Daniel Parsons, environment associate director and Laura Martin, senior environment consultant, Atkins, explore how the new Environmental Outcomes Reports (EORs) will deliver an outcomes-based approach to developments
Environmental reporting is about to undergo an overhaul. The Levelling Up bill, which is approaching its final reading in the House of Lords, will enforce a generational change in how environmental impact is assessed.
The ongoing uncertainty is challenging for developers, but while the new regime is yet to be fully elaborated, it’s already clear that our industry is being challenged to improve how we manage environmental data. If we can do so, however, the benefits could be huge.
With a changing climate comes changing regulations. Environmental Impact Assessment (EIA), which has been in force since 1987, is being replaced with a whole new regime: Environmental Outcomes Reports (EORs).
Governing how environmental factors are measured, evidenced, and reported, the new system will affect the vast majority of projects undertaken in our industry.
Understanding Environmental Outcomes Reports (EORs)
But while Outcomes Reports have been introduced as part of the Levelling Up bill, their actual form remains vague, and uncertainty is rippling through our sector.
It’s understandable: the government is proposing a radical departure from existing norms and familiar processes. A huge backlog of case law supporting the old EIAs may no longer be relevant. In the face of the coming change, developers must begin considering how they will adapt. Some may decide to hurry to submit their EIAs before the regime changes, others to delay their projects until the new system has been implemented.
Either way, developers are being confronted by generational change, compounded by uncertainty.
Uncertainty is never ideal. Yet the government has sought the insights of the industry. They have consulted a wide range of industry bodies, from statutory stakeholders to consultants and Local Authorities.
Atkins is helping the government by sharing experience and detailed knowledge on impact assessment by submitting a formal response to the government’s initial consultation so that the new regime is reflective of the industry and has the best chance to succeed.
Much remains to be finalised, yet the EOR approach promises several benefits to developers and the public alike. However, to realise these opportunities, our sector is being challenged to change.
EORs demand an outcomes-based approach to a proposed development
Regulations governing reporting are always difficult to form. Environmental assessment methodology, with its continuously increasing complexity, is particularly challenging.
These assessments determine the environmental performance of projects, influencing not just how they are received but what success itself looks like. Covering so many issues and receptors, these regulations are also very complex.
Trade-offs are unavoidable – not only between environmental outcomes and economic growth but between different environmental goods. Noise barriers maintain tranquillity at the expense of eyesores, for example.
Striking a balance in these cases is a political consideration and must therefore be justified. Transparency matters. People care about their local environment, and inscrutable or inadequately-explained environmental impact reports make it harder for locals to contribute – lowering confidence and increasing cynicism and conflict.
Moreover, these assessments are predictions for the future at a time of unprecedented change. There are, therefore, a lot of unknowns and uncertainty.
What is certain is that the Environmental Statement under the current EIA system will completely change. Currently, Environmental Statements focus on the impact of proposed developments.
EORs demand a more outcomes-based report – not just the impact on the receptors, but what the proposed development’s overall outcomes will be. It’s a different approach and one that will challenge our industry to be more dexterous with how we gather, manage, and present environmental data.
EORs aim to improve environmental performance by embedding desired outcomes earlier in the planning process
EORs promise to deliver more social value. By prioritising outcomes, it challenges developers to consider the environment earlier on in the process.
Instead of measuring the number of trees felled, for example, EORs will report, say, a Biodiversity Net Gain of 10%. Reporting outcomes in this fashion should improve transparency, making projects more navigable and clarifying their tangible effect on the world.
This should improve environmental performance, embed desired outcomes earlier in the process, and enable communities to understand the environmental outcomes of projects.
However, to reap these benefits, environmental data must be gathered, processed, and presented more dexterously. In turn, flexibility depends on processes – data standards, information management, and digital tools.
Data management will become even more important to environmental reporting and strengthening the connection to digital innovation initiatives. Transitioning to integrated, flexible, data-based environmental reporting is challenging.
There is an opportunity for organisations with these abilities, such as Atkins, to adapt to EORs and other changes quickly. And achieving greater mastery over environmental data yields more benefits than just compliance. It enables projects to be assessed much more holistically across the lifecycle.
As well as more flexible reporting, better data modelling allows projects to respond to new conditions with agility. If you’ve been gathering data in the same way for decades and have little experience with other methodologies, this rigidity will make responding to regulatory change much harder.
The new regulations will catalyse the shift towards data-driven reporting
Much remains to be seen. We’re still lacking detail on exactly how Environmental Outcomes Reports will actually work. When the regulations are published, they’ll need additional strong guidance to support them, properly timed and integrated.
Atkins is formally consulting with the government, not just about regulatory reform itself, but also regarding the wider needs and implications on our industry.
Capability, capacity, and reform must accord within statutory stakeholders and competent authorities; otherwise, they risk shouldering greater burdens but without necessarily having additional resources to meet their regulatory requirements.
Whatever happens, the new regulations will catalyse the shift towards data-driven reporting. The benefits could be huge. If the regulation mandates data sharing, it will enhance how environmental baselines are formed, helping to make projects more efficient. Even today, the planning process is often still overly reliant on printed paper documents filed in cabinets.
A shift towards more modern applications
Limited by restrictive file sizes, digital copies are often segmented into an array of sequential documents, making them difficult to retrieve and process and discouraging sharing with the public. A shift towards more modern applications and documents would be welcome.
Ultimately, the regulation will also improve alignment across existing legislation and government policy. All targets and indicators in EOR are subsets of the targets within the wider Environment Improvement Plan.
This means that government policy and legislation, including the way projects are consented to, is structured around a common set of goals, ensuring that environmental priorities are cascaded to plans and projects. If we can be flexible enough to adapt, today’s uncertainty should become tomorrow’s unity.
Daniel Parsons
Environment associate director
Atkins
Laura Martin
Senior environment consultant
Atkins
