sustainable development (HMSO 1994, Stationary Office 1999). The two processes bearmany similarities, although the approach integrated in Sustainability Appraisal includes abroader approach, with the aim of integrating social, environmental and economicconsiderations into the plan preparation. The new aspects introduced by the <strong>SEA</strong> directiveinclude a further focus on the environmental considerations, as well as requirements on theconduction on the assessment, including environmental baseline, prediction methods andconsultation. The ODPM’s Practical Guide for transposition of the EU requirements on <strong>SEA</strong>to the English planning system identifies the possibility of continuing the already establishedpractice and demands on Sustainability Appraisal. The guide states that those responsibleauthorities that so wish can cover the full range of SD issues in their assessment, i.e. alsoincluding social and economic effects of their plans and programmes in addition to theenvironmental effects. On the basis of the review it can be considered likely that thoseauthorities that already have some experience of sustainability appraisal will continue on theprocess established, with the necessary addition to fulfil the legal requirements of thedirective. This has raised some concerns among researchers that the focus on thesustainability appraisal will be at the cost of the environmental components in the assessment(Jones 2007).7.4 Implications of the different planning contextsThe three countries represent different approaches to land use planning, both with respect tolegal structures, roles and levels of government, as well as the history of the planning system.The English planning system is by far the most established, both as a history of statutoryplans as well as planning as a separate profession. Land use planning is Iceland has the mostrecent history of the three countries. Although the first Icelandic planning Act dates to 1921the present planning system is based upon a Planning Act from 1997 that restructured theland use planning, including placing the responsibility for planning is largely placed with themunicipalities, which was previously with the national Planning Agency. In Sweden land-useplanning has been characterised by strong position of the local authorities in land useplanning, which is however regulated by requirements on consultation and participation inthe planning process and the consideration of environmental aspects.All the three countries have a most developed system of statutory planning at themunicipal level with the preparation of plans encompassing the whole of the municipalityarea as well as detailed plans covering detailed parts of the municipalities. None of thecountries have a history of planning at the regional level, nor spatial planning at the nationallevel although all the countries have recently developed tools for establishing planning atthose levels with the development of Regional Spatial Strategies (England) and Regional Plansin Sweden and Iceland and coordinated sector plans and the national level. Hence, withregard to the application of the <strong>SEA</strong> requirements nationally, the relation between the legalintroduction at the national level and the level of implementation, i.e. the municipal/localauthority level stands in focus. All the countries have, or are in the process of revising thenational planning legislation, which has bearings of the application of <strong>SEA</strong>.In the case of Sweden, the planning system is currently undergoing a revision, with themain aims of simplifying the system and making it more effective. Previous legal revision in1997, strengthened the role of the municipal comprehensive plans (MCP) and underpinnedthe requirements on environmental aspects in planning and the municipal authorities have atradition of environmental and sustainability initiatives with the support of centralgovernment, most notably within the context of Local Agenda 21 (Bjarnadóttir and Bradley2003). The requirement of impact assessment in the preparation of municipal comprehensiveplans has been included in the Planning and Building Legislation since 1997, so some104
experience of assessing the plan’s impacts was established prior to the introduction of thedirective. However, several studies have highlighted the challenged position ofcomprehensive municipal plans, identifying the deficiency in revising the MCP every-fouryears which is required according to law and a widespread view that the MCP is not the mostsuitable tool for decision making in land use matters in the municipalities (Riksrevisionen2005, Kommunförbundet 2003). The introduction of <strong>SEA</strong> is therefore made to a context of achallenged planning system, where there is a growing interest in working on strategies andnon-statutory programmes that fall outside the context of the directive, rather than revisingthe municipal comprehensive plan. At the same time, substantial experience exists within thefield of environmental objectives that have been introduced at the national level anddeveloped further at the regional and local levels, as well as widespread permeation of theconcept of sustainability through LA21 and other political commitment.In the case of Iceland, the introduction of the <strong>SEA</strong> requirements coincides with theongoing revision of the Planning and Building Act no. 73/1997 that proposes some majorchanges to the planning system. In the context of land-use planning, statutory planning hasonly been required at the municipal level, as well as there has been some experience of thepreparation of voluntary regional plans. Among the proposed changes is the introduction ofplanning at the national level for spatial planning i.e. that will coordinate planning of differentsectors in a national development strategy (Skipulagsstofnun 2003). In recent years, somedevelopment work has been conducted for environmental assessment of sector plans, thatgoes hand-in-hand with the development of sector planning, e.g. within the transport sector.Hence, it can be argued that the application of <strong>SEA</strong> is introduced at an important time in thedevelopment of the Icelandic planning system; expanding planning practice and exploringnew fields for introducing a more formal planning process, of which there is limitedexperience in Iceland (Theodórsdóttir 2003, Thorgeirsson 2003). In most of the cases theenvironmental assessment has been conducted as a part of a comprehensive planning processwhich is the most established planning process and includes requirements on consultations,public participations etc as a part of the Planning and Building Act. Despite of this theintroduction of the directive will call for several changes in the legislation and regulation onmunicipal planning, including the preparation of environmental assessment report, decisionmaking,information on decision-making and monitoring (Skipulagsstofnun 2003). In sectorplanning there is limited experience of plans and programmes, although several changes haveoccurred in recent years with attempts to develop new planning tools, e.g. legislation requiringthe preparation of a transport programme and programmes on forestry (Landshlutabundinskógræktaráætlun ) and soil reclamation (Landgrædsluáætlun). Within those sectors there is ashorter history of consultation as a part of the planning process the introduction of thedirective will pose a larger challenge (Skipulagsstofnun 2003).In the case of England, the planning system has undergone a substantial revision in therecent years, stipulated by the introduction of the Planning and Compulsory Purchase Act in2004. Among the changes introduced were changes in the role of local plans; from legalbinding instruments to more strategic documents; setting out the development proposals inthe local authority and accompanied with a map presenting proposals for land use. A furtherfundamental change is the strengthening of the regional level as a level for strategic planning.With regard to the application of <strong>SEA</strong>, those changes mean that England is the only countryof those included in the study that will have effective tiering within the <strong>SEA</strong> system, i.e. thestrategies proposed at the regional level that have bearings on land use and developmentstrategies the municipal/local level, have already undergone a Strategic EnvironmentalAssessment process. The increased responsibility of local authorities for creating strategicpolicies as well as the emphasis given to developing spatial planning at the regional level,provide statutory instruments that are compatible with the objectives of the <strong>SEA</strong> directive,105
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