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March 2021 local.gov.uk/pas
Environmental Outcome Reports
Consultation Webinar 30th March
We will begin shortly
local.gov.uk/pas
This session
 Information giving
 Hear from DLUHC (Kim Harding)
 PAS work on environmental assessment so far (Shelly Rouse)
 Hear from two local authorities doing environmental
monitoring
 Dr Jessica Salder, Principal Environmental Assessment Officer,
Surrey County Council, and
 Lisa Kirby-Hawkes, Development Planning Manager at Hampshire
County Council
local.gov.uk/pas
Planning Advisory Service (PAS)
 Team of 13
 Part of Local Government family
 Funded by DLUHC and Defra to
support English planning authorities
“PAS exists to support local planning
authorities in providing effective and
efficient planning services and to
support the implementation of changes
in the planning system”
local.gov.uk/pas
What we do
 Training events and workshops
 Web-based resources and guidance
 Newsletter = 8000 recipients
 Official officer and councillor peer network
 Unofficial network of friends and advisors
 Brand new experimental learning networks:
 NSIP, environment, developer contributions, digital
 Also work with individual councils and offer ‘peer
challenge’ reviews
 Our work programme for 2022/23 includes design,
developer contributions, Local Plans, development
management designation and nutrient neutrality
Environmental Outcomes Reports: a new
approach to environmental assessment
Consultation and Q&A
Consultation closes
9 June 2023
• Levelling Up and Regeneration Bill (LURB)
seeks powers for a new framework for
environmental assessment.
• Royal Assent 2023.
• Consultation - initial thinking on how the
powers in the Bill could be used to deliver
a more streamlined and effective system.
• Environmental Assessment of
Plans and Programmes 2004
(‘SEA Regs’)
• TCPA (Environmental Impact
Assessment) Regs 2017
• Infrastructure Planning (NSIP)
(EIA) Regs 2017
• EIA (Agriculture) Regs 2006 (and
2017)
• EIA (Forestry) Regs 1999 (and
2017)
• EIA (Land Drainage
Improvement Works) Regs 1999
(and 2017)
• Water Resources (EIA) Regs
2003
• The Marine Works (EIA) Regs
2007/1518
• Harbours Act 1964, Schedule
3 (I)
• Highways Act 1980, Part VA
• The Transport and Works Act
1992, (sections 13A, 13B, 13C
and 13D)
• The Transport and Works
(Applications and Objections
Procedure) Rules 2006
• Electricity Works (EIA) Regs 2017
• Public Gas Transporter Pipe-Lines
Works (EIA) Regs 1999
• Pipe-line Works (EIA) Regs 2000
• Offshore Petroleum Production
and Pipelines (Assessment of
Environmental Effects) Regs 1999
• Offshore Oil and Gas Exploration,
Production, Unloading and
Storage (EIA) Regs 2020
• Nuclear Reactors (EIA for
Decommissioning) Regs 1999
What We Heard
… box-ticking exercise….
…. in case of legal challenge …..
…. it doesn’t actually add that much value as a lot of
the information would be done anyway…
…… I don’t actually read it myself ….
……the concept is good ……
…it doesn’t need to include the ‘human stuff’ as that is
already taken care of …..
….its the data …..
…would be good to know if our mitigation actually worked ….
…..if you could get it working as a design tool ?…..
…..don’t trust the findings …
An outcomes-based approach
An outcomes-based approach
o Secretary of State sets outcomes which a plan or
project will have to report against.
o High level
o Set in regulations with supporting suite of
indicators (in guidance).
o Stem from the Environment Improvement Plan
2023
o Be measurable (at the correct scale)
o Be monitored
Outcomes and Indicators
Possible outcomes
• Biodiversity
• Air quality
• Landscape and seascape
• Geodiversity, soil and sediment
• Noise and vibration
• Water
• Waste
• Cultural heritage and archaeology
Scoping
Options to improve scoping…..
Proportionate reporting against
outcomes ?
• Minimal assessment of the outcome in
circumstances where full assessment
not required?
• Rare that the core outcomes are not
relevant at all
The Report
Better alignment
between strategic and
project scale
• Standardised approach to assessment across spatial scales working
towards common set of outcomes
• Streamlined process, avoiding repetition
• Regular strategic/plan-level monitoring
Reports pinpoint
conclusions in technical
work
• Reduced size & complexity of reports through focus on outcomes
• Reports will pinpoint conclusions in underlying technical work
• Confidence levels for predictions and mitigations
Early assessment of
alternatives
• Design tool
• Reduce confusion around alternatives, ensuring assessed at an early
stage
• High level summary record of key dates in decision-making on
alternatives & application of mitigation hierarchy
When (Screening)
• Updated lists
• Proximity to a sensitive site
overwhelming reason for requiring an
environmental assessment?
• How to incorporate?
Mitigation
Avoid Mitigate Compensate
o Mitigation hierarchy now law
o Must be considered in assessment of
alternatives early in the process and
reviewed, as the plan or project
evolves.
o Issue of ineffective mitigation or
unanticipated effects of mitigation
o Should we use adaptive
management to allow mitigation to
be adjusted (up or down) in response
to greater certainty on effects
following implementation? http://lindtoons.com
Mainstreaming monitoring
o Everyone agrees key – some say most
important part of process
(given lack of data & nature & complexities of
implementing development)
o Bill gives powers to require assessments to be
properly monitored to ensure they are
delivering the level of environmental
protection predicted in the EOR.
o If the anticipated levels are not met and
remediation is necessary, it will be pursued
and enforced.
Unlocking data
o Bill bringing forward the digitisation of
planning services.
o Re-use data collected through monitoring to
inform future assessments.
o Environmental data will be standardised
(and submitted in a form that enables
future re-use).
Performance Reporting
o Government seeking to increase transparency on the effectiveness of
assessment.
o Reporting on performance will allow us to better address issues as
they emerge, amending guidance as required.
o Authorities to provide ‘annual consolidated information’ on how plans
are delivering on outcomes - related to existing monitoring duties
Next steps
User-centred process
design
•Using feedback from this
consultation, government will
develop and refine the system
through continued engagement
Secondary legislation and
guidance
•Secondary legislation brought
forward following Royal Assent
•Guidance will be brought
forward to support this
Transition
•A transition period will likely be
required – this will be as time-
limited as is reasonable
Capacity and capability
•The government will support and
work with authorities to ensure
they have the necessary
capabilities and skills
How to Respond
Please respond by completing the Citizen
Space online survey
March 2021 local.gov.uk/pas
Environmental Outcome Reports
PAS work 2022/23
local.gov.uk/pas
What have
PAS done this
year?
We held a workshop
series of five events.
Overview and 4 deep
dives
Over 80 LPAs took part
We set up an officer network
Transition is coming!
Environmental
Assessment bridge to
EOR
We made a report
local.gov.uk/pas
10 Key Challenges Identified
10 Key Challenges identified
There is an acknowledged lack of in-house technical expertise on environmental assessment.
The current policy regime generates significant amounts of paperwork and documentation
Inconsistency of approach in environmental assessment (both EIA assessment and SA/SEA) is a significant barrier in the current environmental assessment
regime.
The scope of environmental assessment has become too broad and there is a need to refocus on the implications of the land use.
The current environmental assessment regime contains an inherent element of uncertainty, and this sits at odds with other elements of the planning
system.
Subjectivity clouds the overall ethos of what environmental assessment is trying to achieve.
There is a significant lack of access to robust and consistent data
There is a fundamental knowledge gap between what environmental assessment does and is and what policy is and does.
There is a lack of monitoring of the forecast impacts or mitigation
Councils aren’t ready for digital assessments
local.gov.uk/pas
The big issue
The lack of in-house technical expertise in
councils and that all parties involved struggle with
capacity and skills. The lack of environmental
expertise within the public sector is creating a
more widespread problem - a lack of confidence for
planners to have autonomy on decision making.
Planners feel unable to properly interrogate
assessments, expert opinions, statutory consultee
responses or stakeholder views due to a lack of
confidence and experience in this field and
therefore fear of legal challenge so become overly
cautious in decision making.
local.gov.uk/pas
So much paperwork!
 The current policy regime generates significant amounts
of paperwork and documentation
 In a nutshell the complexity of process and documentation
inhibits engagement.
 Prevalence of cut and paste or ‘spot the other authority’s
name’
 Local members and communities do not engage with the
scoring and pages of plus/minus type analysis
 The voluminous nature of technical evidence submitted
means that officers have difficulty accessing the pertinent
information on predicted environmental effects
local.gov.uk/pas
We all do it slightly differently
 Inconsistency of approach in environmental assessment
(both EIA assessment and SA/SEA) is a significant barrier in
the current environmental assessment regime.
 Whilst assessments use common themes as headings (e.g.
air, water) there is significant variance in the indicators
and datasets used within assessments
 Assessment authors ‘doing their own thing’ and setting the
assessment frameworks in a multitude of formats.
 An increasing tendency to include a multitude of locally
distinct indicators
local.gov.uk/pas
Environmental Assessment is trying
to do too much
 The scope of environmental assessment has become too
broad and there is a need to refocus on the implications
of the land use.
 Tendency for EIA to cover all conceivable impacts even
where those effects would not be of a scale or type that
would warrant inclusion in the EIA
 Catch-all lists for the types of impacts (direct, indirect,
secondary, synergistic, cumulative, etc.) that might need
to be covered in EIA/SEA.
 How far upstream or downstream do you go?????
local.gov.uk/pas
Certainty versus uncertainty
 The current environmental assessment regime contains an
inherent element of uncertainty, and this sits at odds with
other elements of the planning system
 Lots of elements are crystal ball gazing and predicting effects
and appropriate mitigation. Whereas planning, particularly
through Local Plan examination, requires certainty of delivery
and outcomes
 Plans and development proposals have a desired outcome, so
the uncertainty of effects is turned from ‘cloudy’ to ‘crystal
clear’ to fit with certainty needed for plans and examinations.
local.gov.uk/pas
Inherent bias in the process
 Subjectivity clouds the overall ethos of what
environmental assessment is trying to achieve.
 There is a lack of in-house technical expertise in councils.
This leads to technical evidence or statutory consultee
views being unchallenged by officers and a reliance on
accepting it at face value.
 All technical assessments will involve a degree of
subjectivity, as professionals will often disagree over
methods of data collection, analysis and interpretation.
For LPAs the key issue is having access to suitability
competent professionals across the various disciplines
 We heard that even if officers wish to challenge the
validity of technical evidence or the data it uses they are
cautioned against challenging it by their legal teams.
local.gov.uk/pas
Lack of reliable data
 There is a significant lack of access to robust and
consistent data
 There is a need for data to be trustworthy and
transparent over who owns and manages it
 Significant lack of data read across between strategy and
project level
 Direct quote from a participant - ‘We need to step away
from relying on less robust data and accept the data
flaws. EOR has the potential to simplify and de-risk the
process for us so we can have better conversations’
local.gov.uk/pas
 There is a fundamental knowledge gap between what
environmental assessment does and is and what policy is and
does.
 Consultants, officers, legal professionals, members and
the public conflate the environmental assessment on
whether a scheme is acceptable versus whether the
scheme is acceptable in planning policy terms
 There is confusion as to the purpose of SEA within plan
making, which has largely arisen as a consequence of the
conflation of SEA into SA
 It is not universally understood that is not the job of SEA
or SA to generate options for the Local Plan
Conflating the purpose
local.gov.uk/pas
No feedback loop
 There is a lack of monitoring of the forecasted impacts
or mitigation
 Monitoring is not resourced and therefore
• At the project level - limited to reactionary monitoring
when complaints are received.
• At the strategic level – limited to wider monitoring of
the plan with aspirational indicators or the monitoring
effects at a very high level with no tangible link to the
SA/SEA predictions
local.gov.uk/pas
Councils aren’t ready for digital
assessments
 We heard that councils had been prevented from accepting
digitally based, non-PDF, environmental assessment
(EIA/ES/SEA/SA) due to corporate IT departments. This included
things such as interactive 360 view site surveys and hydrology
simulations for flooding extents.
 The principal barrier appeared to be a reluctance to accept a
non-PDF format from a corporate stance and that planning
departments and officers were frustrated by this.
 The objection to accepting new digital based formats was that
are not ‘uploadable’ or ‘submittable’ in the same way a PDF is and
therefore limited how the council could make the document
available to the public and meet accessibility requirements. The
issues of councils not wishing to accept a format that was
externally hosted was also raised.
local.gov.uk/pas
Speakers
Dr Jessica Salder, Principal
Environmental Assessment Officer,
Surrey County Council, and
Lisa Kirby-Hawkes, Development
Planning Manager at Hampshire
County Council
Environmental Impacts
and Outcomes
Monitoring and Adaptation
in Mineral Site Management
and Restoration
Dr Jessica Salder MIEnvSc MIEMA CEnv
Principal Environmental Assessment Officer
Environmental impacts of surface mineral working
Surface mineral working – e.g. extraction of sands, gravels, clays,
building stones, etc. – is typically associated with a range of
environmental impacts including (but not limited to):
Changes in landscape character, form and coverage – both temporary
and permanent, short and long term, operational and post-development.
Changes in ecology, including habitat and species loss, and loss of
ecological connection – both temporary and permanent, short and long
term, operational and post-development.
Changes in the water environment, affecting surface and ground water
quality and flood risk – both temporary and permanent, short and long
term, operational and post-development.
Changes in air quality, including emissions of dust from site operations
and traffic – temporary, short-term, operational.
Monitoring and managing ecology and landscape impacts
In the short to medium term site preparation and mineral extraction causes:
• Habitat loss and associated impacts on species. Translocation may be an option
for some animal species (e.g. Great crested newts, reptiles, etc.) but for most
animal and plant species the impacts will be adverse due to the fundamental
change in land cover and use. Where areas of key habitat - e.g. Ancient
woodland, veteran trees - are retained whilst the quarry is operational,
monitoring ensures that protective measures (e.g. canopy or root protection
zones, buffer zones, etc.) are implemented.
• Changes in landform, cover and character due to vegetation removal, soil
stripping, void creation, and the introduction of processing facilities, haul roads,
bunds, and other site infrastructure. Where bunds and/or planting are deployed
to mitigate operational visual impacts monitoring ensures that such measures
are effective.
Monitoring and managing ecology and landscape impacts
Restoration schemes set out long term visions for mineral sites. Schemes may
need to be amended in response to external factors over the project’s lifetime. The
MPAs restoration and enhancement specialists work with mineral operators to
monitor, evaluate, review and adapt restoration schemes as necessary.
Restoration of mineral sites can deliver:
• biodiversity gains – creating habitats that support a greater diversity of plant
and animal species than those present prior to mineral working, and providing
links between areas of habitat that have become isolated.
• landscape enhancement – infilling and regrading can deliver landforms and
features appropriate to the site and setting; planting schemes are designed to
respond and link to the landscape character of the wider area.
Landscape and ecology management plans form the basis for ongoing and longer-
term monitoring and management of restored mineral sites.
Monitoring and managing water environment impacts
Changes in water quality and flows arise during and after mineral extraction, on-
site and in the surrounding area.
• Groundwater flows are affected where sites are lined and infilled.
• Surface watercourses or waterbodies may require temporary or permanent
redirection or relocation, and unfilled voids can form new waterbodies.
• Process water, from washing and grading, with high silt content requires storage
in settlement ponds before release to the wider water environment.
• The site’s flood risk characteristics may change with implications for the
surrounding area.
Surface water and groundwater monitoring and assessment plans are used to
monitor operational impacts. Such plans are secured by condition, and include
trigger levels and plans for remedial action. For example, where maximum
excavation depths are specified to protect underlying groundwater resources
groundwater levels are monitored, breaches are reported to the MPA, the
maximum quarrying depth is altered as necessary, and areas of over-extraction are
backfilled with indigenous material.
Monitoring and managing dust
Dust emissions arise during site preparation and active quarrying – from soil
stripping, mineral extraction, mineral processing, vehicle movements on haul roads
and the highway network.
Dust management and action plans are used to monitor and manage operational
impacts. Monitoring and management are undertaken by the site operator.
• Mitigation can include: Wet working of extraction areas; Wetting of working and
processing areas, stockpiles and haul roads; Use of wheel-wash facilities and
sheeting of loads.
• Monitoring can include: On-site logging of rainfall, wind speed and wind direction;
Regular (e.g. quarterly, monthly, fortnightly, etc.) monitoring of dust deposition at
agreed locations around the site (e.g. residences, schools, community facilities,
etc.) against agreed action levels (e.g. monthly average deposition rate, annual
average concentration).
Regular monitoring by planners and complaints from neighbours also help identify
instances of non-compliance and enable corrective action to be taken.
Key messages:
• Monitoring requirements should be built
into planning permissions
• Monitoring of operational impacts is best
undertaken by site operators with MPA
oversight
• Restoration monitoring benefits from a
partnership approach involving MPA
specialists and site operators
• Effective restoration monitoring enables
adaptation to changes in site conditions or
wider circumstances
EOR Webinar 2023: PAS Support
Monitoring of environmental outcomes
for minerals development
A Minerals & Waste Planning Authority Perspective
30 March 2023
Lisa Kirby-Hawkes - Development Planning Manager
Role & how
we monitor
Delivering
environmental
outcomes
Case study
What we will cover
Role & how we monitor
Minerals and Waste Planning
Authority
Proactive monitoring /
enforcement function
Fee paying site visits for minerals
and landfills
Monitoring assisted by other
disciplines and agencies e.g.
ecology, landscape / EA etc
Delivering environmental
outcomes during & through
restoration
MPA Quarries & Nature 2021 … A
50 year success story - Complete
Show - YouTube
Environmental enhancement is
bread and butter for minerals
Long history of delivery both during
AND after development (restoration
/ aftercare)
Environmental impacts assessed
during application - frame
environmental outcomes
Importance of planning conditions /
legal agreements
Plumley Wood Quarry
https://planning.hants.gov.uk/Planning/Display/08/91952
Sand and gravel quarry with restoration to
agriculture, nature conservation and amenity
EIA development granted permission in 2008
Operational since 2009, end date 2025
Actively monitored - 4 visits per year Subject
to a site liaison panel
WORKING
PROGRAMME /
PHASING,
TIMESCALES
NOISE LIMITS,
TEMPORARY
NOISE, LIMITS,
VEHICLE
ALARMS
DUST
MONITORING
LIGHTING
SCHEME
CONVEYOR,
MUD ON ROAD,
ACCESS
CONDITION,
ACCESS
CHANGES
WORKING
DEPTH,
DEWATERING,
STORAGE OF
OILS / FUELS,
NEW SLUICE
Conditions
TREE
PROTECTION,
BUNDS, SOILS,
PLANTING,
WEED CONTROL
CLEARANCE,
SURVEYS,
REPTILE
TRANSLOCATIO
N,
HISTORIC
ENVIRONMENT
REPORT
RESTORATION /
AFTERCARE
PLAN,
SPECIFICATION
HOURS OF
WORKING,
WASH PLANT
CONDITION,
CONVEYOR
IMPORTATION
OF INERT,
RECYCLED
AGGREGATE
LEVELS
Plumley Wood Quarry
Plumley Wood Quarry
Legal agreement for
long-term nature
conservation
management and
mitigation, a new public
right of way, highway
contribution,
hydrological monitoring
and woodland
retention.
Subject to 50 year long term
nature conservation
management of Burnt Hill post
restoration / completion – 80
years!
Links to Blue Haze
heathland
restoration
Onsite
Heathland
restoration
Dormice corridor
Existing Farm
building
Plumley Wood Quarry
Other key features:
Reinstatement of Mire habitats
Active management / clearance
Management of historic environment
finds – kilns etc
Management of the diversions of the
ROW
Plumley Wood Quarry
Other key features (cont):
New application likely (end date)
– may look to amend phasing
and restoration reflecting
changes during life of the
development
Protection species e.g. bats, Dormice
(licence), reptiles (translocation)
Plumley Wood Quarry
Ensuring successful delivery:
Applicant provides annual reports and
quarterly hydrological monitoring
reports
Review undertaken other specialists
Working alongside other agencies
(e.g. EA)
Interaction with other disciplines (e.g.
OWCs)
Summary points
Minerals development already
delivers environmental outcomes
Importance of building outcomes
into permissions (effective
conditions / long term
management) – this is deliverable!
Partnership working is critical in
delivery
Effective monitoring is essential to
delivery – adaptation /
amendments may be required
Thank You
Lisa Kirby-Hawkes: Development Planning Manager
(Hampshire County Council) –
lisa.kirby.hawkes@hants.gov.uk
local.gov.uk/pas
What’s next?
Recording and slides available
PAS webpages on the research project
are already available
Future engagement some focussed on
LPA and some wider
Consultation closes 9th June
local.gov.uk/pas
Subscribe to our bulletin
www.local.gov.uk/pas
It is where we announce new materials and events.
See also @pas_team

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EOR Webinar PAS presentation slidesFINAL.pptx

  • 1. March 2021 local.gov.uk/pas Environmental Outcome Reports Consultation Webinar 30th March We will begin shortly
  • 2. local.gov.uk/pas This session  Information giving  Hear from DLUHC (Kim Harding)  PAS work on environmental assessment so far (Shelly Rouse)  Hear from two local authorities doing environmental monitoring  Dr Jessica Salder, Principal Environmental Assessment Officer, Surrey County Council, and  Lisa Kirby-Hawkes, Development Planning Manager at Hampshire County Council
  • 3. local.gov.uk/pas Planning Advisory Service (PAS)  Team of 13  Part of Local Government family  Funded by DLUHC and Defra to support English planning authorities “PAS exists to support local planning authorities in providing effective and efficient planning services and to support the implementation of changes in the planning system”
  • 4. local.gov.uk/pas What we do  Training events and workshops  Web-based resources and guidance  Newsletter = 8000 recipients  Official officer and councillor peer network  Unofficial network of friends and advisors  Brand new experimental learning networks:  NSIP, environment, developer contributions, digital  Also work with individual councils and offer ‘peer challenge’ reviews  Our work programme for 2022/23 includes design, developer contributions, Local Plans, development management designation and nutrient neutrality
  • 5. Environmental Outcomes Reports: a new approach to environmental assessment Consultation and Q&A Consultation closes 9 June 2023
  • 6. • Levelling Up and Regeneration Bill (LURB) seeks powers for a new framework for environmental assessment. • Royal Assent 2023. • Consultation - initial thinking on how the powers in the Bill could be used to deliver a more streamlined and effective system.
  • 7. • Environmental Assessment of Plans and Programmes 2004 (‘SEA Regs’) • TCPA (Environmental Impact Assessment) Regs 2017 • Infrastructure Planning (NSIP) (EIA) Regs 2017 • EIA (Agriculture) Regs 2006 (and 2017) • EIA (Forestry) Regs 1999 (and 2017) • EIA (Land Drainage Improvement Works) Regs 1999 (and 2017) • Water Resources (EIA) Regs 2003 • The Marine Works (EIA) Regs 2007/1518 • Harbours Act 1964, Schedule 3 (I) • Highways Act 1980, Part VA • The Transport and Works Act 1992, (sections 13A, 13B, 13C and 13D) • The Transport and Works (Applications and Objections Procedure) Rules 2006 • Electricity Works (EIA) Regs 2017 • Public Gas Transporter Pipe-Lines Works (EIA) Regs 1999 • Pipe-line Works (EIA) Regs 2000 • Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regs 1999 • Offshore Oil and Gas Exploration, Production, Unloading and Storage (EIA) Regs 2020 • Nuclear Reactors (EIA for Decommissioning) Regs 1999
  • 8. What We Heard … box-ticking exercise…. …. in case of legal challenge ….. …. it doesn’t actually add that much value as a lot of the information would be done anyway… …… I don’t actually read it myself …. ……the concept is good …… …it doesn’t need to include the ‘human stuff’ as that is already taken care of ….. ….its the data ….. …would be good to know if our mitigation actually worked …. …..if you could get it working as a design tool ?….. …..don’t trust the findings …
  • 10. An outcomes-based approach o Secretary of State sets outcomes which a plan or project will have to report against. o High level o Set in regulations with supporting suite of indicators (in guidance). o Stem from the Environment Improvement Plan 2023 o Be measurable (at the correct scale) o Be monitored
  • 11. Outcomes and Indicators Possible outcomes • Biodiversity • Air quality • Landscape and seascape • Geodiversity, soil and sediment • Noise and vibration • Water • Waste • Cultural heritage and archaeology
  • 12. Scoping Options to improve scoping….. Proportionate reporting against outcomes ? • Minimal assessment of the outcome in circumstances where full assessment not required? • Rare that the core outcomes are not relevant at all
  • 13. The Report Better alignment between strategic and project scale • Standardised approach to assessment across spatial scales working towards common set of outcomes • Streamlined process, avoiding repetition • Regular strategic/plan-level monitoring Reports pinpoint conclusions in technical work • Reduced size & complexity of reports through focus on outcomes • Reports will pinpoint conclusions in underlying technical work • Confidence levels for predictions and mitigations Early assessment of alternatives • Design tool • Reduce confusion around alternatives, ensuring assessed at an early stage • High level summary record of key dates in decision-making on alternatives & application of mitigation hierarchy
  • 14. When (Screening) • Updated lists • Proximity to a sensitive site overwhelming reason for requiring an environmental assessment? • How to incorporate?
  • 15. Mitigation Avoid Mitigate Compensate o Mitigation hierarchy now law o Must be considered in assessment of alternatives early in the process and reviewed, as the plan or project evolves. o Issue of ineffective mitigation or unanticipated effects of mitigation o Should we use adaptive management to allow mitigation to be adjusted (up or down) in response to greater certainty on effects following implementation? http://lindtoons.com
  • 16. Mainstreaming monitoring o Everyone agrees key – some say most important part of process (given lack of data & nature & complexities of implementing development) o Bill gives powers to require assessments to be properly monitored to ensure they are delivering the level of environmental protection predicted in the EOR. o If the anticipated levels are not met and remediation is necessary, it will be pursued and enforced.
  • 17. Unlocking data o Bill bringing forward the digitisation of planning services. o Re-use data collected through monitoring to inform future assessments. o Environmental data will be standardised (and submitted in a form that enables future re-use).
  • 18. Performance Reporting o Government seeking to increase transparency on the effectiveness of assessment. o Reporting on performance will allow us to better address issues as they emerge, amending guidance as required. o Authorities to provide ‘annual consolidated information’ on how plans are delivering on outcomes - related to existing monitoring duties
  • 19. Next steps User-centred process design •Using feedback from this consultation, government will develop and refine the system through continued engagement Secondary legislation and guidance •Secondary legislation brought forward following Royal Assent •Guidance will be brought forward to support this Transition •A transition period will likely be required – this will be as time- limited as is reasonable Capacity and capability •The government will support and work with authorities to ensure they have the necessary capabilities and skills
  • 20. How to Respond Please respond by completing the Citizen Space online survey
  • 21. March 2021 local.gov.uk/pas Environmental Outcome Reports PAS work 2022/23
  • 22. local.gov.uk/pas What have PAS done this year? We held a workshop series of five events. Overview and 4 deep dives Over 80 LPAs took part We set up an officer network Transition is coming! Environmental Assessment bridge to EOR We made a report
  • 23. local.gov.uk/pas 10 Key Challenges Identified 10 Key Challenges identified There is an acknowledged lack of in-house technical expertise on environmental assessment. The current policy regime generates significant amounts of paperwork and documentation Inconsistency of approach in environmental assessment (both EIA assessment and SA/SEA) is a significant barrier in the current environmental assessment regime. The scope of environmental assessment has become too broad and there is a need to refocus on the implications of the land use. The current environmental assessment regime contains an inherent element of uncertainty, and this sits at odds with other elements of the planning system. Subjectivity clouds the overall ethos of what environmental assessment is trying to achieve. There is a significant lack of access to robust and consistent data There is a fundamental knowledge gap between what environmental assessment does and is and what policy is and does. There is a lack of monitoring of the forecast impacts or mitigation Councils aren’t ready for digital assessments
  • 24. local.gov.uk/pas The big issue The lack of in-house technical expertise in councils and that all parties involved struggle with capacity and skills. The lack of environmental expertise within the public sector is creating a more widespread problem - a lack of confidence for planners to have autonomy on decision making. Planners feel unable to properly interrogate assessments, expert opinions, statutory consultee responses or stakeholder views due to a lack of confidence and experience in this field and therefore fear of legal challenge so become overly cautious in decision making.
  • 25. local.gov.uk/pas So much paperwork!  The current policy regime generates significant amounts of paperwork and documentation  In a nutshell the complexity of process and documentation inhibits engagement.  Prevalence of cut and paste or ‘spot the other authority’s name’  Local members and communities do not engage with the scoring and pages of plus/minus type analysis  The voluminous nature of technical evidence submitted means that officers have difficulty accessing the pertinent information on predicted environmental effects
  • 26. local.gov.uk/pas We all do it slightly differently  Inconsistency of approach in environmental assessment (both EIA assessment and SA/SEA) is a significant barrier in the current environmental assessment regime.  Whilst assessments use common themes as headings (e.g. air, water) there is significant variance in the indicators and datasets used within assessments  Assessment authors ‘doing their own thing’ and setting the assessment frameworks in a multitude of formats.  An increasing tendency to include a multitude of locally distinct indicators
  • 27. local.gov.uk/pas Environmental Assessment is trying to do too much  The scope of environmental assessment has become too broad and there is a need to refocus on the implications of the land use.  Tendency for EIA to cover all conceivable impacts even where those effects would not be of a scale or type that would warrant inclusion in the EIA  Catch-all lists for the types of impacts (direct, indirect, secondary, synergistic, cumulative, etc.) that might need to be covered in EIA/SEA.  How far upstream or downstream do you go?????
  • 28. local.gov.uk/pas Certainty versus uncertainty  The current environmental assessment regime contains an inherent element of uncertainty, and this sits at odds with other elements of the planning system  Lots of elements are crystal ball gazing and predicting effects and appropriate mitigation. Whereas planning, particularly through Local Plan examination, requires certainty of delivery and outcomes  Plans and development proposals have a desired outcome, so the uncertainty of effects is turned from ‘cloudy’ to ‘crystal clear’ to fit with certainty needed for plans and examinations.
  • 29. local.gov.uk/pas Inherent bias in the process  Subjectivity clouds the overall ethos of what environmental assessment is trying to achieve.  There is a lack of in-house technical expertise in councils. This leads to technical evidence or statutory consultee views being unchallenged by officers and a reliance on accepting it at face value.  All technical assessments will involve a degree of subjectivity, as professionals will often disagree over methods of data collection, analysis and interpretation. For LPAs the key issue is having access to suitability competent professionals across the various disciplines  We heard that even if officers wish to challenge the validity of technical evidence or the data it uses they are cautioned against challenging it by their legal teams.
  • 30. local.gov.uk/pas Lack of reliable data  There is a significant lack of access to robust and consistent data  There is a need for data to be trustworthy and transparent over who owns and manages it  Significant lack of data read across between strategy and project level  Direct quote from a participant - ‘We need to step away from relying on less robust data and accept the data flaws. EOR has the potential to simplify and de-risk the process for us so we can have better conversations’
  • 31. local.gov.uk/pas  There is a fundamental knowledge gap between what environmental assessment does and is and what policy is and does.  Consultants, officers, legal professionals, members and the public conflate the environmental assessment on whether a scheme is acceptable versus whether the scheme is acceptable in planning policy terms  There is confusion as to the purpose of SEA within plan making, which has largely arisen as a consequence of the conflation of SEA into SA  It is not universally understood that is not the job of SEA or SA to generate options for the Local Plan Conflating the purpose
  • 32. local.gov.uk/pas No feedback loop  There is a lack of monitoring of the forecasted impacts or mitigation  Monitoring is not resourced and therefore • At the project level - limited to reactionary monitoring when complaints are received. • At the strategic level – limited to wider monitoring of the plan with aspirational indicators or the monitoring effects at a very high level with no tangible link to the SA/SEA predictions
  • 33. local.gov.uk/pas Councils aren’t ready for digital assessments  We heard that councils had been prevented from accepting digitally based, non-PDF, environmental assessment (EIA/ES/SEA/SA) due to corporate IT departments. This included things such as interactive 360 view site surveys and hydrology simulations for flooding extents.  The principal barrier appeared to be a reluctance to accept a non-PDF format from a corporate stance and that planning departments and officers were frustrated by this.  The objection to accepting new digital based formats was that are not ‘uploadable’ or ‘submittable’ in the same way a PDF is and therefore limited how the council could make the document available to the public and meet accessibility requirements. The issues of councils not wishing to accept a format that was externally hosted was also raised.
  • 34. local.gov.uk/pas Speakers Dr Jessica Salder, Principal Environmental Assessment Officer, Surrey County Council, and Lisa Kirby-Hawkes, Development Planning Manager at Hampshire County Council
  • 35. Environmental Impacts and Outcomes Monitoring and Adaptation in Mineral Site Management and Restoration Dr Jessica Salder MIEnvSc MIEMA CEnv Principal Environmental Assessment Officer
  • 36. Environmental impacts of surface mineral working Surface mineral working – e.g. extraction of sands, gravels, clays, building stones, etc. – is typically associated with a range of environmental impacts including (but not limited to): Changes in landscape character, form and coverage – both temporary and permanent, short and long term, operational and post-development. Changes in ecology, including habitat and species loss, and loss of ecological connection – both temporary and permanent, short and long term, operational and post-development. Changes in the water environment, affecting surface and ground water quality and flood risk – both temporary and permanent, short and long term, operational and post-development. Changes in air quality, including emissions of dust from site operations and traffic – temporary, short-term, operational.
  • 37. Monitoring and managing ecology and landscape impacts In the short to medium term site preparation and mineral extraction causes: • Habitat loss and associated impacts on species. Translocation may be an option for some animal species (e.g. Great crested newts, reptiles, etc.) but for most animal and plant species the impacts will be adverse due to the fundamental change in land cover and use. Where areas of key habitat - e.g. Ancient woodland, veteran trees - are retained whilst the quarry is operational, monitoring ensures that protective measures (e.g. canopy or root protection zones, buffer zones, etc.) are implemented. • Changes in landform, cover and character due to vegetation removal, soil stripping, void creation, and the introduction of processing facilities, haul roads, bunds, and other site infrastructure. Where bunds and/or planting are deployed to mitigate operational visual impacts monitoring ensures that such measures are effective.
  • 38. Monitoring and managing ecology and landscape impacts Restoration schemes set out long term visions for mineral sites. Schemes may need to be amended in response to external factors over the project’s lifetime. The MPAs restoration and enhancement specialists work with mineral operators to monitor, evaluate, review and adapt restoration schemes as necessary. Restoration of mineral sites can deliver: • biodiversity gains – creating habitats that support a greater diversity of plant and animal species than those present prior to mineral working, and providing links between areas of habitat that have become isolated. • landscape enhancement – infilling and regrading can deliver landforms and features appropriate to the site and setting; planting schemes are designed to respond and link to the landscape character of the wider area. Landscape and ecology management plans form the basis for ongoing and longer- term monitoring and management of restored mineral sites.
  • 39. Monitoring and managing water environment impacts Changes in water quality and flows arise during and after mineral extraction, on- site and in the surrounding area. • Groundwater flows are affected where sites are lined and infilled. • Surface watercourses or waterbodies may require temporary or permanent redirection or relocation, and unfilled voids can form new waterbodies. • Process water, from washing and grading, with high silt content requires storage in settlement ponds before release to the wider water environment. • The site’s flood risk characteristics may change with implications for the surrounding area. Surface water and groundwater monitoring and assessment plans are used to monitor operational impacts. Such plans are secured by condition, and include trigger levels and plans for remedial action. For example, where maximum excavation depths are specified to protect underlying groundwater resources groundwater levels are monitored, breaches are reported to the MPA, the maximum quarrying depth is altered as necessary, and areas of over-extraction are backfilled with indigenous material.
  • 40. Monitoring and managing dust Dust emissions arise during site preparation and active quarrying – from soil stripping, mineral extraction, mineral processing, vehicle movements on haul roads and the highway network. Dust management and action plans are used to monitor and manage operational impacts. Monitoring and management are undertaken by the site operator. • Mitigation can include: Wet working of extraction areas; Wetting of working and processing areas, stockpiles and haul roads; Use of wheel-wash facilities and sheeting of loads. • Monitoring can include: On-site logging of rainfall, wind speed and wind direction; Regular (e.g. quarterly, monthly, fortnightly, etc.) monitoring of dust deposition at agreed locations around the site (e.g. residences, schools, community facilities, etc.) against agreed action levels (e.g. monthly average deposition rate, annual average concentration). Regular monitoring by planners and complaints from neighbours also help identify instances of non-compliance and enable corrective action to be taken.
  • 41. Key messages: • Monitoring requirements should be built into planning permissions • Monitoring of operational impacts is best undertaken by site operators with MPA oversight • Restoration monitoring benefits from a partnership approach involving MPA specialists and site operators • Effective restoration monitoring enables adaptation to changes in site conditions or wider circumstances
  • 42. EOR Webinar 2023: PAS Support Monitoring of environmental outcomes for minerals development A Minerals & Waste Planning Authority Perspective 30 March 2023 Lisa Kirby-Hawkes - Development Planning Manager
  • 43. Role & how we monitor Delivering environmental outcomes Case study What we will cover
  • 44. Role & how we monitor Minerals and Waste Planning Authority Proactive monitoring / enforcement function Fee paying site visits for minerals and landfills Monitoring assisted by other disciplines and agencies e.g. ecology, landscape / EA etc
  • 45. Delivering environmental outcomes during & through restoration MPA Quarries & Nature 2021 … A 50 year success story - Complete Show - YouTube Environmental enhancement is bread and butter for minerals Long history of delivery both during AND after development (restoration / aftercare) Environmental impacts assessed during application - frame environmental outcomes Importance of planning conditions / legal agreements
  • 46. Plumley Wood Quarry https://planning.hants.gov.uk/Planning/Display/08/91952 Sand and gravel quarry with restoration to agriculture, nature conservation and amenity EIA development granted permission in 2008 Operational since 2009, end date 2025 Actively monitored - 4 visits per year Subject to a site liaison panel
  • 47. WORKING PROGRAMME / PHASING, TIMESCALES NOISE LIMITS, TEMPORARY NOISE, LIMITS, VEHICLE ALARMS DUST MONITORING LIGHTING SCHEME CONVEYOR, MUD ON ROAD, ACCESS CONDITION, ACCESS CHANGES WORKING DEPTH, DEWATERING, STORAGE OF OILS / FUELS, NEW SLUICE Conditions TREE PROTECTION, BUNDS, SOILS, PLANTING, WEED CONTROL CLEARANCE, SURVEYS, REPTILE TRANSLOCATIO N, HISTORIC ENVIRONMENT REPORT RESTORATION / AFTERCARE PLAN, SPECIFICATION HOURS OF WORKING, WASH PLANT CONDITION, CONVEYOR IMPORTATION OF INERT, RECYCLED AGGREGATE LEVELS Plumley Wood Quarry
  • 48. Plumley Wood Quarry Legal agreement for long-term nature conservation management and mitigation, a new public right of way, highway contribution, hydrological monitoring and woodland retention. Subject to 50 year long term nature conservation management of Burnt Hill post restoration / completion – 80 years!
  • 49. Links to Blue Haze heathland restoration Onsite Heathland restoration Dormice corridor Existing Farm building
  • 50. Plumley Wood Quarry Other key features: Reinstatement of Mire habitats Active management / clearance Management of historic environment finds – kilns etc Management of the diversions of the ROW
  • 51. Plumley Wood Quarry Other key features (cont): New application likely (end date) – may look to amend phasing and restoration reflecting changes during life of the development Protection species e.g. bats, Dormice (licence), reptiles (translocation)
  • 52. Plumley Wood Quarry Ensuring successful delivery: Applicant provides annual reports and quarterly hydrological monitoring reports Review undertaken other specialists Working alongside other agencies (e.g. EA) Interaction with other disciplines (e.g. OWCs)
  • 53. Summary points Minerals development already delivers environmental outcomes Importance of building outcomes into permissions (effective conditions / long term management) – this is deliverable! Partnership working is critical in delivery Effective monitoring is essential to delivery – adaptation / amendments may be required
  • 54. Thank You Lisa Kirby-Hawkes: Development Planning Manager (Hampshire County Council) – lisa.kirby.hawkes@hants.gov.uk
  • 55. local.gov.uk/pas What’s next? Recording and slides available PAS webpages on the research project are already available Future engagement some focussed on LPA and some wider Consultation closes 9th June
  • 56. local.gov.uk/pas Subscribe to our bulletin www.local.gov.uk/pas It is where we announce new materials and events. See also @pas_team

Editor's Notes

  1. Team of 13 – Planning and Green Wing, made up of Planners, non-planners, and secondees Part of Local Government family – actually part of something called the LGA. Umbrella organisation to support councils across all functions (child and adult social services, finances, housing registers, benefits etc) PAS is the slightly different branded Planning arm Funded by DLUHC and Defra to support English planning authorities – We are robin hoods – take £££ from the gov and spend it on helping the public sector. “PAS exists to support local planning authorities in providing effective and efficient planning services and to support the implementation of changes in the planning system” Basically we try and lift everyone up to make things better for all.
  2. Team of 13 – Planning and Green Wing, made up of Planners, non-planners, and secondees Part of Local Government family – actually part of something called the LGA. Umbrella organisation to support councils across all functions (child and adult social services, finances, housing registers, benefits etc) PAS is the slightly different branded Planning arm Funded by DLUHC and Defra to support English planning authorities – We are robin hoods – take £££ from the gov and spend it on helping the public sector. “PAS exists to support local planning authorities in providing effective and efficient planning services and to support the implementation of changes in the planning system” Basically we try and lift everyone up to make things better for all.
  3. We are small organisation but with a big voice – we are the thinking space that others might not have And we do that in the following ways Training events and workshops Web-based resources and guidance Newsletter = 8000 recipients Official officer and councillor peer network Unofficial network of friends and advisors Brand new Basecamp experimental learning networks: NSIP, environment, developer contributions, digital Also work with individual councils and offer ‘peer challenge’ reviews Our work programme for 2022/23 includes design, developer contributions, Local Plans, development management designation and nutrient neutrality Basically we make things We are the MOT mechanics We are the AA We do loads of behind the scenes stuff to bring local and national government together.
  4. Thanks Shelly. I am Kim Harding. I am the Team Leader for environmental assessment at DLUHC. I am a planner of over 20 years experience. I have worked in the public sector (local government and in a consultee body) and also as a consultant in private practice writng environmental assessments. The first thing I have to say that this presentation comes with a big health warning. The Levelling Up and Regeneration Bill, which gives us the powers to make these reforms, has not yet received royal assent, so it could change. This is also not Government policy, being an area of active policy development. We are taking a test and learn approach to reform. That requires honest conversations about what works and what doesn’t, what we can and cant deliver, and what we need to do collectively to make these processes work effectively. Also most of what I say today is what we plan on testing through the Town and Country Planning and NSIP regimes, the other assessment regimes may or may not take a different approach. This is your first chance to influence the change (assuming you haven’t been involved already). We started actively engaging on this last year and thanks to those of you who participated in our work to date. To those of you who we haven’t yet approached – we are getting to you. We asked users about their experience of the processes but particularly what worked for them and what didn’t. Its safe to say that almost everyone we have talked to so far, agreed that, while the concept of environmental assessment was good, it was time for reform. We also have looked at what is happening on environmental assessment internationally. But we did have a few changes last year and that affected has meant that our programme has slipped slightly.
  5. So where are we at right now? Leaving the European Union presented us with a once in a lifetime opportunity to address widely held and long-standing dissatisfaction around the performance of the EU derived environmental assessment regimes. We are looking to keep what works and create an improved framework of assessment which properly reflects the unique nature of the UK environment.
  6. This is not just about planning – there are 18 different environmental assessment regimes and we are seeking views from stakeholders across all regimes. To maximise efficiencies and reduce duplication, the government will identify opportunities to take a single approach across regimes wherever possible. It will be up to the individual departments to bring forward regulations and guidance to implement EORs for their respective regimes.
  7. These are the messages from the user research and engagement to date. Once we started the conversation we found that almost everyone acknowledged there is now a need for reform of some sort.  This is primarily due to the sheer volume of documentation being produced, but also because there are some serious questions about the effectiveness of the processes.
  8. This is the major change – we are moving towards reporting on contribution to outcomes, measured using indicators. This will ensure that plans and developments support our goals set out in the Environmental Improvement Plan. We are moving away from reporting on the ‘likely significance’ of an effect.
  9. This sets out our starting point for matters that could be candidates for outcomes. The government expects that the matters not in this list will be picked through regime specific outcomes, in accordance with the specific legislative and policy framework, and pressures and needs, of each regime. We will need to be able to measure how a development contributes to the delivery of an outcome and propose to do this using existing indicators and quantitative data wherever possible. Defra currently have an Outcome Indicator Framework of 66 indicators and we expect that this will be our starting point. We are not trying to reinvent the wheel, as the data held in those indicator sets is valuable to us.
  10. The next subsection talks about scoping – which is a huge issue. You may know that the purpose of scoping is to reduce the breadth of issues to be assessed. Users told us that the scoping process is driven by fear of legal challenge, and this is preventing all parties from reducing what matters should be considered in the assessment. There is some good scoping practice out there – but it is very much the exception rather than the rule. To overcome the issue of scoping not scoping out, we will test an approach where applicants report on the performance of projects or plans against all relevant outcomes on a proportionate basis.
  11. Section 5 – covers what should be in the report. We know that reports are too big. Many find the size of reports daunting, methodologies difficult to follow and conclusions on the ‘likely significance’ of an effect subjective, vague and non-committal. The volume of material means important details can be buried in technical appendices.
  12. Section 6 talks about screening. This is actually the biggest area of legal challenge. Our reforms aims to increase certainty over when an assessment is required.  Regulations will be more prescriptive on what needs an assessment and what doesn’t, and we will also set a clearer framework for how borderline cases should be considered. We anticipate that clearer process should mean that these plans and projects are easier to identify as the uncertainties stemming from the current schedules are reduced. As now, the greater the potential impact on the environment, and the greater the probability that the plan or project will require an environmental assessment. We are also exploring whether and how, we could better use proximity, to a sensitive receptor via a defined impact pathway as a screening criteria. For example, the potential effects on a particular species could be used as the starting point for considering whether an assessment is required, instead of, a simple project size threshold. This would place protecting sensitive sites and species at the heart of all screening activity, with the scale of development as the secondary consideration.
  13. The environment is a complex system and we do not have full knowledge about how it works. There are lots of known unknowns and unknown unknowns (to quote NASA). This makes it hard to be certain of the effects of future plans or projects on it. There is academic research that suggests that predictions of impacts in assessments are far more uncertain than they appear, and confidence in the effectiveness of proposed mitigation measures may be misplaced.
  14. Section 8 is on monitoring – so the purpose of the monitoring is to verify whether the effects are as predicted in the assessment, and mitigation to address issues arising has been implemented as proposed. We found that monitoring is rarely done well, if it is done at all, with the exception being minerals and waste planning authorities. Projects also evolve as they are implemented, and mitigation measures may also, in themselves, have unintended consequences, not known at the time of the decision. Continuing high levels of scientific uncertainty mean that many users, academics and practitioners now regard it as the most important element of environmental assessment.
  15. Section 9 asks questions about data and how we can make that work better. Issues with data are universal throughout all regimes, with there being mostly too little but also occasionally too much but not actually the data needed for the assessment.  The Bill will bring forward the digitisation of planning services. We feel that digitisation, increasing online access, and unlocking issues with data is essential to a simpler, faster and more effective environmental assessment process. Collecting and reusing data will help to close the cycle of assessment – taking it from a linear process to a circular one.
  16. The government seeks to increase transparency on the effectiveness of the assessment processes so we can ensure that the system is delivering as it should for the environment and communities. Section 10 talks about reporting – part of our focus is to make the effectiveness of the processes more transparent.
  17. Finally, Section 11 talks about next steps including our intention to progress the reforms through user-centred design.  Our primary focus is to make sure the processes of assessment are fit for purpose, and effective. Secondary Legislation and guidance Regulations will be drafted by the different regime owners and brought forward via secondary legislation for consultation following Royal Assent. Guidance will be developed and brought forward to support the secondary legislation. Transition The government expects that a transition period will be required because of the lead times in developing plans and projects. Capacity and capability The government will support and work with authorities to ensure that authorities have the capability and skills to provide an efficient service and feel confident they can protect our environment and deliver levelling up.
  18. Please respond via Citizen Space which is the department’s online consultation portal and our preferred route for receiving consultation responses.
  19. It has become impenetrable. Hunting for the right information on what the impacts actually are. Lots of cut and paste in both EIA and SA/SEA. Communities and member can’t engage and leads to lots of objections to plans.
  20. Every ES is slightly different in format, data and content. Lots of extra details get added. SA has expanded to include lots of locally distinct matrices.
  21. For example, in a climate change context there is a lack of guidance in relation to the scoping in or out of GHG emissions and how far up or down the value chain an assessment should go - for example – for upstream emissions - should you consider the GHG impacts of mining and smelting the iron that creates the iron components of an aircraft?  for downstream emissions should the GHG assessment for an aircraft manufacturing facility include the likely lifetime emissions of each aircraft produced?  
  22. Unknowns and predictions don’t always sit well with the certainty needed to confidently issues consents or find a plan sound and deliverable.
  23. EIA and ES should be questioned and assessed for its content. They are prepared by competent experts but there will always be subjectivity and inherent bias towards justifying the development. SA/SEA too is subjective, what one person might judge as a + someone else might judge as++ or neutral.
  24. We heard of 30yr old bore data being accepted. There is no set data that is kept up-to-date available for use.
  25. We hear an example where a councillor was unable to separate the EIA process from the landscape and other environmental impacts the proposal had in policy terms 
  26. are, taking some action and future proofing
  27. are, taking some action and future proofing
  28. are, taking some action and future proofing