Climate change and environment impact assessments (EIA): Unpicking the EIA regulations (2017)

By Mark Burrage, RSK Principal Environment Planner, and Danielle King, RSK Environmental Risk Analyst

The climate emergency features regularly in the news, but the details about how to respond to it are not always clear. The Town and Country Planning (Environmental Impact Assessment) Regulations 2017, however, have provided the EIA community with new tools to make its voice heard. As with all new things, we must understand the details so that we feel comfortable and confident with the new regulations and about how we can make the EIA process more impactful.

Climate is mentioned only five times in the 2017 regulations: three times as an environmental factor to be affected; once as a driver of major accidents and/or disasters; and once as a cause of developmental vulnerability. Further clarification is given in Schedule 4, the section detailing the contents of environmental statements, which identifies greenhouse gas emissions and impacts relevant to adaptation as examples of factors to consider.

As climate change was not mentioned in the 2011 regulations, the 2017 guidelines gave climate change greater focus in the EIA process. We have interpreted its inclusion in several ways:

• As an environmental factor to be affected, it is comparable with other factors such as heritage and habitats, and it gives rise to a specific technical chapter.
• As a driver of impacts, it should be considered alongside existing accidents and hazards and, perhaps more accurately, as a factor to consider when addressing how likely and how severe these events may be.
• As a driver of developmental vulnerability, the wording is prescriptive insofar as consideration should be given to the development itself, not (in this way) to the wider environment. In this case, climate change is a driver of impacts and mitigation measures. Although this process is very familiar, the specific inclusion of climate change as an impact driver requires further exploration.
• It is considered a driver of impacts relevant to adaptation, where the adaptation may be relevant to the development of the wider environment. Here, the ability of the environment to adapt to impacts needs to be looked at over time.

RSK has already built on its approach using the Institute of Environmental Management and Assessment guidance on resilience and adaptation, which predates the 2017 regulations. Our approach includes appointing a climate change coordinator and adopting a climate projection following the UK Climate Projections. RSK’s climate change coordinator will ensure that climate change is consistently considered through the impact assessment and design process.

Our experience has been mixed, as regulators, technical specialists, designers and clients vary significantly in their responses. Clients and designers already respond to a wide range of environmental drivers, and it is not always clear that adding climate change to the design development process is an improvement. More developed guidance, such as BREEAM and the Greater London Authority sustainability requirements, provides a more familiar route. This is apparent where more robustly enforced guidance, policy and legislation are present. Currently, within the Town and Country Planning Association arena, guidance for specialists and regulators is patchy, which leads to divergent opinions and approaches.

Finally, the complexity of climate change often makes considering it disproportionate for all but the largest developments. This is arguably the most difficult issue to address because the various ways that climate change is considered dictate that analysing the issue is neither simple nor quick. Rather, it risks developing environmental statements that are overly long and cumbersome.

Despite these challenges, including climate change in EIAs is welcomed, and much more work is necessary if we are to give the climate emergency the weight it deserves to deliver the benefits EIAs can bring to humanity.

In immediate terms, we can enhance the reputation of clients and projects, assist in reducing short- and long-term costs by enhancing project resilience, and help to manage conflict by identifying synergies and bring about win–win solutions, including supporting ecosystems services.

More widely, the impending threat of catastrophic climate impacts is unavoidable. But the EIA community plays an important role in informing and shaping the response. Although government policy is always a question mark, this is a personal and professional challenge to which we look forward.

For more information on RSK’s EIA and climate change services, please contact Mark Burrage, mburrage@rsk.co.uk, +44 (0)1442 416695, or Danielle King, dking@rsk.co.uk, +44 (0)7918 887713.