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4. Environmental space and environmental policy assessments

4. Environmental space and environmental policy assessments1

4.1 Introduction

This chapter examines the potential application of the "environmental space" concept to environmental impact assessment (EIA) and policy analysis. The point of departure is that the environmental space concept has two central implications for such analysis:

Firstly, the traditional emphasis in EIAs has been on outcomes of industrial and development processes, such as "end-of-pipe" pollution. The environmental space approach argues that to achieve sustainable development within a sound economy in Europe, it is necessary to complement this approach by considering changes in production and consumption patterns which would reduce material flows and pollution at source. This provides a practical linkage between environment and the economic and social dimensions of industrial society. Overall, the ES concept is intended to achieve a more pro-active management of the economy and the environment on sustainability principles, at the level of the nation, and for Europe.

Secondly, although environmental space cannot be exactly quantified on the basis of empirical science alone - meaning that goals and targets must rest partly on political judgement, and may need to be adjusted along the way - it can provide a correct directional policy guidance.

Generally, the promotion of environ-mental space has potential to influence production processes in sectors such as industry and agriculture, and to help build a broader, public constituency around sustainable development issues and to foster beneficial changes in consumption patterns. Environmental policy analysis incorporating environ-mental space could make a positive contribution.

More specifically, environmental space can provide a unifying element to assist the "vertical integration" of environmental policy in Europe from project level analysis (EIA) to the bio-regional, programme or national policy level (strategic environmental assessment, SEA, and indicator systems as discussed in the previous chapter) to that of the European Commission. Over time, this type of integration could help generate a more unified and coherent policy approach to sustainable development within the context of subsidiarity

The chapter has three sections. The first examines environmental impact assessment at the project level and the second considers strategic environmental assessment. A final section considers environmental space within a decision framework which integrates project-level EIA with higher order analyses, spatially, and in policy terms. The purpose is to discuss whether the environmental space concept could lead to better informed decisions leading to sustainable development. These will need to based on systematic linkage of the environmental aspects of policy decisions with the economic and social dimensions, and to the use of "top-down" policy and regulation to foster bottom-up innovation. Such linkage is at the heart of the ES concept.

Neither EIA nor SEA is defined here, on the assumption the reader is familiar with both.

4.2 Application to environmental impact assessment

Project-level EIA is institutionalised in the EU by Directive 85/337/EEC for Annex I and II projects, and the methodology is reasonably well advanced for predictions of biophysical impacts. EIA is a useful and important aspect of project appraisal, and there is no reason to alter this statutory function. As with many types of systematic project analysis, the EIA is necessary, but not sufficient, for informed decision-making, and there are advantages to furthering the integration of environmental space analysis into EIA.

First, without adjusting the statutory functions of EIA, the analysis could be expanded to encompass the impacts of a project on consumption of key resources identified within the environmental space methodology. This would provide an additional point of reference to assess the contribution of any project toward, or away from, sustainable resource use. A sustainable project ought ideally, over its lifetime, to contribute to reduced consumption of land (in one or more senses) and key materials as well as energy. If a project should entail increased consumption of some resources and less consumption of others, its viability might nevertheless depend on whether environmental space were most constrained for the former or the latter kinds.

More effective use of scarce materials and resources could generate not only environmental but financial benefits to the project or industrial plant, and to the national economy, as a result of encouraging innovation and efficiency in production and consumption processes. For example, a focus on reduction of material flows and energy for material processing can lead to reductions in the cost of production, leading to reduced product prices or enhanced profitability for the firm.

Second, providing a consistent environ-mental space methodology within EIA could generate more effective integration of EIA results at broader levels of analysis, for example, SEA of a bio-region or of national policy directed toward industrial sectors, such as chemical engineering.

Integration of environmental space into EIA presupposes, however, a certain level of political commitment to the environmental space concept at the EU and national levels, as is already the case in Denmark, and some relatively uncomplicated methodology for assessing environmental space. Such a proposal is unlikely to be acceptable if it is seen to be contributing to bureaucratic procedures, without understanding of the potential benefits. It might be useful, for a trial period, to encourage voluntary environmental space calcula-tions, rather than include these within the statutory requirements.

4.3. Application to strategic environmental assessment

Site-specific EIA is seldom sufficient to allow full integration of environmental factors into decision-making. There are many reasons: a project may be in reasonable fulfilment of an environmentally-misguided policy, such as an environmentallysound bridge which is part of a road building programme which will raise CO2 emissions; there may be cumulative impacts of more than one project in space and time, which are not significant at project level, such as a number of mining or forestry projects in a watershed; there may be drastic cumulative impacts of relatively insignificant actions (like driving a car on one journey, or one boat fishing at sea), which are not addressed in project-based EIA.

This situation is recognised by the Commission. For this reason, on the occasion of the adoption of Directive 85/337/EEC, and through the Environmental Action Programmes, the Commission has indicated its intention to develop Strategic Environmental Assessment for policies, plans and programmes. Spatially, SEA could also be applied at the level of the bioregion. The increasing acceptance of sustainable development as a legitimate goal of policy underlines the need for SEA. However, a formal SEA proposal has not yet been submitted to the Council of Ministers.

More so than at the EIA level, the environmental space concept offers significant potential to contribute to effective SEA, in generating positive environmental benefits by providing more detailed guidance on acceptable boundaries of resource consumption and pollution load, but also by forcing consideration of alternative technological and managerial approaches which can generate similar stream of benefits at reduced environmental costs. For example, the determination of agreed long-term environmental space targets could stimulate innovation in production processes, or in linkages between production and consumption (e.g., re-use or product recycling) by industry. This could be supported as required by policy innovation or financial incentives within a framework of eco-taxation.

Application of environmental space analysis at a sectoral level, such as to chemical industries, could generate innovation throughout the sector. Policies aimed at reductions in pollution or resource use may also be much more acceptable when applied to all firms in a sector, or indeed to all firms in the EU, rather than for any one firm.

It is important to stress that SEA is an informed assessment of the outcomes of programmes or policies, not necessarily a strictly quantitative measurement of that outcome. Like environmental space itself, SEA is to some extent directional. However, this is not a particular constraint, because the SEA will only be one of a number of relevant analyses to strategic decision making, which will also include the use of national and EU-level indicator systems. The SEA task is to inform the decision process so it is more likely that robust decisions will be taken, and to alert us to potential environmental dangers in the policy direction we are heading, so that precautions can be taken.

Here the directional guidance provided by the environmental space concept within an SEA framework could be a valuable addition to the range of analytic approaches for decision-making. Application at the strategic level implied by SEA will cause all "downstream actions" in the policy flow to become more infused with some genuinely sustainable outcomes, rather than just paying "lipservice" to the idea of sustainable development. This enabling of innovation by policy is complemented and supported in the other direction by a flow of information on good practice from the field to the policy process. This does presuppose, however, that an effective regulatory framework for SEA is developed by the EU and Member States, along with the necessary quality control, guidance, training and research and institutional strengthening.

4.4 Potential for better integration of project-level and strategic environmental assessment within the EU and Europe

One of the of the biggest challenges of sustainable development is to integrate levels of analysis and policy (project, fluvial, national, EU, Europe and so on) so that mutually reinforcing actions occur up and down the policy system and the ecosystem. This is a type of subsidiarity, which generates a coherent, sustainable development strategy at the European level, but without under-mining either national sovereignty or local, "bottom up" initiative, for exam-ple at the level of the community or the company.

The environmental space concept could provide a "common thread" throughout the decision framework and assist in making this higher level of integration more feasible. In a way, an hypothesis that this is possible is currently being tested within the Sustainable Europe Campaign, through which the "Towards Sustainable Europe" study is being followed up by FoE groups and research teams in some 30 European countries. Whether this is a reasonably successful approach will be determined during 1996 on return of all the national studies to the European co-ordinating centre, and their assessment. The returns will also help to validate and improve the methodology for assessment of ES at the European level.

Following this, further consideration can be given to the extent to which the application of the environmental space analysis at different levels within an EIA/SEA framework could contribute to the integration of policy and action for sustainable development in Europe.

One area of development is to use knowledge of environmental space to improve and expand policy targets for lower-order analysis such as EIA or cost-benefit analysis, to give these forms of project analysis "value-added" in terms of their contribution to understanding, not only the implications of individual projects in themselves, but their contribution to the broader thrust of sustainable resource use, either negative or positive. Negative impacts of large projects could indicate need for better science or better policy, which positive impacts of projects on resource use could provide models of industrial innovation worthy of replication.

Another area which should be of growing importance in policy analysis is in SEA focused on land use planning, and the integration of urban and rural development plans, and transport plans. Many Europeans are beginning to recognise that land is a vital but scarce resource, easily degraded or alienated, perhaps for a century or more, from sustainable use by such processes as poorly planned urbanisation, industrialised agriculture or the extension of road transport networks without consideration of the environmental and social implications.

It is difficult to conceive of a sustainable Europe which did not have in place sophisticated land use analysis procedures and land use planning processes, particularly at the level of the watershed. Environmental space calculations on the land resource could make a useful contribution. However, such calculations are hampered by unstandardised categories for land use; poor knowledge of the difference between the urban, suburban, rural and natural land use functions; and poor or non-existent data collection on the land resource. Considerably more research and analysis on European land use is required if sustainability is to be achieved. The environmental space concept can provide a framework for this analysis.

4.5 Conclusion

Although environmental space is about reduced and thus more efficient resource consumption, its basic thrust is not negative but positive. The concept challenges Europeans to use the best knowledge, best policy and new technology to achieve a high-quality standard of living within the boundaries of environmental space. Countries which are at the forefront of sustainable development will also be most competitive and at the leading edge of industrial development, and will have highest quality of life in the 21st century. The implication for application to EIA/SEA is that environmental space must be presented, not as a negative factor, but as a positive inducement to industrial innovation, and as a sophisticated addition to our "toolkit" of project and policy assessment tools.

1: Apart from minor revisions this Chapter has been written by Prof. Michael Carley, Hirriot-Watt University, Edinburgh.


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