Strategic environmental assessment monitoring: the enduring forgotten sibling

ABSTRACT

Monitoring in Strategic Environmental Assessment (SEA) is central to determining whether the assessment outcomes and associated mitigation measures have had the desired effect and the environment has been protected on the ground. Despite the critical role this procedural stage plays, and the international attempts to advance practice in this area, monitoring continues to be poorly performed 20 years on from the implementation of the European SEA Directive. 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.

KEYWORDS:

• SEA
• monitoring
• follow-up
• good practice

1. Introduction

Strategic Environmental Assessment (SEA) monitoring is a mandatory requirement under European and certain international law (EC 2001; Dalal-Clayton and Sadler 2005). It is recognised as a good practice principle (IAIA 2002) and essential for assessment accountability 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 physical 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 performance 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).

Figure 1. Monitoring as a cornerstone in Strategic Environmental Assessment (SEA) and SEA follow-up.

Monitoring data can be used to check whether SEA recommendations and mitigation measures have been implemented and how effective these are at protecting 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, without monitoring, it is not possible to know and indeed understand the consequences of SEA. Without monitoring, 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 environmental 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 ‘implementation’ (Fischer and Retief 2021; Therivel and González 2021). Similarly, without monitoring, it is difficult 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).

Arguably, there is little point in SEA without monitoring as the effectiveness of the assessment in protecting 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 literature, 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 relevant manuscripts and two milestone books: one specific 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 publications date from 2003 to 2021. Interestingly, a particular intensive or concentrated attentiveness to SEA monitoring 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 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).

Figure 2. Year of publication of the SEA monitoring and follow-up publications identified in a targeted Scopus search.

Three papers explore specific monitoring case studies (e.g. Azcárate et al. 2013; Gachechiladze-Bozhesk, 2012; Jiricka-Pürrer et al., 2021). Others present conceptual 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 allocation 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 identified impacts, demonstrating ‘a lack of understanding as to the very purpose of monitoring’ (Söderman and Kallio 2009, p. 17). Monitoring generally focuses on observing whether the SEA recommendations and mitigation measures are implemented (Lundberg et al. 2010; Wallgren et al. 2011) and in very rare occasions 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 information 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, especially when it comes to identifying unforeseen effects 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 challenges include ‘a more explicit link between the SEA requirements of an individual plan or programme and existing monitoring activities, in order to avoid unnecessary duplication of these actions (e.g. by establishing 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 international SEA experts to gather information on benefits/limitations of current SEA practice not captured in SEA Environmental Reports (SEA ERs), and to seek expert opinion on how to improve current practice.

Table 1. Case studies reviewed in the second review of SEA effectiveness in Ireland (EPA 2018)

Name of Plan/Programme	Sector	Hierarchy
Clare County Development Plan 2017–2023	Land-use	County
Dublin City Development Plan 2011–2017	Land-use	County
EirGrid Grid25 Implementation Programme 2011–2016	Energy, onshore	National
Fingal County Development Plan 2011–2017	Land-use	County
FoodWise 2025	Agriculture	National
Greater Dublin Area Transport Strategy 2011–2030	Transport	Regional
National Forestry Programme 2014–2020	Forestry	National
National Planning Framework 2040	Land-use	National
National River Basin Management Plan 2018–2021	Water management	National
Nitrates Action Programme 2017–2021	Agriculture, water	National
Offshore Renewable Energy Development Plan 2014	Energy, offshore	National
Shannon Catchment Flood Risk Assessment and Management Plan 2015–2021	Water management	Regional
Southern Regional Waste Management Plan	Waste Management	Regional
Strategic Integrated Framework Plan for the Shannon Estuary 2013–2020	Water management, industry	Regional
Wild Atlantic Way Operational Programme 2015–2019	Tourism	Regional

The key procedural challenges identified in this effectiveness review were similar to those experienced 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 practice. A degree of ‘informal’ monitoring takes place in land-use planning, where the mandatory planning requirement to review development plans every 6 years and to formulate interim reports after 2 years forces planners to take stock of environmental 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 development due to SEA, even in cases where mitigation 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/programme 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 assessment objectives; reusing the assessment indicators and targets from the assessment (i.e. baseline or impact assessment criteria) as part of the proposed monitoring programme presents 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 mitigation (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 monitoring 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 nationally). However, it is the plan-making authority that is responsible for collating and synthesising the relevant information and reporting on it in relation 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.

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 agencies’ 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 adoption, and the absence of guidance on monitoring were also considered key difficulties hindering practice. In particular, consultees recommended that guidance 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/programme (due to multiple factors influencing overall environmental quality, and to amorphous 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.

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 interviews of 14 national and 14 international SEA practitioners, 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.

Table 2. Case studies reviewed in the tiering in environmental assessment research project (EPA 2021)

SEA/EIAa	Sector	Hierarchy
SEA – Clare Wind Energy Strategy 2017–2023	Energy	County
EIA – Knocknalough Wind Farm 2012	Wind
EIA – Cahermurphy-Kilmihil Wind Farm 2014	Wind
EIA – Glenmore Wind Farm 2014	Wind
SEA – Cherrywood SDZ Masterplan 2010–2016	Land-use	Local
EIA – Mixed-use Town Centre Development 2017	Mixed-use
SEA – Eastern and Midlands Region Waste Management Plan 2015–2021	Waste	Regional
EIA – KMK Metal Recycling Ltd. in Kilbeggan 2017	WEEE, metal recovery
SEA – Waterford City Development Plan 2013–2019	Land-use	City
SEA – Kerry County Development Plan 2015–2021	Land-use	County
EIA – N69 Listowel Bypass Proposed Road Development 2017	Transport
EIA – N70 Sneem to Blackwater Bridge Road Project 2019	Transport
SEA – North Quays Strategic Development Zone (SDZ) 2018	Land-use
EIA – Knockboy Residential Strategic Housing Development 2019	Housing
EIA – Kilbarry Residential Scheme 2018	Housing
EIA – North Quays Development 2019	Housing
SEA – Shannon Strategic Integrated Framework Plan 2013–2020	Land- and marine-use	Regional
SEA – Shannon-Foynes Port Development Masterplan 2013–2020	Port
EIA – Shannon-Foynes Port Development Expansion – Strategic Infrastructure Development 2018	Port
SEA – Ulster Canal Restoration Plan 2016–2022	Recreation	Regional
EIA – Ulster Canal Restoration Upper Lough Erne to Clones 2011	Recreation

aShaded SEAs refer to the higher-tier plan. No shading refers to the lower-tier SEAs and EIAs under the higher-tier plan.

The review findings revealed again that, overall, tiering links between SEA and EIA monitoring measures 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 projects, 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 information 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 prioritised are bird surveys (…) together with cetacean monitoring (…) In order to supplement biodiversity data gaps, additional data gathering to be subsequently used during the plan review or at project 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 monitoring measures in each chapter, and these are linked to the SEA. These shortcomings further emphasise the poor performance on the monitoring stage in environmental 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 accumulate back up to inform the strategic monitoring indicator. However, there was also an acknowledgment 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 consultant observed, because they are not ‘stitched into the policy requirements of the relevant plan’.

Two interviewees observed that collecting EIA information 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 contain 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 examples 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 implementation). 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 mandatory under ongoing changes in climate so ‘developing 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: monitoring 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 limitation 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/concerns to influence decisions (González and Gazzola 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 additional to those highlighted by the Irish case studies. For example, SEA monitoring that relies on existing environmental 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 studies have also highlighted shortcomings in current monitoring practice with regards to the implementation of mitigation measures and the identification/evaluation 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 environmental 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.

Table 3. Recommendations to improve SEA (and EIA) monitoring practice

For SEA practitioners – responsible for developing the monitoring measures
1. Definition of Monitoring Indicators	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.
2. Definition of Monitoring Arrangements	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.
3. Monitoring in the SEA ER	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.
For plan-makers – responsible for interrogating data and reporting on monitoring
4. Implementing Monitoring	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).
5. Populating and Evaluating Indicators	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.
For EIA consultants – responsible for filling data gaps and undertaking detailed assessments
6. Carrying out SEA Monitoring	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.
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 Training	Develop guidance and training, including good practice examples, to foster good monitoring practice, taking the 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 Centralisation	Coordinate the gathering and provision of centralised access to relevant environmental monitoring (including 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.

6. Conclusion

Monitoring is a key part of SEA, but it remains the forgotten 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 outcomes and preventing adverse effects on the environment – and thus determine the performance of the pluralist, substantive, normative and knowledge/learning dimensions of SEA effectiveness.

This paper highlights the continuing need for stronger measures to efficiently implement monitoring. The proposed good practice recommendations put forward 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 outcomes and environmental pressures and consequences. 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.

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No potential conflict of interest was reported by the author(s).

Additional information

Funding

This work was supported by the environmental protection agency (Ireland) [2017-NCMS-8 and 2019-SE-DS-21].