An overview of UK practice to date - Introduction to Environmental Impact Assessment - page 233

8.4 EIS quality
As we mentioned in Section 8.1, the preparation of high-quality EISs is one component
of an effective translation of EIA policy into practice. Two schools of thought exist about
the standards that should be required of an initial EIS. Some argue that developers should
be encouraged to submit EISs of the highest standard from the outset. This reduces the
need for costly interaction between developer and competent authority (Ferrary 1994),
provides a better basis for public participation (Sheate 1994), places the onus
appropriately on the developer and increases the chance of effective EIA overall. Others
argue that it is the entirety of environmental information that is important, and that the
advice of statutory consultees, the comments of the general public and the expertise of
the competent authority can substantially overcome the limitations of a poor EIS (Braun
1993). This view is also supported by planning inspectors at appeal and judicial review
cases.
Environmental impact statement quality in the UK is affected by the limited legal
basis for EIA and by the facts that planning applications cannot be rejected if the EIS is
inadequate, that (to date) some crucial steps of the EIA process (e.g. public participation,
the consideration of alternatives (until 1999) and monitoring) are weak and often not
mandatory and that developers undertake EIAs for their own projects. This section first
considers the quality of EISs produced in the UK, based on several academic studies. It
continues with a brief discussion of other perceptions of EIS quality, since competent
authorities, statutory consultees and developers require different things from EIA and
may thus have different views of EIA quality. It concludes with a discussion of factors
that may influence EIS quality.
8.4.1 Academic studies of EIS quality
Academic studies of EIS quality can broadly be classified as aggregated or disaggregated.
Aggregated studies consider the quality of a number of EISs overall, where the EISs
either represent the total population of EISs or a specific subgroup (e.g. type of project).
Disaggregated approaches focus on the quality of the treatment of individual EIS topic
areas (e.g. landscape or noise), or performance with respect to certain EIS components
(e.g. baseline data, the consideration of alternatives) or their presentation (Lee et al.
1994).
Researchers from the University of Manchester have studied aggregated approaches to
EIS quality over the years, using the Lee & Colley criteria (1990) (see Appendix 3).
Based on these criteria, EISs have been divided into “satisfactory” (i.e. marks of A, B or
C) and “unsatisfactory” (D or below). Table 8.5 summarizes some of the findings. It
shows EIS quality to be increasing after dismal beginnings, with about half of recent EISs
being satisfactory.
A study carried out by Oxford Brookes University's IAU for the DoE compared 25
EISs prepared before 1991 with matched 2 EISs prepared after 1991, on the basis of
different sets of criteria, including simple “regulatory requirements” and comprehensive
criteria devised by the IAU. For the simple regulatory requirements, 44 per cent of the
post-1991 EISs fulfilled all the nine criteria used, compared with 36 per cent of the pre-
1991 EISs. A more detailed analysis indicated that 92 per cent of the post-1991 EISs