ارتقای بهبود زیست محیطی در ارزیابی زیست محیطی استراتژیک

This paper evaluates how the enhancement of positive environmental impacts has been considered and developed in Strategic Environmental Assessment (SEA) reports since the SEA Act in Scotland was introduced in 2005. Fifteen Environmental Reports on strategic actions prepared between 2006 and 2009 were scrutinized for this study, one of which pertained to national policy and the rest to responsible authority programmes, plans or strategies throughout Scotland. A four point scale was developed to evaluate the extent to which environmental enhancement promotion or measures were considered in the Environmental Reports: Thorough, Fair, Minimal and Absent. Results found that nine out of the 15 Environmental Reports studied were graded as ‘minimal’ or ‘absent’. The paper concludes that in order for SEA to achieve its full potential, in addition to considering mitigation measures for negative environmental impacts, SEA practitioners and decision makers must begin to realize and exploit potential enhancement opportunities

This paper analyzes how environmental enhancement promotion is being integrated into the Strategic Environmental Assessment (SEA) process in Scotland and, by extension, the role SEA plays in ensuring that environmental enhancement measures are being identified for incorporation into strategic actions. Environmental enhancement of positive impacts, particularly in the context of biodiversity and habitat loss, represents one of the main objectives of sustainable development (see for example CBD, 2002), and SEA is recognized as a potential instrument for promoting its delivery through public body policies, plans and programmes (strategic actions) (Fuller, 2004, ODPM Office of the Deputy Prime Minister, 2005 and Therivel, 2004). However, SEAs have been found to focus mainly on mitigation and frequently ignore the opportunity offered by enhancement measures. For example, an SEA of a Scottish Local Plan carried out in September 2005 categorized all proposals into three categories: A — likely to have a significant environmental effect; B — may have a significant environmental effect, and C — unlikely to have a significant environmental effect. The Environmental Report then stated that proposals falling under category C, the category that included sites where environmental effects were likely to be positive, would not be considered further in SEA (João and McLauchlan 2005). This issue has also been raised by Ng and Obbard (2005, p. 483): ...the application of SEA in Hong Kong continues to have notable limitations. SEA needs to evolve beyond its current sectoral application to examine ways in which development decisions can not only pre-empt and prevent environmental damage, but also positively enhance and restore existing natural resources. Current land use plans and transportation strategies still largely determine the pattern of development in the near future without adequate longer-term environmental cost-benefit analysis. This paper explores the extent to which potential environmental enhancement measures have been developed and positive environmental impacts relating to strategic actions have been identified, enhanced and promoted through the SEA process in Scotland. Scotland transposed the European SEA Directive 2001/42/EC into Scottish Law first as The Environmental Assessment of Plans and Programme (Scotland) Regulations 2004, and then as the Environmental Assessment (Scotland) Act (2005) (hereafter referred to as the SEA Act), with the number of strategic actions being subject to SEA rising from 25 in 2005 to 111 in 2008 (Scottish Government 2009a). Scotland represents an interesting national case study as the Scottish Government committed, through the SEA Act, to extend the requirement of the SEA Directive – which only requires that certain plans and programmes be exposed to the SEA process – to include all plans, programmes and strategies being taken forward by the public sector or responsible authorities preparing strategic actions with a public character (with a few exemptions such as budgets). This decision was in accordance with the Scottish Government's commitment to integrating the principles of sustainable development into Scottish policy (Scottish Government 2005) and its ambition to become a “world leader” in SEA (SEEG, Scottish Executive Environment Group 2004). In order to introduce the context of the analysis of this paper, some examples of how SEA can contribute to environmental enhancement and how it relates to sustainable development are introduced. The method used to select and evaluate the 15 Environmental Reports with regard to environmental enhancement is thereafter presented and the results and analysis are then discussed in the context of the SEA Act and guidance on SEA for practitioners. The paper concludes by offering some recommendations for SEA policy and practice, as well as some suggestions for future research.

Overall, the results of this study have shown that the identification and promotion of environmental enhancement measures in Scottish SEA Environmental Reports are variable but mainly lacking. In addition, the results indicate that where the Scottish Government template/guidelines are used in the preparation of the SEA Reports, the integration of environmental enhancement promotion throughout the various stages of the report is minimal in most cases. The recurring failures of the reports in respect of environmental enhancement promotion centre on three key stages of the process. Firstly, when the relevance of the strategic action to environmental enhancement measures in other policies, plans or programmes is identified, there is little detail included as to how this might affect the overall outcome of the strategic action. Secondly, the development of reasonable alternatives to the strategic actions (or elements thereof) is generally not conducted effectively. For example, feasible alternatives are not developed within which environmental enhancement measures are highlighted and the alternatives identified usually serve to defend the pre-determined or preferred alternative of the strategic action. Thirdly, many of the reports fail to describe with any detail how positive environmental effects resulting from the strategic action might be enhanced. 5.1. Recommendations for SEA policy and practice As many strategic actions have the potential not only to degrade the environment but improve it – for example, through developing brownfield sites, extending and linking wildlife corridors, improving landscape character or historic/cultural assets/resources through landscaping or restoration – actions must be taken to encourage such activity if it is to be consistent with sustainable development. In this respect, the results of this study lead to the recommendation that the Environmental Assessment (Scotland) Act (2005) be amended to put more emphasis on exploiting opportunities to promote environmental enhancement beyond that of offsetting any negative environmental effects. Accordingly, separate guidelines should be developed or adopted which prescribe to SEA practitioners, on a sectoral basis, specific approaches aimed at integrating environmental enhancement as a significant objective of strategic decision making. In particular, the results of the analysis carried out highlight some main issues which guidelines should emphasize: • SEA practitioners should detail how a strategic action might be developed to reflect the requirements of other policies and strategic actions relating to environmental enhancement. • The strategic action should be developed in concert with the SEA process; in particular, by way of developing alternatives for the strategic action with regard to environmental enhancement potential. • The Environmental Report should explicitly detail how positive environmental effects may be enhanced (and monitored) and should highlight appropriate opportunities for environmental enhancement relative to the area affected by the strategic action. The guidelines on integrating biodiversity considerations into SEA practice published by the Royal Society for the Protection of Birds (RSPB, 2004) or English Heritage (2010) mirror some of the above recommendations. Other guidelines focus more generally on achieving best practice overall in SEA by sector. 5.2. Recommendations for future research There is plenty of scope for further research on the topic. For instance, in order to more thoroughly test the inference that lack of environmental enhancement promotion in SEA might be associated with a lack of appropriate guidance, future research may involve interviewing SEA practitioners to assess both in-house and consultative capacity. This would facilitate understanding of the extent to which particular guidelines are followed or otherwise, assess how practitioners perceive their mandate in relation to environmental enhancement promotion through SEA practice, and ascertain whether lack of experience, resources or time – rather than just the quality or availability of guidance – could explain the poorer ratings of the Scottish Government guidance-based SEAs found in this study. Other studies may extend the scale of this study to include the assessment of ERs in other parts of the UK or internationally with a view to comparing the extent of environmental enhancement promotion in the SEA process between different countries. The scope of the study may also be extended to cover more strategic actions and/or include an analysis of the resulting strategic action in order to develop a clearer picture as to what extent environmental enhancement measures are being adopted post-SEA. Such a study could also focus on the robustness of the monitoring regimes proposed through the SEA process and the extent to which any potential enhancement is being realized beyond the ER. Also, especially in the current credit-crunch climate with resources being a recurrent issue for local authorities, further studies into the effects of limited resources on SEA practice and quality should be carried out. Next year (2011) marks the tenth anniversary of the SEA Directive in the European Union (Directive 2001/42/EC) and article 12 states that “(1) Member States and the Commission shall exchange information on the experience gained in applying this Directive and (2) Member States shall ensure that environmental reports are of a sufficient quality to meet the requirements of this Directive and shall communicate to the Commission any measures they take concerning the quality of these reports”. With a review of the SEA Directive due in 2013, hopefully the EU will be inspired by the direction SEA practice is taking and stipulate the promotion of environmental enhancement in the Directive itself in line with Article 174 of the Treaty forming the European Council; which provides that Community policy on the environment is to “contribute to, inter alia, the preservation, protection and improvement (emphasis added) of the quality of the environment...” and Article 6, which provides that “environmental protection requirements are to be integrated into the definition of Community policies and activities, in particular with a view to promoting sustainable development.” Future research into the relationship between environmental enhancement and strategic actions is clearly urgently required to allow governments to assess to what extent positive environmental change and, by extension, sustainable development, is being achieved from top level policy through to local planning. Equally, enhancement can have an important role in project EIA — if EIA is considered early enough and forms an integral part of the project design.