Rethinking Environmental Statements


People currently starting in the workplace have not known a time without the internet. This is the Digital Generation born after 1995 who have grown up with digital technologies and are proficient with it.

Technology has shaped their world and how they see themselves. They understand and speak its language knowing how to navigate between real/virtual and public/private online worlds. They have opinions and freely share them and will not be told what they can and cannot have; compiling their own playlists, getting news direct from Twitter, creating their own Youtube channels. The Digital Generation expect data and information to be available online and to be able to interact with it.

Whilst we, like other consultancies, provide our reports and other outputs in a digital format, the driver for this is usually for ease of sharing or storage. It is likely that recipients tend to print technical documents to read or review them rather than read them on a screen.

Elena San Martin (Senior Environmental Consultant) and Tracey Hewett (Communications Manager) discuss how the Environmental Statement (ES), a key supporting document in development planning applications and marine licence applications, has evolved and what its future might look like.

TH Environmental Statements are big documents these days. Tell me about how the early ES looked.

ES I’ve been in this consultancy for more than decade and when I started they were relatively short – still evidence based but not the volume of evidence that is now required.

TH What’s the driver for more evidence - is it simply that we know more about the marine environment now?

ES Various drivers but yes if you have more evidence about a particular pressure or sensitivity of a feature to that pressure you will need to include that as part of your evidence to support your analysis of the significance of the impact and the need for any mitigation. The level of guidance available for undertaking assessments has also increased over time.

TH Guidance? As in legislation – has that changed?

ES No, the legislation has pretty much stayed the same. There have been some updates. But generally our understanding and interpretation of the legislation, mainly from precedents and case law examples, has improved or become more sophisticated. For example, initially the Habitats Regulations were not always applied in the same way for each project.

TH So things are more consistent?

ES Yes, I think assessments are generally more consistent but at the same time the bar keeps rising.

TH And what is driving this?

ES Usually it’s expectations of regulators or advisors, they differ depending on the type of assessment being undertaken. In England, Natural England provides advice on what should be included in an HRA in relation to protected sites and features. The MMO is the lead regulator in marine EIAs, the local authority is the lead in terrestrial EIAs and the Planning Inspectorate in Nationally Significant Infrastructure Projects (known as NSIPs). The amount of evidence and scope of these assessments (i.e. descriptions of the existing environment) has significantly expanded over the years.
For example, future baseline reviews of a receptor in the absence of the development are now routinely expected. And more recently we have been asked to assess the effects of schemes in relation to a Natura2000 features site’s potential i.e. how the protected site would be affected if it were managed appropriately and were in favourable condition.

TH How do we know?

ES Well it’s based on how receptors have developed historically over time and we use proxies/models and expert judgement.

TH What? That’s really hard! How do you know what’s going to happen naturally…anything could change.

ES Yes, it is tricky. There’s never the perfect evidence base so there’s always a level uncertainty because of that and because of the regulators and advisors needing to be certain. They ask for more and more evidence. So these documents are becoming very lengthy.

TH OK, another question. I wonder about the shadow of the precautionary principle –whether because decision-makers have either a stop or go stamp, do they open an ES with an open-mind or because of the precautionary principle do they open it with a presumption of “No, now demonstrate to me why it should go ahead” – are they looking for green lighting or for reasons to use the red stop stamp?

ES That’s tricky to answer. You get a good indication of what the decision makers are expecting and looking for in the ES at the pre-application stage.

TH Sounds like an exam, sounds like a scorecard

ES A lot of the time it’s not black or white. And depends on the individual you are dealing with. The case officer might not have the depth of knowledge to make the decision. Whereas we, as a consultancy, learn over time and build on past evidence with new science so naturally the documents get bigger.

TH So, we have adapted our ES to meet their needs?

ES Yes. It’s a trade off. I am sure we all want streamlined documents but they also require sufficient evidence so it’s a bit of both.

TH What’s the content of the document?

ES Certain content is stipulated in the EIA regulations – non tech summary, scheme description, method, baseline and assessment of effects. The key elements that have grown in volume are the baseline and the impact assessment sections. So they end up being rather large documents – several volumes if they are for a big development.

TH So, they are proportionate?

ES Yes and you are also largely guided by stakeholders on what their expectations are and on the required scope for the assessment

TH OK, although it’s laid down in legislation, it’s almost that the receiver of the developer’s Environmental Statement gives an indication of content and things that concern them.

ES Exactly, during consultation they might tell you where you need to give more information to satisfy their concerns or help them make an evidence based decision.

TH It sounds like the ES is basically a document for decision-makers but it has multiple types of reader including the public. So let’s imagine 5-10 years from now. Everyone has embraced digital how do you visualise things changing from where they are now. What do you think an online statement might look like?

ES It would be nice for the main body of the ES to be far more succinct and if people want more detail they could drill down to it.

TH Could you also present it differently? Could surveys be an infographic as we interpret the data rather than talk about what the graph shows? Could they be more interactive?

ES We could use infographics. But some stakeholders would still want to see what and how data have been analysed or processed.

TH So, we could provide a means of carving it all up to make it relevant and easy depending who the reader is?

ES Yes.

TH And if we are presenting this all online then it could almost be like a microsite about the proposed development or activity.

ES Yes it could. Especially as no one reads the entire document. People read the part that is of interest to them. I think even now an ES could be indexed better so that the reader could easily find what they want to know. Maybe a microsite would function even better as you could use different ways to get to the same information and the technical documents would all still be behind it.

TH Yes, so we could design different “user journeys” for the different stakeholders that lead to the same pages but give them different pathways. You could also present some of the information as online maps like GIS with clickable points for where a survey was and then when you click on it the infographic pops up.

ES Good idea, you could have an online map of the site and then you could interrogate the data and related reports. Yes, that would be really good. But obviously this would require a lot more creative thinking and that’s not what the technical teams are necessarily best at and as a consultancy that sells time it would be more expensive.

TH Yes, but it might not be much more time. Maybe in the future there are specific roles for online communication specialists who bring it all together with you to create this online document. The technical specialists still create the ES and then you work with the Coms Team about presenting the information, the format.

ES OK. So we provide both; because some want a better way of dealing with these big documents and because increasingly people will prefer this way of interacting with information and data.

TH And it would work for engaging with the public too. They could engage 24/7 and you could use it as a tool at public exhibitions. You could have a really big interactive screen – like in a crime drama – where you could swipe to things that interest them. It would all be there. How transparent! I can see it being like this in the future or we might even be wearing virtual headsets.

ES It would be interesting to know how this might be received; if it would be welcomed by the regulatory bodies.

TH Well, they would still have the usual technical statement and associated elements. There would just be two ways of serving up the information; the traditional document and the interactive digital way.

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Tracey Hewett

Communications Manager

+44 (0) 2380 711 844


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