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Journal of Environmental Assessment Policy and Management


Vol. 10, No. 1 (March 2008) pp. 124
Imperial College Press

WHAT APPEARS TO MAKE SEA


EFFECTIVE IN DIFFERENT PLANNING SYSTEMS
PAOLA GAZZOLA
Department of Civic Design, University of Liverpool
74 Bedford Street South, Liverpool, L69 7ZQ, UK
gazzola@liverpool.ac.uk

Received 1 December 2006


Revised 14 January 2008
Accepted 18 January 2008
If Strategic Environmental Assessment (SEA) is to develop into an effective decision support
instrument globally, then it should not just rely only on the input provided by a selected
group of countries. In this context, the understanding of how to apply SEA effectively in
different planning systems is unlikely to improve if the knowledge about those systems is
limited. This paper establishes what appears to make SEA effective in two countries with
different planning systems: Italy and the UK. Italy is chosen as an example, representing a
specific Southern-European planning culture, which to date has not contributed to the SEA
literature to any great extent. Based on empirical observations, it is suggested that the SEA
effectiveness elements portrayed in the international literature are not fully valid. The UK
is chosen as an example, which represents a specific Northern-European planning culture.
Countries representing this planning culture have contributed heavily to the international
SEA literature and have influenced the development of SEA theory strongly. In this context,
the SEA effectiveness elements and benefits portrayed in the international literature appear
to be valid.
As part of a PhD research project, this paper builds on the findings of a content analysis
of the international SEA literature (Fischer and Gazzola, 2006).
Keywords: Northern-Europe; Southern-Europe; the UK; Italy; SEA effectiveness; planning
cultures.

Introduction
To support practitioners worldwide in the development of effective and good practice Strategic Environmental Assessment (SEA) and to help many countries conform
to best international practice (Cherp and Antypas, 2003), a number of effectiveness
1

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elements have been published in the international SEA literature1 (Sadler and
Verheem, 1996; Partidario, 1997; DETR, 1998; Nooteboom, 1999; CSIR, 2000;
Finnish Ministry of the Environment, 2001; IAIA, 2002; Fischer, 2002). Following
Fischer and Gazzola (2006), a summary of these elements is presented in Box 1.
Box 1. SEA elements portrayed in the international SEA literature.
SEA should be effective in ensuring environmental aspects are given due consideration
in PPP-making;
SEA should be integrated and sustainability-led, supporting a proactive planning process that is driven y clear goals and objectives; apart from environmental aspects, SEA
should also consider economic and social aspects;
SEA should be carried out with professionalism and those conducting it should be
made accountable; SEA should document and justify how environmental and sustainability objectives are considered in PPP practices in a transparent and simple manner;
in this context, quality control is said to be of great importance;
SEA should be stakeholder-driven, explicitly addressing the publics inputs and concerns, ensuring access to relevant information of the PPP-making process;
SEA should provide sufficient, reliable and usable information in a cost and time
efficient manner;
SEA should be iterative, being part of an ongoing decision cycle; it should inspire
future planning through the potential amendment of strategic decisions; in this context,
SEA needs to be applied in a tiered manner with effective project EIA within an
established PPP framework;
SEA should be flexible and adaptive to the PPP process.
Source: Fischer and Gazzola (2006).

SEA effectiveness elements can be divided into context and methodological elements, with the first representing the decision-making context in which SEA works;
and the latter, representing the specific methodology with which SEA should be
applied (Fischer and Gazzola, 2006). In this context, SEA is considered effective
when the benefits that SEA can fulfil are achieved (see Box 2). Thus, when the SEA
context elements representing the necessary framework conditions for effective SEA
are present; and moreover, when SEA is applied according to the methodology portrayed in the international SEA literature (Noble, 2000, 2002). However, findings
of a content analysis of the international SEA literature indicated that the published
SEA elements and benefits are based on practices and experiences of a selected
number of countries (see Fischer and Gazzola, 2006). Within the European context, these include countries representing a Northern-European planning culture.
Countries representing a specific Southern-European or Mediterranean planning
1 In this paper, the international SEA literature refers to single, co-authored and edited books, confer-

ence and workshop proceedings and research project reports published in English up to 2002. Publications were selected based on their accessibility to a wide international audience and on whether they
included international overviews of SEA systems, methodologies and case-studies (Gazzola, 2006).

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culture have not been considered to any great extent in the international SEA literature and have therefore not contributed to the development of the published SEA
elements and benefits.
Box 2. SEA benefits portrayed in the international SEA literature.

SEA can anticipate and highlight potential environmental problems;


SEA can prevent delays and assist the planning process;
SEA lead to better environmental protection and management;
SEA can promote sustainable development;
SEA can guarantee efficiency of the planning process; and
SEA can improve good governance.

Source: Dusik et al. (2003); Partidario (2003).

Purpose of the Paper


Based on the Introduction provided, two main considerations are made. First, if
SEA has to develop into an effective decision-support instrument globally, then it
should not rely just on the inputs provided by a limited group of countries. Within
this context, the elements for effective SEA published in the international SEA
literature may not be fully valid for those countries that have not contributed to
their development, for example, to the Southern-European countries. Second, if the
necessary framework conditions for achieving effective SEA are not fully valid,
then the portrayed SEA benefits are unlikely to be fully achievable. Consequently,
what appears to make SEA effective and the definition of SEA effectiveness may
vary in different planning systems. Thus, the understanding of how to apply SEA
effectively is unlikely to improve if the knowledge about different planning systems
is limited.
By making reference, recognising and understanding the societal and cultural
value frames that generally define the framework within which policies, plans and
programmes (PPPs) are developed and within which politics take place, SEA can
be tailored to a specific situation and the knowledge about a specific policy-making
context can be improved (Bartlett and Kurian, 1999; Nitz and Brown, 2001; Fischer
and Gazzola, 2006; Runhaar and Driessen, 2007; Hilding-Rydevik and Bjarnadttie,
2007). Therefore, it is suggested that an analysis of the rules, values, routines, priorities, attitudes and traditions of a specific societal and cultural framework, which
define, guide and formalise SEA development, is the key to achieve effectiveness
of the overall process.
Focussing particularly on Europe2 and set within the context of the EU SEA
Directive, this paper aims to establish what appears to make SEA effective in two
2 In this paper, the European context is intended as the EU prior to the 2004 enlargement.

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different planning systems, representing different planning cultures. These are:


(a) the Italian planning system, representing a Southern-European/Mediterranean
planning culture. As previously indicated, to date, Southern-European countries
have not contributed to the international SEA literature to any great extent.
Within this context, the portrayed elements for effective SEA may not be fully
valid and the portrayed SEA benefits, may not be fully achievable (Fischer and
Gazzola, 2006); and
(b) the UK planning system, representing a Northern-European planning culture.
Northern-European countries have contributed heavily to the development of the
international SEA literature. Amongst these countries, the UK in particular has
strongly influenced the development of the published SEA elements and benefits
(Fischer and Gazzola, 2006). Within this context, the elements portrayed in the
literature indeed appear to be valid and the SEA benefits fully achievable.
Based on empirical observations, this paper presents the results of a questionnaire
survey on how to adapt effective SEA for integration in planning systems with
different planning cultures. First, the Northern- and Southern-European planning
cultures are defined. This is followed by a presentation of the research methodology.
Subsequently, the findings are discussed, setting the basis for defining what makes
SEA effective in different planning systems.

NorthSouth Divide
In this section the Northern- and Southern-European planning cultures are presented
as opposing cultures, i.e. in terms of a NorthSouth divide. This is done by
looking at: (a) the role that experts and case-studies from Northern and Southern
European countries have in international academic publications; (b) the attitudes
and traditions with which planning is practiced in different countries; and (c) the
attitudes towards the environment within planning in different European countries.
International academic publications
Within the context of the international SEA literature, empirical observations indicated that experts from Northern-Europe have contributed more extensively to
the development of the published SEA elements and benefits than the experts
from Southern-Europe.3 This provides evidence of an emerging NorthSouth
3 These observations are based on the results of a content analysis of 45 key international SEA

publications published up to 2002. The content analysis was guided by three questions, i.e. (1) the
number of publications by the country an author is based in; (2) the number of SEA case-studies per
country mentioned in the international SEA literature; and (3) the frequency with which different SEA
systems are considered in the international SEA literature (Fischer and Gazzola, 2006; Gazzola, 2006).

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divide. Publishing authors, case-studies analysed and the systems described in


the international SEA literature mainly represent practices and contributions from
Northern-European countries. Practices and contributions from Southern-European
countries are scarcely represented (Fischer and Gazzola, 2006; Gazzola, 2006). The
national SEA literature within Southern-European countries tends to be more inward
looking, contributing to the development of SEA in a specific national context rather
than to the international SEA debate (Gazzola, 2006).
Following Curry and Lillis (2004), accessibility to the international academic
research language, i.e. the English language, appears to be one of the main reasons
for the existence of this divide. Publishing in English is one of the main requirements
for making contributions to the international SEA debate, in terms of developing
theory and improving good practice (Gazzola, 2006). Similar considerations have
been made for planning by Faludi and Hamnett (1975), Kunzmann (2004) and Janin
Rivolin and Faludi (2005). Furthermore, in many academic institutions worldwide,
English publications have higher status and constitute a major criterion for promoting scientific debates and for supporting scholars research grant applications
(Curry and Lillis, 2004). Looking particularly at the European context, the NorthernEuropean countries are therefore favoured, as English is spoken as a first or as a
second language. In Southern-European countries English is instead spoken as a
foreign language (Curry and Lillis, 2004).
Planning attitudes and traditions
The planning literature suggests different classifications of European countries,
which vary according to the criteria used. These include, for example:
the legal and administrative approach or style (Newman and Thornley, 1996;
Bhme, 2002);
the historical and cultural integration of environmental protection policies in
planning (Voghera, 2003, 2004);
the traditional planning approach (EC, 1997; Bhme, 2002); and
the planning attitudes (Janin Rivolin and Faludi, 2005).
Despite the different criteria, all classifications have one common denominator, i.e. the separation of the Southern-European/Mediterranean countries from
the Northern-European countries (i.e. the NorthSouth divide). Although the
Northern-European countries can be further divided into Germanic-Anglo-Saxon
(Voghera, 2003) and Nordic countries (Voghera, 2003; Janin Rivolin and Faludi,
2005), in this paper, they are considered as one group as a whole.
Evidences of a NorthSouth divide are also reflected in the lack of comparative
planning studies and published research looking at the opposite sides of the divide.
Whilst for some, this is due to the previously mentioned issues with the English

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language (Faludi and Hamnett, 1975; Kunzmann, 2004; Curry and Lillis, 2004);
for others, the lack of NorthSouth European comparative research is due to the
regional (spatial) disparities between the periphery areas and the core of Europe
(see Zonneveld, 2000). This aspect explicitly emerged during the making of the
ESDP,4 where, according to Portugal, Spain and Italy, the ESDP document failed
to convey a message to the marginal areas, favouring instead the core of Europe
(see Faludi and Waterhout, 2002; Janin Rivolin and Faludi, 2005).
Attitudes towards the environment in planning
In Northern-European countries the environment appears to be traditionally wellintegrated into public decision-making; in Southern-European countries this integration appears to be poorly developed (Bonavero et al., 1999; Lenschow, 2002).
This divide in terms of attitudes towards the environment is reflected in a number
of aspects. An awareness for environmental problems emerged later in SouthernEurope than in Northern-Europe (Williams, 1984; Salzano, 1985; La Spina and
Sciortino, 1993; Sapelli, 1995; Voghera, 2003). The institutionalisation of environmental movements has been weaker in the Southern-European countries, than in the
Northern-European countries (De Lucia, 1992; Rootes, 1995; Boato, 1996; Carter,
2001; Salzano, 2003). Furthermore, when implementing policies aiming to protect the environment and achieve sustainability, Southern-European countries have
been slower in transposing EU environmental Directives . . . and more importantly,
relaxed about enforcing them (Carter, 2001, p. 288; see also Lewanski, 1998, 2002;
Hanf and Jansen, 1998; Dunnage, 2002; Gazzola et al., 2004). Finally, data released
in 2004 indicated that Italy, followed by Spain, had the highest number of infraction
procedures concerning the implementation of EU environmental Directives (Lega
Ambiente, 2005).

Methodology
Southern and Northern-European planning cultures are further described through
a comparative analysis. Planning systems and requirements to take environmental aspects into account are different within different EU Member States (Risse
et al., 2003; Schmidt et al., 2005). Furthermore, the way in which planning and
environmental assessment are organised and practiced, are different in countries
representing different planning cultures (Masser and Williams, 1986; Barker and
Wood, 1999; Bond and Wathern, 1999; Risse et al., 2003; Newman and Thornley,
1996; 2005).
4 ESDP, European Spatial Development Perspective.

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Comparative analysis approach


The comparative analysis approach was conducted at two levels of analysis, (1) the
European level, looking at Northern-European and Southern-European countries
and (2) the case-study level, looking at the UK and Italy. Whilst the UK was chosen
as a case-study representing a specific Northern-European planning culture; Italy
was chosen as a case-study representing a specific Southern-European planning
culture. A framework for the comparative analysis, describing the public decisionmaking contexts in which effective SEA is applied, i.e., the societal and cultural
framework, was developed. It was structured according to five themes, which have
been identified through a literature review. These are:
1. The attitudes towards the environment within planning: This theme aimed to
establish the degree of environmental awareness in a country/system in terms of
the level of environmental integration in public decision-making;
2. The spatial planning system: This theme aimed to identify the strengths and
weaknesses of the countrys planning system, within the context of applying
effective SEA;
3. The EIA system: This theme aimed to explore how effective and well-established
the countrys existing EIA system is;
4. The sustainability context: This theme looked at whether the country has a sustainable development framework or strategy for sustainability in place that provides the aims and objectives for the underlying SEA; and
5. The SEA system: This theme looked at the existing SEA system prior to the
implementation of the SEA Directive (2001/42/EC) and, furthermore, at how the
existing practices have or will be adapted or integrated to meet the Directives
requirements.
The framework for analysis structured the questionnaire surveys and its five themes
were used as key subjects for literature reviews.
Questionnaire surveys
The European questionnaire survey was electronically sent to 114 SEA experts representing the Southern and Northern countries. Whilst the Southern-European countries included Italy, Spain, Portugal and Greece,5 the Northern-European countries
included the Germanic-Anglo-Saxon and the Nordic countries. The experts
were identified using the membership database of the International Association for
Impact Assessment (IAIA). The database specified for each member includes the
5 France is said to act as a bridge between the North-Western and the Southern attitudes in planning

(Breda, 1999; Janin Rivolin and Faludi, 2005).

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country of origin, the institutional affiliation, the area of expertise and specialisation. Other sources for identifying the experts included the European network of
EIA Centres (EC, 2005). The overall response rate was 22.81% and the adjusted
overall response rate was 28.9%.6 The questionnaire survey aimed to discuss the
validity of the portrayed elements for effective SEA and the feasibility of the SEA
benefits for planning systems, representing different planning cultures.
Following the results of the European questionnaire survey, semi-structured
questionnaires were sent to Italian and UK SEA experts.7 These included academics,
government officers, private consultants and representatives of environmental agencies, NGOs and of the Ministry for the Environment and Territorial Protection. The
experts were identified using the participant lists of SEA workshops, seminars and
conferences based in the UK and Italy. Relevant national membership associations
were also consulted, for example, the Institute of Environmental Management and
Assessment for the UK and the Associazione Analisti Ambientali (Association of
Environmental Analysts) for Italy. In total, 34 questionnaires were electronically
sent to UK SEA experts (25.9% response rate) and 22 questionnaires were sent
to Italian SEA experts (19% response rate). To ensure confidence, robustness and
soundness of the surveys results, the questionnaire findings were integrated with
semi-structured interviews with experts from both countries. The questionnaire survey and interviews aimed to identify system-specific elements and benefits relevant
to the contexts of different planning systems. This was done to understand when
SEA is effective in Italy and in the UK.

Questionnaire Findings
In this section, the questionnaire survey and literature review findings are presented.
First, the relationship between the elements portrayed in the international SEA literature and those suggested by the experts is explored. This is followed by an analysis
of the extent to which the SEA context and methodological elements portrayed in the
international literature are present and valid to the Southern- and Northern-European
planning cultures. Finally, the extent to which the SEA elements suggested by the
Southern-European and Italian experts are valid to the Northern-European planning
culture is examined.

6 The questionnaire survey response rate was adjusted by subtracting from the 114 addresses, the

number of questionnaires that were not going to be completed, because they failed to be delivered or
because of the unavailability of the expert. This was done by recording the email notifications.
7 The Italian and UK experts that participated in the European questionnaire survey were not included
in the national experts survey.

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Elements for effective SEA for Southern- and Northern-Europe


Based on the questionnaire survey findings, four sets of SEA effectiveness elements were identified. These included the SEA elements suggested by the experts
representing (1) Northern-Europe, (2) Southern-Europe, (3) the UK and (4) Italy.
Overall, the SEA elements suggested by the Northern- and Southern-European
experts were somewhat inconsistent with each other. The main differences concerned the methodological elements suggested. Whilst the experts representing a
Northern-European planning culture and the UK emphasised the importance of
participative, transparent, flexible and adaptive approaches; the experts representing a Southern-European planning culture and Italy indicated that in order to achieve
effectiveness, SEA should be applied in a rigid, strict and mandatory way. Consistencies between the SEA effectiveness elements were also identified. These included:
the importance of having a legal and administrative framework in place. This is
due to the influence of having a common EU framework, with which all European
Member States must comply; and
the accountability of the decision-making system. For the experts representing
the Northern-European countries and the UK, accountability of decision-making
systems can be achieved through documentations. For the experts representing
the Southern-European countries and Italy, accountability can be ensured through
the institution of an independent body, ensuring quality control.
The relationship between the four sets of SEA elements is further summarised in
Fig. 1. In this context, how the suggested elements relate to the SEA elements
portrayed in the international SEA literature is also presented.
The SEA elements suggested by the Italian and UK experts are consistent
with those identified by the experts representing, respectively, the Southern- and
Northern-European countries (see Fig. 1). Moreover, as shown in Fig. 1, the elements portrayed in the international SEA literature are on the one hand, consistent
with the elements suggested by the experts representing the Northern-European
countries and the UK. Thus, confirming that within the EU context, the elements
portrayed in the international SEA literature are based on practices and experiences
from Northern-European countries only. On the other hand, the elements portrayed
in the international SEA literature are inconsistent with the SEA elements proposed
by the Southern-European and Italian experts. Thus, suggesting that the published
SEA elements are not fully valid to countries belonging to the Southern-European
planning culture. The SEA elements suggested by the Northern-European (NE) and
UK experts, together with the elements portrayed in the international SEA literature,
can therefore be considered as one set of effectiveness elements only. The elements
suggested by the Southern-European (SE) and Italian (ITA) experts, also consistent

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Elements

for

effective SEA

International

Northern-

Southern-

SEA literature

European

European

countries

countries

UK- specific

Italyspecific

International
SEA literature
NorthernEuropean
countries
SouthernEuropean
countries
UK-specific
Italy-specific

, consistency between elements;

inconsistency

between

elements.

In

symmetric

matrix

the

entries are symmetric with respect to the main diagonal (top left to bottom right), thus equal to its
transposed. In Fig. 1, the shaded cells indicate the transposed or symmetric entries.

Fig. 1. Relationship between the four suggested sets of SEA elements and the SEA elements advertised in the international literature.

with each other, can be considered as one set of SEA elements, as well. In Figs. 2
and 3 these two sets of elements are referred to as literature + NE + UK and
SE + ITA.
Literature + NE + UK SEA elements Validity to Southern- and
Northern-European countries
Figure 2 shows the context and methodological elements for effective SEA suggested by the Northern-European and UK experts and portrayed in the international
literature. These are structured in terms of the themes of the framework for analysis
described in the Methodology section. Furthermore, Fig. 2 looks at the extent to
which these elements are valid and contribute to effective SEA in:
Southern-European countries, focussing particularly on Italy as a case-study representing a specific Southern-European planning culture; and
Northern-European countries, focussing particularly on the UK as a case-study
representing a specific Northern-European planning culture.
In Fig. 2, the validity of the SEA elements to different contexts is represented through
shaded areas. These indicate for each context whether an element (a) is valid and
therefore needed to achieve effective SEA; (b) is probably valid and needed to
achieve effective SEA; and (c) is not valid and therefore not needed to achieve
effective SEA. The way in which the SEA elements are performing in the different
contexts is also represented. This is done with symbols indicating for each context

Sust. context

SEA system

= element in place performing poorly

Europe

Southern-

UK

= element not in place

Europe

Northern-

NR = not relevant for SEA approach adopted

Italy

Fig. 2. What constitutes effective SEA in Southern- and Northern-European countries literature + NE + UK SEA elements.

= element in place and fully developed

Is not needed for effective SEA

in SEA making. Availability of manuals and guidance.

cost and time efficient generation of sufficient, reliable and usable information

procedures defined by guidance;

adaptable SEA process open to the input of the general public, with

stakeholder-driven, sustainability-led, focused, iterative, flexible and

documenting, transparency and simplicity;

high degree of accountability and quality control in SEA, through

existence of sustainable development framework/sustainability strategy;

well-established and effective EIA system, to which SEA can be tiered;

effective cooperation and public participation;

well-established PPP-making system (e.g. spatial planning system);

existence of environmental awareness;

integration;

established institutional framework for environmental consideration/

Maybe needed for effective SEA

EIA system

system

Spatial plan

Is needed for effective SEA

experts)

NE+UK

literature,

on

Context criteria

Methodological

(based

Env. attitude

criteria and

SEA

elements

Elements for effective SEA application, validity to:

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11

system

SEA

context

Sust.

system

EIA

system

plan.

Spatial

criteria and

= element in place performing poorly

NR

NR

NR

NR

UK

= element not in place

NR = not relevant for SEA approach adopted

NR

NR

Europe

Southern-

Fig. 3. What constitutes effective SEA in Southern- and Northern-European countries SE + ITA SEA elements.

= element in place and fully developed

Is not needed for effective SEA

in SEA making, through rigid, clear and prescriptive government provisions.

information on environmental baseline, impact and alternative assessments

cost and time efficient generation of sufficient, reliable and usable

SEA;

assessment of alternatives, including the do-nothing alternative in ex-ante

by introducing mandatory requirements for the consideration and

evaluations;

requirements; by instituting independent quality controls through ex-post

subjected to an SEA; by providing clear substantive and procedural formal

ensure better enforcement and transparency by identifying which PPs are

and legal approach;

applied in a systematic, rigorous and strict manner according to a formal

parallel to the PPP-making process;

in which environmental compatibility thresholds are defined; separate or

environmental baseline-driven, with homogeneous procedural requirements

and transparency;

Institution of an independent body to ensure quality control and verifications

the proponent. The proponent and the assessor(s) should be separate.

roles and responsibilities clearly defined with the main responsibilities on

subsidiarity principles;

PPPs must be tiered through a planning approach based on hierarchy and

system), in which PPPs are environmentally compatible;

well-established PPP-making system (for example, spatial planning

increase politicians commitments towards the environment;

consideration/integration;

established institutional and legal framework for environmental

Maybe needed for effective SEA

Context criteria

attitude

Is needed for effective SEA

experts)

by SE+ITA

(suggested

Methodological

Env.

Italy

NR

NR

Europe

Northern-

12

elements

SEA

Elements for effective SEA application, validity to:

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whether an element is (a) in place and fully developed (i.e. X); (b) in place, but
performing poorly (i.e. o); and (c) not in place (i.e. ). The same keys (i.e.
shaded areas and symbols) are used in Fig. 3.
As indicated in Fig. 2, the findings suggest that SEA context elements are currently underdeveloped in Italy and more in general, in Southern-Europe. There is
no established institutional framework in place and an awareness for environmental problems is poorly developed (La Spina and Sciortino, 1993; Sapelli, 1995).
The experts indicated that sustainable development strategies defining environmental objectives are lacking (Bettini and Gazzola, 2001; Gazzola, 2002).8 Although
in place, EIA systems are not working effectively. EIAs are applied too late and
conducted in a highly flexible manner (Lewanski, 2002). The public also appears
to be insufficiently involved (Del Furia and Wallace-Jones, 2000). However, wellestablished and long-term planning traditions and systems on which effective SEA
could rely and build on appear to be in place (Fischer and Gazzola, 2006).
Within this context, the findings suggest that the methodology portrayed in the
international SEA literature based on procedural flexibility is not valid to the Italian context. Experience in Italy with the suggested methodology has proven to
be negative with EIA practice (Schmidt di Friedberg, 1995; Lewanski, 2002; Fondazione Eni Enrico Mattei, 2002). The introduction of flexible SEA in a highly political context would probably mean further legitimising the non-accountable nature
of PPP-making (Gazzola et al., 2004; Fischer and Gazzola, 2006). The questionnaire findings and literature reviews indicated that similar behaviours are likely to
occur in the other Southern-European countries as well, where political negotiations
are also highly influential (La Spina and Sciortino, 1993; Carter, 2001; Gazzola,
2006).
Figure 2 also shows that in those countries that follow a Northern-European
planning culture, the SEA context elements portrayed in the international literature
are not only in place, but also contributing towards the achievement of effective
SEA. However, the effectiveness of the UKs PPP-making system was described as
somewhat uncertain, due to the recent introduction of the Planning and Compulsory
Purchase Act in 2004, reforming the overall planning system. Described as uncertain, was also the tiering relationship between EIA and SEA. By contrast, how an
existing and effective EIA system could contribute to the development of effective
SEA and the benefits that could emerge through tiering seemed more certain and
visible in the other Northern-European countries, particularly in the Netherlands,
Denmark and Germany.
8 The experts responses describe the countries contexts at a national level. Questionnaire findings

indicate that for those countries where planning and environmental assessment responsibilities are
devolved to regional level governments, the description of the contexts are likely to vary.

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Overall, the methodology for effective SEA application portrayed in the international SEA literature appeared to be fully valid and suitable to the contexts of the
Northern-European countries. Thus, effectiveness can occur when SEA is applied
in a stakeholder-driven, flexible, adaptable, sustainability-led and iterative manner.
SE + ITA SEA elements Validity to Southern- and Northern-European
countries
In Fig. 3, the SEA elements suggested by the experts representing Southern-Europe
and Italy are presented. Figure 3 particularly looks at the extent to which the suggested elements are valid and can contribute to the achievement of SEA effectiveness
in Northern- and in Southern-European planning countries, and in the UK and Italy.
Based on the findings, having a well-established PPP-making system in place
is important for both, the Northern- and the Southern-European countries (Fig. 3).
Ensuring that PPPs are (at least) environmentally compatible is particularly important for the Southern-European countries, as the level of environmental awareness
and environmental integration in public decision-making is said to be low in these
countries (Lewanski, 1998). Although long-term experiences in dealing with the
environment are lacking, PPP-making systems in Southern-Europe are said to be
well-established and structured, with long-term planning traditions and practices in
place. Furthermore, planning is mainly practiced following hierarchical and subsidiarity principles, which ensure that the environment is taken into account in a
mandatory manner and that (at least) the environmental compatibility of the PPPs
is achieved (Salzano, 2003; Gazzola and Caramaschi, 2005). As shown in Fig. 3,
these principles are not relevant to planning practice in all European countries
(Albrechts et al., 2003). In the UK, for example, planning functions according to
discretionary and flexibility principles (Prior, 2005; Cullingworth and Nadin, 2006;
Allmendinger and Haughton, 2007).
Experts representing Southern-Europe and Italy have not suggested elements
for the EIA system and sustainability context themes of the framework for analysis, because considered not relevant to their contexts. As indicated earlier,
in Southern-European countries strategies for sustainable development are either
poorly developed or not in place and existing EIA systems are said to be ineffective. In Italy, for example, the existing EIA system is perceived to be unstructured,
non-transparent, insufficiently open and highly political (Malusardi and Talia, 1992;
Schmidt di Friedberg, 1995). Consequently, SEA should not develop relying on such
volatile systems. By contrast, having established EIA systems and strategies for
sustainable development in place are considered important for the development of
effective SEA in Northern-European countries. In the UK, for example, strategies for
sustainable development set the context for planning and Sustainability Appraisals

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(SAs) (ODPM, 2004; 2005; HM Government, 2005). However, within the NorthernEuropean countries, responses from Germany and the Netherlands indicated that
strategies for sustainable development are not an important framework condition
for achieving effective SEA. In these contexts, established environmental objectives
and strategies provide the framework for the underlying SEA objectives (which nevertheless, could be considered as proxies for sustainability strategies).
In summary, Figs. 2 and 3 suggest that the Northern- and Southern-European
planning cultures differ mainly in terms of the specific methodology with which
SEA should be applied. SEA should be applied in a rigorous, structured and strict
manner in those countries that follow a Southern-European planning culture (for
example, Italy). SEA should be applied in a more flexible, adaptive and participative manner with procedures defined by guidance in those countries that follow a
Northern-European planning culture (for example, the UK). Moreover, the findings
indicated that three of the methodological elements suggested by the SouthernEuropean experts could contribute to the achievement of effective SEA in the
Northern-European countries (see Fig. 3). The separation of roles and responsibilities could make planning systems more accountable and improve decision-making
at the operation level. This element could be particularly valid to the UK context,
where organisational issues can represent barriers to effectiveness, for example, in
terms of the effective coordination of policies from the central to the more operational levels of planning and between departments (see Richardson and Jordan,
1979; Jordan, 2002a, b); or in terms of the effective coordination of planning and
appraisal tools within the new planning system (Therivel and Walsh, 2006). The
recent introduction of the new planning system, together with the requirements for
conducting SEA, subsumed within the new SA system, and the requirements for
Appropriate Assessments are said to have generated considerable uncertainties and
added further pressures on planners and authorities (Therivel, 2006). Second, there
are indications that the existence of homogenous formal procedural requirements for
the collection of environmental baseline information in which minimum environmental compatibility thresholds are defined, could contribute to make SEA more
sound and robust and plans and programmes more environmentally sustainable.
Third, if mandatory requirements for considering various alternatives, including the
do-nothing alternative in ex-ante SEA, were introduced, then SEA could become
more effective in supporting decision-making.

System Specific Elements for Effective SEA


In this section, system specific SEA context and methodological elements for Italy
and the UK are presented. These have been identified through interviews, and questionnaire survey and literature review findings.

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System-specific elements for Italy


Similar to the other countries in Southern-Europe, in Italy the environment is poorly
integrated and the SEA context elements are poorly developed. Within this context,
if the elements presented in Table 1 were in place, then effective SEA could develop.
The elements presented in Table 1 address and emphasise two important aspects
describing the Italian PPP-making context. These are:
the high impact that political negotiations and interests have on decision-making
(see also Jones, 2003). In Table 1, this is represented by the importance given
to issues of accountability, controls and verifications and to the need to increase
the political willingness to take the environment into consideration in decisionmaking; and
the low level of environmental awareness. This aspect is addressed by the
need to collect environmental baseline information, to achieve (at least) the
environmental compatibility of PPPs; and by the need to strengthen the existing environmental legislation, which is insufficiently developed.
Overall, to achieve effective SEA in Italy, SEA needs to develop through a strict,
structured and rigid approach. It should rely on clear, rigorous and prescriptive

Table 1. Elements for effective SEA in Italy.


Elements for effective SEA for Southern-European planning culture
established institutional and legal framework for environmental consideration/integration, with
strengthened environmental legislation;
increase in politicians commitments towards the environment;
well-established PPP-making system (for example, spatial planning system), in which PPPs are
environmentally compatible;
PPPs must be tiered through a planning approach based on hierarchy and subsidiarity principles;
roles and responsibilities are clearly defined with the main responsibilities on the proponent.
The proponent and the assessor(s) should be separate. Institution of an independent body to
ensure quality control, verifications and transparency;
environmental baseline-driven, with homogeneous procedural requirements defined by government provisions, separate or parallel to the PPP-making process;
applied in a systematic, rigorous and strict manner according to a formal and legal approach,
with clear procedures and prescriptive government provisions for SEA application and for
taking into account the SEA findings;
ensure better enforcement and transparency by identifying which PPs are subject to an SEA;
by introducing mandatory requirements for the assessment of alternatives, by providing clear
substantive and procedural formal requirements; by instituting independent quality controls
through ex-post evaluations.

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government provisions. Within this context, the main purpose for applying SEA is
to ensure accountability of the decision-making system and to improve the countrys
overall attitude towards the environment in planning.
System-specific elements for the UK
As anticipated in Fig. 1, the system-specific elements for the UK are somewhat
similar to those portrayed in the international SEA literature. The SEA context
elements suggested included the fulfilment of environmental assessment stages,
the practice of public participation, the existence of a sustainability development
framework and the availability of guidance and manuals. The SEA methodological
elements suggested emphasised the importance of procedural flexibility. Based on
the findings represented in Fig. 3, other elements that could help achieve effective
SEA include:
homogenous formal procedural requirements for the collection of environmental
baseline information, in which minimum environmental compatibility thresholds
are defined;
the introduction of mandatory and formal requirements for the consideration of
various alternatives, including the do-nothing alternative in ex-ante SEA; and
the need to introduce more structured quality control measures, such as the definition of roles and responsibilities or the institution of a separate body.
System-specific elements for SEA effectiveness are subsequently summarised in
Table 2.
The elements summarised in Table 2 suggest that SEA should be applied in a
way that suits the UKs regulatory style and builds consensus for the long-term
achievement of sustainability. Within this context, the experts indicated that more
structure and rigour could help limit the vagueness associated with sustainability,
thus the risks of balancing trade-offs between the different dimensions of sustainability (Sheate et al., 2004; Kidd and Fischer, 2007).

When is SEA Effective?


SEA is effective when the benefits that SEA can fulfil are achieved. Thus, when
the SEA context elements representing the necessary framework conditions for
effective SEA are present, and when SEA is applied according to the methodology
portrayed in the international SEA literature (see the Introduction). However, the
findings suggest that in order to achieve SEA effectiveness in different planning systems, different SEA elements are required. Consequently, the benefits that SEA can
achieve are likely to vary in different planning systems, as they must be meaningful
and relevant to the specific contexts in which SEA is applied. Thus, what makes SEA

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Table 2. Elements for effective SEA in the UK.
Elements for effective SEA for the Northern-European planning culture

established institutional framework for environmental consideration/integration, with strengthened environmental legislation;
existence of environmental awareness;
increase of politicians commitments towards the environment;
well-established PPP-making system;
effective cooperation and public participation;
well-established and effective EIA system, to which SEA can be tiered;
existence of sustainable development framework/sustainability strategy;
high degree of accountability and quality control in SEA, through documenting, transparency
and simplicity. This could also be achieved through the clear definition of roles and responsibilities with the main responsibilities on the proponent. The proponent and the assessor(s) should
be separate. Institution of an independent body to ensure quality control and verifications and
transparency;
mandatory requirements for the consideration and assessment of various alternatives and for
the collection of environmental baseline information;
stakeholder-driven, sustainability-led, focused, iterative, flexible and adaptable SEA process
open to the input of the general public;
cost and time efficient generation of sufficient, reliable and usable information in SEA making.
Availability of manuals and guidance.

effective and the understanding of SEA effectiveness varies in different planning


systems. Within the context of the system-specific elements identified for Italy and
the UK, the understanding of SEA effectiveness is likely to stretch from achieving
environmental compatibility as a minimum for the first, to achieving sustainability
for the latter.
In Italy and generally speaking in the Southern-European countries, where the
environment is poorly integrated and context elements are poorly developed, SEA
appears to be effective when it:
raises environmental awareness;
avoids/decreases the influence of political and economic influence in PPPmaking;
ensures environmental consideration;
contributes to making the planning and environmental assessment framework
(more) sound and robust; and
produces relevant and useful findings.
In these contexts, SEA is conceived as a process of value transformation (for
EIA, see Bartlett and Kurian, 1999); a learning process for developing a cultural

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environmental awareness that could be reflected in the countrys planning and


assessment procedures.
In the UK and in the Northern-European countries, where the environment is
traditionally taken into account and integrated into PPP-making and in which context
elements are well-established and effective, SEA is perceived as a support tool that
aims to assist the performance of those elements that are already present in the
system. In these contexts, SEA is effective when it:

assists the planning process preventing delays;


leads to better environmental protection;
promotes sustainable development; and
improves good governance.

Conclusions
This paper aimed to establish what makes SEA effective in two planning systems,
representing different planning cultures. Italy was chosen as a case-study representing a specific Southern-European planning culture and the UK was chosen as a
case-study representing a specific Northern-European planning culture.
The findings indicated that in Southern-European countries (for example, Italy)
SEA context elements are poorly developed and the environment is poorly integrated in public decision-making. In these contexts, SEA should be applied
following a rigorous, structured and systematic approach. In Northern-European
countries (for example, the UK), where SEA context elements are well-established
and the environment is traditionally taken into account, SEA should be applied
with a flexible, adaptive, sustainability-led and stakeholder-driven approach. In
the first case, SEA appears to be effective when it achieves (at least) the environmental compatibility of PPPs. As a learning process, SEA could lead to an
improved development of the context elements and to an increased consideration
of the environment in public decision-making, creating favourable conditions for
broadening the scope of SEA effectiveness to the achievement of sustainability.
In Northern-Europe, SEA appears to be effective when it achieves sustainability outcomes, building consensus for the long-term achievement of sustainability
objectives.
In conclusion, elements for effective SEA can help practitioners successfully
apply SEA in different European planning systems. However, this can occur only
if the knowledge about different planning cultures is improved and the gap in
the NorthSouth divide is reduced. An increase in cross-national comparative
research between Northern- and Southern-European countries is therefore necessary. As indicated by Janin Rivolin and Faludi (2005, p. 195) for the context of

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European spatial planning:


. . . the added value of the Southern experience has so
far received little attention . . . one needs to go beyond the
most commonly known perspectives . . . to also reveal the
less obvious Southern perspectives.
Furthermore, as suggested with this paper, Southern-European countries are:
. . . well capable of introducing some valuable new elements, and they are equally useful as others in enriching
the debate . . . and in deepening our understanding about
current changes [and differences] in planning [and SEA]
practices [and systems] in Europe.
Janin Rivolin and Faludi (2005, p. 195).

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