Environmental assessments of strategic decisions and project decisions: interactions and benefits

Impact Assessment and Project Appraisal, volume 18, number 2, June 2000, pages151–160, Beech Tree Publishing, 10 Watford Close, Guildford, Surrey GU1 2EP, UK.

Tiered decision-making

Environmental assessments of strategic

decisions and project decisions: interactions

and benefits

Sibout Nooteboom

Application of environmental assessment at thelevel of policies, plans and programmes (PPPs)is generally referred to as strategic environ-mental assessment (SEA). SEA has many inter-actions with the environmental assessment offollow-up decisions, whether these are still atstrategic level (SEA), or at project level (EIA).An analysis of cases in the European Union oftiered decision-making and environmental as-sessment, has shown that these interactions canbe beneficial. Hypotheses and facts from the lit-erature are sustained by these cases, and can beelaborated further. It is argued that applicationof SEA can help to improve the decision-makingsystem.

Keywords: environmental impact assessment; decision-making; strategic environmental assessment

Sibout Nooteboom is environmental policy consultant at DHVEnvironment and Infrastructure BV, PO Box 1076, 3800 BBAmersfoort, The Netherlands; Tel: +31 33 468 2707; Fax: +31 33468 2801; E-mail: [email protected]

The author acknowledges Jan Jaap de Boer of Ministry ofVROM for critically reviewing and editing the original report.

ADIRECTIVE ON ENVIRONMENTAL im-

pact assessment (EIA) has existed in theEuropean Union (EU) since 1985 (European

Commission, 1997a). Recently, the European Com-mission has put forward a proposal for a Directive onthe assessment of the effects on the environment ofcertain plans and programmes (EuropeanCommission, 1997b), the so-called SEA Directive.To support discussions about the proposal, a studywas undertaken, resulting in a report entitled “Environ-mental assessments of strategic decisions and projectdecisions: interactions and benefits” (Nooteboom,1999).1 This paper summarises some of the results ofthis study.

The study aimed at analysing the relationshipbetween strategic environmental assessment (SEA) atthe level of policies, plans and programmes, and envi-ronmental impact assessment (EIA) for projects. It isbased on an analysis of the literature and practicalcases of tiered SEA and EIA, interviews with expertswho had been involved in the cases, and on the resultsof a workshop with the participation of a group ofEuropean experts. The cases in the study are listed inBox 1.2

The reviewed existing literature (Lee and Hughes,1995; Sadler and Verheem, 1996; Thérivel andRosário Partidário, 1996; Mens and Ruimte Consul-tants, 1997; Land Use Consultants, 1996) mostlydeals with the links between sequential environmentalassessments in a theoretical way. Although only asmall number, these are the main sources which makeoverviews of SEA theory and practice in Europe. Themechanisms of these interactions in practice are rarely

Impact Assessment and Project Appraisal June 2000 1511461-5517/00/020151-10 US$08.00 © IAIA 2000

analysed in detail. The present study tries to make upfor this gap, confirming the theoretical relationships.

Main conclusions, in line with the existing litera-ture, are that SEA:

� does not replace EIA, but addresses certain impacts(for instance, large scale, cumulative, and synergis-tic effects) and ‘strategic’ alternatives moreeffectively;

� refines the scope of assessments at lower tiers;� often reduces the time and cost of the assessment at

the lower tier;� has its strongest benefits under a number of condi-

tions mainly relating to the system of decision-making;

� can be applied to PPPs (policies, plans orprogramme) which do have environmental reper-cussions, but which are not followed by projectEIAs.

Whereas the original study report analyses all theserelationships in detail, this paper focuses on some ofthe relationships which are not fully developed or il-lustrated with cases in the studied background litera-ture, and where more elaborated ideas emerge. Mostrelationships are demonstrated in the report by a fairnumber of cases from practice. In this paper, a sel-ection of these cases is presented. It starts withdefinitions of terms.

Definitions

Terminology differs between countries. For practicalreasons therefore, the following definitions were ap-plied in this study, some of which are not generallyestablished in the countries from which case studieswere taken.

Tiers of decision-making

When a policy, plan or programme precedes and in-fluences a project decision, the PPP and the projectdecision are supposed to be tiered. Decision-making

may occur in several tiers, each of which may, or maynot, be connected with an environmental assessment(an SEA or an EIA). Tiering may, or may not, have aformal linkage. (Most of the available cases concernstrongly and formally tiered decisions.) The decisionwhich is made chronologically first, is the first tier andthe other is the second tier. A decision which is more‘strategic’ than the other decision, is the ‘higher tier’,and the other decision is the ‘lower tier’. Two environ-mental assessments are tiered to each other if they arelinked to tiered decisions (see Figure 1).

Distinction between SEA and EIA

In this study, a broad definition of SEA is applied, toinclude as many situations as possible. An assessmentis considered to be an SEA if it applies EIA principlesto a PPP. Undertaking an SEA can be either a manda-tory requirement, or voluntary. It may follow a formalor an ad hoc procedure.

Also SEAs have been investigated which are notdirectly connected with a formal PPP, or which formpart of a more general assessment, including, for ex-ample, social impacts. EIA, according to the EIA Di-rective, is in some countries applied to PPP, which arein many cases followed by more detailed decisions.To use consistent terminology, the application of EIAprinciples to PPPs is in the present study considered tobe an SEA.

Strategic decisions, alternatives and impacts

If decision-making about a particular project or activ-ity takes place in several tiers, an earlier tier is, bydefinition, more strategic than a later tier. The earliertiers consider alternatives which are more strategicthan those considered at a later tier. The environment-al impact that is caused by rejecting a strategicalternative (such as transport demand management in-stead of increasing infrastructure capacity) is called astrategic impact. This does not exclude the possibilitythat strategic alternatives (and impacts) can also beconsidered at project level, for instance, in the ab-sence of tiering.

152 Impact Assessment and Project Appraisal June 2000

EA of strategic decisions and project decisions

Box 1. The cases of tiered assessments analysed

1. Garzweiler open-cast lignite mining site, Germany2. Residential development in Erlangen, Germany3. Road infrastructure, France4. Nordic triangle transport corridor, Finland5. Spatial planning in Leicestershire County, United

Kingdom6. High speed rail (HSR) Zuid, the Netherlands7. Wind energy planning Zeeland, The Netherlands8. VAM bioreactor, The Netherlands9. International Business Park Friesland (IBF), The 10.

Netherlands10. Policy plan drinking water supply (BDIV), The

Netherlands11. Ministerial Order about manure storage, Denmark12. Ban on certain pesticides, Denmark13. Spatial plans, Sweden

Figure 1. A typical form of tiering: a higher, earlier tierinfluences a lower, later tier

Planning and decision-making systems

A planning and decision-making system is a form-alised system of tiered planning and decision-making,in several tiers from the most strategic level to the pro-ject level. Decision-making is done by a competentbody; planning is the preparation of proposals ofplans.

Elements in the EIA and SEA process

The EIA and SEA process may be shaped in differentways, but at least the following assessment steps areconsidered to be universally applied (either legally orin practice):

� screening, to determine whether a project decisionor a PPP requires an EIA or an SEA;

� scoping, to determine the impacts and alternativesto be considered;

� preparation of an environmental statement (an EIAreport or an SEA report).

A leading principle of any SEA or EIA process is theintegration of its findings into the planning and deci-sion-making process, making use of the results ofinter-agency consultations and public participation.

Refining scope of assessments at lower tiers

In several of the cases studied, strategic tiers have re-fined or reduced the scope of the environmentalassessment at the lower tier (the impacts and alterna-tives that were considered). This is to say, it was easierto identify the issues that the lower tier shouldconsider, and the lower tier could be more focused onthe impacts that really can be influenced by decision-making at that level. There are three mechanisms forthis benefit to occur:

� SEAs can influence the PPP to which they arelinked. The PPP, by rejecting certain strategic al-ternatives, influences the remaining alternativesthat can be taken into consideration for decision-making at the lower tier. The project EIA considersonly the impacts of the remaining alternatives,since the impacts of the strategic alternatives havealready been considered in the prior SEA. This canbe called a ‘funnelling effect’.

� SEAs can be used to develop an environmentalplanning framework, against which the effects ofdecisions at lower tiers could be identified, moni-tored and evaluated. The environmental conditionsfor further elaboration of the project are in this situ-ation given.

� The most common mechanism is that the SEA sim-ply provides useful information and experiencethat gives the lower tier a ‘head start’ compared tothe situation without an SEA (information trans-fer). However, the SEA does not reduce theimpacts to be considered at the lower tier level.

The first and second mechanism can only occur if theSEA is linked to a PPP; these two mechanisms arenow developed.

Funnelling effect

The funnelling effect occurs, for example, in the fol-lowing cases:

� High speed rail Zuid, where alternatives for theRoute Decision tier could be limited to detailed de-velopment of one selected route (see also Box 2);

� the International Business Park Friesland, where aspecial site-selection tier enabled the mandatorySEA for the park to be limited to one selected site;

� the manure storage policy in Denmark, where thescope was more limited for individual manure stor-age if general requirements were satisfied (see Box3).

In theory, these PPPs may also have excluded certainstrategic impacts and alternatives for consideration atlower tiers without a preceding SEA. There are, nev-ertheless, strong indications that the SEA played a

Impact Assessment and Project Appraisal June 2000 153


A leading principle of any SEA or EIA

process is the integration of its

findings into the planning and

decision-making process, making use

of the results of inter-agency

consultations and public participation

Box 2. Refining scope in the case of high speed rail Zuid

In the case of the high speed rail Zuid in The Netherlands,energy use and noise were assessed at several levels, but ina different way:

� Energy use, a typical large-scale impact, is studied at thehighest level because it is significantly influenced by themodal choice (for instance, high speed rail versus aero-plane). Energy use is also assessed at the lowest level,because it is sensitive to the choice of constructionmethod (energy saving is part of the ‘sustainable build-ing’ initiative in the transport sector in The Netherlands).Construction materials were not assessed at the highertiers, probably because these have much less environ-mental impact than impacts and alternatives assessed atthe higher levels (such as modal choice).

� Noise nuisance, a typical local impact, is subject tonational standards, and at the time of the preparation ofthe relevant legislation the generic effectiveness of suchrules was thoroughly evaluated and discussed withstakeholder groups, before it was approved. (A form-alised SEA procedure was not used.) Noise nuisancealso played a role in assessment of the modal split (for in-stance, aircraft noise versus railway noise), and routing(number of residents and peaceful areas near the route).It was also an important consideration in routing and inthe design of mitigation measures.

crucial role: with no SEA, either the PPPs may nothave been approved, or alternatives that were rejectedin the PPP may have been assessed at lower tiers. Ei-ther way, the scope at the lower tier would not havebeen reduced. The funnelling effect is illustrated inFigure 2.

Environmental planning frameworks

Environmental frameworks for further decision-making (sometimes called environmental actionplans, environmental policies or environmentalguidance) were applied in the following cases:

� the local plan of Leicester City included environ-mental guidance for making development consentdecisions (see Box 4);

� the Zeeland wind energy plan included environ-mental guidance for decision-making aboutindividual wind energy sites;

� the Garzweiler II mining plan included environ-mental guidance for the operational plans;

� the Danish Ministerial Order of manure stor-age was in itself an environmental planningframework.

Impacts and alternatives for projects were genericallyassessed at both the SEA the EIA level; the assess-ment could be limited to a check as to whether condi-tions did not change over time, and whether theenvironmental planning framework was properlyapplied.

EIA can make the last project a victim

Many of the SEAs that were analysed, were associ-ated with PPPs that involved several projects or activ-ities. All these SEAs examined the cumulative, andwhere appropriate, synergistic impacts of theseprojects or activities. Appropriate alternatives weresought to reduce these effects. The following casesillustrate this:

� Garzweiler II mining plan, which studied thehydrogeological and ecological impact of severaloperational plans;

� Policy plan drinking water supply, which studiedthe combined effect of all water production facili-ties in the Netherlands on, for example, hydrologyand eco-systems at a national level;

� The International Business Park Friesland (IBF),where the cumulative impact of all businesses inthe park was considered;



Box 3. Ministerial Order about manure storage, Denmark

In this case the first decision-making tier was a MinisterialOrder, which specified standards for environmentally soundmanure storage systems. The purpose of the Order was tolimit the emissions from manure storages to the environ-ment, and to improve the efficiency of decision-making atproject level, by offering exemption from requirements in thescope of the EIA if general environmental rules were obeyedconcerning manure storage. The Ministerial Order had beenintegrated into a guidance document on EIA for livestockfarming. The second tier is the manure storage projects atthe level of individual livestock farms.

All relevant environmental impacts and alternatives formanure storage were generically assessed at the nationallevel. The SEA for the Ministerial Order estimated the impacton the quality of surface water, the quality of ground water,and on health and welfare of the population. All that isneeded at the project level is a verification that the manurestorage facility satisfies the general requirements.

Figure 2. SEA influence on scope of EIA

Note: Solid arrows show influence indirectly via planningdecisions; dashed arrow shows influence directly viavertical integration/co-ordination

Box 4. Spatial planning in Leicestershire County, UK

This case concerns three levels of planning: the EastMidlands region; the county of Leicestershire, situated in thisregion; and two districts in this county (the City of Leicesterand the Borough of Hinckley and Bosworth). The threeauthorities involved wanted to revise their spatial plans andso SEAs, called environmental appraisals, were prepared;they were conducted voluntarily on national guidelines.

The spatial plan at district level (the Local Plan), acts as adecision-making framework for individual project develop-ment consent decisions. At each of these three scale levelsof spatial planning, decisions were made which have envi-ronmental repercussions for the City of Leicester and theBorough of Hinckley and Bosworth. These decisions mainlyconcern where new developments should be located, andthe levels become increasingly detailed. Each level containsthe elements for future policy planning. Local Plans containguidelines for approval of development proposals, which insome cases may require an EIA.

As each level of spatial planning has to take account of thedecisions made at higher levels, these decisions were tieredfrom the highest down to the lowest level. On the other hand,the plans at the lower levels were prepared earlier than thehigher-level plans, or simultaneously. Plans are developedand revised in non-standard cycles. In this case, the lowerlevels happened to be first (earlier in time). Basically, consis-tency between all levels was sought.

Within each of these planning and assessment pro-cesses, strategic objectives including sustainability ones,were defined. These were elaborated into concrete propos-als, which were then adapted to SEA requirements. Thestrategic objectives and the proposals were mainlyconcerned with ‘where’ questions.

� Ban on pesticides in Denmark, which examined theeffect of the ban on total impact of emission ofharmful pesticides by many actors who individu-ally needed no permit or EIA;

� SEAs for comprehensive spatial plans were con-cerned with cumulative and synergistic impacts inparticular. Comprehensive spatial planning inLeicestershire, where consistency of differenttypes of land use is assessed. This approach auto-matically takes account of synergistic impacts ofdevelopment proposals in a certain area.

Of these, only the policy plan drinking water supplyand the IBF were followed by project EIAs. Experts inThe Netherlands expect that such cases occur morefrequently. The study of these cumulative and syner-gistic impacts at the project EIA level is less useful. Ifno SEA is made, and cumulative impacts are thereforeconsidered at project level, a project will be admittedif its individual impact does not cause the cumulativetotal impact of it, and all preceding projects, to exceedallowable limits.

This process continues every time a new project isproposed, until the last proposed project causes thelimit to be exceeded. That project then cannot be ad-mitted, even if its contribution to the cumulative totalis small and its benefits are otherwise important. It be-comes, in a way, a ‘victim’ of the rules. In such situa-tions it can be tempting to change the rules, in otherwords, to amend the PPP that defines the rules, or toapply it in a flexible way, making the limit less strict.(Such cases, though not studied in this paper, areknown in The Netherlands.)

Both victimising the last proposed project and re-considering a PPP do not seem to be efficient. Thetotal process of decision-making may have becomemore efficient if an SEA had been undertaken at thePPP level.

Assessment of large-scale impacts

SEAs may be more effective than project EIAs at ex-amining large-scale impacts, because they are rathermore influenced by strategic alternatives than by pro-ject alternatives. Relatively important environmentaldecisions are often made in PPPs (such as ‘whether’,‘where’ and ‘what type’ of project). The undertakingof SEAs enabled the consideration of such alter-natives, which are in particular relevant for thelarge-scale impacts, at the ‘appropriate’ level. Thismechanism can be observed in the Garzweiler IIlignite mining area (see Box 5), the high speed railZuid, the International Business Park, and the windenergy plan Zeeland. These are all large projectsor groups of closely related projects (mining, trans-port infrastructure, industrial areas, and wind energyparks).

First, decisions in principle were made, althoughnot always submitted to an SEA, then a site or routewas selected, and finally, the site planning was

continued. Each of these decision levels was relevantfor different impacts. In most cases, as the types ofdecisions changed from higher tiers to lower tiers, theappropriate alternatives were selected at each assess-ment level for the specific type of decision. Theimpacts to be examined were generally selected fortheir relation to these alternatives.

There is no typical tiering order for impacts

Notwithstanding the above, it should be remembered,that also small-scale impacts can be considered atstrategic levels:

� they can be used to find the most suitable (least sen-sitive) project locations, of which there are manycases;

� they can be used to assess small-scale impacts ina generic way, identifying suitable generic ap-proaches for mitigation at project level; goodexamples are the Garzweiler mining area and theMinisterial Order about manure storage.

However, these impacts can also be assessed at theproject level. Assessing them generically at strategiclevel has the advantage that it makes project EIA eas-ier, by refining its scope, as discussed earlier.

Large-scale and local impacts both appear to be rel-evant at any level of decision-making. The distinctionbetween ‘whether’, ‘where’, ‘what type’ questions(‘strategic issues’) and ‘how’ (‘project issues’) is asimplification. ‘How’ questions are also often consid-ered in strategic decisions (which, according to thedefinition used in the present report, is any tier exceptthe last), offering frameworks for further activity de-velopment. ‘Where’ questions are often considered atproject level (but within a small area).



Box 5. Garzweiler open-cast lignite mining site, Germany

Lignite (brown coal) is used as an energy source in Ger-many. Garzweiler II is a new lignite mining area. Deci-sion-making occurred in three tiers. The first was thenational level. Decisions had to be made on the quantity ofdomestic energy needed, the energy source that would bemost appropriate, and, if lignite were chosen, which areashould be developed. No SEA was conducted formally atthis stage but environmental impacts were taken into consid-eration. Issues such as climate change and biodiversitywere studied and, as a result, the proposed boundaries ofthe selected mining area (Garzweiler II) were changed toprovide a geohydrological buffer zone.

The second tier was the mining plan for the Garzweiler IIarea, within well defined spatial boundaries. It has a surfacearea of 48.000 hectares. An environmental assessment wasprepared according to the EIA legislation. Because the min-ing plan is not the last tier of decision-making, it is referred toas an SEA, despite it being legally an EIA.

The third tier includes several operational plans for themining area, to be introduced one at a time. These do not re-quire an EIA, but they do need to meet environmental re-quirements which are laid down in the mining plan. The lastof the operational plans will probably be approved in 50years’ time.

SEA also useful without binding PPPs

The interactions described above worked because theinformation provided in the SEA was used in an asso-ciated PPP, which again influenced the lower tier (thesolid lines in Figure 2). These are therefore indirect in-teractions between assessment levels, depending onthe existence of a PPP that has an influence on furtherdecisions. However, many environmental assessmenttiers were also directly linked to each other (the dottedline in Figure 2). In these cases, assessment tiers wereeither integrated by co-ordinating their approach(‘vertical integration’), or by more spontaneous trans-fer of methods and experience. These interactions donot depend on the existence of a PPP. They have in-creased the quality and efficiency of the assessmentprocess as a whole by providing input to the EIA pro-cess at project level.

Many of these benefits could probably have beenreached within one single tier of environmental as-sessment, because any SEA or EIA can (informally)be split into phases. A successful example of thismechanism was the EIA for seven drinking water

extraction sites in Utrecht, the Netherlands(OEDI-EIA), the lower tier of the policy plan drinkingwater supply (see Box 6).

‘Grey-zones’ between SEA and EIA

The difference between project EIA and SEA (as inthe EIA Directive and the proposed SEA Directive ofthe EU) may be not as clear as it is generally thought tobe. Both use the same principles; the differences aremainly caused by the decisions to which they are ap-plied. It is generally assumed that EIAs should be un-dertaken for the last tier of decision-making aboutprojects, and consequently, if EIA principles are ap-plied to other decisions, it should be called an SEA.However, there are cases in which project develop-ment consent was given in a decision prior to the lastone needed before construction works are allowed tocommence. These prior decisions are PPPs. However,in practice, they are also the EIA level. At the last tierno further EIA was required.

Favouring condition: strong functional links betweenprojects PPPs are sometimes designated as consentdecisions, if different proposed developments arestrongly functionally interrelated and consent there-fore needed to be given to them jointly (approval of abinding plan). The plan as a whole would not be feasi-ble if one of its projects were not allowed.

An example is the Garzweiler II lignite miningplan. The EIA level was the mining plan. It provided adetailed environmental framework and monitoringrequirements to ensure that the environmental im-pacts of decisions made in individual operationalplans were insignificant. Garzweiler II is an examplewhere confusion occurred, because a PPP includedbinding consent decisions about larger units of devel-opment which could either be defined as one projectwith sub-projects, or as a number of projects. In thelatter case, it is not a consent decision for the individ-ual projects, and it can therefore legally not be the EIAlevel.

Grey zones If there is uncertainty, as in theGarzweiler case, as to whether a PPP or a lower tier isthe project consent decision, such PPPs can be said tobe in a ‘grey zone’. Another example is the PKB(spatial key decision) level of the HSR-Zuid in TheNetherlands. If a PPP is inside a ‘grey zone’, it may bepossible that the different (sub-)project proposals canbe sufficiently elaborated and associated with anenvironmental planning framework to ensure that un-acceptable environmental impacts will not occur infurther decision-making at (sub-)project level.

If this is based on an environmental assessment ap-plying EIA principles, further assessment at the lowerlevel would not be useful. The environmental plan-ning framework will do its work, and mitigate unac-ceptable or unnecessary impacts at (sub-)projectlevel. Under these circumstances, an EIA at



Box 6. Policy plan drinking water supply (BDIV), TheNetherlands

A national water supply policy was formulated in the (third)“Policy plan drinking water and industrial water supply”(BDIV). This is the highest tier of decision-making in thiscase study. The BDIV includes the following main policies:

� sustained priority for production of sufficient drinking wa-ter of good quality;

� continuation of strict requirements for drinking waterproduction;

� enforcement of quality assurance and environmentalmanagement systems and procedures during produc-tion and distribution;

� use of a number of policy instruments to curb theincrease of water demand in order to reduce the environ-mental impact of water supply activities;

� avoidance of natural areas in site selection to minimiseimpact of land use and soil dehydration;

� revision of the formal planning system for water supply(tiered system and methods for trade-off).

At the second tier, the Water Supply Company MiddenNederland (WMN) had to shift its water intake from ground-water to surface water (this was in response to a provincialtarget to reduce soil dehydration by 20% in 2000). The sevenprojects that were necessary to realise this shift were jointlysubmitted to an EIA procedure. WMN conducted the EIA(OEDI-EIA) in three phases:

1. assessment and decision with regard to the methodfor water extraction (‘how’);

2. assessment and decision with regard to the siteselection for: extraction of riverbank filtration;infiltration and extraction of surface water; andreduction of present ground water extraction(‘where’); and

3. assessment and decision with regard to the design ofchosen sites (‘how’ question).

The intermediate decisions, after stages 1 and 2, were madeinternally by the WMN. Only the result was in the form of per-mit applications and the EIA submitted to the provincialauthority for approval. External parties were consulted in allthree EIA phases.

(sub-)project level can be made unnecessary by anSEA at the level of the PPP.

Therefore, when determining whether a PPP may bethe appropriate level for EIA, it is probably more use-ful to verify the environmental planning framework,rather than trying to define the concept of ‘a project’.It should contain arrangements (in the PPP and in legis-lation) for maximum allowable impacts, implementa-tion monitoring and enforcement. This is in fact whatis done in the case of Garzweiler II and the HSR Zuid:the project consent level is designated as the level atwhich a project is definitively admitted, under suffi-cient environmental restrictions that should beformally verified at lower levels.

Conditions favouring effective SEA

The direct interactions between assessment tiers de-pend on the possibility and willingness to co-ordinatethe tiers, and to use the lessons learned in the first tier.A major factor is the time that passes between tiers. Iftoo much time elapses, many of the assumptions thatcould be made at the time of the first tier, may have be-come outdated when the second tier starts.

For example, in the case of the VAM bioreactor,national guidance on waste processing technologywas given in an SEA-based PPP. This guidance wasoutdated when the VAM proposed the bioreactortechnology. Therefore, technological assessment hadto be part of the scope at the VAM waste processingplant. The same may be true for intervening politicaldevelopments (for instance, the political weight givento certain impacts could change, or a new environ-mental policy could be adopted between tiers).

Importance of binding PPPs

If there is no decision-making system at a strategiclevel with any binding effect, there can be no funnellingeffect, nor a credible environmental planning frame-work. An SEA at that level can still be useful throughits direct effects on lower tiers, but it is not likely to re-duce scope. To do that, it often seems to be necessaryfor an SEA to be connected to a formal PPP.

For an SEA system to be effective in this way, therehas to be a strategic decision-making system suitablefor ‘hosting’ the SEAs. The legal form of PPPs (theircontents, responsibilities, competencies) should bedefined in a way that strategic alternatives which arebetter for the environment can be accommodated at alevel where they are still feasible.

There are two cases in the study for which PPPswere proposed with the only aim to accommodateSEAs. These are the Erlangen housing developmentand the International Business Park Friesland. Theseare ad hoc adjustments of decision-making systems,within the existing administrative setting. PPPs wereproposed to remove strategic impacts and alternativesformally from the scope of the lower-level environ-mental assessment.

In the case of the International Business ParkFriesland, the need for a formal PPP was only recog-nised when the lower tier EIA was under way: this hadto be suspended until the PPP was adopted. Therehave been a large number of EIAs in the Netherlands,for which strategic alternatives were considered atproject level. Including these impacts and alternativesin SEAs gave more legitimacy to the relevant PPP,and assessments need not be repeated at the EIA level.A similar mechanism is also foreseen in France.

There are also cases in which experience with SEAcontributed to a permanent re-definition of the deci-sion-making system, so that the ‘right’ impacts and al-ternatives can be considered at the ‘right’ level. TheHSR Zuid is an example. Here, the ‘whether’ questionwas explicitly linked to the ‘where’ question, sincespatial impacts are significant and should play a rolein the decision-making: ‘whether’ an HSR should berealised. Two SEAs (Nordic triangle transport corri-dor, Finland and policy plan drinking water supply,the Netherlands) contributed to a similar change in thegeneral decision-making system within the sector.

Environmental planning frameworks were in somecases formalised in a PPP, in order to be effective, forexample, the Danish environmental policy on manurestorage facilities and the ban on certain pesticides.Such binding guidance makes scoping at the lowerlevel easier, and it may set limits to the impacts thatcan be expected when the project is further elaborated.It can reject any alternatives that might cause theselimits to be exceeded, reducing the number of alterna-tives and impacts to be considered. It is doubtfulwhether these benefits could have been obtained on apurely voluntary basis (it may even be illegal).

In the case of the OEDI-EIA on drinking waterwells, the initiator took a risk by making his own strat-egy without formal adoption of a PPP, and precau-tions were needed for it to be successful. The plan wasdeveloped and assessed in three phases. The EIA wasdirectly linked, at each phase, to internal decision-making. The final phase led to a formally submittedproposal and an EIA report. The EIA report justifiedthe intermediary decisions that had been made atthe end of the first and second phases, which werestrategically related to phase three.



When determining whether a PPP is

the appropriate level for EIA, it is

more useful to verify the

environmental planning framework

than trying to define ‘a project’: it

should include maximum allowable

impacts, implementation monitoring

and enforcement

Because only the final result was presented to thedecision-makers, they could feel confronted with afait accompli and under pressure not to reject internalstrategic choices in the final proposal, because itwould cause considerable delay. Decision-makersmight have been offered an opportunity to approve theintermediary decisions one at a time (so they wouldbecome separate PPPs). Any reconsideration of inter-nal decisions would then become less likely. The initi-ator successfully reduced this risk by intensiveinter-agency and NGO (non-governmental organisa-tion) consultation in each phase of the EIA.

Discussion

The interactions described can be derived from thecases in a straightforward manner, and are endorsedby the interviewed experts, who knew the cases in de-tail. In this discussion, the background of many ofthese relationships is analysed in a more speculativemanner.

EA issues follow the decision-making tiers

In most of the cases studied, there was an existing sys-tem of tiered decision-making, to which SEAs andEIAs were added (see Figure 3). Feasible alternativesat any level depended on the decision-making system,and impacts were chosen for their ‘influenceability’by these alternatives. Other impacts were more or lessautomatically considered in assessments at other tiersof decision-making. The impacts and alternatives inenvironmental assessments follow the PPPs ratherthan the reverse.

In most of the cases, the tiering order was largelydetermined by the decision-making system. The po-tential scope of PPPs was fixed by legal requirementsand probably limited by the power and competency ofthe responsible agencies. An SEA could encouragethe assessment of extra alternatives for the PPP withwhich it is associated; alternatives relevant only tothat type of PPP. In this way, the impacts and alterna-tives to be considered at project EIA level are refinedand reduced.

Both SEA and EIA are needed

Project EIA alone is not enough to test coherence ofsectoral developments with environmental policyobjectives; for this purpose SEA is needed next toEIA. At project level, it is difficult to assess thesignificance of a small contribution to a largeenvironmental problem. Instead, environmentalsustainability objectives should probably trickledown by testing the coherence of sectoral decisionswith these objectives, by undertaking SEAs andEIAs. Applying only EIA is often not enough, be-cause not all impacts can be appropriately addressedat the project level, as was seen above. In this respect,EIA and SEA are supplementary.

This mechanism does not concern an interactionbetween two succeeding tiers, but in the first placeone between environmental policy and each of thetiers of sectoral decision-making. It is, in a way, anabstraction of the other mechanisms that are de-scribed above.

It seems that, ideally, the importance (or politicalweight) of, for instance, reducing a unit of greenhousegas emission should be identified through an assess-ment at country level. This could be laid down in envi-ronmental policy. Sectoral PPPs and project decisionsshould be coherent with this policy, and they shouldgive the appropriate weight to greenhouse gas emis-sion. To assess this coherence, SEA and EIA would beuseful tools. In this way, SEA and EIA help to ‘trickledown’ environmental objectives into sectoral deci-sion-making, along with the funnelling effect andenvironmental planning frameworks (see Nooteboomand Wieringa (1999) re links between environmentalpolicy and SEA).

Adjusting decision-making systems

Decision-making systems may be adjusted if strategicenvironmental questions cannot be addressed at theappropriate level. All decision-making systemsevolve, as environmental assessment (as a tool) itselfevolves. There are indications that in many sectorsand countries, experience with environmental assess-ment has encouraged governments to make suchchanges.

A survey indicated that in several EU countries,the planning systems in the transport sector havebeen, or are being, adapted to enhance the quality ofthe decision-making process, and to include environ-mental issues (Kolpron Consultants, 1994). Theremay be more systems where such a re-definition isappropriate.

Environmental issues are not the only importantfactor in decision-making; economic, social and otherfactors may also play a significant role. However, asenvironmental issues rise on the political agenda, de-cision-making systems themselves may have to be al-tered to bring environment issues to the forefront ofdecision-making. This can be observed in some of thecases in this report.



Figure 3. Two persepectives on the planning process, andhow environmental assessment influences both

Possible legal arrangements.

Benefits and interactions are not evenly distributedover the sectors of society, and any legal arrange-ments probably need to take account of these differ-ences. There appear to be differences between thefollowing situations:

� Tiered decisions (plans, programmes and projects)about individual major projects requiring an EIA:in these situations, assessment issues are clearlytiered and strategic decisions offer environmentalframeworks for further decision-making and as-sessment, thus reducing the scope of lower tierassessments.

� Sector decisions (policies and plans) affecting anumber of activities, many of which may not re-quire an EIA: here the main benefit is probably thatcumulative, synergistic and generic effects can beassessed efficiently.

� Tiered comprehensive spatial planning on differentscales, focusing on the consistency (environmentaland otherwise) of a number of developments in anarea: in this situation no clear tiering of impacts ap-pears to exist. On the other hand, great benefits canbe obtained by co-ordinating the assessment meth-ods and participation.

These differences are not yet well analysed, and it isunclear what the implications are for legal systems. Italso seems difficult to make legal environmental as-sessment arrangements about the types of impact thatshould be considered in particular types of policies,plans, programmes or project decisions (as indicatedabove, there is not a typical tiering order for impacts).It is difficult to generalise tiering orders acrosscountries, sectors and even across cases. On the otherhand, in individual cases, the scoping process that isundertaken at each assessment tier appears to be flex-ible enough to determine impacts and alternativesrelevant to that decision.

The question as to what a decision is about, andwhich types of alternative are feasible at that level, isin the first place determined by the decision-makingsystem and the proponent, and not by the environ-mental assessment process, nor by environmentalassessment legislation. The way to consider highlystrategic environmental alternatives, is probably toapply SEA to the levels where they are still consideredto be realistic options.

SEA can help improve the decision-making system

It is generally acknowledged that a decision shouldconsider impacts of any nature, beneficial as well asadverse. Each impact should not be assessed in moredetail than necessary to make a trade-off at that levelof decision-making. At strategic level, when broadbrush alternatives are compared (which will be elabo-rated in follow-up decisions), the impacts can also beassessed in a broad brush fashion. Relatively

unimportant adverse effects may, for example, be de-scribed as ‘worst cases’ (how bad could an effect be?).

The impacts should nonetheless be assessed withsufficient detail to give the decision-makers confi-dence that the risk of unacceptable impacts remainssmall, once the plan is further developed and imple-mented. It is likely that this confidence is related to theposition of the impact on the political agenda. The po-litical agenda may change quickly, and appropriateimpacts and alternatives in an SEA may thereforechange accordingly.

The decision-making system and the agencieswhich develop and assess proposals, should take intoaccount the priorities of the competent bodies (polit-ical issues). A flexible scoping phase is not sufficientif the decision-making system determines whichalternatives could be feasible, and which are not (forexample, another transport mode may not be feasiblewhen the initiator is a road administration).

SEA, as a transparent and flexible process, is a use-ful means to teach practitioners and planners aboutpolitical priorities that cannot be realised through theexisting system. In the long run this may help to re-shape planning and decision-making. However, thetransparency needs to apply to strategic decision-making as a whole, rather than only the assessment ofenvironmental impacts.

Notes

1. This publication can be ordered at: Distributiecentrum VROM,Tel: +31 900 8052 (Dfl 0.40/pm); Fax: +31 900 2018052.

2. The case descriptions are based on a large number of sources,for which the reader is referred to the original report(Nooteboom, 1999).

References

European Commission (1997a),” Council Directive of 27 June 1985on the Assessment of the Effects of Certain Private and PublicProjects on the Environment” (85/337/EEC - OJ 175/40, 5 July1985; as amended by Council Directive 97/11/EC - OJ L 73/5,March 1997)

European Commission (1997b), “Proposal for a Directive of theCouncil related to the assessment of the impact on the environ-ment of certain plans and programmes”, Official Journal of theEuropean Communities, COM(97/C 129/08).

Kolpron Consultants (1994), Besluitvorming over groteinfrastructuurprojecten in andere Europese landen [Deci-sion-making about large infrastructure projects in otherEuropean countries] (Kolpron Consultants, Rotterdam).

Land Use Consultants (1996), Environmental Impact Assessment:A Study on Costs and Benefits (European Commission DGXI,Brussels).

N Lee and J Hughes (1995), Strategic Environmental AssessmentLegislation and Procedures in the Community (EIA Centre,Manchester/European Commission DGXI, Brussels).

Mens and Ruimte Consultants (1997), Case Studies on StrategicEnvironmental Assessment (European Commission DGXI,Brussels).

S Nooteboom (1999), Environmental Assessments of StrategicDecisions and Project Decisions: Interactions and Benefits(Ministry of Housing, Spatial Planning and The Environment ofThe Netherlands, The Hague).

S Nooteboom and K Wieringa (1999), “Comparing strategic envi-ronmental assessment with integrated environmentalassessment”, Journal of Environmental Assessment Policy andManagement, 1(4), December, pages 441–457.



B Sadler and R Verheem (1996), SEA, Status, Challenges andFuture Directions (Ministry of Housing, Spatial Planning and theEnvironment/International Study of Effectiveness of Environ-

mental Assessment/EIA Commission of The Netherlands).R Thérivel and M Rosário Partidário (1996), The Practice of Strat-

egic Environmental Assessment (Earthscan, London).



Documents

Environmental assessments of strategic decisions and project decisions: interactions and benefits