Maeve McElvaney reviews the new IEMA guide to using EIA to shape quality developments
After the launch of the IEMA quality mark scheme in 2011, opportunities arose to improve practice among environment impact assessment (EIA) professionals in the UK. In particular, it was felt that guidance was needed on the role EIA played in shaping design before a project was granted consent.
IEMA EIA Guide to Shaping Quality Development aims to promote the assessment as a design tool and establish the principles and framework for maximising the interaction between the environmental technical team and the master planning or architectural team.
LDA Design worked with the Environment Agency and IEMA on the guide, which was launched at the institute’s EIA masterclass conference in November 2015. LDA is a design, environment and sustainability consultancy that works on development and infrastructure projects, and has a good understanding of how the environmental impact assessment and design processes interact.
Better interaction
As well as achieving higher quality design, it is expected that closer interaction will contribute to the delivery of more proportionate EIA, as well as shaping decision making throughout the development process. EIA coordinators should take responsibility for maximising interaction and aim to achieve these objectives:
- improve environmental outcomes in project design, for example by avoiding or incorporating sensitive environmental receptors in the final plan. This would help to protect and enhance receptors as part of the design and during the life of the project;
- allow better informed decision making across the whole project team to achieve the right outcome for environmental issues;
- contribute to better solutions by taking account of a project’s environmental, commercial and operational requirements and deliver a well-rounded design that works and delivers for all; and
- reduce consenting risk and delay, and therefore costs, by ensuring that environmental issues and associated direct and indirect benefits and problems are adequately thought through and discussed with the statutory bodies that must be consulted about a planning application.
While preparing the guide, it became clear that an alternative approach to EIA coordination, rather than the generally accepted standard practice of achieving ‘design freeze’ before assessment work starts, may help to achieve these objectives.
LDA Design coordinates EIAs by using the ‘narrative led’ method – a process of environmentally informed design and the inclusion of mitigation (both primary and tertiary) as part of the design, which is clearly described in one place in the environmental statement (ES). We have found that this approach helps to deliver a more proportionate ES by setting out a clear rationale for the final design. It also helps to reduce the complexity of assessment chapters by removing the need to identify and assess potential effects that have been designed out entirely.
A set of principles
The guide makes clear that a narrative led approach is a good way to integrate EIA and design. It also highlights several EIA coordination principles and guidelines that can bring about such an approach.
Principle 1
Ensure early, effective and continuing interaction – The EIA coordinator should help to drive early, effective and constant interaction between environmental thinking and the design process. Ideally, this should take place early in the process, and the results, whether sensitive environmental conditions or difficult planning issues are identified, should feed into project need and risk, viability and site selection. Early engagement between the environmental and design teams helps to identify issues that may result in a project becoming unfeasible, reduces the likelihood of it being hampered by built-in negative environmental effects, and assists designers to think about how to weave the environment into the final design.
EIA coordinators also need to advocate the benefits of coordinating an assessment using the narrative led approach and strive to involve the whole project team, including planners, designers, engineers, legal advisers and construction contractors.
Persistence in working towards an interactive approach, even in small ways, and truly selling the benefits whether they relate to risk, feasibility or design, will help to deliver a more environmentally-informed design, identifying benefits and minimising risk. This interactive approach allows the clear flow of information across the team, whether it relates to environmental sensitivities or the effects, or mitigation measures. Information exchange enables the EIA coordinator to monitor the design process effectively and to identify whether one form of mitigation could cause adverse side effects in order to address them – for example, ensuring that a well thought out drainage strategy delivers ecological objectives as well as amenity benefits.
The accurate recording of environmental mitigation measures, starting as early as possible and continuing throughout the project programme, can naturally feed into the design evolution chapter of the ES. It can also form the backbone of key mitigation commitments, all of which can contribute to the wording of planning conditions, management plans and detailed design. Accurate reporting also helps to ensure that amendments to the design do not reverse an important facet that had been decided earlier. This ensures the project is run efficiently, avoids abortive work and keeps down costs.
Principle 2
Undertaking appropriate stakeholder engagement – Typically, large, complex infrastructure projects benefit greatly from effective, well managed consultation to inform the design and gain buy-in, as well as to identify issues of concern for the local community. As projects evolve, it is good practice to consider whether further consultation is required to allow statutory consultees to respond to any key design changes. This provides an opportunity for the EIA coordinator and team to further reduce the scope of the impact assessment, ensuring that it is proportionate and focused solely on effects that may be significant.
Principle 3
Good management of consenting risk – Using EIA as a risk management tool can help to meet this key requirement expected of developers. Risks include: ensuring that the design responds to the environment; meeting the commercial needs of the client; and clearly communicating the design narrative, while focusing only on significant environmental effects.
From experience, risk can be managed by ensuring the EIA coordinator exercises leadership and has a good understanding of the planning strategy and process. Relaying information on the type of application (full, outline or s73, for example) and level of design detail required to other members of the team is imperative if the assessment is to be adequate and proportionate.
A narrative led approach can help to capture the influence of the environment and consultation responses on the design evolution and how they fed into the final design. This demonstrates to stakeholders the options that were considered – in line with EIA regulation requirements – and why a measure was carried forward.
Although the ES should be a factual and objective document, it should also help users to understand the proposed development. Describing the design evolution in its own chapter, before the one describing the project, helps stakeholders see why particular decisions were taken and in what order, helping to frame their vision of the final design. It is good practice to clearly outline the final design in the project description chapter and refer explicitly to the mitigation measures, both primary and tertiary, that support it. Classifying mitigation into one of these three types aids clarity and achieves a more proportionate ES:
- Primary – an intrinsic part of the design evolution, which should be described in the project description chapter. An example includes reducing the height of a development to reduce visual impact.
- Secondary – this requires further activity in order to achieve the anticipated outcome. It is described in the topic chapters and secured through planning conditions or management plans. An example includes describing lighting limits, which will be conditional on the submission of a detailed layout.
- Tertiary – this is required regardless of the EIA because it is generally imposed through legislative requirements or standard sector practices. One example is implementing considerate contractor’s practices to manage activities that have potential nuisance effects.
LDA Design typically includes both primary and tertiary mitigation in the project description. The EIA is based on delivering both forms of mitigation – any effects that might have arisen without them do not need to be identified as potential effects because they should not arise. Therefore, the difference in significance between potential effects and residual effects requires consideration only if secondary mitigation is involved – resulting in a simpler and more proportionate ES.
Building effective and valuable environmental benefits into project design helps secure permission, delivers a better design and provides reasons for communities and wider stakeholders to support a developer’s aspirations for the site. The EIA coordinator has a role in encouraging the assessment team to identify these opportunities and in ensuring they are communicated to the developer and design teams, and reflected clearly in the ES.
Principle 4
The ES should present a clear narrative and focused chapters – Presenting a clear narrative of how the environment has shaped the project design helps to deliver fewer, more proportionate ES topic chapters. The project description should be sufficiently detailed so that each chapter can refer back to it and rely on its content. Each assessment chapter needs to provide only a very brief reference to the aspects of the design (primary mitigation) and tertiary mitigation that are relevant to the topic. Secondary mitigation will, however, require more detailed description in topic chapters. Including a clear, itemised mitigation summary in the ES will also help to keep topic chapters short and focused.
Shape of things to come
Using EIA to shape design at LDA Design has produced higher quality developments, improved its understanding of how to ensure the process interacts effectively with other pre-application project activities and achieved better environmental outcomes than would have been attained. Importantly, it helps to promote EIA as a both a design tool and risk management tool.
A proportionate statement
The proportionate environmental statement
- Has a project description that clearly describes the parameters of the development and sets out all primary and tertiary mitigation.
- Clearly describes the evolution of the design and details how environmental effects have been avoided or reduced through the design process.
- Has a clear, itemised mitigation summary.
- Only contains chapters needed to report on likely significant effects arising from the final design.
The proportionate environmental statement chapter
- Refers to the main ES project description and design evolution.
- Briefly summarises key mitigation relevant to the topic.
- Assesses only potential effects arising from the final design, incorporating all primary and tertiary mitigation.
- Identifies residual effects only if secondary mitigation is required.
- Focuses primarily on significant effects.
