📘 Disclaimer: This document is a conceptual proposal prepared for consideration by East Hampshire District Council (EHDC). It does not represent current policy but outlines an optional framework that EHDC could choose to adopt, pilot, or develop further. It has been designed to be implementable in its current form or used as a foundation for future formal guidance or policy inclusion.
| EIA-SCREEN: A Framework for Responsible Environmental Assessment in East Hampshire |
There are no legal, financial, or procedural barriers preventing East Hampshire District Council (EHDC) from implementing a stronger Environmental Impact Assessment (EIA) screening policy — none. The full cost of EIA preparation falls entirely on developers, not the council. National policy (NPPF) not only allows but encourages local authorities to tailor EIA thresholds and requirements to reflect their area’s specific environmental and infrastructure pressures. EHDC holds full legal discretion to do so. The only missing ingredient is political will: a genuine, resident-focused leadership that chooses to act. Strengthening EIA screening is a no-brainer — it costs EHDC nothing and delivers enormous public benefit. Any refusal to pursue this reform cannot be justified on planning grounds; it can only be seen as an abdication of responsibility.
📚 Background and Purpose
An Environmental Impact Assessment (EIA) is a legal process that ensures proposed developments are properly assessed for potential environmental harm before planning permission is granted.
Under the Town and Country Planning (Environmental Impact Assessment) Regulations 2017, developers must submit an EIA if their proposal:
- Is a Schedule 1 project (which always requires a full EIA), or
- Is a Schedule 2 project (which requires an EIA if it’s likely to cause significant effects)
However, for Schedule 2 projects, it is the council’s legal responsibility — in this case, EHDC — to carry out a screening decision to determine whether a full EIA is required.
At present, this screening process:
- Lacks consistency,
- Is vulnerable to underestimating impact, and
- Often fails to consider cumulative development pressure or sensitive local contexts.
This framework is designed to strengthen how EHDC applies EIA screening, improve public transparency, and ensure that environmental protection is proactive, locally relevant, and legally robust.
📏 Defining Cumulative Development for Screening
All EIA screening decisions must assess cumulative development activity within the named settlement, and within any related functional service area — regardless of whether that area is larger, smaller, or overlapping with the settlement boundary.
Functional service areas may include:
- Shared GP catchments
- School admissions zones
- Utility networks (e.g. drainage or wastewater)
- Any other relevant infrastructure zones identified by consultees
Screening must use a rolling five-year window, and include:
- All approved major developments (whether built or not),
- All pending or validated applications,
- And any phased or related applications on adjacent or linked land.
🔢 Note: Population growth thresholds are still calculated by named settlement using official Census or mid-year estimates.
📘 Public Explanation – Why We Use This Approach
Local services rarely follow clean village or town boundaries. One GP might serve three villages. A school catchment might cover only part of a town.
If EHDC only looks at what’s happening inside a single boundary, it could miss serious pressure on those shared services — or fail to flag cumulative environmental risk.
That’s why this framework uses a more realistic approach: it looks at both the named settlement and the real-world infrastructure areas people depend on — even if those areas are bigger, smaller, or cross between places.
✅ It doesn’t overcomplicate things.
✅ It doesn’t block development.
✅ It just makes sure EHDC doesn’t miss what really matters — and applies the law fairly based on how services actually function.
⚖️ A. Local Plan Allocation and Delivery Rate Triggers
A full EIA must be required if any single application, or the combined effect of applications over five years, in a named settlement:
- ✅ Meets or exceeds the total housing allocation for that settlement (from the adopted Local Plan); or
- ⏱️ Delivers 10 years’ worth of Local Plan housing in fewer than 10 years; or
- 📈 Exceeds double the expected annual delivery rate, based on Local Plan targets divided by the total plan period.
These thresholds apply regardless of whether the growth comes from one scheme or many.
📘 Public Note – Why This Matters
Let’s say Medstead is supposed to grow by 400 homes between 2020 and 2040 — that’s 20 homes a year.
But if 200 homes are approved by 2026, we’re already at 10 years’ worth of growth in just 6 years.
That puts pressure on roads, GPs, schools, drainage — often before upgrades are in place.This policy doesn’t block that growth — it just says, “Let’s stop and assess the full impact before approving more.”
🧮 B. Proportionate Screening Thresholds by Settlement Size
Even before Local Plan allocations are reached, EHDC will apply proportionate EIA screening thresholds based on settlement population.
| To further support fair and proportionate screening, EHDC will apply scale-sensitive “starting points” for triggering EIA in different types of settlements — especially where cumulative activity does not yet meet allocation-based thresholds, but may still pose serious environmental risk. |
| Settlement Type | Population Range | Suggested EIA Screening Trigger |
|---|---|---|
| Small Village | Fewer than 1,000 | 30+ dwellings or over 10% population growth |
| Large Village | 1,000–4,999 | 50+ dwellings or over 7% population growth |
| Town | 5,000–9,999 | 75+ dwellings or over 5% population growth |
| Large Town / Urban | 10,000+ | 100+ dwellings or over 3% population growth |
These guidelines reflect the principle that what is “major” depends on local scale — and that even modest proposals can pose serious impact in small or sensitive locations.
📘 Population growth should be measured over a rolling 10-year period, comparing historic figures (Census or ONS) to current or post-development totals.
|Growth percentages should be calculated using a rolling 10-year baseline, comparing Census or official mid-year population estimates against post-development projections. This ensures consistency with Local Plan methodologies and national planning practice.|
🔧 C. Operational Safeguards and Screening Integrity
To ensure decisions are fair, evidence-based, and transparent, EHDC will apply the following safeguards during EIA screening:
1. 📇 Accountability and Traceability
- Every EIA screening opinion must include the officer’s name or ID, department, and planning reference number.
- A contact email must be provided so the public can submit questions or complaints.
2. 📊 Numerical Evidence from Consultees
- Consultees (e.g. NHS, Natural England, Southern Water) must provide quantitative data, such as:
- Patient capacity
- Sewer load
- School places
- Generic “no objection” responses without data will be considered insufficient.
3. 🗣️ Public Transparency and Consultation
- Where EHDC determines that EIA is not required for a large, cumulative, or sensitive project, it must:
- Publish a draft opinion
- Hold a 14-day public consultation
- Public feedback must be:
- Categorised as:
- ❌ Unsubstantiated – no clear evidence
- ⚠️ Accepted risk – noted, not escalated
- ✅ Actioned – accepted and addressed
- Summarised and published in the final screening opinion
- Categorised as:
✅ Final Summary
This updated screening policy:
- Protects local services by accounting for real cumulative growth
- Uses Local Plan logic to trigger proper scrutiny
- Ensures that both small villages and fast-growing towns get the oversight they need
- Brings accountability and transparency into every EIA decision
It’s not about blocking development. It’s about getting it right — legally, environmentally, and fairly.
🔍 Final Summary
This EIA Screening Framework ensures that:
- 📚 EHDC follows its Local Plan without overlooking environmental risk,
- 🚨 Growth that is too fast or too concentrated is caught early,
- 🏘️ Settlements of all sizes are treated fairly and proportionately,
- 🔍 And service-based impacts — like GP or school overload — are not missed just because they cross an invisible line on a map.
This is about using real-world logic, not bureaucratic boundaries, to ensure sustainable, transparent, and responsible planning in East Hampshire.
✍️ Component Delivery Framework – A structured summary for EHDC adoption and rollout
| Component | Environmental Impact Assessment (EIA) Strengthening |
| What It Delivers | A consistent, transparent, and legally robust framework for cumulative-aware EIA screening. It ensures that clustered or sustained development is not allowed to bypass environmental scrutiny. |
| Function | Introduces mandatory cumulative development checks, population and housing thresholds, sensitive settlement triggers, consultee data requirements, and public consultation processes during EIA screening. |
| Legal Basis | – Town and Country Planning (EIA) Regulations 2017 – National Planning Policy Framework (Paragraphs 180–183) – Planning and Compulsory Purchase Act 2004 (local thresholds and guidance) |
| Completion Criteria | – Live Cumulative Development Tracker published – Publicly available screening opinions with officer details and email contact – Threshold-based triggers and sensitive zone flags operational – Local Validation Checklist and decision templates updated – Screening & Sensitivity Map launched – Case officers trained |
| How to Implement | 1. Develop a cumulative development tracker by postcode and settlement 2. Define population and housing growth thresholds by settlement size 3. Designate sensitive settlements based on environmental and infrastructure data 4. Update validation requirements and officer templates 5. Create internal protocols for numeric consultee responses 6. Publish draft screening opinions for public comment where needed 7. Embed all components in EHDC guidance and training |
| Timeline | Policy drafting and approval process: 4–6 weeks System and tracker development: 6–8 weeks Template and guidance updates: 2–3 weeks Training and rollout: 3–4 weeks Total estimated time to full implementation: 12–18 weeks from approval |
| Owner | EHDC Planning Policy & Development Management Teams (joint lead), supported by Legal and GIS/Data teams |