What the newly published NPS EN-1 means for economies, people, and places
The need to properly assess the environmental, social, and economic impacts of a project remains a key theme throughout the NPS EN-1. This highlights the importance of socio-economics EIA, which covers a substantial proportion of the economic impacts, and partially covers social impacts (with other elements picked up by alternative disciplines).
Having worked closely with section 5.13 (Socio-Economic Impacts) over recent years, I was interested to dive in and find out whether any of the following nuances had been tightened up:
- Tensions between assessing local and/or regional socio-economic study areas
- Extent of ‘early engagement’ with local authorities
- Interlinkages with other topics
Somewhat surprisingly, the text in section 5.13 remains entirely unaltered.
Whilst this leaves some room for improvement in future updates, it does allow for an early reflection on how best to handle certain nuances of the policy, based on our experience using the previous version of NPS EN-1 over the past number of years.
How to resolve the tension between local and/or regional socio-economic impacts
Below is an excerpt from paragraph 5.13.2, with emphasis added:
5.13.2 Where the project is likely to have socio-economic impacts at local or regional levels, the applicant should undertake and include in their application an assessment of these impacts as part of the ES (see Section 4.3).
This introduces a degree of ambiguity. If a project is likely to have socio-economic impacts at a regional level, but not a local level, should local impact also be assessed (and vice versa)? Or is an assessment of regional impacts alone sufficient to ensure compliance when impacts may be felt at both levels?
Either position is a reasonable interpretation of paragraph 5.13.2. It is important for a developer to ensure any assessment of socio-economic impacts fully considers the interplay between local and regional impacts, whilst striking an appropriate balance with the need for assessments to remain proportionate.
This is a complex issue to navigate, not least because of the tension between economic and social factors, which should be assessed separately. Greater clarity could have been offered in the update.
Helpfully, in 2022 Marine Scotland published guidance for defining socio-economic study areas when assessing the impact of offshore renewables and other marine developments (prepared by BiGGAR Economics). This provides a set of six principles which should be applied when considering the spatial scales for assessing the socio-economic impacts. Whilst this guidance is non-binding in the world of NPS EN-1, it is a highly instructive framework on which to develop a robust methodology which would stand up to examination.
Why early engagement with local authorities is essential
Below is an excerpt from paragraph 5.13.3:
5.13.3 The applicant is strongly encouraged to engage with relevant local authorities during early stages of project development so that the applicant can gain a better understanding of local or regional issues and opportunities.
We have worked with a range of developers over the years, taking different approaches to local authority engagement. Some developers are keen to engage as early as possible to develop an approach with local authority input. In other instances developers have a preference for limiting engagement with local authorities outside of scoping responses. This can be motivated by:
- The legitimate need to protect commercial interests,
- A well-intentioned desire to avoid over-promising on local economic benefits,
- A nervousness around unnecessarily setting alarm bells ringing on issues that would otherwise have flown under the radar,
- Likely a combination of the above plus a number of other considerations.
In our experience, early engagement with local authorities is well worth the time. They will typically a) respect the commercial constraints being balanced by the developer, b) understand an explanation of the nuances of economic impact estimates, and c) appreciate the opportunity to flag the particular local concerns which should be considered when assessing the socio-economic impacts.
Early engagement will also provide developers with the opportunity to explore appropriate mitigations and enhancements with key stakeholders, which will help to shape their approach to matters such as skills and employment plans, supply chain engagement strategies, visitor facilities, accommodation strategies, and other community benefits. Giving appropriate consideration to these matters forms part of NPS EN-1 requirements, in any case.
It is likely that socio-economic EIAs will progress to examination with much greater levels of goodwill from local authorities where they have had a meaningful opportunity to input to the approach. On the other hand, where thorny issues are left until examination, a similar (or greater) amount of resource will need to be committed to resolving outstanding points of disagreement, with less goodwill from a local authority which feels sidelined.
What consideration should be given to linkages between socio-economics and other topics?
Below is an excerpt from paragraph 5.13.6:
5.13.6 Socio-economic impacts may be linked to other impacts, for example visual impacts considered in Section 5.10 but may also have an impact on tourism and local businesses.
The example provided in the policy text is a generally understood interaction within the topic of socio-economics, but, there are many more areas where socio-economic matters might overlap with other topics. In such instances, it is important to apply proportionality when considering impacts emanating from other topics which have the potential to result in socio-economic effects.
One such example we have worked on is an offshore wind farm located in the Irish Sea. The shipping and navigation EIA determined there was a potential for significant effects (moderate adverse) on lifeline ferry services to the Isle of Man. This meant it was necessary for our work to assess the potential indirect economic and social implications of changes to lifeline ferry services, covering sectors reliant on freight services (e.g. retail and logistics, construction, and manufacturing), sectors reliant on passenger movements (e.g. tourism, leisure, hospitality), and the social implications in terms of leisure passengers and health.
Another such example we have worked on is an onshore cable route located in northwest England. The aviation EIA determined there was a potential significant adverse effect on a limited set of operations at a regional airport. This meant it was necessary for our work to assess the potential indirect economic implications of changes to airport activities under certain limited conditions, accounting for the regional economic contribution of affected activities, as well as nearby Enterprise Zone activity reliant on affected activities.
Through sufficient planning during scoping and Preliminary Environmental Information Report (PEIR) stages, it was possible to set up appropriate thresholds that would guide the approach to assessing such instances within the socio-economics EIA. The key point with the examples provided was that in each instance there was a significant effect identified in another topic assessment which had the potential to result in indirect socio-economic impacts – this was a key trigger for further assessment within our topic.
Conclusions
The overall messaging within the updated NPS EN-1 retains the key theme of ensuring proper assessment of the environmental, social, and economic impacts of a project. This places socio-economics EIA in a pivotal position for ensuring this is achieved.
Section 5.13, which sets out the policy’s requirements for assessing the socio-economic impacts, remains unchanged from the previous version. This provides a degree of consistency from which to prepare socio-economics EIA work moving forward. However, the ambiguities and nuances present in the previous version have now been carried forward into the current iteration.
From our experience of contributing to multiple NSIP applications over recent years, we’ve become familiar with the technical challenges that need to be addressed to ensure compliance with section 5.13 of NPS EN-1. This often hinges on balancing the commercial constraints faced by developers with the political sensitivities faced by local authorities. Early and effective dialogue across application project management, developer consenting teams, and stakeholder representatives is an essential ingredient to ensuring that socio-economics EIA work is prepared in a manner that will stand up to increasingly intense scrutiny at examination.
