Widening the scope: strategic environmental assessment - Introduction to Environmental Impact Assessment - page 361

either are dormant or have migrated. The amount and type of public consultation
undertaken in project EIA may be similarly limited.
By being carried out early in the decision-making process and encompassing all the
projects or actions of a certain type or in a certain area, SEA can ensure that alternatives
are better assessed, cumulative impacts are considered, the public is better consulted, and
decisions about individual projects are made in a proactive rather than reactive manner.
Strategic environmental assessment can also help to promote sustainable development.
In the UK, for instance, SEA is often expanded or integrated into sustainability
assessment/appraisal. 2 This involves not only broadening the scope of assessment to also
consider social and economic issues, but also setting sustainability objectives and testing
whether the PPP will help to achieve them. In other words, sustainability assessment tests
whether the PPP helps to promote a sustainability vision, whilst SEA tends to focus on
preventing environmental problems.
12.2.3 Problems with SEA
In the early days of SEA, lack of experience and appropriate techniques limited the
quality of SEAs. As SEA practice has evolved, these problems have eased but others
have emerged.
First, many PPPs are nebulous, and they evolve in an incremental and unclear fashion,
so there is no clear time when their environmental impacts can be best assessed: “the
dynamic nature of the policy process means issues are likely to be redefined throughout
the process, and it may be that a series of actions, even if not formally sanctioned by a
decision, constitute policy” (Therivel et al. 1992). Second, where SEA is required only
for programmes and/or plans but not policies, an environmentally unfriendly policy can
lead to environmentally unfriendly plans: in such a case, the plan-level SEA can at best
mitigate the plan's negative impacts, not consider more sustainable policy level
alternatives. Third, multiple PPPs often affect a single area or resource. For instance,
energy and transport PPPs—and many others—affect climate change. Waste and
minerals PPPs are often integrally interconnected, as are land-use and transport PPPs. As
such, it is often difficult to assess a PPP on its own.
There has also been considerable uncertainty about whether SEA should be broadened
out to also cover social and economic issues. Considering environmental issues
separately from social and economic issues may give them an additional “weight” in
decision-making and helps to keep the integrity of the environmental assessment. On the
other hand, sustainability appraisal more closely reflects actual decision-making, and is
legally required for many UK PPPs anyway, so integrating the two procedures makes
sense in terms of efficiency.
Finally, and most importantly, policy making is a political process. Decision-makers
will weigh up the implications of a PPP's environmental impacts in the wider context of
their own interests and those of their constituents. SEA does not make the final decision:
it merely (sometimes maddeningly so) informs it.