254 Environmental Impact Analysis
programmatic EISs have the potential to develop a successful SEA approach,
and the application of SEA can benet from experience and supportive case
law of successful programmatic and tiered EISs. The European Union has man-
dated an established general protocol for SEA and requires member countries
to develop guidelines and specic requirements. Japan and several other Asian
governments have also developed SEA procedures, and in southern Africa
there is some progress in this area (Sadler et al. 2011). However, developing
frameworks is one thing and demonstrating progress by implementation is
another matter. SEA has experienced constrained and limited progress due
largely to the lack of tested guid ...