The Effect of Environmental Assessment on UK Local Planning Authority Decisions
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Transcript of The Effect of Environmental Assessment on UK Local Planning Authority Decisions
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Urban Studies, Vol. 34, No. 8, 1237±1257, 1997
The Effect of Environmental Assessment on UKLocal Planning Authority Decisions
Christopher Wood and Carys E. Jones
[Paper ®rst received, July 1996; in ®nal form, January 1997]
Summary. Environmental assessment (EA) is intended to ensure that environmental considerations are properly weighed in the decisions made by local p lanning authorities on plannin
applications. This paper analyses whether, to what extent, and how, EA has in¯uenced LPA
decisions. Forty case studies were analysed by examining relevant documentation and conductin
interviews with participants in the EA process. EA appears to have had a gradual rather tha
a revolutionary effect on decision-making. Its ma in bene®ts have been the enhanced provision o
environmental information and, to a lesser extent, assistance in setting conditions and i
modifying proposals. However, these bene®ts are not occurring in all cases, and changes ar
needed if the expected advantages of EAÐbetter integration of environmental considerations int
project planning and decision-makingÐare to be fully realised in the UK.
Introduction
Environmental impact assessment (EIA) is
an anticipatory environmental management
tool wh ich is designed to affect decisions
about projects which might have signi®cant
ef fects on the envir onment. E I A should
in¯uence siting decisions about proposed
pro jects in tw o main ways. First, it sho uld
lead to the m itigation o f the adverse environ-
mental impacts of a project to the point
where the project becomes environmentally
acceptable (i.e. `sustainable’). When, by vir-
tue of the nature, scale or location of the
pro ject, its environmental disbe ne®ts, even
after mitigation, outweigh its economic and
other bene®ts, it should result in a decision
not to pr oceed.In the UK, certain planning applications
cannot be determined unless an environmen
tal assessment (E A) is carr ied ou t ®r st. Th
pr oponent of a project subject to EA is re
quired to prepare a document (an environ
m en tal stat em en tÐ E S) set tin g o ut i
environmental effects. The EA is a `materia
consideration’ in the decision made by th
local planning authority (LPA) on whether o
not to gr ant planning perm ission for the pr o
ject. While it is axiomati c that EA shoul
affect planning decisions, there has been lit
tle research to date on wh ether it actuall
does so. This paper presents the ®ndings o
an investigation of whether, to what exten
and how EA has in¯uenced LPA decision
on planning applications. T he paper comm ences wi th an ou tli ne o
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CHRISTOPHER WOOD AND CARYS E. JONES1238
the nat ure of EIA and an explanation of the
ways in which it affects decision-making.
Next, an overview of UK environmental
plan ning and the ro le of EA is pr esented.
This is fo llow ed by an explanation of the
methods employed in the investigation. Themain results of the research into the effect of
EA on LPA decision-making are then pre-
sented in ®ve sections, the ®rst of which
deals with the evaluation of the ES by plan-
ning of®cers. The next fo ur sections analyse
the in¯uence of EA: on the pl ann ing of®cer’s
report to the LPA planning committee; on the
plan ning committee’s decision; on the condi-
tions attached to the plan ning perm ission;
and on modi®cations to the project designed
to mitigate environmental im pacts. Finally, a
num ber of conclu sions abo ut the nature of
the UK E A process are drawn and several
recommendations for im provement are made.
Environmental Impact Assessment
EIA is a systematic procedure for consider-
ing the possible effects of a proposed project on the environment before a decision is made
on whether the project should be given ap-
pro val to proceed. Consu ltation and partici-
pati on are integr al to this procedure, wh ich
originated in the US in 1970 with the im-
plem entation of the National Env ironmental
Policy Act (Caldwell, 1989; Glasson et al.,
1994; Wood, 1995). This act can now be
seen to have anticipated the world’s concern about sustainable development, inter-genera-
tional equity, resou rce usage and the inte-
gration of environmental considerations into
decision-making generally (World Com-
mission on Environment and Development,
1987). EIA has subsequently been adopted
by numerous developed, and developing,
countries (Gilpin, 1995). Environmental im-
pact assess ment can also be applied to poli-ci es, pl ans and p rogram mes (see, for
example Glasson 1995; Wood 1995)
stages (not all of which are statutory require
ments):
Ð determ ining wh ether an EA is necessary i
a particular case (screening);
Ð deciding on the coverage of the EA (scop
ing); Ð describing the project and the environmen
in the ES;
Ð assessin g the magnitu de and sign i®canc
of impacts in the ES;
Ð pr esenting alternatives and mitig ati o
measures in the ES;
Ð review ing the ES;
Ð consultat ion and participation;
Ð syn thesising the ®ndings fr om con sultatioand reaching a decision; and
Ð mon ito ring the im pacts of a pr oject if it i
implemented.
Within Europe, the effect of EIA on sitin
decisions, while marked, has been gradua
rather than revolutionary:
Whilst a sizeable proportion of project
has been modi®ed to reduce their negativenvironmental impacts, in many cases th
mitigation measures used were only o
m inor or m oderate environm enta
signi®cance (Lee, 1995, p. 81).
In other countries, there has been a genera
consensus that the bene®ts of EIA outweig
its costs (Wood, 1995; Sadler, 1996). O
those taking part in a lar ge international sur
vey, 70 per cent believed that EIA always ooften contributed to more informed decision
making and 54 per cent felt that EIA pre
vented environmental damage. They also fe
that EIA conf erred im po rtant bene®t s beyon
informing decision-makers such as increas
ing environmental awareness and improvin
pr ofession al capabili ties (S adler, 1996 ).
EIA and decision-making. The literature concerning decision-making identi®es two type
of decision making model (Simon 1948
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ENVIRONMENTAL ASSESSMENT AND UK PLA NNING DECISIONS 123
set of explicit goals and alternative courses
of action and therefore to select the `best’
course of action to achieve the stated goals,
using the relevant data and criteria. The be-
havioural model recogn ises that in reality
hum an know ledge is often incomplet e, that the val ues that und erlie ob jectives are not
always shared, and that the capacity for ratio-
nal analysis of alter natives in complex situa-
tions is limited. Go als ar e therefore not well
de®ned (and are potentially con¯icting) so
that decisio n-m akers at tem pt to balance
con¯icting interests as best they can (Simon,
1948; Cohen and Cyert, 1965). These models
can be, and have been, related to decision-
making in the EIA process (Culhane et al .,
1987). The EIA process contains elements of
the tw o types of model and can be view ed as
a hybrid situation. Decision-making within
the EIA pr oce ss of ten involves many individ-
uals and can be very complex. The decision
will usually be in¯uenced by political press-
ure as well as by the environmental advan-
tages/d isad vantages of the propo sal in
question (Culhane et al., 1987; Kobus andLee, 1993).
Culhane et al. (1987) considered how EIA
could improve decision-making within the
US EIA system and described thr ee mod els.
The `r ational-objective model’ holds that the
documentation should be technically in-
formed, reasonably thorough and, most im-
por tant, unbiased . The use of mem bers of
different professions operating within a stan-dard procedure for decision-making should
make the process more ef®cient and is the
essence of the `internal reform model’. The
`external reform model’ focuses on external
pressures that reinforce environmental values
within decision-making. These three models
are all relevant to the UK situation where
elements of all are seen within local planning
authority decision-making.
ceived much greater emphasis from centra
gover nment since 1990 ( Her Majesty’
Government, 1990). Recently, the govern
ment has stressed the role of the plannin
system in achieving sustainable developmen
(Her Majesty’s Government, 1994). This rol has been given sub stance by new requir e
ments to integrate environmental consider
ations into all development plans (Davoudi e
al., 1996) and to subject plans to an environ
mental appraisal, and by the publication o
planning po licy guidance (e.g. Department o
the Env ironmentÐ Do E, 19 92).
T he basis of the UK plan ning system rest
in the right of central and local governmen
to cont rol all develo pm ent (i ncludin
changes in the use of land). All plannin
decisions must be made in accord with th
relevant development plan unless `materia
considerations’ indicate otherwise. In prin
ciple, therefore, environmental consider
ations are taken into account in considerin
all planning applications (Blowers, 1993). I
addition, certain development projects whic
are likely to have signi®cant environmentaeffects must also be subject to a separate EA
This is because the Euro pean directive o
EIA has been implemented in the UK b
means of various regulations, of which th
pr ovisions of the Town and Coun try Plan
ning (A ssessm ent of Enviro nmental Eff ects
Regu lations 1988, as am ended, for E nglan
and W ales apply to far m ore pro je ct
than those of all the other regulations pu together.
DoE has speci®ed that, when determinin
a planning application, the LPA must hav
regard to all the environmental informatio
(the ES, any further relevant information
and comments received upon the ES and th
application) as well as to other material con
siderations (DoE, 1988). It is a requiremen
that, in addition to normal planning consu lta tio ns, various bod ies be con sul ted wh en a
E A is under taken ( English N ature th
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CHRISTOPHER WOOD AND CARYS E. JONES1240
EA in the form of circulars and guidance
(DoE, 1988, 1989, 1994, 1995a; Land Use
Consultants, 1994a). In addition, LPAs have
been advised that ªconditions attached to a
grant of planning permission may incorpor-
ate mitigation measures proposed in an en-vironmental statementº (DoE, 1995b, para.
77).
Decisions on planning applications are
made by LPAs, but there is a right of appeal
against refusal. Appeal (and `called-in’) deci-
sions are taken by central government fol-
lowing a public inquiry chaired by a planning
inspector. Because LPAs deal with large
num bers of pl ann ing applications, the elected
members of planning committees normally
(but not always) accept the recommendations
of planning of®cers without signi®cant dis-
cussion (Cullingworth and Nadin, 1994;
Essex, 1996). However, the relative weight
given to environmental and to economic de-
velopment objectives by of®cers and elected
members will vary from place to place ac-
cording to local circumstances and the result-
ing political orthodoxy (Tewdwr-Jones,1995). Planning applications accompanied by
ESs would be expected to be more contro-
versial than routine applications. In such
cases, therefore, politicians might be ex-
pected to diff er more than usu al fr om their
of®cers in the weights they place on the
various relevant material considerations
(Kitchen, 1996).
The governm ent has stated that it expectsEA to yield certain bene®ts:
Environmental assessment techniques can
help bo th develo per s and public authorities
with environmental responsibilities to
identify likely effects at an early stage, and
thus to im pr ove the quality of both pr oject
planning and decision-making (D oE ,
1988, para. 7).
EA can affect planning decisions both di-
rectly and indirectly
tent, teno r and recommendatio ns of a plan
ning of®cer’s report to the plan nin
committee. Secondly, it may in¯uence th
nature of the decisio n made by the plan nin
committee. Thirdly, the L PA m ay attach con
ditions to any per mission w hich can bin¯uenced by the EA. Finally, EA can als
af fect the nature of the project throug
modi®cations to mitigate its environmenta
impacts. These m odi®cations may be made a
any of the stages of the EA process, from th
consideration of alternatives to the monitor
ing of impacts. These modi®cations may, o
course, themselves in¯uence the LPA’s de
cision about the planning application.
Indirect in¯uence of EA on decision-making
EA may also affect LPA planning decision
indirectly by way of the comments (whethe
written or otherwise) of those consulted b
the LPA, and of others who choose to partic
pate. These comments often have an im po rt
ant in¯uence on LPA planning decisions an
can be consciously ( or unconsciouslyin¯uenced by the EA and, in particular, b
the ES. On the other hand, some com ment
to the LPA may make no reference to th
EA.
Previous Studies of EA and LPA Decision
making
Un ravelling the various facets of decisi onmaking about planning applications ac
companied by an ES is clearly dif®cult. It i
therefore not sur pr ising that little speci®
guidance is provided by the existing litera
ture. Studies that have been un dert aken o
the EA pr ocess wi thin the UK , includ ing th
stages relevant to aspects of decision-mak
ing, include:
Ð Lam bert and Wood (1 99 0), on the basis o
3 detailed case studies;
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ENVIRONMENTAL ASSESSMENT AND UK PLA NNING DECISIONS 124
sis of 32 extractive industry EAs for appli-
cations submitted b etween 1988 and 1991;
Ð Fro st (1 99 4), using a sample of 30 case
studies;
Ð L ee et al. (1994), on the basis of a re-
examination of previous cases and a num-ber of further case studies;
Ð Nelso n (199 4) (see also Land Use Consul -
tants, 199 4b), an analysis of a sam ple of
30 ESs;
Ð Fuller and Binks (1995 ), based on replies
to a qu estionnaire distr ibuted for the In ter-
nation al Associa tion of Im pact Assess -
ment study on the effectiveness of EA;
Ð Jones and Wood (1 995), usi ng a sample of
10 EA cases subject to public inquiry;
Ð L eu et al. (1995), using a sample of 167
local authorities;
Ð Glasson et al. (1996), examining ES qual-
ity based on a sample of 25 matched pairs;
and
Ð Hughes and Wood (1 996), based on a
study of 5 formal and 5 informal ESs.
These studies have yielded impor tant resul ts
relating to the different aspects of the direct
and indirect in¯uences of EA on decision-
making outlined above.
In¯uence of EA on planning of®cers’ reports.
During the early years of the EA process in
the UK , Wood and Jon es (1 991, 1992) re-
vealed that the majority of the LPAs needed to requ est info rmation additional to that pro-
v id ed in th e E S t o m eet t heir d ecisio n-
making needs. This was reinforced by Kobus
and Lee (1993) and complemented by Jones
and Wood (1995) who found that planning
inspectors also often requested additional in-
formation to supplement the ES in inquiry
cases. In a more recent study, Hughes and
Wood (1996) reported that all the planningof®cers’ reports contained a summary of the
main ®ndings of the ES and also outlined the
familiar with, the recommended EA pro
cedure contained in DoE guidance.
Jones and Wood (1 995) fo und that plan
ning inspe ctor s also make use of ESs i
drawing up their reports, but that the ES wa
generally given less weight than the add tio nal evidence pr esented at the inquir y.
In¯uence of EA on planning committee deci
sions. An early study by Lambert and Woo
(1990) reported that LPA response to EA
was very variable and that decisions ap
peared of ten to have lit tle regard to th
®ndings of the EA. However, Kobus and Le
(1993) reported that in about 50 per cent o
cases the LPA judged the ES, and the result
of consultations based upon it, to be of im
port ance in determ ining the planning appl
cation. They also found that the returns from
consultations were more likely to be `ver
important’ in determining the planning appli
cation than the content of the ES . Interest
ingly, other material considerations wer
judged to be more impor tant than enviro n
mental considerations in determining plan ning applicati ons in the major ity of cases
Lee et al . (1994) found that other materia
considerations were considered to be mor
important in making decisions in more tha
half the cases. T hey also reported that bo t
the contents of the ES and the consulte
comments based upon it were considere
important in reaching planning decisions i
up to 30±45 per cent of cases.Nelson (1994) reported that 23 per cent o
LPAs found the ES to be of `much’ assist
ance in decision-making. S ixty per cent o
LPAs believed the ES had been of `some
assistance, with 14 per cent saying it ha
been of `little’ assistance and 3 per cent o
`no’ assistance. In 1995, Fuller and Bink
reported that 68 per cent of a wide range o
EA practitioners held the view that EA `always’ or `often’ contributed to more in
formed decision making Glasson et a
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CHRISTOPHER WOOD AND CARYS E. JONES1242
ES to have had `little’ or `no in¯uence’. In a
more recent study, Hughes and Wood (1996)
reported that, in the majority of cases, the
plan ning of®cers and the developers believed
that bo th the contents of the ESs and the
comments arising from consultations had an important in¯uence on the decisions. In all
cases, the planning of®cers believed that the
ES was an aid to decision-making.
In their consideration of EA cases involv-
ing planning inquiries, Jones and Wood
(1995) found that the results from consulta-
tions based upon the ES and the pl anning
application were often as important as the ES
in making the decision (and sometimes more
so).
In¯uence of EA on planning conditions.
There has been very little pu blished on the
use of planning conditions to formalise the
commitments made i n ES s or the suggestions
arising from EA consultations. Jones and
Wood (1995) found that environmental con-
ditions were imposed in all four cases where plan ning perm ission was gr anted fo llow ing a
pub lic inqu iry. These related most fr equently
to landscaping followed by noise control.
In¯uence of EA on project modi®cations.
Wood and Jones (1991, 1992), together with
Kobus and Lee (1993), found that nearly
tw o- thirds of pr ojects were modi®ed as a
r esult o f th e E A p ro cess b ut th at t he semodi®cations were often of a minor nature.
However, a later study indicated that, in the
opinion o f the LPA of®cers involved, around
50 per cent of projects were modi®ed to
some degree on the basis of the ES and the
consultations associated with i t (L ee et al.,
1994). Similarly, Frost (1994) found that 50
per cent of 30 pro jects were `m aterially’
altered during the post-submission stage of the EA process, and Jon es and Wood (1 995)
found that 7 of a sample of 10 cases were
sions, to determine whether any real trend
over time are discernible. However, it ap
pears that, in the opinion of planning of ®cer
there may have been an increase in the pr o
port ion of cases in wh ich the conten ts of th
ES were considered important in reachin the decision. On the other hand, ther e ma
have been a decrease in the pro portion o
cases in which consultations were considere
important (Lee et al., 1994).
Methodology
This research involved 40 EA cases draw
from throughout Great Britain. All the case
were selected utilising several criteria. Cr
teria relating to pr oject type and DoE regio
were applied so that the sample re¯ected th
overall population of planning cases wher
EA w as required in Great Britain as at Marc
1993 (utilising existing EIA Centre infor
mation on ESs). The sample was also sub
divided to include cases where plannin
perm ission was either gr anted or refu sed an
where cases were subsequently dealt wit thro ugh the appeal/call-in pr ocess. The se
lected cases related to initial decisions mad
by the LPAs during three time-periods: Jul
1988±June 1990 (13 cases); July 1990±Jun
1992 (14 cases); and July 1992±June 199
(13 cases). These three time-periods wer
chosen to investigate whether increasing ex
perience of EA had any effect on plan nin
decisions. Half of the cases were selectewhere permission was granted by the LPA
with the remainder being divided betwee
cases where permission was refused and th
application was not taken further, and case
which went to appeal or were called-in b
the appr opr iate Secretar y of State.
T he 40 cases included 17 diff erent types o
pr oject, of wh ich 6 fell within Schedule 1 t
the Regulations and 34 wi thin Schedule 2 The Schedule 1 pr ojects covered a majo
power station an installation dealing wi t
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ENVIRONMENTAL ASSESSMENT AND UK PLA NNING DECISIONS 124
plan t, ur ban developments (8), a cable car,
local roads (2), a pipeline installation, a yacht
marina, waste disposal installations (8), a
hotel com plex and a motor race track.
The 40 pr op osed pr ojects were located in
the Eastern (4), East Midlands (5) No rthern (3), North-West (4), South-East (4), South-
West (3), West Midlands (5), and Yorkshire
and Humberside (4) regions and in Scotland
(5) and Wales (3). The types of LPAs in-
volved were 15 county councils, 18 district
councils, 4 metropolitan district councils, 2
development corporations and a national
park authority. The 40 cases are believed to
be suf®ciently representative of the UK
pop ulation of planning EA cases, in term s of
pro ject type, DoE region, local pl anning
authority, etc., for any conclusions drawn
from their analysis to be broadly applicable
to the wider domain .
A master questionnaire was designed to
elicit information about the in¯uence of EA
on various aspects of LPA decision-making,
and from this several shorter questionnaires
were prepared, each designed for use with a particular grou p/o rg ani sation within the EA
pro cess. The questionnair es designed for
plan ning of®cers were used duri ng face-to-
face interviews and a visit to each planning
authority was combined with scrutiny of the
plan ning ®l e. Prior to each visit, the ES,
plan ning of®cer’s report and LPA decision
notice were read and relevant info rmati on
was recorded. Usi ng the info rmation obtained fr om the
plan ning ®le, the other main participants in
the EA pr ocess were in terv iewed by tele-
pho ne, using the appr opria te questionnaire.
These includ ed statutory EA consultees, con -
sultancies who had undertaken the EA, major
pub lic interest gr oups and local actio n
groups.
All data from the questionnaires werecoded for analysis (frequency analyses.
cross tabulations and correlations to elicit
Evaluation of Environmental Statement
by Planning Of®cers
LPA evaluation of the ES. The majority (9
per cent) of the local plan ning of®cers mad
some evaluation of the E S, and this w a
generally through internal consultatiowithin the LPA (49 per cent). In three cases
Schedule 3 to the EA Regulations was use
as a checklist to assist in evaluation and in
further three cases both internal and externa
consultation took place. In the remainin
cases, various combinations of consultatio
and documentation were used.
Where the planning of®cers formed a view
as to the adequacy of the ES,1
72 per cenindicated that the ES was `adequate’ for de
cision-making purposes; in the other cases
the ES was felt to be `inadequate’.
Use of consultants by LPA. Most LPAs (7
per cent) did no t re tain exter nal consu ltancie
to assist them in evaluating the info rmatio
contained within the ES. In two cases, th
Institute of Environmental Assessment waretained (the LPAs concerned becomin
members of the Institute for the express pur
pose of ob taining review s of the ESs). Th
external consultancy’s appraisal of the E
was `very in¯uential’ in framing the plannin
of®cers’ recommendations in ®ve of the nin
cases. However, the appraisal by the consul
tancy had `no in¯uence’ on the desig n of th
pr oject in seven of the nine cases.
LPA consultations on ES and planning appl
cation. Formal consultations by the LPA fo
lowing submission of the ES and plannin
application should take place with a variet
of consultees in all instances (DoE, 1989
However, as shown in Table 1, this was no
always true for the cases in this study. Th
relevance of the project to the interests of th`statutory EA consultees’ should be deter
mined by the consultees themselves but i
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CHRISTOPHER WOOD AND CARYS E. JONES1244
Table 1. Consultations undertaken by LPAs following submission of ES and planning application anresponses of consultees
Consultees
Other Major Nature statutory public interest
conservation Countryside EA localagencies Commission HMIP consultees action groups
Cases where LPAundertook 35 31 22 39 38consultation after (88) (82) (55) (98) (95)submission of ESand PA
Cases where aresponse was 35 21 18 39 38
made to LPA (100) (68) (82) (100) (100)consultation
Cases whereconsultees made 27 10 12 35 26speci®c comment (77) (47) (67) (90) (69)on the ES in response to LPAconsultation
Notes: Figures in parenthesis are percentages.HMI P is only a statutory EA consultee for cases involving mining ope rations, manuf acturing industry o
disposal of waste w hich are likely to g ive rise to radio-active or special waste or wo rks likely to give ris to particular emissio ns.Other statutory EA consultees include National Rivers Autho rity (now part of the E nvironment AgencyHealth and Safety Executive, water companies and relevant local authorities.
Countryside Commission, HMIP and their
equivalentsÐwere less likely to be consulted
than the more traditional planning consultees
and the public.
Where consultation took place, a responsewas not always forthcoming from all groups
of consulteesÐspeci®cally, the Countryside
Commission and HMIP (Table 1). The varia-
bility in response was governed by the par-
ticular interests of the consu ltee gro ups and
whether the projects in question were likely
to have a direct effect on these inter ests.
Not all responses from consultees included
speci®c comments relating to the ES (see Table 1). Tho se most likely to pr ovide suc h
comments were the other statutory EA con
adequate for decision-making purposes, fur
ther information was requested in 68 per cen
of cases. In these cases, this was mainly (8
per cent) done in an info rmal or voluntar
manner without invoking any regulation The speci®c clause in the EA Regulation
relating to requests for further informatio
was used on three occasions and the power
conferred on LPAs by the General Develop
ment Order once. In the majority of cases (8
per cent), on ly on e request for fu rther info r
mation was made, although in 19 per cent o
cases between two and ®ve separate request
were made. Analysis revealed that furtheinformation was more likely (90 per cent o
cases) to be requested where the plannin
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ENVIRONMENTAL ASSESSMENT AND UK PLA NNING DECISIONS 124
one or more of the consultees in half of the
cases. Of the remainder, requests arose solely
from the LPA in 38 per cent of the cases and
solely from the consultees in 12 per cent of
the cases.
The info rmation requested was quitevaried in range but related most often to:
Ð landscape and visual issu es (33 per cent of
cases);
Ð ecology (33 per cent);
Ð highw ays issues (26 per cent);
Ð noise (22 per cent);
Ð design and layout of the project (22 per
cent);
Ð em issions and wastes rising fr om the pr oj-ect (22 per cent);
Ð hyd ro logy (15 per cent); and
Ð restor ation and after-use (15 per cent).
The info rmati on was generall y (in 89 per
cent of cases) provided by the developer or
consultant, although in one case the supplier
queried the necessity of the request. Where
the requ ested info rmation was not supplied,
the planning author ity did no t pu rsue the
matter, because it intended to refuse the ap-
plic ation anyw ay and anticipated an appeal.
The fu rther info rmation was also dis-
tributed to certain of the statutory EA consu l-
tees in some of the cases. 2 The natu re
conservation agencies (in 57 per cent of
cases) and the major public interest groups
and local action groups (in 46 per cent of
cases) were more likely to receive the further information than the other consultees (in
only 24±29 per cent of cases). The nature
conservation agencies (in 77 per cent of
cases) and the major public interest groups
and local action groups (in 64 per cent of
cases) w er e much more likely to make a
response to the LPA.
In¯uence of EA on Planning Of®cers’ Re-ports
reports, while 26 per cent merely mentione
the exi stence of the ES (F igure 1) . Ho we ver
a further 26 per cent of reports summarise
the contents of the ES and in 16 per cent o
cases the contents of the ES were used t
pr ovide the structure of the planning of® cer’own report. In seven of cases, the infor
mation contained in the ES was conveyed t
the planning committee by supplying bo t
the planning of®cer’s repo rt and the ESÐo
parts of it. In on e case, the committ ee re
ceived the of®cer’s report together with a
extensive formal presentation of the issue
involved.
T he main trend in the presentation of th
contents of the ES in planning of®cers’ re
ports ov er time was the increase in the distr
bution of the ES itself (or parts of the ES
including the non-technical summary) to th
committee. In only 8 per cent of cases i
1988±90 was the ES distributed to the com
mittee; in 1990±92 it was 15 per cent; and i
1992±94 it was 31 per cent.
T he results of consu ltations on the plan
ning applic ation and ES were generall y summarised in the planning of®cers’ reports (8
per cent of cases) (F igure 1). In one case, th
consultation results were merely mentioned
and in 13 per cent of cases, the consultation
were used to structure the report itself.
An evaluation of the weight given to th
content of the ES in the planning of®cers
reports was undertaken by calculating th
pr oportion of the report dealing with the Econtent (Figure 2). In nearly three-quarter
(74 per cent) of the cases in this sample, les
than on e-®f th of the repo rt dealt with th
content of the ES. Only two reports (5 pe
cent) devoted more than 50 per cent of th
report to the ES. T here was little change ove
tim e in the pr op ortion of space devoted to th
ES in of®cers’ reports.
When the planning of®cers’ reports weranalysed in a similar way for the number o
pages covering the consultations a diff eren
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CHRISTOPHER WOOD AND CARYS E. JONES1246
Figure 1. Presentation of the content of ESs and the consultations in planning of®cers’ reports.
tions. In just ov er one-qu arter of cases, dis-
cussion of the results of consultations took
30±40 per cent of the report. In 13 per cent of
cases, the reports devoted 50 per cent or
more of their content to the consultations.
This pattern did not vary wi th time. Gener-
ally, those planning of®cers giving promi- nence to the ES in their reports also tend ed
to give sim ilar prom inen ce to consultat ion
returns.
Usefulness of ES and consultations to plan-
ning of®cers. Planning of®cers were asked
for their opinion about the usefulness of the
contents of the ES when reaching their rec-ommendations. The majority (63 per cent)
had found the ES to be either `v ery’ or
ES in reaching their recommendations re
mained consistent over time.
Statistical analysis revealed that the degre
of usefulness of the ES indicated by th
planning of ®cers in dr awing up their recom
mendations appeared not to be related to th
pr oportion of the planning of®cer’s repodevoted to the content of the ES (see above)
Presumably, those of®cers who indicated tha
the ES had been useful wh en reaching the
recommendations did not directly translat
this usefu lness into the wr iting of their re
ports and explicitly refer at length to th
content of the ES.
When asked for their opinion on the use
fulness of the results of the consultations o the ES and plan ning application, 68 per cen
of planning of®cers expressed the view tha
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0
10
0-10 10-20 20-30 30-40 40-50 50+
Pages of report (percentage of whole)
ESs Consultations
P e r c e n t a g e o f p l a n n i n g o f f i c e r s © r e p o r t s
20
30
40
50
ENVIRONMENTAL ASSESSMENT AND UK PLA NNING DECISIONS 124
Figure 2. Proportions of planning of®cers’ reports devoted to ESs and consultations.
regarding the consultations as `very’ or `rea-
sonably useful’ did not alter with time. The
consultations on the ES and planning appli-
cation w ere f elt over all to have been of
slightly more use to the planning of®cers
than the ES itself. This is perhaps not sur pr is-ing given that ESs often contain technical
details which planning of®cers are not al-
ways fully trained (or suf®ciently experi-
enced) to handle adequately. A nalysis
indicated that the consultation returns re-
ceived more prominence in the planning
of®cers’ reports (see above) where these re-
turns were regard ed as useful by the pl anning
of®cer.
Weight given to ES and consultations in
plannin g of®cers’ reco mm endations. The
plan ning of®cers were asked for thei r op in-
ion about the weight given to the contents of
the ES in their re com m endations (F igure 3).
Over one-third (35 per cent) of the of®cersquestioned felt that in drawing up their rec-
ommendations they gave `substantial’ or
gave the ES `no weight at all’. There wa
little variation in this pattern over time.
Planning of®cers’ responses tended t
con®rm the independent evaluation that th
ES was not given great weight in plannin
of®cers’ reports (see above). Where of®cerindicated that more than `marginal’ weigh
had been given, this was not apparent in th
number of pages dealing wi th the ES in the
reports. However, those planning of®cer
who indicated that `marginal’ or `no weight
had been given to the ES contents tended t
re¯ect this in the proportion of their report
devoted to the E S. It appea rs th at t h
in¯uence of the content of the ES on plan ning of®cers was achieved thro ugh the sup
ply of info rmati on wh ich, in turn, in¯uen ce
opinion about planning applications.
T he plann ing of ®cers stated th at the result
of the consultations on the ES and plannin
application were given `substantial’ or `con
siderable’ weight in framing their recommen
dations in nearly one-half (48 per cent) of th
cases (Figure 3). This was generally greate than the weight they gave to the ES. Th
remaining planning of®cers stated that the
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0
10
Substantia l Considerable Some/
Moderate
Marginal None No comment
Officers© opinions o f influence
ES Consultations
P e r c e n t a g e o f r e p o r t s
20
30
40
CHRISTOPHER WOOD AND CARYS E. JONES1248
Figure 3. Planning of®cers’ opinions about the in¯uence of ESs and consultations in recommendation
and ES were undertaken by the planningauthority with a wide range of bodies. The
plan ning of®cers were asked to indicate the
speci®c in¯uence that the comme nts received
from these different bodies had on their rec-
ommendations (Figure 4). The results are
presented as a percentag e of the total com-
ments (expressed in brackets) received from
each group. Those with most in¯uence were
reported to be major public interest groupsand local action groups (37 cases) and other
statutory EA consultees (39 cases). The na-
ture conserv ation agencies (33 cases) and
HMIP (14 cases) were reported to have had
similar in¯uence, whilst the Countryside
Commission (17 cases) had the least. There
appeared to have been a slight decrease in
the in¯uen ce of comments fr om all consu l-
tees ov er tim e.
one-®fth (8) of cases, the LPA decision waachieved within the statutory 16 weeks. Afte
eight months a decision had been made i
nearly tw o- thirds of the cases (66 per cent
and after a year 82 per cent of the cases ha
been decided. A ll the cases had been decide
after two and a half years.
T he decision made by the planning com
mittee was the same as that recommended b
the planning of®cer in 97 per cent of casesIn one case, the planning of®cer recom
mended granting planning permission, bu
this recommendation was ov erturned by th
planning committee who refused the appl
cation (which was ®nally approved on ap
peal).
When asked for their opinion as to th
overriding factor in¯uencing the decision b
the com mittee, ov er one-thir d of plan ninof®cers (37 per cent) indicated the environ
ment (Figure 5) This was followed by exist
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EN0
20
40
60
80
10 0
P e r c e n t a g e o f c o m m e n
t s
CC HMIP
Consultees
O SCs Public group s
Very Reasonable Margina l Not at all No comment
ENVIRONMENTAL ASSESSMENT AND UK PLA NNING DECISIONS 124
Figure 4. In¯uence of consultees’ comments on planning of®cers’ recommendations. EN 5 EnglisNature. CC5 Countryside Commission, HMIP5 Her Maj esty’s I nspectorate of P ollution. OSCs5 othe
statutory consultees; (or equivalents in Scotland and Wales, in each case).
for the development; or the economic regen-
eration of an areaÐwere cited.
The reasons advanced in the LPA decision
notices were generally standard plann ing ar-
guments for granting or refusing planning
permission. Where perm ission was gr anted
the main reasons were that:
Ð a balance could be achieved bet ween en-
vironmental issues and economic/develop-
ment issues;
Ð there was a need for developm ent or that
there we re no reason( s) to refu se; and
Ð bene® ts wo uld accrue to the local econ -
omy/infrastructure/employment from the
development.
A greater variety of reasons was given for
those cases wh ere the LPA refu sed per
the sample the inadequacy of info rmatio
supplied in the ES on environmental impact
was quoted as one of the reasons for refusa
Weight given to ES and consultations i
planning comm ittee dec isio ns. The plannin
of®cers, together with others involved in th
EA process for the cases, were asked fo their view s on the im po rtance of the E S t
the decision made by the planning committe
( Figure 6). Consultants believed mo
strongly in the importance of the ES in plan
ning decisions, with 44 per cent indicatin
that they felt the ES to have been `v ery’ o
` reaso nab ly im por tant’. T he p lan nin
of®cers, together with developers, member
of major public interest groups and locaaction groups and of®cers from the natur
conservation agencies felt that the ES was o
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60
ES Consultations
P e r c e
n t a g e o f c a s e s © v e r y / r e a s o n a b l y © i n f l u e n t i a l
20
40
80
CHRISTOPHER WOOD AND CARYS E. JONES1250
Figure 5. Planning of®cers’ opinions of main factors in¯uencing decisions.
groups questioned in this study felt that the
ES had only been of `marginal importance’
or indeed `not at all important’ to the de-
cision in the majority of cases and this
changed little over time. These ®ndings are
not sur pr ising given the technical nature of
many ESs; traditionally, members of plan-
ning committ ees rely heavily on pl anningof®cers to present the salient facts concern-
ing applications and tend to seek little direc
access to the documentation themselves.
When planning of®cers and consultee
were also asked for their views on the im
port ance of the results of the consultation
concerning the ES and planning applicatio
on the committee’s decision, all indicate
that such consu ltations were mor e impo rtan to the eventual decision than the ES (F igur
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ENVIRONMENTAL ASSESSMENT AND UK PLA NNING DECISIONS 125
Figure 7. Planning of®cers’ opinions of effect of EA on decisions.
6). Planning of®cers believed that the consul-
tation returns were most import ant, with just
over three-quarters (78 per cent) indicating that they were `v ery’ or `r eason ably im port-
ant’ to the decision. This view was matched
by major public interest groups and local
action groups (64 per cent) and consultants
(60 per cent). T he remaining groups attached
rather less importance to the consultations,
but in all cases f elt that they w er e more
important than the ES to the decision. This
indicates the reliance on the `expert opinion’of the consultees by planning committees
(and by planning of®cers in making their
recommendations).
Many of the respondents from the consul-
tee or ganisatio ns were un able to give an
opinion on the importance of either the E S or
the consu ltations in the decision , as they had
had little invo lvement in the cases after the
formal LPA consultation stage. For example,between 50 and 70 per cent of of®cers from
English Nature the Countryside Commission
desire to be better informed on the progres
of cases through the planning system. 5
Effect of EA on decision outcomes. Plannin
of®cers’ responses, on being asked whethe
the outcome of the decisio n on the develop
ment would have been different if an EA ha
not been undertaken, are summarised in Fig
ure 7. Only one planning of®cer stated tha
the decisio n wo uld have been reversed without the EA (i.e. refused rather than granted)
Nearly half of the planning of®cers (47 pe
cent) felt that there would have been n
difference at all to the decision, whilst th
remainder (50 per cent) felt that although th
outcome itself would not have been differen
without the EA, other bene®ts relating t
more information on environmental issue
and the setting of conditions would not havexisted. This indication that undertaking a
EA improves the availability of informatio
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CHRISTOPHER WOOD AND CARYS E. JONES1252
Table 2. Main environmental planning conditions imposed by LPAs(for 20 cases)
Conditions Number (and percentage) of casesconcerning where condition included
Landscaping 15 (75)Noise 14 (70)
Restor ation issues 9 (45)Nature conservation 7 (35)Dust 7 (35)Drainage and water quality 4 (20)Archaeology 3 (15)Bunding 2 (10)Odours/fumes 2 (10)
Remo val of existing mat erial/Site survey 2 (10)
Emissions to air 2 (10) Use of ES 2 (10)
In¯uence of EA on Planning Conditions
The planning decisi on notices for the 20
cases granted planning permission by the
LPA were examined to establish the main
types of environment al cond itions attache d.All 20 of the permissions speci®ed some
environmental conditions and the details are
shown in Table 2.
The enviro nm ental cond ition s (as opposed
to those relating to site design, operation,
access, etc.) most likely to be included were
those relating to lan dscaping (o ne of the most
common conditions imposed on all planning
permissions) and noise. Just und er half of the20 cases included conditions concerned with
the restoration of the site and in over one-
third of cases nat ure conserv ation issu es and
measures to deal with dust were included.
Interestingly, the conditions for two of the
cases contained direct reference to the ES
and indicated that the measures contained
therein were to be fo llow ed.
In the 19 cases where direct comparison between the planning of®cer’s report and the
decision was possible 6 it was found that in
in 11 per cent of cases the actual condition
were speci®ed in greater detail than those se
out by the planning of®cer, and in 5 per cen
of cases additional conditions were speci®ed
In¯uence of EA on Project Modi®cations
Projects rarely pass through the plannin
pr ocess with out some modi®cations takin
place, du e either to cost, desig n and othe
non- envir onmental factors or to the nee d t
render the project less environmentally harm
ful. Planning of®cers, developers and consul
tants were asked to indicate how manmodi®cations had been made to the develop
ments in question and their responses ar
summarised in Figure 8.
In just over one-®fth of 37 cases in th
study,7 modi®cations were made both prio
to the sub mission of the ES and after it
submission. Modi®cations took place solel
pr ior to E S subm ission in just und er on e
third (31 per cent) of cases and only after Esubmission in one-sixth (16 per cent) of th
cases However in just under one third (3
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ENVIRONMENTAL ASSESSMENT AND UK PLA NNING DECISIONS 125
Figure 8. Numbers of m odi®cations to cases and stages at which they occurred.
they used led to any mod i®cation s.8 Several
forms of guidance were indicated, either
solely or in combination, including the UK
EA regulations, the European EIA Directive,
other similar ESs and previous experience.
W here guidance was used, it led to
modi®cations in 28 per cent of the cases. The
work involved in ES preparationÐas distinct
from cost or other factorsÐled to modi®-cations to the project in 72 per cent of cases.
In all, pre-ES submission modi®cations w ere
made as a consequence of undertaking the
EA process in 79 per cent of cases.
Developers and consultants were ques-
tioned regarding any modi®cations arising
from the scoping stage. In the ®ve cases
where the developer undertook scoping with
the consu ltancy retain ed, modi®catio ns arosein two cases. Of the seven cases where topics
were suggested by the Countryside Com
the other EA statutory consultees (48 pe
cent of cases), and the major public interes
groups and local action groups (30 per cen
of cases), these led to modi®cations in ap
pr oximately on e-third of these cases. In non
of the cases in this sample did topics sug
gested by HMIP at the scoping stage lead t
modi®cations.
T he no n- statutory info rmal consultationundertaken by the LPA with consultees prio
to ES sub mission led to project mod i®catio n
in o nly o ne o f th e 10 case s w here su c
consultation took place.
Modi®cations also arose from topics sug
gested by the consultees to the LPA durin
formal consultations on the planning appl
cation and E S. A s stated above, modi®
cations were less likely to arise at this stagin the EA process. Modi®cations occurred i
35 per cent of cases w here the other statutor
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CHRISTOPHER WOOD AND CARYS E. JONES1254
arose from comments received from the
Countryside Commission.
Two of the plann ing of®cers interviewed
expressed the view that ªmitigation measures
are often neglected in the EA process, partic-
ularly at the early project design stageº.Analysis over the time-periods of the
study shows that modi®cations were made
more often at the pre-ES submission stage
during 1992±94 (in 75 per cent of 12 cases)
than during 1988±9 0 (in 33 per cent of 12
cases). However, it appears that the pattern
of modi®cations made after submission of
the ES but pr ior to the decisio n has remained
unchanged.
Conclusions
This stu dy has show n that the effect of EA
on planning decisions has been gradual
rather than revolutionary. Rather than alter-
ing the outcomes of planning decisions, its
main bene®ts are the enhanced provision of
information about the environmental conse-
quences of actions to decision-makers and, toa lesser extent, assistance in the setting of
conditions and in modifying proposals. How-
ever, these bene®ts are not occurring in all
cases, and the expected advantages of EAÐ
b ett er p roj ect p lan ning an d d ecisio n-
makingÐare not yet being fully realised in
the UK . The exper ience of the in¯u ence of
EA on planning decisions in the UK tends to
re¯ect international practice (Lee, 1995;
Wood, 1995; Sadler, 1996).
It is notable that the planning of®cer’s
recommendation was accepted by the plan-
ning committee in virtually ever y case and
that an extensi ve fo rmal pr esent ation to the
committee was only deemed necessary in
one case. I t is apparent that E A has not
pro ved as controver sial as anticip ated. EA
would have been more effective if i t had
been introduced less seamlessly into the UK plan ning syste m, since contro ver sy wo uld
their recommendations as to wheth er a pr o
ject sho uld receive planning perm ission
They gave consi der able weight to the ES i
drawing up their recommendations in ove
one-third of the cases, even if they did no
always explicitly refer to the ES. Planninof®cers, together with developers and mem
bers of major public interest groups and loca
action groups, believed that planning com
mittees gave considerable weight to the con
tents of the ES wh en re aching their decision
in about one-third of the cases. This rein
forces the ®ndings of earlier work (Kobu
and Lee, 1993; Lee et al., 1994; Glasson e
al., 1996; and H ughes and Wood, 1996
This use of ESs by L PA s in decisio n-makin
corresponds to Culhane et al.’ s ( 1987
`rational-objective model’ of reform (above
In¯uence of consultations on decision-mak
ing. The consultations undertaken on the E
appear to have been more in¯uential than th
ES during LPA decision-making. More tha
two- thirds of planning of® cers regarded thes
consultations as being useful when drawinup their reports. They gave considerabl
weight to the consultation returns in drawin
up their recommendations in nearly half th
cases. The consultees themselves, and th
planning of®cers, also indicated their view
that the consu ltations carr ied considerabl
weight with planning committees when mak
ing a decision. Again, this result supports th
®ndings of earlier work by Kobus and Le(1993), Lee et al. (1994), Jones and Woo
(1995) and Hughes and Wood (1996). It thu
appears that Culhane et al.’s (1987) `externa
reform model’ of decision-making provides
partial explanati on of L PA behaviour.
In¯uence of EA on decision outcomes. Ove
one-third of planning of®cers indicated tha
environmental issues were the major factoin¯uencing the decision by the comm ittee. I
three of the cases the in adequacy of info r
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ENVIRONMENTAL ASSESSMENT AND UK PLA NNING DECISIONS 125
of®cer stated that the decision outcome
would have been reversed without the EA.
Nearly half of the planning of®cers felt that
E A had made no diff er ence at all to the
decision, whilst the remaining half felt that,
although the decision itself would not havebeen different without the EA, other bene®ts
relating to information on environmental is-
sues and the setting of conditions had been
gained. This ®nding con®rms the results of a
recent survey by Fuller and Binks (1995).
The bene®t of increased info rmation on en-
vironmental issues corresponds to Culhane et
al.’s (1987) `rational-objective model’ of re-
form.
In¯uence of EA on planning conditions. En-
vironmental conditions were imposed by
LPAs in all the cases where planning per-
mission was granted. The most frequently
used conditions related to landscaping (one
of the most common conditions imposed on
all planning permissions) and noise, support-
ing the ®ndings of Jones and Wood (1995).
In¯uence of EA on project modi®cations. In
the 68 per cent of cases wh ere modi®catio ns
did occur, they were often only of a minor
natu re. This ®n ding tends to supp ort the
work of Wood and Jones (1991), Lee et al.
(1994), Frost (1994), Fuller and Binks (1995)
and Jones and Wood (1995). There also ap-
pears to have been an increase in pre-su b-
mission modi®cations. The guidance used to prepare ESs and the wo rk undertaken in
preparin g the ES had varying degr ees of
in¯uence on modi®cations to mitigate ad-
verse impacts. This provides evidence that
developers’ decision-making has been affec-
ted by Culhane et al.’s (1987) `internal re-
form model’.
Increasing the in¯uence of EA on LPA de-cision-making. The relatively minor impact
that EA has had thus far on decision making
ened guidance in the practical use of EA
speci®cally targeted at decision-making b
planning of®cers.
T his gu idance could speci®cally em ph a
sise the role of the ES, and EA more gener
ally, at the following stages: Ð in reaching re com m endations and prepar
ing planning of®cers’ reports (through uti
isation of the material in the ES
distribution of the ES or its non-technica
summary to the planning committee an
greater dialogue with consultees about th
content of ESs);
Ð decision-m aking (critical evaluation of th
material in ESs and of the results of consultations);
Ð settin g planning cond itions (u tilising th
contents of the ES and the results of con
sultations to set appropriate conditions t
minimise the impacts of the developmen
and contribute to enhancement of the en
vironment); and
Ð pr oject mod i®cations (by encour agin
greater use of modi®cations to mitigat
adverse impacts throughout the EA pro
cess).
Although recent guidance (Land Use Consul
tants, 1994 a; DoE, 199 5a) covers several o
the abo ve recommendations, it could usefu ll
be supplemented by further detail, includin
pr actical exam ples. There also appears to b
a need for the various participants in the EA
pr ocess, notab ly the EA consu ltees, to play greater role in in¯uencing outcomes, particu
larly during scoping, ES evaluation and de
cision-making. It is therefore apparent tha
further training of the various participants i
the EA pro cess is needed to ensur e that th
potential bene® ts of EA are more fu lly re
alised within the UK.
If the UK is to learn from internationa
experience, it will also need to strengthen it
EA systemÐi.e. to progress from a `Mark I
to a `M ark II’ system , as many countrie
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CHRISTOPHER WOOD AND CARYS E. JONES1256
sual in the national culture and (2) are
explicit in public law and policy.
It is therefore necessary not only to improve
the operation and nature of the EA system,
but also to ensure that it receives real public
and political endorsement. Only then will it
begin to ful®l its potential of ensuring that
UK planning decisions becom e more com-
pati ble wi th sustainability goals.
Notes
1. One planning of®cer declined to comment;in two cases, there was no evaluation of the
ES; in one case, the ES fed straight into a public inquiry.2 . I n A p ril 1 994, the E A R egu lati on s w er e
amended to require all further information requested as part of the EA procedures to becirculated to the statutory EA consultees for comment.
3. In two cases, no written of®cer report was prod uced. In one case, the decision was dele-gated to the planning of®cer concerned, and
the other case was called-in by the Se cretar y
of State.4. Two cases were called-in by the Secretary of State and no decision was made by the LPA.O ne of the 38 cases w as appealed on thegrounds of non-determination, but the plan-
ning auth ority in dicated the decision it would have reached.
5. In A pril 1994, LPAs w ere required, w hen granting planning permission, to include astatement in the decision notice to the effect
that the environm en tal information had been tak en in to consideration in rea ching the de-cision.
6 . O ne case w as d el eg ated t o t he p lan ni ngof®cer.
7. In the remaining three cases, it did not prove possible to ascertain information concer ningany modi®cations.
8. In two out of the 40 cases in the sample, it was not known what guidance was used, if any.
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