Upgrading Britain's infrastructure - a constructive approach to a low-carbon economy
The UK needs significant levels of new infrastructure to renew ageing facilities such as energy, transport and water management to meet future demand and help deliver a low carbon economy, says Josh Fothergill.
However, many development proposals prove controversial and face strong local opposition. This is not limited to nationally significant infrastructure, but is also a regular occurrence on relatively small scale wind energy proposals.
The scale of investment needed in UK infrastructure is truly vast. Infrastructure UK - the Treasury's in-house unit - manages the National Infrastructure Plan, tracking 550 projects to be delivered in the next decade, requiring £310bn of investment.
Much of this investment will relate to energy and transport infrastructure; however significant work will also progress related to water, sewerage, flood and coastal management infrastructure.
Whilst some may consider the solution to be simple - propose "the right development" in the "right location" - such opportunities may not be realistic. This is because of the scale of the infrastructure needed and the timescale over which it must be met.
As a result, significant numbers of infrastructure proposals, which carry environmental and social risk, will pass through the UK's consenting regimes over the next decade.
The environment profession will have a vital role in delivering this much needed infrastructure but does it have the right tools to help secure the UK's economic and environmental future?
How effective are current consenting regimes in reducing environmental impacts of large infrastructure projects?
Whilst some infrastructure developments are consented by planning authorities, since 2010 nationally significant infrastructure projects (NSIP) have been managed directly by the Planning Inspectorate (PINs) - formerly the Infrastructure Planning Commission - with consent awarded by the relevant Secretary of State. As a consequence the policies used to consider environmental and social concerns in consenting have diverged.
Whilst such policies are generally in alignment there is only one process that provides a consistent basis for evaluating the significance of a proposal's environmental, and often social, effects - Environmental Impact Assessment (EIA).
EIA acts to reduce the environmental impact of development proposals and was introduced in the late 1980's through Directive 85/337/EEC. It ensures the environment is a key consideration when determining a development's consent. EIA is only required where a project is considered likely to generate significant environmental effects. Whilst the Directive is environmental by nature, many issues considered relate to social concerns, such as the effects on visual amenity and archaeology.
EIA is now the key tool used to manage the interface between new infrastructure and their potential environmental and social effects.
Over 25 years EIA's role has evolved shaping the design and location of development. It also increasingly generates financial savings for developers. For example, the Environment Agency EIA co-ordinators saved over£15million in 6 years through cost avoidance during the assessment of flood risk management infrastructure.
Cost avoidance was achieved for example when the Environmment Agency made over 15% of savings by forming local partnerships, by sharing costs with other developers. Costs were also cut by taking alternative approaches to archaeological assessment, generating over £400,000 of savings in 2010/11).
EIA's Future: Helping deliver the UK's infrastructure challenge?
EIA is very effective at managing potential environmental effects of infrastructure proposals, but must improve to meet growing environmental, social and economic challenges. In October 2012 the European Commission proposed significant revisions to the EIA Directive (2011/92/EU ).
Its stated aim being: to streamline EIA and improve quality and enhance consistency between Member States. However, UK environmental professionals should be wary of both the scale and scope of the proposals.
There are risks of introducing substantial new administrative burdens and opportunities for legal challenge without delivering comparable improvement in environmental protection in the EIA directive proposals. Further, the Commission’s proposals failed to recognise the increasing focus infrastructure developers now place on environmental considerations when developing infrastructure, as a result of improvements in corporate responsibility since the 1980’s.
Instead the EIA directive should further integrate the environment into infrastructure design and enhance decision-making, based upon:
- Beginning EIA earlier
- Requiring pre-application consultation
- Making the developer responsible for their EIA’s scope
- Reporting on the performance of mitigation
The result would drive improved consideration of the environment in design – avoiding adverse effects; enhance stakeholder buy-in – reducing delays resulting from objections; and increase confidence in assessment - delivering more focused outputs. This will deliver: “proportionate assessments that deliver improved environmental outcomes” and drive further cost savings to developers and other stakeholders.
The EIA Directive's revision must upgrade EIA ensuring it continues to play a key role in delivering the critical infrastructure needed to drive future economic, social and environmental prosperity.
Josh Fothergill is policy & practice lead at IEMA