Select Committee on Transport, Local Government and the Regions Memoranda


Memorandum by Gifford Consulting Engineers (PGP 21)

THE PLANNING GREEN PAPER

  I refer to Press Notice No 38 of Session 2001-02, dated 31 January 2002 and hereby submit a memorandum to the Committee. My comments relate specifically to the procedures for scrutinising major development projects. Having been an expert witness at Terminal 5 Heathrow I can appreciate the desire to introduce new measures to speed up major planning decisions and safeguard public debate. Careful consideration needs to be given to the ways in which any new procedures fit with European and UK legislation, not least the Human Rights Act, the (forthcoming) Strategic Environmental Assessment Directive and the Aarhus Convention for public participation.

  The work of the Parliamentary Office of Science and Technology (Postnote Number 173) is a very useful starting point and should be applauded.

  The following comments arise from about four years of work directing a unique team within the Environment Agency's National Centre for Risk Analysis and Options Appraisal in Westminster, developing and contributing towards integrated appraisal tools. The team consisted of environmental specialists, a social psychologist and economists attempting to develop truly integrated tools and techniques for use within the Agency and also parallel initiatives particularly in central Government (DTLR, DEFRA and MoD). An integrated approach is essential to avoid the pitfall of developing approaches that are biased towards one discipline (eg. towards environmental disciplines). A list of peer review papers and publications arising from this work and other relevant sources are listed at Appendix A. These were written before leaving the Agency on 1 January 2002 to work for Gifford and Partners.

  One example of this work is the Development of a policy appraisal checklist for the Environment Agency (Pollard and Brookes, 2001). This is illustrated by the flow chart at Appendix B. This is a simple tool, designed to allow policy makers in the Environment Agency consider the possible environmental, social, economic and resource use impacts of the policy options available to manage risks, and to allow the monitoring of impacts of policy options selected. This approach drew upon previous practical experience of policy and integrated appraisal overseas (eg the e-test developed in the Netherlands) and work in England and Wales (eg by DETR/DTLR and the Cabinet Office). The approach has been subjected to road-testing within the Agency and it is intended that the process will be iterative. This is an initial screening tool and more prescriptive techniques (such as EIA, cost-benefit analysis etc) can subsequently be applied when the circumstances warrant more detail.

  In developing appropriate techniques for scrutinising major infrastructure projects it is recommended that a series of key steps should be followed:

  Step 1.  Establish the decision context, including identification of decision-makers and key stakeholders.

  Step 2.  Define the aims of the appraisal, based on established principles of proportionality, consistency, transparency and iteration.

  Step 3.  Choose a detailed method proportional to the task in hand (eg ease of use; science based; data availability; manpower requirements; audit trail etc).

  Step 4.  Adopt/develop/agree environmental, economic, social and technical objectives, criteria and sub-criteria, thresholds and indicators. Use established methods to derive criteria; grouping etc.

  Step 5.  Trial method (involving relevant specialists) and undertake sensitivity testing.

  Step 6.  Draft user guidance.

  Step 7.  Undertake peer-review.

  Step 8.  Produce final guidance.

  Step 9.  Initiate long-term road testing and review.

  Research (by the Environment Agency) has shown preferences amongst a large number of practitioners in this field for an "ideal" appraisal to be:

    —  based on sound science, rigour, and factual information.

    —  integrate but not dilute expertise.

    —  focused on outcomes.

    —  cost-effective and affordable.

    —  easy to follow.

    —  undertaken by an independent body.

    —  not swayed by special interests.

    —  quantitative where appropriate.

    —  a balance of environmental, social and economic concerns.

  I trust that this information will prove useful to your Committee. Please let me know if you require further information or clarification.

Dr Andrew Brookes

Associate—Environmental

for Gifford Consulting Engineers

APPENDIX A.  SOME RELEVANT REFERENCES

  Brookes, A, Eales, R, Fisher, J, Foan, C and Twigger-Ross, C (2001) An Approach to Integrated Appraisal: Progress by the Environment Agency in England and Wales., Journal of Environmental Assessment Policy and Management. Vol.3., 1, 95-122.

  Department of the Environment, Transport and the Regions (1998) Policy appraisal and the Environment, DETR, Eland House, London.

  Department of the Environment, Transport and the Regions (1998) A new deal for trunk roads in England: understanding the new approach to appraisal, DETR, Eland House, London.

  Department of the Environment, Transport and the Regions (1999) Proposals for a good practice guide on sustainability appraisal of Regional Planning Guidance, DETR, Eland House, London.

  Department of Trade and Industry (2001) Towards more sustainable decisions, The Foresight Programme, DTi, London.

  Pollard, V and Brookes, A Development of a policy appraisal checklist for the Environment Agency of England and Wales., Journal of Environmental Assessment Policy and Management. Vol.3.,4, 533-559.

  Royal Institute of Chartered Surveyors (2001) Comprehensive Project Appraisal: towards sustainability. RICS, Parliament Square, London SW1P 3AD.



 
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