The role of SEA in integrating and balancing high policy objectives in European cohesion funding programmes

Environmental Impact Assessment Review 38 (2013) 44–53

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Environmental Impact Assessment Review journal homepage: www.elsevier.com/locate/eiar

The role of SEA in integrating and balancing high policy objectives in European cohesion funding programmes Alexandra Jiricka ⁎, Ulrike Pröbstl University of Natural Resources and Life Sciences, Vienna, Austria Institute for Landscape Development, Recreation and Conservation Planning, Peter-Jordanstraße 82, 1190 Vienna, Austria

a r t i c l e

i n f o

Article history: Received 7 February 2012 Received in revised form 9 May 2012 Accepted 22 May 2012 Available online 28 June 2012 Keywords: SEA Cohesion funding High policy goals Handbook Transnational Cooperation

a b s t r a c t Funding programmes for European cohesion policy are a crucial tool to support the sustainability goals of the European Union and national policies of its member states. All these funding programmes require a Strategic Environmental Assessment (SEA) to enhance sustainable development. This article compares five first SEA applications at cohesion policy level to discuss challenges, limitations and benefits of this instrument. In order to support the SEA-process a “Handbook on SEA for Cohesion Policy 2007–13” (GRDP 2006) was developed. The paper examines the special requirements and challenges at the programme level given the special conditions for stakeholder involvement, integration of SEA in the programme development process and strategies to cope with uncertainties to ensure real compatibility with policy goals. Using action research and indepth interviews with SEA planners and programme managers enabled us to analyse the suitability of the methodology proposed by the handbook. The results show that some recommendations of the handbook should be changed in order to increase the transparency and to enhance the standard and comparability of the SEA-documents. Overall the SEA proved to be a rather successful tool for the integration of sustainability goals at the EU and national policy levels. Its particular strengths emerged as the process makes uncertainties visible and leads to possible redefinitions while maintaining actual policy goals. © 2012 Elsevier Inc. All rights reserved.

1. Introduction The Strategic Environmental Assessment for plans at different levels has been in use since the EU directive on SEA entered into force in 2004. The directive's aim, amongst others, is the integrative consideration of environmental goals in planning practice (cf. Annexes 1 and 2 Directive 2001/42/EC). These goals are to determine standards for the assessed documents and ideally serve as a “benchmark” so that assessed plans and programmes reach higher environmental compatibility. Especially in the context of spatial planning, national guidance documents (e.g. Amt der Steiermärkischen Landesregierung, 2011) help to meet the implementation of the directive requirements and standards at national and federal state level. The relevant practical implementation has been and is being critically analysed and further enhanced (Arbter and PlatzerSchneider, 2005; Fischer, 2010; Jiricka and Pröbstl, 2008; Pröbstl et al., 2006; Therivel, 2010). In contrast, programme planning has attracted less attention. This article analyses the first experiences in programme planning within the European cohesion policy. Funding programmes for European ⁎ Corresponding author. E-mail addresses: [email protected] (A. Jiricka), [email protected] (U. Pröbstl). 0195-9255/$ – see front matter © 2012 Elsevier Inc. All rights reserved. doi:10.1016/j.eiar.2012.05.002

cohesion policy are fundamentally linked to respecting and enhancing European and national high policy objectives (like maintenance of biodiversity through NATURA 2000 areas or the amelioration of water bodies according to the Water Framework Directive). Their goal is to be consistent with EU sustainability objectives on the one hand and the member states' national policies on the other hand. Five case studies of first applications of Strategic Environmental Assessment at cohesion policy level show the challenges of trading off and balancing high policy objectives and the contribution of SEA to guaranteeing their agreement with the original political goals. The goal of this article is to discuss the specific challenges these Strategic Environmental Assessments raise in practical application of cohesion funding with regard to performance and efficiency (see Fundingsland Tetlow and Hanusch, 2012). In this context a handbook created for this purpose serves as evaluation background. The “Handbook on SEA for Cohesion Policy 2007–13” (subsequently referred to as: GRDP — Greening Regional Development Programmes Network, 2006 and “the handbook”) was created by “Greening Regional Development Programmes”, a pan-European network, with the support of the Interreg IIIC programmes and published in 2006. The GRDP partnership consists of public institutions at local, regional, national and international levels and research organisations from eight EU member states (cf. GRDP — Greening Regional Development Programmes Network, 2006, p. 4). The “benchmark-based” approach recommended in the

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handbook, basing the assessment on the direct examination of compliance to transnational and national sustainability goals, is of special interest. Section 2 introduces the objectives and specifications for funding programmes at cohesion policy level. The five programmes examined (Alpine Space II, 2007–13; Austria-Bavaria, 2007–13; Austria-Czech Republic, 2007–13; Central Europe Programme, 2007–13; SouthEast Europe Programme, 2007–13) influence funding at a transnational scale resulting in strategies at international, national and regional levels. In this context it is discussed whether the SEA proved to be a successful tool for the integration of sustainability goals on both the EU and national policy levels. Section 3 introduces the methodological approach consisting of a combination of action research and in-depth interviews with SEA planners and programme managers. This enabled us to analyse crucial factors during the process management. The results are discussed in Section 4, with special focus on the methodological integration of high policy goals within the SEA process (especially the scoping, assessment of impacts, monitoring and recommendations). This leads to the discussion (Section 5) about recommendations for future SEAs at programme planning level and allows drawing conclusions (Section 6) about the enhanced observance of high policy objectives through SEA in this international matter.

the reference to the specifications of the programming documents, and a cross-sectionally oriented participation of the administration, research and implementation levels. In the course of programme planning, typically a so-called “Task Force” is established which is responsible for compiling the topics for the next programme period. This group includes for the most part high-ranking administration officials from the various member states. While this group stipulates the content scope, the programme planning process, including the required SEAs, is governed by the socalled “Managing Authority”, a supra-national administration unit which is subsequently responsible for the implementation of the programme (cf. Fig. 1.) The difficulty of programme planning lies in the requirement of stipulating clear priorities with regard to content, but at the same time leaves enough room for multi-faceted and innovative project proposals from the supra-national consortiums. The EU requires an SEA to be prepared for any programme it funds in parallel to the implementation of the programme. The expert assessor faces the difficulty of evaluating the “programme outlines”, i.e. in many cases very generally worded specifications, and deducing therefrom possible impacts on environmental issues.

2. Programmes, partners and planning procedure

The handbook on Strategic Environmental Assessment of programmes for Cohesion policy (GRDP — Greening Regional Development Programmes Network, 2006), which was briefly introduced at the beginning, provides a possibly ideal set of procedures for the most important content of the environmental report, and also for the procedure itself, which helps to analyse the performance of SEA in the case studies. It is the only document available after the European Commissions Handbook on EU Structural Funds from the late 90ties (see Fischer, 2003) referring explicitly to cohesion policy. Therefore the consideration and compliance with the suggestions of the GRDP handbook are essential for an evaluation of SEA performance at this level. Against this background, the following threepart approach was adopted to comprehend and analyse the planning practice. Firstly, several completed environmental reports on Objective 3 programme plans (SEA Austria — Bavaria, 2007–13; SEA Austria–Czech Republic, 2007–2013; SEA Central Europe Programme, 2007–13; SEA South-East Europe Programme 2007–2013) were evaluated and analysed according to the basic principles and criteria specified in the handbook (which refers to the stages of SEA-processes as described in the European Directive 2001/42/EC). This leads to a sub-division of the Results section — where the theoretical advice provided by the handbook is compared with the practical application resulting from the

First we need to introduce the objectives and specifications for those funding programmes at cohesion policy level we used for this study. The cohesion policy of the European Union provides a framework for financing a wide range of projects and investments with the aim of encouraging economic growth in EU member states and their regions. Its aim is encouraging “economic, social and territorial cohesion in the European Union by correcting imbalances between regions” (European Commission, 2011). The Objective 3 programmes referred to in the paper are used to build closer links between border regions and promote cooperation amongst regions in different member states by means of joint projects and exchanges of experience. The five programmes examined are Interreg IVB Alpine Space II (2007–13), Central Europe Programme (2007–13), South-East Europe Programme (2007–13), Transnational programmes Austria-Czech Republic (2007–13) and Austria-Bavaria (2007–13). These so-called Objective 3 programmes stipulate the range of topics for which teams of scientists, public administration units, communities and businesses can submit cross-border project proposals. The prerequisites for the funding of the submitted projects are, amongst others, a far reaching cooperation of the respective member states involved (e.g. in the programme “Alpine Space” of the Alpine countries),

3. Methodological approach

Managing Authority MA manages the process and organises the participation and recruiting of experts

Organises the process

SEA Experts

Task Force Stipulates the content of the programme

Discussion of contents

Compilation of the environmental report

Fig. 1. Institutional bodies within an SEA process for cohesion policy.

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description in the environmental reports and supplemented by expert interviews and action research as explained in the following paragraphs: Guideline-based interviews were conducted with the respective experts involved in the five SEAs (SEA coordinators/experts from Austrian Institute of Ecology ÖÖI and Austrian Society for Environment and Technology ÖGUT). Thereby, primarily the importance of SEAs in the planning process, the feedback to the programme planning and the influence of SEAs on the final planning document were examined. Initially the applicability of the approaches of the handbook was discussed in correlation to the SEA stages and the evaluation of the environmental report. This allowed direct feedback to the analysis of the report documents. Furthermore one complete planning process was examined by means of action research — the SEA for the Objective 3 programme “Alpine Space II 2007–13”. Action research aims at addressing concrete practical problems and, by participating in the process, finding out more background information about the discussion and decision process (Gagel, 1995; Lecomte, 1988). This way the role and the potential influence of the planner and the environmental assessor could also be analysed. Thus, action research stands out due to the temporary abandonment of the otherwise axiomatic distance maintained to the object of study (cf. Moser, 1977). The roles taken on in the course of action research ranged from participant observation to active interaction with the involved parties. Action research in connection with planningscientific questions is characterised by the fact that an equitable and cooperative communication and action context is created between the researchers and the decision makers involved (e.g. the members of the Task Force). The participating evaluations in this context are part of the characteristic tasks. For this study the authors attended all meetings of the drafting process of the new Cohesion Policy Programme “Alpine Space II” which were in relation to the SEA compilation process. This allowed analysing the interaction between the drafting team of the Managing Authority and Task Force with the SEA team. 4. Results 4.1. Performance of SEA in comparison with the recommendations by the handbook The presentation of the results follows the steps of procedure of the SEAs and concludes with a discussion of the planning process including the involvement of the public and the consideration of the SEA's results within the European programme planning. In this process, the recommendations of the handbook are always the initial point and are then set in contrast with the practical experience. Particular attention is paid to the role and significance, and the possibility of integration, of high policy goals in the planning process. 4.1.1. Scoping 4.1.1.1. Theoretical advice. According to GRDP — Greening Regional Development Programmes Network (2006), those environmental issues, which are to be considered within the SEA are to be defined in the course of scoping. The handbook, in this respect, suggests expanding the environmental issues (as defined in the Directive 2001/42/ EC) to include additional “environmental concerns”. These are oriented along international and national environmental goals (deriving from e.g. Directive 2009/28/EC of the European Parliament and of the Council of 23 April 2009 on the promotion of the use of energy from renewable sources). In addition to the ones demanded by the SEA-Directive 2001/ 42/EC, these additional “environmental concerns” address topics such as “adaptation to climate change” or “energy efficiency”. These are to be collected on the basis of relevant environmental goals which are considered in programme planning and point the way in the SEA process. In

addition, indicators (or specific questions) shall be deduced, which the analyses in the SEA process can build upon. The handbook attaches great importance to the environmental goals since they are regarded as the basis for various steps in the SEA process (ascertainment of the actual state, evaluation of the programme's possible impacts, ascertainment of the cumulative effects, evaluation of the suggested management and monitoring system). The handbook points out that for each programme specifically suited environmental goals have to be found, reflecting the current environmental state and its further development. To this end, firstly the possible environmental goals are to be collected and then the most effective ones are to be selected. These two steps are to be carried out in cooperation with the relevant environmental authorities in order to identify the key environmental issues (GRDP — Greening Regional Development Programmes Network, 2006, p. 13). A prerequisite for the quality of environmental goals is their measurability and the availability of data for revision. The positive or negative effects of the programme should be able to be analysed on the basis of the environmental goals (GRDP — Greening Regional Development Programmes Network, 2006, p. 14). The handbook thus proposes progressive procedural steps: not only avoiding negative effects on environmental issues stands at the fore, but also enhancing the environmental state. The environmental goals shall serve as a “benchmark system” in order to analyse the programme with respect to its environmental compatibility and also to optimise it in this regard. Scoping also aims at coordinating the chosen procedural steps with the relevant environmental authorities. The handbook also recommends consulting relevant stakeholders who can possibly provide documentation and data. 4.1.1.2. Applicability of the suggested approach. The procedural steps described in the handbook differ considerably from the established SEA practice at the level of national plans and programmes in many European countries such as Germany, Italy, Austria and France (Pröbstl et al., 2007) and from the process stipulated by the EU directive which unambiguously specifies the environmental issues (Directive 2001/42/EC Annex II). This discrepancy rather leads to confusion — as the interview of experts indicated. What results in difficulties with the suggested approach is the fact that cohesion funding involves multinational processes, and therefore the environmental goals are not always consistent. Exclusive orientation at the EU's environmental goals may, under certain conditions, entail thematic gaps when considering environmental impacts/ topics and may to some extent “undercut” national standards and regulations. Due to the degree of abstraction of the programmes to be assessed and the great geographic extent to be examined, the assessment regarding threshold values (national/international) is only possible in a form of an estimation of trends and foreseeable tendencies. While high policy goals may point the way regarding the selection of indicators and the description of the actual environmental state, the direct integration of environmental goals in the assessment is problematic. Action research has also indicated this problem. In this case, mainly the comparability regarding environmental impacts is at risk, as individual interests, such as “utilisation of renewable energy sources”, may also entail negative environmental impacts or “side effects”, or may eclipse these. This could result in a “trade-off” of the (environmental) goals which, however, is not desirable. It is important, though, to anticipate and avoid negative environmental impacts (see Section 4.1.2). Consequently, there have been differences in the individual SEAs regarding the selection of the environmental issues to be assessed. While in three of the examined Strategic Environmental Assessments only the environmental issues according to the SEA Directive — Annex I were assessed, in the two other cases additional environmental concerns were included (in correspondence to the handbook's

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recommendations). These environmental concerns mainly cover the areas “sustainable mobility systems”, “energy efficiency and renewable energy sources”, and “sustainable resource management”. Against the background of the interviews and action research, the additional objective definition by the expert assessors is to be classified as unsuitable and not target-oriented due to the reasons mentioned above. The consultations were a very important part of all SEAs at which help regarding the method and data sources was provided and also criticism was expressed. The communication was conducted in written form, but in some cases also personal meetings with the representatives of the authorities took place to facilitate the incorporation of their requests and experience into the process. This personal communication which otherwise is more established in local or regional planning has also proved itself on this planning level. Though the suggested consultation of NGOs and other relevant stakeholders in the course of the scoping is recommendable at the stage of data gathering, the scope of examination (and the indicators to be considered according to the availability of data) should be established exclusively by the contracting authority, that is e.g. the Task Force or the immediate environmental authorities, otherwise irritation may arise in the subsequent process (Fig. 2). 4.1.2. Assessment methodology 4.1.2.1. Theoretical advice. The SEA's goal is to indicate all possible, significant impacts of the programme, both positive and negative, on the environmental issues according to the SEA Directive (Annex I, 2001/ 42/EC). The causal argumentation should be comprehensible, and the causal relationships shall be expressed in a not too complex but still comprehensible way (Perdicoulis et al., 2007). The handbook (GRDP — Greening Regional Development Programmes Network, 2006, p. 21ff) relates the assessment primarily to the previously defined environmental goals and the indicators deduced from them which provide information whether or not the respective goals have been reached. The suggested assessment matrix therefore includes the indicators and goals attributed to the environmental issues. This conforms with the “objectives-led SEA” approach (UNECE — United Nations Economic Commission for Europe and REC — Regional Environmental Centre for Central and Eastern Europe, 2006 in Cherp et al., 2007). The suggested assessment is very complex and rates the degree of impact based on a four-point-scale (negative, large-scale negative, positive, large-scale positive), the probability of impacts (very probable, probable), the frequency and duration of impacts (frequent/long-term to permanent, occasional/short-term), and reversibility (irreversible, reversible). Furthermore, it has to be evaluated whether there is a transboundary effect. In all cases where future impacts cannot be estimated, this fact shall be indicated with a special symbol (e.g. “?”).

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It is well-established that there is a problem with restricted assessability due to the complexity and uncertainty of both planning and the (ecological) system concerned on the one hand, and because of the high degree of abstraction of such political funding programmes on the other hand (cf. Chaker et al., 2006; Perdicoulis et al., 2007) and is also mentioned in the handbook. One suggested solution is to focus on the definition of “selection criteria” for future projects (cf. GRDP — Greening Regional Development Programmes Network, 2006, p. 21). 4.1.2.2. Applicability of the suggested approach. In contrast to the guideline the analysed reports take a different path. In the various assessments, different assessment approaches were chosen by the interviewed experts and in the course of action research: – Retrospective and conclusion by analogy: were there similar or comparable objectives in the past period, and what kind/type of projects and which environmental effects were the results? – Best case scenario: which positive goals does the programme want to achieve and which types of projects and environmental effects can therefore be expected? – Worst case scenario: which types of projects and environmental effects could occur in the worst case? – Likelihood scenario: which types of projects are likely under the given description, and which environmental effects derive from these? In the case of programmes, which specifically tie in with earlier programmes and their objectives, the experts regarded conclusion by analogy as the appropriate method. In the case of new programme objectives, however, this approach was not suitable. The stakeholders and representatives of authorities involved assessed the “best case scenario” as the most appropriate procedure and requested the expert assessors to exclusively use this method. Many of the interviewed experts disapproved this approach because the SEA is supposed to be applied in terms of the precautionary principle as the following example illustrates: “The programme partners asked the expert carrying out the SEA to take note of the handbook on SEA for cohesion policy 2007–2013 set up in the framework of the GRDP (Greening Regional Development Programmes) project. As recommended in this document, the environmental assessment of the programme followed the worst case principle and applied a long-term perspective. Thus, this principle was the basis of the evaluation to make sure that the main task of the strategic environmental assessment – to identify possible negative impacts at an early stage – is fulfilled. It is worth mentioning that for this reason the results of the SEA might appear more negative than findings of SEA applied to other comparable Structural Funds programmes.” (European Territorial Cooperation, 2007– 2013 Operational Programme Alpine Space, p. 74).

Fig. 2. Analysis of the scoping process in the five case studies (+ = application of handbook suggestions, +/− = suggestions of the handbook only partly applied, − = suggestions of the handbook were not applied).

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As the “worst case scenario” implicates the risk of exaggerating the possible problems, focus was often put on the likelihood scenario. To make the assessment comprehensible, each programme objective was preceded by a summary of the background, the intended effect and the assumable impact chains. The content and validity of the document were coordinated with the Managing Authority. Thus, the Strategic Environmental Assessment's perspective could be harmonised with the programme planning's perspective. In this spirit, analogy by conclusion is being combined with consultation and coordination with the programme planners, if possible. These procedural steps have proved themselves suitable to tackle difficulties when assessing long-term objectives of programmes. Action research showed, however, that it is often necessary to combine the various approaches (e.g. retrospective and likelihood scenario). According to the experts, one further difficulty at the assessment was that often the activities and programmes facilitated by the Funding programme do not have any negative effects per se (e.g. research activities), but they are crucial for subsequent measures which, on their part, may entail considerable negative impacts on some environmental issues. In this regard, different assessment approaches arose which, on the one hand, only incorporated into the assessment the impacts directly financed by the programme, and on the other hand, according to the precautionary principle, also took into consideration the probable secondary effects. In the course of action research, the scaling suggested in the guideline was subject to intense discussion. Especially the differentiation between positive and large-scale positive seemed to make little sense in consideration of anticipatory environmental protection. It was regarded as more important to openly point out where no unambiguous assessments are possible. Similar thoughts also came up at the other studies. Regarding the scale of intensity of the expected impacts, a five-pointscale was used at one of the SEAs and a three-point-scale in all other cases. The evaluation in the case of the five-point-scale encompassed strongly negative, negative and slightly negative effects, no significant effects, and positive effects. In all other SEAs examined the gradation covered positive, negative and neutral effects. In two cases, a “caveat” was added to these three effects in terms of reservation if no clear statement about possible environmental impacts could be made. In addition, the category +/− was introduced in the case of two SEAs, as both positive and negative effects were regarded possible. In addition to the recommendation of the handbook, possible preventive measures were also taken into consideration. In the case of efficient measures, a reduction of the negative effects by one level of evaluation was assumed (cf. Oberste Baubehörde, 2006; Pröbstl et al., 2006). In contrast to the handbook's recommendation, the assessment was not put into direct relation with the environmental objectives in the most SEAs, its aim was rather to establish, by means of the indicators, which impacts on the environmental issues are to be expected. In two of the five SEAs the environmental goals were directly considered in the argumentation of the assessment (see Fig. 3). They were also added to the assessment matrix at the respective environmental issues, alongside with the indicators. Some experts, however, rate this representation as disadvantageous because the clear arrangement of the impacts is impaired. The summarising assessment of different environmental issues (as done in three SEAs) – which can be influenced in totally different ways – is also inappropriate. 4.1.3. Examination of alternatives 4.1.3.1. Theoretical advice. According to the handbook, the SEA-expert is expected to take on an active role, amongst others with respect to formulating an objective or a measure anew or by adding conditions to the implementation of the objective or the measure (GRDP — Greening Regional Development Programmes Network, 2006, p. 20–21). This approach extends the role of SEA assessor to a conceptual position within the whole programme drafting team.

4.1.3.2. Applicability of the suggested approach. As shown in Fig. 1, this is only possible and viable in a restricted way as the SEA-expert would go beyond their scope of authority and indirectly take over the role of the programme planner. No alternative objectives were generated by the SEA experts in any of the SEAs examined (see Fig. 4). The experts stipulated suggestions for modification and conditions for objectives though. The final report of the Alpine Space II Program describes this process: “One major purpose of the Strategic Environmental Assessment is the consideration of reasonable alternatives. For this purpose two more objectives, according to the draft of the programme of August the 14th which was subject to the public consultation were presented the SEA-report. They had to be taken into account for the final evaluation. In correspondence to the assessment results of the first draft of the environmental report some objectives were alternated or even left out during the elaboration of the final version of the Operational Programme. In return others were added. In the SEA-report these alterations of objectives are also described.” (European Territorial Cooperation, 2007–2013 Operational Programme Alpine Space, p. 75). Critical assessments and a subsequent adjustment by the programme planners (in this case the Task Force) in the course of SEA still helped to exert positive influence on the planning. The impartment of “background knowledge” about possible (side) effects which can cause negative impacts, and assistance at the “specification” of environmental goals, so that negative impacts can increasingly be eliminated, played a special role in this respect.

4.1.4. Mitigation and compensation measures 4.1.4.1. Theoretical advice. According to the handbook, formulating “selection criteria” shall contribute to averting or minimising negative effects. These criteria shall facilitate the selection process of future projects by making apparent both positive and negative effects of the project. Ideally, these criteria become an integral part of the management system for the implementation of the programme planning document. The evaluation of the projects shall be carried out in line with the environmental goals and indicators (GRDP — Greening Regional Development Programmes Network, 2006, p. 26–27).

4.1.4.2. Applicability of the suggested approach. In this case the practice of the examined studies complies with the handbook's specifications. In all cases, selection criteria were defined for future projects (see Fig. 5). At this step, the environmental-goal-oriented approach proved to be important at the definition and argumentation of the chosen selection criteria. The interview with the experts and action research showed, however, that the relevant programme planners do not appreciate a detailed set of criteria since an SEA might restrict their subsequent decisions.

4.1.5. Participation of the public/consultations 4.1.5.1. Theoretical advice. With respect to the consultations, the handbook suggests some ambitious procedural steps, such as the organisation of a public exhibition about the content of the SEA in the countries concerned or the involvement of a consultative group made up of representatives of the relevant environmental authorities on the one hand and of the concerned public on the Fother (GRDP — Greening Regional Development Programmes Network, 2006, p. 10–11). These approaches correspond with the procedural steps of an environmental impact assessment (EIA) or an SEA with a smaller sphere of action.

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Fig. 3. Assessment approach used in the five case studies (+ = application of handbook suggestions, +/− = suggestions of the handbook only partly applied, − = suggestions of the handbook were not applied).

4.1.5.2. Applicability of the suggested approach. Contrary to the requirements and recommendations of the handbook, in none of the cases was a form of involvement of the public chosen which addresses a broad spectrum of the population (see Fig. 6). Though an online participation was carried out on the webpage of the relevant programme planning agencies, only the relevant or possibly interested offices were directly asked for their opinion. It also appeared that general public interest in programme planning was low. Statements were, for the most part, given by public authorities and only sporadically by NGOs. The number of statements also diverged in the countries involved. This suggests that there is a connection between the intensity of involvement on the one hand and the significance of the instrument SEA and the awareness for anticipatory environmental precaution in the individual countries on the other hand. The expanded involvement as suggested by the handbook was criticised by the experts as being extensively inappropriate. 4.1.6. Monitoring 4.1.6.1. Theoretical advice. Monitoring aims at identifying unexpected impacts at an early stage. According to the handbook this comprises a validity check of the statements made in the SEA, including preventive, compensatory and offsetting measures. Based on the previously defined indicators and objectives, a quantitative assessment shall be carried out, where possible. In the process, the estimated values in the SEA (e.g. land consumption) shall be compared with the actual

changes caused by the programme. At the same time, monitoring is to be kept as simple as possible, it should be organised in a realistic and feasible way, and contain clear time specifications (cf. GRDP — Greening Regional Development Programmes Network, 2006, p. 30). 4.1.6.2. Applicability of the suggested approach. Though the monitoring practice acts upon the fundamental ideas of the handbook (see Fig. 7), according to the expert assessors, the desired quantifiable level of detail appears to be unaffordable for this kind of programmes. The formulation of recommendations for the monitoring activities was done in the individual environmental reports in a comparable way. An evaluation at mid-term of the programme period was chosen as the ideal time for monitoring. Nonetheless, the question of indicator selection is mostly not conclusively clarified. The allocation of impacts to the respective projects funded is often not possible in an exactly quantifiable way, as indirect effects, which were induced by the projects, but are not supported within the programme, should be considered, too. […] SEA-experts suggested a set of indicators to be used. These indicators shall constitute the basis for further elaboration and adaptation by the programme to be used as an effective tool of project steering and assessment from the early Alpine Space 2007–2013 Operational Programme stages of OP implementation. Depending on the nature of the interventions, qualitative assessments will be sufficient,

Fig. 4. Assessment of alternatives in the five case studies (+ = application of handbook suggestions, +/− = suggestions of the handbook only partly applied, − = suggestions of the handbook were not applied).

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Fig. 5. Integration of selection criteria as mitigation measure (+ = application of handbook suggestions, +/− = suggestions of the handbook only partly applied, − = suggestions of the handbook were not applied).

where necessary also quantitative data of a reasonable detail will be included in the assessment (European Territorial Cooperation, 2007–2013 Operational Programme Alpine Space II, p. 75). While programme planning regards self evaluation as sufficient and adequate, most experts push for the monitoring to be carried out by external experts. “These monitoring activities will be carried out either by the Joint Technical Secretariat or by external experts.” (European Territorial Cooperation, 2007–2013 Operational Programme Alpine Space II, p. 75).

4.2. Efficiency (impact) of the SEA According to SEA literature efficiency is linked to the impact of SEA on the planning process and the decision making (Fundingsland Tetlow and Hanusch, 2012). In the next sections we discuss the process design and time management which are substantial for the space provided to SEA in the planning process and crucial for the extent of interference in the decision making process. The last section in this chapter draws conclusions about the impact the five SEAs had on the programme planning results. 4.2.1. Process design and time management Following the handbook and other publications any SEA should start as soon as possible in order to identify alternatives at an initial

stage and effectuate changes in the programme planning (Balfors and Schmidtbauer, 2002). The decision makers should be actively involved in the SEA process (GRDP — Greening Regional Development Programmes Network, 2006; Joao, 2005). At the same time, also the SEA expert assessors should be involved in the decisions of the programme planners. For this reason, the handbook suggests that the SEA experts regularly participate in the meetings of the programme planning and monitoring committee — as observers, but with the right to ask questions and comment on the conceptual design at hand. The SEA expert assessors should be able to request meetings with the programme planners, if necessary, in addition to these official meetings (GRDP — Greening Regional Development Programmes Network, 2006, p. 9). The evaluation of the five case studies showed that the elaboration of a development programme for big European subspaces, such as the Alpine region, requires time and – also due to different national interests and priorities – controversial discussions and concertation processes. In the practical implementation, the active involvement of SEA experts only took place after the conclusion of the discussion process and the availability of the first results. In all practical examples examined, the respective involvement was implemented, amongst others, in a form of official meetings with the Task Force and the Managing Authority in order to coordinate the process. In addition, accompanying contact was maintained in the most cases throughout the entire planning phase with the Managing Authority and the programming experts, respectively. Despite this positive process in all cases, some expert assessors still expressed criticism with respect to time management. According to the SEA-experts, the preparation of the environmental report was

Fig. 6. Participation applied (+ = application of handbook suggestions, +/− = suggestions of the handbook only partly applied, − = suggestions of the handbook were not applied).

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Fig. 7. Practicability of suggestions for the monitoring process (+ = application of handbook suggestions, +/− = suggestions of the handbook only partly applied, − = suggestions of the handbook were not applied).

often done under great time pressure, which was, in many cases, due to delays in programme planning. While in the course of action research the environmental report could be updated until the completion of the programme, in all other cases the environmental report does not correspond with the latest state of the programme planning. The commissioned experts mostly blamed this on budget reasons or a too tight time frame. 4.2.2. Impact of the SEA The question arising at the end of the process is “what has the SEA achieved” and “to what extend does it contribute to a better consideration of environmental requirements”?. According to its intention, the SEA, as an instrument to accompany and evaluate the process, is supposed to result in a continuous improvement of programme planning (Joao, 2005). This processaccompanying support accounts for its strategic character and distinguishes it from other evaluation instruments, such as EIA (Cherp et al., 2007). In this respect, one finds the term “integrated model” of SEA in the literature. In this case the SEA does not only conduce to the assessment of the programme, but is also incorporated into the programme development itself (Joao, 2005 p. 10). In some cases the SEA was carried out as an iterative process, as the assessments of the SEA were discussed and incorporated into the programme planning process. Here the suggestions of the SEA were to some extent adopted in the programme planning, in some cases very successfully (e.g. SEA Alpine Space II): “The programme partners, however, have been striving to take the findings of the SEA into consideration when setting up the present document. Based on the findings of the SEA-experts the objectives defined in the description of the priorities were reconsidered and partly reformulated, the same applies for the fields of actions, indicative activities and target areas.” (European Territorial Cooperation, 2007– 2013 Operational Programme Alpine Space II, p. 75). The experience of the SEA-experts also indicated that at the programme level itself not everyone involved could see the sense and benefit in the Strategic Environmental Assessment. According to the interviewed experts, for many decision-makers involved for the first time the SEA is an expensive and time-consuming obligation and the value of which is not or not yet apparent. The results of action research showed, however, that the analysis of the SEA team with an extensive interpretation and illustration of possible projects contributed to a gradual revision and improvement, after all: “Overall the cooperation of the Task Force and the evaluation process — within the SEA led to a constant improvement and discussion concerning sustainability and mitigation of negative impacts on the environment. Feedback between the drafting team and the Strategic

Environmental Assessment team as well as resonances from the consultations led to significant changes in the programme which can be appreciated on the part of the concerned environmental issues. Therefore the process can be seen as successful and correspondent to the recommended approach to ensure iterative planning, as suggested in guidance like the handbook on SEA for cohesion policy 2007–2013.” (European Territorial Cooperation, 2007–2013 Operational Programme Alpine Space II, p. 75). These effects, however, can only be expected if the commissioned expert assessors can carry out the assessments and prepare the environmental report independently from of the Task Force and the Managing Authority. It remains a desideratum that the finished procedures as the first ones of their kind in this field of planning are publicised and thus contribute to a positive attitude on the side of the parties responsible. “The programme's positive effects and potentials for synergies in the sense of maximising its contribution to an environmentally sustainable development shall be exploited at best and, where possible, be strengthened.” (European Territorial Cooperation, 2007–2013 Operational Programme Alpine Space II, p. 75). The analysis of the projects selected after an SEA shows that through the awareness-raising process – which can be introduced by SEA experts – the consideration of high environmental policy goals can be improved. The challenge thereby is to identify contradictions and negative side effects between the objectives and to eliminate these by preventive measures and selection criteria as far as possible. In addition, action research and the interviews with the experts showed a phenomenon, which is characteristic for many plans: the efficiency of the planning strongly depends on the experts and stakeholders involved. What is more, also the manner and number of coordination meetings, which provide a platform for controversial discussions and make personal commitment possible, decide about the consideration of the SEA's critical findings. It proved to have a positive effect, if especially in the debate about critical assessments the SEA team had some experienced experts with sufficient knowledge of the moderation of planning processes. In this respect, also the independence of the SEA expert assessors turned out to be an important element (cf. Fischer and Gazzola, 2006). 5. Discussion The examined SEAs were the first ones of their kind within the European cohesion policy (Objective-3 funding). Given the little experience in this field, it was surprising to see the high degree of congruence in

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the procedural steps taken by the SEA-experts within the five different assessment procedures at programme level — which makes it possible to derive clear recommendations for future practical implementation. These experiences are also contrast to some ideas of the handbook and should be considered in future revisions. Therefore the discussion concentrates on those aspects, which are recommended as subject to revision, expansion or up-date within the GRDP handbook: The involvement of environmental issues during the scoping should preferably be done according to the SEA Directive and accompanying guideline. An additional definition of environmental concerns does not only open up the possibility of manipulation by expert assessors or contracting authorities, but also impedes traceability and comprehensibility for third parties. If this sets a precedent, at every study one would have to deal with new assessment and environmental concerns, as the case may be. This would also be opposed to a general understanding of what anticipatory environmental protection is meant to achieve by the SEA in the framework of the EU. Some added environmental issues, such as “agricultural interests” or “protection of habitat from natural hazards” do not clearly correspond with the precautionary environmental planning principle of SEA (cf. Jackson and Illsley, 2007; Wallington et al., 2007) and open up the discussion to sociological and economic components. The SEA, in this case, tends to lose its “edge” as an instrument of anticipatory environmental precaution and moves towards the approach of SA (Sustainability Appraisal) practiced in Great Britain (c.f. Benson and Jordan, 2004). In any case, an arbitrary extension of the environmental issues goes at the expense of transparency, clear arrangement and legibility. Similar concerns arose in case of the approach of “objectives-led assessment” in the way proposed by the handbook. Only two out of five analysed programmes included environmental objectives directly in the assessment schemes. Expert interviews confirmed the difficulty to agree on policy goals for different nationalities involved. In case the assessment of the programme objectives is made with regard to the achievement of environmental goals only a common understanding of goals and thresholds is necessary though. In particular those programmes which define funding policies for a very heterogeneous area such as the Central European programme or the South European Program had to cope with very different environmental states and challenges, thresholds, policy interests and resulting goals. Furthermore an assessment of the programme objectives regarding their environmental impacts (as suggested be the EU SEADirective) enables a direct comparison with other programmes and monitoring results. A further aspect is the presentation of assessment results, which on the one hand should be transparent and compact (see Fundingsland Tetlow and Hanusch, 2012) but should also allow the reader to understand the conclusions drawn. Against that background an accompanying verbal argumentation – in addition to a matrix assessment according to the environmental issues precised by the SEA Directive – seemed to be more efficient, which ideally sums up and completes the assessment in table form and discusses correspondence and contradictions to international and national environmental goals. Furthermore ways within the bounds of mitigation measures (e.g. formulation of selection criteria) can show how to ensure the observance of these goals. In all cases, the decisive challenge proved to be the high level of abstraction of the programmes. The priorities and goals assessed were, for some part, worded in a very general way and therefore left ample room for interpretation regarding possible projects. The approaches applied in the SEAs vary therefore regarding the approach applied. Literature and legal decisions in Germany sustain the combination of a “worst case approach” in case of uncertainty with a review on similar cases (Lau, 2011). Against this background the “likelihood scenario” as explained in this paper proved to be an adequate strategy. In order to reduce the large room for interpretation and different understanding it is helpful to describe and define first an appropriate background for each programme goal, e.g. based on the evaluation of similar objectives in the

last funding period and the related realised projects or similar research questions from other calls. Based on this analysis and the defined background, scenarios for the impacts of the goals of the current programme can be modelled and subsequently coordinated with the programme planning with respect to their validity. This way, it was possible to specify what the wording of the respective objectives means. This specification leads to more transparency useful for both the cooperation with the Task Force, on the one hand, and during the consultations on the other hand. In addition, action recommendations and selection criteria for future projects can be deduced from it. This method also improves traceability for third parties. The action research and the interviews with the SEA experts showed significant differences in the understanding of the possible role of SEA experts. While the handbook encourages the development of alternatives by the SEA-expert, the practical implementation shows that sufficient alternatives are generated in the course of programming. Ideally, these are initiated and influenced by the discourse with the SEA expert and thus lead to a continuous improvement of the programme. For an outsider the development of the programme should be easily traceable in retrospect. The handbook suggests monitoring using quantifiable indicators, which seems to be less applicable because of the high level of abstraction of the programme. Then again, monitoring is increasingly gaining in importance, as the observance of negative impacts is especially important due to prognostic uncertainties. It has to be determined whether the selection criteria were effective and if negative effects could thus be minimised. In this respect, the likelihood scenario is advantageous because the prognosis and the result at the time being can be compared. In case of great deviations corrective measures can be implemented at the level of the approval of projects or the description. The environmental reports of our case studies recommend in unison to carry out an evaluation at the mid-term of the programme. Finally the case studies showed that the appropriate form of involvement of the public recommended especially in the case of supra-national programmes is a web-based approach and publishing via e-mail and corresponding forums. Any involvement beyond this level is very difficult to provide because of the high level of abstraction of the programmes and the high amount of institutions involved. One of the key requirements and overall recommendations drawn within this study for the SEA at the level of programme planning is to allow for sufficient time for the iterative process. In the majority of the examined cases the environmental report was not updated until the end of the programme planning. The SEA expert should be involved at an early stage and should be independent from national or transnational influences. Only if this is guaranteed the public, the decision-makers and also the European Union as funding body can get an adequate picture of the programme and its possible impacts. 6. Conclusion The review on the role of SEA in Cohesion Policy can be completed with regard to the projects selected within the last funding period. A view on projects selected within the on-going funding period showed that environmental concerns, by the majority, are of high significance in the evaluated Cohesion Funding programmes. The implementation of high policy goals is primarily apparent in the reduction of green house gas emissions, the preservation of biodiversity and the strengthening of renewable energy resources. The majority of projects e.g. in the cooperation region Alpine Space II, address international environmental objectives. These objectives are either formulated as the main target (like the reduction of green house gas emissions in CO2-NeutrAlp) or they give rise to expectations of positive synergy effects with respect to intensified stewardship of natural resources (like stewardship of land resources in COMUNIS). Possible negative impacts, which were stated as risks in the SEA, e.g. regarding handling biomass as a resource for energy production,

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