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The Commonwealth of Australia, Victoria, Western Australia and New Zealand have some legal provisions, of a permissive nature, relating to SEA within their ELA requirements. Despite this, and a recent growth in interest in such provisions, very few SEA reports have been submitted to date. Victoria (on one occasion), New Zealand (on one occasion) and Western Australia (on two or three occasions) have required and assessed SEA reports. Experience in these four jurisdictions suggests that SEA will rarely be undertaken where the environmental authority can evaluate the activities of other, frequently more powerful, government departments only by invitation. For SEA to be undertaken, it appears that there needs to exist a specific requirement upon the proponent and an environmental authority with the power to ensure compliance.

This paper describes the Polish requirements for environmental impact assessment (EIA) and discusses procedures and practice in relation to screening, scoping environmental impact statement (EIS) preparation, EIS review, decision-making and monitoring. It is concluded that there is little information available about EIA practice in Poland, that there are confusions of nomenclature, that developers have insufficient choice of consultant, that EIA consultants often prepare weak EISs, that delays in reviewing EISs are common and that public participation is unsatisfactory. A number of reforms are planned which should lead to real improvement in EIA practice and meet the requirements of the European Directive.

Environmental assessment became mandatory in the UK under a European directive in July 1988; between then and the end of December 1990, 472 environmental statements (ESs) are known to have been submitted to competent authorities by developers. The distribution of ESs by type of regulation under which they were submitted, and by type of project for which they were prepared, is examined. The numbers and types of developers and consultancies involved in preparing, and the numbers of competent authorities involved in reviewing, a 50% sample of 236 ESs are analysed. The length and price of these 236 ESs are discussed, together with the content of 100 ESs known to have been submitted by July 1989. Recommendations relating to the listing, to the availability and to the content analysis, of ESs are made which are intended to assist in improving UK environmental assessment practice.