STRATEGIC ENVIRONMENTAL ASSESSMENT OF THE EUROPEAN STRUCTURAL FUND OBJECTIVE ONE PROGRAMME FOR THE HIGHLANDS AND ISLANDS OF SCOTLAND

STRATEGIC ENVIRONMENTALASSESSMENT OF THEEUROPEAN STRUCTURAL FUNDOBJECTIVE ONE PROGRAMMEFOR THE HIGHLANDS ANDISLANDS OF SCOTLANDArthur Keller, Scottish Natural Heritage, Edinburgh, UK

INTRODUCTION

The EU has committed itself to integrating itsenvironmental objectives into all of its poli-cies. Its regional policy is one of its most

significant areas of activity, with considerableimplications for the environment. However,despite the instigation of regulations which seek toinclude an environmental element into the Struc-tural Funds, there has been disappointmentexpressed in the difference that has actually beenmade in practice. This paper sets out the approachtaken in the Highlands and Islands of ScotlandStructural Fund Programme to address this issue.A Strategic Environmental Assessment (SEA) of theProgramme was undertaken to set a frameworkwhich would guide the Programme towards its aimof sustainable development for the Highlands andIslands.

BACKGROUND

European policy framework

The Treaty on European Union (1992, better knownas the ‘Maastricht Treaty’) states that ‘environ-mental protection requirements must be integratedinto the definition and implementation of theCommunity’s other (non-environmental) policies’.

Thus the EU is obliged by its founding legislationto integrate environmental issues into its policies.The Fifth Environmental Action Plan, which wasadopted by the Council of Ministers in 1993, isconcerned with just how environmental objectivescan be incorporated into other activities in the EU

CCC 0961-0405/97/020063–06 $17.50# 1997 by John Wiley & Sons, Ltd. and ERP Environment.

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to achieve sustainability. It states: ‘Given the goal ofachieving sustainable development it seems onlylogical, if not essential, to apply an assessment ofthe environmental implications of all relevantpolicies, plans and programmes’.

Structural Funds

The Commission of the EU (‘the Commission’)recognized that one of its main activities which hadpotentially deleterious effects on the environmentwas its financial support for regional developmentthrough its Structural Funds. The EU targets theseagainst particular objectives, three of which relateto geographical areas. Of these, Objective 1, whichis to assist less favoured areas whose developmentis lagging behind, applies to the Highlands andIslands of Scotland. (The other two geographicallytargeted Objectives, 2 and 5b, assist urban areasfacing industrial decline, and rural areas requiringeconomic diversification, respectively.)

Single Programming Documents (SPDs) areagreed between the Commission and the MemberState following negotiations over the RegionalPlans submitted by the Member States. The SPDsreflect the economic, social and environmentalneeds of the respective regions and set out multi-annual programmes of action required to promoteinternal and external cohesion within an agreedfinancial envelope. The previous tranche coveredProgrammes for the period 1994–9.

Environmental profiles

In pursuit of the EU’s environmental policies, arevision of the regulations governing the StructuralFunds was undertaken. In the 1994 tranche,Regional Plans were required to contain anappraisal of the environmental situation of theregion concerned and the impact on it of the stra-tegies and operations proposed. ‘Protecting andimproving the environment’ should be a ‘hor-izontal’ aim of the Programmes. This means that,although the main focus will be the improvementof the economic and social conditions of the region,it must also be demonstrated that this can beachieved without damage to the environment.

The precise requirements of this appraisal werenot specified, but in 1993 the Commission issuedan Aide Memoire to the Member States to giveclearer details. It stated that the information shouldbe presented in an ‘Environmental Profile’, sub-mitted as part of the Regional Plan. This shouldindicate the most significant environmental issuesand acute problems in the region. The Profileshould be divided into three parts: a sectiondescribing key issues, a section describing the legal

and administrative framework and a description ofthe impacts of the Plan.

It should be noted that, although the Commis-sion only requires a broad review of impacts, it alsocalls for a description of the methods for avoidingenvironmental impacts and assessing alternativesof infrastructure development and regional aidcovered by the Plan.

Applying the environmental regulations to theStructure Funds in practice

Very few of the plans actually submitted from theMember States considered the impacts of the pro-posed Programmes on the environment, however.Most contained a straightforward description ofdesignated areas and key environmental issues inthe area without addressing how the proposedProgramme might affect this situation, other thanthrough specifically designed environmental mea-sures.

As a result, the new regulations made little dif-ference to the mainstream elements of the Pro-grammes. Without a formal framework for theimplementation of environmental considerationsinto the process, it was hard to define individualprojects in terms of sustainability. Environmentalinterests were difficult to defend when faced withproposals from development interests which didnot fit comfortably with the environmental objec-tives of the Programme, but which were not inbreach of any environmental legislation per se. TheStructural Funds, however, are limited publicmonies granted to promote sustainable develop-ment and therefore the projects benefiting fromthem should be required to demonstrate a greaterlevel of environmental performance than is thelegal minimum set for any project.

In March 1996, the European Parliament passeda resolution stating that the environmentalrequirements of the Structural Funds were notbeing adequately met, and that the Commissionshould improve its procedures in this regard. TheParliament may withhold funding for StructuralFunds if it is not satisfied with the improvements.

STRATEGIC ENVIRONMENTALASSESSMENT OF THE HIGHLANDS ANDISLANDS OBJECTIVE ONE PROGRAMME

The Programme

The Highlands and Islands of Scotland is a diverseregion on the Atlantic fringe of northwest Europe.It has a dispersed population for whom the pri-mary industries, tourism and food processing are

ASSESSMENT OF EUROPEAN STRUCTURAL FUND OBJECTIVES IN SCOTLAND

64 EUROPEAN ENVIRONMENT

very important sectors. Therefore, it is recognizedthat the economy of the region is dependent on themaintenance of a high quality environment. Thiswas stressed in the SPD of the Highlands andIslands Objective 1 Programme, which consists of£240 million of Structural Funds aid in total,including a series of Measures under a specificenvironmental Priority. The development of com-munications and transport infrastructure, tourismand primary industries also featured strongly inthe Programme, and these activities could haveimplications for the environment.

Therefore, the Highlands and Islands Pro-gramme Partnership (HIPP), the grouping thatadministers the Programme, was keen to ensurethat all of the activities which were funded wouldcontribute to the achievement of its environmentalobjectives. It determined to undertake an SEA of itsProgramme which would provide a systematicframework by which the funding decisions wouldincorporate environmental considerations.

Thus the SEA served to: (i) ensure that the agreedSPD took account of environmental considerationsand that the priorities and measures were imple-mented appropriately; (ii) generate guidance forapplicants on preparing projects; and (iii) provide aframework for the programme managementstructure and its partners to appraise projects.

The SEA was undertaken in 1996, two years intothe six year programme, and was funded half bythe HIPP and half by Scottish Natural Heritage(SNH), the wildlife and countryside agency whichacts as a competent environmental authority for theProgramme. The steering group included thePartnership Executive, SNH, the HighlandsRegional Council (as a representative of the localauthorities) and the Royal Society for the Protectionof Birds (representing the voluntary sector). Aconsultancy team lead by Environmental ResourceManagement was employed to undertake thework.

The process

The most important aspects of the process were:defining the key principles of environmental sus-tainability; assessing the components of the pro-gramme against these principles; and definingguidance for the operation of the Programme in thelight of this assessment.

Defining key principlesThe starting point of the SEA was the environ-mental objectives of the SPD which formed thebasis of the ‘Key Principles’ against which theProgramme was assessed. The Programme has thefollowing strategic objectives: strengthening the

region’s economy; alleviating the problems of per-ipherality andinsularity; strengthening the economic and socialstability of communities; preserving existing en-vironmental quality and ensuring the environ-mental sensitivity of future economic development.

In relation to the last objective, the followingmore specific objectives are listed: to foster sensi-tive economic development based on the region’senvironmental qualities; to develop the use of localrenewable resources; to incorporate environmentalenhancement into sectoral growth and diversifica-tion strategies and schemes; to promote goodpractice in environmental management, especiallyin small and medium-sized enterprises; and toimprove environmental training.

In addition, the Programme must be placedwithin the wider policy context, particularly that of

Table 1. Hierarchy of strategies and policies applicable tothe Highlands and Islands Objective 1 Structural FundsProgramme

InternationalAgenda 21UN Framework Convention on Climate ChangeConvention on Biological Diversity

EuropeanEC Fifth Environmental Action Programme

UKThis Common Inheritance (and subsequent

annual reports)Sustainable Development: the UK StrategyClimate Change: the UK ProgrammeBiodiversity: the UK Action PlanSustainable Forestry: the UK ProgrammeIndicators of Sustainable development for the

United KingdomScotland

Sustainable Development and the NaturalHeritage: the SNH Approach

Rural Scotland: People, Partnership andProsperity

National Planning Policy Guidance (NPPGs)Planning Advice Notes (PANs)

RegionalStructure PlansHIE Strategy for Enterprise DevelopmentHIE Strategy for Enterprise and the EnvironmentHighlands Regional Council Draft

Environmental StrategyRegional and Islands Councils’ and Enterprise

Network sectoral strategies (e.g. HRCIndicative Forestry Strategy, HRC RegionalPolicy Guidelines on Wind Energy, HRCProspects for Fisheries and Aquaculture in the1990s, HIE Aquaculture and Sea FisheriesStrategies, HRC Caithness Peat: Review ofSafeguarding and Promotion Policies)Local

SOAFD Guidance to Farmers and Crofters onEnvironmentally Sensitive Areas

Local Plans

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the EU, UK and the region itself. A review of policyobjectives relevant to environmental sustainabilityfor the Highlands and Islands Objective 1 SEA wasundertaken from the existing policy framework(Table 1). These policies, and those of the SPD itself,were then distilled into ten Key Principles (Table 2).To assist the study team in applying these criteriato individual measures under the SPD, a series ofmore detailed ‘Appraisal Questions’ was devel-oped for each principle (Table 3).

Assessing the measuresAn initial screening of the Programme was carriedout to identify those Measures which were mostlikely to lead to significant environmental costs andbenefits. This focused the effort of the SEA on themost important areas.

A pro forma Measure appraisal form was thenprepared incorporating the environmental sus-tainability principles previously identified for eachof the Measures comprising the Programme. TheAppraisal Questions identified under each Key

Principle were then used to assess the impact ofeach Measure. This identified whether the Measurewould lead to projects which were broadly in lineor in conflict with each Key Principle, and theprobable nature and extent of any adverse impactsor benefits that might accrue from their imple-mentation. There was no extraneous attempt toquantify these impacts as this would have beenextremely time consuming and would only give afalse impression of precision that is not reflected inthe accuracy of prediction that was possible.Rather, the assessment was qualitative and direc-tional.

An example of a completed appraisal form fromis presented in Table 4. The process of carrying outthe assessment required considerable and broadranging knowledge of environmental concerns sothat the appraisers could recognize the potential forthe many different types of impact that might arisewith the implementation of various projects indifferent environments. A small team of appraisers,with complementary backgrounds and experience,cross-checking each others appraisals and discuss-ing areas of uncertainty, was therefore used.

Following the assessment at Measure level theresults were brought together in a summaryassessment for each Priority.

Developing guidance for the Programme

Based on this assessment, a simple Guidance sheetwas prepared for each Measure for use by appli-cants for funds in the preparing projects and by theProgramme Executive and its Advisory Groups inappraising submissions. These sheets includeinformation on key environmental issues thatmight arise for each Measure. Opportunities forcreating environmental benefits through the Mea-sure, and for mitigating any adverse effects thatmight occur, are outlined. These Guidance sheetsshould help to ensure that the projects that are

Table 3. Appraisal questions for Key Principle 4: Maintain and Improve Natural Heritage Resources: Wildlife, Habitatsand Landscapes

Could the measure lead to projects which might cause loss of or damage to:Protected and endangered species (eg badgers, otters, bats, red squirrels, rare plants)?;Areas designated for their nature conservation or landscape significance by international, national or local

authorities or other bodies?;Other natural or semi-natural areas of importance to wildlife, in particular remnant green spaces, urban fringes,

woodlands and forests, hedgerows, other wildlife corridors (e.g. river banks, disused railway lines)?;Sites of importance for their unique geology or physiography?

Could the measure lead to projects which occupy open countryside which might be accommodated withindeveloped areas on brownfield sites?

Does the measure encourage projects which could benefit natural heritage resources by increasing wildlife potential(e.g. creating green spaces and corridors), using natural landscaping, clearing dereliction and creating newlandscape resources?

Does the measure encourage projects which could enhance people’s enjoyment or benefit from natural heritageresources by improving access for recreation, education, scientific research?

Table 2. Key principles of environmental sustainability

Minimize use of non-renewable resourcesEnvironmentally sound use and management of

hazardous/polluting substances and wastesUse renewable resources within limits of their

capacity for regenerationMaintain and improve the quality of natural

resources: wildlife, habitats and landscapesMaintain and improve the quality of natural

resources: soils and water resourcesMaintain and improve the quality of historic and

cultural resourcesMaintain and improve local environmental qualityProtect the regional and global atmosphereDevelop environmental awareness, education and

training in environmental managementPromote public participation in decisions involving

sustainable development



supported by the Programme are the best envir-onmental alternative available to meet the objec-tives of each Measure.

DISCUSSION

The environmental policy objectives of the High-lands and Islands Objective 1 Programme aredefined only in broad terms and the SEA hashelped to define how they may be achieved. TheSEA offers a systematic method for scrutinizing theoverall shape of the Programme and its individualcomponents. Thus it should help to ensure that theProgramme does not conflict with its own objec-

tives and with the wider policy objectives of theEU.

In practice, the success of the SEA will be felt interms of the degree to which the projects that theProgramme funds are influenced by it. The Gui-dance issued as a result of the SEA may encourageapplicants to consider the environment throughoutthe development of their project, and it shouldimprove the consideration that is given to theenvironment during the decision-making processfor applications. However, the weight attached tothe environmental issues that are identified as aresult of this process will be a matter for the Pro-gramme’s decision-makers to address.

Table 4. Example of completed measure appraisal form

Priority: 1 Business development

Measure: 5 Provision of new sites and premises for SMEs

Key Principle Assess-ment

Comments

Minimize use of non-renewable resources �/ Potential for impacts to be adverse or beneficialdepending on, e.g. transport and buildingenergy efficiency, sustainability of constructionmaterials, flexibility of accommodation forfuture uses

Environmentally sound use and managementof hazardous/polluting substances and

wastes

�/ Impacts depend on appropriateness of premisesfor processes involving hazardous materials andwastes (.g. material storage facilities, sewerageand surface water drainage arrangements, etc.)

Use renewable resources within limits ofcapacity for regeneration

? Potential beneficial impacts from use ofrenewable resources in construction materials

Maintain and improve the quality of wildlife,habitats and landscapes

�? Potential for adverse impacts as a result of newdevelopment in sensitive areas of high naturalheritage quality

Maintain and improve the quality of soils andwater resources

�/ Potential for impacts to be either adverse orbeneficial depending on whether actions reduceor contribute to contaminated/derelict land

Maintain and improve the quality of historicand cultural resources

�? Potential for adverse impacts as a result of newdevelopment in sensitive areas of high qualityhistoric and cultural resources

Maintain and improve local environmentalquality

�/ Potential for impacts to be either beneficial oradverse depending on land take (greenfieldversus brownfield), renewal of existingbuildings, effect on townscape quality and senseof security/safety, etc

Protection of the atmosphere (global warming d

Develop environmental awareness, educationand training

d

Promote public participation in decisionsinvolving sustainable development

d

Overall assessment �/ Potential for both adverse and/or beneficialimpacts, depending on specific circumstancesand extent of consideration given toenvironmental requirements in site location anddesign

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EUROPEAN ENVIRONMENT 67

This SEA was applied to a Programme for whichthe SPD had been agreed and which was mid-waythrough its operation. Therefore, it had to consideralternative means of achieving the Measures thathad already been set out and was not in a positionto propose alternative Measures for the Pro-gramme. Nevertheless, the method could beapplied to a Structural Fund Programme during itsdevelopment, so that it could be used to influencethe final SPD. It is hoped that the method devel-oped by the Highlands and Islands Objective 1Programmemay be of benefit to other Structural Fund Pro-grammes.

CONCLUSIONS

Strategic Environmental Assessment could be auseful mechanism to ensure that the StructuralFunds serve to promote sustainable development,as espoused by the EU’s Fifth EnvironmentalAction Plan. For this to be achieved, there must bea strong political will to achieve it. In particular, theEuropean Commission has an important co-ordi-nating role. It must guide the regions in developingthe process and applying it, monitor implementa-tion and revise the process in the light of experi-ence.

Indeed, the experience of the application of SEAto the Structural Funds throughout Europe hasimplications for the development of the proposedSEA Directive. Even though regulations are inplace to require SEAs for Structural Funds, theprocess which ensued during the last tranche didnot achieve the intended integration of environ-mental concerns into the Programmes. To someextent was this because the process had not beendeveloped at that stage and there was no estab-lished method or detailed guidance on how an SEAshould be undertaken. As a result, rather limited

environmental profiles were submitted by theregions and accepted by the Commission, withlittle impact on the environmental performance ofthe Structural Fund Programmes. Similarly, an SEADirective may not be successful in influencing theprogrammes and plans at which it is directed ifappropriate SEA methods have not been developedand tested in practice.

REFERENCES

Bradley, K. (1996) SEA and the Structural Funds. In: ThePractice of Strategic Environmental Assessment (Eds R.Therival and M.R. Partidario), Earthscan, London.

Commission of the European Communities (1992) FifthEnvironmental Action Plan, CEC, Brussels.

Commission of the European Communities (1993)Environmental Profiles for Structural Fund Applications,Aide Memoire to Member States, CEC, Brussels.

European Commission (1994) European CommunityStructural Funds Objective One Single ProgrammingDocument: 1994–1999: the Highlands and Islands, EC,Brussels.

Environmental Resources Management (1996) Highlandsand Islands Objective One Programme: Strategic Environ-mental Assessment, Environmental Resources Manage-ment for HIPP and SNH.

Robinson, R.G.W. (1996) Strategic Environmental ImpactAssessment for the Scottish Highlands and IslandsObjective 1 Region. In: EU Structural Funds—MoreValue for Money, Report of WWF Conference 27–28November 1995, WWF, Brussels.

Seamark, D. (1996) European Funding and Environ-mental Appraisal, Town and Country Planning, Dec.

Wilson, E. (1993) SEA: evaluating the impacts of Eur-opean policies, programmes and plans, EuropeanEnvironment, 3(2).

BIOGRAPHY

Arthur Keller, Scottish Natural Heritage, 2–5 AndersonPlace, Edinburgh, EH6 5NP, UK.

