Professionals and Qualifications

Who can prepare an Environmental Statement

6 min readBy PlanScope Editorial Team

The 2017 Regulations put competence on the applicant. You must use competent experts and you must say who they are and what qualifies them.

The Town and Country Planning (Environmental Impact Assessment) Regulations 2017 answer this directly. Regulation 18 requires the Environmental Statement to be prepared by competent experts, and it requires the statement to be accompanied by a statement from the applicant setting out the relevant expertise or qualifications of those experts. The obligation sits on the applicant, not on the consultant.

That second half is the part people underplay. You are not only required to use competent people. You are required to say who they were and why they were competent, in a document the authority, the statutory consultees and any objector will read.

What the Regulations require, and what they leave open

The Regulations do not define competence, name qualifications or set up a register. There is no accreditation you can buy that satisfies regulation 18 on its own.

What they do is put the judgement in the open. The applicant asserts competence, the local planning authority forms its own view, and the authority then has to reach a reasoned conclusion on the likely significant effects of the development. An authority that cannot do that on the material supplied will ask for more, and on an EIA application with a sixteen-week determination period that request is expensive.

So competence is evidenced rather than certified. Three strands carry it: an academic or vocational qualification in the discipline, full or chartered membership of the institute that governs it, and project experience close enough to the one in hand that the method choices look practised.

Writing the statement of expertise

Keep it factual and specific. For each chapter, give the author's name, their role, their qualifications, their professional membership and grade, their years in the discipline, and one line on comparable work. Where survey work was subcontracted, name the surveyor and record the licence or accreditation that authorised it.

The version that fails is a page of company names and the phrase "with over 25 years of combined experience". That tells the officer nothing, and it invites a consultee to ask who actually wrote the ecology chapter.

Two details are worth building in. Say who peer-reviewed each chapter, if anyone did. And confirm that the author of each chapter is the person who signed off the method, because on large teams the modeller and the author are sometimes different people and consultees notice when the method reads as though nobody owned it.

Where you are commissioning this work, the brief is what determines whether you get named authorship at all. Our note on writing a brief for a specialist planning report sets out the clauses that matter.

Coordinator against topic specialist

An Environmental Statement is a set of topic assessments plus the connective work that makes them one document. Both need competence, of different kinds.

The topic specialists are governed by their own institutes and standards. Ecology sits with CIEEM and the assessment guidelines it publishes, with protected species survey and licensing restricted to suitably licensed ecologists under the Wildlife and Countryside Act 1981 and the Conservation of Habitats and Species Regulations 2017. Noise sits with the Institute of Acoustics and BS 4142:2014+A1:2019 or the relevant construction noise standard. Air quality sits with IAQM guidance. Transport sits with the highway authority's expectations and a transport planner who can defend a TRICS-based trip generation. Archaeology sits with CIfA standards, and choosing a suitable practice is covered in choosing an archaeologist and registered organisations. Landscape sits with GLVIA3.

The coordinator's competence is different. That person has to spot when the ecology chapter assumes a lighting design the lighting chapter has not adopted, when the transport chapter's construction traffic figures do not match the construction management plan, and when the cumulative assessment has quietly omitted a consented scheme next door. They also write the non-technical summary, which is the only part of the statement most councillors read.

A coordinator without topic depth can do the job. A coordinator who cannot read a noise model or a habitat condition assessment cannot.

Scoping is where the team gets fixed

Requesting a scoping opinion is optional, and on anything contested it is worth the time. The authority consults, and the opinion comes back naming the topics to be assessed, the methods expected and the consultees to engage.

That opinion determines the team. If the opinion asks for a water framework assessment, an ammonia deposition assessment or a whole life carbon chapter, you need someone competent in each before you can programme the work. Commissioning after the opinion lands is normal. Commissioning after the survey season closes is not, and bat emergence surveys running roughly May to September will hold a scheme for a year if the ecologist joins in October.

Independence matters as much as expertise once the assessment becomes contested, because a chapter written by the party with the commercial interest in the answer is easier to attack. The boundaries are set out in independence and conflicts of interest in planning evidence.

Review before submission, not after

A structured independent review of the draft statement earns its cost on any scheme where refusal would be expensive. The reviewer works through each chapter against a consistent set of criteria: is the baseline adequate, is the method stated and justified, are effects characterised consistently, is mitigation specific and securable, is residual significance reasoned rather than asserted.

What that catches, reliably, is inconsistency. Different significance vocabularies between chapters. Mitigation promised in one chapter and absent from the schedule. A non-technical summary that describes a scheme the drawings no longer show.

If you are picking up someone else's chapters, our note on reviewing a specialist report you did not commission covers what to check first.

Where authorities push back

Direct challenges to credentials are rare. What happens instead is a statutory consultee criticises the method, and the authority requests further information under the Regulations. Natural England on survey effort and seasonality. The Environment Agency on modelling assumptions. The lead local flood authority on drainage calculations. The county archaeologist on evaluation coverage.

Each of those requests is, in substance, a competence point, and each stops the clock. The defence is a method that was agreed at scoping, an author who can explain the departures, and a paper trail showing the survey effort matched the published standard.

Assembling the team early

Screening and scoping come first, then the team, then the surveys, then the chapters, then the review. Compressing that order is where programmes fail.

For a developer scoping the cost, the practical sequence is: take a screening opinion so you know whether you are in EIA territory at all, request a scoping opinion, appoint a coordinator with authority over the topic consultants, and hold back a review budget of a few per cent of the assessment cost.

PlanScope can draft Environmental Impact Assessment material as a structured starting point, and the EIA Regulations 2017 require the Environmental Statement itself to be prepared by competent experts, so treat a draft as something for that team to build on rather than a substitute for it. Reviewers who can check and sign off drafted material can be found through the professional directory. For specialist technical reports, qualified professional input may be required.

This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.

Frequently asked questions

Is there a register of people qualified to prepare an Environmental Statement?

No statutory register exists. Competence is demonstrated through qualifications, chartered or full membership of the relevant institute, and directly comparable project experience. IEMA publishes competency frameworks for impact assessment practitioners, and the topic institutes accredit specialists in ecology, acoustics, air quality, transport, archaeology and landscape. The local planning authority forms its own view on what it is given.

Can a planning consultant coordinate an Environmental Statement without topic expertise?

Coordination is a discipline in its own right and a planner can hold it, provided each topic chapter is authored by someone competent in that topic. What a coordinator must be able to do is test the chapters against each other, handle inter-relationships and cumulative effects, and write a non-technical summary that reflects the assessment rather than the ambition.

What happens if the council doubts the competence of an author?

It can request further information, ask for the chapter to be reworked or reviewed, or in a weak case decline to accept that it has enough to reach a reasoned conclusion. That stops the clock on a sixteen-week determination period. In practice the challenge usually arrives through a statutory consultee criticising method rather than as a direct challenge to credentials.

Does PlanScope produce an Environmental Statement?

PlanScope can draft Environmental Impact Assessment material as a structured starting point, but the EIA Regulations 2017 require the Environmental Statement to be prepared by competent experts. A draft is something for that expert team to build on, check and take responsibility for. It is not a substitute for the surveys, the modelling or the professional judgement.

Should the statement of expertise name individuals or companies?

Name individuals, with their role, qualifications, professional membership and the chapters they authored, and identify the firm each belongs to. A list of company logos tells the authority nothing about who did the work. Where a chapter relies on subcontracted survey work, say so and record the surveyor's licence or accreditation.

Sources and further reading

environmental impact assessmentcompetenceeia regulationsprofessionalsdeveloper

This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.

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