طرح حمل و نقل بازی های المپیک آتن 2004 : فرصت از دست رفته برای ادغام ارزیابی زیست محیطی استراتژیک (SEA) ؟

During the 1990s, a considerable debate on the integration of Strategic Environmental Assessment (SEA) with the policy, plan and programming process took place among scholars throughout the world. This debate is relevant today, especially in the context of Sustainable Development (SD) as it is maintained that the integration of environmental concerns in policy, plan and programme (PPP) making, is a step towards sustainable planning practices. This is also the rationale behind the recent enactment of the European Union (EU) Directive on the `assessment of the effects of certain plans and programmes on the environment' (or `SEA Directive') which requires that following the 21st July 2004, all member states' authorities preparing certain formal plans or programmes should undertake SEAs by preparing an environmental report describing the potential effects of plans and programmes upon the environment. This paper applies an integrative SEA/PPP framework, to the transport planning process of a major international athletic event: the Athens 2004 Olympic Games. It was found that despite the lack of a formal SEA in place, there are positive signs for its future integration in similar studies in Greece. Furthermore, it is recommended through comparison with other SEAs for Olympic Games, that weight should be given to the co-ordination of the common stages of the PPP and SEA processes, if SEA practice is to be encouraged in countries with underdeveloped SEA systems such as Greece.

1.1. Introduction Further to a recognised European Union (EU)-wide need for Environmental Impact Assessment (EIA) for development projects (CEC, 1985 and CEC, 1997), Strategic Environmental Assessment (SEA) offers the possibility of assessment, evaluation and monitoring of environmental impacts of programmes, plans and policies (PPPs) at a higher tier of the decision-making process (UNECE, 1992). Following the recent enactment of the EU-wide Directive `on the environmental effects of certain plans and programmes on the environment'1 (CEC, 2001), which will set a regulatory framework for the application of minimum SEA requirements, current practice is limited in Europe. One of the main obstacles for the wider application of SEA and the consequent realisation of its beneficial value to decision-making, environmental protection and promotion of Sustainable Development (SD) is an observed and documented lack of `co-ordination' of both processes (Sadler and Verheem, 1996; RECCEE, 1998; Zagorianakos, 1999 and Zagorianakos, 2001a). The case study examined in this paper, adopts the structure and principles of an `integrated SEA/PPP framework' which has resulted from the undertaking of a recent research study (Zagorianakos, 2001a). The purpose of this paper is to review, in the absence of a formal environmental assessment exercise, the extent to which the transport planning arrangements for the organisation of the Athens 2004 Olympic Games has been subject to SEA type analysis, revealing thus the missed opportunities for better environmental management of similar events of international significance. This examination is especially interesting in the light of the SEA-Directive's enactment, in as far as it offers an indication of the difficulties a formal (i.e. under the Directive's requirements) undertaking of SEA would have posed to the Greek institutional environmental management mechanisms. This paper is also supplemented by the comparison of the case study characteristics with SEAs and transport studies carried out for other (candidate) Olympic cities such as Cape Town2 and Sydney. The first part of the paper provides an insight to the appropriateness of applying SEA to the Transportation Plan. The presentation of the main conclusions of the analysis of the case study follows. The paper concludes by discussing the reasons for the SEA deficiency and highlights the incentives and recommendations for promoting better practice on SEA integration in Greece. 1.2. Is Athens 2004 Transportation Plan suitable for SEA? The hypothetical application of SEA to the Athens 2004 Olympic Games, which is the subject of this paper, is justified by the limited international experience of this type of assessment for major athletic events. The following question needs to be addressed, however, before elaborating on this case study: is Athens 2004 Transportation Plan suitable for SEA? After all, one would have thought that the Olympics Transportation Plan is still a `project' albeit a major one rather that a plan. In other words, is the Athens 2004 Transportation Plan sufficiently far up the scale to warrant consideration under SEA? Under a rather narrow definitional viewpoint, the Athens 2004 Transportation Plan has the characteristics of a programme as it includes `the consideration of more than a single project' (CEC, 1996) and in that respect certainly qualifies for SEA examination. In addition, the Plan would also warrant consideration under SEA Directive's provisions since according to the scope of the SEA-Directive [CEC, 2001, Article 3 (scope) para. 2; Article 2 (definitions)]: `An environmental assessment shall be carried out for all plans and programs, (a) which are prepared for … transport … and which set the framework for future development consent of projects listed in Annexes I and II to Directive 85/337/EEC' and `For the purposes of this Directive “plans and programs” shall mean plans and programs: which are subject to preparation and/or adoption by an authority at national, regional or local level … and which are required by legislative, regulatory or administrative provisions'. The SEA Directive has only recently been enacted but not yet transposed into member states' legal system. It is for this reason that a potential voluntary SEA application to the Olympics plans and programmes, prior to the Directive's adoption, would have provided valuable insights to its future successful implementation in Greece.

The Transportation Plan for the 2004 Olympic Games is characteristic of the way that environmental protection issues are taken into account at a strategic level of decision-making in Greece. Although a full SEA was not undertaken, a number of elements of SEA integration were found. This case study, therefore, points out the opportunities that the application of SEA can offer in an underdeveloped environmental management context. The analysis found that the recent absence of a regulatory framework for SEA (such as the proposed SEA Directive), the lack of tradition on environmental assessment application, and the lack of political will which is partly the result of the controversial political issues involved in the organisation of this major international event, are the most influential factors for the observed lack of SEA application. The good news is that the existing and potential integrated elements were/can be cost-effective and a minimum effort could have been made to bring the fragmented elements of integration into an integrated form and utilise the different types of expertise into a more constructive and communicative exercise. These conclusions should also be seen in the context of an undeveloped system of SEA in Greece (Zagorianakos, 2001b). Given that the equivalent term for SEA in Greek has only recently been introduced for the purpose of implementing the SEA Directive, and there is no SEA application documented in the relevant literature,6 this case study aims at providing a fruitful arena for a debate on the initiation of SEA practice in Greece. The debate can be based on current latent experience within the country as well as on good practice on integration in other countries with established SEA systems. The outcome of the debate should also feed into current attempts for the preparation of Greece for the implementation of the recently enacted SEA Directive. The reasons for the domination of developmental over environmental considerations and the resulting absence of both a `full' SEA and adequate `SEA elements of integration', can be attributed to a number of reasons. These are related inter alia to the lack of mandatory provisions for the undertaking of an SEA (such as the SEA Directive), the unfamiliarity or lack of trust in the benefits of SEA integration, the government focus on the cultural aspects of the Athens candidacy instead of environmental protection, or simply to the lack of environmental assessment tradition in Greek regional and spatial planning. The interviewees contacted for the purpose of this case study, maintained that there are two main reasons for the absence of SEA or other environmental assessment tools in the Transportation Plan. These are the political and, as such, confidential, nature of the Transportation Plan with its direct implications for the planning and management of the Olympic Games, and the procedural, methodological and institutional difficulties involved in impact assessment at this strategic level of decision-making. The environmental assessment activities undertaken in other Olympic Games' candidate cities, can provide valuable lessons to the Greek government. In the Sydney 2000 Olympics for example, good practice initiatives included the on-going monitoring of greenhouse gas emissions, the integration of social impacts from an early stage, the active involvement of environmental NGOs in the design phase of the study for the Olympic Village, and the institutional arrangements for the involvement of the public (e.g. Communication Strategy, Games Workforce Environmental Training Plan, Environmental Volunteer Procurement Strategy). In the Cape Town 2004 Olympic Bid, all socio-economic and environmental aspects of the Olympic Games proposal were accommodated under the umbrella of an SEA methodology. This gives an indication of the value placed on SEA. Is there evidence for a justified optimism for future SEA application in Greece? The examination of this case study showed that the undertaking of an assessment of the transport-related environmental effects of the Olympic Games in 2004 and the integration of the outcome before, during and after the Games is a feasible endeavour. This is supported by the fact that (a) there was a strong commitment to financial resources throughout plan making, (b) methodological and organisational insights were gained by looking at previous Olympic Games Bid competitions, and that (c) more than 30 experts from over 20 different disciplines were employed in the preparation of the winning Bid File for the Olympic Games in 2004. A successful integration however, would have required the introduction of a flexible process that is cost-efficient, qualitative, focused and participatory. Furthermore, the training of ATHOC's staff on SEA would have further facilitated the exercise. The adoption of an SEA process can be beneficial for ATHOC, the city image, and environmental planning and management practice in at least three ways. First, information could be generated for the purpose of enabling the anticipation, control and mitigation of environmentally harmful actions. This information can be particularly useful in planning for the `day after' the Games and, as such, effectively portray ATHOC's long-term vision for local/regional environmental quality. Second, the environmental profile of Athens as a city can be promoted internationally since it will set itself in a position to compare and compete on environmental grounds with other cities organising the Games. Third, if the potential SEA exercise was structured in such a way as to incorporate the requirements of the recently passed SEA Directive (CEC, 2001), it would greatly entertain fears expressed by Greek planners about the problematic introduction of European Union's environmental legislation (Zagorianakos, 2001b). Finally, the presentation of the Athens 2004 Transportation Plan, allows the inference of conclusions with relation to the nature and form of SEA per se, and in particular the changes necessary to accommodate the specific conditions of the Greek transport planning practice. The transport planning process has many procedural similarities with basic SEA methodology. It is at these `connection points' where the introduction of an integrated-SEA should be targeted. As far as SEA is concerned, the inherent weaknesses of the Athenian planning system suggest that the methodological and procedural flexibility of SEA is the key for the promotion of SEA application in countries (such as those that will join the EU) where environmental assessment of strategic actions is either absent or underdeveloped.