Environmental Impact Assessment presentations/20170926 RH NG.pdf20 Environmental Impact Assessment | 26th September 2017 | Rufus Howard Continued… ^The Infrastructure Planning (Environmental

Environmental Impact Assessment

Digital Assessment

IEMA Webinar

Rufus HowardBSc LLM FIEMA CEnv PEIA MIoD

26th September 2017

Environmental Impact Assessment | 26th September 2017 | Rufus Howard

What has it got to do with you?

Director of Sustainable Development RHDHV

Chairman of IEMA Impact Assessment Network

IEMA Strategic Advisory Board

Registered Principal EIA Practitioner

Chartered Environmentalist and Fellow of IEMA

Env. Man. BSc & Env. Law Masters; PhD in Management

Advising the World Bank on the development of a global ESIA Accreditation System for the new ESF

Leading the Industry Evidence Programme: Offshore Wind


A focus for UK’s IA Network & QMark


The State of EIA

IEMA Special Report 2011

“Long Environmental Statements add burdens to all parties involved”

“Ineffective Scoping – risk aversion, poor planning, and commercial realities.”

Environmental Impact Assessment | 26th September 2017 | Rufus Howard 5

IAIA Florence 2015

“The theme of this year’s conference isfascinating: digital. The Latin origin of

this word is digitus (finger). And it’s true:now we have the entire world in ourfingers. We don’t even need to press,just touch. How will this amazing soft

technology change the world? How willit affect the way people communicate?

How will it transform the way we collectand process information? The way

decisions are made?”


IEMA Proportionate EIA Strategy 2017

EIA-as-normal Risks:

•Being a key voice for the

environment in decision-making

•Adding value to development

design

•Engaging the public in effective

consultation

•Helping manage risks to

consenting

•Being more than an expensive

procedural exercise


Justice Sullivan - 2004

‘It would be no advantage to anyone concerned… -

applicants, objectors or local authorities - if ES were

drafted on a purely “defensive basis” mentioning

every possible scrap of information ... Such

documents would be a hindrance not an aid to sound

decision-making by the local planning authority, since

they would obscure the principles issues with a welter

of detail’.

Derbyshire Waste Ltd vs Blewett and SoS for Environment [2004] EWCA Civ 1508 at para 42


Trends Over Time

0

50

100

150

200

250

300

0

1000

2000

3000

4000

5000

6000

7000

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9000

10000

Oct-05 Nov-05 Aug-07 Dec-09 Sep-11 Oct-11 Jan-12 Oct-12 Nov-12 Aug-13

GreaterGabbard

Thanet SheringhamShoal

Dudgeon KentishFlats

Extension

Galloper Triton Knoll Sea Green East Anglia1

DoggerBank Creyke

Beck

Environmental Statement (Page Length) Scoping Report (Page Length)


Proportionate EIA

Systematic Collaborative Action


Four Strategic Themes for Action


Embracing Innovation & Digital

11


The world moves on ….

Interesting developments are popping up fast

Who wants to go through 35,000 pages of paperwork? Boring!

Let's do it differently!

Interactive digital Impact assessment as the new standard

12



Clients and Regulators Views?

www.theneweis.com

https://www.youtube.com/watch?time_continue=8&v=6hTx5yTAMGo

https://www.royalhaskoningdhv.com/en-gb/specials/digital-eis

https://www.royalhaskoningdhv.com/en-gb/specials/digital-eis?utm_source=newsletter&utm_medium=email&utm_campaign=digitaleis


Industry Evidence Programme (IEP)The Goals of the IEP are to:

Focus EIA on the significant environmental topics

Identify topics of negligible concern

Identify topics with established mitigations that reliably reduce significance

Identify topics with likelihood of significant adverse effects

Provide a central hub for evidence, good practice and guidance

Provide standardised and verified mitigation solutions

Provide standardised templates for conditions

Provide standardised monitoring for impacts during construction and

operation

Provide evidence to support decisions that lead to a proportionate EIA

Reduce costs and programme for developers, regulators and stakeholders

Provide greater legal and scientific certainty for all stakeholders

Establish knowledge gaps to direct further research


Steering Committee

16


Stakeholder Views

What are your organisations concerns if you were to receive a

digital, web based, versus a paper based Environmental

Statement?

Do you think your organisation would accept a digital ES

(assuming it contains the correct information you would expect

from an ES)?

Do you foresee any legal or regulatory reasons why your

organisation would not accept a digital Environmental

Statement?


Regulators Views?


What are your organisations concerns if you were to

receive a digital, web based, versus a paper based

Environmental Statement?

“Accordingly it is apparent that the 2009 EIA Regulations do not explicitly define the ES as being (or needing to be) a paper based document. However, the 2009 EIA Regulations do frequently refer to ‘copies’ in respect of the ES, which may imply that the Regulations envisage the ES is a physical entity rather than a digital only document. Nonetheless this is not explicitly stated in the 2009 EIA Regulations.” PINS


Continued…

“The Infrastructure Planning (Environmental Impact Assessment) 2017 Regulations (2017 EIA Regulations) which have now been made and will come into force on 16th May 2017 includes provision requiring that the ES is available on a website maintained by or on behalf of the Secretary of State. As with the existing 2009 EIA Regulations the 2017 EIA Regulations do not explicitly state that the ES should be a paper based document.” PINS


but…

“The Infrastructure Planning (Applications Prescribed Forms and Procedures) Regulations 2009 (as amended) state that if requested by the Planning Inspectorate the Applicant should provide three paper copies of the application form and other supporting documents and plans. This would include paper copies of the ES as a supporting document.” PINS


but…

“Further to this the Planning Inspectorate Advice Note 6: Preparation and submission of application documents includes advice that states:

“The applicant is required to submit its full application in both electronic and hard copy format. Whilst the Planning Inspectorate encourages electronic working, the submission of hard copy documents and plans is required in order to ensure the smooth running of the examination process.” “ PINS


Other Statutory Consultees

“Overall we would be very supportive of this sort of evolution of EIAs, it is without a doubt the direction things should and are going to take. It’s definitely an exciting step – as you know, we agree with the need to reduce the hard copies of ESs and can see it as an excellent tool for public engagement and non-technical summaries” Statutory Consultee



“We are supportive of the approach in principle and can see the benefits in terms of increased accessibility, ease of use and interpretation etc.

The format would be particularly useful as a public engagement tool and for providing non-technical summaries but only very careful application of the approach will allow it to act as a replacement for a conventional ES.”



“In answer to your specific queries I have gathered thoughts from some of our officers who were overwhelmingly receptive to the idea:-”

I have categorised these comments into three types:• IT (software and hardware)• Interactivity (usability)• Archives (records)


IT Concerns

• “Need backwards compatibility for whichever browser /

reader product is used

• Training would be needed

• Inconsistency if not all applicants take this approach

• How would the digital approach handle supplementary

material?”

• Will programs be supported by our systems?”


IT Concerns

• What if can’t use Wifi at hearings due to security?

Can they be accessed offline?

• There would have to be an agreed standard and

format for the new product.

• File path lengths for downloads (limit for 150 /

250 characters) which often is problematic for

large ES downloads


Interactivity and Commenting

“Would be best to be in a format that is easily printable so case officers can print out particular sections if needed

Agreed fonts if using Acrobat

There may be the danger to go hyperlink crazy so that you are hopping around the website trying (and potentially missing) important information such as caveats.”


“How would we comment on it – easy at the moment with page numbers and sections?

Web version could facilitate joint comments if could come up with some access structure.

Also could maybe allow more than one person to comment at a time (e.g. as per sharepoint files) and make collating comments easier”




“There will still need to be the ability to drill down through the interactive layers to a full and detailed quantitative assessment of key issues/impacts - presumably in the form of underpinning chapters and supplementary technical reports. The approach will save time in navigating your way through an ES, allow faster cross referencing and reduce printing costs but wouldn’t replace the need for this material.”


Archiving and Records

• “Legacy issues and responsibility for archiving would also have to be considered.

• Version control and subsequent editing after submission would have to be very strictly set out.

• Where would they be stored – we have to go back to original ESs sometimes years after they were first submitted – and be assured there are no changes”


Archiving and Records

• “Need a permanent archive (might be needed in 50 years time…)

• Need a clear audit trail on the files (i.e. it cant be edited by the submitter once it has been submitted).”

• The ES would need to be hosted by the Appropriate Authority (AA) for control to be maintained and for the information to be “submitted to the AA”.

• Information will also need to be held for the lifetime of the project which would create particular storage issues for authorities.”


Do you think your organisation

would accept a digital ES (assuming

it contains the correct information

you would expect from an ES)?

“Having links to click through to relevant related sections will be a lot easier than a thousand sticky notes in various paper reports, or having lots of clunky pdfs open at once.

This does move to the ‘digital by default’ government position”


Do you think your organisation

would accept a digital ES (assuming

it contains the correct information

you would expect from an ES)?

“Yes.”


Key Point

“In terms of it replacing ESs, there are probably quite a few questions to be answered. It must still contain the same information we would expect from an ES, complete with references.”


Key Point 2

“The risk that, without the constraints of printing costs, Environmental Statements would actually get longer, rather than shorter, thereby complicating and lengthening the review process rather than streamlining it as intended.”


Key Point 3

“Public accessibility – need to keep in mind that not everyone is online / has access to a fast internet connection, so hard copies can still be useful for public consultation.

“Consultation of the public would need to allow for those who do not have internet access (or knowledge of the web).”


Key Point 4

“What is really needed to reduce the difficulties of handling conventional ES’s is to address some of the more fundamental reasons why ES’s are very large. These include looking at our ability to eliminate issues sooner from the assessment, ensuring assessment is proportionate to risk and avoiding ‘Data Rich Info Poor’ data collection”


Conclusion

• Appetite for Innovation

• Potential Advantages

• Several Challenges in Implementation

• Part of the solution not the whole solution

• Pilots needed

• Willing engagement


Any Questions?

40

@Rufus_Howard

https://uk.linkedin.com/in/impactassessment

https://uk.linkedin.com/in/impactassessment

Refreshing the approach

to EIA

Nick Giesler: Head of

Environment,

Crossrail 2

Crossrail 2 – new transport

solution

• 100km route, with twin tunnels over

35km

• 51 stations

• 30 trains per hour

• Carrying up to 270,000 people in

peak

• Open in the early 2030s

• Joint TfL/Network Rail project

A new railway to serve London and the wider Southeast

The EIA challenge

• Too big ESs: too much information; abstruse conclusions

• Over-elaborate process

• Double-handling – waste and inconsistency

• Big teams; big documents; big assessment - big costs

• Life style

Growth of Environmental Statements

The good ol’ days

• HS1 – (1994)

900 pp, 10 docs

• Thameslink 2000

(2004)

750 pp, 5 docs

• Crossrail (2005)

2,200 pp, 9 docs

The behemoths

• Hinkley Point C (2011)

31,133 pp, 185 docs

• Thames Tideway (2013)

25,600 pp, 93 docs

• HS2 (2013)

39,610 pp, 536 docs

• HS2 (with additional

provisions)

50,000 pp +

Cultural change

• Embed the approach in a large and diverse team

• Secure consistent thinking and expectations

• Challenge entrenched working practice

• Build on recognised achievements and skills

• Get stakeholders on board

• Comprehensive planning early on

Definitive scoping

• Assess only what you need to assess

• Design only what you need to design

• Be incisive; be bold; NOT reckless

• Scope as first stage assessment

Scope Assess

Stage 1 assessment Stage 2 assessment

Realise synergies

• ES largely a product of the EIA.

• But other processes support it:• transport assessment

• economic case

• strategic case

• HIA

• Equalities studies

• Refreshed approach needs wider application than just EIA.

Synergise assessments and reports

ES

TA

EqIAHIA

Economic report

ES

TA

HIA

EqIA

Economic reports

Communicate and innovate

• ES must communicate effectively.

• Devise for readers, not writers.

• Intuitive, well written and abundantly illustrated products.

• Effective use of technology, including on-line reporting.

• Innovative user interfaces for maps, animations and other graphical material.

• Bespoke production team, not just editing the work of others.

Summary: steps for change

• Develop an explicit and lucid approach

• Challenge working practice, but build on success

• Long-term planning to shape short-term work

• Scope bold: only assess what we need to

• Review assessment workstreams to realise synergies

• Develop innovative and contemporary products focused on their main audience

• Strong leadership and direction

Online scoping

Online scoping

Documents

Environmental Impact Assessment presentations/20170926 RH NG.pdf20 Environmental Impact Assessment | 26th September 2017 | Rufus Howard Continued… ^The Infrastructure Planning (Environmental