SEA IN THE CONTEXT OF LANDTUSE PLANNING

• a minimalist,• an environmentalist• an intentionalist approach.The second framework used for analysing the material is the presented by Sheate et al (2001)where the different context for SEA introduction is examined according to three differentmodels, i.e.:• Constitutional/Legislative Model• Process/Strategy Model• Ad-hoc Institutional ModelThis is in turn discussed with regard to the national actors’ explicit and implicit expectationstowards the directive interpreted from official documentation, i.e. legal texts, preparatorywork and official debated and discussions which gives an indication of the rationale of theintroduction of SEA to the national planning system.7.1. Introduction of the directive into different national legal contextsThe transposition of the Directive into national legislation occurred in July 2004 in Englandand Sweden and in Iceland in June 2006. In Sweden the requirements of the directive2001/42/EC were introduced as a part of the Environmental Code, introduced to Chapter 6,which also includes the requirements for Environmental Impact Assessment (EIA). In theother two countries the SEA demands are introduced in separate legal instruments; a SEAAct in Iceland and SEA Regulations in England, Scotland, Wales and Northern Ireland. Inthe preparatory work for the introduction of the directive into the Swedish system it is statedthat the requirements shall be introduced, to the greatest extent possible, in the existing legalframework for Environmental Impact Assessment (SOU 2002:97). On the contrary theIcelandic introduction of the SEA requirements strives to separate the SEA requirementsfrom the existing EIA practice, where it was stressed by the chairman of the environmentalparliamentary committee preparing the SEA proposition, that overlaps and linkages toEnvironmental Impact Assessment should be avoided, and stressed that the assessment ofplans and programmes is a separate and new instrument (Althingi 2006). In England theintroduction of the SEA is set against a background of over 10 years’ experience ofSustainability Appraisal and this experience is reflected in the guidelines and governmentalguidance for SEA introduction where the implementers are recommended to build upon theexisting practice of sustainability appraisal in the SEA introduction.The directions issued by the government for the Swedish implementation of thedirective were to ease the introduction of the new instrument into an already existingframework, building upon existing practice and knowledge. This aim is also to avoidduplication with the EIA process, with the objective that the processes will be bettercoordinated when integrated as much as possible in the legislation. This approach hashowever been criticised as instead of clarifying the process, it will add to the confusionbetween the two processes; what SEA will actually contribute with, as well as a confusionwith similar terms for the EIA and SEA processes and the usage of the same term for thereport presenting the results of respectively the EIA and the SEA processes (Emmelin andLerman 2005). When considered in relation to the origins of the SEA directive and thedebate on the differences and methodology of the EIA and SEA processes, Sweden has takena clear stance in the interpretation of SEA as an extended version of EIA, where the socialand economic aspects of sustainable development are taken care of within the planning98