Introduction
Some EIA practitioners can fall into a familiar cycle of describing baseline conditions, assessing adverse impacts, evaluating significance, identifying mitigation measures and then presenting the residual impacts of a scheme after mitigation.
To a degree this ‘cycle’ may be encouraged by the common mitigation hierarchy now fully embedded in EIA practice and recognised in page 5 of IEMA’s Special Report on The State of Environmental Impact Assessment Practice in the UK (2011). This involves:
- trying to avoid or design-out adverse impacts in the first instance;
- followed by a desire to reduce or mitigate adverse impacts; and finally
- if neither of these outcomes are possible, then compensate for such impacts.
While this mitigation hierarchy has become commonplace for good reason, it generally focuses on the adverse impacts of a proposed development.
However, Schedule 4 of the EIA Regulations (2017) (as amended) directs that any description of the likely significant impacts in an environmental statement (ES) should cover, amongst other things, the “… positive and negatives effects of the development”. Furthermore, aside from what is set out in the EIA Regulations, for an ES to be considered comprehensive and robust it should present the reader or decision-maker with all of the likely significant impacts on the environment, both positive and negative, to enable a balanced judgment to be made.
There is seldom an occasion where a proposed development will have only negative impacts on the environment. In reality all development proposals are likely to have at least one significant positive impact on the environment and the ES should not be ashamed to assess any beneficial impacts and present any such findings in just as prominent a manner as would be the case for an adverse impact. Indeed an EIA practitioner is being diligent and helpful to the final decision-maker if they to do so.
Potential Sources of Beneficial Impacts
Of course the type of beneficial impact that may arise from a development proposal will very much depend on the nature of the proposal itself.
Andrew Martin – Planning’s (AM-P’s) has extensive experience undertaking EIAs for strategic scale mixed-use or residential-led new neighbourhoods and urban extensions, which are usually classified as ‘urban development projects’ under Schedule 2 of the EIA Regulations (2017) (as amended). In these cases, beneficial impacts can manifest themselves in some or all of the following topic areas:
- Land Use
- The delivery of new housing land can help to address an identified shortfall in a local authority’s five-year housing land supply.
- The extension of local foot and cycle paths can enhance the local network of Public Rights of Way.
- Socio-Economics
- Temporary employment opportunities are frequently created during the construction phase of a development.
- Where commercial floorspace is to be provided on-site, permanent employment opportunities can be created once a development is complete.
- The delivery of new education or health facilities which provide greater capacity than the need generate by a development alone can benefit the local community.
- The delivery of new homes that address a specific housing need, such as affordable or retirement living, can benefit the local community.
- Ecology
- It is increasingly common for the creation or enhancement of habitats on-site or nearby to result in a net biodiversity gain.
- Arboriculture
- Likewise the extensive planting of new trees or hedgerow on-site or nearby can result in a net arboricultural gain.
- Transport
- Increased public transport patronage can be achieved in the local community through the provision of new or enhanced services and routes.
- Improved highway safety can be achieved through physical highway works or other measures to reduce speed limits or speed awareness.
- Flood Risk & Drainage
- A decrease in localised flood risk and surface water discharge rates are frequently achieved through the provision of extensive SuDS on-site, including an additional allowance for future climate change and urban creep.
The above examples are by no means an exhaustive list. They do, however, provide an indication of the of the type of potential beneficial impacts that can be attributed to some urban development projects.
Conclusion
Increasingly beneficial impacts are being considered by local authority planning officers in their overall balancing exercise, when weighing up the advantages and disadvantages of a particular proposal and determining a planning application. As such AM-P is an advocate of assessing and presenting any relevant beneficial impacts in the accompanying ES.
This should encourage more stakeholders, including applicants, consultees, community groups and local people, to view the EIA process as not just an administrative assessment tool required to comply with certain regulations, but as a proactive and useful means to identify and examine the benefits (as well as the adverse impacts) of a development proposal.
At the very least considering beneficial impacts within an ES will help to present a more ‘balanced’ picture to the reader or decision-maker. At the most it could make a material difference to the final decision on a particular urban development project.
– Prepared by Mr Olivier Spencer, Director, Andrew Martin – Planning Limited, February 2020 –