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Strategic environmental assessment monitoring:

the enduring forgotten sibling

Ainhoa González

To cite this article: Ainhoa González (2022) Strategic environmental assessment monitoring:
the enduring forgotten sibling, Impact Assessment and Project Appraisal, 40:2, 168-176, DOI:
10.1080/14615517.2022.2031552

To link to this article: https://doi.org/10.1080/14615517.2022.2031552

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IMPACT ASSESSMENT AND PROJECT APPRAISAL
2022, VOL. 40, NO. 2, 168–176
https://doi.org/10.1080/14615517.2022.2031552

Strategic environmental assessment monitoring: the enduring forgotten

sibling
Ainhoa González
School of Geography, University College Dublin, Dublin, Ireland

ABSTRACT ARTICLE HISTORY

Monitoring in Strategic Environmental Assessment (SEA) is central to determining whether the Received 30 June 2021
assessment outcomes and associated mitigation measures have had the desired effect and the Accepted 10 January 2022
environment has been protected on the ground. Despite the critical role this procedural stage KEYWORDS
plays, and the international attempts to advance practice in this area, monitoring continues to SEA; monitoring; follow-up;
be poorly performed 20 years on from the implementation of the European SEA Directive. good practice
Several frameworks and approaches can be found in the academic literature, but many are
conceptual and arguably fail to provide pragmatic unsophisticated solutions that are readily
implementable in practice. This paper attempts to address this by first outlining common
issues reported in the academic literature in the last two decades, then highlighting ongoing
issues, as identified in two recent Irish research projects, such as poor definition of monitoring
indicators and lack of integration of monitoring commitments into plans/programmes. It then
puts forward a set of recommendations intended to foster a practical and sensible approach to
kick monitoring into action.

1. Introduction
Strategic Environmental Assessment (SEA) monitoring
is a mandatory requirement under European and cer­
tain international law (EC 2001; Dalal-Clayton and
Sadler 2005). It is recognised as a good practice prin­
ciple (IAIA 2002) and essential for assessment account­
ability and learning (Jiricka-Pürrer et al., 2021; Persson
and Nilsson 2007). SEA monitoring can be defined as
the process undertaken post-assessment and during
plan/programme implementation to understand the
actual – as opposed to predicted – outcomes of the
plan/programme and SEA. It relies on observations to
detect, understand and evaluate changes in the physi­
cal environment (Azcárate et al. 2013).
Monitoring is considered a key component of SEA
‘follow-up’ defined as the ‘monitoring and evaluation of
the impacts of a project or plan (. . .) for management of,
and communication about, the environmental perfor­
mance of that project or plan’ (Morrison-Saunders and
Arts 2004, p.4). It is the ultimate procedural step, and
a cornerstone for both SEA and follow-up, that helps
check whether SEA is tangibly effective (Figure 1). The
prime function of monitoring in SEA follow-up is to
provide data and information on the actual effects of
implementing a plan/programme to help determine
whether the SEA predictions were correct and potential
significant effects have been mitigated (Morrison-
Saunders and Arts 2004; Gachechiladze-Bozhesku and
Fischer 2012).
Monitoring data can be used to check whether SEA
recommendations and mitigation measures have been
implemented and how effective these are at protect­
ing the environment. Monitoring can help identify
unforeseen effects (and support timely remedial
action), address assessment uncertainties and fill data
gaps identified during the SEA – at planning level but
also at project implementation level (Morrison-
Saunders and Arts 2004; Gachechiladze-Bozhesku and
Fischer 2012; Azcárate et al. 2013) In other words, with­
out monitoring, it is not possible to know and indeed
understand the consequences of SEA. Without moni­
toring, it is very difficult to satisfy the substantive
dimension of SEA effectiveness and establish whether
SEA has resulted in environmental protection. It is not
possible either to ascertain whether tiering in environ­
mental assessment has been effective, that is, whether
SEA’s role in informing planning decisions and indeed
project development and associated Environmental
Impact Assessments (EIAs) has been fulfilled
(González and Therivel 2021). And therefore, whether
any causal links can be made from ‘decision’ to ‘imple­
mentation’ (Fischer and Retief 2021; Therivel and
González 2021). Similarly, without monitoring, it is dif­
ficult to learn from experience to continue enhancing
assessment processes and outcomes (Jiricka-Pürrer
et al., 2021; Partidário and Fischer 2004; Persson and
Nilsson 2007; Thérivel and González, 2019).

CONTACT Ainhoa González ainhoa.gonzalez@ucd.ie University College Dublin, Dublin, Belfield, D04 F6X4, Ireland.
© 2022 The Author(s). Published by Informa UK Limited, trading as Taylor & Francis Group.
This is an Open Access article distributed under the terms of the Creative Commons Attribution-NonCommercial-NoDerivatives License (http://creativecommons.org/licenses/by-
nc-nd/4.0/), which permits non-commercial re-use, distribution, and reproduction in any medium, provided the original work is properly cited, and is not altered, transformed, or
built upon in any way.

Figure 1. Monitoring as a cornerstone in Strategic
Environmental Assessment (SEA) and SEA follow-up.
Arguably, there is little point in SEA without mon­
itoring as the effectiveness of the assessment in pro­
tecting the environment remains unknown and
learning is halted. Yet, monitoring continues to be
the forgotten sibling in the environmental assessment
family of steps and tools – forgotten yet essential. This
paper aims to revisit the importance of monitoring,
acknowledging the shortcomings identified in the
international literature and in recent practice reviews.
The goal of the paper is to update the state of the art,
and thus to continue to foster discussions in this area
by attempting to fill in certain knowledge gaps.
Perhaps more importantly, the ultimate purpose of
the paper is to put forward a series of reasonable
pragmatic measures to foster action on monitoring
that can also serve as the basis for future research on
monitoring performance.
2. SEA monitoring in international research
Monitoring in environmental assessment has gained
significant international attention in the academic lit­
erature, but more so on EIA than SEA. When applying
the search string [‘Strategic Environmental
Assessment’ OR ‘SEA’] AND [‘monitoring’ OR ‘follow-
up’ OR ‘follow up’], with no other search limitations,
Scopus renders 195 results, which when filtered further
for their actual linkage to SEA renders 30 results.
A thorough review of these papers identified 22 rele­
vant manuscripts and two milestone books: one spe­
cific to environmental assessment follow-up by
Morrison-Saunders and Arts (2004), which is mostly
focused on EIA but does include chapters on SEA
follow-up, and one on SEA by Sadler et al. (2012) that
touches upon SEA monitoring. The identified publica­
tions date from 2003 to 2021. Interestingly, a particular
intensive or concentrated attentiveness to SEA mon­
itoring and follow-up is observed between 2007 and
2013 where 68% of the peer-reviewed journal articles
were published (Figure 2). Since 2013, SEA monitoring
IMPACT ASSESSMENT AND PROJECT APPRAISAL 169
Figure 2. Year of publication of the SEA monitoring and
follow-up publications identified in a targeted Scopus search.
and follow-up seem to have lost research momentum;
indeed, the later publications refer to SEA monitoring
as part of wider SEA effectiveness reviews and there is
a dearth of targeted research on the topic – albeit two
recent papers bring some attention back to it (i.e.
Gutierrez et al. 2021; Jiricka-Pürrer et al., 2021).
Three papers explore specific monitoring case stu­
dies (e.g. Azcárate et al. 2013; Gachechiladze-Bozhesk,
2012; Jiricka-Pürrer et al., 2021). Others present con­
ceptual frameworks, including:
● conformance, performance, management and
dissemination approach for each planning tier
proposed by Partidário and Fischer (2004);
● indicator-based plan monitoring developed by
Mascarenhas et al. (2012);
● linking planning and programming processes
through monitoring by Wallgren et al. (2011).
● micro- and macro-evaluations by Sadler (2004);
● multi-track approach with different levels of follow-
up suggested by Partidário and Arts (2005); and
● tool kit including analytical and deliberative tools
proposed by Nilsson et al. (2009).
Most of the papers, however, report on SEA monitoring
performance itself as portrayed in a range of good
practice case studies and SEA effectiveness reviews
(e.g. Gachechiladze et al. 2009; Söderman and Kallio
2009; Lundberg et al. 2010; Wallgren et al. 2011;
Gachechiladze-Bozhesku and Fischer 2012;
Lamorgese et al. 2015; Hadi et al. 2019; Gutierrez
et al. 2021). In these publications, there is a general
agreement that monitoring is weak.
3. Enduring challenges in monitoring practice
The international literature continues to report on
monitoring shortcomings such as the absence of allo­
cation of monitoring responsibilities (Polido et al. 2016)
and questionable adequacy of monitoring measures
(Gutierrez et al. 2021). Monitoring measures in SEA
environmental reports are typically not linked to iden­
tified impacts, demonstrating ‘a lack of understanding
as to the very purpose of monitoring’ (Söderman and
Kallio 2009, p. 17). Monitoring generally focuses on
170 A. GONZÁLEZ
observing whether the SEA recommendations and
mitigation measures are implemented (Lundberg
et al. 2010; Wallgren et al. 2011) and in very rare occa­
sions they measure actual impacts on the physical
environment (Azcárate et al. 2013). When they do,
measurements and observations are commonly
based on existing monitoring systems, following from
the SEA Directive’s recommendation to use ongoing
monitoring arrangements where appropriate, with
a view to avoiding duplication of monitoring (EC
2001). Where existing monitoring systems are applied,
these do not always cover the indicators and informa­
tion needs of SEA (Hanusch and Glasson 2008;
Gacheciladze et al., 2009).
Monitoring has been advocated as a means to fill
in data gaps and address uncertainties, but only on
very rare occasions has it been reported to be
applied with that goal in mind (e.g. Azcárate et al.
2013; Polido et al. 2016). The large majority of the
reviewed manuscripts (86%) highlight the need to
nurture and strengthen monitoring and follow-up
on SEA.
The above findings echo those of the recent
European SEA REFIT programme (EC 2019) which
also pointed to monitoring requirements being
poorly implemented, including the identification of
appropriate monitoring indicators. The REFIT report
is unclear on whether Member States undertake
monitoring systematically and on the frequency of
monitoring. Although some Member States claim
that monitoring reports are submitted ‘regularly’
for certain plans, the REFIT report does not state
which countries cultivate such good monitoring
practice. The findings also suggest a reliance on
standard indicators (e.g. guidance-defined and/or
associated to ongoing monitoring measures), with
case-by-case monitoring indicators more often
defined at lower planning tiers.
The REFIT study concludes that ‘there are challenges
in the quality of monitoring the environmental effects
of the implementation of plans or programmes, espe­
cially when it comes to identifying unforeseen effects
Table 1. Case studies reviewed in the second review of SEA effectiveness in Ireland (EPA 2018).
Name of Plan/Programme
Clare County Development Plan 2017–2023
Dublin City Development Plan 2011–2017
EirGrid Grid25 Implementation Programme 2011–2016
Fingal County Development Plan 2011–2017
FoodWise 2025
Greater Dublin Area Transport Strategy 2011–2030
National Forestry Programme 2014–2020
National Planning Framework 2040
National River Basin Management Plan 2018–2021
Nitrates Action Programme 2017–2021
Offshore Renewable Energy Development Plan 2014
Shannon Catchment Flood Risk Assessment and Management Plan 2015–2021
Southern Regional Waste Management Plan
Strategic Integrated Framework Plan for the Shannon Estuary 2013–2020
Wild Atlantic Way Operational Programme 2015–2019
and undertaking remedial action (. . .) environmental
effects are not adequately monitored (. . .) and poor
monitoring hinders the Directive’s success.’ (EC 2019,
p. 46). Recommendations to address ongoing chal­
lenges include ‘a more explicit link between the SEA
requirements of an individual plan or programme and
existing monitoring activities, in order to avoid unne­
cessary duplication of these actions (e.g. by establish­
ing an open national/regional database of
environmental monitoring activities)’ and provision of
‘examples of successful [monitoring] implementation
approaches, including strategies for ensuring [their]
long-term sustainability’ (EC 2019, pp. 47 & 159).
3.1. Monitoring performance in Irish SEA practice
A research project looking at SEA effectiveness in
Ireland (EPA 2018; González et al. 2019) included
reviewing current monitoring practice in Irish SEAs to
support the development of monitoring guidance. The
review looked at 15 good practice SEA case studies
across sectors and planning hierarchies (Table 1), and
interviewed 30 national SEA practitioners and 13 inter­
national SEA experts to gather information on bene­
fits/limitations of current SEA practice not captured in
SEA Environmental Reports (SEA ERs), and to seek
expert opinion on how to improve current practice.
The key procedural challenges identified in this
effectiveness review were similar to those experi­
enced in an earlier review (EPA 2012), notably the
consideration of alternatives and monitoring. As
with SEA practice internationally, monitoring
remains the most significant gap in Irish SEA prac­
tice. A degree of ‘informal’ monitoring takes place
in land-use planning, where the mandatory plan­
ning requirement to review development plans
every 6 years and to formulate interim reports
after 2 years forces planners to take stock of envir­
onmental changes – but this is not in a formal SEA
monitoring sense. The current generally systemic
lack of SEA monitoring hinders a comprehensive
evaluation of impact avoidance and sustainable
Sector Hierarchy
Land-use County
Land-use County
Energy, onshore National
Land-use County
Agriculture National
Transport Regional
Forestry National
Land-use National
Water management National
Agriculture, water National
Energy, offshore National
Water management Regional
Waste Management Regional
Water management, industry Regional
Tourism Regional

development due to SEA, even in cases where miti­
gation has been integrated into the final plan. The
review unveiled the following ongoing monitoring
deficiencies:
● Monitoring typically focuses on plan/programme
implementation (e.g. whether the plan/pro­
gramme policies and actions have been realised
within the planning period), rather than on the
environmental impacts and/or changes resulting
from plan/programme implementation, as per
SEA requirements.
● Monitoring indicators are often based on assess­
ment objectives; reusing the assessment indica­
tors and targets from the assessment (i.e.
baseline or impact assessment criteria) as part
of the proposed monitoring programme pre­
sents one of the key inadequacies in current
SEA practice, as these may not capture key issues
or may be too broad to inform monitoring at the
local level.
● Monitoring is regularly used as a form of mitiga­
tion (i.e. ‘monitor and manage’). This approach is
appropriate for filling data gaps but should only
be used as a mitigation measure of last resort as, if
applied as such, it would allow impacts to
become significant before they are identified.
● The opportunity to use monitoring to specifically
address identified data gaps (and thus help with
the assessment of subsequent iterations of the
plan/programme, and project-level assessments)
is generally missed.
● Monitoring periodicity, thresholds or remedial
actions are commonly missing in the SEA moni­
toring programme.
● Lack of clarity of monitoring responsibilities.
Monitoring data tends to come from third-party
bodies undertaking systematic monitoring of key
indicators (e.g. the Irish Environmental Protection
Agency – EPA – monitors water quality nation­
ally). However, it is the plan-making authority that
is responsible for collating and synthesising the
relevant information and reporting on it in rela­
tion to their plan/programme, which is often not
captured in SEA ERs.
● Monitoring data from one round of plan-making
do not seem to inform the next round of plan-
making; SEA ERs jump straight into the baseline of
the current plan, with no reference to what has
happened since the adoption of the previous
plan/programme.
● Monitoring reports are not prepared and/or made
publicly available. While some monitoring may be
taking place, there is a lack of understanding of its
occurrence and effectiveness as the findings are
rarely made available.
IMPACT ASSESSMENT AND PROJECT APPRAISAL 171
To compound the issues above, consulted experts
and practitioners highlighted several significant
monitoring challenges including the fact that
national legislation does not specify reporting
requirements or assign any third-party authority
with oversight/enforcement functions in relation to
SEA monitoring. They also noted that responsibility
for monitoring and remedial action is particularly
difficult to assign where issues cross several agen­
cies’ responsibilities. For example, in the case of
water quality, the monitoring is undertaken by the
EPA, wastewater upgrades are through Irish Water,
and the pressure sources may ultimately be
a combination of diffuse agricultural pollution, land-
uses, industrial effluent and wastewater. How this is
captured through a development plan/programme
monitoring measures, and remediated, is not
straightforward.
Consultees observed that knowledge exchange on
monitoring, or on whether monitoring is taking or has
taken place, if affected by personnel changes
between planning cycles: institutional memory, for
instance on where to find data or indeed the need
to collate and analyse them, can be rapidly lost with
changes of planning personnel. A lack of resources to
carry out monitoring following the SEA/plan adop­
tion, and the absence of guidance on monitoring
were also considered key difficulties hindering prac­
tice. In particular, consultees recommended that gui­
dance is needed to:
(1) clarify the actual objective of SEA monitoring
(e.g. is it to monitor the plan/programme or
the environment, and to what effect?);
(2) provide recommendations on the evidence
needed to track changes resulting from a plan/
programme; and
(3) showcase approaches that help address the
complexity of interactions that make it difficult
to determine whether any environmental
changes occur as a result of a given plan/pro­
gramme (due to multiple factors influencing
overall environmental quality, and to amor­
phous links between planning hierarchies and
sectors, where a plan/programme will influence
plans/programmes/projects downstream but
also across parallel sectors).
The guidance should also provide recommendations on
the nature and level of monitoring. For instance, where
plans/programmes lack geographic specificity or contain
only high-level strategic objectives, monitoring should
focus on national indicators to examine environmental
trends; where plans/programmes contain detailed
actions, monitoring should focus on cause-effect models
to measure environmental effects more directly.
172 A. GONZÁLEZ
Table 2. Case studies reviewed in the tiering in environmental assessment research project (EPA 2021).
SEA/EIAa
SEA – Clare Wind Energy Strategy 2017–2023
EIA – Knocknalough Wind Farm 2012
EIA – Cahermurphy-Kilmihil Wind Farm 2014
EIA – Glenmore Wind Farm 2014
SEA – Cherrywood SDZ Masterplan 2010–2016
EIA – Mixed-use Town Centre Development 2017
SEA – Eastern and Midlands Region Waste Management Plan 2015–2021
EIA – KMK Metal Recycling Ltd. in Kilbeggan 2017
SEA – Waterford City Development Plan 2013–2019
SEA – Kerry County Development Plan 2015–2021
EIA – N69 Listowel Bypass Proposed Road Development 2017
EIA – N70 Sneem to Blackwater Bridge Road Project 2019
SEA – North Quays Strategic Development Zone (SDZ) 2018
EIA – Knockboy Residential Strategic Housing Development 2019
EIA – Kilbarry Residential Scheme 2018
EIA – North Quays Development 2019
SEA – Shannon Strategic Integrated Framework Plan 2013–2020
SEA – Shannon-Foynes Port Development Masterplan 2013–2020
EIA – Shannon-Foynes Port Development Expansion – Strategic Infrastructure Development 2018
SEA – Ulster Canal Restoration Plan 2016–2022
EIA – Ulster Canal Restoration Upper Lough Erne to Clones 2011
aShaded SEAs refer to the higher-tier plan. No shading refers to the lower-tier SEAs and EIAs under the higher-tier plan.
3.2. SEA and EIA monitoring links in Irish SEA
practice
A recent project on the influence of SEA on EIA, or tiering
in environmental assessment (EPA 2021; González and
Therivel 2021) reviewed a separate set of nine SEAs and
12 associated EIAs (Table 2). Specific review criteria were
included to evaluate monitoring links between SEA and
EIA (e.g. checking whether the higher-tier SEA refers to
monitoring data from previous strategic actions, the SEA
monitoring refers to individual projects/EIAs, and the
lower-tier EIA/SEA refers to the higher-tier SEA and its
monitoring). The review was supplemented with inter­
views of 14 national and 14 international SEA practi­
tioners, plan-makers, development control planners and
academics. The interviews aimed to identify links
between SEA and EIA, good practice, and suggestions
for fostering and strengthening these links.
The review findings revealed again that, overall,
tiering links between SEA and EIA monitoring mea­
sures are weak. Only one of the reviewed seven SEAs
(i.e. Waterford City Development Plan 2013–2019 SEA
ER) relates its monitoring programme to specific pro­
jects, with the rest keeping monitoring at the strategic
level. Some have vague project-level monitoring
references, such as the Clare Wind Energy Strategy
SEA ER which recommends that monitoring informa­
tion should be placed on Geographic Information
Systems (GIS), and updated as data become available,
for instance from EIA Reports (EIARs). In a number of
cases, SEA ERs refer to monitoring as a means to fill in
data gaps. For example, the Shannon Strategic
Integrated Framework Plan 2013–2020 states that
‘the most significant data gaps which should be priori­
tised are bird surveys (. . .) together with cetacean
monitoring (. . .) In order to supplement biodiversity
data gaps, additional data gathering to be subse­
quently used during the plan review or at project
Sector Hierarchy
Energy County
Wind
Wind
Wind
Land-use Local
Mixed-use
Waste Regional
WEEE, metal recovery
Land-use City
Land-use County
Transport
Transport
Land-use
Housing
Housing
Housing
Land- and marine-use Regional
Port
Port
Recreation Regional
Recreation
level should be undertaken’ (SIFP SEA ER, p. 426). Of
the 12 EIARs, only two have EIA monitoring measures
that are influenced by monitoring at the higher tier.
For example, the Cherrywood project (Mixed-use
Town Centre Development 2017) EIAR includes mon­
itoring measures in each chapter, and these are linked
to the SEA. These shortcomings further emphasise the
poor performance on the monitoring stage in envir­
onmental assessment practice.
The interviewed practitioners and experts
attested to the importance of monitoring at both
SEA and EIA levels and highlighted the role of
monitoring in linking different tiers of assessments –
that is, in supporting tiering in impact assessment.
Strategic monitoring indicators can be brought
down to the project level to follow up on the
implementation of SEA mitigation measures, fill
data gaps and identify unforeseen adverse effects.
The monitoring information at EIA level can accu­
mulate back up to inform the strategic monitoring
indicator. However, there was also an acknowledg­
ment that ‘monitoring programmes are included in
the SEA ER and then almost forgotten about (. . .)
Monitoring is the exception rather than the norm’
and that ‘monitoring is often insufficiently detailed
or clear to inform EIA’. Similarly, a planner noted
that SEA monitoring provisions may not be followed
up because of lack of resources or, as an EIA con­
sultant observed, because they are not ‘stitched
into the policy requirements of the relevant plan’.
Two interviewees observed that collecting EIA infor­
mation on sensitive issues that may have arisen at the
project stage (e.g. extracting relevant information from
the EIARs) to inform future SEAs would be a resource
intensive task. One of them noted that ‘while EIAs con­
tain a wealth of information in terms of dedicated long-
term and seasonal surveys, analysis of baseline and

historical monitoring information, much of this is not
captured or collated in any coherent manner which can
be made available for use in SEAs’.
None of the international interviewees gave exam­
ples of effective monitoring of either SEA or EIA. SEA
monitoring, where carried out, seems to be of the
environmental baseline – bringing together data that
already exists elsewhere – rather than monitoring of
the effectiveness of SEA mitigation (or of plan imple­
mentation). It was considered that, in Europe at least,
this lacuna seems to be because there is no legal
requirement for anyone to check the results of SEA or
EIA monitoring, except in limited cases such as
licensed facilities (regulated, for example, under
Integrated Pollution Prevention and Control licensing).
Yet, it was observed that monitoring will become man­
datory under ongoing changes in climate so ‘develop­
ing climate change indicators that can be measured at
various tiers could give SEA better footing.’
4. Discussion
On top of the recognition of its legal mandate, the
importance and benefits of monitoring have been
widely acknowledged (e.g. Azcárate et al. 2013;
Gachechiladze-Bozhesku and Fischer 2012; Jiricka-
Pürrer et al., 2021; Morrison-Saunders and Arts 2004;
Persson and Nilsson 2007). In addition, monitoring is
considered the stage that could best link SEA and EIA
procedures; tiering through monitoring can enhance
both assessment types (González and Therivel 2021).
However, the latest peer-reviewed publications, the
findings from the European REFIT review and recent
Irish research studies all point to the same issue: mon­
itoring remains the forgotten sibling of environmental
assessment practice. The findings of the Irish reviews,
for example, echo previous studies. The inadequacy of
monitoring indicators observed in Irish practice was
also observed by Polido et al. (2016). The missed
opportunity of monitoring to fill data gaps, address
uncertainty and capture unforeseen adverse effects is
a shortcoming that was also noted by Azcárate et al.
(2013) and Partidário and Fischer (2004). The lack of
resources to support SEA monitoring implementation
remarked by Irish practitioners aligns with the findings
from a previous online international survey
(Gachechiladze-Bozhesku and Fischer 2012) and the
more recent SEA REFIT (EC 2019). This particular limita­
tion could potentially be addressed by participative
monitoring approaches that rely on citizen science,
such as those reviewed by Stepenuck and Green
(2015) and Carton and Ache (2017). Such approaches
enable distributed data collection over long periods
and foster public input and engagement in decision-
making by increasing awareness of local issues/con­
cerns to influence decisions (González and Gazzola
IMPACT ASSESSMENT AND PROJECT APPRAISAL 173
2019). Nevertheless, the complexities of determining
whether any environmental changes occur as a result
of a given plan/programme remain, as previously
emphasised in the international literature (e.g. Arts
1998; Partidario and Fischer, 2004; Cherp et al. 2012;
Fischer and Retief 2021). Similarly, the absence of
reporting or communication of SEA monitoring results
in practice has been repeatedly noted (e.g.
Gachechiladze et al. 2009; Lundberg et al. 2010;
González et al. 2019).
The international literature has identified issues addi­
tional to those highlighted by the Irish case studies. For
example, SEA monitoring that relies on existing environ­
mental observation systems is often inappropriate and/
or insufficient due to problems with data collection
frequencies, scales and compatibilities (Hanusch and
Glasson 2008; Gachechiladze et al. 2009). Previous stu­
dies have also highlighted shortcomings in current
monitoring practice with regards to the implementation
of mitigation measures and the identification/evalua­
tion of unforeseen, emerging and external issues
(Hanusch and Glasson 2008; Gachechiladze et al. 2009;
Lundberg et al. 2010; Wallgren et al. 2011).
Interestingly, many of the practical inefficiencies
encountered in other assessment stages (e.g. baseline
environment, alternatives, mitigation) are being slowly
but surely addressed. This is partially as a result of
guidance and ongoing practice, and partially the result
of a build-up of legal challenges that have fostered
improvements in SEA practice. A review of Court of
Justice of the EU (CJEU) case law highlights that SEA
and EIA legal challenges to date have mostly focused on
the failure to carry assessments and comply with legal
requirements concerning the environmental report (EU
2020; ECGF 2021). Monitoring does not seem to have
‘hit’ the CJEU yet which, in itself, is a sign that this
procedural stage and its implementation continue to
be overlooked and neglected.
5. Recommendations for good monitoring
practice
In an attempt to support better monitoring practice and
in order to foster further discussion on this critical envir­
onmental assessment sibling, Table 3 puts forward a set
of pragmatic recommendations. These have been
gleaned from the literature, interviews with planners
and SEA experts, and case studies.
6. Conclusion
Monitoring is a key part of SEA, but it remains the for­
gotten sibling to the other SEA steps that are generally
improving worldwide. The enduring poor performance of
SEA monitoring significantly reduces the ability of the
impact assessment research and practice community to
determine whether SEA is resulting in sustainable
174 A. GONZÁLEZ
Table 3. Recommendations to improve SEA (and EIA) monitoring practice.
For SEA practitioners – responsible for developing the monitoring measures
1. Definition of Monitoring
Indicators
2. Definition of Monitoring
Arrangements
3. Monitoring in the SEA ER
For plan-makers – responsible for interrogating data and reporting on monitoring
4. Implementing Monitoring
5. Populating and Evaluating
Indicators
For EIA consultants – responsible for filling data gaps and undertaking detailed assessments
6. Carrying out SEA Monitoring
a. Identify a suitably small set of highly relevant indicators to meaningfully monitor the environmental effects of
plan/programme implementation.
b. The monitoring indicators should measure:
● Identified/likely environmental impacts of the plan;
● Unforeseen adverse impacts of the plan, notably assumptions underlying the SEA impact predictions that may
not happen in practice (e.g. changes in travel behaviour in response to a new bus service); and
● The implementation of mitigation measures, including their effectiveness – to allow this, mitigation measures
should be clearly described and measurable; and
● Data gaps that need to be filled before the next iteration of the plan (where the plan is cyclical) or the next
phase of plan implementation.
c. Align indicators with the scope and nature of the plan (e.g. several water quality indicators may be needed for
a water resources management plan but only one of such indicators, if any, may be relevant to a transport
plan).
d. Use existing monitoring programmes and initiatives appropriate to the issues and scale of the plan (e.g. water
quality and biodiversity reporting datasets for populating indicators relevant to the regional and local levels;
Sustainable Development Goal (SDG) indicators for national assessment monitoring). However, depending on
the level of detail required, more local-level and/or bespoke monitoring may be needed. Larger-scale datasets
may help identify whether more local-level monitoring is needed (e.g. if there is a particular problem at the
local level) or not.
e. Link the monitoring indicators to measurable international and national thresholds/standards (e.g.
achievement of World Health Organisation air quality standards, or the SDGs). This allows the normative
effectiveness of SEA to be tested.
a. Identify the data sources that will be used for monitoring each indicator.
b. Identify the organisations with relevant monitoring responsibilities. While the plan-maker is, in all cases,
responsible for plan-implementation monitoring, different third-party organisations may be responsible for
monitoring specific indicators (e.g. water or air quality).
c. Define the level of detail of monitoring required – see 1d. above.
d. Define the monitoring frequency and reporting requirements (e.g. who should be notified). This facilitates
communication between agencies and resource allocation in case of environmental problems.
e. Define remedial actions if the monitoring data identifies significant adverse unforeseen impacts, and the level
of impact at which the remedial actions would be implemented. This could include the application of
additional technologies (e.g. to reduce point source pollutants or improve energy efficiency if stated air quality
or energy targets are not met), additional management measures (e.g. closure of certain areas to recreational
activities if recreational activities are increasing traffic congestion or affecting the populations of certain
species), and not permitting a subsequent planned phase of development (e.g. phase 2 of a wind farm if phase
1 leads to an x% reduction in bird or bat populations).
f. Define the responsibility for remedial actions. A clear definition of responsibilities would provide accountability
for remedial action where environmental targets are not achieved.
a. Include a specific recommendation in the SEA ER for the monitoring programme to be incorporated into the
plan/programme or added as a chapter so that this aspect is not ‘lost’ as part of plan/programme
implementation reviews.
b. Refer to previous plans/programmes’ monitoring frameworks and data in the next round of plan SEA. In
particular, the next SEA should identify from the monitoring data any unforeseen adverse impacts of the
previous plan, and attempt to explain why these occurred. Monitoring can provide a robust and up to date
baseline for future SEAs and, more importantly, a better understanding of the implications of certain plans/
programmes – which can, ultimately, contribute to better planning and more informed decisions.
a. Include a specific commitment in the plan/programme for environmental monitoring and reporting, as
identified in the SEA.
b. Earmark resources, including a defined budget, within the plan-making organisation to collate and report on
the relevant monitoring information.
c. Devise a monitoring approach within the organisation that feeds into plan/programme implementation review
and related reporting. This allows uncertainties and data gaps to be addressed, provides a more robust baseline
and better informs future planning. Moreover, plans at different levels could use the same methodological
framework with regards to core indicators, monitoring frequency, etc. to help align internally all monitoring
efforts in plan-making.
d. Consider the issue of monitoring as part of scoping or alternatives workshops during the preparation of a plan/
programme. This is particularly useful for cyclical plans, since it would ensure that previous monitoring data
inform the new SEA, and that monitoring of the new plan learns from any issues arising from monitoring of the
old plan.
e. Make monitoring data and reports available online and, where suitable, link monitoring data to existing GIS
databases. This can enhance understanding and knowledge across planning hierarchies and sectors, and avoid
institutional memory loss.
f. Where monitoring of individual areas or projects is required, include these requirements in a GIS, so that
planners can interactively click on a site to find out required measures and refer to them at the project level
(this is currently done, for example, in Clare County Council’s land-use planning system, and in the preparation
of Irish River Basin Management Plans).
a. Document the monitoring data on a regular (e.g. annual) basis, and make the monitoring results public.
b. Test the plan/programme impacts in relation to established targets and thresholds.
c. Use spatial/GIS data for spatial plans to ‘zoom in’ on areas to undertake more detailed appraisal of changes in
environmental indicators, and identify where remedial actions may be required.
a. Check the relevant SEA/plan/GIS system, and carry out project-specific monitoring requirements resulting from
SEA. This will allow the EIA to effectively address data gaps and strategic issues and uncertainties (e.g.
cumulative impacts, carbon emissions, habitat fragmentation) for a robust assessment.
b. Publish the monitoring data from a. so the information can accumulate back up, to work with and inform the
strategic level indicator and future SEAs.
(Continued)
 IMPACT ASSESSMENT AND PROJECT APPRAISAL 175

Table 3. (Continued).
For SEA practitioners – responsible for developing the monitoring measures
Strategic recommendations for policy-makers
7. Monitoring Requirements Amend guidance and, where appropriate, legislation/regulations to require monitoring findings to be made
publicly available on the plan-makers’ website alongside the plan/programme and SEA related documentation.
8. Monitoring Guidance and Develop guidance and training, including good practice examples, to foster good monitoring practice, taking the
Training points above into account. In particular, showcase approaches that help to address the complexity of
interactions, which makes it difficult to identify the environmental changes that result from a given plan/
programme. For example, showcase approaches that distinguish between the environmental actions of an
individual plan (e.g. energy efficient housing) and the actual aims (e.g. zero carbon by 2040).
9. Dedicated Resources Create a dedicated team (probably at the national level, possibly comprising representatives from the statutory
environmental bodies) to ensure compliance with the statutory requirements for SEA monitoring, follow up on
environmental trends and engage with planners during plan-making. This advisory role would also enhance
environmental integration in plan-making and develop more sustainable plans/programmes.
10. Monitoring Data Gathering and Coordinate the gathering and provision of centralised access to relevant environmental monitoring (including
Centralisation spatial) data across planning hierarchies and sectors. This would present a rapid and systematic way of
addressing ongoing monitoring limitations and reduce the costs of evidence gathering for next round of SEAs.
11. Technology Support Use technology and innovation to encourage monitoring implementation and to tap into currently available but
under-used sources of data gathering and sharing (web-based services, citizen science, remote sensing, etc.).
Support citizen science initiatives and empower the public by giving them a voice, and allow plan-making
authorities to tap into local knowledge and data sources and volunteered reporting of environmental changes.

outcomes and preventing adverse effects on the envir­ References

onment – and thus determine the performance of the
pluralist, substantive, normative and knowledge/learning
dimensions of SEA effectiveness.
This paper highlights the continuing need for stron­
ger measures to efficiently implement monitoring. The
proposed good practice recommendations put for­
ward have an Irish practice focus but are also relevant
and transferable to other SEA and planning contexts,
and should be useful for improved SEA monitoring in
any jurisdiction. At the heart of it is the need for
practitioners to focus efforts on monitoring and for
plan-makers to commit to implementing monitoring
programmes if future plan/programme cycles are to
benefit from properly understanding assessment out­
comes and environmental pressures and conse­
quences. The establishment of appropriate
monitoring systems that respond to monitoring
requirements across multiple sectors and planning
hierarchies will require investment, but should deliver
net benefits in due course by informing assessments
that provide for better plans with a reduced risk of
unforeseen impacts and need for remedial action.
Disclosure statement
No potential conflict of interest was reported by the
author(s).
Funding
This work was supported by the environmental protec­
tion agency (Ireland) [2017-NCMS-8 and 2019-SE-DS-21].
ORCID
Ainhoa González http://orcid.org/0000-0002-9334-3066
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