Government Updates Proposals for Environmental Outcome Reporting

MHCLG has published its response to the 2023 consultation on the proposals to introduce Environmental Outcome Reports (EOR) to replace Strategic Environmental Assessments (SEA). It also published its roadmap to deliver the new system by the end of next year.

The application of SEA to neighbourhood plans has been problematic from the outset. With little guidance to plan makers or to LPAs on how to go about this in the early days, and with so little funding available, developers quickly spotted SEA as the ‘Achilles Heel’ in the process. Some successful Judicial Reviews were a painful reminder that this highly technical responsibility had to be handled with great care.

For many years, communities were able to access a free SEA service from the national support programme. The process and output closely resembled those of Local Plan sustainability appraisals in terms of the depth and breadth of their technical content.

That ‘gold-plating’ of the process tackled the legal challenge problem, but at what price? Firstly, it hid the fact that far too many neighbourhood plans were having to have an SEA than the law and guidance required. Secondly, it made projects entirely dependent on external support as volunteer teams would be very unlikely to take the risk of producing an SEA themselves. And thirdly, the true cost of carrying out SEAs is now clear, with communities realising that it will eat up a significant proportion of their project budget.

For those reasons alone a replacement system must be welcomed, but with caution. Neither of the two new reports, or the 2023 consultation document, mentioned neighbourhood plans. And we know of no independent research since 2015 of how SEA has been applied to those plans that could have informed the new EOR system from this different plan making perspective.

With a much higher proportion of future neighbourhood plans choosing to allocate development sites, we also worry that even a supposed lighter touch EOR regime will continue to focus too much on environmental and not social and economic impacts. And ‘lighter touch’ may still be unaffordable for too many as local planning authorities remain risk-averse in their information needs.

We will therefore keep a close eye on how the new system is designed and tested and we hope to be involved in the coming months. Very few other bodies could match our experience and expertise in operating SEA for neighbourhood plans.