SEA IN THE CONTEXT OF LANDTUSE PLANNING

that the directive has spurred the discussion on a new national planning level. Hence it can beclaimed fall into the category of the ‘Process/Strategy Model’ or the ‘policy analysis/appraisalinspired SEA’.In England the SEA requirements are introduced by a separate SEA regulation.However, the introduction of SEA is integrated in the institutional tools that existing for theplanning system and hence would closely resemble ‘policy appraisal inspired SEA’ accordingto the categories presented by Sheate et al (2001). However, meanwhile the SEA introductionis explicitly affected by an existing tool with similar objectives of integration, namely thesystem of sustainability appraisal that has been a regulatory requirement in England since1992 for local development plans and will be introduced to an existing practice ofsustainability appraisal. The reference to EIA and environmental protection is minimal in theEnglish approach. Applying the triple structure presented above, the transposition of thedirective in England assembles the minimalist approach, with the main objective of fulfillingthe EU requirements. At the same time, much of the intentions of the directive have in recentyears been implementing by the introduction of environmental appraisal as well as recentchanges in the spatial planning system. It could therefore be argued that the English style ofimplementation falls into the intentionalist category of implementation.In summary it can be claimed that the three countries studied have chosen differentframe of reference for the introduction of SEA, e.g. the framework provided by EIA, theland-use planning processes and the practice of sustainability appraisal.A comparative summary of the three countries’ introduction of the SEA directive ispresented below:109