Abstract
This professional practice report reflects upon lessons learned from piloting and evaluating an innovative approach to policy strategic environmental assessment (SEA) in developing countries. The primary analytical focuses of the approach are institutions and governance characteristics, plus it places strong emphasis on learning. The piloting provides valuable insights about the conduct of SEA at the policy level and in socio-political where there is limited experience with SEA. From our observations we reflect upon the importance of appropriate ownership of an SEA; the practical implications of working in contested political environments; the challenges in using SEA as a tool to promote good governance; and the centrality of a long-term perspective to environmental and social mainstreaming.
Introduction
Much of the impact assessment community's experience with strategic environmental assessment (SEA) to date has been gained from practices in OECD (Organization for Economic Co-operation and Development) countries and at the programme and plan level of decision-making. The context is markedly different for impact assessment professionals working in international development co-operation. The aid modalities that are currently receiving most attention in this field are intrinsically tied to high level government policies (e.g. budget support and sector reforms). It is generally accepted that decision-making at the policy level differs in important respects from other decision tiers or levels; in particular, it is invariably more complex, contested and unpredictable (Cohen et al. Citation1972, Boothroyd Citation1997, Sabatier Citation2007).
The socio-political and cultural contexts in which international development co-operation takes place can also be radically different from that of the OECD countries: among other things, financial resources are more limited; poverty levels are high and inequalities marked; and public administration and judicial systems are constrained by capacity shortages, plus often experience comparatively high levels of corruption. There has been considerable discussion about how such contextual factors can or should influence SEA practices (e.g. Boyle Citation1998, Hilding-Rydevik and Bjarnadóttir Citation2007, Bina Citation2008). While it is now generally accepted that SEA is a framework concept and practices must vary according to context, precisely how they should be adapted is an open question, particularly in relation to policy decisions.
Under the so-called Paris Declaration,Footnote1 OECD countries and their developing country counterparts have committed to using SEA in international development co-operation and to develop common, harmonized approaches (OECD Citation2005). The OECD Development Assistance Committee has published guidance on SEA which emphasizes the importance of experimentation with different approaches and learning from experience (OECD Citation2006). In this article, we address the conceptual and practical challenges for impact assessment professionals working in international development co-operation by reflecting upon lessons learned from the application of an innovative policy SEA approach developed by the World Bank. The innovations of the World Bank's SEA approach are a function of its willingness to engage critically and practically with contemporary scholarship. This is significant for, as various scholars have noted, SEA scholarship and real-world practices are weakly linked (Hertin et al. Citation2007, Adelle et al. Citation2011).
The paper is structured as follows. It commences with an introduction to the World Bank's policy SEA approach, describing in brief its key innovative features and how it is envisaged to be practised. This is followed by an introduction to a pilot programme that sought to validate the World Bank's policy SEA approach and reflections upon the principal lessons learned from this pilot programme. The paper concludes with recommendations on how to design and practise policy SEA in development co-operation and beyond.
Policy SEA in practice: the World Bank model
The World Bank has developed an approach to policy SEA that has a different focus compared to most contemporary SEA practices. A distinctive feature of this policy SEA approach is that it places institutions, as opposed to impacts, at the heart of the analysis. The term ‘institutions’ is used in reference to formal and informal rules structuring human relationships (North Citation1994). These might include such features as the way in which the government bureaucracy is organized and managed, through to cultural norms that affect everyday social interactions. The approach is based on an assumption that environmental and social mainstreaming is strongly affected by the institutional framework which exists in a particular country context.
The World Bank approach is intended to be iterative and adapted to the country and policy context, using individual policy interventions as ‘windows of opportunity’ to pursue a broader goal of environmental mainstreaming across political and social milieu. The focus of the World Bank's policy SEA approach is resolutely on institutions and governance as structural determinants of opportunities for mainstreaming:
In order to more effectively influence policies, the proposed SEA approach aims to strengthen the institutional, technical and governance dimensions of policy-making processes. In addition to applying analytical and participatory approaches typical within SEA frameworks, SEA for policies… also needs to incorporate a third pillar, designed to enhance learning and continuous improvement of policy design and implementation.
(Ahmed and Sanchez-Triana Citation2008, p. 187)
Environmental concerns are to be mainstreamed in decision-making through analytical and dialogical processes focused on the elucidation of environmental and social priorities. In this manner, SEA becomes a tool for fostering learning among stakeholders about the environmental and social dimensions of policy interventions and to reflect stakeholder preferences about which of these dimensions should be addressed in policy reforms. This is expected to raise awareness of, and increase the prominence given to, environmental and social concerns in politics; to strengthen environmental and social civil society advocacy groups, as a mechanism for promoting oversight of governance practices by civil society and a culture of dialogue above and beyond the specific policy intervention under consideration; to improve social accountability; and, critically, to foster learning across all stakeholders. A further principle that the World Bank seeks to put into operation through policy SEA is to ensure that marginalized and otherwise vulnerable or under-represented sections of society are afforded a genuine opportunity to contribute to policy-making.
The notion that learning should be a principal goal of policy SEA is a particularly noteworthy innovation for, while much has been written on learning, very limited consideration has been given to the purposeful operationalization of this rather nebulous concept in impact assessment practices. Learning is viewed by the World Bank as a mechanism to ensure that the SEA has long-lasting influence on the political landscape above and beyond the individual policy intervention to which the SEA is linked (Slunge et al. Citation2011). Learning is interpreted broadly as constituting reflection upon policy-making problems, goals and strategies by stakeholders and as, ‘building capacity to produce and apply knowledge for better development’ (Carden Citation2009, p. 21).
From a practical perspective, the World Bank's policy SEA approach involves a series of core activities. It typically commences with a situation analysis in which the main environmental and social dimensions of the policy intervention under consideration are identified. The situation analysis provides baseline information on which to initiate a dialogical process for the prioritization of these environmental and social dimensions by the stakeholders themselves.
The next analytical step in the policy SEA approach is an institutional, capacity and political economy assessment. According to the World Bank et al. (Citation2011) this assessment should:
| 1. | Review the legal and regulatory framework. | ||||
| 2. | Assess the gaps which underpin observed failures to address environmental and social priorities. | ||||
| 3. | Assess the effect of the proposed policy on the identified gaps. | ||||
| 4. | Assess the political feasibility of the SEA recommendations. | ||||
The focus on institutions results in an analytical concern with policy history; the goals, values and behaviours of actors; horizontal and vertical co-ordination mechanisms within government; and mechanisms for accountability (Ahmed and Sanchez-Triana Citation2008). This is expected to contribute to an understanding of weaknesses in governance and institutions, and hence to provide a basis for the formulation of recommendations on policy, institutional, legal, regulatory and capacity adjustments that promote environmental and social mainstreaming. Multi-stakeholder dialogue is expected to occur throughout a policy SEA (World Bank et al. Citation2011).
Lessons from practice
In 2006, the World Bank established a pilot programme to validate their policy SEA approach. The first phase of the pilot programme involved undertaking six SEAs in various developing countries and for a variety of policies (see Table ). In each case the SEAs were implemented in partnership with a national counterpart in the country concerned. In the second phase of the pilot programme, the Swedish EIA Centre at the Swedish University of Agricultural Sciences, the Environmental Economics Unit at the University of Gothenburg and the Netherlands Commission for Environmental Assessment were invited by the World Bank to join in the evaluation of the pilot SEAs. The evaluations generated wide-ranging lessons. We focus in this paper on succinctly presenting a small number of the lessons which are considered to be particularly germane to impact assessment professionals.Footnote2
Table 1 Policy SEAs conducted as part of the pilot programme.
Prerequisites for an effective policy SEA
Some of the lessons learned concern prerequisites for an effective policy SEA, wherein effectiveness is interpreted broadly as the purposeful employment of SEA (Cashmore et al. Citation2009, Citation2010). A key insight from the pilot programme concerned the importance of ownership of a policy SEA by an appropriate organization and the trade-offs involved in deciding who should lead the SEA. Many developing countries have limited experience of systematically addressing environmental and social concerns at strategic levels of decision-making and their capacity to lead a policy SEA under such circumstances is limited. That was certainly the case in the countries involved in the pilot programme, with the notable exception of China. It was evident from the pilot programme that bilateral and multilateral development co-operation organizations can play a catalysing role in generating awareness about, and interest in, SEA as a tool for environmental and social mainstreaming at the highest strategic level. They can create conditions conducive to effective policy SEA through a broad spectrum of activities that foster capacity development and commitment to mainstreaming activities. They can also play a very significant role in facilitating the exchange of experiences between developing countries using policy SEA approaches, as this pilot programme illustrates. Yet our experiences strongly suggest they should not be the organization driving individual policy SEAs, despite their considerable political influence.
Our analysis highlighted the importance of having a strong national lead organization to ensure that a policy SEA achieves its goals and that the mainstreaming process continues beyond the completion of the SEA report. Ownership at the national level is important for generating trust in the process and ownership of any recommended policy, institutional or governance realignments. National environment agencies may appear to be a logical organization to lead a policy SEA, but frequently in developing countries they lack sufficient political influence and resources. We suggest that ownership of a policy SEA typically should be assumed by the policy proponent; that is, the government ministry or department primarily responsible for the particular sector or sectors which the policy intervention affects.
Ownership of a policy SEA by the policy proponent can inevitably lead to tensions, notably that of vested interests. Such tensions are unavoidable, but the process of raising the policy proponent's awareness about the effects of vested interests etc., is in itself a critical element of the learning associated with environmental and social mainstreaming. Nevertheless, it is important that the lead organization has genuine high level commitment to the policy SEA and strong incentives to reflect upon the results and recommendations. It also needs sufficient capacity and training to understand the concept and practice of policy SEA, plus to appropriately integrate SEA in the policy process. If these conditions are not met prior to the commencement of a policy SEA, the discrete policy intervention in question may not represent a suitable ‘window of opportunity’ for environmental and social mainstreaming; valuable resources may be wasted.
We also emphasize the importance of engendering ownership of the environmental and social mainstreaming processes among broader stakeholders in order to ensure their commitment to mainstreaming. This is inherent in the concept of open and inclusive dialogue embedded in the World Bank's approach, but in the messy reality of real-world politics it can be extremely challenging to achieve.
Political context
The policy SEA approach places the issue of national political context at the heart of the analytical work through its focus on institutional and governance dimensions of environmental and social mainstreaming. The pilot programme showed that such issues need to be addressed with considerable skill and sensitivity in a policy SEA. For example, the policy SEAs analysed such sensitive issues as institutional practices that were judged incompatible with (largely Western) principles of good governance, vested interests pervading government institutions, deep distrust among stakeholders and historical failures to implement policy commitments. Focusing attention on such issues can create various tensions: indeed, the notion of analysing governance and institutions on its own proved controversial in the Chinese policy SEA. The political ramifications of the findings of the policy SEAs were also generally underestimated at the start of the pilot programme.
Likewise, the roles and influence of non-formal and customary institutions are important to consider when designing an individual policy SEA. The importance of such institutions to socio-political systems tended to be underplayed in some of the pilot SEAs. Yet the evaluations showed that policy SEAs are unlikely to be influential in the long term if these non-formal and customary institutions are not adequately involved.
Political analysis and fostering constructive dialogues over sensitive political issues among high ranking politicians are skills that traditionally have not been strongly emphasized within the impact assessment community; neither are the types of cultural analysis associated with developing a complex understanding of non-formal and customary institutions that may operate in developing countries. These factors have practical implications for the conduct of policy SEA. There is a need to ensure that consultancy teams have the necessary competence to carry out institutional and governance analyses. Traditionally, SEA consultants have been environmental professionals, engineers and technical specialists, building on their experience of carrying out environmental impact assessments of projects. In addition to such experience, policy SEA needs to draw on disciplines such as anthropology, sociology, economics and political science; that is to say, teams need to include experts who can address the complexities of political and cultural systems, including power relations and drivers of development, plus include facilitators that can work effectively with high level politicians.
Process and goals
It was noted previously that the World Bank's policy SEA approach aims to promote environmental and social mainstreaming through different immediate goals than those of most contemporary SEA practices, and hence its methodology is distinct too. The pilot programme demonstrated that impact assessment professionals are invariably competent at performing analytical activities associated with policy SEA, although different skills were required given the focus on governance and institutions. What tended to be more problematic was the design and conduct of dialogical practices capable of promoting the goals of enhanced accountability, social empowerment and learning. In particular, the amount of resources which need to be dedicated to fostering a multi-stakeholder dialogue designed to achieve such goals is easily underestimated.
In order to ensure that vulnerable and marginalized groups are properly included in political dialogue, policy SEA needs to include a considered analysis of the obstacles to full representation and should propose mechanisms by which unorganized stakeholders can be reached. The design of dialogical activities also needs to be particularly sensitive to power relations. For example, in the case where a minority of stakeholders oppose the majority view but are considerably more politically influential, the SEA is unlikely to promote learning unless steps are taken to ensure they cannot unduly dominate policy decisions. Conversely, when the minority view is represented by weaker stakeholders, particular attention needs to be paid to how to give voice to these views. The methods used may necessarily vary not only between policy contexts but also between different groups of stakeholders within a specific context.
Meaningful involvement of concerned stakeholders is crucial to strengthening civil society advocacy groups. The pilot programme indicated that policy SEA appears to have the potential to empower civil society groups by institutionalizing an ethos of inclusive dialogue within a governance regime. We argue that to achieve lasting strengthening of civil society advocacy groups it is critical that adequate resources are dedicated to developing dialogical processes that will persist throughout the policy SEA and beyond. The evaluations showed clearly that one-off consultation exercises, single-day one-room workshops etc., are not an effective approach to empowering civil society, nor are they sensitive to power imbalances among stakeholders that may affect their capacity to participate.
Active and empowered civil society advocacy groups can strengthen demand for accountable governance practices. This is dependent upon the type of sustained dialogue discussed above. The importance of taking a long-term perspective to environmental and social mainstreaming, even when dealing with seemingly transient policy interventions, cannot be understated. A critical step here is to ensure there are appropriate mechanisms to feed back information to stakeholders who have participated in a policy SEA. Although open access to the SEA report would be expected, this is not always the case in developing countries. Additionally, the SEA report may not be an effective vehicle for communicating with many stakeholders. Additional modes of communication are needed.
Experience from the pilot programme has shown that policy SEA can strengthen accountability in other ways, such as simply by empowering stakeholders through improved access to information. The establishment of monitoring frameworks for environmental and social priorities was an important lever for stronger accountability in several of the pilot cases.
Learning
A key innovative feature of the World Bank's policy SEA approach is that it places considerable emphasis on the role of learning in achieving environmental and social mainstreaming. It is difficult to ascertain to what degree the pilot SEAs successfully promoted learning in practice because it is recognized that learning may have a gestation period of a decade or more (Sabatier Citation1988) and that, where learning is observed, it is problematic analytically to separate the influence of SEA from other variables. Certainly various learning outcomes were observed during the evaluation of the pilot SEAs. We found evidence that policy SEA created space for new policy framings to emerge and new governance expectations to develop. There was limited evidence that this led to what we might label as ‘deep learning’Footnote3 in terms of concrete reforms of institutions and governance, but, as previously mentioned, it is likely that any such changes will take many years to emerge.
What the pilot programme did clearly show in respect to learning was the importance of creating enduring dialogical processes among stakeholders. New ideas were incorporated in the framing of policy problems in some of the pilots, but without opportunities for continued reflection on environmental and social concerns in appropriate forums (i.e. ones that are open, accountable, inclusive etc.), for trust to develop and relationships to grow, learning is likely to remain superficial and fragile. The importance attached to the prioritized environmental and social concerns may fade if the perspectives of civil society groups are not continuously reflected in the policy dialogues and the pre-SEA status quo may re-emerge.
Maintaining a learning process related to the prioritized concerns is in part dependent on civil society groups having the capacity and opportunity to participate, plus acceptance by the policy proponent of the need for transparent and accountable governance. The experiences gained from the pilot programme emphasize the importance of taking a long-term perspective to mainstreaming through learning at the policy level.
Conclusions
Systematic experimentation with an innovative approach to policy SEA has provided a unique opportunity for reflection upon conceptual and methodological aspects of the practice of SEA in international development co-operation and beyond. This professional practice report has provided a succinct overview of what were deemed to be the most insightful or otherwise germane lessons for impact assessment professionals that were learned from the pilot programme.
The key goals of the World Bank's policy SEA approach all build upon effective involvement of stakeholders in SEA and policy decisions. The participatory dimensions of policy SEA are thus of equal, if not greater, importance than the analytical dimensions (see also Vicente and Partidário Citation2006); nevertheless it appears that the participatory dimensions of SEA practices are arguably the more problematic of the two. While there is a considerable body of literature on the principles and methods of participation, practice appears to lag considerably behind theory. Consequently, we highlight the following points about participation in policy SEA:
| • | Meaningful dialogue may be extremely resource intensive, requiring the commitment of considerable time and skilled human resources. | ||||
| • | Participation which is sensitive to power relations and culture will typically involve the use of a variety of dialogical methods. | ||||
| • | A key challenge in achieving learning is to foster enduring dialogue. This requires a long-term perspective on mainstreaming to be adopted and effective co-ordination of individual policy SEAs with other mainstreaming activities. | ||||
| • | In dialogues over highly politicized issues, which a focus on institutions and governance may bring to the fore, highly skilled facilitators are needed. | ||||
In emphasizing the participatory dimensions of policy SEA, we do not seek to denigrate the importance, or skilled nature, of analytical activities, for the two are interdependent. Yet the analytical dimensions of policy SEA build more directly upon existing strengths within the impact assessment community, although slightly different types of expertise to those typically represented in contemporary SEA or environmental impact assessment practices are needed given the nature of policy decisions in development co-operation. Anthropologists, economists and political scientists have a greater role to play at the policy level.
While the primary focus of the policy SEA approach is to mainstream environmental and social considerations in the governance regimes of developing countries, we note that the pilot SEAs also generated information of considerable value to development co-operation organizations. Policy SEA has the potential to highlight areas for inter-sectoral co-ordination and collaboration; it can contribute to identifying issues to prioritize in strategic dialogues with the developing country in question, and it brings to the surface the issue of capacity requirements for mainstreaming. It can also identify how the various development co-operation organizations operating in a particular developing country could improve inter-organizational co-ordination and hence the efficiency of their activities beyond the policy intervention in question.
To conclude, we return to a central goal of the World Bank's policy SEA approach – learning. It has been noted that, while there was evidence that some learning occurred as a consequence of the policy SEAs, it is too early to draw firm conclusions about how successful the pilot programme was in this respect. As Carden (Citation2009, p. 21) notes: ‘This kind of influence can take years, or even decades to take effect or become apparent. But is no less important for that’ (emphasis added). The pilot programme served to illustrate the gravity of the conceptual and practical challenges to using SEA as a tool to purposefully orchestrate deep learning in contested policy settings. Nevertheless, the willingness of development co-operation organizations to experiment with a somewhat intangible, academic concept like learning is to be commended.
Acknowledgements
The paper draws on experiences gained from an SEA pilot programme funded by the World Bank, the Swedish International Development Co-operation Agency and the Netherlands Commission for Environmental Assessment. The authors acknowledge the support made by advisory groups that have provided input to the design and evaluation of the pilot programme and to individuals who worked on specific country pilots: Jiri Dusik, Paul Guthiga, Yin Jian, Juan Albarracin Jordan, Wilfred Nyangena and Ulf G. Sandström. The views expressed in the paper are those of the authors and do not represent those of the World Bank, the Swedish International Development Co-operation Agency and/or the Netherlands Commission for Environmental Assessment.
Notes
1. The Paris Declaration on Aid Effectiveness is an international agreement that seeks to promote harmonization and alignment of international aid efforts, more effective management of aid and a stronger focus on the monitoring of results. As such, it effectively constitutes a meta-framework of organizing principles for international development co-operation.
2. The detailed findings and recommendations for policy-level SEA are presented in World Bank et al. (Citation2011).
3. Frequently, this is referred to as double-loop learning in literature on learning, after Argyris and Schön (Citation1978).
References
- Adelle , C. , Jordan , A. and Turnpenny , J. 2012 . Proceeding in parallel or drifting apart? A systematic review of policy appraisal research and practice . Environment and Planning C , in press
- Ahmed , K. and Sanchez-Triana , E. 2008 . “ Using strategic environmental assessments to design and implement public policy ” . In Strategic environmental assessment for policies. An instrument for good governance , Edited by: Ahmed , K. and Sanchez-Triana , E. 181 – 205 . Washington, DC : World Bank .
- Argyris , S. and Schön , D. 1978 . Organizational learning: a theory of action perspective , Reading, MA : Addison-Wesley .
- Bina , O. 2008 . Context and systems: thinking more broadly about effectiveness in strategic environmental assessment in China . Environmental Management , 42 ( 4 ) : 717 – 733 .
- Boothroyd , P. 1997 . “ Policy assessment ” . In Environmental and social impact assessment , Edited by: Vanclay , F. and Bronstein , D.A. 83 – 126 . Chichester : John Wiley & Sons .
- Boyle , J. 1998 . Cultural influences on implementing environmental impact assessment: insights from Thailand, Indonesia and Malaysia . Environmental Impact Assessment Review , 18 : 95 – 116 .
- Carden , F. 2009 . Knowledge to policy: making the most of development research , Ottawa : International Development Research Centre .
- Cashmore , M. , Bond , A. and Sadler , B. 2009 . Editorial introduction: the effectiveness of impact assessment instruments . Impact Assessment and Project Appraisal , 27 ( 2 ) : 91 – 93 .
- Cashmore , M. 2010 . Evaluating the effectiveness of impact assessment instruments: theorising the nature and implications of their political constitution . Environmental Impact Assessment Review , 30 ( 6 ) : 371 – 379 .
- Cohen , M.D. , March , J.G. and Olsen , J.P. 1972 . A garbage can model of organizational choice . Administrative Science Quarterly , 17 ( 1 ) : 1 – 25 .
- Hertin , J. 2007 . Rationalising the policy mess? Ex ante policy assessment and the utilisation of knowledge in the policy process . Environment and Planning A , 41 ( 5 ) : 1185 – 1200 .
- Hilding-Rydevik , T. and Bjarnadóttir , H. 2007 . Context consciousness and sensitivity in SEA implementation . Environmental Impact Assessment Review , 27 ( 7 ) : 666 – 684 .
- North , D.C. 1994 . Economic performance through time . American Economic Review , 84 : 359 – 369 .
- OECD . 2005 . Paris Declaration on Aid Effectiveness , Paris : OECD .
- OECD . 2006 . Applying strategic environmental assessment. Good practice guidance for development co-operation , Paris : OECD .
- Sabatier , P. 1988 . An advocacy coalition framework of policy change and the role of policy-oriented learning therein . Policy Sciences , 21 : 129 – 168 .
- Sabatier , P.A. , ed. 2007 . Theories of the policy process , Boulder, CO : Westview Press .
- Slunge , D. 2011 . “ Conceptual analysis and evaluation framework for institution-centered strategic environmental assessment ” . In Strategic environmental assessment in policy and sector reform. Conceptual model and operational guidance , 127 – 176 . Washington, DC : World Bank .
- Vicente , G. and Partidário , M.R. 2006 . SEA – enhancing communication for better environmental decisions . Environmental Impact Assessment Review , 26 : 696 – 706 .
- World Bank, University of Gothenburg, Swedish University of Agricultural Sciences and Netherlands Commission for Environmental Assessment . 2011 . Strategic environmental assessment in policy and sector reform. Conceptual model and operational guidance , Washington, DC : World Bank .