The staff of the Marine Management Organisation (MMO) have acknowledged the complexity of the Southern Area for which they are now embarking on a marine planning process. This was made clear at a workshop in January held to launch the new planning process.
Some old chestnuts still plague the planning process. Top of the list is how to deal with cumulative effects of projects. When asked about this, MMO could do little more than admit that they were struggling with this issue. How do you make a planning decision when faced with looking at the impact of a project in an area where there are other applications and consents for projects that may or may not go ahead? Not easy! But that is why they are there. After the workshop we pressed the point, and MMO are now consulting the Coastal Partnerships to see how to develo the debate.
Here are the questions being asked by MMO, and our response.
What does the term cumulative effects mean to you?
The phrase came to the fore when the Habitats Regulations came out. Developers and Relevant Authorities were required to consider the effect of plans or projects “alone or in combination with other plans or projects”in “an appropriate assessment” . This lengthy phrase was reduced to the shorthand term “cumulative effects”. The scope of the term “cumulative effects” may have been widened since then, but this remains the fundamental issue. Later legislation such as the various environmental impact assessment regulations also require cumulative effects to be considered, but the exact phraseology may vary.
It is usual for the impacts to be measured against a baseline at the time when the application for a plan or project is made (i.e. not taking account of past impacts). Recently it has been suggested that in some instances (e.g. the cumulative impact of numerous small dredging campaigns in marinas and the channels of the Hamble River) may have had an adverse effect that ought to be taken into account i.e. That the baseline should be set back in time. This would be equivalent to a polcy requiring that any new project should (wholly or in part) mitigate past loss. It is usual to put such a problem in the ‘too difficult’ basket. Perhaps the idea ought to be given an airing?
How would you like to engage with the MMO planning team on this matter?
Developers, and those seeking to protect an area, need to understand clearly the criteria for development. Our understanding is that one of the primary reasons for the creation of MMO and its marine planning function was the realisation that projects for cables, fishing, marine conservation, and alternative energy generation (incl offshore windfarms) were leading to a complex situation that required management. Almost by definition this requires an understanding and a clear attitude to cumulative effects.
The absence of any clear strategy for dealing with the issue could call into question the entire basis of marine planning. That would be a pity. Moreover, projects on land are usually constrained by a site dedicated for a specific purpose. Only rarely is the multifunctional use of an area encountered, whereas at sea this is commonplace, We believe that an opportunity to tease out the issues and to reach some understanding of how multiple projects will be viewed would be valuable.
In particular, there should be a recognition that there are 2 clear strands to the problem, namely
- · Scientific – i.e. the technical process of determining what should be the baseline, and how to estimate the impacts . This problem is susceptible to an objective approach.
- · Organisational – i.e. the process of how to decide which plans or projects to include in a cumulative effects assessment; how to deal with projects that may arise after the assessment has commenced; how to take into account plans or projects for which consent has been granted and which have not started (and which may or may not start) etc. This is NOT susceptible to an objective approach and must be dealt with subjectively
Those not in the eco-industry, such as local government, NGOs , and others such as Solent Protection Society, which is not part of the professional eco-industry would value an up to date statement on the the first of these. In this regard it is understood that ABP Mer have recently undertaken a project on behalf of Natural England on this subject. Some report back would be useful, with an opportunity to question and comment.
With regard to the second bullet, two papers were presented at the recent Coastal Futures conference that clearly indicated frustration at lack of progress in this area would be worth revisiting with a discussion opportunity. Also it would be worth a workshop style session at which the alternative approaches were explored and there would be an opportunity for creative ideas to be put forward
Do you think it would be useful if the Solent Forum held a workshop on cumulative effects?
We are delighted to learn that MMO have listened, and plan to investigate this area thoroughly.
Indeed, thay have recently stated that
“The Marine Management Organisation (MMO) has let a contract for consultancy support to NIRAS Consultancy Ltd supported by AMEC to take forward this MMO project on cumulative effects. The project is due to run to the end of March 2014 and aims to develop a consistent approach to the identification and consideration of cumulative effects that can be applied at a strategic level across all relevant MMO functions (this may include marine planning, marine licensing and marine conservation and enforcement) and across all Marine Policy Statement sectors. The project seeks to consider environmental, social and economic cumulative effects.
The project aims to produce key outputs as follows:
1. A framework for high level scoping of cumulative effects. This will aim to help highlight critical issues at a high level relating to cumulative effects between and within specific marine activities to enable more targeted consideration/assessment of these issues across MMO functions.
2. Guidance on potential options for where responsibility may lie for cumulative effects assessment/mitigation. This is under development but may include aspects of proportionate expectations (e.g. relating to scales of activities), issues arising from shared space, what level of information might be required, might we look at primary effects as a surrogate for all effects at the high level, etc.”
SPS will be participating in this process.