SEA IN THE CONTEXT OF LANDTUSE PLANNING

on the subject, prior to the formal identification of the case studies as a part of the research.This included a review of SEA literature, including both research and practice reports, inorder to establish a basis of current discussions in SEA to date. Furthermore key publicationsin planning theory, as well as recently published articles debate current planning issues werereviewed as a part of the literature review, in order to identify relevance of issues discussed inrelation to SEA.Comparative analysisTwo major themes are in focus for the gathering of information from the case studies:• Firstly, aspects relating to the actual legal introduction of the contents of the directive2001/42/EC in the three countries; e.g. plans and programmes covered by the directive,the environmental assessment process (scoping, environmental reporting, consultation,relation to decision making, mitigation and follow-up).• Secondly, the aspects of land use planning in the countries studied, including the legalbasis, main actors, planning levels as well as other environmental initiatives.The information gathered by the case studies is analysed by a comparative analysis (Patton1990:402-406, 466-467). In the comparative analysis a set of indicators is chosen in order toidentify the pattern of convergences and differences (divergence) in the information gathered.The sampling of empirical information was carried out in two stages; firstly information wassampled in order to identify the research questions and secondly to identify the relevantaspect to be studied in the national case studies. The comparative description and analysis ofthe information gathered thus takes a starting point in the contextual aspects considered to beof relevance for the introduction of the directive; the national legal framework, the land-useplanning system, previous experience of applying SEA and the expectations attached to SEA.In the research the different modes of implementation are examined in the light ofsignificant characteristics of the planning system, such as; the administrative levels ofplanning, tiering of planning activities at different administrative levels, legal requirements onthe contents of the plans, government environmental policy and public participation. Theinteraction between SEA implementation modes and salient characteristics of the planningsystem is analysed and discussed on the basis on categories of implementation discussed byEmmelin and Lerman (2005):• Minimalist, i.e. with the objective of implementing the directive in the specific nationalcontext with minimum of disruption.• Intentionalist, i.e. aligning national legislation with the intention of the directive.• Environmentalist, i.e. use the directive as a lever to change national policy.In a study on the role of Strategic Environmental Assessment (SEA) in integrating theenvironment into strategic decision-making in all EU countries, as well as some non-EUcountries and international financial institutions, Sheate et al (2001) identified three keymodels of processes, institutions and communication mechanism utilised for environmentalintegration:• Constitutional/Legislative Model, i.e. specific legal provisions for environmentalprotection and integration in a country’s constitution or a ‘consolidated’ legislation orlegislation that imposes duties on public bodies.15