What are SA/SEA adoption statements?

SA/SEA Adoption Statements are a key tool for improving transparency in the decision making process. The document allows stakeholders to see how environmental and sustainability factors have been considered. It shows how consultee views have been taken into account during the preparation of the plan. It also outlines the measures for monitoring the significant environmental effects of implementing the plan.

Each country within the United Kingdom legally requires a Strategic Environmental Assessment (SEA) Adoption Statement after adoption of a plan or programme[1]. As Sustainability Appraisals (SAs) incorporating SEA are undertaken for development plans in England and Wales, the Adoption Statement will usually be for the combined SA/SEA.  Essentially, the Statement tells ‘the plan-making story’, as it is produced at the final stage of the plan-making and sustainability appraisal process[2].

NB: An SA/SEA Adoption Statement is distinct from the Adoption Statement required about the plan itself, which will usually be one page long and outlines the date the plan was adopted, where the adopted plan can be viewed for inspection and identifies the documents that have been made available in accordance with the Regulation 26 of The Town and Country Planning (Local Planning) (England) Regulations 2012.

Preparing an SA/SEA Adoption Statement

In theory, preparing a SA/SEA Adoption Statement should be relatively straightforward as ideally all “the information should already be provided within the SEA/SA report, to show the public and examiners/inspectors that the SEA/SA has been taken seriously and has made a difference”[3].

However, in practice this is not always the case as the high volume of information gathered during the SA/SEA process often leads to a crossover of information between the different sections of the Adoption Statement.  This is especially true between the sections on how environmental considerations have been integrated into the plan and how the Environmental Report has been taken into account.

Our experience shows that a clear audit trail of decision making (i.e. the reasons for selecting reasonable alternatives, preferred alternatives, and discounting alternatives) from the outset is paramount.  Difficulties arise where there is not a clear audit trail or where opinions expressed at consultation stages have not been taken into account. LUC considers clear audit trails as imperative to the SA process as a whole, but particularly in producing a robust SA/SEA Adoption Statement. We advise our clients to produce one, whichever stage of the SA process they are at.

Structure of the document

SA/SEA Adoption Statements are not necessarily long documents. Rather than re-presenting information from the SA reports, they typically signpost the relevant sections.  The structure is therefore generally similar to the SA report as they broadly utilise the five regulatory requirements as chapter/section headings:

• How environmental considerations have been integrated into the plan.
• How the Environmental Report has been taken into account during preparation of the plan.
• How the opinions expressed by the public, consultation bodies and where appropriate other European Member States, during consultation on the plan and Environmental Report have been taken into account.
• The reasons for choosing the plan as adopted, in the light of the other reasonable alternatives dealt with.
• The measures that are to be taken to monitor the significant environmental effects of the implementation of the plan.

On completion of the SA/SEA Adoption Statement

Unlike SA reports prepared for other stages in the plan-making process, there is no formal requirement for publishing a SA/SEA Adoption Statement for consultation. However the plan-making authority needs to make the statutory consultation bodies, the public who expressed an interest in the plan, the Secretary of State and, where relevant, other EU Member States aware where the Adoption Statement can be viewed or obtained from.

[1] Regulation 16 of The Environmental Assessment of Plans and Programmes Regulations 2014 (SEA Regulations) in England; Section 18 of the Environmental Assessment (Scotland) Act 2005 in Scotland; Regulation 16 of the Environmental Assessment of Plans and Programmes (Wales) Regulations 2004 in Wales; and, Regulation 15 of the Environmental Assessment of Plans and Programmes Regulations (Northern Ireland) 2004 in Northern Ireland.

[2] Known as the ‘Post adoption reporting and monitoring the significant effects of implementing the Plan’.

[3] RTPI (2018) RTPI Practice advice: Strategic Environmental Assessment – Improving the effectiveness and efficiency of SEA/SA for land use plans.  Available at: https://www.rtpi.org.uk/media/2668152/sea-sapracticeadvicefull2018c.pdf.

Strategic Planning & Assessment at LUC