Royal Commission on Environmental Pollution

Theme 5: Assessment Approaches

SUMMARY

1.       Assessment approaches for landscape are in a state of flux

The implementation of the character approach recommended in the 1997 PPG7 is proving to be a slow process. There are indications that the approach is not fully understood or the potential benefits appreciated. This has not been helped by a shortage of resources and the inconsistent application of the approach by Local Planning authorities.

2.       The introduction of new methodologies is potentially counter-productive at this stage

New guidance and methodologies for landscape assessment are being finalised by the Countryside Agency and the other environmental agencies based on the character approach. The draft reports introduce new, and more complex, terms and techniques for assessment. In comparison to existing methodologies these are more arduous to implement at the professional level and are more demanding for the public.

Given the formative nature of the landscape character approach, greater simplicity and clarity are required to gain the confidence of the public and local planning authorities. This is especially important at a time when the public is being encouraged to take a fuller role in defining the importance of the landscape

3.       An independent review of the character approach is recommended

Before new methodologies are introduced it is recommended that the implementation and application of the character approach be reviewed. There is now a sufficient body of experience at Structure Plan and Local Plan level to assess how the character approach is being applied at EIP and Local plan Inquiries and in development control.

The review should include recommendations for good practice and clarify the relationship between the character approach and landscape designations. Consideration should also be given to how the character approach can be included within a unified system of Sustainability indicators to provide a consistent basis for higher level decision making.

4.      More consistency is required in the acquisition and interpretation of environmental data

Where assessments are devolved to local communities the base data and outputs are unlikely to be comparable at the District or Regional level. This diminishes their value and makes higher level decision-making more dependent on a top-down approach based on statutory designations.

The new Regional Planning Boards provide a focus for the co-ordination of local landscape information. This should enable strategic decision-making to be better informed and less susceptible to delay and amendment at the local level.

5.       The existing EIA process provides a 'core' assessment approach

EIA is a formal requirement for some projects and will be required whether other assessment techniques are adopted or not. EIA also has wider applications as a structured approach to assessment. It has a well established methodology and there is a good knowledge and training base.

It meets requirements for public consultation and is adaptable to a range of projects and levels of detail.

6.       There are well established guidelines for landscape and visual impact assessment within the EIA framework

The Landscape Institute, in association with the Institute for Environmental Management and Assessment has developed and published Guidelines for Landscape and Visual Impact assessment. The Guidelines are supported by a profession with over 5000 members and a long established knowledge and training base at University level and including CPD courses in EIA.

The Guidelines were published in 1995 and are recommended for all levels and types of projects including those that do not require a formal EIA. They are widely accepted as the definitive methodology for the subject.

The existing Guidelines are being reviewed in the light of experience gained by Institute members over the last 5 years. They will take account of the new EIA regulations and developments in the character approach and evolving methodologies such as Environmental Capital. An updated version of the Guidelines for Landscape and Visual Impact will be published at the end of the year.

The Landscape Institute

1.      This evidence has been prepared on behalf of the Landscape Institute. The Institute is the Chartered Institute in the UK for Landscape Architects and comprises landscape designers, planners, managers and scientists. Founded in 1929 the Institute now has over 5000 members working in both the public and private sectors.

2.      Institute members are involved in environmental appraisals in their capacity as employees of national and local government bodies and agencies and as private consultants advising private and public bodies.

3.      The Landscape Institute has developed assessment guidelines for landscape and visual impact in association with the Countryside Agency and the IEA (now IEMA). The Guidelines on Landscape and Visual Impact Assessment were published in 1995 and have the support of a wide range of bodies within environmental planning.

The 1995 Guidelines are currently under review and the consultation draft is to be published in mid-summer for final publication in late 2000/ early 2001. The review will take account of changes in the planning background (including developments in sustainability policy) and the recommendations of Institute members who have specialised in the implementation of the EIA methodology over the last 5 years.

4.      In addition to their specialist landscape role many of the Institute's members are employed as co-ordinators and authors of project-based EIAs because of their broad environmental training and their iterative role in the development of the scheme proposals alongside the EIA process.

5.      Chartered Landscape Architects are also engaged in a range of environmental studies including national, regional and local landscape assessments, Community Forest Plans, good practice guidance for the environmental design of highways and lighting etc.

6.      The work of Institute members is influential in the environmental planning system through data collection and survey through to policy advice and appearances as expert witnesses at public inquiries. To promote co-ordination and dialogue with other organisations within the environmental planning system the Institute has established links with relevant Government Departments, the Planning Inspectorate, the Countryside Agency and other professional bodies including the RTPI. This has encouraged an exchange of views about the effectiveness of the existing system and the options for the future. The principal focus of these discussions has been the future of the landscape character approach and the role of landscape designations in appraisal techniques.

7.       The Landscape Institute's current policy on these issues is set out in its response to the Countryside Agency's Interim Guidance on Landscape Assessment published in December 1999 and in its Advice Note 01/99 on Landscape Assessment:-

• The application of the landscape character approach should be rigorously reviewed before the system is extended or further changes/ methodologies are introduced.
• The environmental appraisal of landscape issues should not be based solely on landscape designations

• The apparent failure of the character approach to gain support outside the environmental planning system because of a lack of understanding of how it can be applied to conserve and enhance the landscape in the context of the Development Plan process.
• The inconsistent application of the character approach and landscape designations at regional and local level
• The growing pressure to engage the public in the process of environmental appraisal and therefore the need for greater clarity and understanding
• The contradiction between the character approach (based on local distinctiveness) and designations (based on the blanket application of policy)

10.      The evidence submitted by the Landscape Institute sets out the views of the professional group who are most involved in the application of landscape and environmental appraisal methodologies on a day-to-day basis. It explains how the current system works, its strengths and weaknesses, and offers advice on the options for the development of a an appropriate methodology which builds on the experience of the last 5 years since the character approach was introduced in the 1995 Rural White Paper.

11.      The evidence begins with a brief pre-amble on the current appraisal system as it applies to landscape issues. This is followed by responses to the questions set out in the Royal Commission's invitation to submit evidence (Annex A) under heading 5 - Assessment Approaches.

Preamble / background to the evidence

12.      Environmental appraisals include the assessment of effects of change on people (views /amenity) and the landscape as a resource within both town and country.

13.       Planning policy guidance identifies specific objectives for the landscape within the overall commitment to sustainable development. To assess/ monitor proposals for change against these objectives it is necessary to have appropriate baseline information on the existing situation, including the current pattern of change:-

Table 2: Baseline Requirements to Meet Policy Objectives

The requirement for baseline information can be summarised as :-

• landscape character
• landscape change
• landscape quality

• landscape features

The extent of landscape features such as hedgerows, streams and woodland provides information about landscape character and a measurable indicator of change.

15.       It is relevant to ask whether the present level of information provides an adequate baseline for the assessment of compliance with sustainability objectives?

The effectiveness of the baseline is dependent on :-

• consistency of approach
• level of detail
• appropriateness to the 'test' to be applied
• geographical coverage and cross-border consistency
• clarity and public confidence

16.       Existing landscape indicators of sustainability are summarised in Table 3. The Indicators of Sustainable Development for the United Kingdom include indicators for land cover and landscape:-

- Rural land cover
- Designated and protected areas
- Damage to designated and protected areas
- Agricultural productivity
- Nitrogen Usage
- Pesticide usage
- Length of landscape linear features
- Environmentally managed land

- landscape character
- measures of landscape quality or condition
- damage to designated landscape areas
- woodland cover

Table 3: Landscape Indicators of Sustainability
(excludes wildlife issues)

19.       Indicators are being developed at regional and local level and are subject to public consultation to establish what is important to local people.

Character maps and descriptions

20.       The National character map of England covers the whole of the countryside and identifies 159 areas of distinctive character. The boundaries of the character areas have been refined where regional or local studies have been undertaken but the coverage of these secondary studies is very uneven and there has been no consistent use of methodology. Nevertheless it is likely that most LPAs in England will have completed their 'second-tier' landscape assessment and character map within the next 5 years as part of the Development Plan review process. This information is generally intended to provide supplementary planning guidance as a background to countryside planning policies rather than as a basis for new policies.

21.       The character maps provide a context for rural change but are often too broad- brush to assist in decision-making in the areas of greatest planned change i.e. extensions to urban areas and transport corridors.

22.       More localised and detailed studies (e.g. urban capacity and 'whole settlement' studies) are needed to inform planning decisions about the location of built development. The application and coverage of these urban is variable but improving. There is currently little co-ordination between urban and rural studies.

Landscape designations

23.       The definition of criteria for landscape designations has become increasingly confusing because landscape 'quality', as a basis for designation, has been replaced by the concept of landscape 'value'. The Countryside Agency provide a list of criteria which can be used to identify valued landscapes for designation at all levels (Interim Guidance on Landscape Assessment: 1999). One of these criteria is 'Landscape Quality' which is defined:

'This is a function of the extent to which the character of the landscape is demonstrated in a particular area, in terms of the presence of key characteristics and absence of atypical and incongruous features. It also depends upon the state of repair of elements in the landscape and the integrity or intactness of the landscape'. (Note: this definition is under review).

24.      It is therefore proposed that landscape quality be defined in terms of landscape character rather than the 'traditional' aspects of scenic quality and 'natural beauty'. These older terms were based on what the landscape looked like and the emotions it produced. They have lost their currency within the environmental planning system because they were largely subjective and a more objective and integrated approach (combining landscape, ecology and heritage) was sought. This is summarised by the Buckinghamshire County Council Landscape Plan as follows

"initially the emphasis was placed on the largely subjective evaluation of landscape quality in terms of "what makes any one landscape better than another". Thinking has evolved and now greater recognition is placed upon local distinctiveness and character, in terms of "what makes any landscape different from another" which can be assessed on a more objective basis."

25.       The modern approach to designations and landscape quality is dependent on the availability of a landscape assessment (characterisation) studies to provide information on landscape character, condition and distinctiveness.

26.       However, landscape designations are not solely based on character and their boundaries do not coincide with character area boundaries. Therefore other information will also be required for appraisal purposes e.g. for scenic quality, conservation interests and values such as tranquillity.

27.      Landscape assessments, which have been produced for AONBs by the Countryside Agency, include information about the special qualities and features of the areas and their spatial disposition within the designation. Similar information has not been produced for National Parks.

28.       The position regarding local landscape designations is unclear with some planning authorities abandoning them in favour of the character approach and some justifying them (in accordance with PPG 7 para 4.16); others continue to rely on old-established designations with little or no justification. In general very little information is available about the features or qualities which require special protection.

29.       For many areas the problems identified in the 1995 Rural White Paper which the 1997 revision of PPG7 sought to resolve still persist i.e. large areas of unsupported blanket designations and a significant gap between the protection afforded to statutory designations and areas with no designation. The 'gap' between statutory designations and undesignated land still exists (PPG7 para 4.16) but the implication of the policy is that the differential has been reduced (PPG7 para 2.14). Although landscape character and landscape designations are described in PPG7 as 'complimentary' the relationship is not as clear as this term suggests.

The current position

30.       Unfortunately, lack of resources, poor co-ordination and a lack of understanding/ comprehension of the benefits of the character approach have failed to deliver the expected benefits except at the local level in some Districts.

31.       The landscape planning world is therefore in a state of flux until the character approach has worked its way through the system. During this transitional stage the environmental agencies have been developing the concept of Environmental Capital; 'What matters to whom and why?' The pilot studies for this approach have focussed on applying the methodology to specific development-related tasks at local level. The original concept of Environmental Capital (applied at all levels) was based on designations but this is now considered to be too simplistic 'delivering islands of environmental quality in a sea of mediocrity or degradation'.

32.       There are now three 'complementary' methodologies in place: landscape character, landscape designations and Environmental Capital (albeit the Environmental Capital studies are at the pilot stage), none of which have universal coverage or consistent application. There are also two current reviews of landscape terminology and assessment techniques (one by the Countryside Agency and the other by the Landscape Institute/IEMA).

33.       The initial results of the pilot studies for Environmental Capital methodology show that it does not generally produce different results to existing appraisal techniques but that the 'process' may be improved. This underlines the current emphasis on greater public involvement and 'engagement' in determining local values. This attention to 'how' decisions are made is a feature of all levels of environmental planning from SEA down to Village Design Statements. The challenge is to determine how the bottom-up assessments of value (often using different assessment techniques) can be measured against each other in order to make higher level decisions e.g. at District or Regional.

34.       Within this context there appears to be a growing feeling that the character approach is too academic and has not delivered. The early Environmental Capital approach (largely based on designations) and the introduction of the 'What Matters and Why' approach (largely based on public preferences and perceptions) adds to the complexity of appraisal methodologies and makes designations appear increasingly attractive because they are clear-cut and easy to understand.

35.       This confusing state of affairs comes at a time when consistent environmental information is required to inform strategic and local appraisals. To assist in future decision making it is recommended that an assessment is made of the current status of landscape studies within the UK to identify methodologies, overlaps, inconsistencies etc. with a view to establishing good practice and a way forward. The assessment should include consultation with the public and different levels / types of decision-makers to obtain their views and preferences.

The review should be based on the principles set out in the revised PPG7 (1997). The aim would be to:-

• Develop a consistent methodology for character studies and sustainability indicators/appraisals to enable comparison of lower level assessments and inform regional planning
  
• Let the character studies work through the system before trying to introduce further changes/ methodologies. Future studies should follow good practice and existing studies should be reviewed against the guidelines recommended in the study.
  
• This should lead to a reliable 'second tier' of character areas which can assist regional and local decision making.
  
• Include statutory landscape designations within the second-tier studies to achieve a seamless map of character areas. Identify in words and plans the special features and qualities which justify designation of all designated areas (including statutory designations - ref. PPG 7 para. 4.1), accepting that there are variations in landscape character AND landscape quality within designated areas.

36.       The appropriate appraisal methodology will vary with the scale of decision making. It will also depend on the availability of reliable and comparable data for the geographical study area. Table 4 shows how the main appraisal methodologies relate to each other.

Table 4: Appraisal Methodologies

38.       The benefits of the EIA process for the delivery of sustainability objectives are widely accepted (see Circular 02/99 paragraph 14) and can be applied at a range of scales. The methodology is well -defined and supported by guidance manuals, DETR publications, university training courses and an accreditation/ audit body (IEMA).

39.       There is evidence of the increasing use of EIA methodology because of uncertainty about the need for a formal EIA and the acknowledgement of the benefits that EIA provides in presenting environmental information in a systematic way.

40.       The Landscape Institute has consistently advised that its Guidelines for Landscape and Visual Impact Assessment (GLVIA) should be used for all projects in order to promote good practice within the profession. This is particularly important for landscape and visual impact issues where there will always be a subjective element of appraisal which needs to be presented in a structured way. A methodical approach also assists in the iterative design/ assessment process which aims to achieve the optimum fit between development/ change and the environment.

41.       The Guidelines provide the basis for considering the landscape aspects of environmental plans at all levels. The landscape methodology has also been selected to enable EIA data to be used for planning policy tests and also provides a basis for sustainability tests (see Table 5). At the higher levels landscape assessment methodology can be included as part of a 'Mini-EIA' which can be refined as the detail increases at the local level.

Environmental Impact Assessment (EIA)

Sustainability Appraisal

42.       This methodology is developing in response to the growing interest and policy requirements for information about sustainability. The appraisal technique is based on the selection of indicators and criteria for measuring (generally quantitative) change.

43.       It is appropriate for all levels of decision making from policy through to site selection and site planning. It is similar to EIA but is often presented as a simple matrix, summarising a more complex and detailed analysis.

44.       Difficulties arise when the need to summarise/ distil information into a small number of categories, leads to a distortion of the facts.

45.       Sustainability appraisals/matrices are helpful as a check or summary but should always be supported by a reasoned assessment.

Environmental Capital

46.       Environmental Capital is considered in more detail later in this evidence. The main point to note at this stage is the potential benefit of the Environmental Capital approach to the baseline evaluation particularly at a local level where there are no designations (see Table 4).

Table 5: Assessment Methodologies based on EIA

Do appraisal methodologies applied to individual cases provide sufficient information about their implications for the achievement of wider environmental goals?

47.       Individual projects often rely on the Development Plan to have taken account of the wider issues in determining land use allocations.

Therefore, project-based EIAs normally include an indication of the implications for the achievement of wider environmental goals through an assessment of the effect of development/ change on planning policies / objectives. However this is not a compulsory part of the information required to meet the EIA directive and does not apply to schemes which do not require an EIA.

48.       Local planning authorities are also carrying out more formalised comparative assessments of alternative sites using sustainability criteria/indicators. The private sector (e.g. house builders) is also giving serious consideration to developing sustainability appraisal techniques to identify the wider environmental issues of individual projects e.g. waste minimisation, biodiversity, energy reduction.

49.       In all cases it is important to consider the cumulative effects/benefits of individual options. It does not necessarily follow, for example, that the cumulative effects of allocating the top ten individually ranked sites is less significant than selecting a combination of sites from the top fifteen or twenty. This is because some combinations may be able to deliver significant social and economic benefits with a relatively small increase in environmental harm.

b)      Could increased use of such methodologies dovetail effectively with the efficient operation for environmental planning systems?

50.       Methodologies such as GLVIA are based on EIA and have the advantage that they are already part of the environmental planning system. The revised Guidelines set down a series of principles which can be applied to all levels of plan making and appraisal.

51.       Sustainability appraisal could dovetail with existing EIA processes and provide information related to sustainability policies. The current use of landscape indicators is set out in Table 3.

52.       Sustainability appraisal could greatly assist in decision making provided that there was sufficient agreement on the selection of criteria and their application. There would need to be consistency of approach within the regional planning areas to allow data to be used in both 'top-down' and 'bottom-up' assessments.

53.       The Environmental Capital approach has still to prove its worth but it appears that it could be developed to add weight to the consultation process and improve evaluation of local importance. However, the indications are that this requires more time than other approaches because of its complexity. The methodology is being finalised over the next few months and should be reviewed again at a later stage.

How widely applicable should environmental appraisal be?

54.       Ideally it would be helpful to apply environmental appraisal/ reporting to all projects and plans provided that it did not give rise to significant cost or time penalties. Unfortunately the current system suffers from uncertainty about the scope and detail required for appraisal and the appropriate test for compliance. Standards are inconsistent and are open to abuse on both sides.

55.       If the benefits of environmental appraisal are to be achieved through wider application greater attention needs to be given to regulation and monitoring to ensure that the information required meets the objective of the assessment; the requirement for too much information may be an unnecessary burden on beneficial development opportunities, too little information may lead to poor decision-making or legal challenges.

What level of detail is appropriate for the various plan types?

56.       The current/developing system is set out in Table 6. It has the advantage that the level of detail increases as the decision becomes more site specific. The disadvantage is that the higher level decisions are based on generalised information which may prove to be misleading or inappropriate at the local level.

57.       For example the use of sustainability indicators provides some broad guidance at a national level but, for landscape designations, has still to be refined to indicate the effects on condition and quality. Indicators are also only based on the scale of loss (i.e. the extent of development) and not its nature, permanence etc. which will affect the ability of the landscape to absorb development and the potential effect on the qualities of the landscape.

58.       The analysis in Table 6 is based on LI/IEMA Guidelines for landscape and visual impact and subdivides the landscape into three sub-elements (features, character and quality) within each level of appraisal. The level of detail should be appropriate to the level of decision making and the availability of consistent and reliable data within the area.

59.       It is generally assumed that the level of appropriate detail increases down the decision-making hierarchy. For higher level decisions Table 6 illustrates the reliance on designations; this approach contradicts PPG7 (para 2.14) in that it fails to give sufficient importance to all landscapes and inevitably directs development towards undesignated areas.

60.       The use of indicators gives a general impression of the context for spatial planning decisions and policy in order to encourage positive change e.g. through new planting or control losses/ damage by directing development away from 'sensitive areas' (presently defined by designations). However the DETR Circular 02/99 for EIA makes it clear that it cannot be assumed that designated areas are always 'sensitive'- see paras. 38, 39 and 44. Broad-brush decisions will need to be tested at the lower levels to allow a more detailed assessment to be undertaken and this then needs to be fed back into the strategic analysis.

61.       Unfortunately the logical sequence of top-down decision-making informed by bottom-up information often fails because the Plans are reviewed out-of sequence or environmental information is not available e.g. County or Local landscape character studies or urban capacity studies. For landscape issues this puts the emphasis back on to designations, particularly statutory designations. This may be an acceptable approach provided always that it is confirmed (at the lower level) through more detailed assessment. For example at the higher levels development may not be acceptable in AONBs but at the local level it may be acceptable either because it is the most sustainable location (taking all factors into account) and/or the quality of that particular part of the AONB is poor.

Table 6: Assessment Approaches (England)

Who should be responsible for: i) undertaking environmental appraisal, and ii) judging its quality?

62.       Environmental appraisal is best undertaken by professionals with training in the subject (e.g. through landscape or planning courses) and preferably some form of post qualification accreditation.

63.       Landscape professionals are well placed to take on the co-ordination role for environmental appraisal as the mitigation measures commonly manifest themselves in the design and management of the landscape. Landscape architects also able to provide an integrated approach to landscape conservation and heritage issues.

64.       Many local authority landscape/countryside units and private practices have expanded their services to include ecologists and archaeologists in order to meet the demand for a co-ordinated response to the land-based elements of environmental appraisal.

65.       The judging of environmental appraisal is increasingly undertaken by independent auditors e.g. the IEMA or private consultancies. This trend has developed because of the scarcity of environmental expertise within some determining authorities and the tendency of the appraisal author (developer or local authority) to use their own staff (or consultants) to undertake the appraisal.

66.       There is a strong case for regular, independent auditing with an appeal procedure to a higher power e.g. a specialist unit within the DETR. The DETR already have responsibilities as an adjudicator for screening and scoping of EIAs and the auditing of EIAs submitted under the Transport and Works Act and Highways Act (check). The DETR (through its regional Government offices) is also required to comment on environmental appraisals which form part of Regional Planning Guidance and Development Plans. These powers could be extended to all forms of environmental appraisal.

c)      What would be the value of increased use of other assessment tools, e.g. sustainability appraisal, environmental capital, environmental footprints, environmental space, and health impact assessment?

67.       There would be a benefit in developing more formalised methodologies for:-

• Sustainability assessments
• Cumulative assessments

Cumulative assessments are needed because they are often dealt with poorly at the project level and/or are assumed (incorrectly to have been considered at the Development Plan stage.

68.       In both cases there is a need for a consistent methodology which can be applied at a range of levels. There are now sufficient examples of completed appraisals to undertake a review of current practice with recommendations for an appropriate methodology.

69.       Environmental Capital methodology has been considered earlier in this evidence. The pilot studies have established potential benefits in the 'process' of decision-making but, compared with existing techniques, Environmental Capital makes little difference to the decision.

70.       The Environmental Capital approach is being promoted by the environmental agencies as an assessment tool. There is good reason to be cautious about adopting the methodology at this stage:-

• The Environmental Capital approach has changed significantly from its original form and may change again
  
• The pilot studies do not show significant benefits over other methodologies
  
• The character approach (upon which much (but not all) of Environmental Capital is based) is at a defining stage in its development and could be damaged by introducing more complex methodology
  
• The role of landscape designations is unclear
  
• The assessment focuses on the need to undertake public participation to record what is important and why. However, the methodology uses academic terminology which may be difficult to understand by people outside the planning system.
  
• The methodology also relies on information about 'Rarity' and trends which may not be available (as it requires an environmental database at District or Regional Level)
  
• Environmental Capital does not replace the need for formal (or informal) EIA.

[Note that these techniques compliment the EIA process but do not replace it. Both of the DETR methodologies use the Environmental Capital approach even though this methodology has still to be finalised following the assessment of the pilot studies].

d)       Are there good examples of comparisons between the actual environmental, social and economic effects predicted when a case was being considered and what the actual effects were?

72.       There are very few examples of comparisons between predicted and actual effects. Where effects are the subject of planning conditions e.g. noise levels there will be information available on predicted and actual noise levels but these are rarely compared.

73.      The comparison of predicted and actual effects for landscape is particularly difficult to obtain because of the relatively long time periods (e.g. for tree growth and screening) and the effects of 'external' factors such as weather, vandalism etc.

74.      However, the HA has established a system of comparison for DBFO contracts where the contractor is obliged to meet the mitigation standards set out in the EIA; the contractor's performance against these standards is monitored on a 5 year cycle (e.g. DBFO contract for the M40 Road Widening and corridor management).

In addition, is there evidence of the effectiveness of pre-development mitigation and compensation agreements at avoiding unsustainable outcomes?

75.       Pre-development mitigation and compensation measures can include advance planting, path diversions, habitat relocation, fauna relocation (e.g. bats, badgers and great-crested newts). These are generally very effective at reducing the potential impact of development and avoiding an unsustainable outcome through habitat loss or long term visual impact. There is sufficient information about these techniques to assess their potential effectiveness at the decision-making stage (Local Plan review or planning application). Environmental Capital may help this process by providing a transparent, systematic means of justifying decision made in relation to mitigation etc. However, it should be noted that this method does not necessarily give different results from other techniques although it does provide a clearer record of the process .

76.       These measures will only be effective in avoiding unsustainable outcomes if they are tied into the outline permission through conditions/ agreements. Currently there are few checks on their effectiveness and little in the way of sanctions if they are not effective. Longer-term management plans, supported by commuted sums, can provide a large measure of control for the regulating authority but require a degree of flexibility to ensure that the measures can be adapted to meet the sustainability objectives. An alternative approach is to define performance criteria for mitigation e.g. boundary planting should screen X% of the development within 15 years; again the problem is defining a sanction/ penalty if this is not achieved.

77.       Pre-development mitigation may also include survey and monitoring to establish a more detailed baseline e.g. for archaeology or aquatic wildlife. These more detailed studies are often not required to support an outline planning application and EIA.

78.       Planning conditions may need to require that the final form of development should be modified to take account of the information obtained through those surveys (e.g. through archaeological investigations) or additional mitigation measures/ compensation provided to offset any effects revealed after planning permission is granted. Ideally all the key issues should have been identified before planning permission is given).

e)      How adequate is the knowledge base, including the location and availability of expertise, provision for training for practitioners, and the accessibility and quality of data?

79.      The knowledge base for landscape assessment is extensive and training is provided through recognised landscape courses and EIA courses.

There are also CPD courses on EIA available at a number of universities and colleges.

80.       Assessment methodology for landscape and visual impacts is well documented and kept up-to-date through consultation with a wide range of bodies including the DETR, Countryside Agency, Planning Inspectorate etc. The original 1995 assessment guidelines were produced jointly with the IEA (now IEMA) who are responsible for accreditation and audit of EIA professionals and ESs. The new guidelines are to be published towards the end of 2000.

81.      The LI/ IEMA methodology is universally accepted as the standard for the profession and provides substantial consistency throughout the UK and Ireland.

How far are any of these elements in the knowledge base constrained by the lack of resources or suitable institutions, and, if appropriate, how could that be remedied?

82.       The limiting factor for assessments involving landscape and visual impact is the availability of consistent baseline data on landscape resources and landscape character.

83.       The limitations are the result of a shortage of funding at LPAs and the inability of LPAs to achieve consistency within regions and counties. This creates difficulties in assessing projects which cross borders and significantly reduces the availability of comparable data for assessment at County and Regional / national level.

84.       The Landscape Institute has recommended that a nation-wide review of the present arrangements be undertaken before further changes are made (ref para above).

85.       Subject to the outcome of this study it is suggested that many of the existing limitations could be remedied by the standardisation of baseline data capture and recording/ mapping within LPAs and other authorities e.g. Community Forests. This information could be used to develop a consistent secondary tier of landscape areas based on the National Character Map and provide baseline information for indicators and sustainability appraisal. This information could be used to inform decisions at the Regional and Local levels. More detailed local studies would need to fit into this 'top down' approach initiated by the national character study. Any existing studies could be used to inform the assessment of the second-tier areas and could be modified/ adapted in the light of the larger scale work.

86.       The studies could be commissioned by the regional planning boards using public and private sector resources based on a set of national criteria to be established by a Countryside Agency / DETR / Landscape Institute working party.

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