system. For instance, Poland has a well-established system of national, Voivodship (regional) and local land use plans, a relatively detailed executive order which requires SEA for these, and guidelines for how to do it. As such, a large number of SEAs for land use plans have been carried out in Poland in recent years, which in turn engenders a fertile climate for the application of SEA to other PPPs. In contrast, SEA requirements in Hungary are much less precise, and only one SEA has been carried out there to date separately from the decision-making process. This situation is reminiscent of that in the United Kingdom, where few "environmental appraisals" were carried out until clear methodological guidelines were developed in 1993, despite previous formal government backing for such appraisals in early 1992. As the Central European countries' SEA acts are further elaborated through regulations, executive orders and guidelines, the number and quality of SEAs are likely to improve.

The types of PPPs for which SEAs have been carried out in Central European countries differs from those in most other countries with established SEA systems. Of particular interest are the SEAs for policies, national-scale PPPs, and privatisation, which have been carried out only on a limited basis elsewhere to date. Also interesting is the application of SEA to sectors for which few SEA examples exist in other countries, for instance for industry and agriculture. The Polish case study shows that even such a complex process as privatisation -- notoriously difficult to describe, much less appraise -- can be subject to SEA, with very useful results. The situation in Central Europe is in particularly stark contrast to the European Commission's lengthy and detailed negotiations regarding a limited range of land use plans and programmes.

One of the major problems cited by SEA experts from Central European countries is the lack of relevant baseline information. Although SEAs -- especially those that compare alternative PPPs -- can be carried out with little environmental information, it is impossible to set environmental targets, limits or carrying capacities without such data, nor is it possible to identify particularly problematic issues (e.g. whether the PPP will exacerbate the loss of an already scarce habitat type). The lack of baseline data has also been highlighted as a problem in other countries: for instance, the SEA for the trans-European rail network (CEC, 1993) noted that it was not possible to quantify impacts on agriculture, landscape or sensitive sites due to lack of data. Despite sporadic environmental monitoring, this is likely to continue to be a problem in the future in many countries, not just in Central Europe.

The SEAs and SEA guidelines discussed here use a range of techniques for impact identification, prediction and evaluation, for instance:

- overlay maps

- matrices of PPP actions v. their environmental impacts

- matrices of PPP actions v. mitigation measures

- matrices which show the compatibility of the PPP actions v. other PPPs

- subjective appraisals of impact significance

Generally the techniques used are non-quantitative, in keeping with the relative lack of baseline data and the more strategic nature of the PPPs appraised: as such, they resemble the British system of "environmental appraisal" more than, say, the more detailed and quantitative model of SEA used in the United States. However, the issue of appropriate methodology is still very topical in the Central European countries, as is shown by the number of methodological SEA guidelines currently being developed.

The Central European countries' consistent focus on analysing alternative PPPs is particularly commendable, since only such a comparison can ensure that an optimal PPP is selected. This is in stark contrast to the European Commission's draft Directive on SEA, which would require only alternatives which have already been considered during the preparation of the plan/programme to be discussed in the SEA, not a mandatory appraisal of alternatives.

With the notable exception of the Slovak Republic, consultation of the public as part of SEA in Central European countries is still very limited. This is likely to be a function both of the large scale and high level of some of the strategic actions being appraised, and also of the relative unfamiliarity with public participation processes in formerly Communist countries. Clearly the latter situation will change with time. On the other hand, most other countries with SEA systems also have problems grappling with how (and whether) to foster public participation in policy decision-making: for instance the draft EC Directive leaves public participation procedures up to individual Member States.

More worryingly, SEAs in Central European countries seem to be having at best a minimal effect on decision-making, at a time where crucial decisions about future directions for development are being made. In Poland, for instance, the SEAs for privatisation are being carried out independently from decisions regarding the privatisations, and in Hungary the SEA for the motorway network seems to have been ignored by decision-makers (arguably this is not very different from the situation in most other countries; see Therivel and Partidario, 1996). A major factor in this is the enormous economic pressure under which the Central European countries operate, which means that environmental measures are seen as unnecessary and costly add-ons. As government agencies become more familiar with the concept of early integration of environmental issues in decision-making, this situation is likely to change. However it is probably the major limitation to SEA at the moment.

All of the Central European SEA experts whom the author has spoken to have been quick to point out problems in their SEA systems and their own perceived lack of expertise. However the Central European countries have two major advantages which are not shared by other countries with developing SEA systems. First, their administrative structures have been, and to an extent still are, in a state of rapid change, with a consequent open-minded acceptance of innovative ideas. Many government environmental departments are staffed by young and energetic staff who are willing to try out such ideas in practice. This is in contrast to the more established and rigid (or more experienced and wise, depending on one's point of view) bureaucracies of other countries. Second, SEAs in Central European countries are carried out by a small number of very active, dedicated, and knowledgeable researchers who are willing to experiment with new techniques and to actively push for the adoption of SEA, often in the absence of any additional funding for these activities. In these respects, other countries have much to learn from Central Europe.

The author is very grateful to the Austrian Academy of Sciences (Institut für Technologiefolgen-Abschätzung) CAG Consultants, and Oxford Brookes University for their support; to Rudolf Verheyen and Katia Nagels of the University of Antwerp for allowing access to the NATO/CCMS conference documentation; to the researchers whose work she has cited; and particularly to Zdenek Lipsky (Czech Institute of Applied Ecology, University of Prague), Urszula A. Rzeszot (Institute of Environmental Protection, Warsaw), Mária Kozová (Comenius University, Bratislava), and Zsuzsa Mondok and Dr. Endre Tombácz (ÖKO Inc., Budapest) for their very helpful review of this article. Any errors are solely attributable to the author.

Notes

1. The Proposal for a Council Directive on the assessment of the effects of certain plans and programmes on the environment of 4 December 1996 would apply to land use plans and programmes which affect the nature and location of projects.

2. 20-24 September 1995 in Lanaken, 18-20 April 1996 in Terceira, and 6-10 November 1996 in Warsaw. The results of the first two workshops are published by Verheyen and Nagels (1996).

3. The authority responsible for deciding on the policy, plan or programme

References

I Belcáková (1996) "Strategic environmental assessment and spatial planning in Slovakia", in Verheyen and Nagels (1996), pp. 68-71.

Commission of the European Communities (1993) The Trans-European Rail Network, Environmental Impact Assessment, summary report, Directorate-General VII, Brussels.

J Dusik (1995) "Czech Republic", in International Roundtable on Practical Implementation of EIA in Central and Eastern Europe, 8-10 November, Bratislava, Ministry for Environment of the Slovak Republic et al., pp. 27-36.

Y M Karaczun and R Grzeszkiewicz (1996) Ownership transformations in agriculture vs environmental protection, Institute for Sustainable Development, Warsaw.

I Kasparová, M Frieb, Z Lipsky, M Martis and E Nováková (1996) "A proposal of methodological guidelines for strategic environmental assessment (environmental impact assessment of conceptions)", in Verheyen and Nagels (1996), pp. 144-152.

M Kozová and R Spácilová (1995) "Strategic environmental assessment (SEA) and a proposal for its application in the environmental assessment of the drinking water policy for the East-Slovakian region", Acta Environmentalica Universitatis Comenianae 4-5, pp. 187-192.

Kozová, M., I. Belcáková and M. Finka (1996) "Strategic environmental assessment experience in the Slovak Republic", in Verheyen and Nagels, pp. 43-55.

Z Lipsky (1996) "Strategic environmental assessment in the Czech legislature: uncertainties when to use EIA procedure", in Verheyen and Nagels (1996), pp. 34-37.

Z Mondok (1996) "Case study for Hungary", in Verheyen and Nagels (1996), pp. 177-179.

U Rzeszot (1996) "SEA in Poland - tradition, legislation and case study", in Verheyen and Nagels (1996), pp. 62-67.

R Therivel and M Rosário Partidário, eds. (1996) The practice of strategic environmental assessment, Earthscan, London.

R Verheyen and K Nagels (1996) Methodology, focalisation, evaluation and scope of environmental impact assessment, Fourth report: Strategic environmental assessment: theory versus practice, Report No. 212, University of Antwerp.

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