Environmental Impact Assessment presentations/20170926 RH NG.pdf20 Environmental Impact Assessment |...
Transcript of Environmental Impact Assessment presentations/20170926 RH NG.pdf20 Environmental Impact Assessment |...
Environmental Impact Assessment
Digital Assessment
IEMA Webinar
Rufus HowardBSc LLM FIEMA CEnv PEIA MIoD
26th September 2017
Environmental Impact Assessment | 26th September 2017 | Rufus Howard
What has it got to do with you?
Director of Sustainable Development RHDHV
Chairman of IEMA Impact Assessment Network
IEMA Strategic Advisory Board
Registered Principal EIA Practitioner
Chartered Environmentalist and Fellow of IEMA
Env. Man. BSc & Env. Law Masters; PhD in Management
Advising the World Bank on the development of a global ESIA Accreditation System for the new ESF
Leading the Industry Evidence Programme: Offshore Wind
Environmental Impact Assessment | 26th September 2017 | Rufus Howard
A focus for UK’s IA Network & QMark
Environmental Impact Assessment | 26th September 2017 | Rufus Howard
The State of EIA
IEMA Special Report 2011
“Long Environmental Statements add burdens to all parties involved”
“Ineffective Scoping – risk aversion, poor planning, and commercial realities.”
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IAIA Florence 2015
“The theme of this year’s conference isfascinating: digital. The Latin origin of
this word is digitus (finger). And it’s true:now we have the entire world in ourfingers. We don’t even need to press,just touch. How will this amazing soft
technology change the world? How willit affect the way people communicate?
How will it transform the way we collectand process information? The way
decisions are made?”
Environmental Impact Assessment | 26th September 2017 | Rufus Howard
IEMA Proportionate EIA Strategy 2017
EIA-as-normal Risks:
•Being a key voice for the
environment in decision-making
•Adding value to development
design
•Engaging the public in effective
consultation
•Helping manage risks to
consenting
•Being more than an expensive
procedural exercise
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Justice Sullivan - 2004
‘It would be no advantage to anyone concerned… -
applicants, objectors or local authorities - if ES were
drafted on a purely “defensive basis” mentioning
every possible scrap of information ... Such
documents would be a hindrance not an aid to sound
decision-making by the local planning authority, since
they would obscure the principles issues with a welter
of detail’.
Derbyshire Waste Ltd vs Blewett and SoS for Environment [2004] EWCA Civ 1508 at para 42
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Trends Over Time
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1000
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Oct-05 Nov-05 Aug-07 Dec-09 Sep-11 Oct-11 Jan-12 Oct-12 Nov-12 Aug-13
GreaterGabbard
Thanet SheringhamShoal
Dudgeon KentishFlats
Extension
Galloper Triton Knoll Sea Green East Anglia1
DoggerBank Creyke
Beck
Environmental Statement (Page Length) Scoping Report (Page Length)
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Proportionate EIA
Systematic Collaborative Action
Environmental Impact Assessment | 26th September 2017 | Rufus Howard
Four Strategic Themes for Action
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Embracing Innovation & Digital
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The world moves on ….
Interesting developments are popping up fast
Who wants to go through 35,000 pages of paperwork? Boring!
Let's do it differently!
Interactive digital Impact assessment as the new standard
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Environmental Impact Assessment | 26th September 2017 | Rufus Howard
Environmental Impact Assessment | 26th September 2017 | Rufus Howard
Clients and Regulators Views?
www.theneweis.com
https://www.youtube.com/watch?time_continue=8&v=6hTx5yTAMGo
https://www.royalhaskoningdhv.com/en-gb/specials/digital-eis
Environmental Impact Assessment | 26th September 2017 | Rufus Howard
Industry Evidence Programme (IEP)The Goals of the IEP are to:
Focus EIA on the significant environmental topics
Identify topics of negligible concern
Identify topics with established mitigations that reliably reduce significance
Identify topics with likelihood of significant adverse effects
Provide a central hub for evidence, good practice and guidance
Provide standardised and verified mitigation solutions
Provide standardised templates for conditions
Provide standardised monitoring for impacts during construction and
operation
Provide evidence to support decisions that lead to a proportionate EIA
Reduce costs and programme for developers, regulators and stakeholders
Provide greater legal and scientific certainty for all stakeholders
Establish knowledge gaps to direct further research
Environmental Impact Assessment | 26th September 2017 | Rufus Howard
Steering Committee
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Stakeholder Views
What are your organisations concerns if you were to receive a
digital, web based, versus a paper based Environmental
Statement?
Do you think your organisation would accept a digital ES
(assuming it contains the correct information you would expect
from an ES)?
Do you foresee any legal or regulatory reasons why your
organisation would not accept a digital Environmental
Statement?
Environmental Impact Assessment | 26th September 2017 | Rufus Howard
Regulators Views?
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What are your organisations concerns if you were to
receive a digital, web based, versus a paper based
Environmental Statement?
“Accordingly it is apparent that the 2009 EIA Regulations do not explicitly define the ES as being (or needing to be) a paper based document. However, the 2009 EIA Regulations do frequently refer to ‘copies’ in respect of the ES, which may imply that the Regulations envisage the ES is a physical entity rather than a digital only document. Nonetheless this is not explicitly stated in the 2009 EIA Regulations.” PINS
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Continued…
“The Infrastructure Planning (Environmental Impact Assessment) 2017 Regulations (2017 EIA Regulations) which have now been made and will come into force on 16th May 2017 includes provision requiring that the ES is available on a website maintained by or on behalf of the Secretary of State. As with the existing 2009 EIA Regulations the 2017 EIA Regulations do not explicitly state that the ES should be a paper based document.” PINS
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but…
“The Infrastructure Planning (Applications Prescribed Forms and Procedures) Regulations 2009 (as amended) state that if requested by the Planning Inspectorate the Applicant should provide three paper copies of the application form and other supporting documents and plans. This would include paper copies of the ES as a supporting document.” PINS
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but…
“Further to this the Planning Inspectorate Advice Note 6: Preparation and submission of application documents includes advice that states:
“The applicant is required to submit its full application in both electronic and hard copy format. Whilst the Planning Inspectorate encourages electronic working, the submission of hard copy documents and plans is required in order to ensure the smooth running of the examination process.” “ PINS
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Other Statutory Consultees
“Overall we would be very supportive of this sort of evolution of EIAs, it is without a doubt the direction things should and are going to take. It’s definitely an exciting step – as you know, we agree with the need to reduce the hard copies of ESs and can see it as an excellent tool for public engagement and non-technical summaries” Statutory Consultee
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Other Statutory Consultees
“We are supportive of the approach in principle and can see the benefits in terms of increased accessibility, ease of use and interpretation etc.
The format would be particularly useful as a public engagement tool and for providing non-technical summaries but only very careful application of the approach will allow it to act as a replacement for a conventional ES.”
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Other Statutory Consultees
“In answer to your specific queries I have gathered thoughts from some of our officers who were overwhelmingly receptive to the idea:-”
I have categorised these comments into three types:• IT (software and hardware)• Interactivity (usability)• Archives (records)
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IT Concerns
• “Need backwards compatibility for whichever browser /
reader product is used
• Training would be needed
• Inconsistency if not all applicants take this approach
• How would the digital approach handle supplementary
material?”
• Will programs be supported by our systems?”
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IT Concerns
• What if can’t use Wifi at hearings due to security?
Can they be accessed offline?
• There would have to be an agreed standard and
format for the new product.
• File path lengths for downloads (limit for 150 /
250 characters) which often is problematic for
large ES downloads
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Interactivity and Commenting
“Would be best to be in a format that is easily printable so case officers can print out particular sections if needed
Agreed fonts if using Acrobat
There may be the danger to go hyperlink crazy so that you are hopping around the website trying (and potentially missing) important information such as caveats.”
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“How would we comment on it – easy at the moment with page numbers and sections?
Web version could facilitate joint comments if could come up with some access structure.
Also could maybe allow more than one person to comment at a time (e.g. as per sharepoint files) and make collating comments easier”
Interactivity and Commenting
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Interactivity and Commenting
“There will still need to be the ability to drill down through the interactive layers to a full and detailed quantitative assessment of key issues/impacts - presumably in the form of underpinning chapters and supplementary technical reports. The approach will save time in navigating your way through an ES, allow faster cross referencing and reduce printing costs but wouldn’t replace the need for this material.”
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Archiving and Records
• “Legacy issues and responsibility for archiving would also have to be considered.
• Version control and subsequent editing after submission would have to be very strictly set out.
• Where would they be stored – we have to go back to original ESs sometimes years after they were first submitted – and be assured there are no changes”
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Archiving and Records
• “Need a permanent archive (might be needed in 50 years time…)
• Need a clear audit trail on the files (i.e. it cant be edited by the submitter once it has been submitted).”
• The ES would need to be hosted by the Appropriate Authority (AA) for control to be maintained and for the information to be “submitted to the AA”.
• Information will also need to be held for the lifetime of the project which would create particular storage issues for authorities.”
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Do you think your organisation
would accept a digital ES (assuming
it contains the correct information
you would expect from an ES)?
“Having links to click through to relevant related sections will be a lot easier than a thousand sticky notes in various paper reports, or having lots of clunky pdfs open at once.
This does move to the ‘digital by default’ government position”
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Do you think your organisation
would accept a digital ES (assuming
it contains the correct information
you would expect from an ES)?
“Yes.”
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Key Point
“In terms of it replacing ESs, there are probably quite a few questions to be answered. It must still contain the same information we would expect from an ES, complete with references.”
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Key Point 2
“The risk that, without the constraints of printing costs, Environmental Statements would actually get longer, rather than shorter, thereby complicating and lengthening the review process rather than streamlining it as intended.”
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Key Point 3
“Public accessibility – need to keep in mind that not everyone is online / has access to a fast internet connection, so hard copies can still be useful for public consultation.
“Consultation of the public would need to allow for those who do not have internet access (or knowledge of the web).”
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Key Point 4
“What is really needed to reduce the difficulties of handling conventional ES’s is to address some of the more fundamental reasons why ES’s are very large. These include looking at our ability to eliminate issues sooner from the assessment, ensuring assessment is proportionate to risk and avoiding ‘Data Rich Info Poor’ data collection”
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Conclusion
• Appetite for Innovation
• Potential Advantages
• Several Challenges in Implementation
• Part of the solution not the whole solution
• Pilots needed
• Willing engagement
Environmental Impact Assessment | 26th September 2017 | Rufus Howard
Any Questions?
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@Rufus_Howard
https://uk.linkedin.com/in/impactassessment
Refreshing the approach
to EIA
Nick Giesler: Head of
Environment,
Crossrail 2
Crossrail 2 – new transport
solution
• 100km route, with twin tunnels over
35km
• 51 stations
• 30 trains per hour
• Carrying up to 270,000 people in
peak
• Open in the early 2030s
• Joint TfL/Network Rail project
A new railway to serve London and the wider Southeast
The EIA challenge
• Too big ESs: too much information; abstruse conclusions
• Over-elaborate process
• Double-handling – waste and inconsistency
• Big teams; big documents; big assessment - big costs
• Life style
Growth of Environmental Statements
The good ol’ days
• HS1 – (1994)
900 pp, 10 docs
• Thameslink 2000
(2004)
750 pp, 5 docs
• Crossrail (2005)
2,200 pp, 9 docs
The behemoths
• Hinkley Point C (2011)
31,133 pp, 185 docs
• Thames Tideway (2013)
25,600 pp, 93 docs
• HS2 (2013)
39,610 pp, 536 docs
• HS2 (with additional
provisions)
50,000 pp +
Cultural change
• Embed the approach in a large and diverse team
• Secure consistent thinking and expectations
• Challenge entrenched working practice
• Build on recognised achievements and skills
• Get stakeholders on board
• Comprehensive planning early on
Definitive scoping
• Assess only what you need to assess
• Design only what you need to design
• Be incisive; be bold; NOT reckless
• Scope as first stage assessment
Scope Assess
Stage 1 assessment Stage 2 assessment
Realise synergies
• ES largely a product of the EIA.
• But other processes support it:• transport assessment
• economic case
• strategic case
• HIA
• Equalities studies
• Refreshed approach needs wider application than just EIA.
Synergise assessments and reports
ES
TA
EqIAHIA
Economic report
ES
TA
HIA
EqIA
Economic reports
Communicate and innovate
• ES must communicate effectively.
• Devise for readers, not writers.
• Intuitive, well written and abundantly illustrated products.
• Effective use of technology, including on-line reporting.
• Innovative user interfaces for maps, animations and other graphical material.
• Bespoke production team, not just editing the work of others.
Summary: steps for change
• Develop an explicit and lucid approach
• Challenge working practice, but build on success
• Long-term planning to shape short-term work
• Scope bold: only assess what we need to
• Review assessment workstreams to realise synergies
• Develop innovative and contemporary products focused on their main audience
• Strong leadership and direction
Online scoping
Online scoping