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STRATEGIC ENVIRONMENTAL ASSESSMENT OF
COMPREHENSIVE PLANS:
A COMPARATIVE ANALYSIS OF COMPREHENSIVE PLANS FROM
SCOTLAND, CALIFORNIA, AND NEW ZEALAND
by
Christine Slanz Ignas
B.Sc. The University of Northern British Columbia, 1999

THESIS SUBMITTED IN PARTIAL FULFILLMENT OF
THE REQUIREMENTS FOR THE DEGREE OF
MASTER OF NATURAL RESOURCES AND
ENVIRONMENTAL STUDIES

THE UNIVERSITY OF NORTHERN BRITISH COLUMBIA
December 2003

© Christine Slanz Ignas, 2003

1^1

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Abstract
Environmental impact assessment (EIA) has been successfully established world-wide
as an effective tool to promote sustainable development by addressing the environmental
impacts of development on a project by project basis. Strategic environmental assessment, or
SEA, has emerged over the past ten years, as a way to integrate environmental considerations
at more strategic levels o f decision-making. In particular, the planning system has a vital role
to play in promoting more sustainable land-use patterns and use o f resources. The
community’s comprehensive plan must set a framework for long-term development that helps
promote a more sustainable future for everyone in the community.
While the effectiveness of EIA has been of interest to researchers for some time, it is
only recently that the effectiveness of SEA is receiving similar attention. There have been
very few attempts to evaluate SEA application to comprehensive plans. The primary purpose
of this thesis is to examine and compare the application and the effectiveness of SEA in
comprehensive plans in three case studies: Perth and Kinross Council (Scotland); San Joaquin
County (California, US), and Waitakere District (New Zealand). To compare effectiveness in
the three case studies, an evaluation framework has been developed. The cases are evaluated
against criteria within four levels o f the framework: policy context, institutional arrangements,
SEA processes, and SEA methods.
This study has shown that the strategic environmental assessment processes of the
comprehensive plans in Perth and Kinross (Scotland), San Joaquin County (California, US),
and Waitakere District (New Zealand) were only adequately effective. Differences in
effectiveness among the three cases as well as among the levels of the evaluation framework,
indicate two things. First, while there is scope for improving current practice, there is no need
to reinvent the wheel. The knowledge for conducting SEA successfully is there and waiting to
be applied. Second, as experience grows, and as regulations, guidance and training are
strengthened, SEA practice is improving.
There appears to be resistance among decision-makers to either implement SEA
processes in the absence of legal obligations, and to abide by the recommendations that
emerge from the SEA. Advocates of SEA must recognize that many decisions are really made
incrementally, and that decisions are often made with imperfect information despite the effort
and resources spent to collect data and information (Clark 2000,16). Although SEA is not
without problems (for example, the establishment of good baseline data, approaches to the
assessment o f enviromnental capacity, and the tensions involved in the trade-offs between
socio-economic and physical environmental goals (Glasson 1995, 729), the process does offer
the potential to integrate environmental and sustainability factors into the mainstream of
policy-making and planning. Assessment of environmental impacts at higher tiers of
decision-making addresses the cause of environmental problems at their policy source, rather
than just treating the symptoms of the impacts.
Overall SEA can be seen as a catalyst toward more integrated planning for sustainable
development. SEA is still in a relatively early stage in its development, and current practice
provides a stepping stone to something more substantial. SEA is significantly more complex
than project EIA, and it will require developing a professional capacity to ensure its success
and acceptance.

11

Table of Contents
Abstract

ii

Table o f Contents......................................................................................................................................................... iii
List o f Figures ............................................................................................................................................................. v
List o f Tables

............................................................................................................................................................vi

Acknowledgem ents.....................................................................................................................................................vii

Chapter One
1.0
1.1
1.2
1.3
1.4
1.5
1.6

Introduction............................................................................................... 1

Introduction
1
Purposes and Objectives o f Research............................................................................................................... 3
Research Questions ...........................................................................................................................................4
Background
4
Case Studies
6
Terminology
9
Thesis Outline
......................................................................................................................................... 10

Chapter TwoPlanning for Sustainability at the Local Level: A Review of the Literature
2.0
2.1
2.2
2.3
2.4
2.5
2.6
2.7

12

Introduction
12
Context o f Sustainable Development.............................................................................................................. 13
Role o f Planning in the Transition to Sustainability......................................................................................19
Approaches to Planning for Sustainability..................................................................................................... 23
Environmental Impact Assessment (EIA).....................................
29
Strategic Environmental Assessment (SEA).................................................................................................. 33
Strategic Environmental Assessment at the LocalLevel...............................................................................46
Summary
53

Chapter Three Research Design and Methods.............................................................................. 54
3.0
3.1
3.2
3.3
3.3.1
3.4
3.5

Introduction
54
Research Design
.........................................................................................................................................54
Methods
56
Case Studies
59
Criteria for Selection o f Case Studies.............................................................................................................59
Methods o f Analyses........................................................................................................................................63
Issues o f Validity and Reliability.................................................................................................................... 66

Chapter Four A Framework for Evaluating SEA Effectiveness for Comprehensive Plans
4.0
4.1
4.2
4.3
4.4
4.5
4.6

Chapter Five
5.0
5.1
5.2
5.3
5.4

68

Introduction
68
Concepts o f Effectiveness in EA and SEA Systems.....................................................................................69
Importance o f Context..................................................................................................................................... 74
A Framework for Evaluating SEA Effectiveness for Comprehensive Plans............................................. 75
Evaluation Framework Criteria.................................
78
Evaluation o f Significance............................................................................................................................... 82
Summary
83

Overview of the Case Studies...............................................................................85

Introduction
85
Scotland - Perth and Kinross District.........................................................................................................87
California, USA - San Joaquin County........................................................................................................101
New Zealand - Waitakere District................................................................................................................115
Summary
126

111

Chapter Six
6.0
6.1
6.2
6.3
6.4
6.5

Case Study Results and Analysis........................................................................... 127

Introduction
127
....................................................................................................................................... 128
Policy Context
Institutional Arrangements..............................................................................................................................134
SEA Processes
....................................................................................................................................... 142
SEA Methods
....................................................................................................................................... 153
Summary o f Effectiveness..............................................................................................................................159

Chapter Seven
7.0
7.1
7.2
7.3
7.4
7.5

Conclusions and Recommendations................................................................... 164

Introduction
164
Conclusions
165
Suggestions for Improving SEA o f Comprehensive Plans......................................................................... 171
Suggestions for Improving SEA o f Comprehensive Plans in the Case Studies........................................179
Opportunities for Future Research.................................................................................................................180
Concluding Remarks....................................................................................................................................... 180

Literature Cited................................................................................................................................ 182
Appendices:

Appendix A
Appendix B
Appendix C
Appendix D
Appendix L

Overview of SEA of Comprehensive Plans in Selected Countries........................... 195
List of Documents and Legislation Reviewed......................................................... 196
Provisions for SLA in the Case Studies...................................................................198
Abbreviations and Acronyms............................................
202
Glossary of Planning and Environmental Assessment Terms................................. 203

IV

List of Figures
Figure 1
Figure 2
Figure 3
Figure 4
Figure 5
Figure 6
Figure 7
Figure 8
Figure 9
Figure 10
Figure 11
Figure 12
Figure 13
Figure 14

Inherent conflicts in sustainable development..........................................................21
SEA as a tiered-forward process................................................................................ 38
The relationship between models of SEA................................................................. 40
Research designs and methods................................................................................... 58
Triangulation among data sources.............................................................................64
Effectiveness Triangle.................................................................................................73
Evaluation Framework................................................................................................76
Map o f Perth and Kinross, Scotland......................................................................... 88
Steps in sustainability appraisal in Scotland.............................................................96
Map o f San Joaquin County, California...................................................................102
Map o f Waitakere, New Zealand............................................................................. 117
The sequence of steps in Section 32 Analysis........................................................123
Evaluation framework............................................................................................... 127
Findings o f overriding considerations in San Joaquin County's EIR.................... 132

List of Tables
Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
Table 7
Table 8
Table 9
Table 10
Table 11
Table 12
Table 13
Table 14
Table 15
Table 16
Table 17
Table 18
Table 19
Table 20
Table 21
Table 22
Table 23
Table 24
Table 25

Characteristics o f case studies........................................................................................ 8
Bellagio Principles........................................................................................................ 18
EIA and SEA compared............................................................................................... 37
Guiding Principles of SEA........................................................................................... 39
Institutional barriers to introducing and implementing SEA .................................... 45
Aims and objectives o f SE A ........................................................................................ 77
Guiding Principles of SEA........................................................................................... 78
Principles and evaluation criteria for the policy context...........................................79
Principles and evaluation criteria for institutional contextarrangements................ 80
Principles and evaluation criteria for SEA processes................................................81
Principles and evaluation criteria for SEA methods.................................................. 82
Summary of case study characteristics....................................................................... 86
Scottish policies on environmental appraisal............................................................ 94
Steps in the Perth and Kinross Sustainability Appraisal...........................................98
Example o f an impact matrix in sustainability appraisal for a single policy in the
Perth and Kinross Structure Plan 2002..................................................................... 100
Topics that must be addressed in an E IR ................................................................. 110
Example o f a checklist for Section 32 Analysis...................................................... 125
Evaluation of procedural and substantive effectiveness of the policy context
128
Evaluation of the procedural and substantive effectiveness of institutional
arrangements................................................................................................................135
Evaluation for procedural and substantive effectiveness of SEA processes
143
Evaluation for procedural and substantive effectiveness of SEA methods
155
Summary o f effectiveness......................................................................................... 159
Summary o f conclusions........................................................................................... 165
Summary o f suggestions for improving SEA practice............................................ 172
Summary o f improvements for the case studies...................................................... 179

VI

Acknowledgements
First and foremost, I would like to thank my husband, Dominic Ignas, for all his
support, encouragement and love. I am particularly grateful to my parents, Mary Slanz and
John Slanz, as well as to the rest of my family, for the unconditional love and support that
they have always shown throughout my academic and professional endeavours.
I would like to extend my appreciation and gratitude to my supervisors. Dr. Doug
Baker and Dr. John Curry, and to my committee members. Dr. Annie Booth and Tony
Jackson, for their time, interest, and expert advice. A special thank you to Doug for providing
direction and encouragement when I needed it. Thank you also to my external examiner. Dr.
Heather Smith, for her insight and suggestions to improve this document.
I would like to acknowledge my fellow graduate students at the Graduate Students
Office who provided both friendship and an integral slipport network. Thanks also to Alisa
Thompson at the UNBC Northwest Regional Campus in Terrace for providing a comfortable
environment to complete the final draft of this thesis. A special thank you to Bethany Haffner
at the Office of Graduate Studies for ensuring that the administrative path along the way has
always been a smooth one.

VII

Chapter One
Introduction
1.0

Introduction
Planning for sustainable development is about making the built environment more

liveable, ecosystems healthier, economic development more responsive to the needs of place
and the benefits of improvement more equitably distributed (Ericksen et al. 2001). Local landuse plans (referred to as “comprehensive plans” in this thesis) should integrate these elements
of environmental quality, economic development and social well-being. The integration of
environmental impact assessment (EIA) principles into planning and policy making has been
called the “ultimate means by which sustainable development can be achieved” (Partidario
1996, 34). Strategic environmental assessment (SEA) has emerged as a way to integrate EIA
and comprehensive planning to promote sustainability. SEA is a process for identifying and
assessing the environmental effects of a policy, plan or program (PPP) so that they may be
taken into consideration before the plan is approved or adopted.
While EIA focuses narrowly on the potential environmental impacts that may arise
from a specific development project, SEA is set at a higher, more strategic level of decision­
making, within a context of broader visions, goals and objectives. The ‘strategic’ component
of SEA is “the process of defining goals or visions in terms of the desirable principles to be
established, proposing alternative possibilities to achieve these principles, and selecting the
most desirable approach” (Noble 2002).
Many countries currently undertake SEA or a SEA-type system of their comprehensive
plans, such as the United Kingdom, Sweden, the United States and New Zealand (refer to
Appendix A for an overview of SEA of plans in selected countries). While the term “SEA” is
not always used to describe these existing practices, the type of evaluation complies with

1

many of the principles of SEA as described in the academic literature (Sadler 1998; Sadler and
Verheem 1996; Partidario 1996; Therivel et al 1992). In this thesis, the term SEA will be used
to refer to all SEA-type systems. Driven by the recent adoption of the European Union’s
Directive for SEA‘ which requires the 15 Member States^ to implement legislation for SEA
for plans and programmes (including comprehensive plans), there has been an upsurge of
attention to this topic by both academics and practitioners. One of the key areas of interest is
the evaluation of the effectiveness of SEA, as applied to comprehensive plans and the ways in
which effectiveness can be measured. The effectiveness of EIA systems has been of interest
for some time (e.g., Sadler 1996; Wood 1995; Gibson 1993; CEARC 1988), but it is only
recently that the effectiveness of SEA systems has been considered (e.g., Fischer 1999;
Marsden 1998a; Sadler and Verheem 1996).
In evaluating effectiveness, the concern is with “how well SEA actually works, which
components and activities contribute to or detract from success, and what realistically could
be done to improve the process(es) under review” (Sadler and Verheem 1996, 18). Two
dimensions of effectiveness have been described in the “SEA Report” (the accompanying
document to the International Study on the Effectiveness of Environmental Assessment) substantive and procedural (Sadler and Verheem 1996). The first is used to determine the
extent to which SEA performance meets “established purpose(s), goals and objectives”, and
the second is used to determine the extent to which SEA performance meets “accepted
provisions and principles”.

* Directive 2001/42/EC of the European Parliament and of the Council on the Assessment of the Effects of
Certain Plans and Programmes on the Environment. Adopted at Luxembourg on 27 June 2001 (CEC 2001).
^Currently, the 15 Member States of the European Union include (with date joining EC/EU): Austria (1995),
Belgium (1952), Denmark (1973), Finland (1995), France (1952), Germany (1952), Greece (1981), Ireland
(1973), Italy (1952), Luxembourg (1952), the Netherlands (1952), Portugal (1986), Spain (1986), Sweden (1995)
and the United Kingdom (1973).

The principles and features of SEA have been highlighted in numerous journals,
exploring the benefits of, and rationale for, SEA as a concept. There have been few efforts
directed towards the comparative evaluation of SEA application at the plan level. This thesis
aims to fill that gap by exploring the current state of SEA or SEA-type systems of
comprehensive plans and by evaluating the effectiveness of SEA-type systems in
comprehensive planning through a comparative review of three case studies located in
Scotland, California and New Zealand. These case studies represent three different models of
SEA within three distinct jurisdictions.
1,1

Purposes and Objectives of Research
The primary purpose of this thesis is to examine the application and the effectiveness

of SEA in comprehensive planning. To achieve this purpose, the research has the following
objectives:
(i)

to determine how SEA is applied to comprehensive plans in the United Kingdom,
California and New Zealand;

(ii)

to develop an evaluation framework and associated criteria, against which to measure
the effectiveness of SEA of the identified case studies’ comprehensive plans;

(iii) to use this framework to measure the effectiveness of SEA systems in comprehensive
plans, both procedurally (the extent to which the SEA system conforms to established
provisions and principles) and substantively (the extent to which the objectives of SEA
are met);
(iv) to determine whether the model of SEA followed (i.e., standard or EIA-based model;
equivalent or environmental appraisal model; integrated or environmental management
model) results in greater effectiveness;

(v)

to verify whether current SEA theory accurately reflects existing SEA practice; and

(vi) to provide suggestions to improve SEA of comprehensive plans.
1.2

Research Questions
In order to realize the research purpose and objectives, the following five research

questions were posed:
(i)

What are the criteria and how does one determine effective implementation of strategic
environmental assessment (SEA) of comprehensive plans?

(ii)

To what extent does SEA of comprehensive plans follow accepted provisions and
principles (procedural effectiveness), and to what extent does SEA result in the
achievement of its stated goals and objectives (substantive effectiveness)?

(iii) Does the model of SEA followed result in greater effectiveness?
(iv) Does current SEA theory accurately reflect existing SEA practice?
(v)

What recommendations can be made to improve the effectiveness of SEA as applied to
comprehensive plans?
The answers to these questions may provide guidance to future planners, local

authorities and decision makers at all levels that wish to implement effective SEA systems for
the evaluation of comprehensive plans.
1.3

Background
For the past decade, different strategic environmental assessment processes have been

used in several countries under different names. A number of definitions for SEA are offered
in the academic literature and through legal provisions for SEA.
definitions is offered by Therivel et al (1992, 19-20):

One of the most cited

...a formalized, systematic and comprehensive process o f evaluating the
environmental impacts o f a policy, plan or programme and its alternatives,
including the preparation o f a written report on the findings o f that evaluation,
and using the findings in publicly accountable decision-making.
This definition highlights several key features of SEA including; a systematic process,
the need for evaluating alternative options, documentation and the accountability of decision
makers to the public. Similarly, Sadler and Verheem (1996, 27) also highlight SEA as a
systematic process, but their definition identifies the need for early application of SEA and the
equal consideration of all three elements of sustainability;
SEA is a systematic process fo r evaluating the environmental consequences o f
proposed policy, plan and programme initiatives in order to ensure that they
are fully included and appropriately addressed at the earliest appropriate
stage o f decision making on par with economic and social considerations.
Although the term ‘SEA’ is fairly recent, SEA-type provisions were mentioned for the
first time at the birth of EIA, in the form of a need to

.include in every recommendation or

report on proposals for legislation...a detailed statement on...the environmental impact of the
proposed action...” [excerpt from NEPA 1969, Section 102(4332) (c)]. More recently, the
growth of interest in SEA (as well as the term itself) has been spurred by the European Union
with its recent adoption of a SEA Directive that requires all Member States to incorporate
SEA into national legislation for certain plans and programmes by July 2004.
Over the past decade, experience has accumulated in the practical application of the
strategic environmental assessment of comprehensive plans in many countries, including the
United Kingdom, Sweden, Belgium and the United States, to name a few. However, a review
of the existing SEA literature led to the following conclusions; (i) SEA has been applied
primarily in an ad hoc manner, with little attention devoted to the development of an
appropriate framework and a set of tested methods (Partidario 2000; Therivel et al 1992;

Bridgewater 1989); (ii) a greater understanding of the political and institutional contexts that
SEA occurs within will serve to advance the effectiveness of SEA application (Marsden
1998a; Marsden 1998b; Partidario 1996; Sadler and Verheem 1996); (iii) many practical
issues with respect to the application of SEA processes and methods have yet to be resolved
(Sadler 1998; Sadler and Verheem 1996); and (iv) an understanding of how assessments from
different countries compare in both application and effectiveness has been inadequate (Fischer
1999).
1.4

Case Studies
In order to address the research questions, three case studies were selected from

around the world and evaluated against a set of identified criteria (refer to Chapter Three and
Chapter Four). The cases were selected on the basis of several criteria; (i) the case must
include an evaluation of the environmental (or sustainability) impacts of a comprehensive plan
(as defined in section 1.5); (ii) the primary language must be English to assist in the
interpretation of documents and interviews by the researcher; (iii) case study material must be
easily accessible; and (iv) the case must be identified as a “good practice” SEA by the
literature, practitioners or through special recognition (such as awards). Furthermore, each
case study represents one of three models of SEA, as identified by Sadler and Verheem (1996)
and the European Commission (Sheate et al. 2001a), to assess whether the effectiveness of a
SEA system has any relationship with the type of model that has been implemented in a given
jurisdiction.
Using the criteria noted above, the following three cases were selected for further
investigation on the effectiveness of SEA systems for comprehensive plans (see Table 1 for a

summary of the characteristics of the case studies): (i) Scotland: Perth and Kinross Council;
(ii) California, United States: San Joaquin County; and (iii) New Zealand: Waitakere District.
(i)

Perth and Kinross Council (Scotland) - Sustainability Appraisal of the Structure
Plan. Since 1992, SEA has been applied to local authority development plans in the
United Kingdom, first under the guise of ‘environmental appraisal’, and later, extending
its scope to embrace the comprehensive aim of sustainable development. SEA in the
UK has been rapidly evolving, and while current practice is variable, the majority of
local authorities in the UK (including Scotland) undertake some form of SEA for
development plans (Therivel 1998; Curran et al. 1998). Perth and Kinross Council had
completed the most recent SEA in the UK at the onset of this study. This case is an
example of an appraisal inspired model of SEA.

(ii)

San Joaquin County (California, United States) - Environmental Impact Report
for the General Plan. Since 1970, the California Environmental Quality Act (CEQA)
has provided the regulatory and institutional basis for environmental assessment for both
plans and projects.

Planning in California has been increasingly supported by

development fees as a result of the stringent CEQA requirements for comprehensive
assessments for development projects (Olshansky 1996). This case reflects many of the
features of an EIA inspired model of SEA. The San Joaquin County EIR has been
awarded as the “Outstanding Environmental Document Of the Year” in 1992 by the
Association of Environmental Professionals in California.
(iii) Waitakere District (New Zealand) - Section 32 Analysis of the District Plan. New
Zealand revolutionized its approach to environmental assessment and planning in 1991
with major reforms that saw the abolition of over 50 pieces of legislation (including the

Town and Country Planning Act), and the implementation of the Resource Management
Act. While there is no specific mention of SEA in the RMA, there is a requirement
found in Section 32 which outlines the duties of local government to consider
alternatives and to assess benefits and costs. The Waitakere District Plan was identified
as the “Best Quality Plan” in New Zealand by a planning team preparing a report for
Government. This case closely resembles the integrationary model of SEA.
Table 1

Characteristics of case studies

Sclocled 1.oca!

Model ol SIC \
1\p e of .\ssessiiieiil
Type of Plan
\ ear of .\ssessiiieiil

.jiistificalioii

Scotland
(I nited KingdonU
Peith and Kinross
Council
Equivalent, or
Environmental
Appraisal
Sustainability
Appraisal
Structure Plan
Plan-2 0 0 1
Assessment - 2002
I IK has a decade of
e\perience in
sustainability
appraisal. Perth and
Kinross Council had
the most recently
completed appraisal
at the onset of this
study.

(aliforniu

\cw /calaiid

San Joaquin County

Waitakere District

Standard, or EIAbased

Integrated, or
Environmental
Management
Section 32 Analysis

Environmental
Impact Report
General Plan

District Plan

Plan and Assessment1987-1992
California has over
three decades of
experience in SEA.
San Joaquin County’s
EIR was awarded the
“Outstanding
Environmental
Document of the
Year (1992) by the
Association of
Environmental
Professionals,
California Chapter.

Plan and Assessment1996-2003
In New Zealand,
SEA and planning are
strongly integrated
through the Resource
Management Act.
Waitakere District
was identified as the
“Best Quality Plan”
in New Zealand by a
team preparing a
report for
Government
(Ericksen et al. 2002)

1.5

Terminology
1.5.1

Strategic Environmental Assessment

Definitions of SEA usually refer to a systematic and comprehensive process that
involves a written report on the environmental and other impacts of a policy, plan or program.
These basic requirements are frequently fulfilled by assessments that are not formally called
SEA. Therefore, it was decided to include any assessment of the environmental impacts of a
comprehensive plan. This also included assessments that were integrated into the planning
process.

Many assessments that are the basis for formal SEA currently have different

terminology from SEA, such as ‘sustainability appraisal’ (UK), ‘environmental impact report’
(California), and ‘section 32 analysis’ (New Zealand).

1.5.2

Comprehensive plans

The units of analysis in this thesis are the SEA systems of comprehensive plans in
three selected case studies. The term comprehensive plan is used generically in this thesis to
refer to all types of plans that set out the desirable future physical development of a
community. Terminology varies between case studies, such as ‘development plan’ or
‘structure plan’ (UK), ‘general plan’ (California), and ‘district plan’ (New Zealand).

In

Scotland, the Town and Country Planning (Scotland) Act requires the preparation and
implementation of development plans. A development plan comprises mandatory structure
plans (for the wider area) and local plans (for smaller cities and towns). Structure plans and
local plans contain a number of objectives and policies. In California, state law requires each
city and county to adopt a general plan “for the physical development of the county or city,
and any land outside its boundaries which bears relation to its planning” (California
Government Code Section 65300). Similarly, the district plan in New Zealand is mandatory

and must conform to the mandatory regional policy statements and optional regional plans for
the area. In keeping with the direction set by the Resource Management Act, the district
plan’s general approach is to control the effects of activities, rather than the activities
themselves.
1.6

Thesis Outline
This thesis is divided into seven chapters. Chapter Two provides an overview of the

evolution and current trends in planning for sustainability at the local level. Concepts of
sustainability within a local planning context are explored, along with a discussion of the
methods used to evaluate ‘sustainability’. Both Environmental Impact Assessment (EIA) and
Strategic Environmental Assessment (SEA) are examined in depth.
Chapter Three provides a discussion of the research design, including the rationale for
the case study approach and the methods employed for the collection and analysis of the data.
The chapter concludes with a discussion on the validity and reliability of the research.
An evaluation framework, along with associated criteria, is introduced in Chapter
Four, against which the performance of a SEA system of comprehensive plans can be tested.
A discussion of the concepts of effectiveness as well as the rationale for the evaluation criteria
is provided, supplemented by references from the literature and from the practice of SEA in
other countries.

Four elements of the framework are then outlined: policy, institutional,

procedural and methodological.

For each of the elements of the framework, criteria is

selected that will evaluate the effectiveness of a SEA system both substantively, and
procedurally. The chapter concludes with a discussion of the strengths, weaknesses and
transferability of the framework.

10

Chapter Five presents a description of the political and institutional contexts of each of
the case study jurisdictions, as well as the SEA practices and methods used in relation to
comprehensive plans.
In Chapter Six, the performance of the SEA system for comprehensive planning in
each of the three case studies is analyzed against each criterion of the evaluation framework,
both procedurally and substantively. A discussion of the results is organized by the level of
the framework.
Chapter Seven discusses the implications of the case study results. Major conclusions
reached as a result of this study are provided. Two sets of recommendations are advanced for
improving SEA systems. The first set is offered to overcome the common shortcomings
identified in Chapter Six to improve the overall understanding of SEA practice in relation to
comprehensive plans. The second set is directed towards the individual case studies. The
chapter concludes with a discussion on future research opportunities and closing remarks.

11

Chapter Two
Planning for Sustainability at the Local Level: A Review of the Literature
2.0

Introduction
This chapter focuses on six areas derived from the literature to provide the context for

a discussion on sustainability planning at the local level. First, an overview of sustainable
development is provided.

This discussion is linked to the question of how sustainable

development principles can be introduced in the decision-making process. Second, the role of
planning in the transition to sustainability is examined. Third, the approaches to sustainability
planning is presented.

This discussion follows the evolution of environmental planning,

beginning with the early attempts by planners to integrate environmental considerations into
planning and decision-making processes, and moving on to the more recent recommendations
by both the Brundtland Commission and the World Conference on Environment and
Development in Rio de Janeiro to develop methods to measure and assess progress toward
sustainable development. Fourth, environmental impact assessment (EIA) at the development
project-level is investigated as a tool to examine the sustainability of decision-making,
focusing on both the achievements and limitations of EIA. Fifth, a discussion is provided on
the need for assessment at higher levels of planning and policy-making, strategic
environmental assessment (SEA).

SEA is defined, accompanied by a discussion of its

benefits, principles, and approaches. The chapter concludes with an examination of SEA at
the local level, focusing on the influence of the new European Union Directive on SEA and
the recent efforts at a integrated approach.

12

2.1

Context of Sustainable Development
2.1.1

Introduction

As highlighted by the Brundtland Commission and confirmed by the United Nations’
Conference on Environment and Development (also known as the Rio Earth Summit), local
communities have a significant role to play in the advancement of sustainable development.
To set the context for planning for sustainability at the local level, this section will investigate
the history and definitions of sustainable development within both a global and a local
context; the principles of sustainability and the challenges of implementing these principles
into practice; the role of planning in the transition to sustainability and the tools available for
planning; and evaluating sustainability at the local level.
2.1.2

DeHnitions of Sustainable Development

Fifteen years have passed since the Brundtland Commission popularized the term
sustainable development^ as “...development that meets the needs of the present without
compromising the ability of future generations to meet their own needs” (WCED 1987, 43).
This definition is only one of many used to describe sustainability. While many definitions
suggest that sustainability is influenced by the interrelationship between social, economic and
environmental components, the emphasis placed on each varies according to interpretation.
The concepts of ecological carrying capacities, human quality of life, and equity concerns
between generations figure prominently in the more common definitions of sustainable
development.
One of the earliest attempts at defining sustainable development emerged from the
World Conservation Strategy (lUCN/UNEPAVWF, 1980):
For the purposes of this thesis, sustainable development and sustainability are used inter-changeably.

13

For development to be sustainable, it must take account o f social and
ecological factors, as well as economic ones; o f the living and non-living
resource base; and o f long-term as well as the short-term advantages and
disadvantages o f alternative action.
Although somewhat verbose, this definition highlighted a number of key issues to be
considered when planning for development.

Several years later, the consideration of

environmental factors in decision-making became part of the World Bank policy:
“ ...environmental issues must be addressed as part of overall economic policy rather than
project-by-project” (World Bank 1987).
The World Conservation Union, the United Nations Environment Program and the
World Wide Fund for Nature emphasize both human quality of life and ecological carrying
capacity in their definition: “Improving the quality of human life while living within the
carrying capacity of supporting ecosystems.” (lUCN/UNEPAVWF 1991). Similarly, Byrne
and Hoffman (as cited in Massam and Dickinson 1999, 210) focus on the ecological element
within sustainability, claiming that true sustainability requires the recognition that we cannot
grow endlessly to meet our needs: “We must, instead, develop within our ecological means,
meeting the needs of the present and future generations”.
The concept of equity in both present and future generations is a recurring theme in
many definitions of sustainable development. The Rio Declaration’s Principle 3 provides the
equivalent of the more popular Brundtland definition: “to equitably meet developmental and
environmental needs of present and future generations” (UNCED 1992a). Emphasizing the
role of local governments as builders and maintainers of infrastructure and as service
providers, the International Council for Local Environmental Initiatives (ICLEI 1996, 4)
redefined sustainable development as “...development that delivers basic environmental.

14

social and economic services to all without threatening the viability of the ecological and
community systems on which these services depend.”

2.1.3

Principles of Sustainable Development

Common principles found throughout these definitions are those of ecological carrying
capacity, human quality of life and equity between present and future generations. The focus
on the earth’s carrying capacity has been the foundation for many environmental planning
approaches and tools, such as ecological footprint analysis (Wackemagel and Rees, 1995),
natural carrying capacity (Woollard and Rees, 1999; Daly 1999; Rees 1990), and
bioregionalism (Aberley 1994; Andruss et al. 1990).

Generational equity principles have been a more recent addition to sustainable
development theories (George 1999; Counsell 1999; Selman 1996). George (1999, 178)
suggests that these principles - inter-generational equity and intra-generational equity - may
be regarded as the “twin pillars of sustainable development”. Inter-generational equity, or
“futurity”, implies that each generation should “hand on the earth to the next generation in at
least as good a condition as it inherited it” (Selman 1996, 11). Intra-generational equity, or
“social justice”, requires that sustainable development focus on the principle of human needs
(Selman 1996, 11). Selman (1996) and Counsell (1999) identify a third fundamental principle
of transfrontier responsibility infers that sustainability in one area “cannot be achieved at the
expense of environmental conditions elsewhere” (Selman 1996,11).
In order to move toward sustainability, the Rio Declaration also brought to the
forefront several other important principles to deal with these themes; the Precautionary
Principle and the Polluter Pays Principle. Rio Principle 15 - the Precautionary Principle

15

(UNCED 1992a) provides some guidance with respect to ensuring development that is
sustainable:
...where there are threats o f serious or irreversible damage, lack o f full
scientific certainty shall not be used as a reason fo r postponing cost-effective
measures to prevent environmental degradation.
The principles discussed here provide a framework for sustainable development in
several common theme areas, including the conservation of non-renewable resources,
replenishment of renewable resources, reduction of pollution, promotion of a harmonious
relationship between the natural and built environments, protection of environmental quality,
and social equality (Woollard and Rees 1999; Selman 1996; Blowers 1993).

2.1.4

Operationalizing Sustainability Principles

Although the concept of sustainable development has been widely accepted and
common principles have been identified, there appears to be a lack of understanding about
what sustainable development actually means.

Blowers (1993, 5) suggests that the

“uncertainty over impacts, the often contradictory nature of competing interests and objectives
of any specific action, and the lack of knowledge regarding the sensitivity of the baseline
environment” results in difficulties in the implementation, or operationalization, of the
concept of sustainable development.
Similarly, Sadler (1994, 5) contends that a “key innovation in the transition to a
sustainability agenda...[is]...translating the principles of environmental sustainability into
operational terms.” Other authors have also expressed this challenge (e.g.. Counsell 1999;
Selman 1996; Blowers 1993). Discussion has centred on the theoretical constructs of
sustainability and the translation of the concept and its principles has been difficult to apply in
practice. The literature highlights two fundamental reasons for this: (i) the lack of an overall

16

consensus on what sustainable development means; and (ii) that the identified ‘core’
principles of sustainable development are more suited as lofty visions rather than measurable
goals (Counsell 1999; Selman 1996; Blowers 1993).
Trying to apply the notion of ecological planning has been difficult because “the
thresholds at which development becomes unacceptable cannot easily or scientifically be
identified” (Healey and Shaw 1993). Counsell (1999) claims that these thresholds are socially
determined, and thus, are based on the different values which communities place on different
aspects of the environment. Therefore, the determination of societal values becomes a key
component of operationalizing sustainable development.
Operationalizing sustainable development principles within the planning system
framework is particularly challenging. With respect to Great Britain, Counsell (1999, 46)
argues that the use of sustainable development themes or principles is “heavily constrained by
the nature of the UK planning system, as they are typically dealt with as aims and objectives.”
He suggests that greater innovations has been shown in “making operational a series of
secondary themes and principles, concerned with the protection of resources (environmental
capacity, environmental capital, the precautionary principle) and socio-economic issues
(social equity, policy integration, participation), more clearly allied to planning in the UK.”
(Counsell 1999,47).

17

Table 2

Bellagio Principles

G uiding Vision an d Goals
Assessment o f progress towards sustainable development should be guided by a clear vision of sustainable development and goals that define that
vision
Holistic Perspective
Assessment o f progress toward sustainable development should:
• include review o f the whole system as well as its parts
• consider the well-being o f social, ecological, and economic sub-systems, their state as well as the direction and rate of change of that state, of
their component parts, and the interaction between parts
• consider both positive and negative consequences of human activity, in a way that reflects the costs and benefits for human and ecological
systems, in monetary and non-monetary terms
Essentia! Elem ents
Assessment o f progress towards sustainable development should:
• consider equity and disparity within the current population and between present and future generations, dealing with such concerns as resource
use, over-consunption and poverty, human rights, and access to services, as appropriate
• consider the ecological conditions on which life depends
• consider economic development and other, non-market activities that contribute to human/social well-being
A dequate Scope
Assessment o f progress towards sustainable development should:
• adopt a time horizon long enough to capture both human and ecosystem time scales thus responding to needs o f future generations as well as
those cuirent to short term decision making
• define the space o f study large enough to include not only local but also long distanced impacts on people and ecosystems
• build on historic and current conditions to anticipate future conditions - where we want to go, where we could go
P ractical Focus
Assessment o f progress toward sustainable developiiKsnt should be based on:
• an explicit set o f categories or an organizing framework that links vision and goals to indicators and assessment criteria
• a limited number o f key issues for analysis
• a limited number o f indicators or indicator combinations to provide clearer signal o f progress
• standardizing measurement wherever possible to permit comparison
• comparing indicator values to targets, reference values, ranges, thresholds, or direction o f trends, as appropriate
O penness
Assessment o f progress toward sustainable development should:
• make the methods and data that are used accessible to all
• make explicit all judgements, assumptions, and uncertainties in data and interpretations
Effective C om m unication
Assessment o f progress toward sustainable development should:
• be designed to address the needs of the audience and set of users
• draw from indicators and other tools that are stimulating and serve to engage decision-makers
• aim, from the outset, for simplicity in structure and use o f clear and plain language
B road Participation
Assessment o f progress toward sustainable development should:
• obtain broad representation o f key grass-roots, professional, technical and social groups, including youth, women and indigenous people - to
ensure recognition o f diverse and changing values
• ensure the participation of decision-makers to secure a firm link to adopted policies and resulting action
O ngoing Assessment
Assessment o f progress toward sustainable development should:
• develop a capacity for repeated measurement to determine trends
• be iterative, adaptive, and responsive to change and uncertainty because systems are c onçlex and change frequently
• adjust goals, frameworks, and indicators as new insights are gained
10.

• promote development o f collective learning and feedback to decision-making
Institutional C apacity
Continuity o f assessing progress toward sustainable development should:
• clearly assign responsibility and providing ongoing support in the decison-making process
• providing institutional capacity for data collection, maintenance and documentation
• supporting development o f local assessment capacity
Hardi and Zdan 1997

18

The Brundtland Commission and Agenda 21 both called for the development of new
ways to measure and assess progress toward sustainable development.

In 1996, an

international group of measurement practitioners and researchers came together in Bellagio,
Italy to review progress and to synthesize insights from practical ongoing efforts, resulting in
the Bellagio Principles (Table 2) (Hardi and Zdan 1997). These principles have provided the
foundation for many research initiatives in the measurement and evaluation of sustainable
development (e.g., indicators).

Other relevant research initiatives include sustainability

indicators and targets (refer to section 2.3.4). Recently, local authorities in the United
Kingdom are attempting to operationalize sustainability through sustainability appraisals of
their development plans - assessing individual policies against a selected set of sustainability
criteria (DoE, 1993). This will be discussed in more depth in section 2.6. These initiatives all
exemplify the focus that local authorities world-wide are currently placing on methods to
move toward sustainability.
2.2 Role of Planning in the Transition to Sustainability
Many authors identify local communities and local governments as having a significant
role to play in the transition to sustainability through the land-use planning system (e.g.,
IC L E I1996; Selman 1996; Blowers 1993; UNCED 1992b). Local authorities
...construct, operate and maintain economic, social and environmental
infrastructure, oversee planning processes, establish local environmental
policies and regulations, and assist in implementing national and sub-national
environmental policies. At the level o f governance closest to the people, they
play a vital role in educating, mobilizing and responding to the public to
promote sustainable development. (ICLEl 1996, 4)
In many jurisdictions, local planning systems facilitate the movement toward
sustainability.

Selman (1996) discusses several key elements. First, the regulation of the

development of land (not including farming or forestry) can ensure that land is not wastefully
19

used and that certain critical land resources arc substantially protected.

Second, many

planning acts require the inclusion of public comments in the preparation of plans and in some
development decisions. Third, land use plans typically adopt a long-term planning timescale
(some as many as twenty years). Finally, the planning system allows for the integration of
various land interests in a ‘horizontal’ perspective, cutting across professions such as
engineering, ecology and economic development.

2.2.1

Sustainability within the Traditional Planning System

Within the traditional planning system, it has been customary to integrate
environmental issues with those of social concerns. The three broad goals of comprehensive
planning, in particular appear to be incorporated within the overarching framework of
sustainable development: (i) economic growth and efficiency; (ii) environmental protection
(natural and built); and (iii) social justice and equity (Hodge 1998, 433).

Therefore,

comprehensive planning should provide an excellent vehicle for sustainable development
initiatives.

However, evidence suggests that economic concerns have received priority

attention by planners, calling into question the feasibility of balancing the three components of
sustainability. Some definitions of sustainable development have followed this emphasis. For
example, the Local Agenda 21 action plan for sustainable development defines the concept as
“...a program of action for local and global economic reform” (ICLEI 1996, I). While the
environment is mentioned as one of the goals of the action plan, its exclusion in the definition
of sustainable development implies that environmental goals are minor when compared to
economic goals.

20

2.2.2

Inherent Conflicts within Sustainable Development

The emphasis on the economic component of sustainability has been highlighted by
several authors as an inherent conflict that needs to be reconciled (George 1999; Ravetz 2000;
Campbell 1996).

Campbell (1996) suggests that sustainable development can be

conceptualised as three points o f a triangle, in which each point (or goal) is linked to the other
two (Figure 1). Campbell identifies these three conflicts as: (i) the property conflict between
economic growth and social justice; (ii) the development conflict between environmental
protection and social justice; and (iii) the resource conflict between economic growth and
environmental protection (Campbell 1996, 296).
Figure I

Inherent conflicts in sustainable development

Social Justice
Economic Opportunity
Income Equality
PROPERTY
CONFLICT

DEVELOPMENT
CONFLICT

SUSTAINABLE
DEVELOPMENT
Overall Economic
Growth and Efficiency

>■ Environmental Protection
RESOURCE
CONFLICT

Campbell 1996,298

The ideal position for the planner, the sustainability position, is at the centre of the
triangle, balancing each o f the goals. Campbell (1996, 296) states that
this centre cannot be reached directly, but only approximately and indirectly,
through a sustained period o f confronting and resolving the triangle’s
conflicts. To do so, planners have to redefine sustainability, since its current
formulation romanticizes our sustainable past and is too vaguely holistic.

21

Campbell (1996) argues that planners need to manage and resolve conflict, while
promoting creative technical, architectural and institutional solutions - a very tall order,
indeed.

2.2.3

Local Agenda 21 Processes

This role of local communities in the advancement of sustainable development has
also been highlighted by Agenda 21, one of the products of the Rio Earth Summit. Chapter
28, better known as Local Agenda 21 (LA21) calls on governments to “review the status of the
planning and management system and, where appropriate, modify and strengthen procedures
so as to facilitate the integrated consideration of social, economic and environmental issues.”
(UNCED 1992b). Many of the signatory nations have undertaken LA21 processes and plans
within their local jurisdictions (e.g., Finland, the Netherlands, Sweden, and the United
Kingdom).
In particular, the United Kingdom has taken a strong leadership role in the promotion
o f sustainable development initiatives, including the formulation of national sustainable
development strategies. Local Agenda 21 plans and sustainability appraisals of development
plans.

The UK Government “now sees the planning system as a key instrument in the

delivery of sustainable development” (Selman 1996, 116).

This has been accomplished

through the use o f non-statutory Planning Policy Guidance (PPGs) in England and Wales, and
through Scottish Planning Policies (SPPs), formerly known as National Planning Policy
Guidelines (NPPGs)" in Scotland. These planning policies include advice on the inclusion of
sustainability considerations in local authority planning practice (Selman 1996, 30).

National Planning Policy Guidelines (NPPGs) in Scotland are currently being replaced by Scottish Planning
Policies (SPPs). The term SPPs will be used in this thesis from this point on.

22

2.3

Approaches to Planning for Sustainability
The land use planning system has been identified as a key factor in the transition to

sustainability at the local level (McDonald 1996; Selman 1996; Blowers 1993). This section
will examine the tools available for planning, managing and evaluating sustainable
development at the local level.

Within an environmental planning and management

framework, a number of these tools are discussed in this section: ecological footprint analysis
(Wackemagel and Rees 1995), natural and social capital and carrying capacities, and
bioregionalism. The section following will focus entirely on the tools of environmental impact
assessment, strategic environmental assessment and sustainability appraisal.

2.3.1

Environmental Planning

Environmental planning developed from the need to link sustainable development to
traditional ‘town planning’. The roots of the traditional town planning system are based in
concerns about the unhealthy and crowded industrial cities.

In an attempt to reconcile

economic prosperity with acceptable standards of human living conditions and social
development, two distinct approaches emerged. One approach centred on the problem of the
deterioration of living conditions; the other viewed the problems as a result of the
deterioration of the physical appearances of the cities themselves.
Out of the first approach emerged Ebenezer Howard’s concept of Garden Cities. The
Garden City Movement promoted a harmonious and interdependent relationship between
people and their surroundings, accomplished through the development o f a strong town centre,
concentration of population, agricultural belts and the provision o f open green space. The
City Beautiful Movement emerged from the second approach - a resurgence of Renaissance
design principles that were revived by the 1893 Chicago World Fair. Critics have argued that

23

this movement resulted in ‘mere adornment’ and failed to address the real problems of city
housing and sanitation (Hodge 1998, 59). Although these two movements failed to achieve
any lasting momentum, they have contributed to environmental and regional planning as we
know it today. Patrick Geddes, a Scottish biologist and planner, has been recognized as the
first among contemporary planners to sense the need for regional plarming, as well as
promoting the need to understand the interdependencies that exist between humans, the
natural environment and the built environment (Hodge 1998,311).
During the 1920s, plarming concerns shifted to the need to conserve resources and to
preserve open spaces.
appear.

Since the 1960s, the concept of sustainable development began to

The planning focus then shifted to the need to protect entire ecosystems and

biological diversity. Blowers (1993) suggests that one of the reasons for the emergence of
environmental plarming is a greater understanding of the earth’s services.

Scientists are

begirming to understand more about the earth’s limits and its functions. Evidence suggests
that the earth’s resources provide three essential functions: as a source (supplier of natural
resources), as a sink (assimilator of wastes) and as a service (provider of atmospheric,
hydrological and other essential life support) (Selman 1996; Rees 1990).
Blowers (1993, 14) discusses environmental planning as a comprehensive approach
with three basic features: (i) it considers future uncertainty by a precautionary approach; (ii)
it reflects the integrated nature of environmental processes and policies; and (iii) it takes a
strategic view of decision-making.

These features share similar characteristics to those

discussed for sustainable development as discussed in the Brundtland Report.

24

2.3.2

Carrying Capacity and the ‘Ecological Footprint’

One of the main objectives of environmental management is to maintain the
environment’s carrying capacity on behalf of sustainable development. This focus on the
earth’s carrying capacity has been advocated by ecologists and ecological planners as
necessary to move toward sustainable cities (Woollard and Rees 1999; Wackemagel and Rees
1995; Blowers 1993).

Blowers (1993) suggests that understanding the earth’s carrying

capacity (the upper limits that can be supported before the system deteriorates) is integral to
moving towards sustainable communities:
Development is often confused with growth. Growth conveys the idea o f
physical or quantitative expansion o f the economic system. Development is a
qualitative concept incorporating notions o f improvement and progress.
Sustainable development requires that we have regard to the earth’s
regenerative capacity, the ability o f its systems to recuperate and maintain
productivity. Thus the conservation o f resources is a strong component o f
sustainable development. (Blowers 1993, 5)
Woollard and Rees (1999, 29) claim that human carrying capacité is at the heart of
the sustainability crisis. They acknowledge that human carrying capacity is a controversial
premise; conventional theory states that the concept of a human carrying capacity is irrelevant
because humans can “continuously increase our own carrying capacity by eliminating
competing species, by importing locally scarce resources and through technology” (Woollard
and Rees 1999, 31).

Ecologists and ecological planners argue that carrying capacity should be the
fundamental basis for demographic accounting (Woollard and Rees 1999; Hardin 1991; Rees
1988) and view humans as biological entities and their economy as “an embedded subsystem
of the ecosphere, therefore constrained by real ecological limits” (Woollard and Rees, 1999,
^Carrying capacity is defined as the maximum population of a given species that can be supported indefinitely in
a defined habitat without destroying the habitat (Woollard and Rees 1999,31).

25

31). In support of this theory, Wackemagel and Rees (1995) have developed and applied the
concept of the ‘ecological footprint’, an accounting tool that can estimate the resource
consumption and waste assimilation of a community in terms of corresponding productive
land area. According to Wackemagel and Rees (1995, 51-52):
The Ecological Footprint o f a specified population or economy can be defined
as the area o f ecologically productive land (and water) in various classes cropland, pasture, forests, etc. - that would be required on a continuous basis
(a) to provide all the energy/material resources consumed, and (b) to absorb
all the wastes discharged by that population with prevailing technology,
wherever on Earth that land is located.
One of the strengths of the ‘footprint’ analysis is that it can be applied at any level. For
example, an ‘activity’ can be building a new settlement, the environmental impacts of a
university or the aggregate of environmental impacts from a whole city.

The ecological

footprint analysis has been undertaken for many cities worldwide. Levett (1999, 146) notes
that some attempts to use ‘footprint’ analysis as a tool at the city level has had some
difficulties in obtained local data. For example, in Barcelona and Santiago de Chile, data had
to be prorated from national and regional data which makes the incorrect assumption that the
footprint per person in the city is the same as the regional or national average (Levett 1999,
146).
While ‘footprint’ analysis can be a powerful tool for raising awareness of over­
consumption, Levett (1999, 145) notes that it must be used with caution. First, it is only
concemed with the biological productivity of land and does not adequately reflect other
benefits or uses of land such as landscape, recreation, cultural and historical aspects. Second,
some environmental risks such as radioactive contamination from nuclear power where there
is no straightforward way to translate the risk of damage into an area of land is not adequately
illustrated. Third, using equal share per head as the basis for allocating ‘footprints’ does not

26

adequately consider the disparities between developed countries and developing countries.
Developing counties complain that the developed world has been consuming more than its fair
share for a long time and should now have less to compensate; developed countries assert that
it takes more energy to support life in some places than others (e.g., northern Canada). As
with many other methods for measuring sustainability, political or value judgments are
inevitable.

2.3.3

Bioregionalism

Bioregionalism is more than simply an approach to sustainable development or
environmental planning, but offers an overall philosophy to life based on a fundamental set of
ideas. Bioregionalism calls for human society to be more closely related to nature (hence,
‘bio’) and more conscious of its locale or region (the ‘region’) (Andruss et al. 1990, 2). The
concept is based on ‘bioregions’ - biologically and culturally defined regions - as the most
appropriate spatial scale for human governance and development (Aberley 1994, 8).
Communities live within the bioregion’s limitations, as well as using the region’s resources
for its benefit. Implicit within the bioregionalism concept is a form of governance which
includes political decentralization, self-determination and a commitment to social justice
(Aberley 1994, 8).
Bioregionalism emerged from a grassroots social movement in North America and
Europe in the early 1970s in response to the escalating resistance against the prevailing
scientific world view and in the regionalism of Patrick Geddes, Lewis Mumford, and Howard
Odum (Aberley 1994, 8). Theories of regional planning espoused by planners such as Jane
Jacobs, Ian McHarg and E.F. Schumacher have also been influential in the development of

27

bioregionalism (Baker and Booth 1998). While enthusiastically touted as an idyllic objective,
bioregionalism has not been widely implemented.

2.3.4

Sustainability Indicators

The identification and implementation of sustainability indicators was recognized as a
key goal in Agenda 21, which observed that “indicators of sustainable development need to be
developed to provide solid bases for decision-making at all levels” (George 1999, 175).
Sustainability indicators are increasingly viewed as a way to operationalize sustainable
development principles.

They are “definable, measurable features of the world whose

absolute values or rate and direction of change are intended to reveal whether the world (or a
city) is becoming more or less sustainable” (Partidario and Moura 2000, 35). Significant
activity in the development of indicators has been seen across the globe (e.g., Oregon
Benchmarks Project, 2000; European Sustainability Index Project, 1997; Local Government
Management Board’s Research Project on Sustainable Indicators in the United Kingdom,
1995; and Sustainable Seattle Project, 1992).
Sustainability indicators have played a role in both environmental impact assessment
and strategic environmental assessment, but these efforts have primarily been devoted to
retrospective analysis of past developments (George 1999). Further, George (1999, 176)
argues that “the development of indicators has resulted in considerable complexity, which has
made it difficult to derive suitable criteria for environmental assessment”.
Within the last couple of years, there have been several research efforts to identify
frameworks and methods to develop and implement sustainability indicators within the
environmental assessment realm (e.g., Partidario and Moura 2000; Thissen 2000). One of
these methods, strategic sustainability assessment (SSA), was initially developed as an attempt

28

to address sustainability in a more operational way within a strategic environmental
assessment framework.

Partidario and Moura (2000, 35) define this procedure as “an

integrated approach which defines sustainability priorities and criteria at the policy level and
translates these into measurable indicators”. In this approach, indicators of sustainability are
used to relate policy objectives to sustainability, while thresholds and targets enable the
quantifiable measure of the strategy’s (the policy, plan or program) effectiveness in achieving
sustainability (Partidario and Moura 2000, 30).
2.4

Environmental Impact Assessment (EIA)
2.4.1

Introduction

Environmental impact assessment (EIA) refers to “the evaluation of the effects likely
to arise from a major project (or other action) significantly affecting the natural and man-made
environment” (Wood 1995, 1). In theory, EIA should lead to either the avoidance of actions
that are environmentally unacceptable, or to the mitigation to the point of acceptability of
environmental impacts that are approved (Wood 1995). EIA can be (and has been) viewed
from several perspectives: as a planning process, as a decision-making process, and as a
technocratic process. As a planning tool, EIA serves to inform interested parties of the likely
environmental impacts of a proposed project and its alternatives (Ortolano and Shepherd
1995, 3). EIA also serves as an aid to decision-makers by providing necessary information
about the impacts and the consequences of a proposed development project and its
alternatives. As a technocratic process, EIA forecasts and evaluates the impacts of a proposed
project and its alternatives. In the technocratic mode, studies are undertaken such as costbenefit analyses, computer simulations, scenario modelling and other methods of impact
analyses.

29

Environmental impact assessment (EIA) was initially developed in response to
concerns about the impacts of development projects on the bio-physical environment. The
first legislated EIA process was implemented more than thirty years ago in the United States
with the implementation of the National Environmental Policy Act (NEPA) in 1969. Within
the next decade, Canada, Australia, and many European countries followed suit with EIA
regulations and/or legislation. Currently, EIA is used to evaluate project impacts in most
developed countries and many developing countries.

At the international level, the

Convention on Environmental Impact Assessment in a Transboundary Context (1991), also
known as the Espoo Convention, came into force in September 1997. The Espoo Convention
has two major obligations of the Parties: (i) to assess the environmental impact of certain
activities at an early stage of planning; and (ii) to notify and consult each other on all major
projects under consideration that are likely to have a significant adverse environmental impact
across boundaries (UNECE 1991).

Both the United Kingdom and the United States

governments signed the Convention, but only the United Kingdom ratified it. New Zealand
was not a signatory to the Convention.

2.4.2

Achievements of EIA

Ultimately, the goal of EIA is to ensure that environmental impacts of proposed
development projects are either mitigated or avoided in an effort to move towards sustainable
development. Although it is difficult to determine to what extent that this has occurred, it is
evident that EIA has changed the way project proponents and government agencies do
business.
The most evident change is the inclusion of measures in project proposals to mitigate
adverse environmental effects. A less common but significant project-level change is where

30

EIAs have affected project type, size and location. EIA processes have also encouraged inter­
disciplinary and multi-disciplinary approaches, resulting in the involvement of new players,
new perspectives and new methods. Particularly, the inclusion of academic disciplines such
as ecology and anthropology, nongovernmental organizations and the public have been
positive achievements (McDonald and Brown 1995).

2.4.3

Limitations of EIA

Despite the achievements of EIA, the effectiveness of EIA at the project level is
hampered by a number of institutional, technical and political factors. EIA practice is limited
by several weaknesses: the narrow definition of ‘environment’; the failure to adequately
address cumulative impacts; the inability to link policy, planning and assessment; and the sitespecific nature of assessment.

2.4.4

Narrow DeBnition of “Environment”

Although definitions of EIA include within its scope the bio-physical, the social and
the economic aspects of the environment, the primary focus has been on the bio-physical, or
natural, environment. To address the assessment of the social consequences that may follow
from project development, the process of social impact assessment (SIA) emerged. Burdge
and Vanclay (1995, 32) note that “while SIA is normally undertaken within the relevant
national environmental policy framework, it is not restricted to this...”. Often, EIA and SIA
have operated as parallel, but separate, processes, thereby limiting the potential for moving
toward true sustainable development.

31

2.4.5

Failure to Address Cumulative Impacts

The need to address cumulative impacts - the combined environmental impacts of a
number of activities - is a “structural inadequacy of the conventional project and site-specific
application of the EIA process” (McDonald and Brown 1996,486). There is a need for EIA to
promote or regulate multiple developments within a specified geographical area (e.g.,
development plan or land-use plan), or within a particular sector (e.g., energy, transport,
forestry or tourism operations) (Lee and Walsh 1992,130).
Small-scale developments are frequently excluded from the process, which by
themselves may not have a significant environmental impact, but may have a cumulative
impact when combined with a number of other projects in the region. Efforts have been made
to extend project-level EIA to encompass certain types of large-scale projects and the
incremental effects of numerous small-scale actions of similar type, however, these are often
difficult to address without a strategic framework (Dalal-Clayton and Sadler 999).

2.4.6

Inability to Link Policy, Planning and Assessment

By the point that EIA is applied, “higher-order questions of whether, where and what
type of development should take place have been decided, often with little or no
environmental analysis” (Dalal-Clayton and Sadler 1999, 5). The types of projects that are
subject to an imposed requirement for EIA are often limited (projects that are often exempted
include defence or security-related developments, forestry, and agriculture) (Therivel et al.
1992). EIA has also been accused of only a means to justify decisions once they have already
been made. In many instances, the decision to go ahead with a development has already been
committed to by a company or government, and the economic costs of not going ahead are too
great in terms of jobs, revenues, and taxes. Mitigation measures are not often followed, and

32

once a decision to go ahead has been made, efforts to ensure that monitoring and mitigation
measures are being followed are not done at all.

2.4.7

Site-Specific Nature of Assessment

A common criticism of EIA is that it is only applied at the development project level,
addressing only a single project at a specific site. The influence of EIA could be far greater if
it were applied at higher levels of decision-making - policies, plans and programs. EIA at
these levels is referred to as strategic environmental assessment. Strategic environmental
assessment, or SEA, emerged as a response to the limitations and criticisms of EIA. Many
authors have argued that project-level EIA cannot lead to the comprehensive protection of the
environment itself (e.g., Partidario 2000; Sadler and Verheem 1996; Lee and Walsh 1992;
Therivel et al. 1992), and that EIA needs to operate within an integrated framework of
environmental decision-making.
2.5 Strategic Environmental Assessment (SEA)
2.5.1

Introduction

The limitations of EIA have been well documented (e.g., Dalal-Clayton and Sadler
1999; Sadler and Verheem 1996; McDonald and Brown 1995; Ortolano and Shepherd 1995;
Lee and Walsh 1992; Therivel et al. 1992). The principal reasons are that EIA starts too late,
ends too soon, and is too site-specific. EIA reacts to development proposals rather than
anticipating them.

Additionally, it does not steer developments towards environmentally

resilient locations or away from sensitive areas or even to suggest alternatives. It only allows
for proposals to be accepted or rejected. SEA evolved in part in response to these criticisms.

33

In contrast to project-level EIA, SEA considers a broader scope of impacts (such as
cumulative, secondary and indirect impacts). SEA also uses the concept of ‘tiering’ - higherlevel EIAs (or SEAs) can cover general issues before major project-level decisions. SEA can
incorporate sustainability principles throughout decision-making; from policies, plans and
programs down to the level of projects. These arguments are not intended to imply that SEA
should replace project EIA, but rather, refer to the potential for SEA to strengthen project EIA
(Partidario 2000).
Generally, SEA refers to a higher-order type of environmental assessment at the level
of policies, plans and programmes and is set in the context of the overall vision and within a
specified set of goals and objectives for a region (Noble 2000). The principles and processes
of SEA has evolved significantly since it was first discussed in the literature in the early
1990s.
Therivel et al. (1992) provides one of the earliest definitions of SEA, focusing on only
the environmental component of sustainable development:
[SEA is] a formalised, systematic and comprehensive process that evaluates
environmental effects o f plans, policies and programmes, considers
alternatives, includes a written report on the findings in publicly accountable
decision-making. (Therivel et al. 1992, 12).
Several years later, Sadler and Verheem (1996) provided a definition that stressed the
need to incorporate economic and social impacts in addition to environmental ones, resulting
in one of the most complete definitions available in the literature:
[SEA is] a systematic process fo r evaluating the environmental consequences
o f proposed policies, plans or programmes initiatives in order to ensure they
are fully included and appropriately addressed at the earliest appropriate
stage o f decision-making on par with economic and social considerations.
(Sadler and Verheem 1996, 27)

34

This definition highlights the key attributes of SEA, focusing on the need for a process
which evaluates the economic, social and environmental impacts of decisions, at the earliest
possible stage.

SEA has emerged onto the international stage through the efforts of the European
Commission to build on its earlier directive for environmental impact assessment. The recent
adoption of the Directive on the Assessment of the Effects of Certain Plans and Programmes
on the Environment (also known as the EU SEA Directive) in June 2001 requires the EU
Member States to implement legislation for SEA for plans and programmes (including
comprehensive plans). A supplement to the Espoo Convention (1991) is the Protocol on
Strategic Environmental Assessment - also known as the Kiev (SEA) Protocol - signed by 35
countries on May 21, 2003 in Kiev (UNECE 2003). The United Kingdom is one of the
signatories to the protocol, however, neither the United States nor New Zealand signed. Once
in force, this Protocol will require its Parties to evaluate the environmental consequences of
their official draft plans and programmes. In contrast to the EU SEA Directive, this protocol
is not legally binding.

2.5.2

Rationale for SEA

The literature identifies three primary objectives for SEA; (i) to strengthen projectlevel EIA; (ii) to address cumulative and large-scale effects; and (iii) to incorporate
sustainability considerations into all stages of policy formulation (Sadler and Verheem 1996;
Therivel & Partidario 1996; Wood & Djeddour 1992). These objectives are compatible with
those recommended through Agenda 21.

35

SEA is not intended to replace project-level EIA, rather it is meant to strengthen it, or
to ‘add value’ to the decision-making process (Partidario 2000; Lee and Walsh 1992). SEA
can incorporate sustainability considerations by addressing the cause of environmental
problems at their policy source, rather than just treating the symptoms or impacts (Sadler
1996). SEA can also serve as an early warning mechanism to identify cumulative effects
recognizing these are best dealt with on a regional level rather than on a project-by-project
basis.
2.5.3

SEA’s Relationship with EIA

EIA and SEA have a similar objective - to integrate environmental considerations into
the decision-making process (Partidario 1996; Sadler 1996; Sadler and Verheem 1996; Lee
and Walsh 1992). However, as McDonald and Brown (1996) point out, project-level
environmental assessments are generally applied too late in the decision-making process and
often are used to justify decisions already made.

SEA has the potential to address this

deficiency. While SEA and EIA differ fundamentally in scope and in the nature of their
approach, there is room for collaboration. The framework within which SEA is carried out is
encompasses a larger scope and context than project-level EIA does. Additionally, it enables
the consideration of alternative options, rather than simply looking at option alternatives, as is
the case with project-ElA currently. Refer to Table 3 for other comparisons.
In principle, SEA and EIA can and should be tiered or vertically integrated (Sadler,
1996).

It has been widely suggested that project-level EIA can operate more effectively

within the ‘tiered’, or hierarchical, nature of the SEA framework (e.g.. Noble, 2001; Partidario
1996; Sadler 1996; Lee and Walsh 1992; Therivel et al. 1992; Wood and Djeddour 1992).

36

Table 3

EIA and SEA compared
EIA

SKA

Is usually reactive to a development proposal.

Is pro-active and informs development proposals.

Assesses the effect of a proposed development
on the environment.

Assesses the effect of a policy, plan or programme
on the environment, or the effect o f the
environment on development needs and
opportunities.

Addresses as specific project.

Addresses areas, regions or sectors of development.

Has a well-defined beginning and end.

Is a continuing process aimed at providing
information at the right time.

Assesses direct impacts and benefits.

Assesses cumulative impacts and identifies
implications and issues for sustainable
development.

Focuses on the mitigation of impacts.

Focuses on maintaining a chosen level of
environmental quality.

Has a narrow perspective and a high level of
detail.

Has a wide perspective and a low level o f detail to
provide a vision and overall framework.

Focuses on project-specific impacts.

Creates a framework against which impacts and
benefits can be measured.

Dalal-Clayton and Sadler 1999,3

Therivel et al. (1992, 22) suggest that:
In theory, sustainability requires that a proactive approach to the environment
and development be taken. This would encompass a wide range o f human
activities and environmental factors which need to be made an intrinsic part o f
all policies. Sustainability would be implemented by being ‘trickled down’
through plans, programs, and ultimately projects, [emphasis mine].
Noble (2000, 217) notes that in a typical tiered-forward process, actions at one stage
are conditioned by actions in previous stages; as decisions and developments progress to later
stages of the process, feasible alternatives to the proposed action become increasingly limited.
Partidario (2000) illustrates the tiered-forward process in Figure 2.

37

Figure 2

SEA as a tiered-forward process

POLICIES

r

SEA

r
EIA

PLANS

PROGRAMMES

DEVELOPMENT PROJECTS
Partidario 2000, 654

2.5.4

Principles of SEA

The concept of the ‘strategic’ element has been identified by many authors as a key
element to effective SEA (e.g., Noble 2001; Partidario 2000; Therivel et al. 1992). This
encompasses the need for a proactive assessment within a broader framework. Noble (2000,
211) argues that SEA “must be a proactive assessment, set in the context of broader visions,
goals and objectives, leading to a strategy for action, and considered a wider range of
alternatives to determine the preferred option”.
Many authors have identified various principles to provide the rationale for SEA as
well as to guide its implementation (e.g., lAIA 2001; Partidario 2000; Sadler 1998; Sadler
1996; Sadler and Verheem 1996; Therivel et al. 1992). In the widely dispersed final report for
the International Study of the Effectiveness of Environmental Assessment, Barry Sadler
(1996) identifies thirteen “Guiding Principles”. These principles have been selected to form
the basis of this thesis because of the relative frequency of citations within the literature

38

(Table 4). Sadler (1996, 150) notes that these reflect “those developed earlier but with
modifications from the guidelines in force in the countries and international organizations
reviewed”.
Table 4

Guiding Principles of SEA

initiating agencies are accountable for assessing the environmental effects of new or amended policies,
plans and programmes
the assessment process should be applied as early as feasible in proposal design
scope of assessment to be commensurate with the proposal’s potential impact or consequence for the
environment
objectives and terms of reference should be clearly defined
alternatives to, as well as the environmental effects of, a proposal should be considered
other factors, including socio-economic considerations, to be included as necessary and appropriate
evaluation of significance and determination of acceptability to be made against policy framework of
environmental objectives and standards
provision should be made for public involvement, consistent with potential degree of concern and
controversy of proposal
public reporting of assessment and decisions (unless explicit, stated limitations on confidentiality are given)
inclusion of environmental factors in policy making
tier processes, where possible, to subsidiary SEA and project EIA
monitoring and follow-up of measures, including tracking proposals that initiate further actions
need for independent oversight of process implementation, agency compliance, and government-wide
performance.
Sadler 1996, 151

2.5.5

Approaches and Models of SEA

Approaches
Two distinct approaches to apply SEA to strategic decisions can be identified in the
literature: (i) the top-down (or policy-based) approach and (ii) the bottom-up (or EIA-based)
approach (Partidario 2000; Partidario 1996; Shepherd and Ortolano 1996). In the top-down
approach, sustainability principles are established and they trickle down to policies, plans and
programs, and then to projects. This is the approach that has been taken in New Zealand with
the Resource Management Act, and in Denmark’s SEA of government bills.

39

In the bottom-up approach, project-level EIA’s limited scope is expanded to higherlevel assessments of policies, plans and programs (PPPs). This approach has been adopted in
the Netherlands and the United Kingdom.
Models
Based on both Sadler (1996) and the European Commission SEA Report (Sheate et al.
2001a), four models of SEA are identified (Figure 3): the standard (or EIA-based) model; the
equivalent (or environmental appraisal) model; the integrated (or environmental management)
model; and ad hoc mechanisms of environmental integration.
The standard (EIA-based) model is a rational, technical process where the SEA
process is designed based on existing EIA processes. This model is inherent in Lee and
Walsh’s (1992) observation that the principal stages of SEA and EIA procedures are the same.
The standard model of SEA is patterned after the EIA process with similar steps and activities
but with differences introduced by more fluid policy requirements (Sadler 1996). An example
of the standard model is seen in Denmark’s SEA of Government Bills.
Figure 3

The relationship between models of SEA

.\ppniis:iliiispired SI \

in sp ired

Baseline
Information

.\d lin e
.No syslciiiiitic
proces.s

Objectives led
Indicators

Alternatives
Public Participation

Monitoring
liilegrii(io ii:ir\

SKA

Sheate et al. (2001)
40

The equivalent (or environmental appraisal) model identifies and evaluates impacts of
a preferred option against established objectives. Generally no baseline survey is undertaken,
and there is very little direct public participation. This model is often used with regional and
spatial land use planning such as the United Kingdom’s sustainability appraisals).
The integrated (or environmental management) model is a combination of the first two
models discussed. SEA is undertaken as an integral part of a comprehensive policy and plan
setting process (Sadler 1996). Impacts are appraised against both environmental baseline
information and sustainability objectives.

This model emphasizes the need for the early

application of SEA in the decision-making process, investigates alternative options of
achieving objectives, and promotes the participation of the public. This form of SEA is often
found where there is a strong national environmental legislation and policy framework such as
with New Zealand’s Resource Management Plan.
A number of ad hoc mechanisms of environmental integration form the basis for
evaluating environmental impacts of plans, policies, and programmes in many countries
today. This collection of independent processes include roundtables, auditing procedures, and
state of environment reports. No systematic processes are found that provide links to the
developing policy.

2.5.6

SEA Methodologies

Progress in the development of SEA methodology has been relatively slow.

The

reasons for this lack of advancement is twofold: first, SEA is a new, emerging area of practice
and methodology is still evolving (Sadler 1996); and secondly, it has proven to be difficult to
develop methods, particularly because the outputs are general and the effects and
consequences are difficult to identify and trace (Sadler 1996).

41

Bridgewater (1989) notes that “SEA methodology has not been adequately developed
and attention needs to be focused on the development of an appropriate framework, a set of
guiding principles and a set of tested methods.” This framework “needs to be highly adaptive
and flexible in its methods as it operates within many different contexts, deals with many
different societal values and with high levels of uncertainty.” (Partidario 2000, 655).
Partidario (2000, 655) further states that there is no one universal approach to SEA and no
single tool - a family of tools is more appropriate. Practical case studies have illustrated that
there is a range of tools and techniques that have been applied in support of EA at all levels of
decision-making (Sadler, 1996). The SEA ‘tool kit’ includes the familiar tools and techniques
used in project-level EIA such as checklists, matrices, surveys, case scenarios/studies,
interviews, modeling (GIS) or cost-benefit analysis (CEAA 1997; Sadler and Verheem 1996).
While these tools are similar to those used in project EIA, they are used in a different context
under SEA.
Sadler (1996) makes a distinction between methods of impact identification and
impact analysis. For example, impact analysis methods apply to plans and programs that
“initiate projects and where environmental effects are expected to be significant and
quantifiable or tangible” (Sadler 1996, 17). Davey (1997, 19) suggest that tools are used to
“stimulate discussion of alternatives, thereby influencing the choice of options”. However, at
the project level, “tools are used more to evaluate impacts of chosen projects, regardless of
whether the project itself is sustainable” (Davey 1997, 19).
An additional impediment to the development of SEA methodologies is the need for
different tools and techniques for each level of decision-making. For example, many authors
have noted that it is becoming apparent that SEA at the plan level is distinct from SEA at the

42

policy or program level, and therefore, different methods are required for each (Partidaro
2000; CSIR 1996). A method known as strategic sustainability &y.yga^sment, as advocated by
Partidario and Moura (1996), is not a procedure like SEA or EIA, but rather, “it intends to act
as an instrument that, while operating in the context of a SEA procedure, provides a
framework based on quantifiable approaches (thresholds and targets), and a mechanism to
check on the sustainability trends of a proposed, or on-going, strategy (whether policy,
planning or program)” (Partidario and Moura 2000, 30). This particular method encompasses
both the broader definition of ‘environment’ to include a wider assessment of sustainability
measures, and enables the quantification of strategy effectiveness.

A group of methods

referred to as sustainability assessment systems have been developed for use at the local level
(see section 2.6).

2.5.7

European Union’s SEA Directive

The European Commission (EC) first prepared a preliminary draft directive on the
environmental assessment of policies, plans and programs in 1991. After over ten years of
negotiations among the member states, the EC finally adopted the directive in June 2002, and
is now referred to as the European Union’s SEA Directive 2001/42/EC (2001). The purpose
of the SEA Directive is to ensure that environmental consequences of certain plans and
programmes are identified and assessed during their preparation and before their adoption
(CEC 2001).
The directive is clearly modelled on the EIA directive (Curran et al. 1998). It restricts
the requirement to undertake SEA to land-use plans and programmes which are formally
adopted as part of the land-use decision making process and specifies the sectors to be
included (CEC 2001, Article 3). The directive applies to the comprehensive plans as well as

43

to transport, energy, waste management and other plans and programs where they are prepared
by a ‘competent authority’.
For the purposes of this Directive, the legal text states that ‘plan’ and ‘programme’...
(i) refer only to town and country planning plans and programmes:
• which are subject to preparation and adoption by a competent authority
or which are prepared by a competent authority fo r adoption by a
legislative act, and
• which are part o f the town and country planning decision-making
process fo r the purpose o f establishing the framework fo r subsequent
development consents, and
• which contain provisions on the nature, size, location or operating
conditions o f projects;
(ii) include modifications o f existing plans and programmes as described in
point (i).
(CEC 2001, Article 3)

This definition includes town and country planning plans and programmes in sectors
such as transport (including transport corridors, port facilities and airports), energy, waste
management, water resource management, industry (including extraction of mineral
resources), telecommunications and tourism. The information that is to be included in an
environmental statement prepared for these plans must assess the “significant direct and
indirect effects of implementing the plan or programme on human beings, fauna, flora, soil,
water, air, climate, landscape, material assets and the cultural heritage...” (CEC 2001).
The United Kingdom and Germany were reluctant to agree to the Directive, on the
grounds that it did not adequately consider sustainability assessments, encompassing a fairly
narrow perspective of the ‘environment’. Additionally, the required environmental statement
provided less flexibility than the approach currently being taken by the UK in relation to its
sustainability appraisals.

44

2.5.8

Challenges and Barriers to SEA

While SEA has enjoyed widespread support in the literature as a tool to aid decision­
making, there are several challenges to its development and application. Some of these have
been discussed in previous sections, such as the difficulties with developing methodologies
specific to the level of decision-making. Other challenges include: problems of system
boundaries (e.g., institutional, administrative, and political contexts); lack of information
about existing and projected future environmental conditions; the large number and variety of
alternatives to be considered at different stages of policy formulation; uncertainty over public
involvement in the policy-making process; and the political nature of the decision-making
process (Therivel et al. 1992, 41). It has also been recognized that government agencies do
not have the required level of expertise or resources (both human and financial) (Therivel et
al. 1992, 57).
Sadler (1996) identified several institutional barriers to introducing and implementing
SEA which have been supported by several authors (refer to Table 5).
Table 5

Institutional barriers to introducing and implementing SEA
Insufficient political will - as indicated by low priority given to environmental concerns,
by closed processes of decision-making, and by low levels of accountability
Limited societal support base - as indicated by low degrees of activism and of political
influence by public and community groups
Narrow definition of issues - reflected in prevailing emphasis on economic growth and
failure to consider strategic environmental implications
Compartmentalized organization structures - typically, consideration of environmental
matters is curtailed by the sectoral division of political powers and agency
responsibilities
Bureaucratic prerogatives —environmental requirements encroach on the “turf and

territory” of other sectors which is zealously guarded by officials, especially at the
policy level
Cited in Sadler (1996,148)

45

Horton and Memon (1997) argue that the implementation of SEA can result in the
“uneven development of the environment”.

Based on the inherent conflict between

‘environmental sustainability’ and ‘economic development’, they argue that SEA displaces
and defers this conflict by avoiding some sites and promoting others. Arguing along similar
lines as Campbell (1996) as discussed in section 2.2.2, Horton and Memon (1997) suggest that
if SEA is to contribute to sustainable development, “it must confront directly the conflict of
development and the environment, it must resist rhetorical solutions that disguise the conflict,
and it must avoid spatial solutions that displace the conflict.” (Horton and Memon 1997, 174).
2.6

Strategic Environmental Assessment at the Local Level
2.6.1

Introduction

Many authors advocate the promotion of sustainable development at the local level
through impact assessment systems (e.g., George 2001; Devuyst 2000; Devuyst et al. 2000;
DoE 1993). Methods and tools to evaluate sustainability at the local level can be termed
‘sustainability assessment systems’ (Devuyst 2000; Devuyst et al. 2000). The most common
means of assessing local sustainability has been through the use of sustainability appraisals,
as practiced since 1993 in the United Kingdom, as well as several other European countries.
More recently, Eggenberger and Partidario (2000) have begun investigating the development
of a theoretical framework at the comprehensive planning level to integrate economic, social
and environmental factors.
Devuyst (2000) notes that there are two approaches to assess sustainability at the local
level: (i) those which check whether local authorities are making progress in general in a
sustainable development context (e.g., environmental audits); and (ii) those which check
whether specific policy proposal developed are in line with sustainability goals - more in line

46

with impact assessment systems (e.g., sustainability appraisal).

Although Devuyst (2000)

discusses the relevance of both approaches to be incorporated in a local sustainability
assessment system, the focus in this thesis will be on the second approach.

2.6.2

Developments in Sustainability Appraisal in the United Kingdom

Since 1991, the United Kingdom (UK) has been developing methodologies for
environmental appraisal, and then later, sustainability appraisal, in relation to evaluating the
impacts resulting from development plans. Sweden, Finland, Germany, France, Norway, the
Netherlands and the United States have all had some experience with SEA-type systems at the
local level, however, the UK has been instrumental in developing methods for the
implementation of theory into practice. Sustainability appraisal is a form of SEA that follows
an appraisal, or EIA-based approach, as defined by several authors (Sheate et al. 2001a; Sadler
1996; Partidaro 1996).
The UK Government released its White Paper on the Environment, This Common
Inheritance, in 1990 (DoE 1990), which stressed the importance of ensuring that
environmental considerations were fully incorporated into policy development.

This

document was followed by Policy Appraisal and the Environment (DoE 1991), which was
aimed at central government managers to show ‘how environmental effects can be taken into
account in environmental and other policies’.

In 1994, Environmental Appraisal in

Government Documents, reviewed activities resulting from DoE’s 1991 document.
The UK government furthered its influence and commitment to sustainable
development into comprehensive planning.

The publication of Planning Policy Guidance

Note 12 (PPG12), Development Plans and Regional Guidance (DoE 1992) marked the
beginning of the environmental assessment of local authority development plans

47

(comprehensive plans) in the UK. PPGs in England and Wales are non-statutory guidance for
local authorities and are highly ‘encouraged’, however, they do not carry the statutory weight
accorded to the Town and Country Planning Act.

In Scotland, sustainability appraisal is

promoted through the non-statutory Scottish Planning Policy 1 (SPP 1)^
The concept of ‘environmental appraisal’ was replaced with ‘sustainability appraisal’,
in recognition of the UK Government’s four objectives of sustainable development: (i)
maintenance of high and stable levels of economic growth and employment; (ii) social
progress which recognizes the needs of everyone; (iii) effective protection of the environment;
and (iv) prudent use of natural resources (DETR 1996a).

In this same vein, the UK

government makes a distinction between SEA and sustainability appraisal. SEA is considered
to focus more narrowly on environmental impacts, whereas sustainability appraisal has a
broader scope, including social and economic factors in addition to environmental ones
(DETR 1999a).
Sustainability appraisal of a development plan is quite distinct from that an assessment
of a trade agreement or a national energy policy (George 2001; CSIR 1996). If a planning
system has adopted the concept of sustainable development, then the appraisal will evaluate
the individual pohcies against the plan’s stated goals and objectives. If not, then the policies
(in addition to the goals and objectives) would need to be assessed against a set of identified
sustainability criteria. Sustainability criteria can be effectively used to develop the plan’s
goals and objectives. The literature identifies a number of sets of sustainability criteria (e.g.,
Berke and Conroy 2000; DETR 2000; Hardi and Zdan 1996; DoE 1993). The Bellagio
* Scottish Planning Policies replaced National Planning Policy Guidelines in 2002.
*A Structure Plan “should provide a long-term vision (looking forward at least ten years) as part of an area’s
development requirements, considering the functions and inter-relationship of places, expressing the settlement
strategy for the area and identifying priorities for urban and rural regeneration.” from Scottish Planning Policy
SPPl (The Planning System), Section 32 (Structure Plans). (Scottish Executive 2002a).

48

Principles (Hardi and Zdan 1997), discussed in section 2.1.4 and outlined in Table 2.1, present
10 guidelines for the measurement of progress toward sustainable development. Berke and
Conroy (2000) present a set of six principles that define and operationalize the concept of
sustainable development, based on an extensive search of the literature: harmony with nature,
liveable built environment, place-based economy, equity, polluters pay, and responsible
regionalism (Berke and Conroy 2000, 23). In the UK, the sustainability appraisal process, as
described in the UK government’s good practice guide (DoE 1993; DETR 2000), requires that
policies are appraised against a range of criteria representing the four objectives of sustainable
development in national policy: maintenance of high and stable levels of economic growth
and employment, social progress which recognizes the needs of everyone, effective protection
of the environment and prudent use of natural resources. This is often referred to as an
“objectives-led” approach.
George (2001, 103) argues that the objectives-led approach can lead to a lack of clarity
between what is appraisal and what is planning. He contends that if the planning process aims
to deliver sustainable development, “it must itself define objectives for sustainable
development, and evaluate the interacting social, economic and environmental factors that
contribute to that goal.” Sustainability appraisal, then, is an evaluation of the plan in relation
to its own objectives for sustainable development. George (2001, 100) presents an alternative
“eriterion-based” approach to appraisal, claiming that the definition of a set of criteria against
which the planning process may be judged is an important part of applying sustainable
development principles in practice. George (2001, 100) suggests that the Rio Declaration’s
Principle 3 (which establishes the twin principles of inter-generational and intra-generational
equity) is a good place to begin.

Then, other principles (specifically the ‘precautionary

49

principle’ and the ‘polluter pays principle’) and international commitments (specifically the
Climate Convention and the Biodiversity Convention) can follow. Sustainability appraisal
then judges whether the planning process complies with Rio’s sustainable development
objectives.

2.6.3

Sustainability Assessment Systems

Devuyst (2000) provides examples of both forms of sustainability assessments: those
that attempt to measure progress toward sustainability after implementation (essentially an
auditing function), and those that try to assess the sustainability of policy proposals before
they are implemented (more in line with impact assessment). Devuyst et al (2000) support the
integration of sustainability indicators and targets as an important component of sustainability
assessment in local systems.

Rather than promote a universal methodology to assess

sustainability at the local level, Devuyst et al. (2000) identify a number of different forms of
assessments currently in use in several municipalities world-wide. For example, the Dutch
city of Tilburg has developed a sustainability check called DOTIS in 1997. It consists of a set
of questions which make it possible to assess if certain sustainability goals and measures for
sustainable development are present in the policy proposals developed by the city government.
The City of Ottawa in Canada introduced an environmental assessment system, called the
Municipal Environmental Assessment Process (MEEP) which reviews development
applications for potential environmental effects. MEEP was unique in Canada in that it is the
first environmental evaluation process established at the municipal level that addresses all
lands and activities within the municipality (Devuyst 2000).
Devuyst and van Volsem (1999) have developed sustainable lifestyle assessment
(SLA) to predict, analyze, and evaluate the impacts of all long-term, mid-term and short-term-

50

or routine - decisions made over a lifetime, making use of sustainability goals as a point of
reference (Devuyst and van Volsem 1999, 11).
2.6.4

Integration Framework

The relevance of integration has received much attention in recent years, particularly
in relation to sustainability and planning. According to Kirkpatrick and Lee (1999),
Integration has become a favoured means o f increasing the effectiveness o f
environmental assessment and social and economic appraisal in decision
making in order to promote sustainable development (Kirkpatrick and Lee

Eggenberger and Partidario (2000) have initiated research to develop a framework to
assist the integration of environmental, social and economic issues in comprehensive
planning. There is evidence of planning traditions where it is customary to integrate
environmental issues and concerns into the planning process.

This has resulted in some

practitioners claiming that SEA procedures are not required in comprehensive planning, as the
plans already cover EIA requirements (Partidario, 1996).

However,

Eggenberger and

Partidaro (2000, 202-203) ask.

Are such planning traditions actually carrying out systematic identification
and integrated assessment o f alternatives, in participatory contexts, in a way
that is informative, and accountable... [?]
The focus of comprehensive planning is still strongly oriented towards economic
efficiency and the management of economic growth, and ultimately, comprehensive planning
has to adopt “the role of anticipating development, proposing alternatives and measures, and
co-ordinating sector activities” (Eggenberger and Partidario 2000, 203). This leads to the
identification of a new challenge for planning - the management of change and uncertainty -

51

which can only be achieved if integration is the guiding principle in devising planning
approaches (Eggenberger and Partidaro 2000).
2.6.5

Challenges and Barriers to Sustainability Appraisal

Researchers have identified several barriers to the implementation of sustainability
appraisal at the local level. Most prevalent is the additional investment of time and money to
develop and implement assessment systems.

Many municipal planning departments have

limited financial and human resources to expend to such a venture (Therivel 1998; Partidario
1996). There is also a perception on the part of many planners that comprehensive plans
already cover EIA requirements (Eggenberger and Partidario 2000). Planners also claim that
integration of economic, social and environmental factors have been a tenet of comprehensive
planning for a long time.

However, there is limited evidence suggesting that this is

demonstrated in practice (Eggenberger and Partidario 2000). In many countries, there is a lack
of an overall framework at a higher level of decision-making to guide lower level actions
(Eggenberger and Partidario 2000). If the political commitment and accompanying legislation
do not exist, it is unlikely that local planners will advocate the use of sustainability appraisal.
Noble (2000, 211) argues that most SEAs that have been completed to date around the
world are “simply various forms of project, plan or program assessments and appraisals”. He
maintains that the actual focus of SEA should be on strategic alternatives, and not simply post
hoc assessments. In contrast, Sadler (1999, 1) views the move towards environmental or
sustainability appraisals “which often document the extent to which development plans move
toward or away from sustainability requirements” as “promising developments, especially if
they can incorporate more explicit environmental and sustainability indicators.”

52

2.7

Summary
The literature highlights two primary reasons for the development of environmental

assessment methods: (i) to gauge the progress of society’s transition to sustainability; and (ii)
to evaluate the impact of human activities on both the bio-physical and socio-economic
environment.

Environmental assessment serves as a way to ensure that sustainable

development principles are being implemented into practice.

Strategic environmental

assessment expands on well-established environmental impact assessment processes to ensure
that policies, plans and programs are also evaluated, in addition to development projects. In
response to SEA’s perceived focus on bio-physical environmental factors, sustainability
assessment systems have been developed to emphasize the integration of all three components
of sustainable development.
Comprehensive planning has been identified in the literature as a potential vehicle for
the integration of environmental issues with those of economic and social concerns.
Environmental assessment methods at the local level have been ad hoc at best and have
included sustainability roundtables, environmental audits, and state of the environment
reports. The literature describes several cases of current assessment practices, however, these
cases lack a consistent framework and fail to explain which conditions are required to
facilitate SEA and which factors can make SEA successful.
In the following chapter, the research design is presented. The rationale for the case
study approach and the methods employed for the collection and analysis of the data are
discussed.

53

Chapter Three
Research Design and Methods
3.0

Introduction
The preceding chapter presents a general theoretical framework from the literature for

the analysis of sustainability within a local planning context and the potential for the
implementation of SEA at the local or municipal planning level. A means to examine the
research questions outlined in Chapter One was explored using a case study approach. This
chapter provides a discussion of the rationale for a case study approach, the units of analysis
selected, and the methods for collecting and analyzing the data. Criteria are introduced for the
selection of the case studies, followed by a description of the selected cases. The chapter
concludes with a discussion on the validity and reliability of the research.
3.1

Research Design
This research comprises both qualitative and quantitative methods, both encompassed

within a case study approach.
descriptive information.

Qualitative inquiry enables the collection and analysis of

The qualitative approach involves observing contemporary

phenomena in the natural world, with the researcher performing the role of interpreter
(Marshall and Rossman 1999).

Although this research focuses primarily on qualitative

approaches, quantitative methods are used to complement the analysis to ‘weight’ responses.

3.1.1

Case Study Approach

Yin (1994, 23) defines the case study as:
...an empirical inquiry that investigates a contemporary phenomenon within its
real-life context when, the boundaries between phenomenon and context are
not clearly evident, and where multiple sources o f evidence are used.

54

The case study approach is appropriate to this thesis research because of the
researcher’s decision to cover contextual conditions, as they have significant relevance to the
phenomenon under study. Multiple sources of evidence are used in case study research which
contributes to both the validity and the reliability of the research.
This approach is used by researchers primarily in three circumstances: (i) when the
researcher has access to, but not control, over the subject of study (Yin 1994); (ii) when
research questions are asking “how” or “why” certain events or practices occur (Yin 1994);
and (iii) when the researcher is seeking a general understanding and believes that insight may
be gained into a question by studying a particular case or cases (Stake 1995). This thesis
incorporates all three of the above statements. First, the researcher has access to the academic
literature as well as the government documents and reports relating to the case studies, but
remains an unobtrusive observer and interpreter. Second, this research is exploring how SEA
has been applied to comprehensive planning and how effective these SEA systems have been.
Third, this research seeks a general understanding of how SEA has been applied to
comprehensive plans by examining three cases in depth that have been identified as ‘good
practice’ SEA in the academic literature or by practitioners.
Yin (1994) discusses several types of case study research designs. The research design
can include a single case that is investigated in depth, or can comprise multiple cases that are
compared by identified criteria. Furthermore, both the single and the multiple case designs
can be further distinguished as either holistic (single unit of analysis) or embedded (multiple
sub-units of analysis). This thesis has employed a multiple case study design, with embedded
units of analysis. The units of analysis of a case study define what exactly is being studied.
Although case studies may commonly be about people, organizations or communities, Yin

55

(1994, 22) notes that case studies have also been done about decisions, programs,
implementation processes, and even organizational change. In this thesis research, the units of
analysis are the components of the SEA systems of the individual cases.
3.2

Methods
The case study approach often involves collecting a variety of data and observations

from different sources. The use of multiple sources of evidence contributes to the validity and
reliability of case study research, also known as triangulation. This thesis study uses three
primary methods; (i) a literature review; (ii) the development of evaluation criteria against
which to describe and analyze the case studies; and (iii) post-hoc analysis, which includes
document reviews and interviews (see Figure 4).

3.2.1

Literature Review

An extensive review of the literature was conducted using both the academic juried
literature, as well as the so-called ‘grey literature’ which consists of unpublished reports and
government documents. The purposes of the literature review are threefold: (i) to provide an
overall context and rationale for the strategic environmental assessment of comprehensive
plans; (ii) to determine which countries and local planning authorities are undertaking
strategic environmental assessments of their comprehensive plans; and (iii) to assist with the
development of an analytical framework and the identification of evaluation criteria.

3.2.2

Development of Evaluation Framework and Criteria

An analytical framework and a set of evaluation criteria against which the performance
of an SEA system for comprehensive planning can be tested is suggested in Chapter Four.
This framework is derived from both the academic literature as well as from international

56

studies (for example, the International Study on the Effectiveness of SEA and the European
Union’s SEA Report).

The framework comprises five reference levels of analysis: (i)

normative; (ii) policy; (iii) institutional; (iv) SEA process; and (v) SEA methods.

3.2.3

Post Hoc Assessment

The term post hoc assessment is a research method generally undertaken to improve
resource and environmental planning and management by assessing the strengths and
weaknesses of previous experiences (Serafin et al. 1992; Mitchell 1989). Interactiveinterpretive post-hoc assessment involves reviews of past documentation and uses interviews
to look beyond the data in a systematic way, thus providing for the discovery of different
perspectives. The interactive-interpretive approach uses a range of ‘objective’ and ‘subjective’
information in the assessment (Nelson and Serafin 1995). This mode is pursued in public
policy and thesis research. Documentation provided most of the data required for this study.
Interviews were conducted to complement the existing documentation, and were intended to
“fill in the gaps” as well as to determine the underlying intent and assumptions made in
relation to the SEA undertaken for each case.
Document Review
A document review may involve the examination of any relevant literature, including
internal reports and archival records (Yin 1994). Documents reviewed for this study included:
government legislation and policy directives, government reports, government memorandums,
land use and comprehensive plans, and SEA reports.
reviewed can be found in Appendix B.

57

A complete list of the documents

Figure 4

Research designs and methods

LITERATURE REVIEW
(Theories and Concepts of Sustainable
Development, EIA, and SEA within a Local
Planning Context)

STAGE ONE

DEVELOPMENT O F EVALUATION
FRAM EW ORK AND CRITERIA

STAGE TWO

(predicated from the theories of SEA)
00

CASE STUDY 1:
SCOTLAND
STAGE THREE

PERTH AND
KINROSS
COUNCIL

CASE STUDY 2:
CALIFORNIA
(USA)
SAN JOAQUIN
COUNTY

1r

STAGE FOUR

CONCLUSIONS AND
RECOMMENDATIONS

CASE STUDY 3:
NEW ZEALAND
WAITAKERE
DISTRICT

Interviews

Although the majority of the information collected for this thesis was compiled from
written sources, interviews were undertaken with identified planners in each of the case
locations to complement the data acquired from the document review. Interviews were
conducted in person for the Scotland case study with follow-up questions through electronic
mail, and by fax and/or electronic mail for the California and New Zealand case studies.

It

should be noted that there was some difficulty in obtaining follow-up information from the
informant in the Waitakere, New Zealand case study. This resulted in a heavier reliance on the
documents.
3.3

Case Studies
3.3.1

Criteria for Selection of Case Studies

The literature review identified both countries and local planning authorities that
undertake environmental assessments of their comprehensive plans (for a list of these, refer to
Appendix A). In order to examine how SEA is carried out, and to evaluate the extent of its
effectiveness, three cases were selected.
The following criteria were used as a basis for the selection of the cases:
•

The cases selected were not limited to only those evaluations referred to as
“strategic environmental assessments”, but included all evaluations of the
environmental or sustainability impacts of a comprehensive plan.

•

Cases should have a formal basis for evaluation. While SEA does not have to be
mandatory, it should have some type of formal structure.

59

•

To reduce difficulties in comprehension and interpretation on the basis of language,
only English-speaking countries were included.

•

Only those plans with the characteristics of ‘comprehensive plans’ were considered
- must be long-range (at least five years), focused on physical development and
land use, be comprehensive, and have a regional focus.

•

Information for the plan must be available and easily accessible by the researcher.

•

The case study must be recommended as an example of ‘good practice’ SEA,
through the academic literature, by practitioners, or by special recognition (such as
awards).

3.3.2

Selection of Case Studies

A number of cases have been highlighted in the literature as examples of ‘good
practice’ SEA in different countries. Based on the selection criteria, the following three cases
were selected for further analysis at a more in-depth level.

These cases are: (i) the

Sustainability Appraisal of the Perth and Kinross Council (Scotland) Structure Plan; (ii) the
Environmental Impact Report of San Joaquin County (California, United States); and (iii) the
Section 32 Analysis of Waitakere (New Zealand) District Plan. The case studies provide an
example of each of the three models of SEA identified by Sadler and Verheem (1996) and the
European Commission (Sheate et al. 2001a), respectively: the equivalent (or environmental
appraisal) model; the standard (or EIA based model); and the integrated (or environmental
management) model.

60

Perth and Kinross Council (Scotland) - Sustainability Appraisal o f the Structure Plan
The European Union Directive on SEA comes into force in July 2004. In view of this
impending requirement on Member States to incorporate SEA into national legislation, it is
appropriate to select one of the Member States as a case study in this research. The United
Kingdom has encouraged a form of SEA, referred to initially as environmental appraisal, and
currently as sustainability appraisal, for development plans since 1993. With over a decade
of experience with the environmental assessment of comprehensive plans, the UK provides a
leading example to serve as a case study. The SEA model applied in the UK reflects the
characteristics of the equivalent or environmental appraisal model.

In this model, an

appraisal is undertaken using expert opinion, with very little or no baseline information.
Appraisals can be undertaken quickly and are usually easy to understand (Sheate et al. 2001a).
The Perth and Kinross (Scotland) sustainability appraisal of their Structure Plan* was one of
the most recent appraisals completed in the UK at the time of this study, and was
recommended as a good example of the use of sustainability principles to guide a plan’s
development and appraisal.
The United Kingdom has provided guidance for a form of SEA, referred to as
“sustainability appraisal”, for development plans since 1993. Although there are currently no
legal provisions to undertake SEA, the European Union has adopted a Directive on SEA
which will require all member states to incorporate SEA into all legislation concerning plans
and programmes by July 2004.
San Joaquin County (California)

-

Environmental Impact Report o f the General Plan.

In the United States, unlike many other nations, government agencies have over three
decades of considerable experience preparing environmental assessments of land use plans.

61

Under the California Environmental Quality Act (CEQA) of 1986, California has one of the
strongest regulatory frameworks for SEA of all the states, requiring that local agencies prepare
environmental impact reports (EIR) for all actions that may have a significant effect on the
environment, including comprehensive plans.
The SEA model as implemented in California represents the standard or EIA-based
model. In this model, the SEA of a strategic action is generally patterned after project EIA
(Sadler and Verheem 1996). However, this case study does not include the heavy dependency
on environmental data that is usually associated with the EIA inspired model. Under CEQA,
EIRs prepared for plans are subject to the same content and process requirements as projectlevel EIRs (Bass and Herson 1999). The EIR for the San Joaquin County General Plan® has
been discussed in the academic literature (Skewes-Cox 1996; Therivel and Partidario 1996;
Sadler and Verheem 1996) and the EIR was awarded the ‘Outstanding Environmental
Document of the Year’ by the Association of Environmental Professionals, California Chapter
in 1992.
Waitakere District (New Zealand) - Section 32 Analysis o f the District Plan
The Resource Management Act (1991) revolutionized environmental management in
New Zealand and caught the attention of the world. The Act replaced more than 50 pieces of
environmental, resource and planning legislation including the EIA Act and the Town and
Country Planning Act. The Environmental appraisal of plans and strategies has been a
requirement under Section 32 of the Act (referred to as Section 32 Analysis) since 1991 under
New Zealand’s Resource Management Act.

The Act reflects the philosophy that local

®A General Plan is to act as a basis for rational decisions regarding a city’s or county’s long-term physical
development; it expresses the community’s development goals and embodies public policy relative to the
distribution of future land uses, both public and private. General Plan Guidelines. (OPR 2002).

62

communities should take greater responsibility for the environmental consequences for their
decisions, and as such, implementation of the Act rests largely in the hands of local and
regional authorities (Dixon 2002). The Waitakere Council District Plan^® was identified by
Ericksen et al (2001) as an example of a ‘good quality’ plan in New Zealand.
This model of SEA closely corresponds to the features of the integrated or
environmental management model.

In this model, SEA is undertaken as part of a

comprehensive policy and planning framework (Sadler and Verheem, 1996). The RMA
provides a framework integrating national, local and regional institutions and systems dealing
with resources, so that the environment can be managed as a whole.
3.4

Methods of Analyses
3.4.1

Comparative Analysis

Comparative analysis is used to determine the effectiveness of SEA application in each
of the case studies. The information collected from each research method (the literature
review, the document review and the interviews) provides the validation of how SEA was
applied in each case (see Eigure 5). This information was then subjected to comparative
analysis. Analysis across SEA systems provides a means of better understanding practice any
particular jurisdiction. Some SEA systems perform better than others and comparative
analysis may reveal the factors which are essential to the success of SEA processes.
Comparative analysis assists to accomplish four tasks. First, comparative analysis was used to
identify criteria to measure the effectiveness of SEA application. Second, it highlights the
enabling conditions and prerequisites necessary for effective SEA application.

Third, it

A District Plan describes the district’s significant resource management issues, and sets out objectives,
policies, methods, and rules (similar to zoning bylaws) to address these issues. (MfE 2002).

63

identifies the barriers to effective SEA application. And fourth, comparative analysis provides
the basis for recommendations to improve the effectiveness of SEA application.
The evaluation framework and criteria (discussed in Chapter Four) is used as an
instrument for comparative analysis. The type of comparative analysis undertaken in this
research is parallel demonstration o f theory which is used primarily for comparing case
studies to a theory to demonstrate its ability to place order on the evidence (Skocpol and
Somers 1980). The three case studies are compared to theory - as described in Chapters two
and three - concerning what principles and objectives a SEA system should achieve.
Figure 5

Triangulation among data sources

Document
Review

Literature
Review

CASE STUDY

Interviews

Possible responses to each of the criteria in the evaluation framework are “yes”, “no”,
or “partially”. Each of the criteria is weighted, where “yes” = 2, “partially” = 1, and “no” = 0.
Scores are totalled and related to the possible maximum score for each of four levels of the
framework. This is discussed further in Chapter Four.

3.4.2

Limitations in Trans-National Comparative Research

There are a number of limitations to undertaking comparative research in a trans­
national context.

These include: data availability, common basis for comparison, data

64

collection and language problems. First, data availability in different countries might not be
the same (Marr 1997, 13-15) and PPPs might not always be directly comparable (Flynn 1993,
62). In the three chosen countries, comprehensive planning systems were fairly similar, based
on traditional British town and country planning. Second, even though knowledge of practice
in one country might encourage innovation in another country (Masser 1984, 151), different
planning traditions and political, institutional and cultural circumstances might require
adaptation to different environments. Thus, it might not be possible to transfer practice from
one country to another, as
the danger o f proposing change in practice in the light o f experience abroad is
that practice may be independent fo r its success upon a chain o f circumstances
which does not apply at home (Booth 1986, 1).
These chains of circumstances depend, in particular, on political and organization
structure. The context of SEA application therefore needs to be highlighted. Once differences
are explained, proposals can be made for improving practice.
Third, problems may arise with terminology having different meaning in different
countries. As discussed in Chapter One, the concept of strategic environmental assessment is
known as different names in different countries. In the United Kingdom, SEA is practiced as
sustainability appraisal in relation to development plans. In California, the form of SEA used
is referred to as an environmental impact report (EIR). The term environmental assessment is
used to describe the evaluation for policies, plans and projects. In this thesis, the concept of
SEA comprises the many different names that exist for procedures that have the attributes of
SEA. Comprehensive planning for physical development is also known by different names in
different countries.

In this research, the focus is on district land-use plans: in Scotland,

structure plans are prepared by district councils; in California, general plans are prepared by
county planning authorities; and in New Zealand, district authorities prepare district plans.
65

Fourth, the use of different languages can be a potential problem when comparing practice in
different countries. In order to avoid problems connected with language, the selected case
studies had English as their official language.
3.5

Issues of Validity and Reliability
Internal validity indicates whether an observation or procedure is sound and that it

measures what it is intended to measure (Babbie 2001). The measuring tool in this research is
the evaluative criteria within the framework that is used to evaluate the case studies. The
selection of the evaluative criteria was based on several similar research initiatives illustrated
in the literature (e.g., Eggenberger and Partidario 2000; Fischer 1999; Theiivel 1995). The
strength of the evaluative criteria is that it is based on a strong theoretical foundation. The
weakness of the criteria is that it can be a subjective measurement, based on the researcher’s
interpretation of whether or not the case studies’ units of analyses exhibit the specified
criteria. To counter this limitation, criteria are chosen that are relatively easy to obtain through
existing documents and interviews. For example, a criterion used to determine the
effectiveness of the institutional framework may be the existence of clear, legal provisions for
SEA for comprehensive plans.
External validity refers to how representative the findings of the research are and how
well they can be generalized among the general population (Babbie 2001). In case study
research, the goal is not to generalize conclusions among the general population, but to
understand the particular case(s) under study and to expand and generalize theories (Stake
1995; Yin 1994). Thissen (2000) has suggested that we learn from the successes and failures
experienced by case study subjects and determine what conditions are favourable and what
barriers may exist. One of the purposes of this thesis is to examine the effectiveness of SEA as

66

applied to comprehensive plans. By examining three case studies in different jurisdictions,
factors that contribute to an effective SEA system can be highlighted, providing guidance to
local authorities and decision makers at all levels.
Reliability in research refers to the ability of other researchers to duplicate the steps of
the research and come to similar conclusions (Babbie 2001; Yin 1994; Stake 1995). In case
study research, there are several methods that can contribute to reliability: the creation of a
case study database and the maintenance of a chain of evidence (Yin 1994). A case study
database was developed and maintained throughout the course of this research and included
items such as documents, interview notes, government reports and legislation, comprehensive
plans, and academic literature. The chain of evidence comprises the steps taken to collect and
analyze the data, as well as the declared goals and objectives of the research. This practice
enables another researcher to follow the same procedures and arrive at the same conclusion.
In the following chapter, a framework is introduced to measure the effectiveness of
SEA for comprehensive plans at the local level. The framework uses evaluation criteria that
are based on SEA procedural and contextual principles and is intended to be applied to
municipal plans (e.g., development plans, comprehensive plans, physical plans).

67

Chapter Four
A Framework for Evaluating SEA Effectiveness for Comprehensive Plans
4.0

Introduction
The effectiveness of environmental impact assessment (EIA) has been of interest to

researchers over the past decade (e.g., Sadler 1996; Wood 1995; Gibson 1993; CEARC 1988),
however, it is only recently that the effectiveness of strategic environmental assessment
(SEA) has been considered (e.g., Therivel and Minas 2002; Gibson and Walker 2001;
Marsden 1998a; Marsden 1998b; Lawrence 1997; Sadler and Verheem 1996). As noted by
Sadler and Verheem (1996, 18), the concern with evaluating effectiveness is with “how well
SEA actually works, which components and activities contribute to or detract from success,
and what realistically could be done to improve process(es) under review”.

These reviews

focus on SEA for policies, plans and programs as a whole, rather than examining the
effectiveness of SEA specifically for comprehensive plans.
Every EA and SEA system operates within a political, legal and administrative context
peculiar to the jurisdiction concerned.

There is a need for an evaluation framework for

comparing the formal legal procedures, and the arrangements for their application and practice
in SEA systems. Sadler (1996, 39) suggests that one way to evaluate ‘effectiveness’ is to
compare EA theory with practice, “contrasting what should be done according to the
established norms of law or science with what is done, either in general or within a particular
jurisdiction” . The purpose of this chapter is to introduce and explain an evaluation framework
that considers the political context, the institutional arrangements, the SEA processes, and the
SEA methods that contribute to the effectiveness of a SEA system for comprehensive plans.
To provide the background for the development of the evaluation framework, this
chapter begins with a discussion on how effectiveness can be measured, and how a greater

68

understanding of context may contribute to measuring the effectiveness of SEA. Then, an
evaluation framework is introduced to analyze the effectiveness of the SEA system by
evaluating the effectiveness of the SEA system both substantively (the extent to which the
objectives of SEA are met) and procedurally (the extent to which the SEA process conforms
to the established provisions and principles for SEA). The chapter concludes with a summary
of the strengths and weaknesses of this framework.
4.1

Concepts of Effectiveness in EA and SEA Systems
Gibson and Walker (2001, 454), building on earlier work by Gibson (1993), describe

seven basic principles for effective application of the environmental assessment; (i) respect
uncertainty; (ii) adopt sustainability as the central objective; (iii) set clear rules for application
and implementation; (iv) assess needs and alternatives; (v) ensure transparency and openness
and public participation; (vi) monitor the results and apply the lessons; and (vii) be efficient.
The increasing attention that has been given to the evaluation of the performance of
EA processes provided the impetus for the International Study into the Effectiveness of
Environmental Assessment. The following statement made in a presentation by the President
of the Canadian Environmental Assessment Agency to the International Association of Impact
Assessment (lAIA) Conference in Shanghai in 1993 formally launched the study:
Has environmental assessment achieved its goal o f helping...reach better
decisions? This is the fundamental question that all...practitioners must begin to
address systematically. (Dorais 1993, 1)
In the study’s final report, the meaning of effectiveness was considered extensively.
The term effectiveness refers to “how well something works or whether it works as intended
and meets the purposes for which it is designed” (Sadler 1996, 37). In the Final Report,
Sadler (1996) describes three dimensions of effectiveness - substantive, procedural and

69

transactive (Sadler 1996).

Substantive effectiveness determines the extent to which EA

performance achieves the “established purpose(s), goals and objectives” (Sadler 1996, 39).
From a substantive aspect, how an EA implementation policy works is the extent to which it
meets established objectives such as the impact of the EA on decision-making, and the
amendment of the activity. Procedural effectiveness determines whether the EA conforms to
the “accepted provisions and principles” (Sadler 1996, 39).

For example, how an EA

implementation policy works from a procedural aspect is the extent to which it meets accepted
principles such as clearly defined objectives, provision of support and guidance, application to
socio-economic effects and provision for monitoring.

Transactive effectiveness refers to the

extent that procedural principles deliver the substantive objectives at the least cost and in the
minimum time possible. In this thesis, only procedural and substantive effectiveness will be
further examined because of time and resource constraints.
A number of researchers have examined the effectiveness of SEA (e.g., Therivel and
Minas 2002; Thissen 2000; Fischer 1999; Marsden 1998; Lawrence 1997). Therivel and
Minas (2002) examine effectiveness in relation to the environmental and sustainability
appraisals of development plans that have been undertaken in the United Kingdom for the past
ten years. Based on four questionnaires of UK planning authorities carried out between 1994
and 2001, they note that an “effective SEA” identifies possible changes to the strategic action
which are sustainable or environmentally benign and are included in the strategic plan, as well
as involving people from different disciplines, particularly those that have knowledge of
sustainability issues (such as LA21 officers). They summarize the evolution and current status
of UK development plan appraisal and consider likely changes that will result from
implementing the European Union’s SEA Directive in 2004.

70

According to Thissen (2000), a strategic action (a policy, plan or program) is compared
before and after the SEA is carried out, noting any sustainability or environmentally-related
changes. SEA has to identify the sustainable or environmental ramifications of implementing
the action and suggest possible changes. SEA’s direct outcomes must be the integration of the
changes into the strategic action.
Fischer (1999) completed research to determine the extent to which current assessment
practice of transport infrastructure-related policies, plans and programs (PPPs) results in
certain benefits of SEA in three European Union regions: North West England (United
Kingdom), the administrative region of Noord-Holland (The Netherlands), and the planning
region of Brandenburg-Berlin (Germany). Fischer (1999) linked SEA principles to commonly
perceived SEA benefits (based on a number of different authors), and introduced a set of
evaluation criteria. Fischer (1999) concludes that current assessment practice of transport
infrastructure-related PPPs in the study regions results in SEA benefits to differing extents,
and no assessment results in high scores.
Marsden (1998a) applied effectiveness criteria to the Government of Canada’s SEA
Directive for Policy and Program Proposals and its context. Using the Guiding Principles of
SEA as defined by Sadler (1996), Marsden (1998a) examined three sets of federal government
regulations (Pulp and Paper Regulations, Yukon Timber Regulations and Endangered Species
Protection Act) to determine compliance with the provisions of the Directive (“the Blue
Book”) and to determine compliance with the Guiding Principles of SEA. Marsden (1998a)
suggests that to enhance the process, a need exists to renew commitment, improve guidance,
and provide better coordination and management of the process.

71

Lawrence (1997) proposes a distinction between “quality” and “effectiveness”.
Quality is used to assess the “goodness” of institutional arrangements and methods, while
effectiveness is concerned with the consequences of the arrangements and methods.
Consistent with this evaluation method. Bonde and Cherp (2000) evaluated the quality of SEA
reports based on criteria derived from formal SEA provisions, general objectives and
principles of SEA and reports of good SEA practice. Lawrence (1997) relates “effectiveness”
to both direct and indirect outcomes. Direct outcomes refer to the achievement of identified
goals, realization of impacts as forecast, quality of proposals, compliance with regulations and
provisions, and maintenance of environmental quality. Indirect outcomes may be assessed as
contributions to environmental management principles, administrative and research.
A supplementary report to the International Study on EA Effectiveness focuses on
SEA (the ‘SEA Report’) and describes only the first two dimensions of ‘effectiveness’
(substantive and procedural), focusing primarily on procedural effectiveness. The lack of
focus on the transactive component of effectiveness discussed previously by Sadler (1996)
may be attributed to the relatively small number of SEA cases analysed.
Sadler (1996, 40) uses the concept of an ‘Effectiveness Triangle’ (Figure 6) to
illustrate the cyclical relationships between the policy, the application (practice), and the
results (performance): “The focus is on relating policy to practice to performance, and relating
the implications of performance back to policy adjustments and process development.” Baker
and McLelland (2003) have expanded this framework in their research on EA policy
effectiveness as it relates to participation. The policy is placed at the centre, surrounded by
several aspects of effectiveness. Borrowing from Sadler’s ‘effectiveness triangle’, the
elements of procedural (practice), substantive (performance), and transactive (proficiency)

72

effectiveness are included; a normative (purpose) aspect is a further addition. Within each of
these four dimensions of effectiveness, adjustments are made to the policy to improve how it
works in future applications, and “overall policy effectiveness is reflected by the extent to
which the policy works from all four aspects” (Baker and McLelland 2003, 9).
Figure 6

Effectiveness Triangle

POLICY

Application of process
and procedure

Realization of purpose

PERFORMANCE
Where were the
results?

PRACTICE
What happened?

Contribution to
decision-making

Sadler 1996, 3:4

Evaluation of EA performance can take place on a number of different levels (Sadler
1996; Lee et al 1994; Ortolano 1993): system-wide reviews; decision audits', and activity or
component-specific evaluations.

System-wide reviews evaluate a number of EA/SEA

processes over a given period of time and indicate the overall results in terms of the extent to
which policy or institutional goals were supported (Sadler 1996). For example, an evaluation
of SEA processes within European Union countries during the past ten years would be a
system-wide review. Decision audits evaluate the application of a given EA/SEA process from
start to finish in one or a number of cases, such as an evaluation of the European Union SEA
Directive for a number of different plans and programs. Component specific evaluations
evaluate particular stages or activities of an EA/SEA process. This can either involve a ‘step

73

by step’ analysis as part of the EA/SEA process or as a separate exercise. For example, an
EA/SEA process may be reviewed for such things as procedural compliance (e.g., Marsden
1998a), completeness and quality of EA/SEA documentation (e.g.. Bonde and Cherp 2000), or
adequacy of methods used to assess public involvement (e.g.. Baker and McLelland, 2003).
4.2

Importance of Context
The importance of context is critical in SEA application (Marsden 1998b; Partidario

1996) as strategic decisions are guided by the internal political, legal and administrative
framework in a particular jurisdiction. The prevailing political or organization culture and
structure of decision-making will determine whether and under what circumstances SEA can
be introduced; the existing policy and planning frameworks will determine how SEA is
applied (Sadler 1996, 76).
Previous approaches to measuring effectiveness for EIA have focused primarily on the
existence of identified procedural elements (such as scoping, screening and the consideration
of alternative options). Although sound procedures and appropriate methods and techniques
are also important requirements for SEA, the effectiveness of a SEA system is defined
“...above all, [by] a reasonably supportive political culture” (Sadler and Verheem 1996, 117).
Every SEA system is unique and a product of the political, legal and administrative context
within its particular jurisdiction.

Contextual frameworks enable comparisons to be made

across jurisdictions, providing a means of better understanding SEA practice in any particular
jurisdiction. Some SEA systems work better than others and step-by-step comparative analysis
may help to throw more light on the factors which are essential to the success of SEA
processes (Wood 1995).

74

In order to develop a contextual framework, criteria need to be identified and selected
to evaluate the enabling conditions and prerequisites for effective SEA application to
comprehensive plans.

The evaluation criteria not only can highlight the key factors for

success, but can also identify the obstacles that can be encountered. A framework to evaluate
the effectiveness of SEA application to comprehensive plans is presented in the following
section.
4.3

A Framework for Evaluating SEA Effectiveness for Comprehensive Plans
As discussed in the introduction, this thesis examines the effectiveness of SEA to

comprehensive plans. The evaluation framework presented in this section has been derived
from several sources: Eggenberger and Partidario (2000), Partidario (1996) and Sadler and
Verheem (1996).

The framework comprises five components, or reference levels: (i)

normative; (ii) policy context; (iii) institutional arrangements; (iv) SEA processes; and (v)
SEA methods (Figure 7). These components do not operate in isolation from one another;
rather, there are opportunities for transition and integration between them.
This evaluation framework assists with two primary objectives: (i) to evaluate the
effectiveness of a SEA system substantively (the extent to which the objectives of SEA are
met) and (ii) to evaluate the effectiveness of a SEA system procedurally (the extent to which
the SEA process conforms to the established provisions and principles for SEA).
In this thesis, four of the five elements of the framework are evaluated for
effectiveness, both substantively and procedurally. The normative level of the framework is
not considered in this study as it is very difficult to assess whether or not the plan is achieving
sustainable development. This particular question demands its own research investigation,
and could be the subject for future research opportunities.

75

Figure 7

Evaluation Framework

NORMATIVE
‘Achievement o f sustainability aims and objectives

PROCEDURAL
EFFECTIVENESS

POLICY
‘What is the overall policy context?”

SUBSTANTIVE
EFFECTIVENESS

INSTITUTIONAL
‘Are legislative/administrative
mechanisms in place?”

SEA PROCESSES
‘What are the elements
that facilitate the
application o f SEA?”

SEA
METHODS
“What are the
available
tools
and how
effective /

Marsden (1998a, 243) considers only the procedural effectiveness of SEA in his
research, noting that substantive effectiveness is “a secondary concern” and that “the nature of
higher-order decisions is such that SEA’s role in change simply may not be practicable”. In
contrast, however, this thesis follows the recommendations stated by Sadler (1998, 36) and
investigates both dimensions of effectiveness:

76

Concerns with methodology and procedure often dominate discussion on SEA.
Unquestionably how this process is carried out influences the results.
However, far greater attention needs to be given to whether or not the
objectives o f SEA are being achieved: e.g., via monitoring and evaluation o f
the impact o f the process on decision-making and on protection o f the
environment, [emphasis mine]
Substantive ejfectiveness is determined in this thesis by evaluating the extent to which
the SEA system under study has met the aims, objectives and benefits of SEA, as commonly
identified in the literature (Fischer 1999; Partidario 1996; Sadler 1996; Shepherd and Ortolano
1996) (Table 6).
Table 6

Aims and objectives of SEA
Integration of environmental considerations into PPP decisions
Provision of information on environmental effects
Strengthen and streamline project EIA by:
o early identification of potential impacts and cumulative effects
o addressing strategic issues, re: justification and location of proposals
o reducing time and effort to assess individual schemes
Promote or achieve sustainable development by:
o integrating environment and development decision-making
o designing environmentally sustainable policies and plans
Sadler (1998)

Procedural effectiveness in this thesis is determined by evaluating the SEA system for
compliance with the legal provisions of the jurisdiction under study and with the Guiding
Principles of SEA contained within the Final Report of the International Study of the
Effectiveness of Environmental Assessment (Sadler 1996, 151) (Table 7).

77

Table 7 Guiding Principles of SEA
•
•
•
•
•
•
•
•
•
•
•
•
•

4.4

initiating agencies are accountable for assessing the enviromnental effects of new or amended
policies, plans and programmes
the assessment process should be applied as early as feasible in proposal design
scope of assessment to be commensurate with the proposal’s potential impact or consequence
for the environment
objectives and terms of reference should be clearly defined
alternatives to, as well as the environmental effects of, a proposal should be considered
other factors, including socio-economic considerations, to be included as necessary and
appropriate
evaluation of significance and determination of acceptability to be made against policy
framework of environmental objectives and standards
provision should be made for public involvement, consistent with potential degree of concern
and controversy of proposal
public reporting of assessment and decisions (unless explicit, stated limitations on
confidentiahty are given)
inclusion of environmental factors in policy making
tier processes, where possible, to subsidiary SEA and project EIA
monitoring and follow-up of measures, including tracking proposals that initiate further actions
need for independent oversight of process implementation, agency compliance, and
government-wide performance.
Sadler 1996, 151
Evaluation Framework Criteria
4.4.1

Normative

The normative component is the highest, or most strategic level of the framework, and
purports the ‘ideal’, with respect to what the policy or plan intends to achieve, such as
sustainable development (Gibson and Walker 2001). A normative vision provides guidance
on what should be done, rather than what is done (Sadler 1996, 39). The normative vision
comprises an ideal substantive outcome as well as an ideal process. The normative level of
the framework will not be considered in this thesis as it is difficult to measure whether or not
sustainable development has indeed been achieved as a direct result of the plan.

78

4.4.2 Policy Context
The policy context element of the framework considers the overall policy context
within which the case study exists. EA effectiveness is associated with “changing political
regimes and with the changing level of support for the EIA process” (Wandesforde-Smith
1989, 165). Sadler (1996, 1) notes that a SEA process “can only be fully understood and
comprehensively evaluated in relation to the national or jurisdictional framework of decision­
making within which it operates”. Similarly, Eggenberger and Partidario (2000, 202) state
that, to be effective, SEA needs to be “integrated as far as possible into the existing policy,
institutional and organizational framework and coordinated with initiatives sharing
complementary goals (for instance, LA 21)”. Procedural principles, substantive objectives and
evaluation criteria are outlined below in Table 8.
Table 8

Principles and evaluation criteria for the policy context
l*riiici|ili.-s l o r l ’o lii'\ ( o ii Ua I;

Evaluation Criteria:

1.

Political will and support for sustainable
development initiatives at higher levels of
government (Partidario 1996)

• Cabinet responsibilities for sustainable
development; government-wide initiatives

2.

Systematic, integrated policy framework for
considering sustainability/environmental
principles to guide assessment (Sadler and
Verheem 1996; Partidario 1996; Shepherd and
Ortolano 1996)

• National sustainable development strategies,
objectives and indicators

3.

Commitment to sustainability at the local level

•

Sustainability initiatives in case study

4.

SEA integrated into planning process

•

SEA is integrated into the comprehensive
planning process

.S iii)sl.m liic O liji- c liic s l o r P o l i o C onU -xl:

J .x a liia lio ii CriUri.i:

1.

SEA findings are a central determinant of decision • Legislation or policy requires that SEA findings
are the central determinant of decision

2.

Integrates SEA recommendations into final plan
• Personal opinion by local planning authority about
(Sadler 1998; Therivel and Minas 2002; Partidario
how SEA results are considered in decision
1996)
making

3.

Promotes or achieves sustainable development by
integrating environmental or sustainability
considerations into plan decisions (Sadler 1998)

•

79

Sustainability/environmental considerations
integrated into plan

4.4.3

Institutional

The institutional arrangements component of the framework examines the legislative,
administrative and organizational structures and arrangements that are in place that can
facilitate the implementation of SEA. Sadler (1996) highlights an appropriate institutional
framework with quality controls (e.g., clear requirements, procedural guidance, and provisions
for independent review) as one of the enabling conditions for sound SEA practice. Table 9
provides the procedural principles, substantive objectives and evaluation criteria for the
institutional context.
Table 9

Principles and evaluation criteria for institutional contextarrangements

l*r«icL-(liiral I’riiicipk-s lo r liisliliilio iiiil
A rra n g em en ts:

E valiiiilioii C riteria:

1. Comprehensive plan based on clear legal
provisions

• Legislative requirements for
comprehensive plans

2. Clear legal provisions for SEA (Sadler and
Verheem 1996; Partidario 1996)

• Statutory and binding requirements in law
for both comprehensive plans and SEA

1. Administrative body exists to oversee SEA
process

• Separate agency in place with
responsibility for SEA

2. SEA subject to interagency review

• Process in place for other government
departments and agencies to review and
SEA and provide input prior to decision
making

3. Guidance, training and support provided

• Written guidance, training workshops and
financial support provided to carry out
SEA

4. Visible linkages to decision making (Fischer
1999)

• Approvals or permitting hy government
department or agency based on
submission of SEA report

5. Independent oversight of the SEA (Sadler and
Verheem 1996; Fischer 1999)

• Opportunities for review of quality by
independent parties

S iil)st:in li\c O h ji'c tb c s fo r lii.stiliilioiiiil Coiiti-xl

1. Strengthens project EIA through ‘tiering’ to
carry sustainability principles from plans to
projects (Sadler and Verheem 1996; Ortolano
and Shepherd 1996)

l.\:ilii:ilio ii Crili'i'hi:

• SEA leads to an acceleration of project
EIAs
• SEA substitutes parts of project EIA
• SEA and EIA assess different issues

80

4.4.4

SEA Processes

The SEA processes employed are the ‘building blocks’ that facilitate the application of
SEA in comprehensive planning. While the processes followed varies among jurisdictions,
there are certain steps identified that constitute ‘good practice’ SEA (Sheate et al. 2001;
Fischer 1999; Sadler and Verheem 1996; UNECE 1992): screening, scoping, evaluation and
comparison of alternatives, public participation, outside review, documentation and
monitoring. Evaluation criteria is outlined below in Table 10.
Table 10

Principles and evaluation criteria for SEA processes
1‘i-iiK'iplcs lor .S l.\ i*i<uTsM-s:

Evuliialioii Criteria:

1.

SEA based on an objectives-led approach (Sadler
and Verheem 1996)

•

Environmental, social and economic objectives
defined in order to evaluate significance of
impacts

2.

Effective scoping process in place

•

Comprehensive scoping process that involves
biophysical and socioeconomic issues as well
as the identification of stakeholders involved

3.

Opportunities provided for public involvement
(Fischer 1999; Sadler and Verheem 1996;
Shepherd and Ortolano 1996)

•

Significant opportunities for public
involvement beyond the provision of
information after the process

4.

Mitigation measures identified on SEA level
(Marsden 1998)

•

Mitigation measures identified during the
process

5.

Separate SEA report required with prescribed
content

•

Separate SEA report provided to decision
makers prior to decision

6.

Public reporting of SEA (Verheem and Tonk
2000; Fischer 1999; Sadler and Verheem 1996)

•

SEA results and decision made available to the
public

7.

Provisions for monitoring and follow-up
(Verheem and Tonk 2000; Fischer 1999; Sadler
and Verheem 1996)

• Monitoring program and indicators developed
as part of SEA process

.Siilislaiilht O lijeclh es lor SL.\ 1*rot esses:

1 \uliiuli<iii ( riu-ri.i

1.

Proactive assessment (Fischer 1999; Sadler and
Verheem 1996; Partidario 1996)

•

SEA applied early in the process

2.

Sustainability-led process (Verheem and Tonk
2000; Fischer 1999; Sadler and Verheem 1996)

•

Sustainability objectives adopted and guide
SEA process

3.

Cumulative impacts considered

•

Identification and evaluation of cumulative
impacts related to plan

4.

Alternative options identified and evaluated

•

Identification and evaluation of alternative
options for plan

81

4.4.5

SEA Methods

The methods and techniques used to evaluate plans in SEA application are at the most
operational level of the framework. The type of methods used to evaluate comprehensive
plans are identified in the case studies, and compared against those methods suggested in the
literature and by practitioners. Table 11 provides the evaluation criteria for this element of the
framework.
Table 11

Principles and evaluation criteria for SEA methods

Priici-diinil l'riiicip k 's Ibr S I. \ M eth ods:

E valu ation C riteria:

1. Suitable methods used for scoping

• At least two of the following methods:
checklists, literature surveys, comparisons,
overlay maps, public consultation and
expert judgment

2. Scenarios used to identify and evaluate
alternative options

• Should also include the ‘worst-case’
scenario

3. Information on the affected environmental
baseline conditions collected and described

• Should include an inventory of conditions,
as well as carrying capacity

4. Impacts evaluated as to their significance,
with reference to scope, duration and
likelihood of occurrence

• Type of weighting system used to evaluate
significance or severity of impact (such as
ordinal scale)

SiihstaiiliM ' O h j e e liw s for S I. V M ethods:

E va lu a tio n C riteria:

1. Integration of multi-disciplinary approaches

• Bio-physical and socio-economic
approaches and methods used in evaluation
of plan

2. Integration of qualitative and quantitative
methods

• Qualitative and quantitative methods are
used in evaluation of plan

3. Information presented in a non-technical
summary that was easy for decision-makers
to understand

• Textual summary used

4.5

Evaluation of Significance
Data was collected during the case studies for all criteria presented in the tables in this

chapter. Possible answers to a criterion are “yes” (strong compliance), “partially” (weak
compliance), and “no” (no compliance at all). Each of the criteria introduced is weighted for

82

significance, with “yes” scoring 2 points, “partially” scoring 1 point, and “no” scoring 0
points. All criteria are weighted equally. Scores are totalled and related to the possible
maximum score for each reference level of the framework (i.e., policy, institutional,
processes, and methods). For ease of evaluation and analysis for all criteria at each level, the
following four categories have been identified; (i) under 50 per cent (considered ‘poor’); (ii)
50 per cent to 74 per cent (considered ‘adequate’); (iii) 75 per cent to 89 per cent (considered
‘good’); and (iv) 90 per cent to 100 per cent (considered ‘excellent’).
4.6

Summary
Strengths
The evaluation framework presented in this chapter has several important strengths.

First, it is built upon a carefully construeted theoretical foundation and based on the key
academic literature.

As the literature itself is fairly consistent, the framework can be

considered valid from both a normative and empirical perspective. Second, the framework
incorporates the importance of the policy and institutional contexts within which SEA
operates. A greater understanding of the context helps greatly in measuring the effectiveness
of a SEA system. Third, consistent with the SEA literature and practitioners, the framework is
flexible and adaptable, as it leaves room for further interpretation. It does not advocate a
prescriptive approach, but directs the practitioner to consider a range of mixed stakeholders,
different societal values, and high levels of uncertainty in terms of expected outcomes.
Weaknesses
The framework also has a number of weaknesses. The most significant of these is the
researcher’s own inherent biases which contributed to its development. As noted by Sadler
(1996), all cases of evaluation of performance and judgement about suecess will be subjective.

83

In addition, evaluation is subject to the following conditions (Sadler 1996, 38):
• the EA/SEA process operates in an open ended, decision-making context;
• it is taken forward and influenced by actions o f numerous participants;
• the outcomes o f the process are not always clear or apparent;
• in these circumstances, cause-effect relations cannot be measured or quantified; and
• often, proponents and opponents ofEA differently interpret the utility o f the process.

These weaknesses are inherent in the concept of sustainable development; however,
policy-makers, planners and researchers need to continue to find ways to operationalize
sustainability principles and to further integrate environmental considerations into decision­
making.
Transferability
One of the main purposes of this thesis is the development of a framework that can
assist practitioners applying SEA processes in comprehensive planning.

The theoretical

elements of the framework are transferable to all forms of SEA in all jurisdictions. As noted
earlier in this chapter, the use of such a step-by-step comparative analysis of current practice
can help to throw some light on the factors which are essential to the success of SEA
processes. The policy and institutional levels of the framework ensure that the appropriate
context is considered for a particular jurisdiction.

While analysis across SEA systems

provides a means of better understanding practice in any particular jurisdiction, caution must
be taken when applying the lessons learned in one country to another (Marsden 1998a, 1998b;
Booth 1986; Masser 1984). In Chapter Five, three case studies are described based on four
perspectives; the policy context, the institutional arrangements, the SEA processes followed,
and the SEA methods employed.

84

Chapter Five
Overview of the Case Studies
5.0

Introduction
This chapter provides an overview for each of the three case studies to facilitate a

better understanding of the policy, institutional, procedural and methodological contexts
within which SEA occurs in each case study jurisdiction. A summary of the characteristics of
the case studies is provided in Table 12. The policy and institutional contexts for each case are
examined through the national perspective, as the extent of political support and the
availability of appropriate institutional controls to facilitate the application of SEA are
primarily defined at this level.

The policy and institutional contexts establish an overall

framework within which SEA processes and methods operate at the local level.

The

institutional context comprises organizational structures, the regulatory framework, and
administrative mechanisms.
The status of SEA practice is examined from the national perspective as well as at the
local level. SEA practice is explored through the scope of application, the opportunities for
public involvement and outside review, the basic steps followed, the integration of SEA with
project EIA, and provisions for monitoring. The range of SEA methods and techniques used in
the assessment of plans in the case studies are then discussed. This chapter concludes with a
brief summary of the understanding of the contexts and the practices surrounding the case
studies.

85

Table 12

Summary of case study characteristics
S co tlan d
P erth an d K inross

P o p u la tio n *

C alifurnhi. USA
San J o a q u in C o u n ty

Scotland: 5.()()(),()()()
Perth and Kinross:
134,000

California:

Scotland: 78,000km^
Perth and Kinross:
5,311 km^

N ew /e u la iid
W a ila k e re D istrict

New Zealand:

33,871,648

3,737,280

San Joaquin: 578,600

Waitakere: 168,750

California: 40,397
km^
San Joaquin: 3,621
km^
USA; Presidential
California: Governor

New Zealand:
268,000 km^
Waitakere: 1,391 km^

un 20(i2
cslimjf^s
L a n d A ren

S \s t e iii an d l.e^ al
f o i l » ol ( , o \ i i i i i i i e i i l
H ea d o f S ta te

1le a d ol ( i o \ e i iiiiien t

UK: Parliamentary
Scotland: Scotland Act
(1998)
Queen of England
UK: Prime Minister
Scotland: First Minister
35 unitary authorities

L o ca l G o v ern m en t

1‘ilcclcd Local
O ftlc ia ls
M a jo r C en tres in
C a s c S lu d v \r e a

C o iiijircliciisiv e P lan

i.e » a l P ro v isio n s for
C o iii|irclK iisiv c
P la n s
M iiiislc r /D c p a r lin c n l
R esp o n sib le for
C o iiip relu ii.siv c
PlanniiiK
Le^al P ro v isio n s for
SEA

President of the
United States of
America
USA: President
California: Governor
58 counties
456 cities

New Zealand: Treaty
of Waitangi (1840)
Queen of England
Prime Minister
12 regional councils
74 territories (15 city
councils and 59
district councils)
Mayor and Council

Mayor and Council

Mayor and Council

Perth (main), Kinross,
Aberfeldy, Blairgowrie,
Crieff, Pitlochry

Stockton (main),
Escalon, Lathrop,
Manteca, Ripon,
Tracy

Development Plan
(Structure Plan + Local
Plans) - Mandatory

General Plan Mandatory

Town and Country
Planning (Scotland) Act
1974

California
Government Code
Section 65100

Waitakere City
(main), Hobsonville,
Henderson, Ranui,
Swanson, Massey
North/Westgate, Glen
Eden, New Lynn
District Plan Mandatory
Regional Plan Voluntary
Resource
Management Act
(1991), Part 5

Minister with
Responsibility for
Planning, Scottish
Executive
Scottish Planning Policy
1, 2002 (formerly
National Planning Policy
Guideline 1, 1994) voluntary

Governor’s Office of
Planning and
Research

Minister for the
Environment, New
Zealand Government

California
Environmental
Quality Act (CEQA)
1969 - mandatory

Resource
Management Act
(1991) - mandatory

86

5.1

Scotland - Perth and Kinross District
Scotland is one of four constituent nations that form the United Kingdom, and is

located on the northern part of the island of Great Britain. The district of Perth and Kinross is
located at the geographical center of Scotland, straddling the boundary between the Scottish
highlands and lowlands (see Figure 8 for a map of the area). Perth and Kinross covers 5,311
km^, and houses 134,000 inhabitants, 70% of which are rural dwellers. Perth City is the major
population centre; other smaller communities include Kinross, Aberfeldy, Blairgowrie, Crieff
and Pitlochry. On the national level, Scotland’s industry has shifted from the traditional
reliance on coal, shipbuilding, and textile production to tourism and high technology.
Distilling and oil and gas production still remain important to Scotland’s economy. The
service industry is the focus in Perth and Kinross, particularly in distribution, hotels, catering,
banking and finance (Perth and Kinross Council 2001).
The passing of the Scotland Act (1998) allowed for the Scottish Parliament to be
created in 1999, the first time that Scotland has had its own Parliament in 300 years (Scottish
Executive 2001). Up until that time, Scotland was governed by Westminster Parliament in
London. The Scottish Parliament is responsible for most of the issues of day-to-day concern to
its citizens including health, education, justice, transport and planning (Scottish Executive
2001). The Scottish Executive, the devolved government for Scotland, was established in
1999 following elections to the Scottish Parliament and is led by a First Minister. The national
parliament in Westminster (London) retains responsibility for areas such as defense, foreign
affairs and taxation.

87

Figure 8

Map of Perth and Kinross, Scotland

SCOTLAND

H
Fitlochiy

&

PERTH AND KINROSS

i
Adapted from Scottish Executive 2003 and FBBB 2003

However, Scotland still closely emulates the policy directions that the UK sets, and
therefore, discussion here will also include many aspects of the UK’s progress. The European
Parliament in Brussels, Belgium exercises certain powers vested in the European Union
including trade, environmental issues and regional development.

5.1.1

Political Context

The United Kingdom has come a long way since its reputation as ‘the dirty man of
Europe’ (Lowe and Ward 1998, i). Since becoming a member of the European Union in 1973,
British approaches to environmental management and protection have been severely
challenged and in many respects reformed. With new environmental standards set by the

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European Union, the UK has been forced to integrate environmental initiatives into its
regulations and policies. Over 80 per cent of British environmental legislation emanates from
Brussels (Lowe and Ward 1998, i).
The UK produced a sustainable development strategy soon after the Rio Earth Summit,
as part of the commitments the country made at the conference. This strategy was criticized
for its focus on economic issues; it was revisited and re-released as “A Better Quality of Life”
in 1999, highlighting four priority areas: i) maintenance of high and stable levels of economic
growth and employment; (ii) social progress which recognizes the needs of everyone; (iii)
effective protection of the environment; and (iv) prudent use of natural resources (DETR
1999a). This strategy is coupled with “Quality of Life Counts”, a set of 147 sustainability
indicators, organized under 15 headline indicators (DETR 1999b).

The United Kingdom

released its first progress report on sustainable development in “Achieving a Better Quality of
Life” in January, 2001.
In 1991, the UK government produced “Policy Appraisal and the Environment”, which
encouraged all departments to appraise their policies based on potential impacts to the
environment.

This evolved into ‘environmental appraisal’, a form of environmental

assessment used in the UK in the early 1990s, primarily for development plan. Although
environmental appraisal was not legally required, it was encouraged through guidance
produced by the Department of Environment (DoE) and through Planning Policy Guidance
(PPGs).

In 1996, environmental appraisal became sustainability appraisal to reflect the

sustainability pillars as outlined in the UK’s sustainable development strategy. Sustainability
appraisal considers social and economic effects as well as environmental ones. The process

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tends to be less detailed and more qualitative than many forms of environmental assessment
(ODPM 2003).
Previous to the Scotland Act in 1999, Scotland was governed by these UK initiatives.
While Scotland continues to be a partner in many of the UK’s sustainable development
initiatives, devolution has provided an opportunity to tune policies to the specific needs of
Scotland. The main issues central to sustainable development have been devolved to the
Scottish Executive. The Scottish Executive determined that Scotland needed to adopt its own
strategies and related indicators matching its own priorities.

To this end, the Scottish

Parliament debated sustainable development soon after its creation in February 1999, and
passed a motion placing sustainable development at the heart of its work (Scottish Executive
2000, 1:1).

The Scottish Executive’s sustainable development strategy was released in

December 2002, but did not follow the UK’s lead with respect to social progress, resource
protection and economic progress, focusing primarily on the environmental component,
grouping priority issues into three areas, often called either the three pillar or the W-E-T
approach (waste/resource use, energy and travel): waste/resource use (protect ecosystems
from over-use of resources and reduce use of non-renewable resources); energy (reduce
demand for energy from non-renewable resources); and travel (reduce use of non-renewable
resources for travel) (Scottish Executive 2002b).
Closely aligned to this strategy, a draft set of 40 sustainability indicators has been
developed corresponding to the areas of waste, energy and travel (“Meeting the Needs:
Priorities, Actions and Targets for Sustainable Development in Scotland”). Social and
economic indicators have been published separately in “Social Justice: A Scotland Where
Everyone Matters”.

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The Scottish Executive released its ‘Greening Government’ policy in September 2001,
again following a similar initiative in the UK several years earlier that had failed for a number
of reasons. The ‘Green Ministers’ in the UK government did not have power to make major
policy decisions. They focused on internal activities, met infrequently, and had a very low
status (Voisey and O ’Riordan 1997). The ‘Greening Government’ initiative in Scotland also
focuses primarily on internal activities and have set out nine objectives to promote
environmental improvement (consistent with the W-E-T priorities of the Scottish Executive)
by reducing the impact of their operations on the environment.
publishes annual reports on its environmental performance.

The Scottish Executive

This was followed up by

“Building a Sustainable Scotland: Sustainable Development and the Spending Review” in
December 2002.

Each government department was asked to produce a draft of aims,

objectives and targets for their portfolios with detailed assessment of spending and were asked
to demonstrate how the aims, objectives and targets related to the four Scottish sustainable
development priority areas.
The general concept of sustainable development is further embedded into government
policy through the creation of a Cabinet Sub-Committee on a Sustainable Scotland
(“Sustainable Scotland”), comprised of several cabinet ministers and deputy ministers, as well
as environmental leaders

that is responsible for discussing the integration of the

environment and the principles of sustainable development into the workings of the
Parliament. Other key groups include: the Sustainable Development Commission (an
advisory, non-departmental public body that is jointly appointed by the four UK

“ The Sub-Committee on Sustainable Development includes; the Minister for Environment and Rural
Development, the Minister for Finance and Public Services, the Deputy Minister for Environment and Rural
Development, the Deputy Minister for Enterprise, Transport and Life Long Learning, the Deputy Minister for
Social Justice, the Friends of Earth Scotland, and the University of Aberdeen)

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administrations, which advises on sustainable development across all sectors in the UK) and
the Sustainable Scotland Network (a local government initiatives that comprises members
from all 35 local governments in Scotland).
At the local level, sustainability initiatives have been promoted in the UK through
Local Agenda 21 (LA21) activities. UK Prime Minister Tony Blair challenged all local
authorities to produce LA21 strategies by the end of 2000 to outline how they plan to promote
sustainable development in their local area (UN General Assembly, New York, 21 June 1997).
The Scottish Executive supported this challenge, requesting its own local authorities to
produce LA21 strategies. All 35 local authorities in Scotland have developed LA21 strategies.

5.1.2

Institutional Context

Organization o f Planning
As a devolved matter, planning and the overall management of the comprehensive
system in Scotland is centrally guided and controlled by the Scottish Executive (under the
responsibility of the Minister of Social Justice). The Town and Country Planning (Scotland)
Act (1997) governs comprehensive planning in Scotland, and similar to the UK, there are
statutory requirements for all 35 local authorities to prepare development plans to provide the
basis for decisions on planning applications. Development plans comprise both the structure
plan (prepared by the district council) and the local plans (prepared by the local councils
located within the district). The structure plan takes a long-term view of development,
considering its general scale, and broadly where development should be located. Local plans
are often for smaller areas, and must be consistent with the approved structure plan covering
their area. Local plans set out detailed policies and proposals to guide development. Public
consultation is an important component of both types of plans. Approval of all plans rests

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with the Secretary of State for Scotland (the representative of Scotland in the United Kingdom
government at Westminster).
Non-statutory planning guidance is provided for local authorities in the form of
Scottish Planning Policies (SPPs), formerly known as National Planning Policy Guidelines,
and Planning Advice Notes (PANs) (Table 13). SPPs set out policy on nationally important
land use and other planning matters, covering issues such as transport, natural heritage, land
for housing, shopping centres, and town centres. PANs give advice on how best to deal with
matters such as local planning, rural housing design and improving small towns and town
centres. SPPl details the role of the planning system in promoting sustainable development.
SPP 1, PAN 37 and PAN 49 all provide guidance on the environmental appraisal of
development plans.
The organization and structure of planning in Scotland is proposed to change.

A

review of strategic planning in Scotland was undertaken by the Scottish Executive soon after
taking office in 1999. One of the main proposals within this review was the preparation of a
National Comprehensive Planning Framework for Scotland, a non-statutory planning policy
that is to identify how Scotland will develop over the next 25 years. Stakeholders recommend
that the framework should focus on a limited number of key spatial issues of genuine national
importance such as transport, economic development, energy, water and telecommunications
infrastructure. The framework is to be completed by the end of 2003. Other key changes
emerging from the review include renaming National Planning Policy Guidelines as Scottish
Planning Policies; having only one tier of plans - development plans - essentially abolishing
structure and local plans; requiring second tier of plans only for the four city regions
(Glasgow, Edinburgh, Aberdeen and Dundee).

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Table 13 Scottish policies on environmental appraisal
National Planning Policy Guideline 1 - The Planning System (paras. 27 and 31):
“Special attention should be given to ensure that the strategic policies now in place are consistent with
broader environmental objectives and sustainable development, in line with current national policy and any
wider international obligations...All plans should be regularly reappraised to ensure that policies are
consistent with broader environmental objectives...”
(The Scottish Office Environment Department, 1994)
Planning Advice Note 37 (revised 1996) - Structure Planning (para. 7):
“It is important that those involved in preparing structure plans recognize how a long term settlement
strategy and the policies and proposals in the plan can contribute to achieving the sustainable development
of an area.. .To help in assessing a structure plan’s contribution towards the sustainability o f development,
the Department expects to issue good practice advice on the environmental appraisal of development plans
in the near future”
Scottish Executive 1996b
Planning Advice Note 49 - Local Planning (para. 48):
“The matters to be covered in a local plan are for the local authority to decide.. .But there are likely to be a
number of core topics like the environment... sustainable development and environmental appraisal...”
Scottish Executive 1996a
Planning Advice Note 49 - Local Planning (Annex 1. para. 7):
“.. .project-based environmental assessment is not enough on its own to ensure that we move towards
sustainable development. The environmental appraisal of development plans involves testing a plan’s aims,
policies, and proposals against the aims of sustainable development to identify their likely consequences. It
is now recognized as a policy means of helping to achieve development and growth which is sustainable.”
Scottish Executive 1996

Regulatory Provisions fo r SEA
Currently, there are no legal provisions for SEA, or the appraisal of development plans
in Scotland, although this process is encouraged through non-statutory planning guidance.
However, the European Union’s Directive on SEA is driving the development of new methods
and processes, along with widespread application of sustainability appraisal for plans and
programs. This Directive must be reflected in national legislation by July 2004. The United
Kungdom prepared and distributed a consultative draft for the implementation of the Directive
for England and Wales in October 2003; the Scottish Executive released a similar document in
August 2003.

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Administrative Mechanisms
Although the planning department, housed within the Ministry of Social Justice, is
responsible for providing guidance and practical support for development planning in
Scotland, it is the Secretary of State that must provide official approval.

The planning

department also provides the guidance for sustainability appraisal, but there is no public body
that has responsibility for the administration of sustainability appraisal. This could change
once the Directive comes into effect. Local planning authorities have primarily relied on three
sources of guidance: (i) the ‘good practice’ guidance issued by the UK’s Department of
Environment (1993); (ii) guidance specific to Scotland devised by consultants David
Tyldesley & Associates (DTA 1995a and 1995b); and (iii) sustainability appraisals prepared
by other Scottish and English local authorities (Walsh and Brand 1998).

5.1.3

SEA Process

Scotland
Although there are no legal provisions for SEA in Scotland, most local planning
authorities voluntarily make the decision to evaluate their development plans. The evaluation
can occur at various points of the process: at the beginning, during the process, or after the
draft plan is complete, but before adoption. Some have even occurred once the plan had been
adopted. There is a wide range of practices among planning authorities as to how they carry
out appraisals. Some are prepared in-house, either by a single appraisal planner, a team of
planners that were not part of the plan preparation, or less desirably, by the team of planners
that prepared the plan. Often, consultants are retained to undertake the task.
The UK guidance suggests three steps for good practice; i) characterize the
environment (identify existing baseline conditions); ii) scope the plan (ensure that appropriate

95

policies are in place to cover all aspects of sustainability; and iii) appraise the plan (evaluate
each policy against a set of identified sustainability criteria (DoE 1993). Figure 9 illustrates
the six steps of appraisal as recommended for Scottish local authorities.
Figure 9

Steps in sustainability appraisal in Scotland

Scoping of Aims: are the aims o f the plan compatible with the pursuit o f
environmental sustainability?

Appraising plan principles or strategies: do the plan’s locational
principles or strategy match up with the plan’s aims?

Scoping the policy issues: does the plan cover a full range o f relevant
environmental issues?

Appraising effects of policies: what are the main likely environmental
effects o f each policy?

Appraising effects of proposals: do any o f the plan proposals have
serious environmental effects?

Suggesting requirements for monitoring: how to keep track o f plan
performance, changes in the environment and human responses

DTA 1995, 3

In Scotland, the appraisal of the plan’s principles and/or strategies is generally
evaluated against a set of identified sustainability criteria.

If the plan’s principles are

compatible with the aims of sustainability, it is expected that the rest of the plan will be as
well. Scoping serves to ensure that there are no gaps in coverage among the plan’s policies. A
list of sustainability issues appropriate to the local level is compiled using information from
other sustainability appraisals, from government documents, and from the academic literature.
The plan is then scanned to ensure that there are policies covering all aspects of local

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sustainability.

Any gaps are identified, and revisions are recommended.

Recently, new

guidance for SEA in Scotland has been prepared to provide suggestions on how to comply
with the EU SEA Directive (DTA and Scottish Executive 2003). Referred to as Interim
Planning Advice, an appendix to this guidance lists possible sustainability criteria for local
authorities to use in both scoping and plan evaluation.
The processes and methods used to undertake evaluation of comprehensive plans are
different among local planning authorities. In some cases, only those plan policies that are
deemed to have an impact on sustainability are evaluated (e.g., Aberdeen Structure Plan
Sustainability Appraisal 2002), while in other cases (e.g., Perth and Kinross), every single
policy contained in the plan is appraised. It has become common practice in Scotland and the
UK to prepare a separate sustainability appraisal document to illustrate the appraisal process,
the impact matrices and any monitoring plans.
Perth and Kinross
In Perth and Kinross, the task of undertaking the sustainability appraisal of the draft
structure plan was put out to a tendering process. The successful bidder was the environmental
department of the Perth and Kinross District. An individual from this department was
responsible for the appraisal of the plan, with assistance from other members of the
department. It was determined that the sustainability criteria against which to appraise the
plan would be based on the four themes highlighted in the UK’s national sustainable
development strategy (i.e., social progress which recognizes the needs of everyone, effective
protection of the environment, prudent use of natural resources, maintenance of high and
stable levels of economic growth and employment). For each theme, sustainability criteria

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were selected - 20 in total‘s. Table 14 illustrates the steps followed in the Perth and Kinross
Sustainability Appraisal.
Public involvement was not a visible element of the appraisal process.

Once the

appraisal was complete, copies of the document were made available to the public on the
Perth and Kinross Council website, at the district office in Perth, and through public meetings.
Other government agencies were not given an opportunity to review the appraisal. During the
appraisal, government agencies or departments may have been contacted for information
regarding the analysis of potential impacts, however, this was done on an ad hoc and informal
basis.
Table 14

Steps in the Perth and Kinross Sustainability Appraisal

1.

Scoping the Plan Themes and Strategy : the plan themes and strategy were assessed
against the criteria, with gaps/revisions identified.

2.

Assessment o f Plan Policies and Proposals: Every policy/proposal and associated
background information was assessed against the sustainability criteria with conclusions,
constraints and revisions stated. The grading system used for the assessment is as follows:
++
+
0
-

--

?
3.

Significant move towards sustainable development
Move towards sustainable development
Neutral effect
Move away from sustainable development
Significant move away from sustainable development
Unknown

Develop a Suite o f Environmental Indicators: The indicators were developed to enable the
Perth and Kinross Structure Plan to be continually monitored, and have been structured to
reflect United Kingdom, Scotland and Perth and Kinross priorities. In this sustainability
appraisal the indicators are further streamlined with alternative and additional sources of
information identified to enable monitoring to take place.
Excerpt from the Perth and Kinross Sustainability Appraisal, 2002

12

Social Progress which Recognizes the Needs o f Everyone: Housing, Access, Training, Participation, Safety;
Effective Protection o f the Environment: Travel, Pollution Prevention, Protect and Enhance Open Space,
Landscape and Biodiversity, Built Environment, Cultural Heritage; Prudent Use o f Natural Resources: Waste,
Water, Energy, Land and Soil, Air; Maintenance o f High and Stable Levels of Economic Growth and
Employment: Diversification, Employment, Vitality, Investment, and Entrepreneurship.

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The appraisal process was completed and produced in just over a month. The appraisal
document comprises 150 pages, including an overview of the process, a list of the
sustainability criteria employed, impact matrices for each of the plan’s policies, and
suggestions for monitoring. The indicators for monitoring the Structure Plan were developed
in accordance with national and local priorities, stating sources of relevant data. These
indicators are expected to allow for annual monitoring of the Structure Plan to be undertaken.
In the final appraisal document, it was concluded that
...the draft Perth and Kinross Structure Plan provided a framework fo r
delivering ‘A Sustainable Future’ [the title o f the Structure Plan]. However,
there were still details and gaps that had to be addressed, in order that Local
Plans and development on the ground were consistent with the themes o f the
Structure Plan and adhered to the strategy (Perth and Kinross Structure
Council 2002, 1).
Recommendations for revisions were put forward in the appraisal document; the
influence of these recommendations on decision making will be examined in more detail in
Chapter Six.
5.1.4

SEA Methods

Methods and techniques for sustainability appraisal in Scotland have been fairly
simple - checklists and matrices are used to evaluate the impact of each of the plan’s policies
against a series of sustainability criteria. In the early days of environmental appraisal in the
UK, the use of economic cost and benefit analysis was recommended by the government as
part of its policy appraisal initiative (DoE 1991). However, this has not commonly been used
in Scotland.
In Perth and Kinross, as in most other Scottish cases, ordinal scales are used to
determine the significance of these impacts by assessing whether the policy is a move toward
sustainability, away from sustainability, or will have no effect on sustainability. Table 15
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illustrates how this information is presented. These evaluations were undertaken through the
use of subjective interpretation by the individual carrying out the appraisal, with some input
from the environmental department.
Table 15

Example of an impact matrix in sustainability appraisal for a single policy in
the Perth and Kinross Structure Plan 2002

Policy: Environment and Resources Poliey 12
(Old Policy 10)
“Development that would result in the permanent loss o f prime quality agricultural land will only be permitted where such
land is requiredfo r the implementation o f the strategy. "
SUSTAINABILITY CRTERIA
GRADE
Social Progress which Recognizes the Needs of Everyone
Housing
?
Access
?
Training
0
Participation
Safety
?
Effective Protection of the Enviromnent
Travel
0
Pollution Prevention
?
Protect and Enhance Open Space,
Landscape and Biodiversity
Built Environment
?
Cultural Heritage
Prudent Use of Natural Resources
Waste
0
Water
?
Energy
0
Land and Soil
Air
0
Maintenance of High and Stable Levels of Economic Growth and Employment
Diversification
?
Employment
Vitality
Investment
Entreprenetirship

COMMENTARY

Through discussion with relevant partners.

Does not provide adequate protection

Does not protect land and soil as a non­
renewable resource.

May restrict or enhance diversification
opportunities.

?
?
?
?

Conclusions:
The policy needs to be strengthened. As it stands presently it does not protect agricultural land and soil as a valuable non­
renewable resource.
Constraints:
Where such land is required for the implementation of the strategy
Revisions:
Development will only be permitted where:
•
It promotes farm diversification, particularly in rural areas
•
There are no suitable alternatives
•
It is a scale and standard of design appropriate to its location
There is overriding public interest and environmental, social and economic (sustainable) benefits.
Code Key:
4-+ Significant move towards sustainable development
4- Move towards stistainable development
0 Neutral effect
Move away from sustaitiable development
— Significant move away from sustainable development
? Unknown

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5.2

California, USA - San Joaquin County
In the United States, unlike many other nations, government agencies have

considerable experience preparing environmental impact assessments of land-use plans. The
National Environmental Policy Act (NEPA), signed by President Nixon in 1970, applies to a
variety of federal government activities, including assessment of federal land management
plans. The California Environmental Quality Act (CEQA) was passed in 1970 as a “little
NEPA” which required state decisions to consider environmental effects. Ironically, the
California process has evolved into a much larger process than NEPA in terms of
documentation and activity (Wood 1995). CEQA applies to land-use plans prepared by state
and local agencies in California. Under both NEPA and CEQA, ElA has become an integral
part of the land-use planning process.
San Joaquin County is the 15* largest of the 58 counties in California, with 596,000
people (2002 estimates), and covers approximately 3,624 km^ in central California. Located
in the central valley in northern California (see Figure 10 for a map of the area), San Joaquin
County is primarily an agricultural area producing wine grapes, milk, cherries, tomatoes and
walnuts. The central valley produces approximately eight per cent of the total United States
agricultural sales, while only comprising just over half a per cent of American land in farms.
San Joaquin County comprises seven major population centers, with Stockton serving as the
county seat. Tremendous growth pressures in the nearby San Francisco Bay area and the
Sacramento metropolitan area, coupled with the absence of affordable housing in those cities,
have made San Joaquin County a highly attractive location. In 1990, the population of the
County was 480,628. The General Plan projected that, by 2010, the County’s population
could increase up to 864,200, an increase of 80 percent over the 20-year planning period. In

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addition, a 64 percent employment growth was predicted during this same time period (from
182,237 jobs in 1990 to 298,794 jobs in 2010).
Figure 10

Map of San Joaquin County, California

SAN JOAQUIN
COUNTY

CALIFORNIA

Source: San Joapuin County Council o f Governments 2002

One of the key issues in preparing the County’s General Plan was how to best
accommodate this growth. The evaluation of the available options to address this issue, along
with many other issues, is required under the California Environmental Quality Act (CEQA).
Prior to adoption, all draft General Plans in California are subject to an environmental
assessment process, and an Environmental Impact Report (EIR) must be prepared and
submitted for approval.

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5.2.1

Policy Context

The United States was once a global leader in the early development of policies and
regulatory programs to protect environmental quality. Once NEPA was implemented, it
became a model for environmental assessment, both internationally and at lower levels of
government in the US.

However, during the 1980s, the Republican Congress began to

respond to complaints of regulatory burdens by business interests (Bryner 2000). Republican
leaders in Congress have virtually ignored the idea of sustainable development and the US’s
commitments made at the Rio Earth Summit (Bryner 2000). There is no strong commitment to
sustainable development and the country is far from having in place a comprehensive strategy
that integrates sustainability into environmental, social and economic activities (Demback
1997, 10507, as cited in Bryner 2000, 272).
The President’s Commission on Environmental Quality, set up by President George
Bush during the early 1990s, called for the establishment of a national council on sustainable
development. During the latter stages of his administration. President Bill Clinton appointed
the President’s Council on Sustainable Development (PCSD). This council comprised 25
leaders from corporations, foundations and environmental groups, and was tasked with
formulating a sustainable development plan for the US. In 1994, the PCSD concluded that
...envirdnniental policy has been developed with too little regard fo r its
economic or social consequences; economic policy is made with too little
regard fo r environmental or social consequences; and social policy is made
with too little regard for economic and environmental consequences” (Clark

The vision laid out by PCSD in “Sustainable Development: The Challenges and
Opportunities” (PCSD 1994) incorporates many fundamental principles of environmental
impact assessment; however, not one of the eight task forces set up to deal with the integration

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of environmental, economic and social issues was established on how to use EIA as a tool to
integrate these concerns into decision-making.
California has served as a leader in many aspects of environmental protection, such as
in air, water and toxic pollution. In 1999, California became one of the first states to pass
legislation codifying environmental justice in state statute (Statutes of 1999, Chapter 690).
State law defines environmental justice as.
The fa ir treatment o f people o f all races, cultures, and incomes with respect to
the development, adoption, implementation, and enforcement o f environmental
laws, regulations and policies (Government Code Section 65040.12)

The California Environmental Quality Act promotes concepts of sustainable
development in Section 21001 (“Additional Legislative Intent”):
...it is the policy o f the state to...take all action necessary to protect,
rehabilitate, and enhance the environmental quality o f the state...to provide the
people...with clear air and water...ensure that fish and wildlife populations do
not drop below self-perpetuating levels, and preserve fo r future
generations...create and maintain conditions under which man and nature can
exist in productive harmony to fulfill the social and economic requirements o f
present and future generations (CRA 2002a).
The Governor of California is required to prepare a Comprehensive State
Environmental Goals and Policy Report, containing a long-range (20-30 years) overview of
state growth and development and a statement of approved state environmental goals and
objectives, including those related to land use, population growth and distribution,
development, conservation of natural resources, and air and water quality (Government Code
Section 65041-65049).
Progress in sustainable development has occurred mainly at the state and local
community levels.

The Southern California Council on Environment and Development

(SCCED) was established in 1993 as a local continuation of the process begun at the Rio Earth

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Summit.

Through facilitating multi-stakeholder dialogue and consensus on programs to

protect the environment, strengthen the economy and ensure equality in the Los Angeles area,
SCCED supports the creation of sustainable programs, policies and plans for the region.
Reports on the State of the Local Environment and Economy have been prepared on an annual
basis, along with indicators to chart progress toward sustainability. The Southern California
Association o f Governments (SC AG), representing six counties in and around the Los Angeles
area, publishes annual State o f the Region reports that provide detailed information on
environmental quality, economic growth and quality of life.
At the local community level, the Joint Centre fo r Sustainable Communities,
established by the National Association of Counties and the US Conference of Mayors,
provides examples of counties and cities in all states that are more willing to identify and
respond to environmental and sustainability policies, problems and opportunities.

For

example, Santa Clara County, City of San Jose, City of Davis, and “Sustainable San
Francisco” all provide examples of innovation in sustainable city planning and design in
California (Bryner 2000; Joint Centre for Sustainable Communities 2003). With the support of
the International Council fo r Local Environmental Initiatives (ICLEI), local governments in
the US are working towards improvements in environmental quality and social justice, in
addition to economic vitality.

A number of counties and cities in California have either

explicitly or indirectly created LA 21 processes, for example: San Francisco, San Jose, Santa
Cruz County and Santa Monica.

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5.2.2

Institutional Context

Organization o f Planning
In the US, land use planning is the responsibility of the states and their municipalities.
There is no national law requiring land use planning, however, most states have planning laws
that delegate responsibility for land use planning to cities and counties (Bass and Herson
1999). As with most states in the US, California does not prepare a state land-use plan.
Planning in California falls under the responsibility of the Governor of California’s Office of
Planning and Research. California state law (California Government Code, sections 6530065303) requires each of its 456 cities and 58 counties to adopt a General Plan “for the physical
development of the county or city, and any land outside its boundaries which bears relation to
its planning (California Government Code Section 65300). The General Plan must contain
seven elements - land use, circulation, housing, conservation, open-space, noise and safety but has considerable flexibility as to how they address the required topics.

There are an

additional 46 optional elements that can be addressed.
Regulatory Provisions
Adopting or amending a General Plan or General Plan element is subject to CEQA and
requires preparation of an Environmental Impact Report (EIR). The primary purpose of an
EIR is to inform decision-makers and the public of potential significant environmental effects
of a proposal, less damaging alternatives, and possible ways to reduce or avoid the possible
environmental damage (CRA 2003b; OPR 2002) Guidance for General Plan preparation is
provided by the California Office of Planning and Research, and includes suggestions on how
to carry out the provisions for CEQA in relation to the General Plan process, as well as
suggestions on how the General Plan and its EIR can be consolidated into a single document.

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Detailed procedures for preparing EIRs are also described in CEQA Guidelines issued by the
California Resources Agency, the administrative arm of CEQA.
There are two types of EIRs in the legislation for the preparation of General Plans: a
Programme EIR and a Master EIR. The Programme EIR is the most widely used and can be
applied to any type of plan. This is used when the information for future projects is not
known. The Master EIR is used only for city and county general plans, urban redevelopment
plans and transportation plans. This type is used when the type, density, and intensity of
future projects are known. The Master EIR can also be used to evaluate several known
projects and their cumulative impacts. Cities and counties can prepare either type of EIR,
depending on their circumstances. For example, the City of Santa Rosa prepared a Master EIR
to evaluate a number of proposed projects.
CEQA has been the focus of much controversy since its inception over 30 years ago.
Its least controversial moment was its enactment - it passed the State Assembly 62-1, and
passed the Senate without any dissenting votes (Olshansky 1996). Supporters say that CEQA
has been successful at increasing public participation, improving agency decision-making, and
causing consideration of environmental values (Thomas 1993, as cited in Olshansky 1996,
11). Detractors say that it creates a process that is expensive, uncertain, time-consuming, and
obstructive to needed development projects (Zischke and Kostka 1993, as cited in Olshansky
1996, II).

One thing is for certain - CEQA employs hundreds of planners, technical

specialists, consultants and lawyers to implement, interpret and evaluate its provisions
(Olshansky 1996, 12).

107

Administrative Mechanisms
California has a massive institutional framework within which environmental
protection occurs. The Office of Planning and Research within the Governor of California's
Office oversees land use planning in the state and provides guidelines for the preparation of
general plans.

The California Resources Agency provides the administrative support for

CEQA and provides guidelines for its implementation.

The California Resources Agency

also maintains resource inventory databases for the state.
At the county level, the Board of Supervisors is the cornerstone of policy formulation,
decision-making and implementation. The elected 5-member Board is ultimately responsible
for the adoption of the General Plan, for certifying that the EIR meets the requirements of the
CEQA, as well as for the regulations, capital improvement programs, administration and
review procedures and financial mechanisms that are proposed by the plan (OPR 2002).

5.2.3

SEA Process

California State Level
The most notable observation of the SEA process in California is its significant
integration within the comprehensive planning process, running concurrently with the
development, review and approval of the General Plan. These processes should be “carefully
synchronized so that neither time nor work will be wasted through unnecessary delay or
duplication” (OPR 2002, 136).

The SEA process is also highly regulated under CEQA,

involving a multiple step process, with opportunities for interagency review and participation,
a considerable amount of documentation, and an array of complex methods and techniques for
impact analysis.

Usually, the EIR and associated reports are undertaken by several

consultants.

108

Under CEQA, when a local planning authority embarks on a planning process (a new
General Plan, revised elements of an existing General Plan, a new zoning bylaw or
subdivision rule), an ‘initial study’ (a type of screening) must be undertaken to determine if
the proposal may have significant effects on the environment. If such impacts are likely to
occur from future activities under the plan, the local planning authority must prepare an
Environmental Impact Report (EIR). If the local planning authority determines that the
proposed plan would not result in significant environmental impacts, it may prepare a
‘negative declaration’, which is an abbreviated assessment of the environmental implications
of the plan. If members of the public disagree with a local planning authority’s use of a
negative declaration, they may present evidence to show that environmental impacts would
occur and may appeal to the courts for a decision. Most of the time, however, the preparation
of a General Plan will result in environmental impacts and an EIR will need to be completed.
To call the preparation of an EIR for a General Plan in California a huge undertaking
would be an understatement.

Olsansky (1996) found that a comprehensive update of a

General Plan in the US takes an average of 23 months to complete and costs US$208,000; of
this amount, US$164,200 is for the preparation of the EIR. At the conclusion of the General
Plan process in San Joaquin County (five years after it first commenced), the county had spent
over US$2 million for the preparation of both the plan and the EIRS (US$623,000 was spent
on the EIR process) (Skewes-Cox 1996).
CEQA requires certain topics to be addressed in the EIR (Table 16), covering
primarily ecological and social issues.

While economic considerations are not evaluated

within the parameters of the EIR of the General Plan, economic factors can override
significant ecological impacts through the preparation of a “Statement of Overriding

109

Considerations” by the local planning authority. If the significant ecological impacts cannot
be avoided, and the economic (or social) factors are considered to be of great importance, the
plan can still receive approval. These significant and unavoidable impacts are required to be
documented in a separate section in the EIR.
Table 16
•
•
•
•
•
•

Topics that must be addressed in an EIR

land use and planning;
• geology / soils/ seismicity;
hydrology and water quality;
• traffic / transportation;
air quality;
• noise;
cultural / archaeological resources;
• visual quality;
public health and safety (hazardous
• waste water treatment and storm drainage;
waste, electromagnetic fields, etc);
• fiscal impacts (only as related to
public services (fire and police
environmental impacts such as inadequate
protection, schools, libraries, hospitals);_______ financing for waste water treatment)______

Both public and inter-govemmental involvement are integral components of the
CEQA process. While preparing a General Plan EIR, the local planning authority involves the
public at various stages from the scoping process at the beginning to public meetings during
the process and finally, when the draft EIR is prepared.

Government agencies have

opportunities to comment on the EIR at several points during the process. Once the EIR
process has commenced, a “Notice of Preparation” is sent by the local planning authority to
all other agencies that have jurisdiction over the proposed activity to give other agencies an
early opportunity to provide their input to the plan-making process. Every draft General Plan
EIR is circulated by the California State Clearinghouse to interested State agencies and to
ensure that their comments are sent to the local planning authority. Both the notice of
preparation and the State Clearinghouse review process are valuable mechanisms to foster
intergovernmental coordination (Bass and Herson 1999).

110

Documentation of the EIR process in California is reflected in the Environmental
Impact Report. The EIR record must contain the identification, evaluation and mitigation
measures for each of the required issues to be addressed. The document must contain:
•

description of the existing conditions;

•

identification and evaluation of alternative options;

•

identification of cumulative impacts of the plan; and

•

specification of possible mitigation measures to reduce significant impacts to
acceptable levels.
Under CEQA, every time a state or local agency adopts a plan, it must also adopt a

monitoring program to ensure implementation of the recommended mitigation measures.
San Joaquin County Level
San Joaquin County’s Comprehensive Planning Program comprised three components:
(i) a three-volume county General Plan; (ii) a General Plan Map; and (iii) a County
Development Title (includes zoning maps). At the onset, the General Plan intended to
accommodate the anticipated growth in both population and employment in the county within
the seven existing cities (Escalon, Lathrop, Lodi, Manteca, Ripon, Stockton and Tracy). An
EIR was prepared for this scenario by a consulting company (as is the usual case in
California), for a total cost of US$70,000, with funding for the EIR coming entirely from the
county’s general fund. However, the EIR was never certified because the county decided to
revise its General Plan to include five ‘new towns’ that would accommodate the anticipated
growth. Therefore, the consultants completed a second EIR. The cost estimate for this EIR
was US$525,000, with the developers of the ‘new towns’ providing all of the cost. At the

111

conclusion of the process, the county had spent about US$623,000 on the EIR process, with
over US$2 million in total for the preparation of both EIRs and the General Plan.
In the San Joaquin General Plan EIR, 20 types of environmental impacts were
considered, including: land use, water quality, library facilities, energy, public health and
safety. For each impact, a description is provided for existing conditions under a ‘setting’
section, and the impacts of the General Plan and possible mitigation measures in an ‘impacts
and mitigation measures’ section. The focus of the impact analyses for the EIR is on
cumulative, countywide impacts. A variety of mitigation measures were proposed to reduce
significant impacts to a level where they are no longer significant; these include changes to
policies in the county general plan, to enforceable regulations in the county development title,
and to various zoning maps.
Forecasts were made for an 80 per cent population growth (from 480,628 in 1990 to a
projected 864,200 by 2010) and a 64 per cent employment growth for the county between
1990 and 2010 (Draft EIR). The initial General Plan proposed areas for new residential,
commercial and industrial development in the existing seven urban communities to
accommodate about 70 per cent of this anticipated growth. In addition, five new / expanded
communities were also proposed to accommodate the remaining 30 per cent of the growth.
CEQA requires that alternatives be considered in the EIR, however, there is no minimum
number of options stated. The San Joaquin draft EIR considered three alternative options to
accommodate the anticipated growth: (I) no project alternative (not to build or expand the five
new communities); (ii) city-centred growth (to concentrate all the population growth on the
fringes of the existing urban communities; or (iii) dispersed growth (to build or expand the
five new communities).

112

The EIR identified 77 environmental impacts across nineteen different categories.
While many of these impacts were termed “less than significant”, five were identified as being
“significant and unavoidable. These were:
1. Removal o f more than 42,200 acres o f prime farmland in both the unincorporated
and incorporated areas;
2. Increased county-wide vehicle trips resulting in increased frequency o f accidents
and requirements fo r major road improvements;
3. Degraded air quality due to increased emissions from increased traffic;
4. Removal o f valuable habitat fo r biotic resources and special-status taxa; and
5. Further lowering o f the groundwater table to accommodate increased water
demands, resulting in exacerbation o f problems o f saltwater intrusion, increased
pumping costs, and subsidence. (San Joaquin County 1992,4).
The county filed a statement of overriding considerations that focused on the benefits
resulting from the plan that outweighed these impacts. The EIR also found that the amount of
land designated for development was more than was necessary to accommodate the projected
population and employment growth, therefore, the General Plan was approved on July 29,
1992 with growth to be accommodated at the edge of the existing communities and approved
only two of the five proposed new towns. The final EIR proposed that 74 per cent of the
population would be accommodated in the existing seven communities, thirteen per cent of
the population would be accommodated in the new or expanded communities, and the
remaining thirteen per cent would be living in other unincorporated areas of the County. A
monitoring plan was incorporated into the EIR for all recommended mitigation measures,
some of which were able to be monitored at the time of the adoption of the plan (i.e.,
incorporating the recommended revised policies).

113

5.2.4

SEA Methods

California State Level
One of the benefits of the EIR process in California is the large amounts of
environmental information that is gathered during the preparation of General Plans. The
methods or techniques to be used by local planning authorities in preparing an EIR of a
General Plan are not specifically legislated. Generally, it is expected that the ‘carrying
capacity’ for the area is defined, that baseline surveys are completed, and that maps of
‘opportunities and constraints’ are produced. The description of the existing conditions in the
plan area is a particularly important component of EIR preparation. State regulatory agencies
collect and maintain databases of natural resources for this purpose. Scoping and screening
tasks are undertaken as part of the ‘initial study’ element of the EIR process. This is the
responsibility of the local planning authority and consists of a checklist of impacts to be
compared with the proposed plan.
San Joaquin County Level
The San Joaquin General Plan EIR used a variety of methods and technical tools in
order to assess the identified alternative options. However, the primary methods used as the
basis for the development of the General Plan were population projections and developers’
proposals for new towns (Skewes-Cox 1996). The ‘carrying capacity’ for the county was not
determined and maps of ‘opportunities and constraints’ were not completed (Skewes-Cox
1996). A baseline survey was completed that included: the quality of agricultural soils, levels
of traffic on county roads, air quality data, and data on rare, threatened and endangered
species in the county. Technical tools used in the baseline survey included: travel demand
models, thresholds of significance, aerial photography, and field surveys.

114

5.3

New Zealand - Waitakere District
New Zealand is comprised of three main islands in the South Pacific (North Island,

South Island and Stewart Island), with a combined area of 270,500 km^ - slightly larger than
the United Kingdom (see Figure 11 for a map of the area). With 3.3 million people, however,
its population density is only about five per cent of the United Kingdom’s. The economy of
New Zealand is largely based on its natural resources - meat, wool, forestry, and fishing. As a
result, environmental and resource protection measures have been a priority. In an effort to
consolidate the many pieces of local and national legislation, the Resources Management Act
(RMA) was passed and implemented in 1991. The RMA provides the basis for most resource
management and environmental protection laws in New Zealand. Notable exceptions include
fish, energy, and minerals. The RMA devolves responsibility for resource management and
environmental protection in New Zealand from national to local governments. Local and
regional councils are expected to prepare planning documents that are aimed at achieving
sustainable environmental outcomes, rather than regulating resource development activities.
This focus on ‘environmental sustainability’ is distinct from ‘sustainable development’. The
RMA also recognizes the right of the Maori, the indigenous people of New Zealand, to the
nation’s natural resources and incorporates the Maori interest in decision-making.
Waitakere District encompasses several main centres (Figure 11): Waitakere City,
Hobsonville, Henderson, Ranui, Swanson, Massey North/Westgate, Glen Eden, and New
Lynn). Waitakere City is the fifth largest city in New Zealand with a population of 168,750 in
2001, growing at over 2% a year since the mid-eighties. Maori, the indigenous people of New
Zealand, form 14% of the City’s population. The largest earner and employer in Waitakere is
light manufacturing. Within this sector are two niche markets: boat building and wine

115

production. As well, the service sector is thriving, focusing on the growing leisure market.
Nearly half of Waitakere’s businesses are in the wholesale or retail trades, construction,
restaurants and hotels (Enterprise Waitakere 2002).
Covering an area of 139,134 hectares in the Auckland region, approximately one third
of Waitakere is urban, one third rural and one third wilderness area. More than 40% of the
City’s land area is in parkland and the Waitakere Ranges. In 1993, as part of Waitakere’s ecocity concept, Waitakere Council agreed to implement the goals and programs proposed under
Agenda 21 at the local level. Waitakere has prepared a Local Agenda 21 (the Greenpiint^^),
Stating how their city plans will work towards sustainability in the 21st century.
5.3.1

Political Context

The central government in New Zealand released the “Environment 2010 Strategy”
(published in 1994) as a follow-up to the Resource Management Act. This strategy has a
long-term vision that outlines the government’s five key environmental management goals: (i)
integrate environmental, economic, and social policies, (ii) establish and maintain a coherent
framework of law, (iii) sharpen the policy tools, (iv) build up the information base, and (v)
involve people in decision making. However, this document is primarily focused on the
natural and physical environment, with virtually no mention of sustainable development as a
concept or a goal.

The Greenprint is structured around seven key focus areas: community empowerment, urban consolidation, a
strategy of involvement, a holistic approach to health and safety, traffic reduction and community mobility, a
life-cycle approach to energy, resources and waste, and greater economic independence (Waitakere City Council
2003).

116

Figure 11

Map of Waitakere, New Zealand

NEW ZEALAND

WAITAKERE
DISTRICT

v'

Adapted from Waitakere City Council, 2003

In response to the criticisms, the central government announced its intentions to
produce a “New Zealand Strategy for Sustainable Development” (NZSSD) in August 2001.
Very little progress followed this announcement, and in August 2002, the Parliamentary
Commissioner for the Environment (PCE) noted his disappointment in the progress toward
sustainable development made by the central government:
Our review o f the last decade concludes with the view that New Zealand could have
been a leading light on sustainable development by now - but we are not. However, I
do believe that we have many o f the necessary ingredients to make the transition to a
sustainable development pathway (PCE 2002,1).'^
With this hard-hitting statement. New Zealand’s Parliamentary Commissioner for the
Environment provides several recommendations to the national government, including: the

14

‘Creating our Future: Sustainable Development for New Zealand”; a report produced by the Parliamentary
Commissioner for the Environment, August 2001.

117

establishment of a vision and framework for sustainable development, develop guidelines for
local authorities for Local Agenda 21 processes, establish a body to oversee and coordinate
the Government’s proposed New Zealand Strategy on Sustainable Development, and that
methods be identified and introduced to improve skills in integrating environmental, social
and economic policy analysis and implementation (PCE, 2002, 4).
It was only after the Parliamentary Commissioner for the Environment issued his
report in August 2002 criticizing the lack of progress and leadership by the national
government, that action was initiated. In January 2003, the Minister for the Environment
released its Sustainable Development Programme o f Action (the third document issued by the
Government to focus and re-orient government policy-making and processes'^) replacing the
proposed NZSSD), which provides a set of guiding objectives and principles to policy and
decision-making across the government sector.

The initial focus of the plan is on water

quality and allocation, energy, sustainable cities, and child and youth development. The action
plan will be driven by four ministers - Minister for the Environment, Minister for Social
Development, Minister for Economic Development and Minister for Statistics (responsibility
for Statistics New Zealand). Statistics New Zealand published “Monitoring Progress Towards
Sustainable New Zealand” in August 2002. This was an experimental report and will form the
basis for further work on a set of sustainable development indicators.
The central government announced ‘Green Packaging’ in the annual budget in 1996.
This represents the first attempt to prioritize actions to implement the Environment 2010
Strategy and initially included NZ $11 million in additional funding over three years. In 2001,
this was increased to NZ $22 million to identify environmental problems and provide practical
'^“Growing an Innovative New Zealand” (the Growth and Innovation Framework) (February 2002); and “Key
Government Goals to Guide the Public Sector in Achieving Sustainable Development” (October 2002).

118

support for projects. The Sustainable Development Action Programme, as well as the “Key
Government Goals to Guide the Public Sector in Achieving Sustainable Development” may
be considered first steps towards this process. There is no cabinet-level committee for
sustainable development in New Zealand. There is a Parliamentary Select Committee for
Local Government and Environment, that comprises several Members of Parliament, one
Minister (Customs) and two Associate Ministers (Economic Development and Social
Services).
In his report released in August 2002, the Commissioner stated that “it is the ‘local
initiatives’ dimension of sustainability thinking that has made the biggest contribution of
awareness of sustainable development in New Zealand” (PCE 2002, 9). Although the New
Zealand government has largely ignored the Agenda 21 commitments made in 1992 and have
not provided the necessary leadership (PCE 2002), other sectors have made progress with
their own sustainability initiatives, including; individual local authorities (e.g., Christchurch
City Council, Environment Canterbury; City of Auckland), business organizations (e.g., the
New Zealand Business Council for Sustainable Development), and community organizations
(e.g.. Sustainability Council of New Zealand), have made progress with their own initiatives.
As recommended by the PCE, the Minister for Local Government developed legislation and
guidelines for local authorities for preparing long-term community council plans consistent
with the principles of Agenda 21 (New Zealand Government 2002).

5.3.2

Institutional Context

Organization o f Planning
Under the Resource Management Act, all 12 regional councils must prepare a
Regional Policy Statement. Regional councils may also develop regional plans, and all 74

119

territorial councils must prepare a District or City Plan (15 are city councils; 59 are district
councils).

Responsibility for day-to-day environmental management lies with local

governments. Regional councils have responsibility for community resources - water, air, soil,
conservation and coasts. District councils have responsibility for effects of activities on land,
including noise and the control of subdivision. Recently, the central government strengthened
strategic planning by introducing new long term community plans to integrate decision
making within councils, provide accountability to the local community and enhance
opportunities for community consultation (Dixon 2002, 9). Waitakere has recently adopted
such a plan for the district.
Under the provisions of the RMA, the national government may also prepare a
National Policy Statement to guide local authorities on matters of national significance,
although only one such policy statement has been prepared to date - the New Zealand Coastal
Policy Statement 1994 - and this was a mandatory policy statement.
The RMA established a hierarchical, three-tier planning structure (central, regional and
local levels), creating both horizontal and vertical linkages. This hierarchy is based on the
assumption that decisions should be made as close as possible to the appropriate level of
community of interest where the effects and benefits accrue (Gleeson and Grundy 1997).
National and Regional Policy Statements establish a directional framework for regional and
district plans. Regional Policy Statements must not be inconsistent with national policy
statements and must have regard to any planning documents prepared by Maori authorities.
Under the new Local Government Act 2002, every local authority must prepare a Long
Term Council Community Plans (LTCCPs) which covers a ten year period. The purpose of
LTCCPs is to integrate decision making within councils, provide accountability to the local

120

community and enhance opportunities for community consultation (New Zealand Government
2001). It is uncertain as to how this new form of plans will interact with the district plans,
both of which are statutory.
Regulatory Provisions
Although neither EIA nor SEA is specifically mentioned by name in the RMA, there
are provisions for its use. Section 88(4)(b) requires that “an assessment of any actual or
potential effects...on the environment” must be undertaken.

Every human activity, from

mining operations to home improvements, is required to prepare an environmental impact
assessment. Appraisal of plans and policies is a requirement under Section 32 of the RMA
which charges MfE, regional authorities and district councils with a duty to evaluate their
objectives, policies and methods as well as to consider alternatives. The benefits and costs of
all the above, as well as alternatives, have to be examined and decisions made relative to their
necessity, effectiveness and efficiency in achieving the purpose of the Act before plans are
adopted. Section 32 applies to new plans, plan changes, variations to proposed plans, and
reviews of whole plans or parts of plans. It also applies to policy statements. Guidance for
using Section 32 was first published in 1993 by MfE, and was updated in July 2000.
Administrative Mechanisms
The MfE serves as the public body to ensure that the provisions of the RMA are
carried out.

The actual implementation of environmental management of community

resources rests with the local and regional councils. If a local or regional council is not
carrying out its functions, the MfE can undertake these functions and then recover the costs
from that council and community.

121

5.3.3

SEA Process

New Zealand at the National Level
A Section 32 analysis (SEA) is initiated when a council prepares a new plan or changes
any part of an existing plan. The focus is on the achievement of the purpose of the RMA, that
is, the achievement of sustainable resource management. Figure 12 shows the sequence of
steps in carrying out a Section 32 analysis (s32 analysis). Often, independent consultants
carry out the s32 analysis.
The RMA places an obligation on local councils to consider alternatives and to assess
their benefits and costs. Alternative objectives, policies and methods are identified early in the
process. All alternatives are appraised simultaneously with significant public input before a
preferred option is selected. For example, in order to address the effects of urban growth, a
set of methods considered by a council could be rules (zoning), transferable subdivision rights,
subsidies for infrastructure or charges for council-provided services, and transport-related
initiatives. The “no action” alternative is not specifically mentioned in the RMA nor the
guidance.

122

Figure 12

The sequence of steps in Section 32 Analysis

J. Id e n lify & .specify ih c ic.soiiicc
n u in u g c n ic n l issu es.
2. Id e n lify o b je c li\e (s )

3. Is th e o b je c tiv e n e c e ss a ry

►N O

4 . R e v ie w th e o b je c tiv e a n d /o r the

►Y E S

12. R ev iew the m e th o d s, th e p o licy
a n d /o r the o b je c iiv e a n d c o n sid e r
altern a tiv es

YES
5 . Id en tify tlie ra n g e o f p o lic ie s that
re a iislic a liy c o u ld a c h ie v e th e o b je c tiv e
0. T or e a ch p o lic y , id e n tify th e ra n g e o f
m e th o d s th a t c o u ld b e u se d to im p lem en t

7. A ssess th e e ffc c liv e n e ss o f each m ethod
8. R e je c t m e th o d s (hat are in su ffic ien tly
effe c tiv e
9 . Id e n tify & ev a lu a te the b e n e fits & co sts
o f e a c h m e th o d n o t i e je c te d at S tep 8
10. A sse ss th e re la tiv e e ffic ie n c y o f each
m eth o d
11. A re a ll m e th o d s v e ry in e ffic ie n t (ie co sts
a re la rg e in re la tio n to th e b e n efits? )

12 D e cid e w h ich o f th e m e an s a ie the m ost
a p p io p ria te
13. D e c id e w h ich o f the m e a n s a re the m ost
a p p ro p ria te
14. G o b ac k to a sse ss th e b e n e fits & co sts,
effe c tiv e n e ss & e ffic ie n c y o f o b jec tiv e s
& p o lic ie s
■Vloption an d im p le m e n ta tio n o f plan
p ro v isio n s
A re th e p la n p ro v isio n s a c h ie v in g th e
A n tic ip a te d E n v iro n m e n ta l R e su lts?

►N O

I"* R i'.le .. ' ■|n.li .c . p 'llii ic and
m e th o d s

J

MfE (2000)

123

Evaluating the environmental, social and economic benefits and costs are also part of the
Section 32 analysis.

Consistent with the RMA’s sweeping definition of ‘effects’, the

evaluation is expected to consider cumulative, temporal and spatial effects. All actions in the
analysis are recorded in a ‘Section 32 report’. Although not legally required, the Section 32
guidance recommends that the local council approve the report at the same time that the plan
itself is approved.

Monitoring for both compliance and environmental outcomes is a

requirement of Section 35. The RMA provides for public participation and monitoring, but
leaves much flexibility to the local authorities to determine their own requirements and
procedures. These requirements, as with all provisions in the RMA, are enforceable by third
party appeal to the Environment Court. Indeed, this has been the route taken by many New
Zealand citizens and developers. The Christchurch City Plan, for example, was initiated in
1991 and is still awaiting formal adoption in 2003 as a result of third party appeals of many of
its policies and provisions.
Waitakere District Level
The Waitakere District Plan was prepared over the period 1993 to 1995, and was
publicly notified in October 1995. Council decisions were released in August 1998, resulting
in 174 appeals lodged against the decisions. The majority of appeals were settled by
agreement, with three issues that needed to go to a Court hearing. While there are still several
outstanding appeals, these relate to small parts of the Plan and thus, the Environment Court
has allowed the Plan to be made operative on March 27, 2003, apart from those outstanding
issues. The plan appeals team originally comprised five full time staff, but this has been
progressively reduced as appeals have been resolved, and currently, there are two part time
staff working on the remaining issues.

124

Although not legally required at that time, prior to notification, the Council prepared a
‘Section 32 Report’ (written by an independent consultant planner). Amendments made to
section 32 as part of the RMA Amendment Act (2002) now makes the preparation of a
Section 32 Report legally necessary.

Subsequent changes to the District Plan must also

undergo a section 32 analysis.

5.3.4

SEA Methods

New Zealand at the National Level
Guidance on Section 32 analysis does not prescribe the methods or techniques to be
used by local authorities, acknowledging that individual analysts and decision-makers will
assess benefits, costs, efficiency and effectiveness in different ways. To assist in the
identification of the resource management issues and associated objectives, the guidance
suggests the use of public and expert opinion. Checklists and matrices (as illustrated in Table
17) are used to assess the benefits and costs of alternative options. Responses for each cell
can be in text format, rankings or quantitative estimates.
Table 17

Example of a checklist for Section 32 Analysis
TAKE NO
ACTION

OPTION 2

OPTION 3

OPTION 4

Effectiveness in achieving the
purpose of the RMA and/or the
plan objective
Environmental benefits
Environmental costs
Economic costs
Economic benefits
Social costs
Social benefits
Efficiency
Appropriateness
MfE (2000)

125

5.4

Summary
In this chapter, each case study was examined and described in terms of its own

distinct contexts. The discussion noted some of the strengths and weaknesses associated with
each case. Using the Evaluation Framework developed in Chapter Four as a guide, the cases
will be further analyzed for effectiveness in Chapter Six.

126

Chapter Six
Case Study Results and Analysis
6.0

Introduction
This chapter presents the case study results and discusses the effectiveness of SEA

systems in the three case studies. The analysis combines the evaluation framework (Figure 13)
and criteria developed in Chapter Four with the case study findings to answer the research
questions. As discussed in Chapter Four, only four levels of the framework are evaluated policy context, institutional arrangements, SFA processes and SFA methods. For each of these
four levels, both the procedural and substantive effectiveness is evaluated, using the criteria
identified in Chapter Four.

This chapter concludes with a summary of the overall

effectiveness of the case studies.
Figure 13 Evaluation framework

NORMATIVE

PROCEDURAL
E F F E C T IV E N E S S

POLICY
INSTITUTIONAL
SEA
PROCESSES
SEA
METHODS

127

SUBSTANTIVE
E F F E C T IV E N E S S

6.1

Policy Context
Table 18 provides a summary of the procedural and substantive effectiveness of the

policy context for each of the three case studies. A discussion of each of the criteria is
presented in the following sections.
Table 18 Evaluation of procedural and substantive effectiveness of the policy context
P R O C I 1)1 l ! \ l . m - K r i l N K S K S S

('rilu ria
1. Is th ere a supportive political culture
a t higher levels of governm ent (l.e.,
national, sub-national)?

Scolland
Yes. Cabinet Sub-Committee on
Sustainable Scotland; Greening
Government initiative.

( nliforiua
No. Although sustainable
development is mentioned in
CEQA, this is not reflected in state
policy, nor in national policy.
Several regional and community
initiatives exist in certain areas.

2. Is th e re a systematic, integrated
policy fram ew ork a t higher levels of
decision-m aking fo r co n sid er::^
sustaiimbU ity/environmental principles
(i.e., national, sub-national)?

Yes. National Sustainable
Development Strategies and
Indicators for UK and Scotland.
Strong focus on sustainable
development.

No. A t the national level, the
President’s Council on Sustainable
Development produced
recommendations in “Sustainable
America”, however, progress has
been minimal.

3. Is th ere a com m itm ent to sustainable
developm ent initiatives in the local case
study?

Yes. Perth and Bünross Council
demonstrates strong commitment
to sustainable development.

No. There are no initiatives by local
authorities in San Joaquin County.

4. Is SEA integrated into th e p lanning
process?

No. Currently, SEA is not
integrated with planning process,
operating as an ‘add on’. May
become more integrated once EU
Directive is operational.

Yes. SEA is strongly integrated into
the planning process, running
parallel and simultaneously w ith it.

('rilc ria
1 M u st the Hndings o f the SEA be a
cen tral d eterm in an t of final decision­
m aking?

Scotland
No. Sustainability information is
considered, but necessarily a
central determinant of decision.

2. W as die flnal plan m odified
according to th e recom m endations of
the SEA?

Yes. According to the appraiser,
the conclusions, constraints, and
revisions stated in the
sustainability appraisal, in most
instances, were integrated into the
final structure plan.
Partially. In the opinion of the
appraiser, the SEA has done much
to create linkages that clearly
define relationsWps between
themes. Greater links had to be
made to ensure the three principles
were interdependent.

/ i m I. i i h I

Partially. Progress has been slow
by the central government.
Support for sustainabiUty exists
th r o u ^ the Parliamentary
Commissioner for the
Environment, and this has recently
spurred the central government
into action.
Partially. Up until very recently,
there was no integrated policy
framework at higher levels.
However, progress has
commenced with the “Programme
of Action for Sustainable
Development” (2003), and the
National Environmental Standards
which are nearly completed.
Yes. Waitakere has very strong
commitment to sustainability
through its Eco-City designation
and file Greenprint Strategy,
among others.
Yes. The RMA stipulates that SEA
is part of the planning process,
and this was die case in Waitakere.

si iisrwrivK i:n i:< iivi \i:ss

3. Is sustainable developm ent prom oted
th ro u g h integrating environm ental o r
sustainability considerations Into p lan
decisions?

C alifornia
No. The findings of the EIR can be
put aside with a Statement of
Overriding Considerations, allowing
the General Plan to be approved
even with significant environmental
impacts.
Partially. Several o f the mitigation
measiues recommended for
identified environmental impacts in
the EIR were included in the final
General Plan.

New Zealand
No. RM a makes environmental
assessment central to decision, but
not given weight in practice.

No. A Statement of Overriding
Considerations was prepared in San
Joaquin County which allowed the
adoption o f the Plan even with
significant environmental effects.

Partially. In W aitakere,
sustainable development is
promoted, decision-making is
being affected by appeals to die
Environment Court.

Partially. Plan was modified based
on public input, court decisions
and negotiations.

Coding Key: Yes = 2 points Partially = 1 point No^O points
l O i \ l M OKI S
Pro ced u ral Effecüveness (out oi
Substantive Effectiveness (out o f 6)
O verall Effectiveness for Policy C ontext
(out o f 14)

S rO 'l L A M )
6 (75%)

1 M IIOUM\
2 (2 5 $ )

M \ l / \ \ l Wi n
5 (6 3 $ )

I'll M S
13 o f 24 (54%)

3 (50%)

1 (17%)

20% 0

6 o f 18 (3 3 $ )

7 (5 0 $ )

19 o f 42 (45$)

9 (64%)

128

6.1.1

Procedural Effectiveness

Supportive Political Culture
A supportive political culture is defined in this thesis as one that promotes and
supports sustainable development at the highest levels of decision-making. This refers to the
creation of government ministries or committees responsible for promoting sustainable
development.

Based on this understanding, the Scottish case study demonstrates strong

political commitment for sustainability including: an active Cabinet sub-committee for
sustainable development, a “Greening Government" initiative, and a series of official
statements made by the First Minister in support of sustainable development. In contrast, the
Governor’s Office in the State of California exhibits minimal support for sustainable
development. Voluntary and ad-hoc initiatives promoting sustainability have emerged from
regional organizations (for example, the Southern California Association of Governments) and
from local communities, such as “Sustainable San Francisco”. Progress toward sustainable
development has also been slow in New Zealand. In his annual report in 2002, the
Parliamentary Commissioner for the Environment (PCE) criticized the national government
for its lack of progress in the advancement of sustainable development (PCE 2002). Since
then, the central government has responded with its sustainable development strategy, the
“Programme of Action for Sustainable Development”, released in January 2003. A discussion
paper was released in November 2002 - “A Framework for Developing Sustainable
Communities”, developed in discussion with the Department of Internal Affairs, Ministry of
Social Development, Child you and Family, and the Community Employment Group.
National Environmental Standards are nearly complete.

The Resource Management Act

provides a framework for the incorporation of sustainable resource management to guide

129

management and planning decision-making. However, the definition for ‘environment’
focuses solely on biophysical factors. There are no government departments or committees
that oversee sustainable development. Sustainability initiatives that are occurring in New
Zealand are emerging at the local level (e.g., Waitakere Eco City and Environment
Canterbury).
Systematic and Integrated Policy Framework
A systematic and integrated policy framework for considering sustainability principles
to guide assessment has been identified as a key component to the success of SEA (Partidario
1996; Sadler and Verheem 1996). This includes the implementation of national sustainability
strategies, objectives and indicators. In the United Kingdom, a national sustainability strategy
coupled with associated indicators has been in effect since 1999. Similarly, Scotland has also
developed its own sustainability strategy and indicators; however, the Perth and Kinross
Council chose to use the framework provided by the UK strategy. No such policy framework
exists in California.
In New Zealand, the RMA is intended to provide a systematic and integrated policy
framework. Each local authority is also expected to undertake State of the Environment (SOE)
reporting which feeds into a national SOE report. Plan-making is guided by the requirements
and provisions of the RMA; the s32 analysis is intended to ensure that issues, objectives,
policies and methods included within the plan are consistent with the RMA. Although the
RMA fails to consider the full range of sustainability principles to guide assessment, s32
analysis is required to evaluate social, economic and environmental costs and benefits.

130

Commitment to Sustainability at Local Case Study Level
In 1993, Waitakere became New Zealand’s first Eco-City under Agenda 21 of the
Earth Summit.

As an Eco-City, Waitakere is committed to ensuring that the economy,

environment and society are sustainable.. This direction is outlined in the ‘Greenprint”, the
Council’s LA21 strategy, and achieved through the District Plan. Additionally, Waitakere
demonstrates strong policy commitment to sustainability initiatives including a corporate
sustainability strategy, encouraging residents to ‘buy Waitakere’, the Ecosourcing Code of
Practice, a system of ‘Green Networks’ for cycling and walking, and the City Wellbeing
Strategy. Perth and Kinross Council (Scotland) demonstrates strong commitment to
sustainable development in their environment strategy, various planning processes (such as
the LA21 plan, the Quality of Life strategy, and the community planning process), as well as
the sustainability appraisal of the structure plan.

This mirrors the Scottish Executive’s

commitment to sustainability initiatives. San Joaquin County (California) does not appear to
have a similar commitment to sustainable development, reflecting the lack of such initiatives
at the state and national levels.
Integration into Planning Process
Only one of the three cases demonstrates effective integration into the planning
process. In California, SEA is integrated strongly into the planning process, occurring from
the beginning and continuing throughout the entire process. In New Zealand, s32 analysis
occurs at the onset of the process, but cannot be considered as effectively integrated into the
planning process as it does not continue throughout the process. In contrast, SEA currently is
not integrated at all into Scotland’s planning process, operating as an “add-on” and occurring
only after the plan has been completed.

131

6.1.2

Substantive Effectiveness

Findings as Central Determinant in Decisions
Although SEA is promoted by the academic literature as a means to improve decision­
making, the findings of the SEA are not required to be the central determining factor in
decision-making in any of the three cases. This is arguably the most significant weakness in
SEA practice today. In California, a plan can be adopted even with significant environmental
impacts as long as a “statement of overriding considerations” is filed with the final EIR,
justifying the decision. Of the three alternative options in San Joaquin County, it can be said
that the most environmentally damaging option was selected (Skewes-Cox 1996). Significant
unavoidable impacts associated with the general plan included the removal of prime
agricultural land and significant traffic impacts.

The county’s findings of overriding

considerations focused on three elements which were described as “outweighing” the plan’s
significant, unavoidable environmental impacts (Figure 14).
Figure 14 Findings of overriding considerations in San Joaquin County's EIR
•

•
•

approval of the general plan was designed to accommodate the projected population
growth as long as specific conditions were met by future developments such as
provision of adequate water and sewer service, funding of necessary on-site
improvements and reduction of environmental impacts to an acceptable level;
approval of a Development Title (containing regulations) to protect the public’s
health, safety and welfare; and
expansion of the industrial, commercial, and housing opportunities for existing and
future residents within San Joaquin County.
Skewes-Cox (1996)

In Scotland, the consideration of environmental information is suggested in planning
guidance (SPP 1; PANs 37 and 49), but the results of a sustainability appraisal does not need
to serve as a determining factor in the adoption of a plan. In New Zealand, the RMA makes
environmental assessment central to decision-making. The results of a section 32 analysis do

132

not always figure prominently in determining the adoption of a plan. Many district plans are
held up for many years in the Environmental Court as a result of citizens, organizations and
businesses lodging appeals against various components of the draft plans. The resolution of
the issues of concern has become the central determining factor in the adoption of plans.
Recommendations Resulting in Plan Modification
One of the most important reasons to undertake SEA of comprehensive plans is for the
information and recommendations emerging from the process to be taken into consideration
by decision-makers and incorporated into the final plan. According to the appraiser in the
Perth and Kinross case, roughly half of the recommendations were integrated into the final
plan. In some cases, local authorities deemed that existing policies or practices already
addressed the concerns expressed. In San Joaquin County, the plan was modified from its
initial draft form, but not primarily because of concerns raised in the EIR. The anticipated
growth did not occur in the county due to the general economic recession and slow rate of
development throughout most of California (Skewes-Cox 1996). As a result, the new towns
never proceeded to the first stage of development of a specific plan. Additionally, staffing at
the county department was also reduced due to budget shortfalls, leaving little progress with
the implementation of the EIR’s recommended mitigation measures. The Waitakere Plan was
modified prior to its notification through consultations and analysis (including section 32), and
after notification through submissions by the public and appeals to the Environment Court. In
New Zealand, the effects of section 32 analysis is more difficult to isolate as it is only one
component of many that serve to assess the district plan.

133

Integration o f Environmental Considerations into Decisions
Although one of the primary objectives of SEA is the integration of environmental
considerations into decision-making, this was not achieved effectively in any of the three case
studies. The guidance and provisions for SEA in all three cases state that the consideration of
environmental factors in decisions is a key element, however, this does not always occur in
practice.

In California, CEQA has potentially conflicting objectives; first, to ensure that

environmental considerations are taken into account in decision-making, and second, to allow
the local authority to attach a “statement of overriding considerations” to a plan that has
significant and unavoidable environmental impacts, seriously challenging the achievement of
the first objective.
New Zealand’s RMA has a mandate to ensure that sustainable resource management
decisions are made. The adoption of nearly all district and city plans has been slowed down in
the court system. In some cases, the public may not support the integration of environmental
factors in decision making. For example, in Waitakere, there has been public backlash against
the “green” focus of the Council perceived to be taking priority over social and economic
concerns (Knight 2000).

In Scotland, there has been a strong focus on the pursuit of

sustainability objectives since devolution.

However, recommendations in support of

sustainability (or the environment for that matter) are not always finding their way into the
adopted plan.
6.2

Institutional Arrangements
A discussion of each of the procedural and substantive effectiveness of the institutional

arrangements is presented in the following sections. Table 19 provides a summary of the
findings.

134

Table 19 Evaluation of the procedural and substantive effectiveness of institutional
arrangements
i'K ot i;r)i K.M. i;i ii;t rtvi;.Ni:.ss
Criteria
1. Are comprehensive plans
based on clear legal
provisions?
2. Is the SEA system based on
clear legal provisions?

3. Is there an adnünistrative
body to oversee SEA process
(even in the absence of iegal
provisions)?

4. Is the SEA subject to
interagency review?

5. Are guidance, training and
support provided?

6. Are there visible linkages to
decision-making?

7. Is there independent
oversight of the SEA?
Criteria
1. Is project EIA strengthened
through ‘tiering’ (verticai
linkages) to carry
sustainability principies from
plans to projects?

Scotland
Yes. Statutory: Town and
Country Planning (Scotland) Act.
Non-statutory: Scottish Planning
Policies (SPPs)
No. No legal provisions
currently, but will need to be in
place by July 2004 in compliance
with EU Directive. Currently,
SEA is encouraged through
SPPl.
No. Once EU Directive is
implemented, an administrative
body will need to be in place.

No. Review by other
governmental agencies and
departments is not a binding
requirement. In Perth and
Kimoss, the SEA was subject to
review by the public, including
agencies. Review of government
agencies is generally at the
discretion of the appraiser.
Yes. Guidance for SEA provided
by the UK’s DoE 1993), the
Tyldesley Report (DTA 1995a
and 1995b), Interim Planning
Advice (D TA and Scottish
Executive 2003).

California
Yes. Statutory: California Code
Regulations. Non-statutory:
General Plan Guidelines and
CEQA Guidelines.
Yes. CEQA clearly defines
SEA process and provides the
legal basis for SEA since 1970.

New Zealand
Yes. Statutory plans are
required under the RMA for
district and city plans, but
regional plans are optional
Yes. The RMA provides the
legislative basis for SEA since
1991. Broad framework allows
local authorities considerable
discretion in practice.

Yes. The California Resources
Agency (CRA) and the
Governor of Cahfomia’s Office
of Planning and Research
(OPR) oversee the process.

No. The Ministry for
Environment (MfE) is
responsible, but does not
actively oversee the Section 32
process. Increasingly, the
Environment Court is being
relied upon to solve disputes.
Yes. During plan preparation,
Waitakere was required to
consult the Minister for the
Environment, other central
government ministers as to
who may be affected,
Auckland Regional Council,
and iwi authorities (through
Tangata Whenu andKnnaga)'®
Yes. Guidance provided by
MfE in Section 32 Handbook.
Also, the “Quality Plans
Project” gives authorities
opportunities to share
experience and advice on good
practice.
No. Although a Section 32
analysis and report are required
under the RMA, approval of
district plans are not depended
upon them.
No. Not discussed in guidance,
nor practiced.

Yes. Undertaken by the State
Clearinghouse as part of the
notification process once draft
EIR has been received.

Yes. Guidance provided by
CEQA and OPR.

No. Plan approval is not
Yes. Plan approval is
conditional on the SEA, but is
conditional on submitting a
viewed as good practice to
completed EIR.
undertake one and is left to the
discretion of the local authorities.
No. Not discussed in the
Yes. Required under CEQA.
guidance, nor practiced.
s u n s l AN'l IN 1:1.11 I t H \ EMISS
('ulifnriiin
Sriitlniid
No. A relationship with project
Yes. Tiering is one of the
EIA does not generally exist with strengths of the CEQA.
SEA. In the case study,
recommendations were included
to highlight the need for an EIA
where relevant. Tiering will need
to be a part of the legislation
under the EU Directive on SEA.

New /ealuiid
Partially. The concept of
tiering is an undeveloped area
in New Zealand planning
practices. Project EAs have
largely become a checklist of
required outcomes and rules.

Coding Key: Yes = 2 points Partially = 1 point No = 0 points
Procedural Effectiveness (out of 14)
Substantive Effectiveness (out of 2)
Overall Effectiveness for Institutional
Arrangements (out of 16)

SGOTUAM)
4 (29%)
0

« \ l l | i » R M\
14 (100%)
2 (100%)

M W / I ’ M \ M)
8 (57%)
1 (50%)

l Oi \ l S
26 of 42 (62%)
3 of 6 (50%)

4(25%)

16 (100%)

9(56%)

29 of 48 (60%)

16

Iwi are Maori tribal groups. Tangata Whenu are the people of the land, the people who hold the customary
authority in an area according to tribal custom. Runaga are the local representative Maori groups equivalent of
local government.

135

6.2.1

Procedural Effectiveness

Clear Legal Provisions fo r Comprehensive Plans
There are clear, legal provisions for comprehensive plans in Scotland (under the Town
and Country Planning Act) and in the state of California (through the California Government
Code Regulations). Guidance for the preparation of plans is provided through SPPs and PANs
in Scotland and General Plan Guidelines in California.

In New Zealand, statutory

requirements for the preparation of comprehensive plans for districts and cities; regional
plans, however, are not mandatory. District and city plans are taking considerable amounts of
time to prepare and adopt. For example, Waitakere’s plan preparations began in 1995, and the
plan was made operative in March 2003. Many developers and private citizens are taking
advantage of the opportunity to lodge appeals in the Environment Court against policies
contained within the plans.
Clear Legal Provisions fo r SEA
By far, California exhibits the most comprehensive and enforceable regulatory
provisions for SEA of all three case studies. Since 1970, CEQA has clearly defined the SEA
process and provides the legislative basis for the evaluation of plans for the state through its
Guidelines. Despite the name, these guidelines are legal requirements in California. In New
Zealand, the RMA provides a strong legislative framework for SEA since 1991 under section
32. Referred to as “section 32 analysis” (s32 analysis), this directive requires local authorities
to undertake an evaluation of the benefits and costs of a plan’s policies. Section 32 analysis
was not intended to legislate SEA per se (SEA is not mentioned by name in the RMA), but to
ensure that both the benefits and costs (environmentally, socially and economically) were
adequately considered when preparing district and city plan.

136

The RMA also grants local authorities considerable discretion in the implementation of
its provisions. Coupled with a virtual lack of enforcement procedures, this has resulted in
uneven application of SEA at the local level in New Zealand.
Currently Scotland has no legal provisions for SEA, although it is strongly
recommended in the non-statutory SPPs and PANs. Once the EU SEA Directive comes into
effect, then clear, legal provisions for its application will need to be in place throughout the
UK. The UK has recently drafted guidance to serve as the legal basis for SEA for England and
Wales (ODPM 2003); the Scottish Executive has also developed their own interim planning
advice, prepared by David Tyldesley & Associates and the Scottish Social Research branch
(DTA 2003). Consultation was undertaken with the Scottish Executive’s own Sustainable
Development Unit, Scottish Natural Heritage and the Scottish Environmental Protection
Agency, amongst others. While the EU directive is limited to legislating SEA within a narrow
biophysical environmental focus, the UK and Scottish SEA provisions will continue to
embrace a wider scope to include social and economic considerations as well as biophysical
ones. It is uncertain as to whether the process will be termed as “SEA”, or continue to be
referred to as “sustainability appraisal”.
Administrative Body to Oversee SEA
The identification of an administrative body to oversee the SEA system provides
direction and accountability for the process, even in the absence of a legal framework for
SEA. There is no such administrative body in Scotland that oversees the SEA system. The
Scottish Executive has issued guidance, however, it does not actively provide direction and
accountability for the process. This will most likely change once the EU Directive is
implemented. In California, both the California Resources Agency and the Office of Planning

137

and Research play significant roles in the administration of CEQA and comprehensive
planning. The roles of each are clearly delineated in the legislation and include providing
guidance and training, distributing draft EIRs to other government agencies and departments,
and maintaining numerous databases of environmental information and inventories.
In New Zealand, the Ministry for the Environment oversees and guides the s32
analysis process, however, local authorities are given responsible for the implementation of
the analysis. If local citizens believe that the local authority has neglected its duties, they can
lodge an appeal with the Environment Court. The court system has increasingly been relied
upon to serve as an overseeing body for many aspects of comprehensive planning.
Interagency Review
Review of the SEA by other government agencies and departments is strongly
integrated in California, but is minimal in both Scotland and New Zealand. The California
State Clearinghouse has responsibility for distributing draft EIRs to all affected government
agencies through the “notification” process.

In Scotland, the decision to seek input and

feedback by other government departments and agencies on the draft SEA is left to the
discretion of the local planning authority or the plan evaluator.

In Perth and Kinross,

interagency involvement was sought on an informal basis to provide technical advice or to
provide background information.

Under the RMA in New Zealand, local authorities are

required to consult the Minister for the Environment, other central government ministers who
may be affected, the regional authority for the area, and the Maori (or iwi) authorities.
Whether effective consultation does indeed occur with indigenous peoples is not known; this
subject would require its own in-depth examination.

138

Guidance, Training and Support
Guidance and training to assist local authorities in applying SEA is available in all
three case studies, to varying extents. Of the three, California has the strongest system in
place.

Both CEQA Guidelines and General Plan Guidelines (treated as regulations in

California), with cross-referencing available in both, provide detailed information for SEA.
The UK government has provided guidance in undertaking environmental appraisal since
1991 with the “Good Practice Guide” (DoE 1993). This was followed in Scotland with the
“Methodology for the Environmental Appraisal of Scottish Development Plans” prepared by
British consultants DTA (1995a and 1995b). More recent guidance can be found reviewing
SE As undertaken by local authorities, rather than through government guidance (for example,
the sustainability appraisals for Aberdeenshire and Highland). In New Zealand, the Ministry
for the Environment has also published detailed guidelines for local authorities in its
handbook “What are the Options? A Guide to Using Section 32 of the Resource Management
Act” (MfE 2000).
Additionally, the “Quality Planning Project”" promotes best practice by sharing
knowledge about policy and plan development under the RMA. The website is for council
practitioners and consultant planners, environmental managers and others involved in the plan
preparation process (QPP 2003).
The cost of undertaking SEA in California is primarily covered through either local
general funds or developers’ fees. The first San Joaquin EIR was funded completely from the
County’s general fund. This first EIR was never certified, as the General Plan was revised to
include the five new towns; this second EIR was funded totally be the developers of the new
" The Quality Planning Project is a partnership between the New Zealand Planning Institute, the Resource
Management Law Association, Local Government New Zealand, the New Zealand Institute of Surveyors and
the Ministry for the Environment (QPP 2003).

139

towns. In Scotland and New Zealand, costs for SEA must come out of local authority funds.
The devolution of environmental planning and management in New Zealand from the central
to local governments has been particularly overwhelming for local authorities with no
additional financial or human resources provided.
Visible Linkages to Decision Making
In California, approval of the general plan is based on the submission and approval of
the EIR. However, as noted previously, the EIR does not necessarily have to be lacking
significant environmental impacts to be approved as long as a “statement of overriding
considerations” is included to justify approval of the plan or mitigation measures identified.
In Scotland, plan approval is not connected to the submission of a sustainability appraisal.
The submission of a satisfactory appraisal document will be required once the EU directive
comes into force (DTA 2003).
There are no requirements to submit a s32 analysis report to New Zealand decision­
makers along with the district plan. In 1999, appellants lodged a submission asserting that
Dunedin City Council’s failure to comply with section 32 was so fundamental that the
relevant sections should be withdrawn in whole or in part. While the Environment Court
appeared to accept that there were significant defects in the section 32 report, noting that there
were almost no evaluations in the report (for example, of relevant costs and benefits at least in
quantitative or economic terms) and that parts of the section 32 report were unprofessional
including handwritten notes and a general lack of justification for the challenged policies and
rules. Despite that, the Court ruled that it had no jurisdiction under section 32 to consider
whether or not the analysis undertaken by Council complies with the Act. On appeal, the
High Court ruled in December 2000 that the Environment Court did have jurisdiction to take

140

into account the adequacy or even the total absence of a s32 analysis when considering the
reference on its merits, and that if the Environment Court held that there had been noncompliance with s32, it did not have the power to direct a Council to undertake the analysis,
and would have to do so itself (New Zealand Court of Appeal 2001).
Independent Oversight
The academic literature identifies independent oversight as one of the most important
characteristics of an effective SEA system (Partidaiio 1996; Sadler and Verheem 1996). Yet,
this is one of the weakest elements of effectiveness in all three case studies. The concept of
independent oversight is encouraged in California through guidance, but is not used
effectively in practice as there are no legal requirements for its use. Legal provisions for
independent oversight do not exist in either Scotland or New Zealand, and there is no
evidence to suggest that it is used on a voluntary basis in either of the case studies.

6.2.2

Substantive Effectiveness

Tiering o f Plan-Level SEA and Project EIA
In California and the United States, CEQA and NEPA both encourage agencies to
“...tier their environmental studies to avoid repetition of issues and to focus on those [issues]
that are appropriate for decision making at each level of planning” (Bass and Herson 1999,
280).

Under CEQA, once a Master EIR has been prepared for an area, any subsequent

projects that come within the scope of the Master EIR only need to go through an initial
screening to ensure that the project has been included, and if so, then no further evaluation is
required (Bass and Herson 1999).

In theory, this requirement should result in the need for

fewer project-level EISs. However, this has not proven to be the case. Many impacts will not
be adequately assessed at this level, making it critical that a two-tier approach be applied.

141

specific developments must undergo some type of environmental analysis, with a focus on
impacts not adequately addressed at the general plan stage (Skewes-Cox 1996).

This is

evident in the San Joaquin County case study. Each of the proposed new towns will need to
prepare a “specific plan”, and thus, will require the preparation of an EIR under CEQA. There
are no legal requirements that specific plans comply with the county’s general plan, as the
jurisdiction of the general plan is limited to the unincorporated areas.
SEA and EIA processes are implemented separately in Scotland, with virtually no
opportunities for interaction or tiering. The concept of tiering is required in the impending EU
Directive; UK and Scottish authorities will need to include this in legislation. The RMA in
New Zealand provides for a hierarchical framework of policy and plan making, in that
regional plans must conform to both national and regional policy statements, and district plans
must conform to both regional plans and policy statements. Nearly every activity in New
Zealand, from mining to home renovations, requires an environmental assessment in order to
receive a ‘resource consent’ to proceed. In order to receive a resource consent, an EA must be
undertaken and the outcomes must conform to the district plan of the area. In practice, this has
resulted in a multitude of cases being heard at the Environment Court.
6.3

SEA Processes
The procedural and substantive effectiveness of the SEA processes for each of the

three case studies is provided in the following sections. Table 20 summarizes these findings.

142

Table 20

Evaluation for procedural and substantive effectiveness of SEA processes

Criu^i'ia
1. Is the SEA based on an objectivesled approach?

P U O d l H K \ l LI F I K M m NESS
SvvtiaUil
CdlUuiuia
Yes. Plan is evaluated against
No. Plan follows a baseline-led
sustainabili^ objectives.
approach.

2. Is there an effective scoping
process (Le., a p ^ e d a t onset of
process with public involvement to
define issues)?

No. Although scoping is one of the steps
recommended in both Scottish and UK
guidance, its puipose is to identify gaps
in policy coverage of issues that have
already been identified in the plan.

3. Do opportunities for public
participation exist beyond receiving
information after the process (e.g.,
occurs a t several times throughout
process; results in the genuÜK
consideration of input)?

No. Public participation is not a binding
requirement. In Perth and Kinross,
public consultation occurred once the
SEA was completed, rather tiian early in
the process. Recent guidance for SEA
in Scotland is silent on this issue.

4. Are mitigation measures
identified?

Yes. Mitigation measures were
identified in the Perth and Kinross case
study, however, these measures are not
requirW nor suggested in guidance.

5. Was a separate SEA report
prepared?

Yes. A separate SEA report is not
required, however, in the Perth and
Kinross case study, a SEA report was
produced.
Yes. Although not required, the SEA
report was publicly available in the case
study. Public reporting is part of the
comprehensive planning process.
Partially. There are no requirements for
monitoring. A monitoring plan and
indicators were incoiporated into the
SEA document for the case study.

6. Were the SEA results publicly
reported?

7. Are there provisions for
monitoring?

C riteria

1. Is the SEA a proactive
assessment?

Yes. Scoping is mandatory under
CEQA. Notice of Preparation (NOP) is
circulated to government agencies to
suggest items for consideration. There
are no requirements to include the
public in scoping processes.
Yes. Public participation is a key
feature of CEQA. At a minimum, there
are opportunities for review and
comment. In San Joaquin County, over
100 public meetings were held during
the preparation of the General Plan.
CEQA also requires that all public
comments be addressed by the
responsible authority.
Yes. Mitigation measures must be
recommended in the final EIR for all
identified impacts. In San Joaquin
County, three categories of mitigation
measures were included (policies,
regulations and Iwd use), as well as the
degree of impact (less-than-significant
or significant-and-unavoidable).
Yes. A separate SEA report (EIR) is
required; contents for the report ^ e
specified in CEQA.
Yes. Local authorities must publicly
report results and respond to all
comments by the public. The EIR
document is available to the public.
Yes. Monitoring program is required
for when there are mitigation measures
identified.

SI Its 1 AN r i \ 1 .1 :1 1 1:( 1 1 \ i : \ i s s
C«tiltuL'lli<t

ScutluuJ
No. SEA is undertaken after the plan is
drafted.

2. Is the SEA a sustainability-led
process?

Yes. The sustainability criteria ensures
that all three conq)onents of
sustainability are considered.
Sustainability objectives and criteria
guide the appraisal process.

3. Are cunuilative impacts
considered?

Partially. Where linkages and
cumulative impacts of policies and
proposals could be identified and
appropriately assessed through the SEA,
Àis was highlighted in the revisions,
recommendations and conclusions of tiie
SEA.
No. The identification and evaluation of
alternative strategies to guide plan
development were considered by the
planning team at the onset of the
process, the SEA Itself did not evaluate
alternative options. The two processes
operated separately.

4. Are alternative options identified
and evaluated?

iNvW Zucllrllld

Yes. Although the EIR process runs
parallel to the plan, the developers’
proposals for new town development in
San Joaquin County guided the
process.
Partially. Section 21060.5 of CEQA
defines environment as physical
conditions (including land, air, water,
minerals, flora, fauna, noise, and
objects of historic or aesthetic
significance). However, in San Joaquin
County, both environmental and social
impacts were considered. Economic
impacts addressed are limited to fiscal
and financial impacts borne by the
County.
Partially. The impacts on the seven
cities and the unincorporated areas of
the County ^ e all considered. Each
city has an identified ‘sphere of
influence’. Cumulative impacts on
neighbouring counties are limited to
transportation-related factors.
Yes. Under CEQA, alternatives must
be evaluated (including the ‘no project’
option), but no minimum number of
options are suggested. A clear
justification of choice must be
included. In San Joaquin, three
alternative options were considered,
including the ‘no growth’ option.

Yes. Objectives are identified and plan
policies are appraised in terms of their
ability to satisfy the objectives.
Partially. Scoping is not required per se
under RMA, however, the
identification of resource issues at the
onset of the plan preparation serves as
a form of scoping.
Yes. In Waitakere, consultation with
the public did occur. The RMA
provides for public participation, but
much discretion and flexibility is left
with local authorities.

Yes. The identification of mitigation
measures is considered to be one of the
main purposes of the RMA.

Yes. A SEA report (s32 Report) has
recently been required (2002
amendments to RMA), with prescribed
contents.
Partially. Public reporting is part of the
comprehensive planning process, but
not specifically required for the SEA
component.
Yes. Section 35 of the RMA requires
local authorities to monitor their plans
and policies,. However, according to a
recent survey of local authorities
undertaken by MfE, over on-quarter of
local authorities were not complying
with these provisions.
New Ztdlaiid
Yes. Section 32 appraised is carried out
from the outset of the plan and informs
the content of the plan.

Partially. Sustainable resource
management issues guide the
evaluation process, however, the RMA
definition of environment is focused on
the biophysical elements.

No. The RMA and guidance does not
provide direction for the assessment of
cumulative impacts.

Yes. EA must contain discussion on
alternatives from outset. The ‘no
actitm’ alternative is not mentioned in
legislation nor guidance.

Coding Key: Yes = 2 points Partially = 1 point No = 0 points
< \l l l i i k MV
M-.\V Z1.\I.ANI)
S( OTI.AM)

n>i \i M i m i s
Procedural Effectiveness (out of 14)
Substantive Effectiveness (out of 8)
Overall Effectiveness for SEA Processes (out o f 22)

8 (57%)
3 (38*)
11 (50%)

12 (86%)
6 (75%)
18 (82%)

143

12 (86%)
5 (63%)
17 (77%)

I'll M '
31 of 42 (74%)
14 of 24 (58%)
46 of 66 (70%)

6.3.1

Procedural Effectiveness

Objectives-led Approach
Although an “objectives-led” approach is promoted in much of the academic literature
(Sheate et al. 2001a; Sadler 1996; Sadler and Verheem 1996), there are some researchers who
favour a “baseline-led” approach.

The objectives-led approach is associated with the

complete sustainability focus. A baseline-led approach is closely aligned with an EIA-based
approach, using more technical and scientific methods and focusing more on the
‘environmental’ component of sustainability. In this examination, the objectives-led approach
as supported by Sadler (1996) and Sadler and Verheem (1996) will be considered the most
effective approach in this examination. The objectives-led approach has always been strong
in SEA practice in the UK and Scotland. This was evident in the Perth and Kinross Council
case study through objective setting which guided plan development and evaluation.
In New Zealand, objective setting is a key component in plan-making.

Recently,

guidance has been issued by the MfE to assist local authorities in drafting objectives (MfE
2003a).

Following the identification of relevant resource issues, objectives are identified

associated with particular issues. Plan policies are appraised in terms of their ability to satisfy
these objectives. In California, the setting of objectives does not appear to be a strong
component of plan making or evaluation. Rather, the state follows a baseline-led approach.
The existing environment is first described, and then, the likely future state of each alternative
is evaluated against the initial baseline condition.

144

Scoping
The term “scoping” has slightly different interpretations among the case studies. In all three
cases, scoping is employed at the beginning of the SEA process. In Scotland, scoping is used
to identify gaps in the range of objectives, issues and policies that are identified and assessed
during the appraisal process.

This is generally achieved by first, compiling a list of

sustainability aims, issues and policies (usually through a literature review or review of other
sustainability appraisals and undertaken by the appraiser), and then, by using a checklist,
identifying which items are covered within the plan, which items are missing, and what
revisions are required in order for all sustainability issues to be included. This was undertaken
in Perth and Kinross by the appraiser. The recent draft SEA guidance prepared in the Scotland
suggests changes in the way that the UK has approached the scoping process. In order to meet
the more stringent requirements of the Directive, scoping will be undertaken at the onset of
the planning process and be more prescriptive. In New Zealand, scoping is used at the onset of
the assessment process by identifying sustainable resource management issues by the team
responsible for the preparation of the plan. Scoping is not required in either Scotland or New
Zealand; however, in California, CEQA requires that a scoping process be conducted as soon
as the plan preparation process begins. This is usually undertaken by the plan preparation
team, the EIR team, and the consultants involved.

CEQA and General Plan Guidance

suggests that public input be sought as part of the scoping stage.
Public Participation
In SEA, significant opportunities for public involvement should extend beyond the
provision of information after the process has been completed. Varying degrees of public
involvement occurred in all three cases reviewed. The weakest demonstration of public

145

involvement occurs in Scotland in the form of information provision only. Once the SEA had
been completed in Perth and Kinross, the report was then presented to the public through
public meetings and presentations. This is another element of SEA practice that is being
strengthened in the UK in order to meet the requirements of the EU Directive. In the draft
guidance for SEA in Scotland, it notes that planning authorities will need to take account of
public representations on the draft as well as the SEA, but offers no advice on how to
undertake this requirement.
California exhibits the strongest degree of public participation of the three cases
examined. CEQA requires that only two meetings be held for public comment, but more can
be convened by the local authority if desired.

In San Joaquin County, over 100 public

meetings were held throughout the San Joaquin County. Another requirement of CEQA is that
all public comments on the draft EIR must be addressed in writing by the EIR team. In New
Zealand, public involvement is considered to be a major component of the RMA, however,
this does not extend to s32 analysis. A plan is ‘notified’ (i.e., available for public viewing and
submission of public comments) only after the Council has completed its draft of the plan.
Submissions can then be made to the Council, and if the issues are not resolved to the
satisfaction of all parties concerned, a submission can be made to the Environmental Court
through a ‘reference’ (also known as an appeal). Section 32 analysis is undertaken by either
planning staff or independent consultants with little to no public input at this stage.
Discussions on what the definition of ‘public’ should include is virtually non-existent
in the literature. Rather than examine the different groups (or communities) of people that
comprise the ‘public’, SEA literature relies on the generic concept of the ‘general public’. In
jurisdictions that are home to visible minority groups, including indigenous peoples, very little

146

effort appears to be directed at ensuring that these communities have a real opportunity to
engage in the process. According to New Zealand law, local governments must consult with
the Maori groups in the affected area, however, it is not known how effective these
consultations have been. This is a subject that requires further investigation.
Mitigation Measures
Since very few projects are turned down in California, the main aim of CEQA is to
identify measures designed to mitigate potential or likely impacts has been required in
California since 1986. These measures enable the adoption of the EIR and General Plan even
when significant environmental impacts are likely to occur. In San Joaquin County, three
categories of mitigation measures were recommended in the final EIR: policies (inclusion of
new or revised policies in the Draft General Plan), regulations (inclusion of new or revised
regulations in the Draft Development Title), and land use (revisions to the General Plan map).
(San Joaquin County 1992b). The level of significance of the likely impacts’ are assigned a
“Degree of Impact” - less-than-significant impact or significant unavoidable impact assuming all the mitigation measures are implemented. Some of the mitigation measures were
able to be monitored at the time of adoption of the General Plan (e.g., incorporation of
recommended new or revised policies), while others needed to be monitored at a specific plan
stage.

Although the identification of mitigation measures is not legally required in New

Zealand, it is recommended in s32 guidance. Similarly, mitigation measures are not currently
required in Scotland; however, mitigation measures were recommended in the Perth and
Kinross sustainability appraisal.

147

Documentation
A separate SEA report was prepared in all 3 case studies, although its preparation is
only required in California and New Zealand. In California, the SEA report is referred to as an
Environmental Impact Report (EIR).

CEQA prescribes the contents of an EIR.

In New

Zealand, the preparation of a report - a Section 32 Report - has only been a requirement since
the amendments to the RMA in 2002. Waitakere Council prepared a Section 32 Report,
although it was not legally required at the time that plan preparations began. In Scotland, a
separate SEA report is not required but it has become an accepted practice. A separate report
was prepared in the Perth and Kinross case study. The recent interim planning advice provides
a list of required contents for the SEA.
Public Reporting
Public reporting on the SEA results, as well as the EIR process and the General Plan
process, is a legal requirement in California. In New Zealand, the s32 analysis is generally
available for public viewing, comment and appeal. The s32 anlaysis for the Birdwood Urban
Concept Plan (a recent addition to the Waitakere District Plan) is currently available on the
Council’s website. In Scotland, there is currently no requirement or guidance suggesting that
the SEA should be reported publicly. However, a majority of the completed SEAs are
available on the Internet (e.g., Aberdeenshire, Highlands).

The Perth and Kinross

sustainability appraisal was available to the public in hardcopy form from the Council office,
as well as on a compact disc. It was not available on the Council website, although a number
of other plans in the district are offered (e.g., the structure plan, the local plans, community
plan and LA21 plan).

148

Monitoring
In order to ensure that the identified mitigation measures are being applied, it is
necessary to establish a monitoring program.

In California, a monitoring plan has been

required since 1989, once the mitigation measures identified in the EIR have been accepted
and form a part of the General Plan.

Although there are no formal requirements for

monitoring in Scotland, indicators for Perth and Kinross have been developed to enable the
structure plan to be continually monitored. These indicators were developed through the
sustainability appraisal process, and were structured to reflect UK, Scottish and Perth and
Kinross priorities.
Section 35 of the RMA in New Zealand requires all local authorities to monitor the
efficiency and effectiveness of policies, rules or other methods of their plans. In practice,
there has been a reliance on public complaints to perform this task. Section 35 also requires
local authorities to prepare a five-year report of the results of their monitoring. The MfE
undertakes a biannual survey of local authorities to determine compliance with the RMA.
According to the most recent survey (2001/02), there is less than full compliance with the
monitoring requirements. With one hundred percent of local authorities participating in the
survey, it was reported that 75% of regional authorities stated that they were monitoring their
plans and policies, 61% of territorial authorities (including Waitakere), and 60% of unitary
authorities.

State of the Environment reports have been prepared by 100% of regional

authorities and 80% of unitary authorities, but only by 48% of territorial authorities. There is
considerable room for improvement in the enforcement of monitoring provisions in New
Zealand. Waitakere Council has identified thirteen sustainability performance measures to

149

track how it is achieving sustainable outcomes for the City, and reports on these in its Annual
Plan. However, these indicators are not linked to the District Plan.

6.3.2

Substantive Effectiveness

Proactive Assessment
Proactive assessment is evident in two of the three cases examined. In both California
and New Zealand, SEA is applied early on in the plan-making process. Proactive assessment
is not the norm for Scotland. In Perth and Kinross, SEA was undertaken once the draft plan
had been developed. By applying SEA late in the process, the evaluation of potential
environmental impacts of alternative options is not able to be completed. Only one option is
evaluated, with SEA serving primarily as an auditing function.

Proactive assessment is

required with the new interim planning advice.
Sustainability-led Process
One of the strengths of the Scottish SEA system is its sustainability-led process.
Sustainability objectives and criteria were selected that represented all three dimensions of
sustainability - environmental, social and economic - to guide the appraisal process in Perth
and Kinross.

The United Kingdom’s National Sustainable Development Strategy themes

were selected to guide the assessment of the plan’s policies.
In framing the RMA, the New Zealand Government stated that it was rejecting the
Brundtland approach to sustainability on the grounds that this “embraced a very wide scope of
matter including social inequities” and that it was “inappropriate for legislation of this kind to
include such goals” (MfE 1991, cited in Gleeson and Grundy 1997, 299). The mandate of the
RMA, therefore, avoided meeting head on the challenge of integrating environment and
development in regional and local planning (Gleeson and Grundy 1997). In the 2002

150

amendments to the RMA, the words “economic” and “social” were removed from the
definition of sustainable resource management, justified by the Ministry for the Environment
on the grounds that some councils were using the existing definition to justify the
development of district plans that seek to achieve social planning objectives (Morgan 1999).
Waitakere is an exception to this direction, initiating many sustainable development activities.

In California, CEQA defines ‘environment’ as “the physical conditions which exist
within the area which will be affected by a proposed project, including land, air, water,
minerals, flora, fauna, noise, objects of historic or aesthetic significance” (CRA 2003, Section
21050.5). However, in relation to General Plans, several social issues are also to be addressed;
these issues focus primarily on public health and safety. Economic issues considered in the
EIR are limited to those relating to fiscal costs and benefits (e.g., the building of infrastructure
and the provision of services). In San Joaquin County, detailed reports that assessed the
fiscal and financial analysis of the draft General Plan and the growth forecasts for the County
were prepared by consultants (San Joaquin County 1991 and 1992c).
Consideration o f Cumulative Impacts
SEA has been touted as an effective means to considering cumulative impacts (Sadler
and Verheem 1996; Partidario 1996). Under CEQA, the evaluation of ‘area-wide’ impacts are
to be included in the EIR. Although included in San Joaquin County’s EIR, the General Plan
can only directly affect unincorporated areas, and each of the incorporated city councils must
prepare their own local plans (referred to as “specific plans”), as well as their own EIRs. Both
the General Plan and the Specific Plans for the towns within the County must not conflict, and
consultation between the two levels of government needs to occur on a regular basis. In

151

Scotland, there are no provisions to assess cumulative impacts, and the available guidance is
silent on this issue. In the Perth and Kinross Council case study, the appraiser noted that
“where linkages and cumulative impacts o f policies and proposals could be
identified and appropriately assessed through the sustainability appraisal, this
was highlighted in the revisions, recommendations and conclusions o f the
sustainability appraisal”.
In New Zealand, the RMA and the accompanying guidance does not specifically
mention the consideration of cumulative impacts.
Consideration o f Alternative Options
In Scotland, the evaluation of alternative options is not a requirement. In the Perth and
Kinross case study, the identification and evaluation of alternatives was not undertaken in the
SEA. According to the plan evaluator, the sustainability appraisal itself did not evaluate
alternative options as “it became apparent at an early stage that there were no firm guidelines
on how to undertake such appraisals.” However, alternative options were identified and
evaluated at the onset of plan development by the planning team. Three alternative options
were considered: (i) concentration - focusing development substantially in Perth, its
immediate edges and key transport corridors; (ii) dispersal - spreading new development
widely across the area in other towns and villages while tightly constraining Perth; and (iii)
selective growth - of Perth and key towns (Perth and Kinross Council 2002; DTA 2003). Each
option was appraised against eight sustainability criteria*®. Option 3 emerged as the favoured
option. The manner in which the process occurred is a major weakness in the system. First, the
planning team undertook the appraisal of the alternative strategies, rather than an independent
appraiser. Second, one process occurred at the onset of plan development, and the other

*®The eight sustainability criteria are: existing development pattern; energy efficiency; efficient use of
infrastructure; access to employment; relationship to services and amenities; reducing travel; impact on the
landscape and impact on the cultural heritage (Perth and Kinross Structure Plan 2002).

152

process occurred at the end of the process. The two processes were not integrated.
Alternatives were not identified nor evaluated for the individual policies within the plan.
In San Joaquin County, three alternative options were assessed: (i) the city-centred
growth option, (ii) the new town growth option, and (iii) the no growth option.

CEQA

requires that a full range of alternatives must be evaluated (including the ‘no action’ option),
along with a clear justification of the choice provided, however there are no minimum
numbers of alternatives suggested.

In New Zealand, the RMA requires that section 32

analysis identify and evaluate possible alternatives for objectives, policies, rules and methods
at the onset of plan development, with the costs and benefits of each alternative option
evaluated. Guidance is provided for the evaluation of alternative options by the Ministry for
the Environment. The ‘no action’ option is not mentioned in the legislation or guidance. In
Waitakere, an average of three alternatives were identified and evaluated for each policy.
6.4

SEA Methods
In the following sections, the procedural and substantive effectiveness of the SEA

methods is discussed for each of the three case studies. Table 21 provides a summary.
6.4.1

Procedural Effectiveness

Scoping Methods
Scoping has been described as “the most crucial step in ensuring that the SEA is
feasible and useful” (Therivel 1996, 35). A number of methods have been identified in the
literature as current best practice in scoping: checklists, literature surveys, comparison with
other plans, overlay maps, public consultation and expert judgment (Therivel and Brown
1999; Therivel 1996; Sadler and Verheem 1996). The first three of these methods (checklists,
literature surveys, comparisons with other plans) were employed in the Perth and Kinross case

153

study. However, as described in section 6.1.3, scoping in Scotland is somewhat different than
in other jurisdictions. Scoping occurs after the issues have already been identified, rather than
being used to identify the key topics of concern.

A checklist was developed based on

literature surveys, reviews of other plans, and sustainable city resources. The structure plan is
then evaluated against the checklist to ensure that there are no gaps in coverage among the
plan’s policies.

So, although the methods used were suitable, the process was less than

optimal. In California, scoping is referred to as an ‘initial study’. A detailed checklist is
found in the CEQA Guidelines and lists 14 categories of potential effects. Other government
agencies are often consulted during the scoping process.
In New Zealand, scoping is undertaken in s32 analysis through identifying
environmental issues of concern for the area in question. There are no specific requirements
in the RMA as to the methods employed to determine these issues. Generally, these are
determined by the Council and planning staff, and although the Quality Planning Project
recommends consultation with the public in this stage, it does not usually occur (QPP 2003).

154

Table 21

Evaluation for procédural and substantive effectiveness of SEA methods
I'lWH’KDi'RA L KUKcTi vi ;m :ss

Criteria
1. Were suitable methods
used for scoping (e.g.,
checklists, literature reviews,
comparison with other
plans, overlay maps, public
consultation, and expert
judgment)?
2. Were scenarios used to
identify and evaluate
alternative options,
including the ‘worst-case’
scenario?

3. Was information on the
affected environmental
baseline conditions collected
and described (e.g.. State of
the Environment reporting,
environmental stock,
resource inventories)?

4. Were impacts evaluated as
to their signiflcance?

Scotland

California

New Zealand

Yes. Scoping methods in the
Perth and Kinross case study
included literature reviews,
comparison with other plans,
and checklists.

Yes. Scoping methods in the
San Joaquin County case
study included checklists,
literature reviews, public
consultation and expert
judgment.

Partially. Scoping methods in
the Waitakere case included:
checklists and expert
judgment.

No. Alternative options were
not evaluated in the Perth and
Kinross case study and is not
recommended in Scottish
guidance.

Yes. Scenarios for all
alternative options (including
the ‘no action’ option) were
used for evaluation. CEQA
requires that ‘worst-case’
scenarios are developed and
analyzed through ‘build-out’.
Yes. A baseline survey was
undertaken. However, a
criticism has been that
‘carrying capacity’ and maps
of ‘opportunities and
constraints’ were not
completed (Skewes-Cox
1996).

No. Scenarios are not
required by RMA nor
recommended in guidance.

No. The earlier environmental
appraisals were more tightly
defined and could go into
greater depth (i.e., to identify
‘environmental stock’). In
Perth and Kinross, strategies
and prior research was
gathered to provide insight
into the range of issues
affecting the area. An
‘indication’ of the
‘environmental stock’ was
provided.
Yes. Impacts are only
Partially. Impacts are only
evaluated in terms of moving
evaluated in terms of being
strongly or slightly toward or
‘less-than-significant’, or
away from sustainahle
‘significant-and-unavoidable’.
development, are neutral, or
These terms are not defined.
are unknown.
si'iisiA N r i\ i: El 11'cn vE M .ss

Partially. Baseline
environmental conditions of
the area are collected and
described as part of the larger
regional plan (Auckland
Region). Waitakere has also
completed a SOE report.

Yes. Impacts are evaluated in
terms of ‘high’, ‘medium’, or
‘low’ risk levels to the
environment, or can be scored
on a scale from 1 to 10.

Criteria
1. Do the methods provide
for an integration of multi­
disciplinary approaches (i.e.,
are both bio physical and
socio-economic approaches
and methods used)?
2. Are both qualitative and
quantitative methods used?

Scothiiid

Cnlil'orniu

New Zealand

No. Although environmental,
social and economic impacts
were all considered, there was
a weakness in bio-physical
approaches.

Partially. Both bio-physical
and socio-economic methods
were used, but could be
strengthened.

No. The case study only used
qualitative methods.

3. Was the information
presented in a non technical
summary that was easy for
decision-makers to
understand?

Yes. Tables were used (for
example. Table 14 in Chapter
Five) to present the
information as a textual
summary.

Yes. Both qualitative and
quantitative methods were
used. However, the use of
science was not embedded in
the process.
Partially. This is not a
requirement under CEQA,
however in the San Joaquin
case, an executive summary
was provided, along with a
much larger volume of
information..

No. Generally, assessments
are subjective and non­
technical. Cost benefit
analysis is used as well. There
was a weakness in bio­
physical approaches.
Yes. Both qualitative and
quantitative methods are
generally used (subjective
assessments, cost benefit
analysis)
Yes. A non technical
smnmary was provided, even
though this was not a legal
requirement at the time of the
process.

Coding Key: Yes = 2 points Partially = 1 point No = 0 points
l Oi \l S( OKI S
Procedural Effectiveness (out of 8)
Substantive Effectiveness (out of 6)
Overall Effectiveness for SEA
methods (out of 14)

s( Oi l \M)

< \l II OKM \

M M / I \l \M)

IOI’\I.S

4(50%)
2 (33%)

7 (88%)
4(67%)

4 (50%)
4 (67%)

15 of 24 (63%)
10 of 18 (56%)

6 (43%)

11(79%)

8 (57%)

25 of 42 (60%)

155

Scenarios to Evaluate Alternative Options
Although CEQA does not require the use of any particular assumptions, the evaluation
of impacts in most plan-level EIRs begins with a projection or forecast of plan “build-out”
(Bass and Herson 1999). This concept refers to the ‘worst-case’ analysis of population growth.
Steps typically include: (1) estimating and quantifying the increase in population and
employment, the number and square footage of housing units required, the location of
facilities, the production of materials, and the movement of goods and people; (2) determining
and quantifying the effects on resources and the anticipated pollution levels likely to occur;
and (3) a range of alternative scenarios are then developed (Bass and Herson 1999). The
evaluation of impacts of each alternative is usually compared in a matrix format. In San
Joaquin County, a growth forecast analysis was prepared by consultants for the County.
Scenario analysis is not generally undertaken in Scotland to identify or evaluate
alternative options. In New Zealand, the impacts of each alternative option on the environment
and the potential of each option to achieve sustainable resource management is evaluated on a
matrix (the “decision-making matrix”), based on planning staff’s professional opinions.
Information on Baseline Environment Conditions
Collection of good baseline data is one of the major challenges of SEA (Glasson
1995). In the UK’s guidance for environmental appraisal of development plans published in
1993 (DoE 1993), a baseline-led approach (establishing the area’s ‘environmental stock’ as
the basis for appraisal) was promoted.

More recently, the wider scope of sustainability

appraisals has shifted the focus to an objectives-led approach (using a series of objectives for
sustainable development). Sustainability appraisals are much wider in scope, whereas their

156

environmental appraisal predecessors were more tightly defined and would therefore go into
greater depth (i.e., identify ‘environmental stock’).
Significance o f Impacts
All three case studies attempt to illustrate the level of the significance of the
environmental impacts. In Scotland, the significance of potential environmental impacts is
communicated through the use of ordinal scales, illustrating the move toward or away from
sustainable development (e.g., significant move towards sustainable development, move
towards sustainable development, neutral effect, move away from sustainable development,
significant move away from sustainable development, unknown).
California General Plan Guidelines suggest an evaluation based on five levels of
environmental impact (very bad, bad, neutral, good, very good), with an opportunity to offer
explanation. San Joaquin County’s EIR assigned a ‘Degree of Impact’ to demonstrate the
level of significance of the likely impacts - ‘less-than-significant’, or ‘significant unavoidable
impact’. In New Zealand, s32 guidance suggests that in order to determine the effectiveness
of alternative methods to achieve a plan’s policy, the level of risk to the environment must be
determined. This can be ranked (e.g., ‘high’, ‘medium’, or ‘low’), or scored (e.g., 1 to 10).
6.4.2

Substantive Effectiveness
Integration o f Multi-disciplinary Approaches
There was no evidence of multi-disciplinary methods being used in any of the three

cases examined. In Scotland and New Zealand, an individual’s subjective interpretation is the
primary approach used in evaluation. This involves decision making that is based on the
values held by the appraiser. Although subjective interpretation has much value as a method,
it would be more credible if the appraisal was undertaken through a team approach, with

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representatives from the local authority, non-governmental organizations, and the public. In
California, there is some evidence of multi-disciplinary approaches. Databases of biophysical
and socio-economic information are used to assist in the evaluation of the plan.
Qualitative and Quantitative Methods
Qualitative methods were dominant over quantitative methods in all three cases. In
both Scotland and New Zealand, qualitative methods are the usual methods implemented in
evaluation. In California, CEQA specifically requires the use of qualitative methods, although
the types of methods are not indicated:
Section 21001. The Legislature further finds and declares that it is the policy o f
the state to: (g) Require government agencies at all levels to consider
qualitative factors as well as economic and technical factors and long-term
benefits and costs, in addition to short-term benefits and costs and to consider
alternatives to proposed actions affecting the environment”. (CRA 2003a)
Non-Technical Summary o f Environmental Information
In all three case studies, a non-technical summary of environmental information was
provided to decision-makers as well as to the public. A common complaint under CEQA is
the voluminous and technical information that is provided to decision-makers. This was not
the case in the San Joaquin County case study. An executive summary was provided as a non­
technical summary that was easy to understand. More detailed information could be found in
the larger EIR.
6.5

Summary of Effectiveness
The overall effectiveness of the three cases combined is 61 per cent, considered only

as “adequate” according to the evaluation classes. For overall effectiveness, California scores
the highest at 73 per cent. New Zealand is next with 64 per cent, followed by Scotland at 45
per cent. Procedural effectiveness is stronger than substantive effectiveness in most cases.

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This is most likely because it is easier to identify whether procedural steps or stages have
actually occurred than to accurately determine whether the outcomes are a direct result of the
SEA.
Table 22 provides a summary of procedural, substantive and overall effectiveness
achieved at each level of the framework by each of the three cases examined. This will be
discussed further in the following sections.
Table 22

Summary of effectiveness

SCOTLAND

POLICY

Procedural
Substantive
Overall

INSTITUTIONAL

Procedural
Substantive
Overall

4/14 (29%)
0/2 (0 %)
4/16 (25%)

Substantive
Overall

NEW
ZEALAND

TOTAL

2/8 (25%)
1/6 (17%)
3/14(21%)
I4/14(1ÜÜ

2/6 (33%)
7/14 (S()%'
14(57%,

6/18 (33%)

16/16ll00'<)

9/16(56%!

OVERALL

Key:

6.5.1

26/42(1
4 <1 II'~ 30/48 (6:

3/8(38%.

8/14 (57%1
29/44 (66%)
. 13/22 (59%)

16/66 (70
15/24 (63% )
10/18(56%)
25/42(60%)
86/132 (()5%)
34/66(52%)

42/66 (64%)

120/198 (61%) (

4/8 (50%)
SEA METHODS

19/42/45%'!

I

12 14( 8 6 % I

Procedural

SEA PROCESSES

CALIFORNIA

Substantive
Overall
Procedural
Substantive

2/6(33%')
6/14(43% )
22/44 (50';( )
8/22(36%)

Overall

30/66 (45% )

4/6 i67%j

13/22 (59%)

Meets 90 to 100% of criteria

“excellent”

Meets 75 to 89% of criteria

“good”

Meets 50 to 74% of criteria

“adequate”

Meets less than 50% of criteria

“poor”

Effectiveness by Case Study

It is not surprising that California has the most effective SEA system of the three cases
examined, given its three decades of experience. The strengths of California are found in its

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#

1

institutional arrangements, SEA processes and SEA methods. Weaknesses focus on the policy
context, particularly the lack of commitment for sustainability at higher levels.
In New Zealand, the overwhelming responsibilities for environmental planning and
management have been downloaded to local governments without the appropriate financial
resources, training and expertise. As a result, practice varies from one area to another.
Waitakere District illustrates a good example of effective SEA processes, outperforming
California in many of the individual criteria. Weaknesses include the policy context,
particularly the lack of leadership at the national level for sustainable development and the
absence of National Policy Statements. Institutional arrangements are also ineffective,
particularly with respect to enforcement and monitoring.
Currently, Scotland has the most ineffective SEA system. The strengths of Scotland are
found in its policy context, particularly the commitment and support of the Scottish Executive
for sustainable development. Although Scotland is currently weak in meeting SEA process
criteria, the system has a strong sustainability-led approach and uses sustainability objectives
as criteria for evaluation. Weaknesses are found in institutional arrangements and SEA
processes, particularly poor opportunities for public participation, the lack of a tiering
framework, and no evaluation of alternative options. Additionally, appraisal operates as an
‘add on’, occurring after the plan has already been developed rather than operating parallel to
the process.
These weaknesses in the UK system have continued to be evident even as practice has
evolved over the past decade. When practice fails to improve sufficiently then the system
itself needs to be strengthened, as has happened in California over the years. If the Perth and
Kinross case study was evaluated again, using the recent advice prepared in advance of the

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EU Directive, Scotland would surpass California, scoring 86 per cent. This suggests that
regulatory provisions can serve to strengthen the SEA system. The biggest area of
improvement is found in SEA processes, but there is very little change with respect to SEA
methods.

Effectiveness by Levels of the Framework
The results of the analysis for each level of the framework is presented in the order of
the most effective level to the least effective level.
Effectiveness o f SEA Processes
SEA processes are the most effective level of the framework, scoring 70 per cent
overall. California scored 82 per cent. New Zealand scored 77 per cent, and Scotland scored
50 per cent. Strengths of all three processes include the identification of mitigation measures,
the preparation of a SEA report, and public reporting. There is a need in all three cases to
strengthen the consideration of cumulative impacts.
Effectiveness o f Institutional Arrangements
Institutional arrangements scored 63 per cent overall. California displays very effective
institutional arrangements, scoring 100 per cent, both procedurally and substantively. In all
three cases, procedural guidance is available. Independent oversight, interagency review and
the tiering framework all could be strengthened.
Effectiveness o f SEA Methods
SEA methods scored 60 per cent overall. California has relatively effective methods at
79 per cent, with New Zealand (57 per cent) and Scotland (43 per cent) following. All three
cases lack the integration of science into the evaluation and display a weak use of quantitative
methods. Although qualitative methods are a very important component of evaluation.

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quantitative methods are needed to measure the change from the initial baseline environmental
condition, as well as to predict impacts to the environment over time.
Effectiveness o f Policy Context
Effectiveness of the policy context is the weakest level of the framework at 45 per
cent. Scotland has the most effective policy context at 64 per cent, California has the weakest
at 21 per cent, and New Zealand scores 50 per cent. Strengths include a strong commitment to
sustainability in the local case studies in Perth and Kinross (Scotland) and Waitakere District
(New Zealand). Major weaknesses in all three cases in the failure of SEA findings to serve as
a central determinant in decision-making. Although SEA is either legally required or
encouraged, there is no similar requirement on the part of decision-makers to follow
recommendations. Some recommendations were incorporated in all three cases, but these were
limited to minor changes.
Chapter Seven provides the major conclusions reached in this thesis, as well as two
sets of recommendations. The first set of recommendations is intended for SEA systems in
general, while the second set is directed toward the three individual case studies. Chapter
Seven concludes with a discussion of further research and concluding remarks.

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Chapter Seven
Conclusions and Recommendations
7.0

Introduction
This study has shown that the strategic environmental assessment processes of the

comprehensive plans in Perth and Kinross (Scotland), San Joaquin County (California, US),
and Waitakere District (New Zealand) were only adequately effective. Differences in
effectiveness among the three cases as well as among the levels of the evaluation framework,
indicate two things. First, while there is scope for improving current practice, there is no need
to reinvent the wheel. The knowledge for conducting SEA successfully is there and waiting to
be applied. Second, as experience grows, and as regulations, guidance and training are
strengthened, SEA practice is improving.

There appears to be resistance among decision-makers to either implement SEA
processes in the absence of legal obligations, and to abide by the recommendations that
emerge from the SEA. Advocates of SEA must recognize that many decisions are really made
incrementally, and that decisions are often made with imperfect information despite the effort
and resources spent to collect data and information (Clark 2000,16). Although SEA is not
without problems (for example, the establishment of good baseline data, approaches to the
assessment of environmental capacity, and the tensions involved in the trade-offs between
socio-economic and physical environmental goals (Glasson 1995, 729), the process does offer
the potential to integrate environmental and sustainability factors into the mainstream of
policy-making and planning. Assessment of environmental impacts at higher tiers of
decision-making addresses the cause of environmental problems at their policy source, rather
than just treating the symptoms of the impacts.

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Following is a detailed description of the major conclusions reached as a result of this
research. Two sets of recommendations are then offered. The first set is advanced to overcome
the common shortcomings identified in Chapter Six in an effort to improve the overall
understanding of the practice of SEA in relation to comprehensive plans. The second set is
directed towards improving SEA practice in each of the case studies.

Chapter Seven

concludes with a discussion on suggested further research and closing remarks.
7.1

Conclusions
Table 23 summarizes ten major conclusions which have become evident through the

examination of the three case studies. These conclusions do not stand alone, but are related to
one another.
Table 23 Summary of conclusions
1. SEA theory does not accurately reflect SEA practice.
2. The role of public participation and consultation is not understood in SEA processes,
particularly in relation to the inclusion of different ‘publics’.
3. SEA recommendations are often disregarded in decision-making.
4. SEA has the potential to incorporate sustainability considerations and add value to the
planning process.
5. Practitioners of SEA find themselves searching for arguments that can justify the added
value of SEA, particularly where SEA is not a legal obligation.
6. There is a tendency to oversell SEA as an analysis that can predict sustainability.
7. The ongoing conflicts between environmental, social and economic goals limit SEA’s
ability to be effective.
8. There is a downshifting of environmental planning and management responsibilities from
central government to local authorities.
9. Compliance with regulatory provisions for SEA is not always evident.
10. There is a reliance on qualitative methods, particularly subjective interpretation, for impact
identification, evaluation, mitigation, and monitoring._______________________________

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1. SEA practice does not accurately reflect SEA theory. This study has found that the
practice of SEA of comprehensive plans operates in a fairly ‘ad hoc’ fashion, and tends to be
quite flexible. Effectiveness in this study was evaluated against a set of criteria that was
selected from the academic literature. These criteria were identified as ‘guiding principles’ of
SEA, as ‘benefits and aims’ of SEA, as cited by many known researchers in the field (e.g.,
Partidario 2000; Fischer 1999; Marsden 1998; Partidario 1996; Sadler 1996; Sadler and
Verheem 1996). The fact that adherence to these criteria was relatively weak among the case
studies indicate that SEA practice is not accurately reflecting current SEA theory. The
converse may also be true: that SEA theory does not accurately reflect SEA practice.
Comparative evaluation of case studies of SEA application to comprehensive plans is limited,
and not recent (e.g., Curran et al. 1998; Asplund and Hilding-Rydevik 1996; Rumble and
Therivel 1996; Shepherd and Ortolano 1996; Skewes-Cox 1996). SEA theory would benefit
from research that poses stronger questions on the justification of SEA, as well as more
comparative case study evaluation. SEA practice would benefit from a stronger case for the
need for its application. This would involve ‘champions’ among practitioners that would
demonstrate its utility.
2.

The role of public participation and consultation is not understood in SEA

processes, particularly in relation to the inclusion of different ‘publics’. There has been
limited research into the practice and theory of public participation in SEA processes at either
the policy or plan level. Examinations into the role of the public in EIA processes are found
in the literature (for example. Baker and McLelland 2003; Sadler and Boothroyd 1993;
Nicholson 1990), however, strategic analyses are much more complex and therefore require

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further investigation. Further, the inclusion of different ‘publics’ in SEA participation is not
discussed in the academic literature, nor is it evident in practice.
3.

SEA recommendations are often disregarded in decision-making. The immediate aim

of SEA is to facilitate sound, integrated decision-making in which environmental
considerations are explicitly included. SEA does so by providing clear information on the
environmental effects, risks and consequences of options in planning. It appears that this
purpose is achieved in the cases to some degree. SEA is also directed toward achieving or
supporting ultimate goals of environmental protection and sustainable development. This aim
is not often followed in SEA, as found in this thesis. There are several reasons why SEA
recommendations are often disregarded in decision-making. First, decision-makers do not take
unnecessary risks, but will take risks that they can manage. Practitioners know that EA can be
a tool that turns rhetoric about sustainable development into action; many decision-makers do
not yet believe that. The entire sustainable development movement has brought EIA
practitioners an opportunity to help top level decision makers use the EIA tool to successfully
set a sustainable course (Clark 2000, 26). Second, the lack of certainty is often cited as a
reason why SEA is progressing slowly at higher levels. There always will be some people
adverse to risk unwilling to make decisions or allow decisions to be made without virtual
certainty. Third, many decision makers currently prefer to ignore the existence of SEA rather
than risk sacrificing the incremental nature of their decision-making processes to the
technocratic and rationalist commitments imposed by EA procedures used currently (Clark
2000; Partidario 2000). Finally, there is a lack of incentive and insufficient environmental
interest to effectively use SEA. Economic interests are much stronger (in terms of power and
influence) than environmental ones. The SEA debate needs to be refocused back to the reason

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why SEA was initiated in the first place. The recognition and clear identification of the added
value of SEA to decision-making and to planning must be at the forefront of the debate.
4.

SEA has the potential to incorporate sustainahility considerations, thereby adding

value to the planning process. Despite SEA’s shortcomings, SEA offers the possibility of a
higher tier of assessment of environmental impacts appropriate for comprehensive plans.
Sadler (1996) claims that SEA can add value to the planning process by:
•

Incorporating sustainability considerations by addressing the cause of environmental
problems at their policy source, rather than just treating the symptoms or impacts;

•

Serves as an early warning mechanism to identify cumulative effects recognizing these
are best dealt with regionally rather than on a project-by-project basis; and

•

Focus and streamline project EIAs making them more consequential by ensuring prior
questions of need, justification and alternatives are subject to environmental scrutiny at
the appropriate policy, plan and/or programme level

5.

Practitioners of SEA find themselves searching for arguments that can justify the

added value of SEA, particularly where SEA is not a legal obligation. Although SEA has
the potential to add value, practitioners find themselves in the position of justifying the time
and costs of undertaking SEA, in addition to the political risks involved in the trade-offs
between socio-economic and physical environmental goals.

The recognition and clear

identification of the added value of SEA to decision-making must be at the forefront of the
debate. In order for SEA to be effective, it needs to be built into policy and planning decision­
making mechanisms and accepted by policy makers, planners, bureaucratic officers, and all
potential users that “prefer to ignore the existence of SEA rather than risk sacrificing the
incremental nature of their decision-making processes to the technocratic and rationalistic

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commitments imposed by environmental assessment procedures...” (Clark 2000, as cited in
Partidario 2000, 657)
6. There is a tendency to ‘oversell’ SEA as an analysis that can predict sustainability.
Sadler (1998) and Kirkpatrick and Lee (1999) have noted that the academic literature is fairly
promotional with respect to SEA, and should be treated with caution. Indeed, a researcher
would have a difficult task to uncover many academic references that provide substantial
criticism of SEA as a process.

As noted previously, SEA theory needs to provide more

rigorous evaluative research to justify its application. Research aimed at advancing SEA
methods and processes need to incorporate more examples of current, practical case studies.
7.

The ongoing conflicts between environmental, social and economic goals limit SEA’s

ability to be effective. Sustainable development entails the integration of environmental,
social and economic objectives where possible, and making hard choices and negotiating
trade-offs between objectives where integration is not possible (Dalal-Clayton 2002). These
negotiations are influenced by factors such as international and national security, prevailing
economic interests, political systems, institutional arrangements and cultural norms. The
conflicts are often real, but vary according to circumstance. At the local level, resolution of
conflicts should be achieved through an adaptive process of integration, but more usually it
will require trade-offs to be made among the different interest groups concerned. There is a
need to build capacity for participatory planning for sustainable development between
stakeholders, including government agencies, industry, indigenous people, minority groups,
and community organizations. Local strategies for sustainable development are a tool to assist
communities to overcome problems and start to strengthen capacity for sustainable
development.

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8. There is a downshifting of environmental planning and management responsibilities
from central governments to local authorities. This is becoming increasingly more evident
in all three cases examined. This trend, however, needs to be accompanied with both financial
and technical support. SEA expertise is limited at the local level, and combined with a lack of
financial support and technical expertise, SEA is approached through ad-hoc methods. This
has resulted in an uneven application of SEA of comprehensive planning among communities,
particularly evident to a strong degree in New Zealand, and to a lesser extent in Scotland.
9. Compliance with regulatory provisions for SEA is not always evident. Although some
countries have strong regulatory frameworks in place for SEA and planning, there appears to
be a lack of enforcement to ensure that local governments are complying with the provisions.
This corresponds closely to the need for political support and commitment at both national
and local levels to ensure that SEA provisions are followed. Additionally at the local level,
this may be the result of a lack of financial and human resources that are necessary to carry
out effective monitoring and enforcement.
10. There is a reliance on qualitative methods, particularly subjective interpretation, for
impact identiHcation, evaluation, mitigation and monitoring. Qualitative methods such as
subjective interpretation are often used in SEA as they are fairly quick, easy to use and
inexpensive. Although qualitative methods are a very valid and important component of SEA,
quantitative methods have an extremely significant role to play. In order to provide more
certainty and acceptance by decision-makers for SEA, advancements in quantitative methods
are needed. The establishment of good baseline data, approaches to the assessment of
environmental capacity, and approaches to the assessment of cumulative effects all require the
use of quantitative methods. Researchers have indicated that sustainability appraisal forms of

169

SEA are more qualitative, and are considered to generally be less effective, as they are done
with little or no baseline information and may be considered as poorly informed. Sheate et al.
(2001) notes that the subjectively of appraisal does not need to be a problem, if the process
itself is transparent and subjected to sufficient public and expert scrutiny. Unfortunately, this
appears to be lacking in current appraisal forms of SEA, including the Perth and Kinross case
study examined in this thesis.
7.2

Suggestions for Improving SEA of Comprehensive Plans
This thesis has identified a number of shortcomings in the three case studies. These

weaknesses are outlined in Table 24. Based on these findings, suggestions are offered to
improve current SEA practice, and hopefully, to further advance the effectiveness of SEA of
comprehensive plans. Recommendations follow for each of the four levels of the framework
evaluated - policy, institutional, SEA processes, and SEA methods.

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Table 24

Summary of suggestions for improving SEA practice

POLIC’i
• A sustainability framework is needed to guide the formulation of plans.
• Refocus the SEA debate back to the question as to why SEA is applied in the first place; SEA as a
central determinant of decision-making.
• To incorporate sustainability considerations and add value, SEA needs to be fully integrated with
_____________ __
planning processes___________ _
i N s n n rioN.vi.
• Strengthen tiering framework
• Encourage interagency review.
• Implement independent oversight and quality control.
• Implement visible linkages to decision making.
• Legal provisions need to be enforced (e.g., monitoring).
SEA PROCESSES
• Strengthen opportunities for public participation; devise strategies for the inclusion of different
‘publics’, particularly indigenous peoples
• Strengthen and expand scoping, particularly to include public participation.
• Strengthen impact monitoring and enforcement.
• Training and guidance needs to be accompanied with financial resources.__________________
SEA .METHODS
• Implement an integrated and multi-disciplinary approach and use both qualitative and
quantitative methods.
• Use scenarios to evaluate alternative options (including no action option).__________
OVERALL
• Decision-making needs to be transparent and accountable, as well as linked to SEA.
• Stages of SEA should be prescriptive, however, the approaches and methods can be more flexible.

7.2.1
•

Policy Context

To guide the formulation of plans, a sustainability framevrork is needed. In both the

California and New Zealand case studies, stronger political will and support for sustainable
development initiatives needs to be established that can provide a systematic policy
framework to integrate sustainability considerations into plan decisions at lower levels of
planning. This requirement has been established in the Scotland case study. A sustainability
framework can both guide the formulation of plans, as well as provide a measure against
which existing plans can be assessed. The preferred option then is the one which is most
compatible with the sustainability parameters. Rather than developing a separate set of criteria
and indicators, developed in isolation of other processes, existing ones should be built upon.

171

particularly those with a local flavour, such as local quality of life indicators and local
environmental and socio-economic indicators.

To ensure compatibility with higher tiers,

national sustainable development strategies and indicators should also be integrated. If none
exist, then the Bellagio Principles (accepted as international standards) can be used and
adapted.
•

Refocus the SEA debate back to the question as to why SEA is applied in the first

place. The main rationale for applying SEA is to help create a better environment through
informed and sustainable decision-making. SEA helps to ensure that many of the
environmental issues of global importance are considered in plans, policies and programs at
different administrative levels (i.e., national, regional, local). These include, for example,
climate change, acidification and energy use. An important reason for applying SEA is the
expectation that if social, economic and environmental effects are properly considered on top
of the decision making hierarchy in a publicly accountable fashion, there should be less
friction and fewer problems at decision-making levels further down the decision making
hierarchy. However, in order to live up to this expectation, a clearly defined decision making
hierarchy needs to be in place.

•

To incorporate sustainability considerations and add value, SEA needs to be fully

integrated with planning processes. To add value to the planning process, SEA needs to be
integrated with comprehensive planning, rather than operating simply as an ‘add-on’ or
serving only as an auditing function. What SEA brings to planning is early consideration of
the environment, incorporation of economic development and the material needs of human
communities, early consultation with the public, and a consideration of alternatives before
there is an irreversible commitment of resources (Clark 2000, 17).

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7.2.2
•

Institutional Arrangements

Strengthen tiering framework. The opportunity to ‘tier’ environmental assessment is

one of the primary benefits of SEA. This is particular effective at the regional level where
regional assessment can ‘pre-dear’ development projects or plans.

The hierarchical

framework for planning is most evident with the RMA in New Zealand, where regional
strategies and plans provide the context for district and city plans, which in turn set the
direction for development projects. Unfortunately, this does not occur in reality. Tiering can
potentially avoid duplication of effort and money, while at the same time, provide an
integrated and coordinated planning and assessment system.
•

Encourage interagency review. Review of SEA by other governmental agencies is most

often undertaken in an unstructured and informal basis.

However, a more structured

framework for referrals to other agencies would be beneficial to SEA.

Often, different

agencies have knowledge and expertise of environmental and sustainability information which
can greatly assist the SEA process.
•

Implement visible linkages to decision-making. One of the most effective ways to

ensure SEA is undertaken in an appropriate manner is to link decision-making to its
implementation. In order for a plan to receive approval, a completed SEA must accompany it.
However, for this to be an effective option, there needs to be the provision of financial
resources, as well as training and guidance.
•

Implement independent oversight and quality control. Many of the SEA systems that

were investigated during the course of this research appeared to be undertaken internally and
were not subject to independent oversight or quality control measures.

173

Although some

systems were more effective than others, all systems would benefit from more structured
oversight and quality control.

This could be achieved in two ways.

First, a strong,

administrative body at a higher level of decision-making would be able to undertake this task.
In this way, decision-making (i.e., approval of the comprehensive plan) would be linked to a
satisfactory SEA (i.e., successful completion of SEA according to a checklist of quality
control measures). Plans that have not undergone successful SEA processes would not be
approved. Secondly, a consultative group comprising representatives from community
organizations, government, and private citizens could be formed that could not only provide
input during the plan and evaluation processes, but could also serve to ensure oversight and
quality control.
•

Legal provisions need to be enforced. In some cases where regulatory arrangements for

SEA are in place, compliance and enforcement are often weak. For example, although the
RMA in New Zealand provides for some strong regulatory provisions for SEA, this is not
often reflected in practice, as evidenced by many appeals by citizens and interest groups to the
Environment Court.

7.2.3
•

SEA Processes

Public participation needs to be strengthened. Interest groups and organizations

should be involved in the assessment itself from the start, for example, in working groups
together with the planners and holding more than one public hearing. Public participation
should at a minimum take place in both scoping procedures (for the comprehensive plan and
for the environmental assessment) and in the assessment of the environmental impacts, in an
attempt to bring in the public’s priorities and values to enhance both the environmental
assessment as well and the planning process. Broad participation in SEA is crucial not only

174

for the effectiveness and legitimacy of the process itself, but also because this participation
can provide important local knowledge. The future of SEA (as with many other environmental
management processes) is in the development and implementation of consensus-building and
conflict resolution techniques. Economic inequality, social instability and environmental
degradation are common features of an unsustainable society. Of particular concern are
minority groups and indigenous people who bear the brunt of these problems because their
livelihoods are balanced on volatile economic opportunities and environments vulnerable to
change. They lack the opportunities for meaningful participation in the decisions that affect
their lives (Dalal-Clayton 2002).
•

Scoping needs to be strengthened and expanded. Scoping serves to ensure that the

appropriate range of environmental and sustainability issues have been considered right from
the beginning of the process, and as such, is strongly linked to the importance of applying
SEA as early as possible. Scoping needs to be strengthened in the UK.

As guidance in

California suggests, scoping should extend beyond the realm of the planning team and the
SEA team, to include both expert opinion as well as public opinion. A stronger scoping
process at the beginning of the SEA process can ensure a more focused SEA.
•

Strengthen impact monitoring and enforcement. Monitoring has been used

sporadically, on an ad-hoc basis and unsatisfactory in both EIA and SEA. Although legally
required in many jurisdictions, enforcement does not often occur. To ensure quality control of
recommendations as well as to promote sustainable outcomes, monitoring needs to be a key
component. To carry this out effectively, indicators need to be developed. More money and
time needs to be allocated for this important stage.

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•

Training and guidance needs to be accompanied with financial resources need to

accompany expanding responsibilities of local governments to undertake environmental
planning.

Guidance was available in all three cases examined. There is no shortage of

guidance in California; both CEQA and the Governor’s Office of Planning and Research
provide guidelines for preparing EIRs of General Plans. As noted throughout this study, an
entire industry exists in the state specifically for the purpose of conducting SEA of
comprehensive plans. Developers expecting to benefit from proposed development projects
enabled by the comprehensive plan contribute some of the cost toward the preparation of the
EIR. In New Zealand, however, the lack of resources and expertise has often been cited as a
reason for the failure of environmental planning initiatives at the local government level
(Dixon 2002).

7.2.4
•

SEA Methods

Implement an integrated and multi-disciplinary approach, and use both qualitative

and quantitative methods. Reliance on a single type of method or approach does not provide
a true measure of integrated, sustainable management. While qualitative approaches to
evaluation are extremely useful and valid sources of information, it is important to not rely
solely on subjective interpretation. The establishment of baseline conditions, from both a
qualitative and quantitative perspective is key as a basis for evaluating monitoring.
•

Use scenarios to evaluate alternative options. Forecasts have traditionally been used to

project patterns from the past into the future.

However, the use of scenarios has been

promoted as a way to outline alternative options.

This allows local authorities to think

strategically about “the likely environment, social and economic consequences of current and
possible future trends and the consequences of making particular policy choices.” (Sadler

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1998, 37). Different scenarios are developed for a number of time periods; less than five
years, five to ten years, ten to twenty-years, and so on. Recent advances in computer
simulation modeling can aid in this process.

7.2.5
•

Overall

Decision-making needs to be transparent and accountable, as well as linked to SEA.

A statement of the decision, indicating how SEA requirements were taken into account should
be made available to the public. A precondition for the success of EIA-based SEA appears to
be a capability to structure decision processes and to force decision makers to take
environmental issues into account in a publicly accountable fashion (Fischer 2003). The
submission and subsequent approval of the SEA, at the same time as the plan itself, creates a
visible linkage of the SEA to decision-making. This could be particularly effective if approval
of the SEA (in terms of processes followed and outcomes achieved) was undertaken through
independent oversight
•

Stages of SEA should be prescriptive, however, the approaches and methods can he

more flexible. The current tendency in the SEA debate to ask for more flexibility and
adaptability must be treated with caution. This is potentially at odds with some of the main
reasons for conducting SEA in the first place, and raises the question whether decision makers
are simply being provided with an excuse for not changing anything in existing practice
(Fischer 2003). The stages to undertake during a SEA needs to be prescriptive (for example,
scoping, identification of alternatives, evaluation of environmental impacts, identification of
mitigation measures, selection of monitoring program), with minimum requirements set. The
choice of approaches or methods can be left to the discretion of the local conununity.

177

7.3

Suggestions for Improving SEA of Comprehensive Plans in the Case Studies
Table 25 lists the major shortcomings of each of the three case studies that need to be

improved.
Table 25 Summary of improvements for the case studies

POLICY

INMI Il ' I IONM

SI.M-UOCI SSI s

s i \M i l i i o n s

SCOTLAND'’

CALII’OKNIA

NEW ZEALAND

• SLA central determinant in
decision making
• SI A integrated into planning
pii'cess
• .SL.A related to existing
sustainability instmments
(LA21 plans, community
plans)

• Political will and support
for sustainable development
• Systematic policy
framework to consider
sustainability principles
• SEA related to
sustainability instruments
• SEA central determinant in
decision making
• Sustainable development
promoted in decisions

• Political will and support for
sustainable development
• Systematic policy framework
to consider sustainability
principles
• SEA related to sustainability
instruments
• SEA central determinant in
decision making
• Sustainable development
promoted in decisions
• EIA/SEA central to decision
making, according to RMA!
• Independent oversight
• Interagency review
• Enforce legal provisions
• Administrative body to
oversee SEA
• Training and funding need to
accompany the downloading
of environmental
responsibilities to local
authorities
• Strengthen scoping
• Strengthen public
participation, particularly
with respect to Maori peoples
• Strengthen (i.e., enforce)
monitoring provisions
• Cumulative impacts
• Evaluate ‘no action’
alternative option
• Scenarios to evaluate
alternative options
• Collect environmental
baseline conditions
• Integration of multi­
disciplinary approaches
• Use both qualitative and
quantitative methods

• Independent oversight
• Interagency review
• Leual provisions for SEA
• .Administrative body to
oseisee SEA
• ’iieiing

• Siiengthen public
paiticipation
• Stiengtben scoping
• SE A to be a proactive
assessment
• Cumulative impacts
• i,\aluate alternative options

• Need to include different
‘publics’ in process
• Objectives-led approach
• Sustainability-led process
• Cumulative impacts

• Si. eiiarios to evaluate
alternative options
• Collect environmental
baseline conditions
• Integration of multi­
disciplinary approaches
• Use both qualitative and
qii.ii ititative methods

• Integration of multi­
disciplinary approaches
• Use both qualitative and
quantitative methods
• Present information in a
non-technical summary that
is easy for decision makers
to understand

Many of the shortcomings of the Scotland SEA system have been addressed with the recent Interim Planning
Advice (DTA 2003), in response to the impending EU SEA Directive.

178

7.4

Opportunities for Future Research
Throughout this research, it became obvious that there were so many opportunities for

future research. These opportunities can be explored on both a global level, as well as from a
Canadian perspective. On a global level, further study needs to be conducted in the following
three areas: (i) the implementation of the EU SEA Directive; (ii) an in-depth examination of
both the practice and the theory of public participation in SEA of comprehensive plans
(including different ‘publics’); and (iii) the extent to which cumulative impact assessment is
advancing due to SEA. From a Canadian perspective, exploratory research is needed in the
following three areas: (i) an examination of the extent to which local Canadian communities
are currently integrating environmental and sustainability considerations into comprehensive
plans and the methods used to achieve this; (ii) the development of a SEA framework for use
in Canadian comprehensive planning processes; and (iii) a case study, applying a SEA-type
process throughout a local Canadian planning process, using commonly accepted principles of
SEA.
7.5

Concluding Remarks
While SEA is a promising avenue for incorporating environmental and sustainability

considerations into the higher levels of decision-making, it is still at a relatively early stage of
evolution. There are many shortcomings in current SEA practice, as identified in this thesis,
pertaining to effective methods and processes. Many barriers to SEA application currently
exist; key among these is insufficient political will to take SEA seriously.
Assessment of environmental impacts is important because human activities are
altering natural cycles and systems on an unprecedented scale, and the risks and impacts are
more significant than ever before (Dalal-Clayton 2002). SEA is important because it provides
179

a basis for designing policies and plans that take account of environmental opportunities and
constraints. SEA brings to decision-making the “early consideration of the environment,
incorporation of economic development and the material needs of human communities, early
consultation with the public, and a consideration of alternatives before there is an irreversible
commitment of resources” (Clark 2000, 16).
Overall SEA can be seen as a catalyst toward more integrated planning for sustainable
development. SEA is still in a relatively early stage in its development, and current practice
provides a stepping stone to something more substantial. SEA is significantly more complex
than project EIA, and it will require developing a professional capacity to ensure its success
and acceptance.

180

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193

Appendix A
Overview of SEA of Comprehensive Plans in Selected Countries
A u slraliu

A ustria

lU luiiiiii (1 I )

C anada

D enm ark (K l')

Finland (I<AI)

1 1.IIK\- ( 1 1 )

(■ i-iiii.iii\ (I'C )

(il-LTCC (KU)

lloiiK K m ig

Italy (1-;U)

Nellu-i kinds (1 I I

N ch /i-.ik iiid

N iin i.is

Portugal (KU)
S p ain (KU)
Sw ed en i l 1 1
1 lilted K iiiydiiiii il l i
I lilted S la tes

No specific provisions for SEA are currently in place at the national level, however. Western
Australia’s Environmental Protection Act (1986) explicitly provides of EA of policies, plans
and programmes. Some experience has accumulated.
SEA is not a legal requirement, but will need to comply with the EU SEA Directive. Currently,
enviromnental aspects are considered and incorporated in the establishment of various plans
and progranunes, such as land use, waste, traffic, energy and water.
SEA is not a legal requirement but will need to comply with the EU SEA Directive. Some
experience with volimtary SEAs of transport plans.
SEA is a legal requirement for federal government. Federal Ministers are required to conduct
SEA on proposed policies, plans and programmes. Voluntary SEA was undertaken for OttawaCarleton (Shepherd and Ortolano 1996).
Regional and urban land use plans must submit to the Environmental Impact Assessment
system prior to approval and implementation, since 1997. By October 2000, more than 150
plans had been evaluated.
SEA is a legal requirement for bills and government proposals. Voluntary SEA of National
Land Use Plan has been carried out. Also, research and voluntary SEA of County and
Municipal Plans. (CEC 2001)
The existing Firmish EIA Act requires SEA for certain plans, programmes and policies, but
provides little detail on how this process should be carried out.
Since 1990, through the use of laws, experiments and research, the French Government has
tried to introduce SEA (Sadler and Verheem 1996). Currently, SEA is a legal requirement at
regional levels for Master and Zoning Plans.
SEA is not currently a legal requirement, but needs to comply with the EU SEA Directive.
There has been some experience with spatial and sectoral plans, particularly in landscape
planning and zoning/building planning.
SEA is applied in a limited form in the areas of land-use planning, development plans and
regional plans. There is a requirement to undertake environmental assessments of regional
development plans with regards to European Union Structural Fund regulations. Documents
from these environmental assessments are not publicly available.
Application of EA to policy proposals dates from October 1992 (Sadler and Verheem 1996).
SEA has been applied to several sub-regional and local plans.
Environmental assessments are carried out under requirements of EU Structural Fund
regulations for regional development plans and for certain plans and programmes in the Valle
d’Aosta Region.
SEA is applied for certain types of plans and programmes, including structme plans for
electricity supply, industrial and drinking water supply, landscaping, nature conservation and
outdoor recreation, provincial waste management proposals, mineral extraction plans and
certain types of lancl use plans (Verheeml993).
SEA is a legal requirement. The Resource Management Act (RMA) requires environmental
assessment for all regional and district policies, plans and programmes.
SEA is a legal requirement for all legislation and policy decisions since 1995. Voluntary
SEAs occtu" at regional and local levels. A project on the application of EIA principles in landuse planning has been imdertaken in a number of municipalities.
SEA is not a legal requirement. Regional development plans require an environmental
assessment imder EU structural fund regulations.
Environmental assessments occur during the preparation of regional development plans under
European Union Stmctural Fund regulations.
SEA is a legal requirement. Environmental assessments of comprehensive plans of
municipalities fall under the Planning and Building Act.
SEA is not a legal requirement. Sustainability appraisals of development plans are encouraged
in planning policy guidance.
SEA is a legal requirement under the National Enviromnental Policy Act (NEPA). All
legislation or major federal actions which significantly affect the quality of the human
environment, include a ‘detailed statement’ assessing the environmental impacts. In
California, the California Environtal Quality Act (CEQA) requires all comprehensive plans to
complete an Environmental Impact Report (EIR).

194

Appendix B
List of Documents and Legislation Reviewed
SCOTLAND CASE STUDY
Legislation
Town and Country Planning (Scotland) Act 1997. Chapter 8, Part II. Edinburgh; Scottish
Executive. Online: http://www.hmso.gov.uk/acts/actsl997/1997008.htm.
Directive 2001/42/EC. Directive on the Assessment o f the Effects o f Certain Plans and
Programmes on the Environment. Luxembourg: European Parliament and Council.
Adopted 27 June 2001.
Guidelines
Scottish Planning Policy I (SPPI). The Planning System. Edinburgh: Scottish Executive.
November 2002. Online: http://www.scotland.gov.uk/library5/planning/sppl-00.asp
Planning Advice Note (PAN) 37. Structure Planning. Edinburgh: Scottish Executive.
1996. Online: http://www.scotland.gov.uk/about/Planning/advice.aspx.
Draft Guidance on the Strategic Environmental Assessment Directive. 2002 London:
Office of the Prime Minister.
Environmental Appraisal o f Development Plans - A Good Practice Guide. 1993.
Department of Environment. London: HMSO.

Documents
Perth and Kinross Council Structure Plan. 2002. Perth: Perth and Kinross Council.
Sustainability Appraisal o f the Perth and Kinross Council Structure Plan. 2002. Perth:
Environment Department, Perth and Kinross Council.

CALIFORNIA CASE STUDY
Legislation
California Environmental Quality Act (CEQA). 2003 (as amended). California Public
Resources Code. Division 13, Environmental Protection. Sections 21000 - 21177. Online:
http://ceres.ca.gov/ceqa/
California Government Code. Sections 65302-65303. Governor’s Office of Planning and
Research. On-line: http://ccr.oal.ca.gov/
Guidelines
CEQA Guidelines. 2003 (as amended). Title 14, California Code of Regulations. Chapter
3, Guidelines for Implementation of the California Environmental Quality Act. Sections
15000 - 15387. Online: www.ceres.ca.gov/topic/env_law/ceqa/guidelines
General Plan Guidelines. 1998. Sacramento: Governor’s Office of Planning and Research.
Online: www.opr.ca.gov/planning/PDFs/genplan.pdf
195

Documents
San Joaquin County General Plan 2010. Adopted July 29,1992 as amended by Board of
Supervisors, County of San Joaquin.
Final Environmental Impact Report on the San Joaquin County Comprehensive Planning
Program. 1992. Prepared by Baseline environmental Consulting. SCH No. 91012072.
Memorandum. April 4, 2000. To Board of Supervisors, County of San Joaquin. Re:
General Plan 2010 Review.
Memorandum. July 6, 2000. To Surrounding Property Owners. Re: Publication of Draft
Environmental Impact Report No. ER-98-2 for the Proposed Oakwood Lake Expansion
Project (C/O Vemalis Partners Ltd., and Brown Trust)(SCH NO. 99022040)
Final Report. January 1992. Fiscal and Financial Analysis of the Draft San Joaquin
County General Plan. Prepared by: Economic and Planning Systems. Prepared for: San
Joaquin County Community Development Department and the County Administrator.
Revised Report. October 1991. Growth Forecast for San Joaquin County. Prepared by:
Economic and Planning Systems. Prepared for: San Joaquin County Community
Development Department.

NEW ZEALAND CASE STUDY
Legislation
Resource Management Act 1991. Principle Act. Ministry for the Environment. New
Zealand. On-line: www.legislation.govt.nz
Resource Management Amendment Act 2003. Amendments to Principle Act. Ministry fo r
the Environment. New Zealand. On-line: www.legislation.govt.nz
Guidelines
What are the Options? A Guide to using Section 32 o f the Resource Management Act.
2000. (ref ME358). Auckland: New Zealand. On-line:
www.mfe.govt.nz/publications/rma/options-guide-to-section-32-jul00.pdf
Section 32: Methods o f Implementation. Quality Planning Project. 2003. New Zealand
Planning Institute, the Resource Management Law Association, Local Government New
Zealand, the New Zealand Institute of Surveyors and the Ministry for the Environment.
www.qualityplanning.org.nz/index.php
Documents
Waitakere District Plan. Made operative March 2003.
Section 32 Report fo r the Birdwood Urban Concept Plan

196

Appendix C
Provisions for SEA in the Case Studies
SCOTLAND CASE STUDY
European Union:
Directive 2001/42/EC on the Assessment of the Effects of Certain Plans and Programmes on
the Environment. (European Parliament and Council, Luxembourg: 27 June 2001)
Article 3, Paragraph 1:
“An environmental assessment, in accordance with Articles 4 to 9, shall be earned out for
plans and programmes referred to in paragraphs 2 to 4 which are likely to have significant
environmental effects.”
Article 3, Paragraph 2:
“Subject to paragraph 3, an environmental assessment shall be carried out for all plans and
programmes...which are prepared for agriculture, forestry, fisheries, energy, industry,
transport, waste management, water management, telecommunications, tourism, town and
country planning or land use and which set the framework for future development consent
of project listed in Annexes I and II to Directive 85/337/EEC.
Article 3, Paragraph 3:
Paragraph 3: “Plans and programmes referred to in paragraph 2 which determine the use
of small areas at local level and minor modifications to plans and programmes referred to
in paragraph 2 shall require an environmental assessment only where the Member States
determine that they are likely to have significant environmental effects.
Article 4, Paragraph 1:
“The environmental assessment referred to in Article 3 shall be carried out during the
preparation of a plan and programme and before its adoption or submission to the
legislative procedure.”
Article 5, Paragraph 1:
“Where an environmental assessment is required under Article 3(1), an environmental
report shall be prepared in which the likely significant effects on the environment of
implementing the plan or programme, and reasonable alternatives taking into account the
objectives and the geographical scope of the plan or programme, are identified, described
and evaluated. The information to be given for this purpose is referred to in Annex I.”

197

Scotland:
National Planning Policy Guideline 1 - The Planning System (paras. 27 and 31):
“Special attention should be given to ensure that the strategic policies now in place are
consistent with broader environmental objectives and sustainable development, in line with
current national policy and any wider international obligations.. .All plans should be
regularly reappraised to ensure that policies are consistent with broader environmental
objectives...”
(The Scottish Office Environment Department, 1994)
Planning Advice Notes (PANs) (Scottish Executive)
PAN 37 (revised 1996) - Structure Planning (paragraph. 7):
“It is important that those involved in preparing structure plans recognize how a long term
settlement strategy and the policies and proposals in the plan can contribute to achieving
the sustainable development of an area...To help in assessing a structure plan’s
contribution towards the sustainability of development, the Department expects to issue
good practice advice on the environmental appraisal of development plans in the near
future” (The Scottish Office Development Department, 1996b)
PAN 49 - Local Planning (paragraph 48):
“The matters to be covered in a local plan are for the local authority to decide.. .But there
are likely to be a number of core topics like the environment... sustainable development
and environmental appraisal...” (The Scottish Office Development Department, 1996a)
PAN 49 - Local Planning (Annex 1, yarasrayh 7):
“.. .project-based environmental assessment is not enough on its own to ensure that we move
towards sustainable development. The environmental appraisal of development plans
involves testing a plan’s aims, policies, and proposals against the aims of sustainable
development to identify their likely consequences. It is now recognized as a policy means
of helping to achieve development and growth which is sustainable.” (The Scottish Office
Development Department, 1996a)

198

CALIFORNIA CASE STUDY
California Environmental Quality Act (CECA)
Section 21003. Planning and environmental review procedures; documents; reports; database;
administration of process
The Legislature further finds and declares that it is the policy of the state that:
(a) Local agencies integrate the requirements of this division with planning and environmental review
procedures otherwise required by law or by local practice so that all those procedures, to the maximum
feasible extent, run concurrently, rather than consecutively.
(b) Documents prepared pursuant to this division be organized and written in a manner that will be
meaningful and useful to decisionmakers and to the public.
(c) Environmental impact reports omit uimecessary descriptions of projects and emphasize feasible
mitigation measures and feasible alternatives to projects.
(d) Information developed in individual environmental impact reports be incorporated into a data base
which can be used to reduce delay and duplication in preparation of subsequent environmental impact
reports.
(e) Information developed in environmental impact reports and negative declarations be incorporated
into a data base which may be used to make subsequent or supplemental environmental
determinations.
(f) All persons and public agencies involved in the environmental review process be responsible for
carrying out the process in the most efficient, expeditious manner in order to conserve the available
financial, governmental, physical, and social resources with the objective that those resources may be
better applied toward the mitigation of actual significant effects on the environment.

199

NEW ZEALAND CASE STUDY
Resource Management Amendment Act (2003) Section 32
32. Duties to consider alternatives, assess benefits and costs:
(1) In achieving the purpose of this Act, before a proposed plan, proposed policy statement,
change, or variation is publicly notified, a national policy statement or New Zealand coastal
policy statement is notified under section 48, or a regulation is made, an evaluation must be
carried out by (a) the Minister, for a national policy statement or regulations made under section 43; or
(b) the Minister of Conservation, for the New Zealand coastal policy statement; or
(c) the local authority, for a policy statement or a plan (except for plan changes that have
been requested and the request accepted under clause 25(2)(b) of Part 2 of Schedule I; or
(d) the person who made the request, for plan changes that have been requested and the
request accepted under clause 25(2)(b) of Part 2 of the Schedule 1.
(2) A further evaluation must also be made by (a) a local authority before making a decision under clause 10 or clause 29(4) of the
Schedule 1; and
(b) the relevant Minister before issuing a national policy statement or New Zealand coastal
policy statement.
(3) An evaluation must examine (a) the extent to which each objective is the most appropriate way to achieve the purpose
of this Act; and
(b) whether, having regard to their efficiency effectiveness, the policies, rules, or other
methods are the most appropriate for achieving the objectives.
(4) For the purposes of this examination, an evaluation must take into account (a) the benefits and costs of policies, rules, or other methods; and
(b) the risk of acting or not acting if there is uncertain or insufficient information about the
subject matter of the policies, rules, or other methods.
(5) The person required to carry out an evaluation under subsection (1) must prepare a report
summarising the evaluation and giving reasons for that evaluation.
(6) the report must be available for public inspection at the same time as the document to
which the report relates is publicly notified or the regulation is made.

200

Appendix D
Abbreviations and Acronyms
The use of abbreviations and acronyms is intended to be minimal in this thesis.
However, the following acronyms that are used are listed here for the reader’s convenience. A
description of some of these terms appears in Appendix E.
General:
CEC
EA
EIA
EU
LA21
PPP
SEA
W-E-T

Commission of the European Communities
Environmental Assessment
Environmental Impact Assessment
European Union
Local Agenda 21
Policies, Plans and Program(me)s
Strategic Environmental Assessment
Waste-Energy-Transport

Scotland;
DETR
DLTR
DoE
NPPG
PAN
PPG
SA
SPP
UK

Department of Transportation and Regions (UK, prior to 1999)
Department of Local, Transportation and Regions (UK, after 1999)
Department of Environment (UK)
National Planning Policy Guidance (Scotland)
Planning Advice Notes (Scotland)
Planning Policy Guidelines (UK)
Sustainability Appraisal
Scottish Planning Policies (Scotland)
United Kingdom

California:
CEQA
CRA
EIR
EIS
NEPA
OPR

California Environmental Quality Act
California Resources Agency
Environmental Impact Report
Environmental Impact Statement
National Environmental Policy Act
Office of Planning and Research

New Zealand:
AAE
LTCCP
MfE
PCE
RMA
RPS
QPP
s32

Assessment of Environmental Effects
Long Term Council Community Plan
Ministry for the Environment
Parliamentary Commissioner for the Environment
Resource Management Act
Regional Policy Statement
Quality Planning Project
Section 32 Analysis

201

Appendix E
Glossary of Planning and Environmental Assessment Terms
GENERAL
Carrying Capacity - the maximum population of a species that can be sustained indefinitely in a
given habitat.
Ecological Footprint - the land (and water) area that would be required to support a defined
human population and material standard indefinitely.
Effectiveness - how well something performs
Environmental Assessment - a tool for integrating environmental considerations into decision­
making by ensuring that significant environmental effects of the decision are taken into account.
Environmental Impact Assessment (EIA) - a public process by which the likely effects of a
project on the environment are identified, assessed and then taken into account by the consenting
authority in the decision-making process.
Local Agenda 21 (LA2I) - a participatory community process, which came out of the Rio Earth
Summit in 1992, as part of making Agenda 21 relevant at the local level. It is driven by local
authorities.
Objectives-led - in the context of SEA, the term implies either that the environment is incorporated
into the policy objectives, or that the assessment is guided by a set of environmental objectives,
which may not be the same as those of the policy it is assessing.
Procedural Effectiveness - the extent to which performance meets established purpose(s), goals
and objectives (Sadler and Verheem 1996, 19)
Scoping - the process of determining the parameters, boundaries and key issues to be addressed by
an environmental assessment.
Strategic Environmental Assessment - a systematic process for evaluating the environmental
consequences of proposed policies, plans or programme initiatives in order to ensure they are fully
included and appropriately addressed at the earliest appropriate stage of decision-making on par
with economic and social considerations (Sadler and Verheem, 1996, 27)
Sustainability Assessment (SA) - adaptation of existing impact assessment systems used to
examine during the decision-making process if policies, plans, programmes or other initiatives will
lead society into a more sustainable direction.
Sustainability Lifestyle Assessment - a tool developed by Devuyst and van Volsem (1999) to
predict, analyze and evaluate the impacts of all long-term, mid-term and short-term decisions made
over a lifetime, making use of sustainability goals as a point of reference.
Substantive Effectiveness - the extent to which performance meets accepted provisions and
principles (Sadler and Verheem 1996, 19)
SCOTLAND
Development Plans - the statutory development plan for an area currently comprises the structure
plan and the local plan. The purpose of the development plan is to guide the future development of
an area. Plans contain policies which should cover key land use issues including housing, transport,
employment, retailing, recreation, conservation and environmental protection.

202

Enviromnental Appraisal - a form of environmental assessment used in the UK (primarily for
development plans) since the early 1990s. Superseded by sustainability appraisal.
Community Planning - under the forthcoming Local Government Act 2003, local authorities and
public bodies will have a statutory duty to initiate and facilitate the community planning process.
This means that the local authority working in partnership with other public bodies such as police,
health boards and enterprise companies, the private and voluntary sectors and communities to
improve the delivery of public services and the well being of communities.
Local Plans - a local plan sets out detailed policies and specific proposals for the development and
use of land that should guide day-to-day planning decisions. They must identify effective
opportunities for development and encourage investment in an area. The aim is to exert a positive
influence over land use decisions.
National Planning Policy Guidance (NPPGs)- set out policy on nationally important land use and
other planning matters, covering issues such as transport, natural heritage, land for housing,
shopping centres, and town centres. Currently being revised and renamed as Scottish Planning
Policies (SPPs).
Planning Advice Notes (PANs) - give advice on how best to deal with matters such as local
planning, rural housing design and improving small towns and town centres.
Planning Policy Guidelines (PPGs) - for England and Wales
Structure Plans - under current arrangements structure plans should provide a long-term vision,
looking forward at least 10 years, as part of an overview of an area’s 0 development requirements,
considering the functions and inter-relationship of places, expressing the settlement strategy for the
area and identifying priorities for urban and rural regeneration.
Scottish Planning Policies (SPPs) - same as National Planning Policy Guidance (NPPGs). In
November 2002, NPPGs began to be renamed SPPs when revised. Currently, NPPG 1 and NPPG 2
have been revised and renamed as SPPI and SPP2, respectively. Remaining NPPGs will be
renamed as SPPs when it becomes necessary to revise their contents.
Sustainability Appraisal - a form of assessment used in the UK (primarily for development plans
and regional planning guidance) since the late 1990s. Considers social and economic effects as well
as environmental ones. Tends to be less detailed and more qualitative than many forms of
environmental assessment.
CALIFORNIA
Community Plans - refer to Special Plans.
General Plans - prepared by county and city planning authorities for the physical development of
the county or city, and any land outside its boundaries which bears relation to its planning
(California Government Code Section 64300). Must address issues concerning land use,
circulation, housing, conservation, open-space, noise and safety.
Enviromnental Impact Report (EIR) - a detailed statement prepared under CEQA describing and
analyzing the significant environmental effects of an activity and discussing ways to mitigate or
avoid the effects.
Environmental Impact Statement (EIS) - term used in NEPA for EIRs.

203

Master Environmental Impact Reports - prepared for all, or a portion of, the territory subject to
a public agency’s control in order to provide inf^ormation which may be used or referenced in EIRs.
Programme Environmental Impact Reports - an EIR which may be prepared on a series of
actions that can be characterized as one large project and are related either; (i) geographically; (ii)
as logical parts in the chain of contemplated actions; (iii) in connection with issuance of rules,
regulations, plans or other general criteria to govern the conduct of a continuing program; or (iv) as
individual activities carried out with the same authorizing statutory or regulatory authority and
having generally similar environmental effects which can be mitigated in similar ways.
Special Plans -"community plans" and "specific plans" are often used by cities and counties to plan
the future of a particular area at a finer level of detail than that provided by the general plan. A
community plan is a portion of the local general plan focusing on the issues pertinent to a particular
area or community within the city or county. It supplements the policies of the general plan.
Specific plans describe allowable land uses, identify open space, and detail the availability of
facilities and financing for a portion of the community. Specific plans must be consistent with the
local general plan. A specific plan implements but is not technically a part of the general plan. In
some jurisdictions, specific plans take the place of zoning. Zoning, subdivision, and public works
decisions must be consistent with any applicable specific plan.
NEW ZEALAND
Assessment of Environmental Effects (AEE) - a report outlining the effects that a proposed
activity might have on the environment.
District Plans - the RMA requires district and city councils to prepare district plans for all of the
area that they are responsible for. Each plan describes the district’s significant resource
management issues, and sets out objectives, policies, methods and rules to address these issues.
District plans must be consistent with national or regional policy statements or regional plans.
Environment Conrt - formerly called the Planning Tribunal. Specialist court where people can go
to appeal decisions made by councils on either a policy statement or plan, or on a resource consent
application, or to apply for an enforcement order. Same powers as the District Court.
Iwi - Maori tribal groups
Long Term Conncil Community Plans (LTCCPs) - under the new Local Government Act 2002
(Part 6, Section 93), every local authority must prepare a LTCCP which covers a ten year period.
The purpose of the LTCCP is: (i) to describe Council’s activities; (ii) to describe community
outcomes desired for the city; (iii) provide integrated decision making (between the Council and the
community) and coordination of resources; (iv) provide a long term focus for the Council’s
decisions and activities, (v) provide a basis for accountability to the community; and (vi) to provide
an opportunity for community participation. Under section 94, every LTCCP must contain a report
from the local authority’s auditor on (i) the extent to which the local authority has complied with
the requirements of the Act in respect of the plan; (ii) the quality of the information and
assumptions underlying the forecast information provided in the plan; and (iii) the extent to which
the forecast information and performance measures provide an appropriate framework for the
meaningful assessment of the actual levels of service provision.
National Policy Statements (NFS) - when deemed necessary, the Minister for the Environment
can issue a national policy statement to guide local authorities on matters of national significance.
To date, no national policy statements have been prepared, although the Government has agreed to
the development of a National Policy Statement on Biodiversity.

204

Quality Planning Project - the purpose of the project is to promote best practice by sharing
knowledge about policy and plan development under the Resource Management Act. It is a
partnership between the New Zealand Planning Institute, the Resource Management Law
Association, Local Government New Zealand, the NZ Institute of Surveyors and the Ministry for
the Environment.
Regional Plans - although not mandatory, two-thirds of the regional councils now have operative
regional plans, with most of the remainder in the Environment Court. Like district plans, regional
plans describe the regionally significant management issues facing a particular area or resource
within the region. The plan will then set out objectives, policies and methods to address these
issues, and also outline the environmental results that are anticipated from their implementation.
Regional councils must ensure that their plans are not inconsistent with national or regional policy
statements, or other regional plans.
Regional Policy Statements (RPS) - the Resource Management Act also requires each regional
council to prepare a regional policy statement, which provides an overview of the region’s resource
management issues and facilitates an integrated approach with district councils to manage those
issues. Regional policy statements establish a directional framework for regional and district plans.
Regional policy statements must not be inconsistent with National Policy Statements. Almost all
regional councils now have operative regional policy statements.
Resource Consent - a land use consent, issued in terms of the Resource Management Act 1991, by
the territorial authority for land use not designated a permitted activity in the territorial authorities’
District Plan. For example, wishing to locate a building closer to the boundary than that permitted
by the District Plan.
Runaga - the local representative Maori groups equivalent of local government.
Section 32 Analysis (s32) - Section 32 of the RMA imposes a rigour on decision-makers by
requiring them to evaluate their objectives, policies, rules and methods before adopting them. The
benefits and costs of all of these have to be examined, and decisions made taking into account
necessity, effectiveness and efficiency.
Structure Plans - is a tool available to councils to manage the environmental effects arising from
subdivision and development, and are found within the District Plans.
Sustainable Management - defined under the RMA as managing the use, development, and
protection of natural and physical resources in a way, or at a rate, which enables people and
communities to provide for their social, economic, and cultural well being and for their health and
safety while (a) sustaining the potential of natural and physical resources (excluding minerals) to
meet the reasonably foreseeable needs of future generations; (b) safeguarding the life-supporting
capacity of air, water, soil, and ecosystems; and (c) avoiding, remedying, or mitigating any adverse
effects of activities on the environment.
Tangata Whenua - are the people of the land, the people who hold the customary authority in an
area according to tribal custom.
Treaty of Waitangi - the founding document of New Zealand as a nation, given legal effect in its
incorporation into various statutes, particularly for environmental and resource management. By the
Treaty, Maori ceded to the Crown the right to govern, and in return the Crown confirmed and
guaranteed the rangatiratanga of tangata whenua.

Urban Concept Plan - is a planning tool that the local council can use to manage the
effects arising from subdivison and development in an urban area.

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