SEA IN THE CONTEXT OF LANDTUSE PLANNING

analytical framework above, this approach could be termed as environmentalist, i.e. there areexpectations among national actors that the introduction of the directive could be used as alever to change national policy, not only as a way to introduce environmental aspects, but tostrengthen the spatial planning system. Some of these changes will be included in the revisedPlanning Act, inter alia; a new national planning level will be created with the preparation of aNational Planning Policy. However, the legislation resulting from the discussions on SEA, theSEA Act adopted in 2006 closely follows the approach of the SEA directive and thus doesnot reflect this expectation of SEA as an innovative instrument of change. The Englishapproach is largely based on continuing to build upon tools that have been in development inthe UK over the last decade; i.e. sustainability appraisal. Sustainability takes a broaderapproach including both social and economic considerations on par with the environmentalconsiderations. It appears to be the ruling view, both in legal guidance, as well as academicliterature originating from the UK, that the existing requirements on EnvironmentalAppraisal are further developed than those of directive, with more ambitious goals andrequirements that have been developed on the basis of experience of application in the UKcontext. However, the application of Sustainability Appraisal at the local authority level hasreceived the criticism of being vague, and reviews have illustrated that the results have largelydependant upon the interest and ambition of the local authorities. With the introduction ofthe SEA directive certain aspects need to be more defined, i.e. new requirements onenvironmental baseline data, consulting the public and authorities during that assessment, andnot least, how the results are integrated into decision-making. Coincidentally, theimplementation of the directive takes place at the same time as fundamental changes areoccurring in the English town planning system and the move from the preparation of localplans at the local authority level, to the introduction of local development documents that willeffectively replace local plans, unitary development plans and structure plans.Sheate et al (2001) presented three models for environmental integration, i.e. the‘Constitutional/legislative model’, the ‘Process/strategy model’ and the ‘Ad-hoc institutionalmodel’, for analysing the findings from the three countries’ approaches for introducing theSEA directive to their national legislations. Furthermore Sheate et al presented models ofSEA practice; ‘EIA inspired SEAs’, ‘policy analysis/appraisal inspired SEA’, ‘policyintegratory SEA’ and ‘Ad hoc mechanisms of environmental integration’. Applying themodels it becomes apparent that the experience of actual application include a mixture of thedifferent model of environmental integration and SEA practice.On the basis of those models, he following conclusions can be made:The Swedish approach of introducing SEA resembles largely the ‘Constitutional/legislativemodel’ in that it introduces minimum requirements for SEA in the existing environmentallegislations, i.e. the Environmental Code. Furthermore, the SEA requirements are introducedin the same chapter as the previous requirements on EIA, and the same authority isresponsible for preparing guidelines for the two processes, and resembles in that way one ofSheate four broad models of SEA practice (Sheate et al 2001) ‘EIA inspired SEAs’. However,the SEA introduction also involves other parties, most notably The National Board ofHousing, Building and Planning (Boverket) and the Planning and Building Act where theapproach could be argued to bear stronger resemblance to the ‘Process/Strategy Model’.The Icelandic approach to the SEA introduction also involves specific legal proceduresthat impose duties on public bodies (i.e. Constitutional/legislative model), but in the Icelandiccase the separation from EIA has been an explicit objective during the introduction of thedirective. Furthermore, the connection to the land use planning system has been strongduring the introduction of the directive, and the introduction of SEA in parallel to therevision of the Planning and Building Act has been an important influence, even to the extent108