Stakeholder Engagement

Purpose

This Policy Position Statement reviews the current situation relating to stakeholder engagement¹ in environmental decision-making and outlines the areas where further action is needed.

CIWEM considers that all public, private and voluntary organisations preparing policies, plans, programmes, and projects relating to the environment should:

1. Develop and implement policies for stakeholder engagement which recognise that this will:
   • Help in finding solutions with a better long-term outcome for the environment and stakeholders
   • Reduce objections to projects
   • Foster local pride and a sense of ownership among stakeholders
   • In the long term enhance the understanding of environmental issues by the public and help to deliver more sustainable outcomes.
2. Promote stakeholder engagement in their projects, plans and policies
3. Share knowledge to identify and promote good practice to the benefit of all interests
4. Consider the need for stakeholder engagement at the inception of projects, plans and policies to ensure that managers buy-in to the process
5. Identify and map relevant stakeholders properly at an early stage to ensure 'no surprises' at later stages
6. Promote the economic, environmental and social benefits of stakeholder engagement to overcome poor awareness or suspicion
7. Demonstrate to stakeholders that engagement is credible by adopting approaches which involve open and honest dialogue, in contrast to 'tick in the box' exercises which persuade no-one
8. Demonstrate to stakeholders that engagement is worthwhile by reporting back transparently on how their views have been taken into account and explaining why particular decisions have been taken

Context

The 1992 UN Conference on Environment and Development, in Rio, originally raised the importance of public / stakeholder involvement in environmental decisions, and placed it on an official footing, both in Principle 10 of the Rio Declaration and Agenda 21 - the action plan for sustainable development.

The UNECE ('Aarhus') Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters was ratified by the EU and UK in 2005.  It establishes minimum standards for public participation in environmental decision-making, and for access to information and justice.  This includes participation in decisions relating to specific projects or activites, as well as programmes, plans and policies.  The projects covered include the granting of licences or permits for certain listed activities - similar to those requring an Environmental Impact Assessment (EIA), Strategic Environmental Assessment (SEA) or Integrated Pollution Prevention and Control (IPPC) licence - as well as other activities which may have a significant environmental impact.

The requirements of the Convention for public participation in projects include²:

• timely and effective notification of the public concerned;
• reasonable timeframes for participation, including provision for participation at an early stage;
• unconstrained scope and range of matters for consideration
• a right for the public concerned to inspect information which is relevant to the decision-making free of charge;
• an obligation on the decision-making body to take due account of the outcome of the public participation; and
• prompt public notification of the decision, with the text of the decision and the reasons and considerations on which it is based being made publicly accessible.

Within these requirements, 'the public concerned' includes those who are affected, likely to be affected, or interested in the decision-making, and explicitly includes non-Governmental organisations (NGOs).

The requirements of the Convention in relation to the preparation of plans or programmes, activities with significant environmental implications, and policies affecting the environment, are less prescriptive than those relating to projects.  However, timescales for participation must still be reasonable, opportunity for early participation must exist and due account must be taken of the outcome of the participation.

The Public Participation Directive implements the Aarhus Convention in the EU.  It amends Directives relating to EIA, IPPC, air quality, nitrate pollution, waste, hazardous waste, packaging and batteries.

The EU Water Framework Directive (WFD) also places emphasises public participation.  In England the Environment Agency, as the authority responsible for implementing the WFD, is required to consult with stakeholders throughout the process, and encourage active involvement of stakeholders.  As well as developing a prototype River Basin Management Plan and Programme of Measures, the Ribble Basin Pilot Project demonstrated how public participation within the river basin planning process could take place.

The 2001 Directive on Strategic Environmental Assessment (SEA) required citizens to be afforded more influence on decisions affecting their environment.  Under this Directive, the environmental effects of a wide range of public plans and programmes must be assessed under better and more open planning procedures.

Driven by a number of high-level policy drivers greater public participation is being advocated and used in all strategic, national and increasingly local development and planning issues.

Key Issues

There is a desire for more accountable decision-making
The 1992 Rio Earth Summit emphasised the importance of involving the public more in decision-making.  Progress on this since has been slow but steady and over recent years there has been a boom in public consultation on plans, strategies and proposals, particularly those produced by public bodies.  Accountability in decision-making has grown from a desire for transparency from interested parties, and a greater desire for involvement from decision-makers who are aware of greater scrutiny and wish to overcome or minimise risks to their process/plan/policy etc.  In many situations, there are no simple solutions; it is rare to have full consensus from the start.  However, the process of engaging stakeholders from the beginning at least demonstrates that all views have been given detailed and fair consideration in reaching a final decision.  As a result, these decisions are likely to have greater acceptance and/or support in the long term.

Identification of Stakeholders

For stakeholder engagement to deliver positive benefits it must be included as an integral aspect of the development and delivery of a plan, project or policy.  Full support for the process by upper management is important otherwise benefits may be compromised down the line.   Once approval for the proposed project has been secured, it is essential to ensure that there is established a clear set of objectives for the engagement activity to come.  The existence of such objectives will facilitate correct identification / mapping of the likely stakeholders.

Stakeholders will be individuals or organisations who are most likely to be affected by, or concerned with the initiative and are likely to include the public, statutory, local and national interest groups, local communities and NGOs.  Care must be taken to ensure that the weight given to stakeholder views is representative to the level of support conveyed by an organisation or group.  For example, the most vocal stakeholder group with the most effective lobbying techniques may not necessarily be the most representative of the community likely to be affected.  Care should also be taken to ensure that all groups concerned, including black, ethnic and minority groups are involved.

Early engagement is essential

Stakeholder engagement aims to minimise risks and expose opportunities available by ensuring that all who need or wish to know about an issue can do so, early. The importance of initiating the engagement process at an early stage cannot be overstated.  For the optimum effectiveness of engagement, the process should be initiated before proposals have begun to be developed, planning permissions submitted or strategic plans put into place, etc.  Bringing together all relevant viewpoints at the earliest opportunity is more likely to ensure that all potential concerns are identified, data requirements and information sources are identified early and that people's values, concerns and interests are built into the development of plans and projects from the point of inception.  Problems are far more likely to occur when people are engaged later in the process when wheels have already been set in motion, and they raise objections to what is being proposed or, worse, starting to be implemented.

There is a range of participatory techniques

Different participatory approaches and techniques are needed to engage the public (comprising a collective of individuals) and organisations (which may include public groups), and techniques should be chosen (and tailored) according to the purpose of the engagement, the audience and the desired outcomes.

Common modes of engagement are the production of information (e.g. newsletters and reports), consultation (via consultation documents and questionnaires) and more active involvement (e.g. workshops and drop-in sessions which must be well advertised and promoted).  Good practice is to undertake a number of these to meet the widest range of needs and expectations.

Provision of good quality background information regarding the proposals is essential to ensure good levels of understanding amongst respondents.  Questionnaires must be well designed so that they obtain information which will ensure balanced and reliable information on the issues which most require consideration. Consultations must be well distributed - web-based consultations may only reach a certain proportion of the target audience.  The consultation exercise undertaken in relation to the construction of the M6 Toll Road in the West Midlands was seen as a model of consultation.

Engaging with the public requires specific skills

There are specific skills associated with getting the best results from stakeholder engagement initiatives, and there is a need for training in, and wider awareness of, these.  Currently, few resources are targeted at optimising such expertise, although a number of consultancies specialise in conducting skakeholder engagement for clients.  It is important to recognise that, if stakeholder engagement is not undertaken correctly, it may result in greater risks than if it was not undertaken at all.  For this reason, it is important that facilitators have the necessary skills to get the most out of the process.

Analysis and Implementation of Consultation Outputs

Once views have been sought it is important that this resource is properly analysed. It is also essential to demonstrate to stakeholders that their views have been taken into account. An auditable trail of how issues and concerns that stakeholders raised have influenced or changed decisions or plans, and how problems will be mitigated must be established.

Where issues and concerns are rejected, the reason for the rejection must be objective and qualified. In such instances, it is essential that transparency is demonstrated as to why such change is not possible. Transparency throughout the process is always important, but this will be felt particularly in such circumstances if suspicion is to be minimised and trust levels maximised. It is likely that the process will involve a compromise and it is essential to demonstrate how and why this compromise has come about.

There is a need for good practice information

There are various sources of guidance on how to undertake stakeholder engagement and/or public participation as part of the development of plans or the delivery of projects, but much is still being learned through experience. It is therefore important that best practice is disseminated and experience shared. The think tank AccountAbility has recently drafted a standard setting out best practice guidance³ providing advice on design and implementation of stakeholder engagement, as well as evaluation and communication of results. Other guidance has also been produced by IEMA⁴, INVOLVE⁵ , Defra⁶ and DFID⁷ for example.

Ongoing engagement is valuable

Once the main phase of engagement has been undertaken there is likely to be a temptation to get on with the project and minimise any further interaction with stakeholders and/or the public. However it is import to maintain a good level of engagement throughout the lifetime of a project. The maintenance, for example, of local liaison groups around facilities have been shown over recent years to be valuable in ensuring continuing levels of engagement leading to better understanding of and support for different perspectives. They also help to ensure that problems or concerns that arise are dealt with promptly and efficiently.  When designing a project plan, there should be an associated engagement plan showing key points in the process where stakeholder engagement can add value, including ongoing loops of engagement and feedback.

Stakeholder fatigue

Whilst stakeholder engagement is important and worthy, it must be undertaken in a way which minimises stakeholder fatigue. With a growing number of issues being the subject of public consultations, stakeholder fatigue is a real concern.  This places greater importance on good delivery of concise and accurate information regarding projects and why they should be of interest to the stakeholder. It must be remembered that it is in the interest of the body putting forward the plans to exploit the benefits of stakeholder engagement, i.e. the prevention of unexpected objections later in the planning process and to gain trust and support, and a lack of responses by stakeholders will reduce such benefits. There is a risk that a false sense of support and acceptance could result. Demonstration that participation was worthwhile is important in preventing fatigue.

Conclusions

CIWEM welcomes the move towards wider stakeholder engagement for to plans or projects relating to the environment.  This process is a legitimate method to facilitate accountability and sustainability of decision-making and in the longer term will help to foster wider understanding of environmental issues and trust of responsible organisations operating in the environment by stakeholders. It will, if properly delivered, also ensure that bodies consider the wider implications of their activities and demonstrate transparency in their actions, support better relationships and communication between organisations and individuals involved, and enable decision-makers to consider the wider implications of their activities and minimise risks to their processes. For these reasons it should be established as an integral part of a project, plan or process.

Stakeholder engagement is gaining wider acceptance and is now supported by a range of legislation. Nevertheless, there may remain a tendency amongst some to regard it as a 'bolt-on' in order to comply with regulations, rather than an integral component of the planning and delivery of an initiative. There is also the possibility for significant sums of money to be spent on stakeholder engagement, with little return if the process is not well designed. It is therefore important that those engaging stakeholders get it right, otherwise significant administrative burden may result.  For this reason, the various sets of available guidance are welcomed, and it is important that organisations share best practice and promote awareness of the benefits of the approach.

References

1. "Any organisation, government entity, or individual that has a stake in or may be impacted by a given approach to environmental regulation….etc" http://www.entrix.com/resources/glossary.aspx
2. UNECE: Aarhus Convention http://www.unece.org/env/pp/
3. AccountAbility: Stakeholder Engagement Standard - exposure draft, 2005  http://www.accountability.org.uk/uploadstore/cms/docs/SES%20Exposure%20Draft%20dtv.pdf
4. IEMA: Participation in environmental decision-making, 2002.
5. Involve: People and Participation: how to put citizens at the heart of decision-making, 2005. http://www.involving.org/mt/archives/blog_13/People%20and%20Participation%20final.pdf
6. Defra: Making Space for Water: Developing a New Government Strategy for Flood & Coastal Erosion Risk Management: The Principles of Stakeholder Engagement and Consultation in Flood and Coastal Erosion Risk Management,2004.  http://www.defra.gov.uk/environ/fcd/policy/strategy/stakeng.htm
7. DFID Sustainable Livelihoods Guidance Sheets, 2006. http://www.livelihoods.org/info/info_guidancesheets.html#1

August 2006

Note: CIWEM Policy Position Statements (PPS) represents the Institution's views on issues at a particular point in time.  It is accepted that situations change as research provides new evidence.  It should be understood, therefore, that CIWEM PPS's are under constant review, that previously held views may alter and lead to revised PPS's.