*4.3. Primary Research Findings*

The research through questionnaires has the objective of enriching the findings of the study. Half of the participants stated that they encountered difficulties in the composition of SEIA, the most commonly encountered of which were the following:


In the composition of a SEIA, the most common criterion in the selection of methods and techniques is the "sector of the plan or program", followed by the "availability of qualitative or quantitative data". The "availability of financial resources" is an equally crucial factor. By contrast, factors of lesser significance are the "study completion timeframe" and "type of decision", while the professional experience of the involved practitioner was a frequent, albeit not decisive, factor in the selection of methods and techniques. Finally, the criteria "scale of implementation of the plan or program" and "availability of human resources" were subject to the most significant divergence of opinions among the participants.

The majority of participants stated that the methods and techniques utilized during the composition of SEIA were appropriate for their purpose. In other words, they were in a position to treat the basic issues which occurred, and were also suited to the decision-making process. Subsequently, the participants considered that the utilized methods and techniques offered adequate alternative choices and effective measures in order to mitigate any negative environmental impacts, while at the same time allowing for the effective comparison between alternative choices. Simultaneously, according to the majority of the participants, the methods and techniques facilitated the incorporation of various substantive environmental aspects. However, there was a number of observations among the participants regarding the shortcomings in their implementation. The majority of the participants believe that the utilized methods and techniques do not allow the effective treatment of uncertainties, are not transparent and relevant to the stated objective, are not comprehensible to all those involved in the SEA process, and finally, are not cost-effective. Finally, the vast majority of participants believe that the utilized methods and techniques contribute to time-consuming processes, resulting in their exclusion from the decision-making timeframe.

As for the existence and utilization of guidance manuals for the selection of methods and techniques during the composition of SEIA, half of the participants consider that these manuals exist, and use them. The remainder of the participants reported that no such manuals exist, at either the national or the European level, as the only guidance comes from the corresponding legislative documents. The guidance manuals used by the participants are documented in Table 8.


**Table 8.** Guidance manuals for the selection of methods and techniques in the composition of SEIA.

However, none of the aforementioned documents propose the use of the most effective methods and techniques during SEA procedures. Certain documents, such as the "Handbook on SEA for Cohesion Policy 2007–2013" and the "Sourcebook on SEA of transport infrastructure plans and programmes", offer a more generalized and adaptable methodological approach for the SEIA guidance of particular types of plans and programs, in order for these to conform to the SEA Directive. Furthermore, documents such as the "Study concerning the preparation of the report on the application and effectiveness of the SEA Directive" and "The Relationship between the EIA and SEA Directives", are meant to offer information to the European Commission regarding the progress of the EU member states in the implementation of the SEA Directive, as well as to emphasize the points at which the SEA and EIA Directives overlap. In other words, the aforementioned documents are exclusively studies for the preparation of reports of the European Commission regarding the implementation and efficacy of the SEA Directive.

The results of the study show the inadequacy of the current methodological guidance for the composition of SEIA by the competent authorities in Greece. The lack of methodological guidance from the competent authorities is, according to the participants of the survey, due to the following reasons:


Based on these findings, the suggested means of improving the current methodological guidance are the following:


The participants in the survey were given a list (table) with the most frequent methods/techniques referred to in the literature, and were asked to indicate those that they know and those they use during the SEA process. The results are shown in Table 9.

One evident observation is that the majority of the participants were aware of almost the entirety of the SEA methods and techniques. A notable exception was those under the heading "Others", suggested by two of the participants. Asked why they did not utilize all the methods of which they were aware, the participants offered the following answers:


These reasons correlate with the previous analysis regarding the difficulties faced by practitioners during the composition of SEIA (inadequacy of the current institutional framework, lack of methodological guidance, limited available financial resources).

The analysis of the implemented methods and techniques arrived at equally useful conclusions. Table 9 demonstrates that the majority of the participants only implement 11 of the methods and techniques. The possibility of their utilization, according to the level and scale of implementation, the quality and type of utilized data, as well as the necessary resources for their conclusion, are depicted in Table 10.

According to the above table, the implemented methods and techniques are notably convenient, as, in their majority, they can be applied, either in part or entirely, at all levels and scales of the plans and programs, irrespective of the quality of the utilized data and the necessary resources. Furthermore, most of these methods and techniques, with the exceptions of the GIS and cost-benefit analysis, contribute to simple and expedient processes, do not require specialized equipment, have a limited implementation cost, and can be applied during most of the SEIA steps. A further point of interest is the widespread utilization of the cost-benefit analysis, as it compares the benefits and costs of a

program based on its monetary worth. However, the composition of SEIA also includes the assessment and evaluation of environmental and social objectives, which are difficult to evaluate by monetary worth. Finally, this particular technique is a time-consuming and costly process, which requires large volumes of data, and is limited to programs and projects, rather than policies and plans.


**Table 9.** Methods and techniques known and used by the participants.

+++ identified by 50% or more of participants, ++ identified by 26–49% of participants, + identified by 25% or less of participants.

**Table 10.** Methods and techniques implemented by the majority of the participants.


++ = fully, + = partly, (blank) = not.

Table 11 demonstrates the methods/techniques which the participants implement during the composition of SEIA, by step. *GIS* were the most popular technique, as they were utilized by all of the participants, with the majority thereof utilizing them during the steps of alternative choices, description of the current situation, and assessment and evaluation of impacts. Accordingly, the expert judgment was implemented by the majority of the participants during the steps of prevention, mitigation, and treatment of impacts. The techniques of indicators and literature/case review are particularly noteworthy for their universal application, the former during the monitoring of environmental impacts, and the latter during the description of the current situation. Finally, the matrices and the multi-criteria analysis were equally utilized in the corresponding steps, the most notable of which was the assessment and evaluation of the impacts, where they were utilized by the majority of the participants.

The variation in the number of methods and techniques utilized at each separate SEA step is of particular note. During the monitoring of environmental impacts, almost all the participants utilized indicators in combination with others, such as expert judgment, GIS, etc. Correspondingly, during the description of the current situation, literature/case review, in addition to GIS, was the favored choice of all the participants. The most noteworthy step, however, was that of the assessment and evaluation of impacts, during which the majority of participants utilized GIS, matrices and multi-criteria analysis, in combination with a number of other methods and techniques, such as cost-benefit analysis, checklists, etc.

The next conclusion which can be drawn from Table 11 is that the entirety of the methods and techniques were applied by the participants in the majority of the various SEIA steps. However, it is troubling that certain, particular methods and techniques were utilized by the participants during the step of the general data. We must keep in mind that this is the initial step in the study, which contains broad references to the plan or program under evaluation, the initiation of planning of the plan or program, as well as the practitioner responsible for composing the SEIA. In essence, this step does not require a defined methodology for its completion.

The entirety of the previously presented methods and techniques contribute to composite processes, and require trained, experienced personnel to carry them out; their ineffective implementation may result in erroneous decisions. The aforementioned considerations highlight certain issues regarding the actual, substantive understanding of the utilized methods and techniques by all those involved in SEA processes, and their effective application at each step.

Finally, the study recorded the participants' opinions on whether SEA is an effective process for the achievement of the objectives set in place by environmental legislation. According to the majority of the participants, SEA is indeed an effective process, due to covering the insufficiencies of Greek environmental law regarding the assessment of environmental impacts at the "strategic" level, i.e., at a higher level than that of each individual project. However, in order for SEA to assume a substantive role during the early stage of planning, certain amendments must be made. It is telling that at this point, there is no consensus among the participants. Some of them support that, since the current methods and techniques were drawn from those used in EIA, the utilization of more "strategic" methods and techniques stands to mitigate the problem. The majority of participants, however, believe the current methods and techniques are adequate for the fulfillment of the objectives of SEA, although systematic methodological guidance is required for their more effective utilization, primarily during the processes of assessment, evaluation, treatment, and monitoring of environmental impacts.



+++filled by 50% or more of participants, ++ filled by 26–49% of participants, + filled by 25% or less of participants.

#### *Sustainability* **2020**, *12*, 3310

#### **5. Discussion and Conclusions**

Based on the findings of the preceding study, the Greek and international practices are comparatively evaluated, taking into account two aspects: Methodological guidance for the composition of SEA, and applied methods and techniques. Subsequently, the conclusions of the primary research regarding both the effectiveness of SEA in Greece and the utilization of methods and techniques will be stated, and certain proposals will be suggested for the elimination of recorded anomalies.

The examination of the methodological guidance for the composition of SEA yielded common results in both international and Greek practice. In particular, the study of representative examples from both Greece and abroad demonstrated that in only half of the examined cases there was a clear reference to the utilized guidance documents, while primary research revealed that only half of the participating practitioners were aware of, and utilized, guidance manuals.

Furthermore, it was found that certain guidance manuals were utilized with greater frequency by the practitioners. At the international level, for which we have detailed information only of those applied in the United Kingdom and Ireland, the "A practical guide to the Strategic Environmental Assessment Directive" is by far the most popular guide. Correspondingly, in Greece, the "Handbook on SEA for Cohesion Policy 2007–2013", is universally applied, while "A practical guide to the Strategic Environmental Assessment Directive" and "Sourcebook on SEA of transport infrastructure plans and programmes" were also regularly consulted. A defining element of the methodological inadequacy in Greece is the lack of any domestic guidance manual, with the guidelines for the composition of SEA being determined by the provisions of JMD 107017/2006 and certain circulars that have been issued.

As was mentioned previously, the aforementioned guidance documents offer a general, flexible methodological approach for the guidance of SEA, with the objective of conforming to the SEA Directive. However, even though some of these documents offer instructions for each individual SEA step, they do not include exact, substantive methodological guidance for the comprehension and selection of the most appropriate methods and techniques for each individual SEA step. Additionally, it appears that certain documents, which were discovered in the international SEA practices (e.g., United Kingdom SEA), have been adapted to the requirements and demands of each state, precluding the possibility of their utilization by other EU member states.

As for the applied SEA methods and techniques, the study demonstrated that similar methods and techniques are utilized in practice, both internationally and in Greece, with their number being from 10 to 12. A number of factors influence the selection of particular methods and techniques by the practitioners of the states in which the SEA Directive has been transposed. First, the common legislative framework which governs the states, which adopts an EIA-like SEA approach, is a crucial factor, due to demanding particular methods and techniques. Similarly, the practitioners utilized specific guidance documents, which recommended a similar approach in the selection of methods and techniques, resulting in the utilization of comparable criteria, as these were established in the course of the primary research, for the selection of the most appropriate methods and techniques during SEA processes.

The majority of applied methods and techniques contribute to simple and expedited processes, process qualitative data, and can be implemented even in cases of inadequate or uncertain information, while, due to not requiring specialized equipment, they can be utilized even when financial resources are limited (with expert judgment, matrices, literature/case review, indicators as notable examples). Of the quantitative methods and techniques, GIS was most widely used in the production of maps and composite diagrams.

There are also evident similarities in the variation of the number of utilized methods and techniques at each individual SEA step. The steps of assessment and evaluation of impacts, and of alternative, saw the use of the widest variety of methods and techniques of those documented in the selected case studies, with the majority of both Greek and European practitioners utilizing risk assessment matrices of primarily table form, in combination with the other methods and techniques. By contrast, the fewest methods and techniques were utilized during the step of monitoring of environmental impacts, with the universal utilization of environmental indicators.

To sum up the findings of the primary study, Greek practitioners encounter significant difficulties during SEA processes, the most important of which have to do with: (a) Incomprehensible, incomplete legislation, (b) difficulties in the determination and categorization of the types of intervention of the plan or program under examination, (c) difficulties in the collection of sufficient and reliable data, (d) insufficient definition of alternative by the practitioners in charge of drafting the plan documents, and (e) lack of cooperation and guidance by the competent authorities.

The current methodological guidance has been deemed inadequate. This particular shortcoming is observable primarily in the lack of a specialized institutional framework for SEA methodology and the lack of trained personnel at the competent authorities. This results in, on the one hand, comments being expressed by the latter being limited to the comprehensiveness of the submitted SEIA file, and on the other the methodology being specialized on the initiative of the practitioners themselves, in order to cover the requirements of the JMD 107017/2006.

Despite the applied methods and techniques being considered appropriate for their objective, the lack of methodological guidance and the selection criteria for the SEA methods and techniques which the practitioners themselves set in place, as they were presented in Section 4.3, result in the selection of methods and techniques which cannot treat uncertainties, are characterized by a lack of transparency, and are not always relevant to the stated objective, while also being incomprehensible to all those involved in the SEA, and lacking cost-effectiveness. The preference for qualitative rather than quantitative methods and techniques is correlated, on the one hand, with the immaturity of the plans and programs, and on the other, with the complexity of the quantitative methods, which, as a rule, contribute to more time-consuming processes, and require the processing of large volumes of data by specialized personnel utilizing specialized equipment.

The more than ten years of experience from the introduction of the SEA Directive into Greek environmental law demonstrate the coverage of a significant deficiency regarding the assessment of environmental impacts during the early planning stage of plans and programs. Despite the fact that SEA has been recognized by the majority of the Greek practitioners who participated in the study as an effective environmental process, the extent to which this particular process has contributed to the goal of sustainable development remains a controversial issue. The ambiguity which, due exactly to its "strategic" nature, characterizes SEA, the current legislation, which, by contrast, requires the adherence to processes based on the corresponding practices of EIA, and the lack of methodological guidance, constitute a tripartite obstacle practitioners have not been able to bypass with the application of the current methods and techniques.

In order to mitigate existing anomalies, crucial changes must be made. These must be immediately applicable, without requiring complex, time-consuming and, primarily, bureaucratic procedures. Within this framework, our suggestion is the determination of technical specifications for the SEA process by sector for plans or programs, in addition to the writing of guidance manuals by sector for plans or programs, as extensions of the technical specifications of the corresponding sector. Furthermore, we propose the writing of a manual of indicators for the recording and monitoring of environmental impacts from the implementation of the plans or programs, by sector and type of plan or program, in addition to training courses for the personnel of the authorities responsible for the planning of plans and programs and the general monitoring and approval of environmental reports and practitioners, in the implementation of the most appropriate methods and techniques during SEA processes. Finally, we propose the broader utilization of participatory methods, such as the citizens' jury, during the step of evaluation of alternative of the plan or program.

**Author Contributions:** Conceptualization, A.T.; methodology, A.T. and A.S.; research conduction, data collection and analysis, visualization, A.S.; research supervision, A.T.; writing, review & editing of the paper, A.S. and A.T. All authors have read and agreed to the published version of the manuscript.

**Funding:** This research received no external funding.

**Conflicts of Interest:** The authors declare no conflict of interest.
