مروری انتقادی از خطوط غالب مباحثات در مورد نیاز ارزیابی زیست محیطی استراتژیک

In spite of almost two decades of experience, Strategic Environmental Assessment's (SEA) foundations remain unclear to the point that the case for needing an instrument called ‘SEA’ could be questioned. The aim is to ask: what problems was SEA meant to solve, and what needs was it meant to address, by reflecting on the strengths and weaknesses of SEA thinking to date. I do so by organising the reasons and arguments offered by scholars and practitioners under three ‘lines of argumentation’ related to the strategic dimension of SEA, its methods and purpose. I explore how each line of argumentation affects the concept of (the purpose and role) and approach to (the procedures, methods and tools) SEA. The problematisation of these arguments and their evolution makes a case for the urgent acknowledgment of misleading simplifications. From this analysis I propose a number of promising fields of inquiry that could help respond to the growing expectations attached to SEA and strengthen its ‘strategic’ dimension: revisiting the concept of assessment in SEA, promoting strategies for the introduction of SEA, and strengthening the contribution of theory to SEA practice.

This paper engages with the foundations of Strategic Environmental Assessment (SEA) as an assessment concept and practical instrument. Although SEA has been the subject of theoretical and practical development for almost two decades, scholars and practitioners remain divided on whether it is theoretical or methodological issues that require additional attention. Back in 1993 scholars maintained that theory had been addressed but that methodologies were lacking: ‘SEA has been considered much more from a theoretical than a practical perspective, SEA methodologies are neither well-developed nor commonly agreed upon’ (Thérivel, 1993:164). Yet a decade later, questions about the conceptual basis of SEA were still being raised by scholars: ‘[SEA is] a … theme in need of reflection, since there has been much development of procedures and methodologies, but significantly less conceptual development’ (González, 2001:5). Practitioners agree: ‘SEA practice is ahead of theory … though we are not sure whether this is a good or a bad thing’.1 These concerns suggest, at a minimum, that early theoretical efforts have left several questions unanswered. Since the early 1990s, SEA commentators have mainly focused on specific practical aspects of SEA as a ‘tool’ applied to development initiatives (Dalal-Clayton and Sadler, 2005, Fischer, 2002, Partidario and Clark, 2000, Thérivel, 2004 and Thérivel et al., 1992), with comparatively few efforts dedicated to SEA theory (Caratti et al., 2004, Partidario, 1996, Richardson, 2005, Thissen, 2000 and Wallington, 2002). Despite SEA's roots in Environmental Impact Assessment (EIA) – which developed in the late 1960s – and almost two decades of experience, scholars and practitioners appear divided on such fundamental matters as the concept of and the approach to SEA. Throughout the instrument's career, divisions over these matters have contributed to innovations in process design and a widening choice of methods and tools, resulting in significant diversity in practice (for a recent overview, see Dalal-Clayton and Sadler, 2005). Yet despite such progress in practice, SEA's foundations have remained unclear: Does SEA differ from EIA? If so, are these differences related to the concept or the approach to assessment, or both? These are decisive times for SEA and such questions need urgent answers. Widespread application has led to a process of transformation involving greater complexity and differentiation in the way SEA is understood and applied. There has also been a systematic growth of expectations attached to SEA. Given the growing investments of governments, and multilateral and bilateral agencies, throughout the developed and developing world aimed at institutionalising SEA, it seems imperative to take stock of developments to date, so as to deepen our understanding about the kind of phenomenon SEA is and should be. This paper is intended as a contribution towards a better understanding of the foundations, the raison d'être, of SEA. The aim is to clarify the challenges to, and potential of, SEA at this critical and opportune stage in the instrument's evolution — a stage when significant attention and resources are being directed to its institutionalisation and application. To do so, I focus on the way scholars and practitioners have framed the case for the development of SEA: What problems was it meant to solve? What needs was it meant to address? To what extent has any of this been achieved? The arguments put forward by members of the SEA community (including scholars and practitioners) in answer to these questions are identified, in this paper, from multiple sources: published academic research, brown literature (especially guidance documents and case study reviews), ‘action research’ (SEA training, capacity building and review of SEA processes),2 interviews conducted as part of previous research undertaken by the author,3 and observations at seminars and conferences on SEA between 2001 and 2005.4 My analysis of the arguments arising from this material suggests that the foundations of SEA can be categorised according to three lines of argumentation, presented in Table 1. In the next three sections of this paper I analyse each line of argumentation in order to illuminate their implicit or explicit framing of SEA concepts and approaches. In doing so I distinguish between their early framing (late 1980s, early 1990s),5 and their evolution during the late 1990s. I explore in particular the links and overlaps between SEA concepts and approaches, and those of its precursor: EIA. In the final section I discuss the weaknesses and (somewhat hidden) strengths of such evolution, highlighting several challenges which, I contend, need to be addressed by SEA scholars and practitioners to strengthen the concept and approach to SEA (Table 2). For the sake of clarity, I wish to explain the use of key words throughout this paper. By the concept of SEA, I refer to the purpose and role of the instrument. The purpose indicates the broad, long-term reasons for institutionalising a system of SEA within a legal framework, a planning context, and/or a particular organisation. The role concerns the way SEA relates to planning and decision-making and interacts with a given institutional, administrative, cultural and political context. Furthermore, the concept of SEA should explain what it means for assessment to be ‘strategic’ and ‘environmental’. By the approach to SEA I refer to the way the instrument is applied in practice: the procedures, methods and tools adopted.

This critical reflection on the foundations of SEA has helped identify the strengths and weaknesses of arguments relating to the concept and approach to SEA. The main factors influencing the early development of these lines of argumentation, and their evolution over the last 15 years, are highlighted in Fig. 1. The first line of argumentation has been a decisive influence in slowing the evolution of SEA in response to identified problems with EIA, by claiming that its strategic dimension was the result of the strategic nature of the planning decisions it was assessing, and by oversimplifying the nature of PPPs and of tiering. This has meant that the development of the ‘strategic dimension’ of SEA, in terms of its role, procedures, methods and tools, was delayed until the late 1990s. The second line of argumentation initially focused on technical and procedural problems (symptoms) related to EIA practice. It was not until the late 1990s that the SEA community began to address the causes that had led to the unsatisfactory implementation of EIA, which related to its failure to live up to the original intentions of NEPA: analysis aimed at restructuring rules and values and inducing ecological rationality into systems of governance (Bartlett, 1997 and Wallington, 2002). Scholars and practitioners gradually looked beyond methodologies, and the scope or scale of impacts, to address key questions about how to conceptualise the object of the assessment (beyond narrow interpretations of PPPs), and how to ensure a more effective integration of the processes of assessment, planning and decision-making. This stage of SEA's career has thus been more reflexive in terms of the role and approach to SEA, consistent with a maturing phase in the instrument's history. The third line of argumentation, that SEA would contribute to sustainable development, has potentially radical implications for the concept of SEA, which in turn affects the approach to assessment. However, the analysis in this paper has identified a striking lack of explanation addressing what this might mean: the kind of sustainability to be embraced, and the way to make that contribution in practice. There have been important instances of innovation and leadership, especially from practitioners rather than theorists (CSIR (Council for Scientific and Industrial Research), 2003, Dalal-Clayton and Sadler, 2005 and Levett and McNally, 2003), but these remain ad hoc contributions, rather than a systematic development throughout the field of SEA. The rapidly expanding field of sustainability assessment (Gibson et al., 2005) can provide useful answers to what it means for assessment to contribute to sustainability, but it also raises the question: how should SEA differ from sustainability assessment? Identified shortcomings in the arguments which justify the need for SEA point to three broad areas of research and development. I contend, further, that these issues demand the urgent attention of policy makers, bureaucrats and experts responsible for the regulation and institutionalisation of SEA around the world, as well as of trainers and capacity builders. The issues raised here also suggest a clear role for SEA scholars, ensuring that further discussions proceed from conceptual and practice-oriented perspectives. 5.1. Revisiting the concept of assessment in SEA I have suggested that most of the early arguments for SEA had in fact already been at the normative heart of EIA's conceptual foundations. SEA is not different from EIA because it applies to strategic initiatives. If it is in any substantive way a departure from EIA, that departure has occurred in practice: SEA is best conceived as a renewed attempt, by the assessment community to address the fundamental challenges identified in the early 1970s — challenges which have been addressed in EIA practice with only limited success. Acceptance of, and response to, these claims is crucial to the future development of SEA. On the one hand, my analysis undermines many of the arguments considered to distinguish SEA from EIA, and thus to provide a raison d’être for SEA. On the other hand, my analysis unveils a renewed strength and sense of purpose for the field of environmental assessment, highlighting its role in the transition to new rules and institutions that promote ecological rationality into systems of governance. The last decade has witnessed significant attempts to strengthen the concept and approach to SEA, as a result of the progressive opening of SEA research to other fields and disciplines, and as a response to innovations in practice. The simple linearity of early normative SEA conceptions jarred with the complexities faced by practitioners: they had to think differently about the object of assessment, and to explore the planning and decision-making dimensions of the PPPs as well as their political, institutional and cultural context; they had to face challenges including the policy-vacuum from which many initiatives arise, and the inevitable clash between values and worldviews intrinsic to most development strategies. These developments, analysed in detail in this paper and confirmed by my own experience in the field, make it possible to identify the following distinctive traits of SEA's evolution: SEA is being used increasingly to address the weaknesses of the policy context for strategic development initiatives, and of the policy processes intended to deliver them. Ultimately, this will lead SEA to address the political, institutional and cultural context that influences both assessment and planning, as originally envisaged by NEPA. In other words, the role of assessment is changing as it moves upstream, targeting the early stages in the design of development proposals, and crucially the processes and contextual factors that shape these proposals. The prediction and evaluation of the potential environmental effects of PPPs has ceased to be an accurate description of what many SEAs achieve – or aim to achieve – despite the fact that many new laws continue to use this as the core definition of the new assessment regimes. Impact prediction and evaluation remain a part of the assessment process, but the importance of these analytical stages is becoming secondary to a range of preparatory tasks (often under the heading of ‘scoping’) that seek to direct planning and decision-making towards environmentally sustainable framings of problems, objectives, and alternatives (Caratti et al., 2004, CSIR (Council for Scientific and Industrial Research), 2003, EC (European Commission), 2005 and OECD DAC (Organisation for Economic Cooperation and Development— Development Assistance Committee), 2006). Collaboration, negotiation and persuasion become central activities of these preparatory tasks, all the more so when the aim is to contribute to sustainable development (OECD and UNDP, 2002). Assessment is becoming more participatory, not only in terms of involving representatives of civil society, but also in seeking greater cooperation and coordination between government agencies, development sectors and sources of expertise that have a direct or indirect interest or contribution to make. Finally, there is a growing emphasis on the opportunity of using SEA as a catalyst for rational and social forms of learning: to promote long-term positive impacts on the culture and worldviews of the organisations and sectors that apply this mechanism (see Nooteboom in this issue; also: Bina, 2003, Nilsson, 2005 and World Bank, 2005), and to strengthen the capacity for environmental planning (Bina, 2003 and OECD and UNDP (Organisation for Economic Cooperation and Development and United Nations Development Programme), 2002) in line with the original EIA concept discussed by Bartlett (1997). However, no single SEA combines all the characteristics described here, and while some recent assessments have applied several of these conceptual and methodological avenues, many more are likely to remain within the straightjacket of narrow interpretations of EIA, failing to realise SEA's potential (a risk, in my view, that persists in relation to the implementation of the European Directive (EC, 2001)). This may be the result of legal requirements, of institutional, cultural and political constraints (discussed in the second line of argumentation), or simply of time and resource constraints. Nonetheless, I would also point to a persistent failure to reflect on what this analysis has shown to be early misconceptions in the framing of a case for SEA. It seems reasonable to assume that this failure will have done little to set SEA onto a path more consistent with the challenges it faces. 5.2. Promoting strategies for the introduction of SEA Instead of searching for universally applicable and replicable good practice examples or manuals, policy makers, bureaucrats and experts responsible for regulating and institutionalising SEA processes should ask themselves first why they want SEA: what it is that needs fixing in the way they take strategic decisions about development (what keeps these from delivering sustainable outcomes?), and what do they think SEA can and should do about it ( Bina, 2003 and Hilding-Rydevik and Bjarnadóttir, 2005). Answering these questions would force authorities responsible for SEA in each development ministry (or sector of government) to critically consider the three lines of argumentations reviewed here. Authorities could then frame the purpose, role, and approach to SEA so that it is relevant and consistent with the institutional, planning, organisational and cultural context of application. This would provide each ministry (or organisation responsible for SEA implementation) the basis for a strategy that would introduce SEA as a system designed to address those challenges that are perceived to be the most serious and urgent within the specific context in question. A similar strategy could also ensure that SEA is institutionalised as an integral part of the structures and processes being set up for environmental governance – including policy integration and sustainable development strategies – thus maximising synergies between otherwise disparate initiatives and frameworks. A strategy for the introduction of SEA could have short- and long-term goals: the first targeted at making specific initiatives (major projects, and PPPs) environmentally sustainable, and the second aimed at progressing institutional and cultural change within the organisation, strengthening the capacity of the organisation to analyse and define development problems and solutions with environmental sustainability as a core concern. This might include the design of opportunities to support ‘learning-oriented assessments’ (Bina, 2003:306, see also World Bank, 2005), which would in turn promote reflection in a case-by-case manner, based on the results of each assessment. Only after this, should responsible authorities search for answers about how to do SEA. In other words, only once these issues have been considered should the question of methods and techniques be addressed. 5.3. Time for theory to contribute to practice Cross-fertilization with other disciplines should be encouraged (the quest for inter-disciplinarity) to strengthen the contribution of theory to practice through the provision of space for reflection and the identification of new directions. I have highlighted the way in which the salient elements of SEA's evolution during the 1990s echoed earlier (or parallel) developments in other assessment instruments and fields of knowledge. I have also suggested that the isolationist tendencies of the EA community (Nitz and Brown, 2002) may have hindered the development of both EIA and SEA. There are signs that this trend may be reversing, however. In recent years, scholars have begun to engage with other disciplines and perspectives, including that of planning (Eggenberger and Partidario, 2000 and Richardson, 2005), strategy formation (Cherp, 2005), knowledge and decision-making theory and policy analysis (Kørnøv and Thissen, 2000). Additional efforts have explored the potential of SEA to contribute to various forms of learning (Bina, 2003 and Nilsson, 2005; Owens et al. 2004) and environmental justice (Connelly and Richardson, 2005 and Jackson and Illsley, 2005). Other fruitful areas of inquiry, yet to be fully explored, include environmental policy integration, sustainable development strategies and environmental governance mechanisms (including how these areas are being discussed in the development studies literature). It is the limited self-reflection within the SEA community that has prompted the present critique of the evolving arguments in favour of SEA. My hope is that, by making explicit the assumptions that underpin the lines of argumentation elaborated in this paper, the SEA community will concede misleading simplifications, question would-be self-evident truths, and acknowledge the potential of alternative lines of inquiry that – building on the strengths of SEA identified herein – could help respond to the growing expectations attached to SEA. This is especially urgent given the rapid dissemination and institutionalisation of SEA around the world, and the enduring authority of the three lines of argumentation: a point reinforced by Dalal-Clayton and Sadler's (2005:21) repetition of most of these problematic arguments in their statement that ‘the rationale for the SEA of PPP falls into three main categories: strengthening project EIA; addressing cumulative and large-scale effects; and advancing the sustainability agenda’. If, as I have argued, SEA is best understood as an attempt to implement original EIA intentions, my explorations should be considered relevant to EIA and SEA, and the distinction between the two would have to be reconceptualised. There is a specific need to consolidate the particular qualities of SEA in terms of strengthening the ‘strategic’ dimension of assessment, consolidating the developments identified for each line of argumentation. Clarifying whether SEA's purpose is to promote environmental protection, environmental sustainability or the broader concept of sustainable development seems a conditio sine qua non if the instrument is to have a future. The SEA community should continue to draw lessons from other instruments, but it should also seek to clarify the difference between SEA and other ‘strategic’ instruments (cf. Dalal-Clayton and Sadler, 2005 and Gibson et al., 2005).