Can Natura 2000 Sites Benefit from River Basin Management Planning Under a Changing Climate? Lessons from Germany - Wetlands and Water Framework Directive: Protection, Management and Climate Change - page 38

All of the PoMs investigated in Germany had undergone a SEA. Analysis of the
environmental reports drawn up in the course of the SEAs showed that for the most
part they contained the necessary information. However, the analysis also showed
that the SEA was usually conducted on a smaller scale than that of the PoM. In
most cases the assessment was carried out for planning units, coordination areas or
the entire planning region. If the objects of assessment used for the SEA were more
speci c, then the environmental assessment could provide more detailed indications

of signi

cant effects on nature conservation issues. In addition, a targeted assess-
ment of relevant cumulative effects on numerous successive or neighbouring water
bodies, and also of the effects of single measures on entire river systems, would
represent a quali ed assessment of cumulative effects that could provide system-

relevant information about the development of special nature conservation issues
(Stratmann et al. 2012c , p. 143).
There is no documentation of the assessment of alternatives in any of the
environmental reports. In all the reports the assessment of alternatives was dis-
placed either sideways (into the management plan that is not subject to the SEA) or
in some cases downwards (to the next planning permission procedure). The
examination of alternatives in the management plan was, however, not carried out
in the formal framework of an environmental assessment, but rather in the planning
stages of the river basin management plan and informal agreements with nature
conservation. There was thus no documentation of assessments of conceptual,
systematic or spatial alternatives. A signi

cant element of the SEA was thus not
applied (Stratmann et al. 2012c , p. 147 et seq.).
In the context of the sideways displacement of the examination of alternatives into
the management plan, it was stated many times that alternatives had been discussed
and evaluated during the management planning process, particularly at the local and
regional level, and that alternatives had therefore already been assessed the

planning of the PoMs. The argument is not fully convincing, because the planning
period for both management plan and PoMs is the same. The documentation and
review of comparisons with alternatives in terms of integrating aspects of nature
conservation would thus have been possible (Stratmann et al. 2012c , p. 147).
Similarly to the examination of alternatives, the spatially de

“ outside ”

ned, quantitative

prognosis of effects was displaced to the next speci c planning stage in all the

environmental reports. This corresponds with the level of speci cation of the

programme of measures, but it means that necessary agreements, for instance with
nature conservation, had not yet been possible. The concern here is that,

firstly,
more time will be needed for agreement at the next planning stage, which could
delay prompt implementation, and, secondly, desirable synergies or important

con ed at this later planning stage where large-scale

alternatives can no longer be chosen. This problem is further compounded by the
fact that no water body speci

fl icts will only be identi

c environmental assessment is carried out, but only
one at the scale of the planning units (Stratmann et al. 2012c , p. 147 et seq.).

Habitats Regulations Appraisal and its role in integrating the objectives of
RBMP and Natura 2000

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