Written evidence submitted by IEMA [FPS 168]

About IEMA

IEMA (Institute of Environmental Management Assessment) is the professional body for everyone working in environment and sustainability. It is the largest professional body for environmental practitioners in the UK and worldwide with 17,000 members. IEMA is an authoritative voice on Impact Assessment and for the past 30 years has been at the forefront of reform. We have remained an integral part of the consultation on change including previous modifications to regulations in the UK. An Impact Assessment Network, established in 2015, brings together skilled and experienced experts in IA and includes representation from developers, consultancies, statutory consultees, academia and others.

 

In this response we have provided a bespoke submission to the Housing, Communities and Local Government Committee (HCLGC) inquiry: The future of the planning system in England. It should be noted that we have already reviewed and responded to the Ministry of Housing, Communities & Local Government (MHCLG) Consultation on ‘Planning for the Future’ hereafter referred to as the ‘Planning White Paper’[1]

Focus on Impact Assessment

The focus of many stakeholders in response to the Planning White Paper has been on the proposed changes to the overarching plan making and the proposals to move to more zonal based planning. However, the Planning White Paper also proposed significant reforms to Environmental Impact Assessment (EIA), Sustainability Appraisal (SA) and the Strategic Environmental Assessment (SEA) regime, collectively we can refer to this as Impact Assessment (IA).

 

As the leading professional institute for IA, IEMA have therefore focused this response on this aspect of the planning system reforms. IEMA agrees with the need for impact assessment reform, however a quicker and simpler system must not reduce the existing protection IA provides to valued assets and people.  Furthermore, IEMA is concerned that the proposals are quite focused on ecological aspects of IA alone. Protecting and enhancing the most valuable and important habitats and species in England is important but is only one of many natural and social assets that need to be safeguarded.  Equally the role of IA and its influence on better development for the people that live there must be recognised and safeguarded.

 

The strength and value of IA is that it provides a holistic and integrated assessment on all aspects of plans and projects including population (social and economic), human health, biodiversity, species, habitats, land, soil, water, air, climate, material assets, cultural heritage, landscape and the interaction between these factors[2].

 

It is unclear from the Planning White Paper what this quicker framework will involve and the relationship between SEA at the plan level and EIA at the project level. The proposed follow up consultation on Impact Assessment in the Autumn of 2020 has not materialised and therefore many questions are left unanswered with respect to the fate of the IA regime and the shape of the reforms on these critical matters.

 

IEMA Recommendations

In the absence of firm proposals , IEMAs key recommendations to guide the IA reforms are to focus on the following priorities:

 

 

 

 

 

 

 

 

March 2021


[1] See IEMA’s paper on Levelling Up EIA to Build Back Better and IEMAs formal response to the MHCLG consultation here (bit.ly/34Hfikr)

[2]As required for example under 4(2) of The Town and Country Planning (Environmental Impact Assessment) Regulations 2017 (https://www.legislation.gov.uk/uksi/2017/571/regulation/4)

[3] Based on 432,200 planning applications in England in 2019 (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/875032/Planning_Application_Statistics_October_to_December_2019.pdf) compared to IEMA estimates of annual UK ES submissions ranging between 600 to 900 gives a conservative total of 0.2%.

[4] Screening remains a key target for current legal challenge as emphasised by a recent flurry of cases in 2020.

[5] A priority will be the documentation of commonly occurring impacts that we have a high confidence in being able to mitigate. This will further influence the proportionality agenda.