6. MORE EFFICIENT RESOURCING
JOINING UP SEAs
Key point: Link your SEA with others that have already been undertaken to give a clearer view of the 'bigger picture' and minimise resource requirements. 6.1 The 2005 Act extends across most public sector plans, programmes and strategies that could generate significant environmental effects. The broad coverage of the legislation in Scotland provides an opportunity to better link SEAs and thus reduce potential duplication. As SEA practice develops and experience grows, this should provide significant opportunities for streamlining. Greater integration may be horizontal or vertical. Within the SEA of development plans, screening plans out in their entirety is unlikely to be a valid option, but hierarchical awareness could allow for:
- transferring information, such as relevant baseline, between assessments.
- scoping specific issues out on the grounds that they have been adequately covered in the SEA of another plan at the same level or in a higher-tier plan or policy document;
- scoping some issues out on the grounds that they can be more meaningfully assessed in the SEA of a lower-tier plan, programme or strategy;
- being clear about the limitations of the assessment for higher-level plans. Whilst problems should not be simply passed from higher to lower-level plans, it is important that SDP SEAs in particular do not over-anticipate LDPs and their SEAs by embarking on a detailed assessment which is dependent on numerous assumptions;
- as mentioned previously, positioning the assessment of supplementary guidance within the broader SEA of the plan can minimise duplication of efforts. This could streamline the SEA by reducing the need for supplementary assessments at a later stage.
6.2 The National Planning Framework ( NPF2) sets out Scottish Ministers' strategic development priorities. Its SEA provides a useful starting point for those who are undertaking SEAs of SDPs and LDPs. Proposals for further assessment, mitigation and monitoring have been built into the NPF Action Programme.
6.3 Where a development plan is taking forward a National Development, it is important to recognise that the NPF2 SEA has already tested the environmental effects of the development in principle, from a national perspective. However, there remains scope for further consideration of more detailed alternatives (e.g. siting, design, layout, construction or operational specifications) at the development plan level as the proposals are taken forward and project specifications become more clearly defined.
SEA AND OTHER ASSESSMENTS
Key point: It is not realistic to expect SEA and HRA to be fully integrated. 6.4 It is possible, and may seem beneficial, to integrate SEA with an appropriate assessment conforming with regulation 85B of the Habitats Regulations, 8 but this can be difficult to achieve and may cause confusion. It is important that planning authorities continue to differentiate between the requirements of, and outcomes from, the two processes and reflect this in relevant reports. However, some of the data gathered to inform the assessments might be combined or integrated, and there may be a requirement to consider further alternatives in both processes.
SEA, MASTERPLANS AND EIA
6.5 The transition from SEA to Environmental Impact Assessment ( EIA) takes place as plans move forward to become site-specific projects. In general, masterplans that form supplementary guidance or are adopted in some way by a public authority may require a SEA, whilst those that are simply developed by the private sector to accompany planning applications may be subject only to EIA. Experience indicates that, if the masterplan covers something greater than a single application, for example a framework for multiple consents by different developers which is to be adopted by a planning authority, a SEA is more likely to be triggered.
Key point: A robust LDP SEA could help to streamline subsequent EIAs. 6.6 There is an opportunity for SEA to strengthen and streamline subsequent EIAs by identifying potential effects early in the process. SEAs can be used to address strategic issues such as the location of developments, before they progress to the project level and are assessed in more detail within an EIA.
MINIMISING DEMANDS ON RESOURCES
6.7 The resource requirements associated with SEA should not be underestimated, but can be substantially reduced by taking forward many of the measures identified in this advice. The recommendations on proportionality and integration should help to make better use of existing resources and ensure that duplication of efforts is avoided.
6.8 SEA can also incur direct costs, including as a result of its statutory advertising requirements. To minimise these costs within the consultation process, it is possible for planning authorities to amalgamate statutory notices relating to the plan and the SEA, providing the requirements of the 2005 Act are met.
WHO SHOULD UNDERTAKE THE SEA?
6.9 It is acceptable, and in many cases preferable, that those who are responsible for preparing a development plan also undertake its SEA. Many of the skills required to prepare a development plan are also relevant to SEA. Therefore, where resources allow, planning authorities should aim to carry out SEA in-house.
6.10 However, in some instances there are advantages in involving external support in the SEA process: to gain a fresh perspective on the plan's content or ensure that the assessment is a rigorous test that does not take any policy assumptions for granted. Such third parties may be officers working in other parts of a local authority or a neighbouring authority, or could be consultants.
6.11 Where consultants are involved, it is likely that planning authorities would benefit from more focused inputs that make use of specialist expertise, as opposed to contracting out the SEA as a whole. This might take the form of training and capacity building, assistance with preparatory information gathering, or undertaking an informal review or a more formal independent verification of an in-house SEA.
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