Gloucestershire Local Transport Plan Review

Integrated Sustainability Appraisal Report

Gloucestershire County Council

November 2019

Gloucestershire Local Transport Plan Review Integrated Sustainability Appraisal Report

Notice

This document and its contents have been prepared and are intended solely for Gloucestershire County Council’s information and use in relation to the Integrated Sustainability Appraisal of the Local Transport Plan Review.

Atkins Limited assumes no responsibility to any other party in respect of or arising out of or in connection with this document and/or its contents.

Document history

Job number: 5189457 Document ref: Revision Purpose description Originated Checked Reviewed Authorised Date V1.0 Draft for Comment ISA Team PMcE CW CW 22/10/19 V2.0 Final Issue ISA Team PMcE CW CW 07/11/19

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Client Gloucestershire County Council

Project Gloucestershire Local Transport Plan Review ISA

Document title Integrated Sustainability Appraisal Report

Job no. 5189457 Copy no.

Document reference

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Gloucestershire Local Transport Plan Review Integrated Sustainability Appraisal Report

Table of contents

Chapter Pages Non-technical Summary 7 The purpose of the ISA 7 Compatibility between LTP Objectives and ISA Objectives 8 Assessment of Strategic Alternatives 8 Assessment of the Revised Draft LTP 10 Mitigation 24 Cumulative, Synergistic and Indirect Effects 25 Monitoring 26 Next steps 27 Conclusions 27 1. Introduction 29 1.1. Purpose of this Report 29 1.2. The need for a Revised Local Transport Plan 29 1.3. Revised Draft LTP Overview 29 2. Approach to Integrated Sustainability Appraisal 32 2.1. Introduction 32 2.2. Sustainability Appraisal / Strategic Environmental Assessment 32 2.3. Health Impact Assessment (HIA) 32 2.4. Equality Impact Assessment (EqIA) 33 2.5. Community Safety Assessment (CSA) 33 2.6. Habitat Regulation Assessment (HRA) 33 2.7. Reporting and consultation as part of the ISA process 34 3. Scope of the Integrated Sustainability Appraisal 37 3.1. Introduction 37 3.2. Spatial Scope 37 3.3. Temporal Scope 38 3.4. Technical Scope 38 4. ISA Methodology 40 4.1. Introduction 40 4.2. Assessment Methodology 40 4.3. SA / SEA 43 4.4. HIA 46 4.5. EqIA 47 4.6. CSA 47 5. Review of Legislation and other Plans and Programmes 48 5.1. Introduction 48 5.2. Methodology 48 5.3. Recent relevant PPPs 51 6. Baseline Information and Key Sustainability Issues 53 6.1. Introduction 53 6.2. Methodology 53 6.3. Data Analysis 53 6.4. Data Limitations 54 6.5. Key sustainability baseline, issues and implications/ opportunities 55 6.6. EqIA and HIA Issues 81

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Gloucestershire Local Transport Plan Review Integrated Sustainability Appraisal Report

7. ISA Framework 87 7.1. Introduction 87 7.2. ISA Objectives and assessment aid questions 87 8. Compatibility between LTP Objectives and ISA Objectives 100 8.1. Introduction 100 8.2. LTP Review Objective 1: Support Sustainable Economic Growth 101 8.3. LTP Review Objective 2: Enable Community Connectivity 103 8.4. LTP Review Objective 3: Conserve the Environment 103 8.5. LTP Review Objective 4: Improve Community Health and Well-being 104 8.6. Conclusions 105 9. Assessment of Alternatives 107 9.1. Introduction 107 9.2. Defining the alternatives 107 9.3. Assessing the Alternatives 107 9.4. Alternatives assessment summary 108 10. Assessment of Revised Draft LTP Policy Proposals 110 10.1. Introduction 110 10.2. Assessment of Cross Cutting policies 113 10.3. Assessment of Themed Policies 120 11. Assessment of Revised Draft LTP Proposed Schemes 127 11.1. Introduction 127 11.2. Assessment of Schemes 136 11.3. Assessment of Scheme Delivery Proposals 140 11.4. Conclusions 141 12. Mitigation 142 12.1. Introduction 142 12.2. Mitigation approaches applied in the ISA 142 13. Cumulative, Synergistic and Indirect Effects 144 13.1. Introduction 144 13.2. Likely cumulative effects 144 14. Monitoring 150 14.1. Introduction 150 14.2. Current LTP monitoring arrangements 150 14.3. Proposed monitoring programme 150 15. Conclusions 156

Tables Table 2-1 Schedule of SEA Requirements 35 Table 4-1 Integration of the Assessment Process 41 Table 4-2 Criteria for Assessing Significance of Effects 44 Table 7-1 ISA Framework and of objectives and assessment aid questions 88 Table 7-2 EqIA Sub-Objectives 94 Table 7-3 HIA Sub-Objectives 97 Table 8-1 Initial compatibility assessment results 102 Table 8-2 Final compatibility assessment results 106 Table 9-1 Summary of findings of Assessment of Alternatives 108 Table 10-1 Draft Revised Draft LTP Policies (as at September 2019) 110 Table 10-2 Assessment of Draft Revised Draft LTP Cross Cutting Policies (as at September 2019) 113 Table 10-3 Recommendations arising out of Assessment of Draft Revised Draft LTP Cross Cutting Policies (as at September 2019) and how the considerations have been taken on board by GCC 116 Table 10-4 Assessment of Draft Revised Draft LTP Theme Policies (as at September 2019) 121

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Table 10-5 Recommendations arising out of Assessment of Draft Revised Draft LTP Theme Policies (as at September 2019) and how the considerations have been taken on board by GCC 123 Table 10-6 Assessment of Revised Draft LTP Theme Policies (as at October 2019) 125 Table 11-1 Schemes per type and per CPS area 128 Table 11-2 Assessment of Revised Draft LTP proposed schemes per type 137 Table 11-3 Overview of Recommended Mitigation for Proposed Schemes 138 Table 12-1 Mitigation approaches applied 142 Table 13-1 Anticipated cumulative, synergistic and indirect effects for Revised Draft LTP 144 Table 13-2 Potential Cumulative effects – Plans and Policies 147 Table 14-1 Proposed Monitoring Programme 151

Figures Figure 3-1 Geographical scope of the Plan...... 37

APPENDICES (separate volume)

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Gloucestershire Local Transport Plan Review Integrated Sustainability Appraisal Report

Abbreviations

AONB Area of Outstanding Natural Beauty AQMA Air Quality Management Area CSA Community Safety Assessment DCLG Department for Communities and Local Government DfT Department for Transport EqIA Equality Impact Assessment ER Environmental Report EV Electric Vehicle GCC Gloucestershire County Council GHG Greenhouse Gas GVA Gross Value Added HGV Heavy Goods Vehicle HIA Health Impact Assessment HRA Habitats Regulation Assessment ISA Integrated Sustainability Appraisal LTP Local Transport Plan NHS National Health Service NPPF National Planning Policy Framework ODPM Office of the Deputy Prime Minister PCG Protected Characteristic Group PPPs Plans, Policies and Programmes PRoW Public Right of Way pSPA Potential Special Protection Area RIGS Regional Importance Geological Sites SAC Special Area of Conservation cSAC Candidate Special Area of Conservation SEA Strategic Environmental Assessment SPA Special Protection Area SSSI Site of Special Scientific Interest SuDS Sustainable Drainage Systems TAG Transport Analysis Guidance WHS World Heritage Site

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Gloucestershire Local Transport Plan Review Integrated Sustainability Appraisal Report

Non-technical Summary

The purpose of the ISA

This is the Non-Technical Summary of the Integrated Sustainability Appraisal (ISA) Report of the Gloucestershire’s Local Transport Plan (LTP) Review. The purpose of this Non-technical Summary is to set out the ISA process and the outcomes derived from this and is intended to inform people who have a general interest in the Local Transport Plan Review, but who are not concerned with its detailed technical assessment. Readers are advised to read the full contents of the ISA Report for more detailed information if required.

Whilst it is important that the LTP Review delivers the vision for transport in Gloucestershire, it is also important that this is done is a way which protects the environment, protects the human health and allows as many different people as possible the same opportunities for accessing the facilities and services they require whilst promoting sustainable economic growth. Therefore, the Revised Draft LTP has been subjected to a series of assessments that cover the topics of Sustainability and Strategic Environmental Assessment (SA/SEA), Health Impact Assessment (HIA) and Equality Impact Assessment (EqIA) and Community Safety Assessment (CSA). It is also important to note that as there is a potential that the Revised Draft LTP could lead to a direct or indirect effect on sites which have been designated at the European level for nature conservation purposes (such as Special Areas of Conservation), a Habitats Regulation Assessment (HRA) was also carried out. Taken together these various assessments are described as an ‘Integrated Sustainability Appraisal’ (ISA).

An ISA Framework has been defined, consisting of a series of objectives, against which the sustainability performance of the Revised Draft LTP has been assessed. These ISA Objectives are: 1. Improve air quality 2. Reduce carbon dioxide (CO2) emissions from transport 3. Protect and enhance protected habitats, sites, species, valuable ecological networks and promote ecosystem resilience and functionality 4. Protect, enhance and promote geodiversity 5. Protect and enhance the character and quality of landscapes and townscapes and visual amenity. 6. Conserve and enhance heritage assets and the wider historic environment including buildings, structures, landscapes, townscapes and archaeological remains and their settings. 7. Protect and enhance the water environment 8. Conserve soil and agricultural resources and seek to remediate / avoid land contamination 9. Reduce risk of flooding and increase resilience of the transport network to the effects of a changing climate 10. Promote prudent use of finite natural resources from primary sources, maximise the use of alternative, secondary and recycled materials, reduce the level of waste generated 11. Reduce the need to travel, particularly by car or move goods by road, and promote sustainable modes of transport and patterns of movement 12. Promote economic growth and job creation, and improve access to jobs for all 13. Coordinate land use and transport planning across Gloucestershire 14. Promote greater equality of opportunity for all citizens, with the desired outcome of achieving a fairer society (EqIA specific objective) 15. Improve health and well-being for all citizens and reduce inequalities in health (HIA specific objective) 16. Promote community safety and reduce crime and fear of crime for all citizens (CSA specific objective)

In addition to the above ISA Objectives, a series of sub-objectives relating to HIA and EqIA have also been defined. These are:

HIA and EqIA  Improve accessibility to services, facilities and amenities for all, in particular by active travel modes

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 Improve affordability of transport  Improve road safety and reduce the number of accidents and other incidents  Reduce severance  Reduce air, noise and light pollution from transport

A series of questions to help aid the assessment and the interpretation of each Objective were also identified. These questions and the ISA Objectives together make up the ISA Framework against which the Revised Draft LTP was assessed.

Compatibility between LTP Objectives and ISA Objectives In the early stages of the development of the Revised Draft LTP, it was important to ensure that the four initial objectives of the Plan were well aligned with the ISA Objectives and therefore an assessment of their compatibility was carried out.

The results of the initial assessment of compatibility indicated that while there were several areas where there was a degree of compatibility between the two sets of objectives. Overall it was concluded that there was a considerable level of uncertainty / unclear outcomes as to how the Revised Draft LTP would perform in sustainability terms, with the potential for adverse effects likely due to the nature of the interventions derived from the Plan not being ruled out. It was therefore recommended that the LTP Objectives could be strengthened to ensure sustainability was more comprehensively established as set out below.

LTP Objectives Recommendations

Initial Revised Draft LTP Objective Recommended Revised Draft LTP Objective Support Sustainable Economic Growth No recommendations Enable Community Connectivity Enable Safe and Affordable Community Connectivity Conserve the Environment Protect and Enhance the Natural and Built Environment Improve Community Health and Well-being Improve Community Health and Well-being and Promote Equality of Opportunity

Following further development of the Revised Draft LTP and consideration of the ISA findings by GCC, the LTP objectives were changed to reflect the ISA recommendations. This substantially improved the degree of compatibility between the two sets of objectives, with only a very small number of areas of uncertainty and potential conflict remaining.

The main areas of uncertainty identified in the assessment, as well as areas of potential conflict, relate to the LTP Objective to ‘Support Sustainable Economic Growth’. This is not entirely surprising as probable interventions arising from implementation of this objective have the potential for both negative and positive sustainability outcomes. However, as the updated Revised Draft LTP now include three strengthened Objectives to ‘Protect and Enhance the Built and Natural Environment’, ‘Improve Community Health and Well-being and Promote Equality of Opportunity’ and ‘Enable Safe and Affordable Community Connectivity’, these enhanced ‘cross cutting’ Objectives should help to ensure that areas of uncertainty, or areas of potential conflict arising out of the implementation of the LTP objective to ‘Support Sustainable Economic Growth’, can be addressed as further implementation details are set out in the developing LTP. The three ‘cross cutting’ Objectives thus provide a strong imperative in the LTP for maximising sustainable outcomes.

The compatibility assessment therefore concluded that the updated Revised Draft LTP Objectives provide a firm underpinning to help ensure that the sustainability performance of the plan could be maximised.

Assessment of Strategic Alternatives Previously in Gloucestershire, a district-based approach to LTP delivery was undertaken, which focused on policies and interventions within individual existing administrative boundaries in Gloucestershire, notably the six districts and boroughs present in the county. For the purposes of the LTP 2015-2031 review, it was

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Gloucestershire Local Transport Plan Review Integrated Sustainability Appraisal Report considered that the district-based approach should be replaced by a ‘Link and Place’ approach. The ‘Link and Place’ approach differed from the previous district-based perspective through introducing travel-focused strategy areas based on connections. This approach advocates the consideration of roads and railways as movement conduits (links) through and to places, with the identification of travel corridors, each of which with distinctive transport opportunities and pressures, in an approach termed ‘Connecting Places Strategy (CPS). Six CPS areas have been identified in Gloucestershire: Central Severn Valley, Forest of Dean, North Cotswold, South Cotswold, Stroud and Tewkesbury.

As such, as part of the SEA undertaken to inform the development of Gloucestershire’s LTP 2015-20311, two strategic and reasonable alternatives were considered:

 Option 1: Continue the existing district-based perspective to the LTP3; and  Option 2: Deliver a Connecting Places Strategy approach.

These options were assessed using a SEA Framework of objectives and assessment questions developed in light of prevailing environmental issues and which was considered robust and appropriate at that time. The assessment found that Option 2 Deliver a Connecting Places Strategy approach was the most favoured approach in environmental sustainability terms and this option was taken forward in the preparation of LTP 2015-2031.

For the purposes of this current LTP review, the evidence base underpinning the ISA of the Revised Draft LTP has been updated and this has led to the development of a new, up to date, robust ISA Framework which contains a new set of ISA Objectives and a new series of assessment aid questions. As such, a review has been undertaken of the two strategic and reasonable alternatives examined previously, in the light of the new ISA Framework, to check that the previous assessment findings are still valid.

Summary of findings of Assessment of Alternatives

Alternatives ISA Objective 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Option 1: Continue the existing district-based 2 2 2 1 1 1 1 1 2 2 2 2 2 2 2 1 perspective to the LTP3 Option 2: Deliver a Connecting Places Strategy 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 approach

The focus of Option 2 on wider geographical areas sharing transport and socio-economic features means that this option is likely to perform better and be more sustainable across the range of ISA Objectives for which it was possible to make a differentiation. The wider geographical approach of Option 2 will allow a clear focus on the eight AQMA within Gloucestershire, as well as a focus for such innovations such as developing an EV infrastructure network and green infrastructure such as cycling and walking routes (ISA Objective 1), will allow better consideration of individual pinch points, or those areas considered for ‘major growth’ and which are likely to lead to increased carbon emissions (ISA Objective 2), will provide more opportunities for biodiversity net gains and green infrastructure improvements. It is recognised though, that many biodiversity impacts can only be addressed in light of knowledge of individual transport schemes (ISA Objective 3), will ensure better consideration of flood resilience of transport schemes and elsewhere (ISA Objective 9) and a more efficient use of resources (ISA Objective 10). In addition to the wider geographical approach of Option 2 benefitting a range of environmental issues, largely through more opportunities to deliver environmental benefits such as biodiversity net gains and flood resilience, compared to Option 1, Option 2 provides a clearer focus on where people live and where they want to travel and the corridors along which these movements take place. These corridors dictate the link type, e.g. national, primary or district links and Option 2 allows detailed consideration of each of these corridor links and the characteristics of it, alongside the environment and such issues as ambience and place. As such, Option 2 would provide clear benefits for ISA Objectives 11, 12, 13, 14 and 15. These benefits will be derived from Option 2 allowing a closer reflection of the relevant infrastructure needs and measures required in each of the areas rather than administrative boundaries. This will provide increased

1 Gloucestershire LTP 2015-2031 SEA Environmental Report, AECOM 2015

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Gloucestershire Local Transport Plan Review Integrated Sustainability Appraisal Report potential to promote accessibility to services, facilities and amenities by a range of transport modes and meet the needs of the various communities of Gloucestershire. In conclusion, it is considered that Option 2 ‘Deliver a Connecting Places Strategy’ approach remains the favoured alternative for the development of the Revised Draft LTP.

Assessment of the Revised Draft LTP Contained within the Revised Draft LTP are a series of policies which aim to ensure that the Vision and Objectives that have been set out are achieved. For the purposes of assessment, these policies have been assessed on an individual basis, in terms of those policies which are considered ‘cross cutting’ and as such apply across the whole of the Revised Draft LTP, or on a grouped ‘themed’ basis, in terms of those policies which are considered to be focused on and address key elements of transportation. The policies considered were:

Draft Revised Draft LTP Policies (as at September 2019)

Policy Type

Policy Policy Text

Cross Cutting PD0.1 Reducing Transport GCC will work with its partners to reduce transport carbon emissions and Policies Carbon Emissions improve air quality in the county by promoting the use of sustainable modes of transport and the uptake of low emission vehicles to tackle climate change

PD0.2 Local Environmental GCC will work with district councils and other partners to; improve air quality, Protection reduce levels of noise pollution and protect against biodiversity and geodiversity loss resulting from traffic or improvements on the highway network

PD0.3 Maximising Investment in GCC will work with partners to ensure the delivery of a financially sustainable a Sustainable Transport Network transport network by maximising opportunities for inward investment.

PD0.4 Integration with land use GCC will work with local planning authorities to make a positive contribution planning and new development towards a step change in sustainable land use planning and enable multi-modal transport opportunities with a clear priority towards sustainable travel choices. GCC will support planning authorities and require developers, through agreements and securing of planning obligations, to mitigate against the impacts of proposed new development on the transport network and transport infrastructure by requiring site master planning and making sure transport considerations are integral to the design of schemes and contribute to making high quality places.

PD0.5 Community Health & GCC will work with partners to improve community health and wellbeing and Wellbeing safety by encouraging and enabling greater numbers of people from all social and economic groups and including those with disabilities, to walk and cycle short distance trips; (e.g. by walking or cycling and using public transport) for short distance trips; helping children and adults, including families and those economically and physically disadvantaged, to enjoy more independent, physically active lifestyles; improving air quality; and connecting people to services, employment, education, health services, social and leisure amenities to allow equality of opportunity to health, social and economic wellbeing.

PD0.6 Thinktravel – Influencing GCC will continue to use the ‘Thinktravel’ brand and associated marketing and Travel Behaviour information tools, behaviour change methodologies and insights to ensure we carry out a range of travel awareness initiatives to understand and influence travel behaviour change and promote the benefits and use of sustainable modes of transport.

Large PD3.1 Gloucestershire’s Freight GCC in its role as Local Highway Authority will work in partnership with Infrastructure Network Highways England, neighbouring highway authorities, Network Rail, – Rail & Parish/Town/District Councils and the Police to maintain a functioning freight Highways network, by ensuring the safe and expeditious movement of goods vehicles using the highway, whilst working towards decarbonising road and rail freight by 2050.

PD3.3 Driver Facilities (Freight) GCC will support facilities for drivers to rest. These will be provided at suitable locations on or near the primary route corridors used by HGV traffic.

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PD3.2 Journey Routing GCC will work in partnership with Highways England, neighbouring highway Information for Freight authorities and the Police to maximise the role of technology for the dissemination of journey information

PD3.4 Driving Better Practice GCC will, as part of the development management process and network (HGVs) management, we will support improved codes of practice across the construction and logistics industry and require the production of Construction Management Plans (CMP) for strategic development sites and planned events, in order to minimise the impact on the surrounding community.

PD3.5 Managing Deliveries in GCC will encourage local communities, Chamber of Commerce, Town and Sensitive Areas Parish Councils to consider the role of freight within their Neighbourhood or Town Centre Plans in order to minimise the impact of deliveries in urban or other sensitive locations and of wasted delivery miles due to failed deliveries.

PD4.1 Gloucestershire’s GCC will maintain a functioning highway network that supports Gloucestershire’s Highway Network transport network by ensuring the safe and expeditious movement of highway users.

PD4.2 Highways Network GCC will provide a resilient highway network that can withstand unforeseen Resilience events, including extreme weather events and long term changes to the climate.

PD4.3 Highway Maintenance GCC will manage the local highway asset management in line with the Highways Asset Management Framework and other guidance or policies such as the Code of Practice for Well Managed Highway Infrastructure.

PD4.4 Road Safety GCC will contribute to improved safety, security and health by reducing the risk of death, injury or illness arising from transport, working with partners to improve personal safety perceptions and the promotion of transport that contributes to good health and wellbeing.

Public PD5.2 Rail Service Capacity GCC will engage with the rail industry to ensure that Gloucestershire benefits Transport Improvements from rail services that facilitate local access and longer distance connectivity to London, Bristol, Birmingham, Cardiff and Worcester.

PD5.1 Rail Infrastructure GCC will engage with the rail industry to ensure that Gloucestershire is well Improvements placed to take advantage of the wider rail infrastructure improvements, including route electrification, HS2 at Birmingham, MetroWest, western access to Heathrow Airport and CrossRail at Reading. Potential enhancements will need to be considered through Network Rail’s Continuing Modular Strategic Planning process which has highlighted the Bristol to Birmingham corridor as a potential candidate in conjunction with the Western Gateway Sub National Transport Body’s priorities.

PD5.3 Rail Station Improvements GCC will engage with delivery partners to maximise the desirability, demand and opportunities for multi-model connections and customer experience of using railway stations within Gloucestershire. Station facilities need to meet existing and forecasted demand by providing the safe and secure facilities for pedestrians, cyclists, bus users and car users.

PD1.1 Gloucestershire’s Bus GCC will take appropriate action to develop and maintain a comprehensive bus Network network in line with the standards set out below.

Tier 1 A route that is one or more of:

 Commercially operated (i.e. no GCC subsidy)  High frequency (one bus every 30 minutes or less)  High use (a minimum of 250,000 passenger trips per year)  Intra-urban (operating between 2 urban areas of at least 20,000 population)  Inter-urban (operating entirely within an urban area of at least 20,000 population) Tier 2 A route that is one or more of:

 Partially commercial (GCC subsidised a maximum of 50% of the route)  Medium frequency (one bus every 31-180 minutes)  Medium use (50,000-250,000 passenger trips per year)  Partially urban (serves at least one urban area of at least 20,000 population)

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Tier 3 A route that does not meet any tier 1 or 2 criteria, likely to include:

 Majority or entirely subsidised  Low frequency (2 buses per day or less)  Low use (under 50,000 passenger trips per year)  Rural (no urban centres of at least 20,000 population) GCC will work with partners and communities to provide realistic opportunities for travel choice by bus for residents, employers, and visitors and promote them as an alternative to the car to encourage increased levels of use.

PD1.3 Bus Priority To manage the use and develop bus priority to facilitate the free movement of buses along congested routes, ensuring the safe movement of all highway users.

PD1.2 Improving the Quality of GCC will encourage investment in public and community transport to increase the Highway Based Public patronage, improve safety and promote bus travel as a viable alternative to the Transport Network car.

PD1.4 Coach Travel GCC will work with coach operators to provide a reliable and efficient coach network that supports tourist day trips and connects communities, employment and services in Gloucestershire with key locations outside the county.

PD1.5 Community Transport GCC will support those with limited travel choice and support local communities to develop innovative responses to local transport need.

PD1.6 Transport Interchange GCC will work with our partners to provide realistic opportunities for travel choice Hubs for residents, employers, and visitors through the delivery of local Park and Ride and commercially viable strategic Park and Ride facilities.

Pedestrian & PD2.1 Gloucestershire’s Cycle GCC will deliver a high quality, coherent, direct, safe, comfortable and attractive Cycleway Network cycle network by improving cycle routes and reinforcing quiet highway connectivity.

PD2.2 Cycle Asset Management GCC will manage cycle infrastructure in line with the Highways Asset Management Framework and other guidance or policies such as the Codes of Practice for Well Managed Highway Infrastructure.

PD6.1 Gloucestershire’s GCC will work with interested parties to provide a safe, reliable and efficient Pedestrian Network highway environment providing links to connect communities, education, employment and services.

PD6.3 Pedestrian Asset GCC will manage pedestrian infrastructure in line with the Highways Asset Management Management Framework and other guidance or

policies such as the Code of Practice for Well Managed Highways Infrastructure

PD6.2 Rights of Way GCC will support the Rights of Way and Countryside Access Improvement Plan in identifying and seeking to support measures to improve safety, accessibility and the quality of the experience for walkers, horse riders, carriage drivers and cyclists where there is an identified need

PD6.4 Pedestrian Safety GCC will contribute towards improved safety, security, health by reducing the risk of death, injury or illness arising from journeys on foot or by mobility scooter. This will be provided by working with partners to improve personal safety perceptions and the promotion of transport that contributes to good health and wellbeing

Influencing PD1.6 Communicating Travel GCC will provide clear and accurate information on services for passengers Travel Information through a variety of outlets mediums, reaching every individual in every location. Behaviour PD2.3 Active Travel: Safety, GCC will contribute towards better safety, security, health and thereby longer life Awareness and Confidence expectancy by reducing the risk of death, injury or illness arising from journeys travelling by bike and other forms of transport. This will be provided by working with partners to improve personal safety perceptions of using the transport network services and promote the use of public and active travel options to contribute to enjoyment and psychological wellbeing

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Cross cutting and themed polices As shown above, the cross cutting Objectives were built upon by a series of Policies and Policy Proposals, six of which also act in a cross cutting fashion (PD0.1-PD0.6) and following the incorporation to the Policies and Policy Proposals of a range of recommendations made during the ISA process, it is anticipated that these will address many of those adverse sustainability issues which will inevitably arise through the implementation of an LTP, as well as accentuate those areas of the LTP that have been identified as being beneficial to sustainability. Of particular note in terms of sustainability are those cross cutting policies relating to Reducing Transport Carbon Emissions and Local Environmental Protection.

Nevertheless, it is important to recognise that elements of the LTP will have adverse effects on the environment and these are promoted by a number of themed policies which were grouped under three themes: Large infrastructure – Rail and Railways; Public Transport; and Pedestrian & Cycleways (see above). This is particularly relevant to those Large infrastructure theme policies which consider and promote schemes that will result in large infrastructure such as new highway and rail links, as well as highway and rail infrastructure upgrade. However, as a result of the ISA recommendations the noted cross cutting policies are referenced across all the theme policies and as such the overall sustainability performance of the Revised Draft LTP should be considered ‘in the round’ in terms of its sustainability performance.

How the ISA recommendations improved the sustainability performance of the Policies and Policy Proposals is illustrated in the following tables:

Results of Draft Revised Draft LTP Policy Assessment undertaken (Pre-Recommendations)

Plan Element ISA Objective 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Policies Cross Cutting PD0.1 Reducing Transport Carbon Emissions ++ + + 0 + + 0 0 - + + + 0 + + 0 PD0.2 Local Environmental Protection ++ ++ + + ------++ ++ + 0 ++ ++ 0 + + PD0.3 Maximising Investment in a Sustainable + + + + + + + + + + ++ + ++ + + + Transport Network PD0.4 Integration with land use planning and new + + + + + 0 0 0 + 0 ++ + ++ + + 0 development PD0.5 Community Health & Wellbeing ++ ++ 0 0 0 0 0 0 0 0 ++ ++ 0 ++ ++ + + PD0.6 Influencing Travel Behaviour ++ ++ 0 0 0 0 0 0 0 0 ++ 0 0 ++ ++ ++ + Grouped Policies Large Infrastructure – Rail & Highways + - + - + - + - + - + - + - - ++ + - + - ++ + + + + - - - + - Public Transport ++ ++ - 0 + + 0 0 - - ++ ++ + ++ ++ + + + + + Pedestrian & Cycleways ++ ++ + 0 + + + + 0 + ++ 0 + + ++ + +

ISA Objective

1 Improve Air Quality

2 Reduce carbon dioxide (CO2) emissions from transport

3 Protect and enhance protected habitats, sites, species, valuable ecological networks and promote ecosystem resilience and functionality

4 Protect, enhance and promote geodiversity

5 Protect and enhance the character and quality of landscapes and townscapes and visual amenity

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6 Conserve and enhance heritage assets and the wider historic environment including buildings, structures, landscapes, townscapes and archaeological remains and their settings.

7 Protect and enhance the water environment

8 Conserve soil and agricultural resources and seek to remediate / avoid land contamination

9 Reduce risk of flooding and increase resilience of the transport network to the effects of a changing climate

10 Promote prudent use of finite natural resources from primary sources, maximise the use of alternative, secondary and recycled materials, reduce the level of waste generated

11 Reduce the need to travel, particularly by car or move goods by road, and promote sustainable modes of transport and patterns of movement

12 Promote economic growth and job creation, and improve access to jobs for all

13 Coordinate land use and transport planning across Gloucestershire

14 Promote greater equality of opportunity for all citizens, with the desired outcome of achieving a fairer society (EqIA specific objective)

15 Improve health and well-being for all citizens and reduce inequalities in health (HIA specific objective)

16 Promote community safety and reduce crime and fear of crime for all citizens (CSA specific objective)

Assessment Scale Assessment Category Significance of Effect

+++ Large beneficial Significant

++ Moderate beneficial

+ Slight beneficial Not Significant

0 Neutral or no obvious effect

- Slight adverse

-- Moderate adverse Significant

--- Strong adverse

? Effect uncertain

+/- Combination of slight beneficial and Not significant adverse effects

++ -- Combination of moderate beneficial Significant and adverse effects

Recommendations arising out of Assessment of Draft Revised Draft LTP Cross Cutting Policies (as at September 2019) and how the considerations have been taken on board by GCC

Policy Recommendations How were the recommendations addressed?

PD01: The policy should clearly set out that the ultimate target is net zero The policy makes it clear that GCC will work reducing carbon (or carbon neutrality) by 2050 – it is recognised that this is with partners to reduce carbon emissions by Transport explained in the expected policy outcomes but such commitment 2050. The policy proposals note the Carbon would sit better in the policy text. introduction of a ‘Reducing Emissions Emissions Pathway’. It is further noted in additional The policy should either commit to intermediate targets if already supporting text that the ‘Reducing Emissions existence for Gloucestershire or to the development of a pathway Pathway’ would build upon action already setting out a clear programme of phased introduction of key policies being taken by GCC to reduce transport CO2 and measures and their projected contribution to meeting carbon emissions. Further supporting text on what budgets through to 2050 actions could be considered within the ‘Reducing Emissions Pathway’ is provided. The policy needs to address the need to reduce travel demand in the first place and set out clear proposals on how greater carbon The need to address travel demand is now

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Policy Recommendations How were the recommendations addressed?

efficiency can be achieved in Gloucestershire. specifically noted in the Policy text and is expanded upon in the Policy Proposals. Proposals for carbon offsetting/ sequestration and how this will be achieved in Gloucestershire need to be added to the policy. Additional supporting text has been added to note that interventions that improve air Although the policy text refers to air quality, the title of the policy only quality could also result from promoting a refers to carbon emissions and the policy proposals and outcomes modal shift from private motor vehicle use to are all concerned with carbon emissions. We recommend that a sustainable travel modes. This includes paragraph needs to be added to explain that interventions that public transport, walking and cycling, and can improve air quality could also result from promoting a modal shift help improve physical activity levels, from private motor vehicle use to sustainable travel modes. This providing additional public health benefits includes public transport, walking and cycling, and can help improve and contributing to reduced CO2 and air physical activity levels, providing additional public health benefits and pollution simultaneously and that air quality is contributing to reduced CO2 and air pollution simultaneously and that considered further in PD02. air quality is considered further in PD02.

The title of the policy should be changed to ‘Reducing transport The title of the Policy has been changed as carbon emissions and adaptation to climate change’. recommended.

We would recommend that text along the following lines in added to The policy text now contains a clear the introductory text: ‘Adaptation to climate change leads to a reference to the need for GCC to work with reduction in harm or risk of harm, or realisation of benefits associated its partners to ensure that the with unavoidable climate change. Adaptation policies to extreme Gloucestershire transport system is resilient weather events such as flooding and heat waves will lead to greater to the impacts of severe weather and climate resilience of Gloucestershire transport network. change and policy proposals include the need to identifying climate change resilience The policy text should then be: ‘GCC will work with its partners to adaptation in order to develop a mitigation reduce transport carbon emissions by promoting the use of package against the risks. sustainable modes of transport and the uptake of low emission vehicles to tackle climate change, and to ensure that the Note is now made in the supporting text to Gloucestershire transport system is resilient to the impacts of severe the policy of adaptation to climate change weather and climate change, so that services can maintaining service resilience in terms of risk to health, wellbeing, reliability in periods of extreme weather’ highway asset from high temperatures, risk to energy supply that may effect a functioning Followed by the following additional proposals: transport network and risk to natural capital, biodiversity, soils and ecosystems of resilience to severe weather etc. However,  Working in collaboration with the Environment Agency, no mention is given to grey, blue or green GFirst LEP,Homes England, Highways England, DfT and infrastructure, though it is noted that any other necessary government to achieve resilient additional Policy Proposals regarding flood transport infrastructure design and management and resilience, and grey, blue and green improved management of grey, blue and green infrastructure have been made to PD02. infrastructure. The recommendations for ISA objective 2 also apply here with the These recommendations have not been addition of the following: addressed.

 Clear linkage between Policy Documents 1-6 and carbon emissions policy is needed  Consideration of more carbon efficient ways for transportation of freight and goods  Set out how carbon and transport policy in Gloucestershire is linked to those in the neighbouring authorities in promoting sustainable regional trips. PD02 Local It is recommended that the policy aims to ‘deliver biodiversity net The policy text has been amended and now Environmental gains’ instead of ‘protect against biodiversity loss’. makes clear reference to ‘achieving Protection biodiversity net gain’. The following policy proposals need to be added: The recommended Policy Proposals Gloucestershire contains both statutory and non-statutory designated regarding both statutory and non-statutory sites that are protected for their importance for nature conservation. designated sites that are protected for their Prime among these sites are Special Areas of Conservation and importance for nature conservation have Special Protection Areas, which form the Natura 2000 European been made in additional supporting text. network of core breeding and resting sites for rare and threatened species, along with some rare natural habitat types. In addition to the Policy proposals relating to green, blue and Natura 2000 sites, there are also internationally important wetlands grey infrastructure have been made, as well designated as Ramsar Sites. There are also a large number of as those relating to maximising the nationally important Sites of Special Scientific Interest, National opportunities for transport interventions to

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Policy Recommendations How were the recommendations addressed?

Nature Reserves, Ancient Woodlands, and many important Local contribute towards major new initiatives. Nature Reserves and green spaces that support wildlife and enhance the wellbeing of the local population. Any potential direct or indirect impacts on these sites that may arise from new or upgraded transport interventions will be appropriately assessed, mitigated, and/or compensated for, in line with existing best practice and relevant legislation over the lifetime of the LTP. This would include the Natura 2000 sites and Ramsar sites for which Habitats Regulation Assessment will be carried out, as necessary, prior to final decisions being made on transport interventions.

Working with its Partners, other statutory bodies, such as the Environment Agency and Natural England, GCC will:

 realise opportunities for green infrastructure enhancement associated with transport infrastructure resilience and performance through both the integration of green, blue and grey infrastructure, and the delivery of green infrastructure-based natural solutions to aid mitigation requirements. The latter includes carbon reduction, clean air, flood risk management and increased resilience to climate change, as well as other place-making and visitor economy objectives.  maximise the opportunities for transport interventions to contribute towards major new initiatives, including Nature Recovery Networks and large-scale woodland creation, support Natural England’s work on the Green Transport Corridors and Green Infrastructure Agreements, as well as their recommendations of the Linear Infrastructure Network, ensuring that within or adjacent to the rail network and Major Road Network, green infrastructure can deliver biodiversity gains, ecological connectivity and ecosystem services. The following change to the policy proposal is recommended: This recommendation has been addressed.

 protect geological sites from degradation and removal caused by transport interventions and where practicable provide enhancements to the geological site and to its accessibility It is recommended that the policy aims to ‘minimise the impact of The recommendation relating to the Policy transport on landscapes and townscapes’ text has been addressed, as have the recommendations relating to the Policy Additional policy proposals: Proposals.

 Transport development proposals will need to demonstrated that there will be no unacceptable adverse impact upon public rights of way and recreational highways, unless suitable permanent diversions or alternative routes are provided. Temporary diversions or alternatives may be required during construction. It is recommended that the policy is changed to include ‘minimisation The recommendation relating to the Policy of the impact of transport on heritage assets and wider historic Text has been made, as have the environment’. recommendations relating to the Policy Proposals. The following policy proposals need to be added:

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Policy Recommendations How were the recommendations addressed?

understanding and appreciation of the significance of heritage assets as part of transport development where appropriate It is recommended that the policy is changed to include ‘protection The recommendation relating to the Policy and enhancement of the water environment’. Text has been addressed, as have the recommendations relating to the Policy Addition of the following policy proposal is recommended: Proposals.

 Transport interventions that have unacceptable adverse impact on water availability or quality or fail to achieve the targets of the Water Framework Directive will not be considered. It is recommended that the policy is changed to include ‘protection of The recommendation relating to the Policy soils and agricultural resources’ Text has been addressed, as have the recommendations relating to the Policy It is recommended that the following policy proposal is added: Proposals.

 Measures will be taken to prevent soil from being adversely affected by either physically or by pollution during transport intervention development. It is recommended that the policy is changed to include ‘reduction of The Policy Text has been amended to risk of flooding over lifetime’. ‘reduce the risk of flooding’. The Policy Proposal text now reads ‘Working with its The following policy proposals are recommended: partners and other statutory bodies, such as the Environment Agency and Natural England, Gloucestershire will work with  Working with its Partners, other statutory bodies, such as natural processes to promote greater flood the Environment Agency and Natural England, resilience to the network, ensuring Gloucestershire will work with natural processes to Sustainable Drainage Systems (SuDS) and promote greater flood resilience to the network, ensuring Natural Flood Management (NFM) are SDS and NFM are incorporated to reduce flood risk when employed wherever possible’. possible. It is recommended that the policy proposals are changed to include: The proposed text relating to local suppliers now reads ‘encouraging whenever possible local suppliers that use sustainably-sourced  Promote the use of local suppliers that use sustainably- and locally produced materials’, while the sourced and locally produced materials with transport- recommendation relating to waste related infrastructure projects management has been made.  Promote the use of increasingly more sustainable waste management practices with transport-related infrastructure projects in line with the waste hierarchy PD03 It is recommended that the policy provides clear support for new This recommendation is included in PD04 Maximising compact, higher density mixed use development with priority given to Integration with land use planning and new Investment in development of new sites already served by public transport in development. Note that the text included in a Sustainable detriment of other more remote and inherently less sustainable PD04 has been amended slightly to reflect Transport locations. the nature of a predominantly rural county, Network which will need to support both urban and rural development.

PD04 It is recommended that the policy be improved to set out proposals The text to the Policy Proposals now reads Integration aimed at reducing the need to travel in the first place such as support ‘Support digital connectivity and virtual with land use for digital connectivity, virtual working etc. working in order to reduce the need to travel’. planning and new It is recommended that the policy provides clear support for new The text to the Policy Proposals now reads development compact, higher density mixed use development with priority given to ‘Support new compact, higher density mixed development of new sites already served by public transport in use development with priority given to detriment of other more remote and inherently less sustainable development of new sites already served by locations. public transport in detriment of over other more remote and inherently less sustainable locations’.

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Policy Recommendations How were the recommendations addressed?

This policy could be expanded or cross referenced to note the and enhance; biodiversity net gain, blue and beneficial effects on wellbeing from having landscapes and green infrastructure, landscapes, townscapes townscapes that can promote a sense of place and the importance of and the historic environment from the protecting landscapes / townscapes from adverse effects of adverse effects of transport’. transport.

This policy could be expanded or cross referenced to note the beneficial effects on wellbeing from having an historic environment Additional supporting text has also been that can promote a sense of place and the importance of protecting added to ‘Recognise the benefits to health the historic environment from adverse effects of transport. and wellbeing by other policies that protect and enhance; biodiversity net gain, blue and This policy could be expanded or cross referenced to note the green infrastructure, landscapes, townscapes beneficial effects on wellbeing from having healthy water and the historic environment from the environment and the importance of ensuring that this is protected adverse effects of transport’. from adverse effects from transport.

This policy could be expanded or cross referenced to note the beneficial effects on wellbeing from avoiding land contamination, or by remediating areas of contamination.

This policy could be expanded or cross referenced to note the beneficial effects on health and wellbeing from avoiding flooding.

Greater clarity could be provided in this Policy relating to safety for The text to this Policy has been strengthened vulnerable persons on the wider public transport network and how and clatrified to note the need for reducing this can be achieved. both actual and perceived risk to personal safety by ‘encouraging the adoption by transport operators of safeguarding policies’.

Recommendations arising out of Assessment of Draft Revised Draft LTP Theme Policies (as at September 2019) and how the considerations have been taken on board by GCC

Theme Recommendations How were the recommendations addressed?

Large Cross reference should be made in the Policies to PD01 which Cross reference has been made across all Infrastructure notes the need for EV charging points. Policies to note that matters addressed within – Rail & the Policy should be considered alongside all Highways It is recommended that note is made of the need to reduce air cross cutting policies, especially those pollution during construction and operation and efficient concerning issues relating to a changing construction / maintenance techniques. climate and the need for reduction in carbon emissions, environmental protection, integration of development, changing traveller While it is recognised that HGVs and Rail freight may be difficult to behaviour and community health and decarbonise, the Policy could expand on the opportunities to wellbeing. decarbonise LGVs and ‘last mile’ delivery vehicles.

Cross reference should be made to PD02 and the need to protect important habitats and sites designated for nature conservation. The above cross referencing in each policies also means that in relation to crime and the While the Policy supporting text is welcomed, it is suggested that fear of crime, an update to the Cross Cutting this could be expanded to provide more information on the Policy of Community Health and Wellbeing will measures that could be taken during design or construction. be of relevance here as it is made clear that it is a key intention to ensure that all travellers, Cross reference could be made to PD02 which recognises the particularly those from disadvantaged and need to protect landscape / townscape. vulnerable groups, can access and use with confidence a safe and welcoming travel network. Cross reference could be made to PD02 which recognises the need to conserve and enhance the historic environment.

Cross reference could be made to PD02 which recognises the need to conserve and enhance the water environment. Similarly, PD02 has been expanded to ensure opportunities to remediate contaminated land should be taken when possible, as well as Cross reference could be made to PD02 which recognises the

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need to conserve soil and agricultural resources. noting the importance of geodiversity. Cross referencing to the PD02 Cross Cutting policy It is recommended that the Policy is amended to recognise the addresses the recommendations made here. need to seek opportunities to avoid land contamination.

This policy could be broadened and made clearer by making specific reference to crime and fear of crime on roads and public transport.

Public Policy text could be strengthened to note the need for Public As noted above, each Policy will now be cross Transport Transport to utilise low or zero emission vehicles for both bus and referenced to the Cross Cutting policies and rail. should be considered in light of the policy text and policy proposals of these. It is considered Cross reference to be made to PD02 which notes in supporting text that this cross referencing addresses the the issue of sites designated for nature conservation and the need recommendations made here. for HRA etc.

Cross reference could be made to PD02 which notes the need to minimise the impact of transport on landscapes and townscapes but it is considered that the policies could also be expanded to make it clear that good design, particularly in relation to stations and surrounding public realm is important in terms of landscape, townscape and visual amenity.

Cross reference could be made to PD02 which notes the need to minimise the impact of transport on historic assets but it is considered that the policies could be expanded to further clarify that good design, particularly in relation to stations and surrounding public realm should include consideration of the historic environment and how this can be enhanced.

Cross reference to PD02 should be made in relation to ensuring the use of SuDS and Natural Flood Management.

Cross reference could be made to PD02 which makes it clear that sustainable waste management practices should be promoted on transport projects, in line with the waste hierarchy.

The policies could be expanded to note the need to ensure people feel safe from crime etc., across all public transport modes / facilities.

Results of Revised Draft LTP Policy Assessment (Post-Recommendations)

Plan Element ISA Objective 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Policies Cross Cutting PD0.1 Reducing Transport Carbon Emissions ++ ++ + 0 + + 0 0 + + + + 0 + + 0 and Adapting to a Changing Climate + PD0.2 Local Environmental Protection +++ ++ ++ + ++ ++ ++ + + ++ +++ + 0 ++ ++ 0 + PD0.3 Maximising Investment in a Sustainable + + + + + + + + + + ++ + ++ + + + Transport Network PD0.4 Integration with land use planning and + + + + + 0 0 0 + 0 ++ + ++ + + 0 new development PD0.5 Community Health & Wellbeing ++ ++ + 0 + + + 0 + 0 ++ ++ 0 ++ ++ + + PD0.6, PD 1.7 & PD 2.3 Influencing Travel ++ ++ 0 0 0 0 0 0 0 0 +++ 0 0 ++ ++ ++

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Plan Element ISA Objective 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Behaviour Grouped Policies Large Infrastructure – Rail & Highways + - + - + - + - + - + - + - - + + - + - ++ + + + + - - - + + - Public Transport ++ ++ - 0 + + 0 0 - - +++ ++ + ++ ++ + + + + Pedestrian & Cycleways ++ ++ + 0 + + + + 0 + ++ 0 + + ++ + +

In conclusion, therefore, notwithstanding that the nature of the Revised Draft LTP will result in some adverse sustainability effects that will require mitigation, it is considered that the policies within the Revised Draft LTP provide a robust basis for an overall strong sustainability performance from implementation of the Revised Draft LTP.

Proposed Schemes

Within Gloucestershire, a series of schemes are anticipated to be implemented, or considered for implementation, across the six Connecting Places Strategies as set out in the Revised Draft LTP, namely:

 CPS1: Central Severn Vale  CPS2: Forest of Dean  CPS3: North Cotswold  CPS4: South Cotswold  CPS5: Stroud  CPS6: Tewkesbury

Within each CPS it was possible to identify common sector and type in relation to each of the identified schemes, namely:

 New Highway Links  Highway Infrastructure Improvements  New Rail Links  Rail Infrastructure Improvements  New Bus Infrastructure  Bus Infrastructure Improvements  Pedestrian & Cycleways

As would be expected, the schemes were shown by the ISA to have a mix of effects on the ISA Objectives, ranging from Major adverse (in terms of the prudent use of natural resources and reducing the need to travel in relation to highway links and highway infrastructure improvements), to major beneficial, particularly in relation to promoting economic growth across a number of scheme types, but also in relation to improving air quality and reducing carbon in respect of bus infrastructure improvements. Where appropriate, mitigation measures for each type of scheme have been proposed. It is important to note that this typical mitigation may, or may not, be applied to an individual scheme – the mitigation to be applied will depend upon the precise design of the scheme, the landscape and environment into which it is to be placed, the level of environmental protection required and the overall economic and social objectives of the scheme. In short, any mitigation to be put in place will be bespoke to and appropriate for, that scheme.

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and this is reflected in scores of major or moderate beneficial effects in respect of these Objectives. It is also the case that these types of scheme for offer some opportunity for improvements in air quality and reduction in carbon emissions (though it is to be recognised that they also would have adverse effects in this regard).

As would be expected in terms of sustainability, new bus infrastructure, bus infrastructure improvements and pedestrian / cycleways are considered to be for the most part beneficial, though some minor adverse effects have been identified e.g. in relation to the use of finite materials, as well as reducing crime and the fear of crime (linked to increases in traffic or an increased presence of people).

All the scheme types have also been noted to bring beneficial effects in terms of promoting greater equality of opportunity and improving health and wellbeing. All the schemes will provide greater opportunities for people to access the full range of services they need – educational, health, social, recreational and leisure, though it is to be recognised that some minor adverse effects have been noted in terms of new highway links and highway infrastructure improvements (primarily as these types of scheme would typically benefit those with access to private cars).

Assessment of Revised Draft LTP proposed schemes per type

Scheme Type ISA Objective

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

New Highway -- ++ -- ++ ------+++ ++ +/- +/- - Links

Highway -- ++ -- ++ ------++ -- ++ -- ++ ------+++ ++ +/- +/- - Infrastructure Improvements

New Rail Links -- ++ ++ ------+++ +++ ++ + + -

Rail Infrastructure ++ ++ -- -- +/- -- ++ ------+++ +++ + + + - Improvements

New Bus ++ ++ - - + +/- 0 - - - ++ +++ + + + - Infrastructure

Bus Infrastructure +++ +++ - - + +/- 0 - - - ++ + + + + - Improvements

Pedestrian / + + 0 0 0 0 0 0 0 0 + + + + + - Cycleways

Overview of Recommended Mitigation for Proposed Schemes

No. ISA Objective Overview of Recommended Mitigation

1 Improve Air Quality It will be important to reduce emissions and protect air quality as much as possible. Mitigation measures may affect the project design, layout, construction, operation and/or may comprise measures to improve air quality in pollution hotspots beyond the immediate locality of the scheme. Measures could include, but are not limited to, changes to the route of the new scheme, changes to the proximity of vehicles to local receptors in the existing route, physical means including barriers to trap or better disperse emissions, speed control and the use of best practice construction techniques. The implementation of mitigation measures may require working with partners to support their delivery and encouragement for the use of low emission vehicles should be made (see also mitigation for ISA Objective 15).

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No. ISA Objective Overview of Recommended Mitigation

carbon footprint can be found in the construction and operation of transport network assets – for example by using more energy efficient lights. The carbon footprint can be readily measured and addressed at construction and operation by use of an appropriate carbon calculator, along with appropriate targets being set.

3 Protect and enhance Opportunities to enhance biodiversity and green infrastructure exist, through designing in protected habitats, sites, biodiversity into schemes. These opportunities include for example, the development of wildflower species, valuable meadows along linear features such as roads and railway lines, which will look attractive and also ecological networks and provide opportunities for pollinators, or could include simple measures such as avoiding the promote ecosystem uncessary use of top soil and the installation of bird / bat boxes on structures or in nearby trees. resilience and More complex measures such as animal over or under passes can be considered. Similarly, functionality biodiversity can be enhanced by the planting of suitable / native species of trees and hedgerows as part of landscaping.. Properly planned maintenance schemes can also enhance biodiversity, for example from the timing and removal of cuttings to the active control of invasive species.

Particular consideration needs to be made to protection measures in relation to any scheme which may impact directly, or indirectly, on any site designated for nature conservation purposes – particularly those designated as SSSI orSAC, SPA or Ramsar. These sites should be avoided if possible.

4 Protect, enhance and It is important to protect those sites or areas known or designated for their geodiversity promote geodiversity importance. As with most impacts, avoidance is the best form of mitigation and as such designated sites should be avoided when possible. If avoidance is not possible, then consideration of the specific important geodiversity features and how these may be protected, or impact upon lessened, should be made during scheme design. Consideration of the potential for geodiversity enhancement should also be made in any scheme design.

5 Protect and enhance the Projects need to be designed carefully, taking account of the potential impact on the landscape / character and quality of townscape. Reducing the scale of a project or making changes to its operation can help to avoid landscapes and or mitigate the visual and landscape effects of a proposed project. Consideration during planning townscapes and visual should also be given to appropriate siting, design of the scheme (including choice of materials) amenity and landscaping schemes. Note that ideally native species or locally characteristic species should be used in any planting. Subject to appropriate planning, screening can also take place ‘off site’ e.g. by planting out gaps in tree lines / hedgerows. Particular consideration is to be given to conserving landscape and scenic beauty in any nationally designated areas, with encouragement given to avoiding these areas if possible. Opportunities for landscape / townscape enhancement should be taken when possible.

6 Conserve and enhance The historic environment includes all aspects of the environment resulting from the interaction heritage assets and the between people and places through time, including all surviving physical remains of past human wider historic activity, whether visible, buried or submerged, and landscaped and planted or managed flora. environment including Heritage assets may be buildings, monuments, sites, places, areas or landscapes. Consideration buildings, structures, should be made of the character and setting of the heritage asset, its significance (and level of landscapes, townscapes protection afforded to it), the potential for loss or harm and need for conservation. Opportunities and archaeological should be taken when possible for the enhancement of heritage assets. It should also be noted remains and their that due to its nature, not all heritage features may be apparent at the planning / design stage and settings. evaluation may be required. Design solutions to minimise damage and/or mitigation of impact through archaeological investigation may be necessary. In some rare cases precautions for unexpected discovery should be taken – perhaps through an archaeological watching brief.

7 Protect and enhance the Impact on local water resources can be addressed through planning and design for the efficient water environment use of water, including water recycling. Consideration should be given to the use of SuDS (including permeable paving), but it is also recognised that conventional drainage will play an important role. Protection and good pollution control measures are to be utilised during both construction and operation of transport schemes.

8 Conserve soil and Protection of soil resources, particularly those of higher quality / areas of better agricultural lands agricultural resources should always be considered – this could be done during scheme planning by careful route and seek to remediate / selection. If areas of good quality soil cannot be avoided, care should be taken during construction avoid land contamination to store topsoil for later reuse – either on site as landscaping or further afield. Opportunities should also be taken to utilise areas of previously developed land and to remediate contaminated land when possible. This could include the removal / appropriate treatment of any invasive species such as Japanese Knotweed.

9 Reduce risk of flooding Flooding poses a particular risk to the transport network and this situation is likely to get worse and increase resilience of with a changing climate. However, new infrastructure developments or improvements to existing the transport network to infrastructure should not be allowed to contribute to an additional flood risk elsewhere. the effects of a changing Opportunities can be taken to lower flood risk by considering flood protection measures, improving climate flow routes, flood storage capacity and using Sustainable Drainage Systems (SuDS). The appropriate use of SuDS will be critical and it should be the intention that site layout and surface

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No. ISA Objective Overview of Recommended Mitigation

water drainage systems should cope with events that exceed the design capacity of the system, so that excess water can be safely stored on or conveyed from the site without adverse impacts. Infrastructure should only be located in flood zones 2 and 3 when there is no other option.

10 Promote prudent use of Consideration during design and construction of transport schemes should be given to the waste finite natural resources hierarchy of prevention, reuse, recycling and disposal. All waste should be handled in accordance from primary sources, to applicable waste management legislation and the emphasis should be to minimise the volume maximise the use of of waste produced and the volume sent for disposal, unless it can be demonstrated that this is the alternative, secondary best environmental outcome. Consideration should be given to the use of recycled materials in and recycled materials, construction. reduce the level of waste generated

11 Reduce the need to Congestion is a major issue on many roads in Gloucestershire and reducing the need to travel by travel, particularly by car car, or move goods by road would improve the congestion situation – perhaps by the development or move goods by road, of more sustainable and active modes, through interventions such as bus priority measures, high and promote sustainable occupancy lanes, cycle lanes and adequate footpaths. Encouraging a shift to more sustainable modes of transport and modes such as buses, rail etc. could come about through the provision of better facilities etc. patterns of movement Further key components would include better accessibility and connectivity between different sustainable transport modes.

12 Promote economic It is vital that the transport network provides and where possible improves, the access to growth and job creation, employment opportunities and effectively connects business areas with residential areas. and improve access to Connectivity between business and residential centres and key infrastructure such as Airports is a jobs for all major consideration to be made, as is connectivity between urban centres across the region. Issues such as the attractiveness of the region as a better place to live and work can also influence and enhance inward investment or tourism and thereby increase employment opportunities across the region.

13 Coordinate land use and All of the proposed schemes will require adherence to the relevant planning requirements for any transport planning across development in Gloucestershire. As such consideration of these requirements will be made at the Gloucestershire design stage of all relevant schemes.

14 Promote greater equality During the Planning and Design stages of any transport scheme, it is vital that consideration is of opportunity for all given to the need for access to key public services such as health, education community and citizens, with the desired leisure facilities by all members of society. Access should be considered in relation to all modes, outcome of achieving a with an emphasis on more active and sustainable types. Affordability should also be a key fairer society (EqIA consideration, with a particular emphasis placed on effects on lower income groups. It should also specific objective) be a priority to enhance access to key services for vulnerable groups.

15 Improve health and well- The consideration of health & safety (including security / crime) is critical as part of scheme being for all citizens and planning and design and should include the introduction of the most modern and effective safety reduce inequalities in measures where proportionate. Safety considerations should apply to the construction phase, as health (HIA specific well as when the transport infrastructure is operational. It should always be the consideration to objective) minimise the risk of deaths or injury arising from the scheme and contribute to an overall improvement in societal safety levels. Consideration during scheme planning and design also has to be given to reducing air pollutant emissions and other aspects such as noise, vibration dust, light pollution and severance which potentially effect health and well-being. Access to public services (health, education, community facilities etc.) is also another key consideration.

16 Promote community It is important that the transport network is safe and secure and that all travellers, particularly safety and reduce crime those from disadvantaged and vulnerable groups, can access and use with confidence a safe and and fear of crime for all welcoming travel network. Use of the latest design standards that address concerns of vulnerable citizens (CSA specific travellers, along with the implementation of security and safety maintenance and improvement objective) plans will promote safety and reduce crime and the fear of crime.

As with the Revised Draft LTP policies and policy proposals, the ISA made recommendations as to how the delivery of the schemes could be improved. A key element was the recognition that consideration of sustainability does not end with the ISA process, but rather is a key element of ongoing future scheme development. The Revised Draft LTP now recognises that there is a need to ‘bridge the gap’ between the LTP and the assessment of individual schemes through requiring that schemes are checked against the degree of alignment with the LTP policies and outcomes and with ISA objectives, as well as any other relevant considerations at the time, prior to proceeding to the formal assessment processes of WebTAG, Environmental Impact Assessment and (where required) Habitats Regulation Assessment.

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Mitigation As part of the ISA assessment process, a series of mitigation measures/approaches have been identified and recommendations made as set out below.

Integration of mitigation in ISA

Mitigation approach How has this been incorporated into the ISA

Refining Policies in order to A series of recommendations were made in relation to each of improve the likelihood of the Policies contained within the Revised Draft LTP with the positive effects and to clear intention that these would maximise beneficial effects and minimise adverse effects minimise adverse. These recommendations ensured that the full range of ISA Objectives were addressed within the appropriate Policy, as well as strengthened the Policies in terms of areas where policy weaknesses were identified. An overview of the recommendations is provided in Chapter 10 on Policies Assessment.

Refining Schemes in order to Each scheme was assessed in relation to its particular scheme improve the likelihood of type e.g. new highway links, new rail links etc. and a range of positive effects and to mitigation measures were developed to cover the Design, minimise adverse effects Construction and Operation stages of schemes. An overview of these mitigation measures for each ISA Objective is provided in Chapter 11 on Scheme Assessment.

Technical measures (such as As above set out above for policies and schemes. setting guidelines) to be applied during the implementation phase

Identifying issues to be The ISA made a clear recommendation within the Scheme addressed in project Assessments to ensure that the LTP sets out clearly a process assessment (including but not of how sustainability issues will be considered in future scheme limited to WebTAG, development. It is clear in the LTP that there is a need to Environmental Impact ensure sustainability is at the front of any process and is Assessment and the integral to the decision making from the very beginning. This development of Environmental will avoid situations where sustainability issues are considered Management Plans) for certain only superficially, or at too late a stage in the process, thereby projects or types of project typically resulting in schemes that are less optimal from a sustainability perspective (see Section 11.3 Delivery Assessment).

Proposals for changing other No proposals have been made to change other plans and plans and programmes programmes as the LTP will act in accordance with a range of other Plans and Programmes e.g. local development plans and there are clear commitments made within the LTP for ongoing liaison between GCC and a range of other bodies. The LTP has been assessed as having cumulative beneficial effects in relation to a number of other Plans in Gloucestershire as it will act to bolster aspects of these other Plans (see Chapter 13 Cumulative effects).

Contingency arrangements for The ISA has proposed a Monitoring Programme (contained in dealing with possible adverse Chapter 14) that covers significant social, environmental and effects. economic effects and which will involve measuring indicators that will enable the establishment of a causal link between the implementation of the LTP and the likely significant effects (both positive and negative) being monitored. This will allow

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identification at an early stage of unforeseen adverse effects and allow appropriate remedial action to be undertaken.

Cumulative, Synergistic and Indirect Effects There is also a requirement to consider Cumulative, Synergistic and Indirect Effects of the Revised Draft LTP as a result of the joint implementation of all policy proposals. Secondary and Indirect effects are effects that are not a direct result of the plan but occur away from the original effect or as the result of a complex pathway. Cumulative effects arise where several proposals individually may or may not have significant effects but in-combination have a significant effect due to spatial crowding or temporal overlap. Synergistic effects are when two or more effects act together to create effects greater than the simple sum of the effects acting alone.

Anticipated cumulative, synergistic and indirect effects for Revised Draft LTP

Effects Causes Significance

Air pollutant It is considered that the Revised Draft LTP will Anticipated medium to long emissions have an overall cumulative beneficial effect on term moderate beneficial air quality. This beneficial effect will be derived effects – benefits may be from integration of the travel network and reduced if continued reliance delivery of better linkages, as well as the on the road network as development and increased use of sustainable opposed to more sustainable modes of transport which will lead to a modes of transport. reduction in air pollutant emissions.

Carbon It is considered that the Revised Draft LTP will Anticipated medium to long emissions help to result in a fall in carbon emissions due term moderate beneficial to integration of the travel network and delivery effects – benefits may be of better linkages, as well as the development reduced if continued reliance and increased use of sustainable modes of on the road network as transport and ultimately achieve net zero opposed to more sustainable carbon emissions. modes of transport.

Biodiversity The Revised Draft LTP and associated While effects in the short schemes will result in a mix of cumulative terms are likely to be slight positive and negative effects on biodiversity. adverse, ultimately, if net For example, some aspects such as integration biodiversity gain is achieved, of transport modes and the development of a long term benefits will be slight comprehensive cycling and walking network will beneficial. allow the potential for beneficial effects to occur, but other aspects such as highway developments or improvements may result in adverse effects – though even these will offer some opportunities for enhancement and ultimately achieve biodiversity net gain.

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Effects Causes Significance

accessibility to the network), other aspects such as schemes are implemented as integration of the network may lead to cumulative adverse effects. Further development of the highway network is also likely to result in an increase in impermeable area and contribute to increased flood risk by increasing runoff. It is considered that overall the cumulative effect will be slight adverse (measures to incorporate SuDS and upstream NFM to existing infrastructure will reduce effects). Soil, There will be a range of cumulative beneficial Anticipated slight beneficial agricultural and adverse effects on soil, agricultural and adverse effects over the resources resources and contaminated land. For example, medium to long term as and the development of the highway network schemes are implemented. contaminated provides an opportunity for positive effects land relating to contaminated land, but it may also provide an opportunity for further land to become contaminated and could potentially lead to the loss of soil / agricultural resources. Effects will be experienced across Gloucestershire. Economic It is anticipated that the Revised Draft LTP will Anticipated major beneficial growth act as a key driver to economic growth across effects over the medium to Gloucestershire. long term as schemes are implemented. Health and It is anticipated that the Revised Draft LTP will Anticipated moderate well-being act to promote health and well-being and beneficial effects over the and equalities through providing greater access to medium to long term as equalities services and employment opportunities, as well schemes are implemented. as greater opportunities for active travel.

The ISA has also considered other plans and projects that might lead to cumulative effects when combined with the Revised Draft LTP. The focus of this in-combination assessment has been on other identified plans and projects of relevance as follows:

 Looking to the Future – GCC Council Strategy 2019 – 2022  Strategic Economic Plan – GFirst LEP  Draft Local Industrial Strategy – GFirst LEP  Gloucestershire 2050 Vision

It was concluded that the sustainability in-combination effects with plans and projects above were generally beneficial, though with significant beneficial effects more likely to be realised over the medium to long term in relation to issues such as air quality and carbon emissions.

Monitoring There will be a need to monitor the implementation of the Revised Draft LTP. As interventions are developed, it is important that decisions in relation to these are taken with the best information available. Therefore, following the assessments, a monitoring programme has been developed to allow the early establishment of a causal link between the implementation of the Revised Draft LTP and the likely significant effects (positive or negative). This will provide GCC and other relevant authorities the information to make appropriate and informed decisions and take appropriate action as soon as possible should the monitoring

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Gloucestershire Local Transport Plan Review Integrated Sustainability Appraisal Report programme be adopted. It is also the purpose of the monitoring programme to help inform future reviews of the LTP itself.

Next steps This ISA Report is being published for formal consultation with the Draft Revised Draft LTP. The results of the formal public consultation exercise may well result in changes to the Draft Revised Draft LTP and these may have implications for the ISA results. In addition, the consultation exercise may result in direct changes to the contents of the ISA Report. These will be reported in the Post Adoption Statement in the next stage of development of the LTP and ISA following adoption of the Plan.

Conclusions The ISA process carried out throughout the development of the Revised Draft LTP has been thorough and comprehensive. Iterations of the Revised Draft LTP have been subject to review by the ISA team and continuous dialogue has taken place with the Plan development team. It is considered that this has resulted in an enhanced incorporation of sustainability considerations as the draft Revised Draft LTP evolved up to and including the current draft consultation version, particularly in terms of aspects related to environmental protection and enhancement (including addressing climate change), improvements to health and community safety, and greater equality of opportunity.

Based on the findings of the ISA, it is possible to draw a number of key conclusions with regards to the Revised Draft LTP. These are outlined as follows.

In the first instance, the overall compatibility of the Revised Draft LTP objectives against a revised and updated ISA Framework (that reflects the latest approaches to sustainability) has been improved through the introduction of additional elements to the Plan Objectives, with final Revised Draft LTP Objectives being:

 Support Sustainable Economic Growth  Enable Safe and Affordable Community Connectivity  Protect and Enhance the Natural and Built Environment  Improve Community Health and Well-being and Promote Equality of Opportunity

The cross cutting Objectives were built upon by six Policies and associated Policy Proposals that also act in a cross cutting fashion and following the incorporation to these of a range of recommendations made during the ISA process, it is anticipated that the final policy proposals (as GCC has re-drafted them in the final Revised Draft LTP) will address many of those adverse sustainability issues which will inevitably arise through the implementation of an LTP, as well as accentuate those areas of the LTP that have been identified as being beneficial to sustainability. Of particular note in terms of sustainability are those final cross cutting policies relating to Reducing Transport Carbon Emissions and Adapting to a Changing Climate, Local Environmental Protection and Health and Wellbeing.

Nevertheless, it is important to recognise that elements of the Revised Draft LTP will have adverse effects on the environment. This is particularly relevant to those theme transport policies which consider and promote schemes that will result, in some cases, in large infrastructure such as new highway and rail links, as well as highway and rail infrastructure upgrade. However, it is the case that the noted cross cutting policies are referenced across all the thematic policies to counteract any predicted negative sustainability effects.

A series of schemes are proposed to be delivered over the Plan period. Within Gloucestershire, these schemes are anticipated to be implemented, or considered for implementation, across the six Connecting Places Strategies (CPS). Within each CPS, it was possible to identify and assess the effects of common sector and type in relation to each of the identified schemes and propose scheme specific mitigation measures.

As with the Revised Draft LTP policies and policy proposals, the ISA made a series of recommendations as to how the delivery of the proposed schemes could be improved. A key element to this was this it is recognised that consideration of sustainability does not end with the ISA process, but rather is a key element of ongoing future scheme development. The Revised Draft LTP recognises that there is a need to ‘bridge the gap’ between the LTP and the assessment of individual schemes through the formal assessment processes

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Gloucestershire Local Transport Plan Review Integrated Sustainability Appraisal Report of WebTAG, Environmental Impact Assessment and (where required) Habitats Regulation Assessment. Consideration of sustainability for Schemes at each stage of their development is now an integral element in Gloucestershire.

It is recognised that the Revised Draft LTP or the Schemes that are derived from it will not act or be delivered in isolation and will influence and be influenced by, other Plans and Policies or developments across and beyond Gloucestershire. On the whole, considering the nature of the policies and the proposed mitigation in respect of Schemes, it is considered that many of the effects will be beneficial, though with significant beneficial effects more likely to be realised over the medium to long term in relation to issues such as air quality and carbon emissions. No significant adverse cumulative effects were identified.

It is important that GCC understand the effects of the implementation of their LTP and the ISA set out a comprehensive monitoring programme that builds upon the extensive monitoring already carried out by GCC. This monitoring programme covers significant social, environmental and economic effects and it will involve measuring indicators that will enable the establishment of a causal link between the implementation of the LTP and the likely significant effects (both positive and negative) being monitored. This will be of particular benefit to those involved with the next iteration of the LTP and if required, will allow early remediation to be undertaken of any identified adverse effects.

Overall, it is considered that the Revised Draft LTP represents a well-balanced approach in terms of sustainability performance across the full range of potential key effects delineated in the ISA Framework, and should help ensure that the vision for Gloucestershire of ‘A resilient transport network that enables sustainable economic growth by providing travel choices for all, making Gloucestershire a better place to live, work and visit’ can be achieved in a sustainable and integrated fashion.

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1. Introduction

1.1. Purpose of this Report This is the Integrated Sustainability Appraisal (ISA) Report of the Gloucestershire’s Local Transport Plan (LTP) (2015-2041), which has been prepared to fulfil the requirements for Sustainability Appraisal / Strategic Environmental Assessment (SA/SEA), Health Impact Assessment (HIA), Equality Impact Assessment (EqIA) and Community Safety Assessment (CSA). In addition, Habitats Regulation Assessment (HRA) has been undertaken as a parallel process to the ISA and is reported separately.

The ISA Report identifies the likely sustainability effects of implementing the Revised Draft LTP and reports on the process of developing the Revised Draft LTP from a sustainability perspective. The ISA and HRA Reports have been produced by Atkins on behalf of Gloucestershire County Council (GCC)

An overview of the Revised Draft LTP is presented in the following section.

1.2. The need for a Revised Local Transport Plan The production of an LTP is a statutory requirement under the Local Transport Act 2008 for Local Authorities. However, its role has changed. It no longer provides the basis of a financial allocation from the Department for Transport (DfT). Instead it sets out the long term policy structure for local transport delivery including a set of scheme priorities.

Gloucestershire’s Revised Draft LTP discusses the transport strategy in two stages: until 2031 and up to 2041. The main body of the Plan sets out the vision for transport until 2031, roughly in line with the time horizons for growth allocations in the adopted Local Plans. However, emerging trends in technology and society as well as strategic ambitions in Gloucestershire that reach beyond this time horizon require a more ambitious strategy that will shape the way Gloucestershire will develop until 2041and beyond. It is envisioned that this vision for 2041 will inform discussions with Gloucestershire Districts on current Local Plan reviews and that there will be another review of this Local Transport Plan, once Gloucestershire’s areas of growth post 2031 are better understood.

It is important to understand that funding will come from a variety of sources. Therefore, prioritisation of schemes will depend on the objectives of the specific funding source. There is an implicit delivery plan in the schemes, with those schemes that currently have funding secured expected to be delivered in the short term, schemes in the CPS strategies in the medium term (i.e. by 2031) and schemes in the futures chapter in the long term (i.e. 2040).

1.3. Revised Draft LTP Overview Gloucestershire’s vision for transport is for:

‘A resilient transport network that enables sustainable economic growth by providing travel choices for all, making Gloucestershire a better place to live, work and visit’

The key objectives for Gloucestershire’s Revised Local Transport Plan are:

 Protect and enhance the natural and built environment  Support sustainable economic growth  Enable safe and affordable community connectivity  Improve community health and wellbeing and promote equality of opportunity

The Revised Draft LTP comprises ten documents, which are listed below with the relevant LTP policies where applicable. The ‘Shaping the Way to 2041’ document brings together emerging trends and visions of how mobility will change over the next decades with possible growth scenarios in Gloucestershire and their impacts on the transport infrastructure required to achieve them and this in turn informs:

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- the Overarching Strategy which highlights the strategic context (vision and objectives) and outlines the key policies that apply across the LTP as a whole;

- Policy documents 1-6 which outline the specific policies within the LTP for each of the transportation themes;

- the Connecting Places Strategies document outline the schemes required within each specific strategy area to deliver the policies within the LTP; and

- the final Delivery Chapter outlines how these schemes could be delivered.

It should be noted that capital scheme priorities have been identified in the Delivery Chapter through a scheme prioritisation process that looks at scheme eligibility and impacts on economic growth, carbon emissions, socio-distributional impacts, the local environment and well-being. Schemes thus identified comply with delivering LTP outcomes but do not reflect a commitment by the county council for funding. The prioritised capital scheme list provides the basis for future funding bids, as opportunities arise through government, and funding partners; including transport operators and developers.

Shaping the Way to 2041

Overarching Strategy

Policy LTP PD 0.1 Reducing Transport Carbon Emissions and Adapting to Climate Change

Policy LTP PD 0.2 Local Environmental Protection

Policy LTP PD 0.3 Maximising Investment in a Sustainable Transport Network

Policy LTP PD 0.4 Integration with land use planning and new development

Policy LTP PD 0.5 Community Health and Wellbeing

Policy LTP PD 0.6 Thinktravel – Influencing Travel Behaviour

Policy Document 1 – Public & Community Transport

Policy LTP PD 1.1 – Gloucestershire’s Bus Network

Policy LTP PD 1.2 – Improving the Quality of the Road Based Public Transport

Policy LTP PD 1.3 – Bus Priority

Policy LTP PD 1.4 – Coach Travel

Policy LTP PD 1.5 – Community transport

Policy LTP PD 1.6 – Transport Interchange Hubs

Policy LTP PD 1.7 – Communicating Travel Information

Policy Document 2 – Cycle

Policy LTP PD 2.1 – Gloucestershire’s Cycle Network

Policy LTP PD 2.2 – Cycle Asset Management

Policy LTP PD 2.3 – Active travel: Safety, Awareness and Confidence

Policy Document 3 - Freight

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Policy LTP PD 3.1 – Gloucestershire’s Freight Network

Policy LTP PD 3.2 – Journey Routing Information for Freight

Policy LTP PD 3.3 – Driver Facilities

Policy LTP PD 3.4 – Driving Better Practice

Policy LTP PD 3.5 – Managing deliveries in urban or other sensitive locations

Policy LTP PD 3.6 – Rail and Water Freight

Policy Document 4 - Highways

Policy LTP PD 4.1 – Gloucestershire’s Highway Network

Policy LTP PD 4.2 – Highways Network Resilience

Policy LTP PD 4.3 – Highway Maintenance

Policy LTP PD 4.4 – Road Safety

Policy LTP PD 4.5 – On-street Car Parking

Policy Document 5 - Rail

Policy LTP PD 5.1 – Rail Infrastructure Improvements

Policy LTP PD 5.2 – Rail Service Capacity Improvements

Policy LTP PD 5.3 – Railway Stations Improvements

Policy Document 6 - Walking

Policy LTP PD 6.1 – Gloucestershire’s Pedestrian Network

Policy LTP PD 6.2 – Rights of Way

Policy LTP PD 6.3 – Pedestrian Asset Management

Policy LTP PD 6.4 – Pedestrian Safety

Connecting Places Strategy

CPS 1: Central Severn Vale

CPS 2: Forest of Dean

CPS 3: North Cotswold

CPS 4: South Cotswold

CPS 5: Stroud

CPS 6: Tewkesbury

Delivery Chapter

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2. Approach to Integrated Sustainability Appraisal

2.1. Introduction In relation to this ISA, the umbrella process of SA/SEA has been followed to cover the requirement for HIA, EqIA and CSA to be undertaken. SA/SEA is a process which in the UK was originally was primarily focused on assessment of plans in the land use sector, but which has become widely accepted as a way of covering environment, social and economic dimensions of sustainable development, rather than just environmental as in a traditional SEA, across a broad range of sectors.

2.2. Sustainability Appraisal / Strategic Environmental Assessment Due to the potential for the LTP to lead to schemes which will require an Environmental Impact Assessment, it is a statutory requirement that SEA is undertaken under the European Directive 2001/42/EC 'on the assessment of certain plans and programmes on the environment' (the 'SEA Directive').

Although the requirements to carry out SA and SEA are distinct, DCLG (Department for Communities and Local Government, formerly the ODPM (Office of the Deputy Prime Minister)) proposed that both can be satisfied through a single appraisal process. It has produced guidance (see Section 4 Methodology) to ensure SAs meet the requirements of the SEA Directive whilst widening the Directive's approach to include economic and social issues as well as environmental ones.

The EU Directive 2001/42/EC on assessment of effects of certain plans and programmes on the environment (the "SEA Directive") came into force in the UK through the Environmental Assessment of Plans and Programmes Regulations 2004 (the "SEA Regulations"). The SEA Regulations apply to a wide range of plans and programmes, including transport plans, and modifications to them.

The overarching objective of the SEA Directive is:

"To provide for a high level of protection of the environment and to contribute to the integration of environmental considerations into the preparation and adoption of plans… with a view to promoting sustainable development, by ensuring that, in accordance with this Directive, an environmental assessment is carried out of certain plans… which are likely to have significant effects on the environment." (Article 1)

The main requirements introduced by the SEA Regulations are that:

 the findings of the SEA are published in an Environmental Report (ER), which sets out the significant effects of the draft plan;  consultation is undertaken on the plan and the ER;  the results of consultation are taken into account in decision-making relating to the adoption of the plan; and  information on how the results of the SEA have been taken into account is made available to the public.

In this ISA process, the ISA Report incorporates the SEA requirement for an Environmental Report.

2.3. Health Impact Assessment (HIA) While there is no statutory requirement to undertake an HIA in relation to the LTP, it was recognised that it provides a useful way to support efforts to improve health of individuals and communities and help address health inequalities. In short, it was recognised that the LTP policies and proposals have the potential to impact on factors influencing the health of communities and individuals such as noise and air quality, access to key services and facilities, as well as the design of transport infrastructure. Undertaking an HIA ensured

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Gloucestershire Local Transport Plan Review Integrated Sustainability Appraisal Report that potential impacts of the LTP on health and health inequalities have been considered as advised in National Planning Policy Framework (NPPF).

The incorporation of HIA is also in keeping with good practice. It is also the case that the Department for Transport (DfT) Transport Analysis guidance indicates that consideration of 'Human Health' is a legal requirement in a SEA and that an HIA is an integral part of an SEA to identify and inform health issues in Plans.

2.4. Equality Impact Assessment (EqIA) An EqIA has been undertaken as it fulfils the statutory duties of public bodies to ensure the promotion of equalities under the Equality Act 2010 and subsequent Public Sector Equality Duty.

The purpose of an EqIA is to ensure plans and programmes do not discriminate against any individual or community and where possible promotes equality. An EqIA considers impacts on a variety of groups, mainly focussing upon the 'protected characteristic groups' (PCGs) established under the Act, namely:

 Age  Disability  Gender  Gender reassignment  Marriage  Civil Partnership  Pregnancy and maternity  Religion or belief  Race  Sexual Orientation

The Act also makes explicit the concept of 'dual discrimination', where someone may be discriminated against or treated unfairly on the basis of a combination of two of the protected characteristics.

DfT Transport Analysis guidance 2009 requires an evidence-led EqIA to be completed to help inform the development of the transport plan, ensuring it addresses any equality issues identified and takes account any impacts the plan may have on the local communities. Although not defined in the Equality Act, it is also the case that the issue of ‘low income’ and the implications of this were considered in the assessment.

The EqIA process is fully reported in this ISA Report.

2.5. Community Safety Assessment (CSA) A further key component fully considered and reported in the ISA is a Community Safety Assessment (CSA). The purpose of undertaking the CSA was to ensure that a scheme, strategy or policy does not have a detrimental impact on community safety (including crime and road safety) and where possible improves the existing situation.

This CSA was undertaken in accordance with the requirements of the Crime and Disorder Act 1998 and fulfils the requirement to carry out a review of the levels and patterns of crime, disorder and community safety in the area when developing a strategy or plan. Reported crime statistics are the most tangible measure to understand community safety and were analysed against the population profile of the area.

2.6. Habitat Regulation Assessment (HRA) HRA is required by Regulation 63 of the Conservation of Habitats and Species Regulations 2017 (as amended) (the Habitats Regulations) for all plans and projects which may have likely significant effects on a European site and are not directly connected with or necessary to the management of the European site.

European sites include Special Areas of Conservation (SAC) and Special Protection Areas (SPA). As a matter of UK Government policy, potential SPAs (pSPA), possible SACs (pSAC), listed or proposed

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Wetlands of international importance (Ramsar sites) and sites identified, or required, as compensatory measures for adverse effects on European sites, pSPA, pSAC, and listed or proposed Ramsar sites, are included for the purposes of considering plans and projects which may affect them2. Hereafter all of the above designated nature conservation sites are referred to as ‘European sites’.

There are four stages to the HRA process. These are summarised below:

 Stage 1 – Screening: To test whether a plan or project either alone or in combination with other plans and projects is likely to have a significant effect3 on a European site;  Stage 2 – Appropriate Assessment: To determine whether, in view of a European site’s conservation objectives, the plan (either alone or in combination with other projects and plans) would have an adverse effect on the integrity of the site with respect to the site structure, function and conservation objectives. If adverse impacts are anticipated, potential mitigation measures to alleviate impacts should be proposed and assessed;  Stage 3 – Assessment of alternative solutions: Where a plan is assessed as having an adverse impact (or risk of this) on the integrity of a European site, there should be an examination of alternatives (e.g. alternative locations and designs of development); and  Stage 4 – Assessment where no alternative solutions remain and where adverse impacts remain: In exceptional circumstances where no alternative solutions remain and where adverse impacts remain (e.g. where there are imperative reasons of overriding public interest). Compensatory measures would usually be required to offset negative impacts.

HRA Stages 1 and 2 have been carried out for the Revised Draft LTP and the assessment results presented in a separate HRA Report.

A total of 18 European sites have been identified for inclusion in the assessment. These comprise 11 sites within Gloucestershire, a further four sites located within 15 km of the plan area/ county boundary and an additional three SACs designated for bats within 30 km. There are no cSACs, pSPAs or pRamsar sites present within the 15 km Zone of Influence of the Plan.

A high-level assessment of the potential for actions within the Revised Draft LTP to have an adverse effect on the integrity of European sites has been undertaken. Detailed information is not yet available about the nature and extent of any works under the schemes of the Revised Draft LTP. However, it is considered reasonable to anticipate from the information available that the developments could be delivered in a manner which avoids any adverse effects on the integrity of the European sites through the use of standard mitigation techniques. Furthermore, it is entirely possible that a number of impacts can be avoided or ‘designed out’ and to facilitate this process early consultation with Natural England is strongly recommended at screening stage for such schemes (Stage 1).

Taking into account the proposed mitigation measures, the robust wording in the Revised Draft LTP policy which commits to the protection of the European sites, it can therefore be concluded that the LTP will not have an adverse effect on the integrity of the European sites alone and in combination.

2.7. Reporting and consultation as part of the ISA process Key consultation requirements are those set in the SEA Regulations which identify three organisations (in England) to act as statutory consultation authorities in the SEA process: Environment Agency, Natural England (formerly English Nature and the Countryside Agency) and Historic England (formerly English Heritage).

Two consultation periods involving the statutory consultation authorities and, in the latter period, the public are also set in the SEA Regulations. The consultation periods relate to:

2 National Planning Policy Framework. Ministry of Housing, Communities and Local Government. February 2019 [Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/810197/NPPF_Feb_2019_revised.pdf]. 3 Likely significant effect is any effect that may reasonably be predicted as a consequence of a plan or project that may affect the conservation objectives of the features for which the site was designated. If any plan or project causes the cited interest features of a site to fall into unfavourable condition they can be considered to have a likely significant effect on the site.

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 Scoping. The responsible authority is required to send details of the plan or programme to each consultation authority so that they may form a view on the scope, level of detail and appropriate consultation period of the Environmental Report. The consultation authorities are required to give their views within five weeks.  The Environmental Report. The responsible authority is required to invite the consultation authorities and the public to express their opinions on the Environmental Report and the plan or programme to which it relates.

To ensure that the evidence base underpinning the ISA was robust and up to date, a review of the SEA and HRA scoping information which informed the development of the LTP 2015-2031 has been undertaken. A formal Scoping Report consultation has not been undertaken as this had already been undertaken for LTP 2015-2031 and the Revised Draft LTP is viewed as a review of the previous LTP. Instead, a Technical Note was prepared and consulted upon by GCC providing background to the Revised Draft LTP and ISA development processes and presenting the results of the focussed scoping information review that was undertaken for information and comment.

Listed below are the key stakeholders that were consulted on the Technical Note and the responses from this consultation have been used to inform the ISA and have helped refine the Revised Local Transport Plan. The Technical Note and the comments received, together with how these comments have been addressed in the preparation of this ISA Report, are set out in Appendix A to this report.

 Department for Transport Liaison  District Council Officers  Environment Agency  Gloucestershire Fire & Rescue Service  Gloucestershire NHS Foundation Trust  Glos. Local Transport Plan Management Board  GCC – Senior Officers  GCC - Councillors  GCC – Highways Asset Management/Network Management  GCC – Development Management  GCC – Strategic Planning & Infrastructure  GCC – ITU & SEN Transport  GCC – Highway Records  GCC – Road Safety  GCC – Adult Social Care & Public Health  GCC – ProW  Homes England  Highways England  Historic England  Natural England  SCIMB – Strategic Communities & Infrastructure Members Board  LCM – Lead Cabinet Members

Key reporting requirements are those set by the SEA Directive and SEA Regulations:

'An Environmental Report shall be prepared in which the likely significant effects on the environment of implementing the plan or programme, and reasonable alternatives taking into account the objectives and the geographical scope of the plan or programme, are identified, described and evaluated.'

As already indicated, the SEA Report has been integrated in this ISA Report. Table 2-1 sets out the way the specific SEA requirements have been met in this report.

Table 2-1 Schedule of SEA Requirements

Information to be included in the Environmental Report under Where covered in ISA the SEA Regulations (Regulation 12 and Schedule 2) Report

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Information to be included in the Environmental Report under Where covered in ISA the SEA Regulations (Regulation 12 and Schedule 2) Report 1. An outline of the contents, main objectives of the plan, and of Chapters 1 and 4 its relationship with other relevant plans and programmes 2. The relevant aspects of the current state of the environment Chapter 6 and the likely evolution thereof without implementation of the plan; 3. The environmental characteristics of areas likely to be Chapter 6 significantly affected 4. Any existing environmental problems which are relevant to the Chapter 6 plan including, in particular, those relating to any areas of a particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC and 92/43/EEC; 5. The environmental protection objectives, established at Chapter 7 international, Community or Member State level, which are relevant to the plan and the way those objectives and any environmental considerations have been taken into account during its preparation 6. The likely significant effects on the environment, including Chapters 8, 9, 10, 11, 13 short, medium and long-term effects, permanent and temporary effects, positive and negative effects, and secondary, cumulative and synergistic effects, on issues such as: biodiversity; population; human health; fauna; flora; soil; water; air; climatic factors; material assets; cultural heritage including architectural and archaeological heritage; landscape; the interrelationship between the above factors 7. The measures envisaged to prevent, reduce and as fully as Chapter 12 possible offset any significant adverse effects on the environment of implementing the plan 8. An outline of the reasons for selecting the alternatives dealt Chapter 9 with, and a description of how the assessment was undertaken including any difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the required information 9. A description of measures envisaged concerning monitoring in Chapter 14 accordance with Regulation 17 10. A non-technical summary of the information provided under Non-technical summary paragraphs 1 to 9

The ISA Report is thus an important consultation document and likely to be of interest to a wide variety of readers including decision makers, other plan/programme practitioners, statutory consultees, NGOs and members of the public. It accompanies the draft LTP on public consultation taking place from early January to March 2020.

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3. Scope of the Integrated Sustainability Appraisal

3.1. Introduction The section describes the spatial, temporal and technical scope of the sustainability studies undertaken as part of the ISA.

3.2. Spatial Scope The Revised Draft LTP applies to Gloucestershire County Council area. It covers the following Local Authorities:

 Forest of Dean District Council;  Tewkesbury Borough Council;  Cheltenham Borough Council;  Cotswold District Council; and  Stroud District Council.

Figure 3-1 Geographical scope of the Plan

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3.3. Temporal Scope The temporal scope of the ISA has been aligned with that for the Revised Draft LTP, which will apply to the period up to the year 2041.

3.4. Technical Scope The ISA has a very wide remit and will consider the following topics associated with the various assessment processes it covers.

3.4.1. SA / SEA The SEA Directive and the SEA regulations require that the likely significant effects on the environment are assessed, considering the following factors and interrelationship between them:

 Biodiversity;  Population;  Human health (covering noise issues among other effects on local communities and public health);  Fauna and flora;  Soil;  Water;  Air;  Noise;  Climatic factors;  Material assets (covering infrastructure, waste and other assets);  Cultural heritage including architectural and archaeological heritage; and  Landscape.

SA guidance requires the consideration of socio-economic factors alongside the environmental factors identified above.

3.4.2. HIA Department of Health guidance recommends that the assessment of transport plans should consider the following topics:

 Transport to work, shops, schools and healthcare  Walking and cycling  Community severance  Frequency and severity of crashes  Collisions causing injury and fatal accidents  Air pollution, noise and  Ageing population and increasing disability

From an HIA perspective, there are vulnerable social groups that need special consideration in transport planning with regards to their health. These groups are likely to experience transport-related exclusion and / or be subject to negative externalities of transport and are as follows:

 Children – who as non-drivers are reliant on others for motorised transport and who suffer the greatest impacts of transport policy on their health, particularly children in low-income families;  Women – who are more likely not to own a car in some communities and find it harder to travel to shops, employment, healthcare and other services;  Older people – who may feel vulnerable using public transport, who often need to seek health services and who are particularly vulnerable to road crash related injuries. Their continuing independence at home is often dependent upon reliable transport options;

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 Disabled and people with other health problems – who may not be able to access many forms of transport or need special arrangements to access those. They are more likely to find it difficult to walk and may also be disadvantaged by the cost of transport;  Low income groups – who are likely to walk further because they cannot afford public transport or to own a car and whose lack of transport options may limit life opportunities. They suffer the most from injuries, noise pollution and air pollution.

3.4.3. EqIA The EqIA process focuses on the consideration of the potential LTP effects on nine protected characteristic groups (PCGs) identified in the Equality Act 2010 that are relevant to the transport agenda:

 Age;  Disability;  Gender;  Gender reassignment;  Marriage and Civil Partnerships;  Pregnancy and maternity;  Race;  Religion or belief; and  Sexual orientation.

A degree of overlap between the HIA vulnerable social groups and the EqIA protected characteristics has been acknowledged by both HIA and EqIA processes. Consistency between the two assessments has been ensured, where appropriate, particularly in terms of assumptions, analysing techniques and findings.

3.4.4. CSA The approach to the CSA has considered the topics of community safety and crime and fear of crime.

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4. ISA Methodology

4.1. Introduction

The ISA has been used as a tool for improving the Revised Draft LTP’s sustainability performance. Specifically, this has been achieved through allowing sustainability objectives to be considered throughout the plan's formulation process: from inception through development of Objectives, Strategic Alternatives, Overarching Strategy, Thematic Policies and Connecting Places Strategy.

As has already been stated, the ISA process fully integrates a range of assessment processes: SA/SEA, HIA, EqIA and CSA. HRA has been undertaken in parallel to the ISA and its results incorporated into the ISA as appropriate. Table 4-1 demonstrates how the integration has been planned and achieved throughout all the preparation stages of the ISA and LTP.

4.2. Assessment Methodology The ISA methodology adopted was developed broadly based on published guidance documents:

 Transport Analysis Guidance (TAG) 2.11 Strategic Environmental Assessment for Transport Plans and Programmes, Department for Transport, 'In Draft' Guidance, April 2009;  Sustainability Appraisal of Regional Spatial Strategies and Local Development Documents - Guidance for Regional Planning Bodies and Local Planning Authorities, by the ODPM, the Scottish Executive, the Welsh Assembly Government and the Northern Ireland Department of the Environment November 2005;  A Practical Guide to the Strategic Environmental Assessment Directive, by the ODPM, the Scottish Executive, the Welsh Assembly Government and the Northern Ireland Department of the Environment, September 2005;  Draft Guidance on Health in Strategic Environmental Assessment, Consultation Document, Department of Health, 2007; and  National Planning Policy Framework, 2019 and associated Planning Practice Guidance, March 2014.

The work undertaken to-date involved the completion of SA/SEA stages A, B and C and associated tasks (see Table 4-1) together with HIA, EqIA, CSA and HRA.

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Table 4-1 Integration of the Assessment Process

data and likely future trends international sites within (as part of SA/SEA). evidence evidence and up to 20km around the Plan area Review and confirm Key Confirm details of all Review and confirm health Review and confirm equalities Review and confirm community sustainability issues – update international sites specific issues (as part of specific issues safety specific issues these if required SA/SEA)

Review objectives and Liaise with SA/SEA team to Ensure inclusion of Health Ensure inclusion of Equalities Ensure inclusion of Community decision-making questions ensure SA/SEA Framework specific objectives in SA/SEA specific objectives in SA/SEA Safety specific objectives in (SA/SEA Framework) – covers international sites Framework Framework SA/SEA Framework update these if required appropriately Prepare ISA Technical Note Input into ISA Technical Input into ISA Technical Note Input into ISA Technical Note Input into ISA Technical Note to consult informally with Note relevant consultees

Review consultation Review consultation Review consultation responses Review consultation Review consultation responses responses and update responses as part of and update scoping responses and update and update scoping information scoping information for ISA SA/SEA for any aspects of information for ISA Report scoping information for ISA for ISA Report Report note in relation to HRA Report Generating B. Developing, Review and confirm Review proposals and Review and confirmation of Review and confirmation of Review and confirmation of Plan options for the refining and Assessment of Plan considerations of likely Plan objectives and strategic Plan objectives and strategic objectives and strategic options LTP to resolve appraising objectives against the impacts options be undertaken within options be undertaken within be undertaken within SA/SEA these strategic updated SA/SEA Framework SA/SEA SA/SEA challenges; options Review and confirm Appraisal Identification and appraising the of Plan strategic options consideration of other plans options and and projects predicting their effects Review and confirm Evaluation / selection of Plan preferred options.

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Transport Sustainability Appraisal/ Habitats Regulation Health Impact Equalities Impact Community Safety Planning Stage Strategic Environmental Assessment Assessment Assessment Assessment Assessment Stage Tasks Tasks Tasks Tasks Tasks Selecting B. Assessing Predict and assess effects of HRA review of proposals in Predict and assess effects of Predict and assess effects of Predict and assess effects of new preferred the effects new or revised options taken draft Strategic Transport new or revised preferred new or revised preferred or revised preferred options to be options for the of the draft forward. Confirm findings in Plan (screening and options to be undertaken options to be undertaken undertaken within SA/SEA. LTP Review and LTP Review relation to previously appropriate assessment) within SA/SEA. within SA/SEA. deciding assessed schemes. Review and confirm and if priorities Review and confirm proposed Review and confirm and if Review and confirm and if Review and confirm and if required, propose mitigation mitigation measures – if required, propose mitigation required, propose mitigation required, propose mitigation measures within SA/SEA required, new mitigation measures measures within SA/SEA measures within SA/SEA measures to be developed Develop monitoring Monitoring as part of Monitoring as part of SA/SEA Monitoring as part of SA/SEA Monitoring as part of SA/SEA programme SA/SEA Production of C. Prepare ISA Report Prepare HRA Report HIA fully documented in ISA EqIA fully documented in ISA CSA fully documented in ISA the draft LTP (separate output) Report (no separate output but Report (no separate output Report (no separate output but Review HIA component properly but EqIA component properly Community Safety component identified) identified) properly identified) Consultation on D. Consulting on ISA Report HRA Report sent to HIA Consultation included in EqIA Consultation included in CSA Consultation included in ISA draft LTP Review Natural England for ISA Report consultation ISA Report consultation Report consultation agreement on findings Production of D. Assess significant changes Assess significant changes HIA assessment of significant EqIA assessment of CSA assessment of significant final LTP Review changes undertaken as part of significant changes changes undertaken as part of SA/SEA undertaken as part of SA/SEA SA/SEA Adoption of LTP D. Post Adoption Statement Prepare updated HRA Relevant results reported in Relevant results reported in Relevant results reported in Post Review Screening Report Post Adoption Statement Post Adoption Statement Adoption Statement

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4.3. SA / SEA

4.3.1. Stage A - Setting the Context and Establishing the Baseline

Other Relevant Legislation, Plans and Programmes The Revised Draft LTP will both influence and be influenced by other plans, policies and programmes (PPPs) produced by local and combined authorities, by statutory agencies and other bodies with plan making responsibilities. Legislation is a further driver that sets the framework for the LTP, both directly and indirectly. Relevant legislation, plans and programmes have been identified and considered to inform the preparation of this ISA Report (see Chapter 5).

Baseline information and Key Sustainability Issues To predict accurately how potential Revised Draft LTP proposals will affect the current baseline, it is first important to understand its current state and then examine the likely evolution of the environment without the implementation of the plan. Baseline information provides the basis for understanding existing local environmental, economic and social issues, in particular in respect of health and equality, and alternative ways of dealing with them; formulating objectives to address these issues and predicting and monitoring sustainability effects.

Key sustainability issues in general, and those pertaining to health and equality in particular, across the north of England have been identified as a result of the analysis of the baseline data and the review of other plans and programmes. The identification of these issues helped focus the ISA processes on the aspects that really matter. Implications to Revised Draft LTP development and opportunities for how the Revised Draft LTP could assist in addressing these issues were also identified.

Information on key baseline and sustainability issues is presented in Chapter 6 of this report.

Developing the ISA Framework A set of ISA Objectives has been developed, against which the policies and proposals in the Revised Draft LTP could be assessed.

For each objective, assessment aid questions were set out to form the ISA framework. The assessment aid questions provided a clarification of the intended interpretation of each objective to support direction of change sought through the implementation of the Revised Draft LTP. The questions have guided the Revised Draft LTP’s assessment process.

The ISA Objectives and assessment aid questions were refined through the consultation on the Scoping Report and are presented in Chapter 7 of this report.

4.3.2. Stage B – Developing alternatives

Testing Revised Draft LTP Objectives against the ISA Objectives A compatibility assessment of Revised Draft LTP objectives in its initial stages of preparation against the ISA objectives was carried out, as part of the iterative process to assess the sustainability of Revised Draft LTP objectives. This assessment ensured that consideration of the ISA Objectives informed the development and refinement of the Revised Draft LTP Objectives and provided a suitable framework for developing alternatives (see Chapter 8 of this report).

Developing, refining and appraising Strategic Alternatives Consideration of alternative strategies for the Revised Draft LTP is an integral part of the plan development. Two strategic alternatives were identified by GCC and have been assessed as part of the ISA process.

This task comprised the prediction of changes arising from the LTP's alternative strategies. While carrying out this evaluation, each alternative was considered in the context of whether it would have a likely significant effect in relation to each of the ISA objectives. The results are presented in Chapter 9 of this report.

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Assessing the effects of the draft Revised Draft LTP Assessing the significance of predicted effects is essentially a matter of judgement. There are a number of factors that will determine the significance of an effect, e.g. its scale and permanence and the nature and sensitivity of the receptor. It is very important that judgements of significance are systematically documented, in terms of the particular characteristics of the effect which are deemed to make it significant and whether and what uncertainty and assumptions are associated with the judgement. The assessment of significance also includes information on how the effect may be avoided or its severity reduced.

In the current practice of IA (influenced by SEA), the broad-brush qualitative prediction and evaluation of effects can be often based on a qualitative seven point scale in easily understood terms. In general, this assessment has adopted the scale shown in Table 4-2 to assess the significance of effects of the schemes and proposals in the Transport Strategy.

Table 4-2 Criteria for Assessing Significance of Effects

Assessment Scale Assessment Category Significance of Effect

+++ Large beneficial Significant

++ Moderate beneficial

+ Slight beneficial Not Significant

0 Neutral or no obvious effect

- Slight adverse

-- Moderate adverse Significant

--- Strong adverse

? Effect uncertain

+/- Combination of slight beneficial and Not significant adverse effects

++ -- Combination of moderate beneficial Significant and adverse effects

Moderate and strong beneficial and adverse effects (and combination of this type of effect) have been considered of significance, whereas no effect and slight beneficial and adverse effects (and combination of this type of effect) have been considered non-significant.

Assessments have been undertaken for proposals contained in the Draft Revised Draft LTP. The results are discussed in Chapters 10 and 11.

As part of the assessment of the Draft Revised Draft LTP, a number of mitigation measures (recommendations) are set out in Chapter 12. GCC has given careful consideration to these recommendations and has addressed these as appropriate in the preparation of the Draft Revised Draft LTP for public consultation.

The term mitigation encompasses any approach that is aimed at preventing, reducing or offsetting significant adverse environmental effects that have been identified. A range of measures applying one or more of these approaches has been considered in mitigating any significant adverse effects predicted as a result of implementing the LTP. In addition, measures aimed at enhancing positive effects have also been considered. All such measures are generally referred to as mitigation measures.

However, the emphasis of the assessments has been in the first instance on proactive avoidance of adverse effects. Only once alternative options or approaches to avoiding an effect have been examined, then ways of reducing the scale/importance of the effect have been examined and proposed.

Mitigation can take a wide range of forms, including:

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 Refining intervention measures in order to improve the likelihood of positive effects and to minimise adverse effects;  Technical measures (such as setting guidelines) to be applied during the implementation stage;  Identifying issues to be addressed in project environmental impact assessments for certain projects or types of projects;  Proposals for changing other plans and programmes.

The assessment also considered cumulative, indirect (secondary) and synergistic effects of the Draft Revised Draft LTP as outlined in the following section.

Secondary and Cumulative Effects Assessment Annex I of the SEA Directive requires that the assessment of effects include secondary, cumulative and synergistic effects.

Secondary or indirect effects are effects that are not a direct result of the plan but occur away from the original effect or as a result of the complex pathway e.g. a development that changes a water table and thus affects the ecology of a nearby wetland. These effects are not cumulative and have been identified and assessed primarily through the examination of the relationship between various objectives during the Assessment of Effects.

Cumulative effects arise where several proposals individually may or may not have a significant effect, but in- combination have a significant effect due to spatial crowding or temporal overlap between plans, proposals and actions and repeated removal or addition of resources due to proposals and actions. Cumulative effects can be:

 Additive - the simple sum of all the effects;  Neutralising - where effects counteract each other to reduce the overall effect;  Synergistic - is the effect of two or more effects acting together which is greater than the simple sum of the effects when acting alone. For instance, a wildlife habitat can become progressively fragmented with limited effects on a particular species until the last fragmentation makes the areas too small to support the species at all.

Many sustainability problems result from cumulative effects. These effects are very hard to deal with on a project by project basis through Environmental Impact Assessment. It is at the strategic level that they are most effectively identified and addressed.

Cumulative effects assessment is a systematic procedure for identifying and evaluating the significance of effects from multiple activities. The analysis of the causes, pathways and consequences of these effects is an essential part of the process.

Cumulative (including additive, neutralising and synergistic) effects have been considered throughout the entire ISA process, as described below:

 Identification of key sustainability (including detailed health and equality) issues as part of the review of relevant strategies, plans and programmes and baseline data analysis.  Establishing the nature of likely cumulative effects, causes and receptors.  Identifying key receptors (e.g. specific wildlife habitats) in the process of collecting baseline information and information on how these have changed with time, and how they are likely to change without the implementation of the Revised Draft LTP.  Particularly sensitive, in decline or near to their threshold (where such information is available) or with slow recovery receptors have been identified through the analysis of environmental issues and problems.  The development of ISA objectives and assessment aid questions has been influenced by cumulative effects identified through the process above and ISA objectives that consider cumulative effects have been identified.  Cumulative effects of LTP proposals have been assessed.

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The results are presented in Chapter 13 of this report.

Monitoring the effects of the LTP implementation Monitoring involves measuring indicators which will enable the establishment of a causal link between the implementation of the plan and the likely significant effect (positive or negative) being monitored. It thus helps to ensure that any adverse effects which arise during implementation, whether or not they were foreseen, can be identified and that action can be taken by GCC, or partner bodies, to deal with them.

A monitoring programme has been prepared showing, for each significant effect, what data should be monitored, the source of the data, the frequency of monitoring, as well as when and what actions should be considered if problems are identified from the monitoring.

The results are presented in Chapter 14 of this report.

4.3.3. Stage C – Preparing the ISA Report This ISA Report has been prepared to accompany the draft Revised Draft LTP on consultation.

4.3.4. Stage D - Consulting on the Draft Revised Draft LTP and ISA Report

Assessing significant changes The ISA Report will be published for formal consultation with the Draft Revised Draft LTP. The results of the formal public consultation exercise may well result in changes to the Draft Revised Draft LTP and these will have implications for the ISA Report. In addition, the consultation exercise may result in direct changes to the contents of the ISA Report. These will be reported in the Post Adoption Statement.

Post Adoption Statement Following completion of the public consultation and preparation of the Final Revised Draft LTP document, a statement (separate document) will be prepared setting out the following:

 How sustainability considerations have been integrated into the plan, for example any changes to or deletions from the plan in response to the information in the ISA Report.  How the ISA Report has been taken into account.  How the opinions and consultation responses have been considered and addressed. The summary should be sufficiently detailed to show how the plan was changed to take account of issues raised, or why no changes were made.  The reasons for choosing the plan as adopted in the light of other reasonable alternatives dealt with.  The measures that are to be taken to monitor the significant environmental effects of implementation of the LTP.

4.4. HIA In order to ensure that potential impacts of the Revised Draft LTP on health and health inequalities have been considered and to fulfil the requirements of health legislation, an HIA has been undertaken in a fully integrated fashion with the SA/SEA process as set out in Table 4-1. The need for HIA arises from the recognition that the Revised Draft LTP proposals may impact on the factors influencing the health of communities and individuals, including such factors as noise and air quality, accessibility to key services and facilities and the design of transport infrastructure.

4.4.1. Approach to HIA The HIA objectives that have been considered have been developed in the light of HIA guidance and identified health issues, as well as the consultation that has taken place. The approach to the HIA has ensured that all relevant topics have been considered throughout the assessment process from establishing the baseline and building up the area’s population profile in terms of health, identifying the key issues, developing the ISA Framework, assessing the Revised Draft LTP, mitigation and monitoring.

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The HIA has identified actions that can enhance positive effects and reduce or eliminate negative effects of the Revised Draft LTP, with respect to health and health inequalities.

4.4.2. HIA consultation Consultation to inform the HIA has been undertaken as part of the overall SA/SEA process as outlined in Table 4-1. Consultation responses have been analysed to inform the HIA (see reporting and consultation as part of the ISA process).

4.5. EqIA In order to ensure that potential impacts of the Revised Draft LTP on equality have been considered and to fulfil legislative requirements, an EqIA has been undertaken in a fully integrated manner with the SA/SEA process.

4.5.1. Approach to EqIA The EqIA objectives that have been considered have been developed in the light of EqIA guidance and identified equalities issues, as well as the consultation that has taken place. The approach to the EqIA has ensured that all relevant topics have been considered throughout the assessment process from establishing the baseline and building up the area’s population profile in terms of equalities, identifying the key issues, developing the ISA Framework, assessing the Revised Draft LTP, mitigation and monitoring.

4.5.2. EqIA consultation Consultation to inform the EqIA has been undertaken as part of the overall SA/SEA process as outlined in Table 4-1. Consultation responses have been analysed to inform the EqIA (see reporting and consultation as part of the ISA process).

4.6. CSA To ensure that potential impacts of the Revised Draft LTP on community safety have been considered, and to fulfil legislative requirements, a CSA has been undertaken in a fully integrated manner with the SA/SEA process.

4.6.1. Approach to CSA The CSA objectives that have been considered have been developed in the light of CSA guidance and identified safety issues, as well as the consultation that has taken place. The approach to the CSA has ensured that all relevant topics have been considered throughout the assessment process from establishing the baseline and building up the area’s population profile in terms of crime and safety, identifying the key issues, developing the ISA Framework, assessing the Revised Draft LTP, mitigation and monitoring.

4.6.2. CSA consultation Consultation to inform the CSA has been undertaken as part of the overall SA/SEA process as outlined in Table 4-1. Consultation responses have been analysed to inform the CSA (see reporting and consultation as part of the ISA process).

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5. Review of Legislation and other Plans and Programmes

5.1. Introduction The first task of the ISA is the identification of other relevant plans, policies, programmes and legislation. This helps to identify relevant environmental and wider sustainability themes, baseline information and key issues. The LTP must be prepared to take these PPPs into account as it may influence and be influenced by them.

The SEA Directive specifically states that information should be provided on:

"The relationship [of the plan or programme] with other relevant plans and programmes"

"The environmental protection objectives, established at international, [European] Community or [national] level, which are relevant to the plan or programme and the way those objectives and any environmental considerations have been taken into account during its preparation"

In addition to this, the PPPs related to wider sustainability, HIA, EqIA and CSA have also been considered.

5.2. Methodology Both the LTP and the ISA Report should be set in the context of international, national, regional and local objectives along with environmental, strategic planning, transport, health, social, economic and equality policies.

Relevant plans and programmes include those at different levels (international, national, regional and local) which influence the Transport Plan, or those in other sectors which contribute, together with the Transport Plan, to sustainability conditions of the area to which they apply.

Appendix B lists the documents reviewed to identify environmental, social (health and equality) and economic themes. A series of key generic themes which have emerged from the review are presented below.

Environmental Themes The review of the PPPs revealed a large number of common themes in terms of their objectives relating to sustainability within the context of transport planning.

Climate Change and Energy  Reduce energy consumption and energy wastage;  Reduce GHG emissions, particularly carbon dioxide;  Maximise the use of renewable energy;  Increase energy efficiency and make use of new and clean technologies;  Minimise the use of fossil fuels;  Need for measures to adapt to climate change.

Transport  Promote mixed-use development policies to reduce the need to travel;  Improve local air quality through minimising traffic related emissions;  Encourage walking, cycling and the use of public transport;  Reduce traffic congestion and improve safety for all road users;  Promote sustainable alternatives to car travel;  Promote viable alternatives to road haulage, such as shipping and rail;  Promote clean vehicle technology;  Connect key regeneration sites;

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 Promote integration, maintain and improve the public right of way and wider access network;  Connect the area to the wider regional, national and international networks.

Natural Resources and Waste  Ensure efficient resource use and minimise resource footprint;  Raise awareness of resource use/depletion;  Use secondary and recycled materials;  Consider opportunities to maximise on-site re-use of materials;  Employ waste reduction methods to minimise construction and maintenance waste;  Reduce the amount of waste disposed of at landfill.

Land  Brownfield/Greenfield hierarchy of land use;  Minimise and seek to reclaim derelict and contaminated land whilst taking into account any biodiversity interests;  Protect farmland and soils.

Water  Improve the quality of ground and surface water;  Improve the biological and chemical quality of rivers;  Make use of vegetated drainage systems and 'Sustainable Urban Drainage Systems';  Minimise the risk and impact of flooding by controlling surface water management and floodplain management;  Prevent inappropriate development in floodplains;  Prepare for impacts of climate change, including sea level rise, coastal squeeze and coastal erosion.

Biodiversity  Contribute to the delivery of local and national Biodiversity Action Plans;  Protect and enhance endangered species, habitats and geodiversity, including sites of geological importance;  Protect and enhance existing wildlife and provide opportunities for new habitat creation  Increase tree cover and ensure the sustainable management of existing woodland;  Protect, maintain and where possible enhance natural habitat networks and green infrastructure, to avoid fragmentation and isolation of networks;  Protect and enhance designated nature conservation sites of international importance (SPA/SAC) and national importance (SSSI);  Promote access and understanding of nature and biodiversity.

Landscape  Protect and enhance landscape and townscape character and local distinctiveness.

Heritage  Help to conserve historic buildings through sympathetic design;  Conserve, protect and enhance designated and non-designated historic assets;  Improve access to buildings and landscapes of historic/cultural value;  Use architectural design to enhance the local character and "sense of place" of development;  Protect local distinctiveness.

Economic Themes  Improve physical accessibility of jobs through the location of employment sites and transport links close to areas of high unemployment.  Widen the number and range of accessible employment opportunities.  Improve rail and road journey reliability for business users.  Support local businesses.

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Social Themes (Health, Equalities and Community Safety) Safety  Promote design that discourages crime and fear of crime e.g. by reducing hiding places or escape routes;  Address anti-social behaviour.

Community services and amenities  Provide or improve access to local health and social care services;  Provide or improve physical accessibility of education facilities and training opportunities;  Provide information and advice to the community on the transport services and initiative available.

Pollution  Reduce light pollution;  Reduce noise pollution and protect tranquillity;  Minimise dust, odours, litter.

Open Space  Ensure the protection, maintenance, enhancement (including creation) of, and access to green spaces, and the wider multi-functional green infrastructure network including the wider countryside; and  Improved public spaces.

Health The derived key health-related themes are:

 Improve health in the UK and globally, taking account of the diverse factors influencing health, such as climate change, pollution, conflict, environmental degradation and poverty;  Tackle poor health by improving the health of everyone, and of the worst off in particular;  Reduce health inequalities among different groups in the community (e.g. young children, pregnant women, black and minority ethnic people; older people, people with disabilities; low income households);  Support the public to make healthier and more informed choices with regard to their health and adopt physically active lifestyles;  Address pockets of deprivation;  Provide physical access for people with disabilities;  Provide or improve access to local health and social care services;  Provide opportunities for increased exercise, thus reducing obesity, particularly in children, and illnesses such as coronary heart disease;  Provide for an ageing population;  Promote healthy lifestyles through exercise, physically active travel and access to good quality and affordable food, which can assist in reducing both physical and mental illnesses.

Equality The derived key equality-related themes are:

 Protect human rights (e.g. the right to liberty and security of person) and fundamental freedoms (e.g. a right to freedom of thought, conscience and religion, freedom of expression, etc);  Prohibit discrimination, harassment and victimisation on such grounds as sex, race, language and religion;  Promote equality of opportunity in the way services are planned, promoted and delivered;  Treat everyone with dignity and respect;  Recognise people's different needs, situations and goals and removes the barriers that limit what people can do and can be;  Create sustainable communities which are active, inclusive, safe, fair, tolerant and cohesive;  Create sustainable communities which are fair for everyone - including those in other communities, now and in the future;  Improve economic, social and environmental conditions particularly in the most deprived areas;

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 Ensure fair access to and distribution of resources across the community;  Assess and address the impacts upon diverse communities including cultural, racial, economic, generational, social (including disabilities) and religious mixes;  Create a sense of belonging and wellbeing for all members of the community;  Provide physical access for people with disabilities;  Minimise isolation for vulnerable people.

Community Safety The derived community safety related themes are:

 Create communities which are safe, inclusive, fair, tolerant and cohesive;  Maintain reductions in crime and anti-social behaviour; and  Improve perception that the communities are safe places to work, live and visit.

5.3. Recent relevant PPPs Recent PPPs of particular relevance to the ISA are:

5.3.1. The 25 Year Environment Plan The 25 Year Environment Plan published by government in 2018 sets an ambitious roadmap to improve the environment within a generation. Challenging goals and targets have been set, in particular the ultimate goals of net environmental gain and net biodiversity gain. The Plan includes a key commitment to embed an ‘environmental net gain’ principle for development, including housing and infrastructure. The Government’s 25-Year Environment Plan states: “We want to establish strategic, flexible and locally tailored approaches that recognise the relationship between the quality of the environment and development. That will enable us to achieve measurable improvements for the environment – ‘environmental net gains’ – while ensuring economic growth and reducing costs, complexity and delays for developers”.

The Plan further supports that the planning system should provide biodiversity net gains where possible, which the Government would like to make mandatory: The plan states that “current policy is that the planning system should provide biodiversity net gains where possible. We will explore strengthening this requirement for planning authorities to ensure environmental net gains across their areas and will consult on making this mandatory – including any exemptions that may be necessary. This will enable those authorities to develop locally-led strategies to enhance the natural environment, creating greater certainty and consistency and avoiding increased burdens on developers, including those pursuing small-scale developments. We would expect this should have a net positive impact on overall development”. “We want to expand the net gain approaches used for biodiversity to include wider natural capital benefits, such as flood protection, recreation and improved water and air quality. They will enable local planning authorities to target environmental enhancements that are needed most in their areas and give flexibility to developers in providing them.”

The Government have also stated in the 2019 spring statement that biodiversity net gain will be made mandatory within the forthcoming Environment Bill expected in Autumn 2019.

5.3.2. National Planning Policy Framework (NPPF) 2019 The National Planning Policy Framework (NPPF) sets out the Government’s planning policies for England and how these are expected to be applied by Local Authorities within their Local Development Frameworks (LDF). The revised National Planning Policy Framework was published in February 2019.

The NPPF provides a framework upon which local planning authorities can develop and adopt local plans for the purposes of determining an application for planning made under the Town and Country Planning Act 1990. A decision on whether to grant planning permission must be made “in accordance with the development plan unless material considerations indicate otherwise” meaning that the NPPF is a material consideration in such planning decisions.

An important function of the NPPF is to embed the principles of sustainable development within local plans prepared under it.

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Chapter 15 of the revised NPPF ‘Conserving and enhancing the natural environment’ sets out the requirements to consider biodiversity net gain in planning decisions. Paragraph 170 states: “Planning policies and decisions should contribute to and enhance the natural and local environment by: […] minimising impacts and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures.”

5.3.3. Climate Change Act 2008 and 2019 Amendment The Climate Change Act 2008 makes it the duty of the Secretary of State to ensure that the net UK carbon account for all six Kyoto greenhouse gases for the year 2050 is at least 80% lower than the 1990 baseline, toward avoiding dangerous climate change. The Climate Change Act 2008 (2050 Target Amendment) Order 2019 amends the 2050 greenhouse gas emissions reduction target in the Climate Change Act from at least 80% to at least 100%. The amendment has the effect that the minimum percentage by which the net UK carbon account for the year 2050 must be lower than the 1990 baseline is increased from 80% to 100%. This target is otherwise known as ‘net zero’ emissions.

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6. Baseline Information and Key Sustainability Issues

6.1. Introduction The SEA Directive states that the Environmental Report should provide information on:

"relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan" and the "environmental characteristics of the areas likely to be significantly affected" (Annex I (b) (c)) and

"any existing environmental problems which are relevant to the plan or programme including, in particular, those relating to any areas of a particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC (Birds Directive) and 92/43/EEC (Habitats Directive)" (Annex I (c)).

To accurately predict how LTP proposals will affect the environmental characteristics, it is important to understand the current state of the environment and then examine the likely evolution of the environment without the implementation of the plan. In this report, given its remit is broader than environmental sustainability, the current state regarding wider sustainability (environment, social and economic) has been characterised.

6.2. Methodology Existing baseline information provides the basis for the prediction and monitoring of the effects of the implementation of the Revised Draft LTP and helps identify sustainability issues and alternative ways of dealing with them (implications and opportunities).

As ISA is an iterative process, subsequent stages in its preparation and assessment might identify other issues and priorities that require the sourcing of additional data and/or information and identification of monitoring strategies. This makes the ISA process flexible, adaptable and responsive to changes in the baseline conditions and enables trends to be analysed over time.

The most efficient way to collate relevant baseline data is through the use of indicators whenever possible (see below). This ensures that the data collation is both focused and effective. The identification of relevant data has taken place alongside the review of other relevant legislation, plans, policies and programmes (Section 5 and Appendix B), the identification of sustainability issues (this section) and developing the ISA framework (Section 8).

6.3. Data Analysis Data have been collated and analysed as part of the identification of key sustainability issues as follows:

6.3.1. Environmental Data  Local air quality (NOx, PM10, AQMA)  CO2 emissions  Climate change  European sites (SAC, SPA)  Ramsar sites  SSSI  Key Wildlife Sites  RIGS  Geological SSSI

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 Geoparks  AONB  National Forest Park  National Character Areas  County Parks  Listed Buildings  Scheduled Monuments  Registered Parks and Gardens  Conservation Areas  River Catchments  Water Quality  Source Protection Zones  Green space  Agricultural Land  Flood risk  Natural resources

6.3.2. Economic Data  Transport network  Employment  Long term trends in GVA  Long term trends in population  Economic sectors, including those related to rural output

6.3.3. Health, Equalities and Community Safety  Population and diversity  General health statistics  Accessibility  Road safety and accidents  Physical activity in children and adults  Equality target groups  Multiple deprivation

6.4. Data Limitations It is believed that the data sets available provide a comprehensive overview of the sustainability situation across Gloucestershire.

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6.5. Key sustainability baseline, issues and implications/ opportunities The following sections provide a description of key baseline data and associated sustainability issues together with a discussion on the implications/opportunities of such issues to the Revised Draft LTP. The analysis of baseline data and sustainability issues has influenced the development of the ISA Framework (see Section 7) in terms of formulating sustainability objectives and assessment aid questions.

It should be noted that, because HIA, EqIA and CSA are also being undertaken, the approach involved the identification of generic HIA, EqIA and CSA key sustainability issues, implications and opportunities and objectives. These have been further developed to ensure a more in-depth level of coverage of issues to satisfy specific HIA and EqIA requirements leading to the development of HIA and EqIA sub-objectives (see section 6.6).

6.5.1. Air quality Key baseline and sustainability issues

Air quality in Gloucestershire is relatively better compared to some other counties due to its rural nature. There are 8 declared AQMAs in Gloucestershire. The largest proportion of air pollution in Gloucestershire arises from road traffic within the County; both Gloucester City and Cheltenham Borough exhibit significantly higher concentrations of pollutants associated with road traffic. The busiest routes of the Gloucestershire county with over 1000 HGV’s alone in a working day include sections of A40, A48, A417, M50, M5, A46, A438, A435, A43114.

Nitrogen dioxide (NO2) emissions are of particular concern and PM10 emissions are also a major issue. PM10 estimates show the highest concentrations are in the North Gloucester region, Cheltenham and around Gloucestershire Airport.5

Gloucestershire is expected to meet requirements of the European Union Air Quality Directive and set air quality standards for air pollutants. Poor air quality can have adverse consequences across many areas but is most closely linked to negative impacts on human health and biodiversity.

Air Quality Management Areas (AQMAs), where national standards are not being achieved, have been established across all the Gloucestershire local authorities and their boundaries tend to reflect the motorway network or traffic bottlenecks. There are eight AQMAs in total6. Four of the AQMAs are located within the Central Severn Vale CPS area. The entire borough of Cheltenham is designated as AQMA. Forest of Dean District Council has designated an AQMA in Lydney. This includes parts of the A4231 and parts of Bream Road and Forest Road in Lydney. Cotswold District Council has designated two areas, one encompassing the junction of the A417 and A436 at the Birdlip (Air Balloon) roundabout, including nearby properties, and the second along the Thames Street on A361 as AQMAs.

There are likely to be increases in air pollution in Gloucestershire as a result of new housing and employment allocations in the Gloucester, Cheltenham and Tewkesbury Joint Core Strategy 20177, in the Draft Tewkesbury Borough Plan 2011-2031, Stroud District Local Plan, Draft Gloucester City Plan 2016-

4 Draft Minerals Local Plan for Gloucestershire (2018-2032) Pre-Publication Consultation Draft (Sustainability Appraisal including Strategic Environmental Assessment, Pg-24

5 http://glostext.gloucestershire.gov.uk/documents/s46091/Appendix%20A%20- %20Air%20Quality%20and%20Health%20in%20Gloucestershire%20Report.pdf

6 Review of Air Quality and Health in Gloucestershire, Published- 26.01.2018.; http://glostext.gloucestershire.gov.uk/documents/s46091/Appendix%20A%20- %20Air%20Quality%20and%20Health%20in%20Gloucestershire%20Report.pdf

7 https://www.jointcorestrategy.org/adopted-joint-core-strategy

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2031, Forest of Dean Core Strategy, and Cotswold District Local Plan 2011-2031.

A Gloucestershire Air Quality and Health Strategy8 has been developed to improve air quality in Gloucestershire. Note this strategy is being integrated with the Gloucestershire LTP Review.

There are habitats of ecological value, notably designated sites of nature conservation importance adjacent to key transport routes and AQMAs. For example: the Lydney AQMA has been designated along parts of the B4231 (High Street, Hill Street and Newerne Street) and parts of Bream Road and Forest Road in Lydney. There are numerous internationally and nationally designated nature conservation sites clustered in the Wye Valley, the Severn Estuary and the Forest of Dean9. The Cotswold Beechwoods SAC is already experiencing poor air quality (NOx especially) that is likely to affect its ecological interest.

Implications/Opportunities for LTP Review

The LTP Refresh should:

- ensure that reducing NO2 and PM10 emissions is a fundamental principle of the Plan and acts to bolster the Gloucestershire Air Quality and Health Strategy as appropriate.

- aim to meet local and national objectives and targets for air quality and be reflective of appropriate legislation, including the Habitats Regulations/Directive, which protects European Sites (see also Biodiversity below).

- encourage measures to reduce road transport emissions which include: promotion of sustainable modes of transport, traffic engineering solutions, road work improvements to enhance capacity and hence improve traffic speed, upgrade of public transport facilities to cleaner technologies, smarter travel management such as workplace, residential and school travel plans, creation of inter-modal interchanges, sustainable freight movements and traffic management interventions and the creation of clean air zones.

- promote the uptake of innovative ultra low-emission vehicle (ULEV) technologies and support the creation of EV charging infrastructure.

- consider ecological receptors (such as the air quality sensitive wetland and heath habitats) alongside human receptors when dealing with air quality.

- promote enhancements to green infrastructure networks as they play an important role in alleviating airborne pollution.

- limit the in-combination effects of new development areas in Gloucestershire on air quality, especially near AQMAs.

ISA Objective

Improve air quality.

8 http://glostext.gloucestershire.gov.uk/documents/s52324/Gloucestershire%20Air%20Quality%20and%20Health%20Strategy%20v.%204 .pdf

9 Environmental Report – Strategic Environmental Assessment of Gloucestershire’s Local Transport Plan 2015 – 2031, March 2015 , Page - 31

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6.5.2. Carbon dioxide emissions Key baseline and sustainability issues

Transport results in a quarter of UK’s carbon dioxide (CO2) emissions, with road transport being the major source.

The Climate Change Act 2008 established a legally binding target to reduce the UK’s ‘net’ greenhouse gas emissions by at least 80% below base year (1990) levels by 2050 and contribute to global emission reductions to limit global temperature rise to as little as possible above 2°C. Since the Climate Change Act was enacted, the Paris Agreement has been signed and ratified by the majority of the world’s Governments. This reflects more recent scientific evidence and commits signatories “to pursue efforts to limit the temperature increase to 1.5°C above pre-industrial levels.” as opposed to 2°C above pre- industrial levels as set out in the Act. The Climate Change Act was amended in May 2018 to reflect the lower limit temperature increase of 1.5°C in the Paris Agreement, effectively resulting in a net zero target by 2050 against 1990 levels.

Under the Act, the UK has so far set five “carbon budgets”. These set interim five-year caps on emissions from 2008 to 2032. The UK is currently in the third budget period (2018 to 2022). The UK has succeeded in meeting the first two budget periods and is on track to meet the third. However, it is not on track to meet the fourth budget period (2023 to 2027).

UK Carbon Budgets Budget number Time-period Carbon Budget Level Reduction below 1990 levels

1 2008-2012 3,018 MtCO2e 25%

2 2013-2017 2,782 MtCO2e 31%

3 2018-2022 2,544 MtCO2e 37% by 2020

4 2023-2027 1,950 MtCO2e 51% by 2025

5 2028-2032 1,725 MtCO2e 57% by 2030

In May 2019, Gloucestershire declared a climate emergency in the county and committed to become carbon neutral by 2050 (in alignment with recent changes in government climate change policy) and to a 80% reduction in the Council’s corporate carbon emissions by 203010. Carbon neutrality implies the use of carbon capture and sequestration techniques such as planting trees.

Gloucestershire, transport accounts for 36.6% of all CO2 emissions (per capital tCO2) below the national figure of 44.6%.8 Nationally, greenhouse gas emissions for transport account overall to 27%, of that figure; road passenger cars account for 55%, HGVs 16.4%, LGVs 15.4% and buses 2.6%, as opposed to railways 1.5% (by source 2017).9

A growing population and increasing traffic and congestion will require a step change in travel modes, including significant mode shift in combination with a dramatic rise in the use of clean emission vehicles if GCC wants to fulfil its target for carbon reduction by 2030 and be carbon neutral by 20507.

New housing and employment growth in Gloucestershire has the potential to increase carbon emissions from transport. The Joint Core Strategy 2017 (JCS) provides for ‘major growth’ around Gloucester,

10 https://www.gloucestershire.gov.uk/gloucestershire-county-council-news/news-june-2019/county-council-leads-on-climate-action/

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Cheltenham and Tewksbury of around 30,000 homes and associated employment. The LTP3 Review in conjunction with the JCS assesses that emissions would increase in approximately 62% of the county11.

Implications/Opportunities for LTP Review

The LTP Review should:

- ensure that reducing CO2 emissions is a core component of all implementation plan elements. This could be achieved via promotion of sustainable modes of transport (as opposed to the private car) including innovative low carbon technology for mass transit and city-wide commuting, use of electric or hybrid vehicles with the provision of electric charging facilities (from green energy sources), low-carbon sources of public transport services and its corresponding infrastructure (such as electrification and hydrogen fuel cell power)smarter travel management such as workplace, residential and school travel plans, creation of inter-modal interchanges, sustainable freight movements and traffic management interventions.

- consider a more rapid electrification of public transport services and its corresponding infrastructure to increase energy saving technologies and reduce transport emissions (assuming a shift in the production of centralised energy production by renewables or other low carbon energy source). In particular, rail electrification would contribute to decarbonisation of both public transport (i.e. passenger services) and freight movements in Gloucestershire. There are opportunities to reduce carbon emissions from freight, both i) by encouraging modal shift from road to rail (first priority); and ii) by supporting the phasing out of diesel traction for rail freight haulage, in favour of traction powered by electric or alternative sustainable fuel sources.

- ensure that new schemes maximise the opportunity for increasing tree /vegetation cover and other green infrastructure, where practical, in order to absorb increased amounts CO2. This will also include offsetting any carbon emissions that cannot be mitigated.

ISA Objective

Reduce carbon dioxide emissions from transport.

6.5.3. Biodiversity Key baseline and sustainability issues

Gloucestershire is a highly diverse county. The county fits into three key Natural Areas - the acid grasslands, bogs, heaths and ancient woodlands in the Forest of Dean and Wye Valley12; the Severn Vale and its floodplain habitats which are important for bird-life, especially wintering wildfowl and breeding waders; and the Cotswolds with its limestone grasslands and beech woodlands.13

Sites are designated for nature conservation purposes at the International (European), National (UK) and Local level across the GCC area and in neighbouring regions. There are 10 International/European sites in and close to Gloucestershire146. Within the Gloucestershire area there are 7 recognised Special Areas

11 Environmental Report: Strategic Environmental Assessment of Gloucestershire’s Local Transport Plan 2015-2031

12 Summary of the Biodiversity Action Plan for Gloucestershire, Page- 2, (https://docs.wixstatic.com/ugd/2d7e8a_96b40a094d23477c8c7efa96a838f655.pdf)

13 https://docs.wixstatic.com/ugd/2d7e8a_96b40a094d23477c8c7efa96a838f655.pdf

14 Environmental Report – Strategic Environmental Assessment of Gloucestershire’s Local Transport Plan 2015 – 2031, March 2015 , Page - 31

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Gloucestershire Local Transport Plan Review Integrated Sustainability Appraisal Report of Conservation (SAC) and two SPA/Ramsar sites15. Gloucestershire’s national nature conservation designations include 123 Sites of Scientific Interest (SSSIs), notified for their biological and / or geological interest.16 Gloucestershire has 3 Areas of Outstanding Natural Beauty (AONB) – the Cotswolds, Malvern Hills and the Wye Valley17. Gloucestershire has 11 Local Nature Reserves18.

In total, there are nearly 800 recognised Key Wildlife Sites in Gloucestershire with more than 100 sites located over or adjacent to a road. New illuminated transport infrastructure has the potential to affect the behaviour of nocturnal species such as bats and foraging and breeding birds11.

The transport infrastructure can lead to potential loss of protected species and habitat loss/deterioration, and/or fragmentation due to land uptake.

The highways network supports habitats and protected species which have the potential to be affected by LTP3 Review proposals19. The Gloucestershire Highways Biodiversity Guidance20 provides an overview of the protected species present on or adjacent to road corridors and the key sensitivities related to the sensitive species present near the route corridors such as nesting birds, roosting bats, badgers, etc.

New illuminated transport infrastructure has the potential to affect the behaviour of nocturnal species such as bats and foraging and breeding birds. The land uptake in areas of limestone grassland and many types of woodland, can significantly affect the biodiversity in the county.

New transport projects have the potential to impact on the sites of ecological value through direct land uptake for infrastructure and construction and operational disturbance (noise, vibration, light pollution etc.) and emissions / contamination (air, water & soil). Increased accessibility to designated sites also has the potential to adversely impact on them. Direct road kill can also impact on some local species populations.

However, well considered transport infrastructure scheme could also make a positive contribute to the county’s biodiversity by way of improving accessibility to existing sites and enhancing or introducing new assets through sensitive exposure and management of features.

Key threats have been identified from air pollution and climate change, which can change distribution of species and habitats as well as provide opportunities for invading species from outside the county and the UK. Species such as the water vole are on the verge of extinction due to these threats13.

Implications/Opportunities for LTP Review

The LTP Review should:

- protect and enhance biodiversity in general and place a particular emphasis on protecting sites designated for nature conservation purposes. This could be achieved by ensuring that planning / design of transport interventions avoid sensitive areas and through the adoption of best practice wildlife friendly designs into road interventions. Where this is not possible, there should be mitigation and compensation for losses.

15 Joint Nature Conservation Committee Listing of Special Areas of Conservation". DEFRA. Retrieved 22.08.2019.

16 http://glostext.gloucestershire.gov.uk/documents/s43528/Item%206%20-%20Minerals%20Local%20Plan%202018- 2032%20Document.pdf

17 Joint Nature Conservation Committee – UK Ramsar Sites (Retrieved 27.08.2019). http://archive.jncc.gov.uk/default.aspx?page=1389

18 https://www.gloucestershire.gov.uk/media/5918/amr_2012-2013-62599.pdf and https://magic.defra.gov.uk

19 Environmental Report Appendix A : Context Review and Baseline Data, Strategic Environmental Assessment of Gloucestershire’s Local Transport Plan 2015-2031

20 https://www.gloucestershire.gov.uk/highways/plans-policies-procedures-manuals/biodiversity-and-highways/

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- explore opportunities for new habitat creation and enhancement associated with transport and associated infrastructure development, e.g. through the use of appropriate locally native species in landscaping plans, through creation of new road verges without use of top soil so as to reduce fertility, and enhancement of the existing road verge network by well-timed mowing and removal of arisings where possible.

- avoid the fragmentation of green infrastructure, which contributes to protecting natural habitats and biodiversity and helps habitats and species adapt to the consequence s of climate change.

- enhancement of the green infrastructure through, for example, vegetation along foot paths, cycle lanes and other public rights of ways. Increased accessibility to appropriately designed multifunctional green infrastructure can play a significant role in diverting access pressure away from more sensitive sites.

- achieve biodiversity net gain through highway schemes and associated development linking in to the highway network.

- In parallel with the ISA of the LTP a Review of a Habitats Regulation Assessment (HRA) is being undertaken which will identify the European/internationally designated nature conservation areas to avoid, or where this is not possible, consider appropriate mitigation measures in the development of the LTP Review.

ISA Objective

Protect and enhance protected habitats, sites, species, valuable ecological networks and promote ecosystem resilience and functionality.

6.5.4. Geodiversity Key baseline and sustainability issues

Geodiversity conservation concerns the protection, management and enhancement of geological formations for which advice is available through the Gloucestershire Geology Trust.

Gloucestershire contains some of the most varied geology within the U.K. This has given rise to a wide range of scenic features for which the county is renowned, including the escarpment of the Cotswolds, the Forest of Dean, May Hill, the deep gorge of the Wye Valley and the low-lying area of the Severn Vale21. The county is split roughly into two parts, both physically and geologically, by the River Severn. In 2014 there were more than 164 RIGS identified, surveyed and recorded throughout Gloucestershire.22. In total, there are 31 Geological SSSI’s within the Gloucestershire Cotswolds region. Additionally, there are 36 GCR (Geological Conservation Review Series) sites within the Cotswolds AONB area, all of which are designated as SSSI’s, displaying sediments, rocks, fossils, and features of the landscape21. Also, two nationally designated Geoparks fall within Gloucestershire – Cotswold Hills and Abberley & Malvern Hills.

New or improved transport infrastructure could result in the destruction or degradation of valued geological features that contribute to the county’s geodiversity interest. However, well considered transport infrastructure scheme could also make a positive contribute to the county’s geodiversity by way of improving accessibility to existing sites and enhancing or introducing new assets through sensitive exposure and management of features, where opportunities arise from new cuttings etc.

Implications/Opportunities for LTP Review

21 Gloucestershire Cotswolds – Geodiversity Audit & Local Geodiversity Action Plan (LGAP), 2005, (http://www.glosgeotrust.org.uk/downloads/Cotswolds%20LGAP.pdf )

22 https://www.gloucestershire.gov.uk/media/5918/amr_2012-2013-62599.pdf

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The LTP Review should:

- Seek to protect and enhance designated sites of geodiversity interest;

- Seek to support opportunities to increase accessibility to sites of geodiversity interest;

- Seek to support opportunities to introduce new geodiversity assets into the county.

ISA Objective

Protect, enhance and promote geodiversity.

6.5.5. Landscape and Townscape Key baseline and sustainability issues

Gloucestershire has one of the most diverse landscapes in England. Landscape Character Assessments have been produced for Stroud District, Forest of Dean, Cotswolds AONB and Cotswold Water Park. The combined landscape character assessment for the whole of Gloucestershire has identified a total of 38 landscape character types23. This unusually large number of types for a county wide assessment reflects the great diversity of the Gloucestershire’s landscape as a consequence of the remarkable range of the underlying geology and the pattern of social, economic and cultural responses to this diversity.

Gloucestershire is divided into three distinct regions, as follows:

- The Cotswolds and The Cotswold Escarpment; - The Royal Forest of Dean; and - The Severn Vale.

Although countryside accounts for 90% of Gloucestershire the remainder is made up of the county’s villages, towns and cities. Gloucester is the county’s capital, of note for its Norman cathedral and restored docks. Other towns include Cheltenham, renowned for its Regency architecture, Tewkesbury and Stroud.

Much of Gloucestershire has been designated as AONB, in national recognition of its special landscape qualities, and includes:

- Cotswolds AONB - Wye Valley AONB - Malvern Hills AONB

Of note the Forest of Dean was England’s first National Forest Park.

England has been mapped into a series of 159 National Character Areas (NCAs). Gloucestershire’s landscape mainly falls within NCA 105, Forest of Dean and Lower Wye; NCA 106, Severn and Avon Vales; and NCA 107, Cotswolds24

There are a number of Country Parks spread across the Gloucestershire region, 6 of which were awarded Green Flag status in 2019.

Much of the urban landscape and townscape is closely linked to the historical development and cultural heritage of the conurbation, including potential archaeological assets. Listed buildings, conservation areas and other heritage/ archaeological assets including historic waterways are important features of

23 https://www.gloucestershire.gov.uk/planning-and-environment/ecology-and-landscape/landscape/

24 http://www.cpreglos.org.uk/news/item/2129-landscapes

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Gloucestershire Local Transport Plan Review Integrated Sustainability Appraisal Report townscapes within Gloucestershire and help to provide the conurbation and distinct settlements within it with a sense of identity. As well as the sense of place contributing to identity the historic character of the countryside, city, towns and villages are a main attraction of tourists to Gloucestershire. Of note there are 14 Conservation Areas in Gloucester alone25.

Implications/Opportunities for LTP Review

The LTP Review should:

- Seek to preserve and enhance the character of Gloucestershire’s landscape, townscape and rural communities by ensuring that its integrity and valuable natural open space is not lost.

- Ensure that transport interventions avoid sensitive areas and respect particular landscape or townscape settings.

- Explore opportunities for landscape and townscape enhancement, e.g. through sympathetic design and materials, and enhancements to existing landscape improvement areas, new planting opportunities associated with transport development.

- Preserve and improve tranquil and dark sky areas especially in rural areas and in particular AONBs.

ISA Objective

Protect and enhance the character and quality of landscapes and townscapes and visual amenity.

6.5.6. Historic Environment Key baseline and sustainability issues

This term encompasses more than just individual heritage features and includes the landscape in which these are located. Transport can impact on the setting of features within the landscape and can cause for example issues such as severance. There can also of course, be direct impacts on cultural heritage features themselves through noise and vibration and pollution.

Gloucestershire contains a wide range of historic and cultural heritage. Neolithic long barrows display the origins of the Cotswold drystone walling tradition 6000 years ago, Iron Age hillforts give an indication of violent times as well as spectacular views, Roman villas such as Witcombe demonstrate the long-term agricultural prosperity of the area. There are huge numbers of notable buildings across the region including Gloucester Cathedral and the parish churches, such as Fairford, Tewkesbury, Elkstone, Deerhurst, Highnam, Newland and Kempley. Secular architecture includes the castles at Sudeley and Berkeley, tithe barns such as Ashleworth, medieval and later country houses of all sizes, and the vernacular homes of the villages that are loved by residents and visitors alike.

Other features of cultural heritage include Scheduled Monuments, Registered Parks and Gardens, and Listed Buildings and Conservation Areas.

Gloucester in particular is comparable in quality to other top-level historic cities in the UK. Its historic buildings and areas are part of the infrastructure of the modern city. In reflection of this heritage, Gloucester produced Gloucester Heritage Strategy 2019-29 Conservation, Regeneration, Engagement26.

25 https://www.gloucester.gov.uk/planning-development/conservation-regeneration/conservation-areas/

26 https://www.gloucester.gov.uk/media/3424/heritage-strategy-final-high-quality-version-002.pdf

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27. Within which it notes that that transport infrastructure, including choice of sustainable modes of transport, linking the historic core to the wider City and beyond is a key element of using heritage to create a vibrant, competitive, resilient and sustainable historic City Centre.

Gloucester Docks history extends over 200 years and represents the most inland port in England. It is located along the Gloucester and Sharpness Canal and River Severn and hosts a national museum operated by the Canal and River Trust. The Gloucester and Sharpness Canal was once the broadest and deepest in the world28 and extends for 16 miles. It is also connected with the Stroudwater Navigation (under restoration) at Saul Junction.

Cotswold District has one of the richest resources of historic environment or heritage assets of any area in England. Heritage assets are both designated (listed buildings, conservation areas, registered parks and gardens and scheduled ancient monuments etc) and non-designated. 29

Tewkesbury presents one of the best medieval townscapes in England with its fine half-timbered buildings, overhanging upperstoreys and elaborate carved doorways. Most of the town lies within the Tewkesbury Conservation Area, over 350 of the buildings are listed of being of special architectural or historic interest. Coaching traffic brought prosperity to Tewkesbury up until the mid 19th century when the advent of the railways bypassed the town and the Industrial Revolution had little impact.30 In 1964 The Council of British Archaeology listed it amongst 57 towns "so splendid and so precious that the ultimate responsibility for them should be of national concern"31.

Cheltenham’s major assets is its Regency heritage. This fine architectural legacy is protected in part by the Cheltenham (Central) Conservation Area, covering over 600 hectares. There are seven conservation areas in Cheltenham:

 Cheltenham (Central) Conservation Area (SPD);  Prestbury Conservation Area (SPG);  Swindon Village Conservation Area (SPD);  St. Mary’s Conservation Area (Charlton Kings) (SPG);  Cudnall Street Conservation Area (Charlton Kings) (SPG);  Bafford Conservation Area (Charlton Kings) (SPG);  The Poets (St. Mark’s) (SPG)32.

Swindon Village Conservation Area contains 19 Grade II listed buildings and structures, 1 Grade II* listed building and some local listed buildings/structures. The conservation area is special because:

 The village has a long history dating back to the 10th Century. The Church of St. Lawrence contains a Norman tower, dating back to around 1100AD;  The area has retained its unique character and appearance through the dominance of historically and architecturally important buildings and their historic settings;  The area has a diverse mix of building types and styles including grand historic buildings dating from the 17th - 19th Centuries;  Large areas of open space and mature tree growth contribute significantly to the overall

27 https://www.gloucester.gov.uk/media/3025/draft-gloucester-heritage-strategy-feb-2019.pdf

28 https://canalrivertrust.org.uk/enjoy-the-waterways/canal-and-river-network/gloucester-and-sharpness-canal

29 https://www.cotswold.gov.uk/media/1057486/Historic-Environmnet-Topic-Paper-020714.pdf

30 https://tewkesbury.cotswolds.info/heritage.shtml

31 https://tewkesbury.cotswolds.info/

32 https://www.cheltenham.gov.uk/downloads/file/778/cheltenham_borough_local_plan_second_review_2006

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appearance and character of the area33.

A Heritage Strategy for Stroud District was developed in February 2018. This Strategy aims to provide evidence and explanation that will allow the Council to set informed priorities in relation to the conservation, management and monitoring of the District’s heritage assets34.

It is important to note that the nature of cultural heritage features means that not all are known at present - in particular buried archaeological remains.

Implications/Opportunities for LTP Review

The LTP Review should:

- Protect and preserve designated and non-designated cultural heritage features and their settings.

- Ensure that - elements of the transport infrastructure in the Gloucestershire area (bridges, stations etc) which are themselves heritage assets are appropriately managed.

- Ensure that transport related development / infrastructure is sensitively designed to be sympathetic to its existing character and significance and that opportunities for improving public experience of historic places are sought.

- Ensure better accessibility to the historic environment.

ISA Objective

Conserve and enhance the heritage assets and the wider historic environment including buildings, structures, landscapes, townscapes and archaeological remains and their settings.

6.5.7. Water Resources and Quality Key baseline and sustainability issues

Gloucestershire falls within the Severn Vale and Upper Thames river catchments. Main rivers in the Gloucestershire region include: River Avon, River Severn, River Thames, River Wye, River Coln, River Cam, River Leadon, River Evenlode, River Chelt, River Windrush, River Frome, River Swilgate, River Churn, River Dikler, River Eye, River Leach, River Frome, River Tryme, River Bybrook, River Isbourne, River Boyd, River Stour.

The water quality within the County overall is not yet meeting good ecological status in regards the Water Framework Directive. However, there is great variation across the two catchments. Whilst only 7% of rivers and lakes within the Severn Vale catchment have good ecological and chemical status, 65% of water bodies in Upper Thames catchment are reported to be at good or moderate ecological status.

Presence of groundwater Source Protection Zones (SPZ’s) in the south east of the county, and smaller areas around Chipping Campden, north of Newent and west of Cinderford, can be a key issue as pollutant run off can affect the water quality. The two main areas designated as SPZ’s are an area to the north-west of Stow-on-the-Wold / south of Chipping Camden (Zones 2&3) and an area in the south of the CPS area

33 https://www.cheltenham.gov.uk/downloads/file/3222/swindon_village_conservation_area_character_apprais al_and_management_plan

34 https://www.stroud.gov.uk/media/558596/item-7-appendix-a-heritage-strategy.pdf

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Although not as major a threat to water quality as some other activities, transport does pose a risk. New transport infrastructure has the potential to modify water flow regimes and can lead to effects on water quality due to construction and operation of the infrastructure. Increased use of existing transport infrastructure, which may not be designed to current standards has the potential to lead to a deterioration of water quality too. For example, highway runoff can have relatively high pollutant loads, especially after dry periods or following gritting operations, and there is the potential for pollution following a transport accident.

Implications/Opportunities for LTP Review

The LTP Review should:

- Prevent pollution of water bodies (surface and groundwater) during the construction, operation and maintenance of any transport project.

- Protect and enhance Gloucestershire’s water resources.

- Promote the appropriate use of Sustainable Urban Drainage Systems (SuDS) in road drainage and surface water run-off to reduce pollution.

- Consider that biodiversity can also benefit from enhancements to road drainage, and associated improvement of water quality.

ISA Objective

Protect and enhance the water environment.

6.5.8. Land use / Soil / Agriculture Key baseline and sustainability issues

Gloucestershire is predominantly rural with two urban centres that serve as the main business and commercial heartland. The development of the County is noted in Gloucestershire’s Joint Strategic Needs Assessment35 to be strongly influenced by connectivity to the Midlands and South West via the M5 corridor and to London and the South East via the M4 corridor.

The west of the county is dominated by the upland area of the Forest of Dean, consisting of semi-natural and ancient woodland. To the east are the Cotswold hills, which are characterised by an undulating limestone plateau given over mostly to grassland. A central belt running roughly north-to-south contains the Severn Vale, a flat fertile valley floor where the lower reaches of the River Severn evolve into a tidal estuary. Finally, the meadows of the Upper Thames Valley (UTV) lie in the far south-east of the county; a largely riverine environment home to the upper reaches of the River Thames. Of note over half of Gloucestershire falls within one of three Areas of Outstanding Natural Beauty.

The Campaign to Protect Rural England Policy Statement36 notes that agriculture in Gloucestershire is dominated by small farms and small fields. While the pattern of field boundaries is an essential component of the character of the landscape, farming is under pressure due to competition from overseas. Whilst the response to such pressure is to apply economies of scale, with larger fields and farms, this could be damaging to the countryside and landscape.

35 https://www.gloucestershire.gov.uk/media/1521542/ugjsna_2017-14.pdf

36 http://www.cpreglos.org.uk/publications/item/2273-farming-and-land-management

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Soil is a finite resource that fulfils many important functions and services (ecosystem services) for society; for instance as a growing medium for food, timber and other crops, as a store for carbon and water, as a reservoir of biodiversity and as a buffer against pollution.

Whilst a significant proportion of the Gloucestershire is afforded protection through international designations including AONB, as well as ancient woodland status and other national and local designations, development pressure will be felt on existing rural areas, with the need for new transport infrastructure contributing to this pressure. This could have a wide range of implications for the land use / soil / agricultural resource e.g. through direct loss, potential for pollution or contamination incidents, severance of farm holdings etc.

Land quality varies from place to place. The Agricultural Land Classification (ALC) provides a method for assessing the quality of farmland to enable informed choices to be made about its future use within the planning system. The location of best and most versatile (Grades 1, 2 and 3a) agricultural land in the county, tends to be in the north-west of Gloucester, around Newent. However, the majority of agricultural land in the county is Grade 3 or 437.

Implications/Opportunities for LTP Review

The LTP Review should:

- Seek to make best use of areas that are already urbanised and provide an opportunity for regeneration / improvements to land quality.

- Avoid use of BMV agricultural land. Where use of BMV agricultural land is unavoidable, measures should be taken to avoid those areas of the highest quality.

- Protect soils as they are essential for achieving a range of important ecosystem services and functions. In particular, it must ensure that that soil resources are protected during the construction phase of schemes.

ISA Objective

Conserve soil and agricultural resources and seek to remediate / avoid land contamination.

6.5.9. Flooding & Climate change resilience Key baseline and sustainability issues

Parts of the county’s transport infrastructure (including some major roads such as the M5, the A40 at Gloucester and the A417 at Maisemore) are currently vulnerable to natural hazards (e.g. flooding). The most significant of flooding events was in 2007 which left 10,000 motorists stranded on country roads, including the M5 where many people remained overnight, and 500 commuters were stranded at Gloucester train station38.

Gloucestershire Highways (GH), which is part of Gloucestershire County Council, has developed a priority list of potential highway improvement schemes, which is used to plan and deliver a prioritised programme

37 https://www.gloucestershire.gov.uk/media/2921/gloucs_ltp3_review_sea_er_appendix_a_v20_190315- 63595.pdf

38 https://www.gloucestershire.gov.uk/media/2189/1_glos_local_strategy_summer_2014_-main_document- 61257.pdf

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Gloucestershire Local Transport Plan Review Integrated Sustainability Appraisal Report of highways maintenance and improvement schemes to help reduce the risk of flooding from highways.

Local communities in Gloucestershire face flood risk from many sources including rivers, surface runoff, groundwater, exceedance from highway and drainage networks39.

Development of transport infrastructure can aggravate existing flood risk in a wide range of ways, for example by requiring land take from flood plains, or by changing the drainage regime etc.

Climate change has the potential to increase the vulnerability of the county’s transport infrastructure to extreme weather events in the future. Expected climate change impacts in Gloucestershire include increased risk of extreme flooding (from more frequent “heavy precipitation events”) and more extreme weather events from higher temperatures and increased wind and rain in winter months.

This is likely to result in:

- Flooding can have direct impacts on buildings and infrastructure, now and into the future, and secondary impacts such as flood damage to people’s homes, and the psychological stress that this can cause flood victims. - Hot weather and periods of prolonged high temperatures can have a significant potential impact on the performance and safety of the transport infrastructure (example buckling of railway tracks or melting of roads) and can cause thermal discomfort in public transport and private vehicles leading to service disruption, health impacts and potential economic losses.40

Implications/Opportunities for LTP Review

The LTP Review should:

- Seek to ensure that transport infrastructure minimises any negative effect arising from flooding. Flood risk should be considered in any design and the implementation of SuDS and upstream storage Natural Flood Management (NFM) should be considered and encouraged where feasible.

- Ensure that where transport schemes require a landtake from the floodplain there is appropriate compensatory measures put in place to avoid increased risk of flooding to the scheme and elsewhere.

- Explore the possibilities for creating blue infrastructure which can both help to manage localised flood risk and simultaneously create new habitats in flood compensation areas, ponds and ditches.

- Recognise the challenges that a changing climate will bring and aim to reduce the impacts. Adaptation to flooding, heat and other climate risks resilience should be considered in any transport infrastructure design, operation and maintenance procedures / regime.

ISA Objective

Reduce risk of flooding and increase resilience of the transport network to the effects of a changing climate.

6.5.10. Waste and Resources Key baseline and sustainability issues

The county’s transport infrastructure is influential in the management of natural resources and waste.

39 https://www.gloucestershire.gov.uk/media/2189/1_glos_local_strategy_summer_2014_-main_document-61257.pdf

40 https://publications.parliament.uk/pa/cm201719/cmselect/cmenvaud/826/82607.htm

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Maintaining and / or upgrading transport infrastructure requires the use of natural resources such as minerals in construction and also contributes towards the generation of waste. It is also possible that transport infrastructure may risk sterilisation of underlying and yet to be exploited, valuable minerals resources.

Transport infrastructure may however, also have a positive role in resource and waste management, by way of facilitating the efficient and effective movement of natural resources and waste in, out and around Gloucestershire, particularly primary minerals and secondary & recycled materials needed to deliver growth; and the recycling, composting and recovery of waste as an alternative to disposal by landfill.

From a planning perspective, the management of natural resources and waste is largely addressed locally through the Gloucestershire Minerals Local Plan (1997 – 2006); emerging Minerals Local Plan for Gloucestershire (2018 – 2032); the Gloucestershire Waste Local Plan (2002 – 2012); and Gloucestershire Waste Core Strategy (2012 – 2027).

Implications/Opportunities for LTP Review

The LTP Review should:

- Seek to ensure that the construction and maintenance of transport infrastructure will be achieved using the least amount of primary materials necessary; by maximising the use of alternative secondary and recycled materials wherever possible; and minimising the level of waste generated throughout the lifecycle of transport assets;

- Seek to avoid, wherever possible the risk of sterilising underlying mineral resources as a consequence of developing new or improved transport infrastructure; and

- Seek to promote the creation of an efficient and effective highway network that will facilitate increased accessibility to waste management infrastructure aimed at diverting waste up the waste hierarchy and away from disposal to landfill and mineral infrastructure needed to deliver future sustainable growth.

ISA Objective

Promote prudent use of finite natural resources from primary sources, maximise the use of alternative, secondary and recycled materials, reduce the level of waste generated.

6.5.11. Transport Key baseline and sustainability issues

Gloucestershire has seen a general increase in both population and economic activity over the last number of decades, as noted by the Joint Strategic Needs Assessment41. Since 2007 the population has grown by 7.3% and this has increased the need for an effective transport system.

Gloucestershire has 3,326 miles of road, over 600,000 residents and over a million households with over 40,000 of these households without a car or van to enable access to essential services42. Nevertheless, Gloucestershire is noted to have a highly accessible transport network providing good connectivity to highway and rail networks, which enables its businesses, commuters, and leisure users to move efficiently on local and national transport networks43.

41 https://www.gloucestershire.gov.uk/media/1521542/ugjsna_2017-14.pdf

42 https://www.gloucestershire.gov.uk/media/2087154/overview-transport-accessibility.pdf

43 https://www.gfirstlep.com/downloads/2018/sep-2-update2018v3.pdf

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The major arterial route in the county, providing transport links to the midlands, north, and south west, is the M5 motorway, where capacity constraints have been identified (specifically J9 and J10). Of note the Growth Zone seeks to identify and secure the availability of quality employment land in proximity to the M5 motorway corridor and is the area around the M5 and was designated by the Gfirst LEP (Local Enterprise Partnership for Gloucestershire) in its Strategic Economic Plan.

The Gloucestershire Council Strategy 2019-202244 aims to develop:

- A highways network that keeps people and goods moving and helps Gloucestershire’s economy; - High levels of satisfaction with roads - To be at the forefront of highways technological transformation, encouraging early adopters to base themselves in Gloucestershire; and - More efficient use of resources and more use of sustainable energy.

It notes that self-driving and semi-autonomous vehicles, the roll out of 5G mobile technology, changing patterns of car ownership and growing public awareness and concern about air quality will shape the way people use the road network in the coming years.

As a county, Gloucestershire is noted as becoming a strong ‘trip attractor’45, particularly into the major employment centres in Gloucester and Cheltenham, but also in areas such as Tewkesbury which has strong road links for manufacturing, logistics and warehousing activity. As a result, a number of opportunities for improving the quality of the bus network have been identified, including:

- Abbeymead & Metz Way Corridor Improvements; - Gloucester Transport Hub (opened Oct 2018); and - A438 / A46 corridor improvements.

The use of Light Goods Vehicles in Gloucestershire has increased 35% between 2000-2013. Conversely the use of Heavy Goods Vehicles in the county has decreased by 20% over the same period46. Typically freight vehicles account for between 1% and 8% of all vehicle movements. However, for certain communities this proportion is far higher. HGV flows on the A46 in Ashchurch, part of Highways England’s Strategic Road Network account for between 10% and 15% of movements. There are several pinch points which impact traffic flows in the county, including:

- A417 Missing Link between the M4 and M5; - A40 at Over and Longford in Gloucester; and - A46 at Ashchurch.

Whilst a switch of freight travel from road to rail is encouraged, there are no rail freight terminals in Gloucestershire. Gloucestershire is an existing (albeit limited) source of rail freight as both origin and destination, examples being the Ashchurch Ministry of Defence facility and the Berkeley nuclear waste transfer station. Additionally, the Bristol – Birmingham main line through the county carries significant longer distance freight flows. There are opportunities for new terminals in selected strategic locations; and for upgrading of the main routes to support both local and longer distance freight movements. The SEP (2.0) for Gloucestershire47 notes limited rail connectivity, particularly direct train services to London and that pockets of the country have limited public transport services. It does however note opportunities to improve direct train service to London and Bristol.

There are actions taking place such as the December 2019 timetable change which is expected to deliver a number of improvements for services in Gloucestershire, for example Gloucester and Cheltenham will

44 https://www.gloucestershire.gov.uk/media/2083042/council-strategy-2019-3.pdf

45 https://www.gloucestershire.gov.uk/media/2211/6_-_ltp_-_stroud_cps-66794.pdf

46 https://www.gloucestershire.gov.uk/media/2226/10a_-_pd3_-_freight_pd_summary-66810.pdf

47 https://www.gfirstlep.com/downloads/2018/sep-2-update2018v3.pdf

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Additionally, the North Cotswolds line between Worcester and Oxford which serves Moreton in Marsh has also seen improved services from December 2019, providing an hourly service to the Capital.

Service improvements on the Birmingham – Bristol corridor through Gloucestershire will also be investigated, through Network Rail’s long term planning processes.

The county’s airport was identified in the original SEP as an important economic asset for Gloucestershire and having significant growth potential. Subsequently two projects have secured funding including the development of an access road to part of the airfield that could support a major new hangar development. A further development (£1.9m) to open up an additional development site on the north side of the airfield (Anson Park) is planned to come forward in 2020. The SEP notes that the close proximity of the airport of Gloucester and Cheltenham and the planned UK Cyber Business Park in Cheltenham ensure that it will be a strategically important asset for the county over the long term.

It is Gloucestershire County Council’s long-term aim to produce a number of Local Cycling and Walking Infrastructure Plan’s48. Over recent years improvements have been made to the cycle network within Gloucestershire including the area of the LEP defined Growth Zone. As Gloucestershire’s aim to retain young people in the county, public transport and walking and cycling infrastructure are important factors to consider as private car ownership amongst this group is falling

Implications/Opportunities for LTP Review

The LTP Review should: - Minimise travel demand and dependence on the private car, thereby reducing future traffic growth and congestion. This could be achieved by: - reducing the need to travel through the increased promotion of flexible working patterns such as home working, increased food retail deliveries and other associated methods. - reducing travel distance through assisting modal shift (by facilitating a widening travel choice through quality integrated facilities and services, walking and cycling improvements, demand management, network management, travel planning and intelligent transport systems) and reducing demand for travel on the SRN, thereby decreasing the necessity for costly and disruptive highway improvements. - reducing car mode share through improvements to sustainable modes - achieving a more efficient use of the network through measures to encourage travel outside of the network peak periods would have benefit in terms of creating capacity at peak times. - reducing highway congestion through through highway improvements. - increasing accessibility through sustainable modes of transport to / from residential and employment areas - Similarly, freight movements should be encouraged away from the road network onto the rail and waterway networks where feasible. - Create the infrastructure to encourage people to switch to low emission vehicles - charging points, preferential parking etc. - Aim to maximise connectivity with the Gloucester Transport Hub and support development and integration of other strategic transport proposals. ISA Objective

Reduce the need to travel, particularly by car or move goods by road, and promote sustainable modes of transport and patterns of movement.

48 https://www.gloucestershire.gov.uk/transport/cycling/

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6.5.12. Economy Key baseline and sustainability issues

The Strategic Economic Plan (SEP) for Gloucestershire 2.049 notes that Gloucestershire has a prosperous and resilient economy set with within a highly attractive natural environment. On many of the headline indicators of economic performance, Gloucestershire performs at, or above, the national average.

In terms of both GVA and employment, some of the largest sectors in the county are Distribution; Transport; Accommodation and Food; and Manufacturing, along with the Public sector (including education and health).

In recent years the greatest growth in GVA has been in Business Service Activities with average annual growth rates of 6% and 5% respectively, this sector has also seen high rates of growth in employment with an average annual growth rate of 4.4%.

Other sectors experiencing high rates of employment growth include Property (6.1% and Agriculture, Gas, Electricity and Water (4.1%).

The 2016 UK Competitiveness Index ranks GFirst as the 14th (out of 38) most competitive LEP in the country.

Total output of the country’s economy represents 12% of the value of the output in the South West and 1% of the UK economy. GVA per head in Gloucestershire is £26,093, on a par with the UK (£26,621) and above the South West average (£23,091).

Manufacturing in Gloucestershire is a significantly higher percentage than nationally, accounting for 15.2% of GVA compared to 10.2% nationally, and 12.2% of employment compared to *% nationally.

Gloucestershire has a higher proportion of people aged 65+ compared to England and Wales (21% compared to 18.2%), and the population is aging – ten years ago the proportion of over 65 year olds in the country was 17.6%.

The SEP for Gloucestershire notes that the aging population means replacement demand will be a critical challenge in the future. Further, the SEP notes a perception that, post-university education, the county suffers a net loss of its young talent.

Gloucestershire is noted to have a skilled workforce, with 56% employed in skilled and professional jobs (2018). Over 58% of the workforce have attained qualifications at NVQ level 3 or 4+ (2017) and almost 43% are in top output growth sectors (2016). Of significance the percentage of employees in high and medium technology manufacturing has increased by 1.7% to 24.7%, which places Gloucestershire in the top third of LEPs.

The SEP has successfully delivered the Gloucestershire Renewable Energy, Engineering and Nuclear Skills Centre (GREEN) which is noted to offer huge potential for businesses in the low carbon, engineering, cyber and digital sectors to develop a collaborative ecosystem, and for skills delivery to be focused on these key sectors for the county. The GREEN skills centre has helped facilitate the wider re- development of the former Magnox site under its new identity as the Berkeley Science and Technology Park.

Funding has been secured through the Local Growth Fund50 to deliver the enabling infrastructure necessary for a dedicated Cyber Park in Cheltenham, building on links with the Government Communication Headquarters (GCHQ). The scale, location and potential connectivity of this site presents a significant opportunity to create a world leading Cyber Park, centred around the Cheltenham National

49 https://www.gfirstlep.com/downloads/2018/sep-2-update2018v3.pdf

50 https://www.gfirstlep.com/about-us/funding-opportunities/

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Cyber Innovation Centre.

Implications/Opportunities for LTP Review

The LTP Review should: - Ensure that young talent is retained by reducing the perceived net loss of graduates in the county. The following implications/opportunities, whilst standalone, may also be seen as complementary to graduate retention.

- Support initiatives stemming from the flagship GREEN skills centre including development opportunities in the renewable energy and low carbon sectors.

Improve connectivity in support of sectors experiencing recent growth, such as Business Services, high and medium technology manufacturing and Cyber Security. This may take the form of improved strategic road networks as well as rail improvements, providing reliable travel alternatives. Improved connectivity should be achieved by sustainable and affordable modes of transport.

- Tackle congestion on transport networks by making existing transport networks more efficient and providing better travel alternatives to the private car. Increased reliability of journeys, in combination with an improvement of connectivity between other large towns in Gloucestershire, will enhance the productivity and competitiveness of the Gloucestershire economy.

- Supporting older people to access work (which may be more flexible/part time) and help realising the untapped potential of an older workforce and their talents and experience.

- Help retain young talent through more flexible working environments/practices ISA Objective

Promote economic growth and job creation and improve access to jobs for all.

6.5.13. Urban Development Key baseline and sustainability issues

A more accessible and efficient transport system requires compact and mixed-use urban development, focussed in and around existing town centres and the regional centre to support regeneration. These patterns can both facilitate mode shift and lead to huge congestion and poor quality of life if delivered poorly or without concomitant transport policies and delivery.

Prioritisation of transport infrastructure investment that will support such land use patterns will contribute to sustainable economic growth and attract inward investment in regeneration areas.

The Joint Core Strategy 2011-203151 (JCS) was published in 2017 and notes that the transport network will enable the scale of residential and employment growth outlined in the JCS by adding new, and managing existing, transport capacity to accommodate increased travel demand.

51 https://jointcorestrategy- my.sharepoint.com/personal/website_jointcorestrategy_onmicrosoft_com/_layouts/15/onedrive.aspx?id=%2Fpersonal%2 Fwebsite%5Fjointcorestrategy%5Fonmicrosoft%5Fcom%2FDocuments%2FJoint%20Core%20Strategy%20%28JCS%2 9%20website%2FJCS%20Adoption%2FJCS%20Plan%20Adopted%20Verison%20%28PDF%2E%2010MB%29%20For matted%2Epdf&parent=%2Fpersonal%2Fwebsite%5Fjointcorestrategy%5Fonmicrosoft%5Fcom%2FDocuments%2FJoi nt%20Core%20Strategy%20%28JCS%29%20website%2FJCS%20Adoption

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The JCS notes that an underpinning reason for allocating development in association with existing urban centres is the potential for enhanced transport connectivity. Not only are these sites closer to strategic and public transport networks, they also offer greater opportunities for people to make more trips – particularly local trips – on foot or by cycle. The transference of more of these local trips to walking and cycling (active travel modes) will be instrumental in creating high quality, vibrant and successful communities, and in ensuring the whole transport network operates efficiently and optimally. The way the development design process is conducted plays an important part in achieving this.

The JCS notes that existing pressures on the network and the delays experienced at present are likely to get worse over the next 15 years as new developments are built and greater numbers of people want to travel within urban centres. Planned highway capacity improvements will separate local and through traffic to ensure it can move with fewer journey delays and without undermining high quality passenger transport networks. Car travel along radial routes into centres will be managed to restrict unnecessary cross-town movements; orbital movements will be prioritised over radial routes to reduce impacts on the urban centres. Whilst car travel will not be restricted, it will not receive priority at pinch points along key bus corridors. In addition, the network will be complemented by attractive pedestrian and cycle infrastructure to enable sustainable travel choice.

The Strategic Economic Plan has been instrumental in the development of ‘The Growth Hub’, the first stop for business support in the county, and GREEN Skills Centre. Farm491 is a state-of-the-art space for agri- tech innovators and opened in 2017. Further the SEP is also implementing a Growth Zone, ensuring the availability of quality employment land in proximity to the M5 motorway and enabling excellent connectivity throughout Gloucestershire and the rest of the UK.

Implications/Opportunities for LTP Review

The LTP Review should: - Support a co-ordinated approach to land use and transport planning across Gloucestershire, including alignment and consideration of the JCS.

- Ensure widespread accessibility to the sites identified in the SEP. This should include the use of sustainable modes of transport.

- Consider the possibility of in-combination effects with new urban development in Gloucestershire.

- Support the development of healthy places, which are designed in such a way as to improve self- containment, particularly for home to work travel, and encourage behaviour change, towards active travel options, such as walking, cycling and use of public transport.

- Ensure that patterns of movement, streets, parking and other transport considerations are integral to the design of schemes and contribute to making high quality places. ISA Objective

Coordinate land use and transport planning across Gloucestershire.

6.5.14. Health and wellbeing and health inequalities Key baseline and sustainability issues

Overall, the health of people living in Gloucestershire is better than the England average across a range of different indicators. However, there are areas of Gloucestershire, where residents experience poorer health than the England average52.

52 https://www.gloucestershire.gov.uk/media/1521542/ugjsna_2017-14.pdf

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According to public health statistics summarized in local authority health profiles the following rates53 are significantly worse than England average:

- In Cotswold and Tewkesbury - the rate of killed and seriously injured (KSI) on roads; - In Gloucester - life expectancy at birth (both Male and Female), the rate of under 75 mortality (all causes), the rate of early deaths from cardiovascular diseases, and smoking prevalence in adults (aged 18+); - In Cheltenham, Stroud, and Cotswold - diabetes diagnoses (aged 17+); - In Stroud - alcohol-specific hospital stays (under 18s); - In Cotswold - dementia diagnoses (aged 65+); and - In Gloucester and Forest of Dean – GCSEs achieved54.

Additionally, the health of people living in Gloucestershire, particularly life expectancy (see below), has not been improving over time as seen in other parts of the country55.

Transport plays a significant role in physical and mental health. The effect can be direct, such as decrease or increase of a number of KSI on roads, or indirect, for example, providing access to rural areas for those people who have no car, promoting physical activity and, therefore, reducing the risk of cardiovascular diseases.

Age and Life Expectancy

Gloucestershire’s 65+ population is projected to experience the greatest growth. For residents of Gloucestershire, although Life Expectancy at 65 years of age is better than the England average for both males and females, it is not improving in line with the national trends for life expectancy, especially for females. For men in Gloucestershire, their Healthy Life Expectancy, the age to which an individual can expect to live with good health, has been declining since 201056.

There is a clear life expectancy gap between those living in the most and least deprived parts of Gloucestershire (an 8.1 year gap for men and a 5.3 year gap for women). This widens in some parts of the county, e.g. in Gloucester where there is an 11.9 year gap for men and a 10.5 year gap for women.

Children’s Health and Wellbeing

The health and wellbeing of children in Gloucestershire is generally better than the England average. Children from poorer backgrounds are more at risk of poorer health outcomes. The level of child poverty is better than the England average with 14.4% of children aged under 16 years living in poverty. However, this means that more than one in every 10 Gloucestershire children is living in poverty.

In 2014/15, children were admitted to hospital for mental health conditions at a lower rate to that in England as a whole.

Causes of Death in Gloucestershire

The three leading causes of death in Gloucestershire are cancer (25.7%), circulatory disease (28.0%) and

53 Note: indicator ‘hospital stays for self-harm’ is not discussed in this table, since it is not directly relevant to this particular analysis.

54 https://fingertips.phe.org.uk/profile/health- profiles/data#page/0/gid/1938132696/pat/6/par/E12000009/ati/101/are/E07000083

55 https://www.gloucestershire.gov.uk/media/1521542/ugjsna_2017-14.pdf

56 https://www.gloucestershire.gov.uk/media/1521542/ugjsna_2017-14.pdf

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The causes of death driving the difference in Life Expectancy between Gloucestershire’s least and most deprived areas include Coronary Heart Disease (CHD), Chronic Obstructive Pulmonary Disease (COPD), Stoke, Cancers and Dementia57.

Childhood Obesity

Over the past 10 school years, obesity levels for Gloucestershire reception children have fluctuated slightly, but have generally remained steady and in 2017/18 were at 10%, which was significantly higher than the national average of 9.5%.

For the same time period, obesity in Gloucestershire year 6 children has risen slowly from 15% in 2009/10 to 17.8% in 2017/2018 in line with the national trend, but levels remain significantly lower than the national average of 20.1%. However, this still means that approximately one in twelve children in Gloucestershire are affected by obesity in reception, doubling to around one in six by the time they reach year.

Research has shown that children who are affected by obesity at reception year are likely to continue to be affected at year 6.

Child obesity prevalence is strongly correlated with socioeconomic status and is highest in the most deprived areas across Gloucestershire. Gloucester and Forest have the highest levels of obese children with levels above the county average. Cotswolds and Stroud have the lowest rates of obese children in year 658.

Adult Obesity

In Gloucestershire modelled data indicates that 23.5% of adults (18 and over) in Gloucestershire are obese – which equates to approximately 114,714 adults59.

Physical Activity

Physical activity levels in Gloucestershire are on average higher than in England.

Gloucestershire’s physical inactivity levels (23.8%) are also better than the national average.

46% of adults in Gloucestershire who are inactive, do want to take part in sport, demonstrating there is an opportunity to increase participation60.

Air Pollution and Health

Air quality levels for PM2.5 in Gloucestershire are in line with regional averages. Air quality levels for nitrogen dioxide at the Lower Super Output Areas (LSOA) level are within EU directive target levels.

However, within Gloucestershire there are nine LSOA that exceed the recommended levels for Nitrogen Dioxide, of these 2 are in the most deprived 20% of the country in terms of indices of multiple deprivation.

In Gloucestershire there are 42,000 people recorded as living with asthma, and over 11,000 people known to be living with chronic obstructive pulmonary disease.

57 https://www.gloucestershire.gov.uk/media/1521542/ugjsna_2017-14.pdf

58 https://inform.gloucestershire.gov.uk/media/1521062/obesity_needs_assessment_-_final_version_january_2017.pdf

59 https://inform.gloucestershire.gov.uk/media/1521062/obesity_needs_assessment_-_final_version_january_2017.pdf

60 https://inform.gloucestershire.gov.uk/media/1521062/obesity_needs_assessment_-_final_version_january_2017.pdf

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Gloucestershire has high rates of car use for travel to work compared to the rest of the UK61.

The rural nature of the county is what attracts many residents to the area and facilitates access to open space improving health and wellbeing, however it can also create problems of accessibility and isolation. This can affect all parts of the population and is a particular problem for people who rely on public transport and the elderly62.

Research relating to the links between transport and health inequalities shows that:

- people without access to a car can experience health problems as a result of lack of access to essential services and amenities and increased level of social exclusion. - disadvantaged groups are more likely to be involved in a road accident. - deprived communities tend to experience poorer air quality as a result of transport related air pollution, and therefore they are more likely to experience the resulting health impacts; - The risk of death for child pedestrians is highly class related. Children in the lowest socio- economic group are over 4 times more likely to be killed as pedestrians than their counterparts in the highest socio-economic group63.

Implications/Opportunities for LTP Review

The LTP Review should: - Encourage healthier lifestyles for all communities by helping to provide environments that promote good physical and mental health. This could be achieved through the promotion of active modes of travel, better design, e.g. integration of green infrastructure, improvements to road safety and reduction in impact of transport, e.g. improvement of local air quality etc.

- Ensure better access, particularly by active travel modes to key health, education, shopping and employment opportunities.

- Deliver a strategy for improving road safety with consideration for deprived areas and in areas where KSI numbers are higher than the national average. One mechanism for this may be through for example reduced traffic speeds.

- Specifically consider how LTP policies address health inequalities (differential health outcomes resulting from socio-economic or other factors) and help close the health inequalities gap, e.g. in obesity.

- Consider the protection of existing and creation of new green infrastructure in association with highway network.

ISA Objective

Improve health and well-being for all citizens and reduce inequalities in health (for HIA sub-objectives see section 6.21 below).

61 http://glostext.gloucestershire.gov.uk/documents/s52324/Gloucestershire%20Air%20Quality%20and%20Health%20Strat egy%20v.%204.pdf

62 https://www.gloucestershire.gov.uk/media/1521542/ugjsna_2017-14.pdf

63 https://www2.gov.scot/Publications/2000/04/0c1a7de7-fee6-47a3-af0b-56e90b39ea8f

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6.5.15. Population growth and make-up of the local population Key baseline and sustainability issues

In 2017, the resident population of Gloucestershire was estimated to be 628,139 people. Gloucestershire’s population has increased by approximately 42,700 people or 7.3% since 2007. The percentage increase is lower than the increase experienced by both the South West (7.5%) and England (8.2%).

On current trends, the latest Office for National Statistics (ONS) 2016-based interim projections suggest that Gloucestershire’s population will increase by 92,200 people or 14.8% to about 715,300 in 2041. This compares to a projected national increase of 12.1%64.

Deprivation

According to the Index of Multiple Deprivation (IMD) 2015, Gloucestershire is ranked 124th out of the 152 English upper tier authorities. This means that Gloucestershire is in the least deprived quintile of English upper tier local authorities in terms of overall deprivation (IMD). Gloucestershire’s ranking has changed little since 2010 when the county ranked 126th out of 149 English upper tier authorities.

In terms of neighbourhoods, Gloucestershire is now made up of 373 Lower-layer LSOAs, an increase on the 367 in 2010.

Gloucester district has the highest overall levels of deprivation in the county, with 10 LSOAs (out of a total of 13) that rank in the top 10% most deprived in England65.

Equality Groups

Gender

The overall population split by sex in Gloucestershire is slightly skewed towards females, with males making up 49.1% of the population and females accounting for 50.9%. This situation is also reflected at district, regional and national level66.

People with Disabilities

According to the 2011 Census 16.7% of Gloucestershire residents reported having a long-term limiting health problem; this was below the national figure. 7.3% reported that their activities were limited ‘a lot’ and 9.5% reported their activities were limited ‘a little’.

The Forest of Dean had the highest proportion of residents reporting a long term limiting health problem at 19.6% of the total population, and was the only district that exceeded the national figure. Cheltenham had the lowest proportion of residents reporting a long-term limiting health problem at 15.1%67.

Dementia

Estimated projections suggest that in 2019 there will be approximately 9,780 people aged 65+ living with dementia in Gloucestershire. Given the ageing population the number of dementia sufferers will increase in the future68.

64 https://www.gloucestershire.gov.uk/media/12777/equality-profile-2019-final.pdf

65 https://www.gloucester.gov.uk/media/1807/understanding_gloucester.pdf

66 https://www.gloucestershire.gov.uk/media/12777/equality-profile-2019-final.pdf

67 https://www.gloucestershire.gov.uk/media/12777/equality-profile-2019-final.pdf

68 https://www.gloucestershire.gov.uk/media/12777/equality-profile-2019-final.pdf

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Learning disability

Estimated projections suggest that in 2019 there will be approximately 11,825 people aged 18+ living with a learning disability in Gloucestershire equating to 2.3% of the adult population.

Of this group, about 2,400 are estimated to have moderate or severe learning disabilities, equating to 0.5% of the adult population.

With regards to children, 4,955 school pupils in Gloucestershire (5.2% of school pupils) were known to have a learning disability in 2018. Of these children, 4,224 had a moderate learning disability and 574 had a severe learning disability69.

Vision and hearing impairments

Vision and hearing impairments affect people from all sections of society and across all age groups. In 2018 approximately 1.6% of the 16+ population in Gloucestershire reported blindness or partial sight. During the same period 7.0% of the population aged 16+ reported deafness or hearing loss.

As age increases the proportion of respondents reporting a limiting long-term health problem increases.

Given the ageing population, the number of people with a limiting long-term health problem is likely to increase in the future70.

Black and Minority Ethnic Groups

Gloucestershire is characterised by a comparatively small Black and Minority Ethnic population.

With regards to ethnic origin, the 2011 Census found that 91.6% of Gloucestershire residents were White British, 2.1% were Asian/Asian British, 1.5% were from a Mixed/Multiple Ethnic group, 0.9% were Black/Black British, 0.6% were White Irish, 0.1% were of Gypsy or Irish Traveller origin, 3.1% were in an ‘other White’ category and 0.2% were in another ethnic group.

The 2011 Census found that overall, 4.6% of the population in Gloucestershire was from Black and Minority Ethnic (BME) backgrounds; this figure increased to 8.4% when the Irish, Gypsy or Irish Traveller and ‘other White’ categories were included.

The proportion of people from Black and Minority Ethnic backgrounds was considerably lower than the national figure of 14.6%.

The population of Gloucestershire has become increasingly diverse. The Black and Minority Ethnic population increased by 70% between 2001 and 201171.

Sexuality and Gender Identity

There are no official estimates of sexual orientation at a county level, making it difficult to obtain a true reflection of this population.

National evidence suggests between 2.1% and 7.0% of people are lesbian, gay or bisexual (LGB). Young people (aged 16-24) are more likely to identify as LGB than older age groups and a higher proportion of males than females identify as LGB.

In Gloucestershire, recorded hate crime relating to sexual orientation 2017/18 has increased to 74 from 14

69 https://www.gloucestershire.gov.uk/media/12777/equality-profile-2019-final.pdf

70 https://www.gloucestershire.gov.uk/media/12777/equality-profile-2019-final.pdf

71 https://www.gloucestershire.gov.uk/media/12777/equality-profile-2019-final.pdf

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Age Profile

Gloucestershire has a lower proportion of 0-19 year olds and 20-64 year olds when compared to the national figure, whilst the proportion of people aged 65+ exceeds the national figure.

As is the case in many parts of the UK, the number of older people in the county has steadily increased over the last 10 years.

Projections suggest this trend will continue, with the number of people aged 65+ projected to increase by 77,000 or 59.4% between 2016 and 2041.

Gloucestershire’s 0-19 year old population is also projected to increase, but at a slower rate of 8.1% or 11,400 people by 2041.

The working age population (20-64 year old) is projected to experience a very small increase of 1.0% or around 3,700 people73.

Faith Groups

The most reported religion in Gloucestershire is Christianity, accounting for 63.5% of the total population, which is higher than the national figure.

Those aged 0-19 are less likely to be Christian than the older population and are more likely to report no religion.

The number of Christians in the county has declined since 2001, reflecting the national trend74.

Implications/Opportunities for LTP Review

The LTP Review should: - Consider specific transport needs of the growing population and of different neighbourhoods and communities.

- Take account of all age groups and special needs and ensure that people from different groups and backgrounds have the same opportunities with regards to access to transport.

ISA Objective

Promote greater equality of opportunity for all citizens, with the desired outcome of achieving a fairer society (for EqIA sub-objectives see section 6.21 below).

6.5.16. Community safety and crime and fear of crime Key baseline and sustainability issues

Community safety is about helping communities to feel and be safe. Aspects of relevance for transport are

72 https://www.gloucestershire.gov.uk/media/12777/equality-profile-2019-final.pdf

73 https://www.gloucestershire.gov.uk/media/12777/equality-profile-2019-final.pdf

74 https://www.gloucestershire.gov.uk/media/12777/equality-profile-2019-final.pdf

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Gloucestershire Local Transport Plan Review Integrated Sustainability Appraisal Report road safety and reducing criminal activities by installing “guardians” such as CCTV or alley gating75.

In Gloucestershire, there were 977 casualties in 2018 compared to 1110 in 2017. Of these, 28 were fatal, 256 casualties were serious and 693 were slight. Young males and older people are overrepresented groups in terms of injury collisions, although the rise in older road users is largely due to their increasing numbers and also being active into later life.

Statistics for 2018 shows that about 55% of killed and serious casualties took place in urban areas, and 45% in rural areas, 60% of slight casualties took place in urban area, and 40% in rural areas. Pedestrians, cyclists and motorcyclists are vulnerable user groups in terms of accidents76.

Total crime rates for district/borough council areas show that Gloucester City Local Authority and Cheltenham Borough Council areas have historically higher rates of crime when compared against the South West region and England as a whole.

However, crime rates in Cheltenham were considerably lower than the national crime rate in 2015/16 for the first time since the new crime recording standard was introduced back in 2003. This is in comparison to 10 years previously where crime rates in Cheltenham were significantly higher than England. Also, annual recorded crime rates lowered in Cheltenham in 2015/16 whereas they increased nationally77.

The yearly increases in recorded hate crime are evident both nationally and county-wide. In Gloucestershire, all monitored strands of recorded hate crime are increasing significantly. Race- related hate crime is the most recorded strand of hate crime in Gloucestershire by a large margin, with 326 recorded offences in 2017/18, representing a 24% increase on 2016/1778.

Implications/Opportunities for LTP Review

The LTP Review should:

- Set out a clear strategy and programme to continue to enhance safety for all road users including pedestrians, cyclists and motorcyclists.

- Aim to reduce the rate of road safety incidents (e.g. through reducing traffic levels and congestion, traffic calming measures, low key accident reduction strategies, 20mph zones).

- Aim to reduce the levels of crime and improve perceptions of safety and security on the transport network.

- Consider schemes that engender a sense of safety and reduce crime and fear of crime through indirect measures.

- Promote interventions that discourage incidences of anti-social behaviour and opportunistic crime.

ISA Objective

Promote community safety and reduce crime and fear of crime for all citizens.

75 https://www.gloucestershire.gov.uk/media/1521542/ugjsna_2017-14.pdf

76 https://www.gloucestershire.gov.uk/highways/road-safety/casualty-statistics/

77 https://www.gloucestershire.gov.uk/media/1521542/ugjsna_2017-14.pdf

78 https://www.gloucestershire.gov.uk/media/12777/equality-profile-2019-final.pdf

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6.6. EqIA and HIA Issues

6.6.1. Physical Activity, Active Travel and Open Space Key baseline and sustainability issues

Physical activity

There is an unequivocal body of evidence which links insufficient physical activity to a range of diseases and other medical problems and premature death (all cause- mortality). The evidence is strongest for chronic diseases, especially:

- cardiovascular disease - stroke - obesity - cancer (colon, and breast) - type 2 diabetes - osteoporosis - depression

Objective data monitoring through accelerometry reveals that 95% of adults in England are deficient in physical activity and so at elevated risk of disease and ill-health.79

The most recent survey (2009/10) found that, in Gloucestershire, across Years 1-13, 54.9% of pupils participated in at least 3 hours of high quality PE and out of hour’s school sport, which was similar to the national average.

Physical activity levels in Gloucestershire are on average higher than in England and broadly similar in five of the districts, with activity levels in Stroud higher than in the rest of the county.

Gloucestershire’s physical inactivity levels (23.8%) are also better than the national average (28.7%), however there is significant local variance within the county, with only 19.1% of the population in Cheltenham reporting as physically inactive, compared to 27.4% in Cotswold, and 27% in Gloucester, closely followed by 26.1% of residents in the Forest of Dean stating they are physically inactive.

It is important to consider that the Active People Survey relies on self-reporting, which has been shown to be unreliable. The real level of physical activity in the county is likely to be significantly lower.

However, 46% of adults in Gloucestershire who are inactive, do want to take part in sport, demonstrating there is an opportunity to increase participation80.

Active Travel

The trend across the UK is for physical activity levels to decline. This is associated with development of obesogenic environments, including widespread use of the private car. There is also increasing evidence of the link between adult obesity levels and travel behaviour, one indicator of which is that countries with highest levels of cycling and walking generally have the lowest obesity rates.

Active travel (walking and cycling) have been identified as a key means by which people can build physical activity into their everyday lives.

Next to providing considerable health benefits, walking and cycling also play an important part as ‘co-

79 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/371096/cl aiming_the_health_dividend.pdf

80 https://inform.gloucestershire.gov.uk/media/1521062/obesity_needs_assessment_-_final_version_january_2017.pdf

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Consequently, environmental and other interventions to facilitate increased population physical activity through cycling and walking are likely to be amongst the ‘best buys’ across many areas of public policy i.e. public health benefits, cost savings for health services and for transport planning.81

Open Space

Gloucestershire’s natural environment is incredibly varied with 38 landscape character types, 123 SSSIs and 3 AONB which cover 51% of the county’s area, as well as nature reserves and other natural assets.

The county’s natural environment is a valuable resource. It provides residents open space that contributes to the physical and mental health and wellbeing of people in Gloucestershire.

It is estimated that 30.4% of the county’s population utilise open space for exercise or health reasons in any given week. This is higher than the national (17.9%) and regional (25.4%) averages.

Given the county’s rich and varied natural environment it is unsurprising that the county is classed as a predominantly rural county by the ONS with 29.65% of the total population and 35.89% of the over 65 population living in rural areas.

- The rural nature of the county is what attracts many residents to the area and facilitates access to open space improving health and wellbeing, however it can also create problems of accessibility and isolation. This can affect all parts of the population, and is a particular problem for people who rely on public transport and the elderly82.

Deprivation

According to the IMD 2015, Gloucestershire is ranked 124th out of the 152 English upper tier authorities. This means that Gloucestershire is in the least deprived quintile of English upper tier local authorities in terms of overall deprivation (IMD). Gloucestershire’s ranking has changed little since 2012 when the county ranked 126th out of 149 English upper tier authorities.

In terms of neighbourhoods, Gloucestershire is now made up of 373 LSOAs, an increase on the 367 in 2010. Gloucester district has the highest overall levels of deprivation in the county, with 10 LSOAs (out of a total of 13) that rank in the top 10% most deprived in England83.

Implications/Opportunities for LTP Review

The LTP Review should:

- Encourage public accessibility to open space and the movement of people within open areas.

- Encourage regular physical activity including active travel for children and adults as part of a healthy lifestyle, including promoting countryside access, to reduce obesity levels and associated health problems.

- Encourage active travel along routes by using vegetation/trees along cycleways and footpaths, so

81 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/371096/cl aiming_the_health_dividend.pdf

82 https://www.gloucestershire.gov.uk/media/1521542/ugjsna_2017-14.pdf

83 https://www.gloucester.gov.uk/media/1807/understanding_gloucester.pdf

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making them more attractive to use and improve well-being.

- Promote accessibility to key services and facilities and employment areas by public transport and active travel modes, particularly to/from relatively deprived areas.

HIA/EqIA sub-objective

Improve accessibility to services, facilities and amenities for all, in particular by active travel modes.

6.6.2. Air, Noise and Light Pollution Key baseline and sustainability issues

Air pollution

In the UK, there are approximately 340,000 life years lost, and 40,000 deaths annually from exposure to poor air quality (estimates principally from particulate matter and nitrogen dioxide). Exposure to poor air quality results in both acute admissions to healthcare services, and long-term health and social care needs. Poor air quality is linked to increased risk for physical health, including respiratory and gastrointestinal problems, and lower mental health outcomes. 84 In children and adults, both short- and long-term exposure to ambient air pollution can lead to reduced lung function, respiratory infections and aggravated asthma. Maternal exposure to ambient air pollution is associated with adverse birth outcomes, such as low birth weight, pre-term birth and small gestational age births. Emerging evidence also suggests ambient air pollution may affect diabetes and neurological development in children.

Poor air quality is a source of inequality, where those who are most deprived are also the most likely to live in areas with the highest level of exposure.

There is strong body of evidence of impacts of both short and long term exposures to particulate matter (PM). Exposure increases mortality and morbidity from cardiovascular and respiratory diseases, including coronary heart disease, stroke, asthma, and lung cancer. There is a developing evidence base for a link between exposure to particulate matter and poorer early childhood development as well as the development of central nervous system conditions such as Alzheimer’s and Parkinson’s disease.

People with asthma and other pulmonary conditions such as chronic obstructive pulmonary disease (COPD) are particularly vulnerable to the impact from poor air quality.

There is a strong independent relationship between short term exposure to NO₂ and the prevalence of respiratory conditions, particularly asthma in children, and associated exacerbation of respiratory conditions (strongest in asthmatics). For longer term exposure to NO₂ there is likely an independent causal effect on respiratory disease. The evidence is also suggestive of a similar relationship to cardiovascular disease, although this is not currently strong enough to support an independent causal relationship.

In Gloucestershire the main local sources of PM2.5 are from combustion of fuel, road use and brake dust. Air quality levels for PM2.5 in Gloucestershire are in line with regional averages. However, there is marked variation between and within districts. Estimated levels are highest in Tewkesbury and Cheltenham, which are both higher than regional averages. Modelled data for PM10 at the lower super output area (LSOA) shows the highest estimated concentrations in Gloucestershire are in the Churchdown and Ashchurch areas of Tewkesbury and the west of Cheltenham.

Air quality levels for nitrogen dioxide (NO2) at the LSOA level are within EU directive target levels. The highest estimated concentrations are in North Gloucester, Cheltenham and around Gloucestershire Airport. Sixteen NO2 monitoring sites across the county exceeded WHO recommendations. Eleven of these sites are located in Cheltenham district, 4 are located in Gloucester and 1 is located in Cotswold at

84 WHO Ambient air pollution: Health impacts (https://www.who.int/airpollution/ambient/health-impacts/en/)

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Gloucestershire Local Transport Plan Review Integrated Sustainability Appraisal Report the Air Balloon Roundabout.

There are 8 air quality management areas (AQMA) (where national air quality targets are not being achieved) in Gloucestershire. Four of the AQMAs are located within the Central Severn Vale Connecting Places Strategy (CPS) area. The entire borough of Cheltenham is designated as AQMA. Forest of Dean District Council has designated an AQMA in Lydney. This includes parts of the A4231 and parts of Bream Road and Forest Road in Lydney. Cotswold District Council has designated two areas, one encompassing the junction of the A417 and A436 at the Birdlip (Air Balloon) roundabout, including nearby properties, and the second along the Thames Street on A361 as AQMAs.

There are likely to be increases in emissions exposure as a result of new housing and employment allocations in the Gloucestershire.

Noise Pollution

There is evidence that noise pollution can lead to a range of health problems including increased stress, strokes, high blood pressure and heart attacks.

Noise pollution can be a major nuisance and is widely recognised as a disbenefit affecting daily life. General annoyance and sleep disturbance are the most widespread effects of environmental noise. Symptoms such as depression, irritability and headaches have also been reported. Stress has been suggested as a possible mechanism through which noise may affect mental and physical health.

In 2014/15 Gloucestershire had a rate of 3 noise complaints per 1000 population, this is below both the regional (5.3) and national (7.1) rates.

The county also has low levels of population exposed to road, rail and air transport noise pollution both during the day (3.3% of the population) and at night (5.5% of the population). This is broadly in line with regional average and below the national average.

Industrial pollution can also have a significant impact on the health and wellbeing of residents as well as the quality of the environment. There have been a low number of major industrial incidents in Gloucestershire in the last 10 years (8), but a higher level of ‘significant’ incidents particularly in areas of the county with concentrations of industry, Gloucester, Cheltenham and the Severn Vale (M5 corridor)85.

Future population and traffic growth, with associated congestion are likely to result in an increase in existing levels of noise.

Light pollution

Health effects of light pollution may include: increased headache incidence, worker fatigue, medically defined stress, decrease in sexual function and increase in anxiety.

The County is classed as a predominantly rural county by the ONS with 29.65% of the total population and 35.89% of the over 65 population living in rural areas86.

According to the England’s Light Pollution and Dark Skies map Gloucestershire is the 17th darkest county out of the 41 within England. The brightest zones (night light are >32 NanoWatts /cm2/sr) fall within urban centres, i.e. Gloucester, Cheltenham, Tewkesbury and Stonehouse, and surrounding areas. Dark zones, i.e. night lights vary from 0.25 to 2 NanoWatts /cm2/sr, fall within rural areas87.

85 https://www.gloucestershire.gov.uk/media/1521542/ugjsna_2017-14.pdf

86 https://www.gloucestershire.gov.uk/media/1521542/ugjsna_2017-14.pdf

87 https://www.nightblight.cpre.org.uk/maps/

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Implications/Opportunities for LTP Review

The LTP Review should:

- Ensure that the population, including vulnerable groups such as children, pregnant women and the elderly, are not exposed to ambient air pollution levels which could impact their physical and mental health.

- Ensure that reducing NO2 and PM10 emissions is a fundamental principle of the Plan and acts to bolster the Gloucestershire Air Quality and Health Strategy as appropriate.

- Consider use of vegetation alongside routes especially trees, which could help to improve air quality by trapping pollutants and producing oxygen and retaining humidity and mitigate noise and light pollution from traffic/transport.

- Minimise as much as practicable noise generation, especially noise generated by traffic, e.g. through use of quiet surfacing and establishment of quiet zones and reduced traffic speeds.

- Minimise as much as practicable light pollution (e.g. through promoting light sources of minimum intensity and LED luminaires).

HIA/EqIA sub-objective

Reduce air, noise and light pollution from transport.

6.6.3. Severance Key baseline and sustainability issues

Severance is often an unintended consequence of a measure intended to address other problems. Certain groups in society are potentially vulnerable to the effects of severance as a result of the transport network, and these include people without access to a car, children, older people, people with disabilities, parents with pushchairs, and deprived residents. Those groups impacted by severance may experience longer journey times or are often required to use pedestrian routes that are inappropriate or difficult to use. In extreme cases, severance issues (either actual or perceived) may result in users limiting their journeys and hence reducing access to opportunity.

Managing bus service provision effectively is essential to keep communities joined up to local essential services.

Cheltenham, Gloucester and the larger market towns in Gloucestershire have the broadest range of frequent bus services available enabling access to essential food retail, education facilities and health services.

The National Indices of Deprivation 2015 includes a measurement of accessibility (Geographical Barriers). Each neighbourhood in England has had distance measurements calculated and ranked to post offices, primary schools, general stores/supermarkets and GP surgeries. Most of the land area of Gloucestershire falls within the most deprived quintile with the exceptions of the urban areas of the county.

Out of the six districts of Gloucestershire, Cotswold District Council has the highest proportion of its

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Gloucestershire Local Transport Plan Review Integrated Sustainability Appraisal Report residents living in the most inaccessible areas where it either takes over 45 minutes to access an essential service or that it is simply not possible to access due to a lack of public transport in their local area88. This causes severance, especially to sensitive receptors such as children, older people, and people with disabilities.

Implications/Opportunities for LTP Review

The LTP Review should:

- Reduce any existing severance issues and ensure new initiatives do not create unnecessary severance for the local population.

- Consider green infrastructure, which could reduce severance by encouraging use of otherwise unattractive routes.

HIA/EqIA sub-objective

Reduce severance.

6.6.4. Affordability of Transport Key baseline and sustainability issues

Any intervention that changes the cost of travel for users may give rise to impacts on personal affordability and may have disproportionate effects where there are few or no travel alternatives, especially where low income households preclude car ownership and use. Changes to transport costs can include public transport fares, parking charges, road user charges or impacts to the road network that impacts on the operating costs of cars.

Gloucestershire has 3,326 miles of road, over 600,000 residents and over a quarter of a million households with over 40,000 of these households without a car or van to enable them to access essential services ie. those services necessary to ensure the full social inclusion of people in society. Managing bus service provision effectively is essential to keep communities joined up to local essential services89.

Implications/Opportunities for LTP Review

The LTP Review should:

- Ensure new transport initiatives are affordable and do not price out certain groups of society.

HIA/EqIA sub-objective

Improve affordability of transport.

88 https://www.gloucestershire.gov.uk/media/1521542/ugjsna_2017-14.pdf

89 https://www.gloucestershire.gov.uk/media/1521542/ugjsna_2017-14.pdf

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7. ISA Framework

7.1. Introduction The assessment framework is a key component in completing the ISA by synthesising the baseline information and sustainability issues into a systematic and easily understood tool that allows the prediction and assessment of effects arising from implementation of the LTP.

7.2. ISA Objectives and assessment aid questions Defining ISA Objectives before the LTP is written gives an early indication of the sustainability issues that will require particular attention in the LTP making process.

The ISA objectives (and HIA, EqIA and CSA sub-objectives) have been worded so that they reflect one single desired direction of change for the theme concerned and do not overlap with other objectives. They include both externally imposed sustainability objectives and other objectives have been devised specifically in relation to the context of the LTP being prepared.

In addition, assessment aid questions have been identified to substantiate the proposed ISA Objectives and HIA and EqIA sub-objectives. The assessment aid questions provide a clarification of the intended interpretation of each objective to support direction of change sought through the implementation of LTP. These questions guided the assessment process reported in Chapters 8, 9 and 10.

The ISA objectives, together with the assessment aid questions make up the ISA Framework that has been used in the assessments of the LTP. The ISA Framework is presented in Table 7-1, with Tables 7-2 and 7-3 showing the proposed EqIA and HIA sub-objectives and assessment aid questions, respectively.

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Table 7-1 ISA Framework and of objectives and assessment aid questions

No ISA Objective Assessment aid questions SEA topic (relevance to HIA, EqIA, CSA and HRA shown in brackets) Environment

1. Improve air quality Will the LTP Review... Air Quality; Biodiversity  Reduce emissions of pollutants from transport? (HIA- ISA Objective  Improve air quality within AQMAs? 16/EqIA- ISA  Promote the use of low emission or zero emissions vehicles? Objective 15)  Reduce traffic growth and congestion and promote more sustainable transport patterns across Gloucestershire?  Promote walking and cycling and improve infrastructure for these forms of travel?  Promote enhancements to green infrastructure networks to facilitate increased absorption and dissipation of nitrogen dioxide and other pollutants?  Commit to the National Air Quality Objectives and avoid the need for new AQMA’s in either Gloucestershire or the surrounding areas?

2. Reduce carbon Will the LTP Review… Climatic factors; dioxide (CO2)  Contribute to meeting national net zero targets on CO2 emissions? Biodiversity emissions from  Reduce the need to travel? transport  Promote the use of sustainable forms of transport and reduce car use?  Promote better coordination and integration of different transport modes?  Encourage greater carbon efficiency in the movement of goods and people?  Encourage use of innovative new low carbon transport technologies?  Encourage use of the transport estate for low carbon energy generation?  Encourage offsetting of carbon emissions?  Create new carbon sinks through enhancing green infrastructure?  Ensure initiatives aiming to reduce traffic speed in residential areas without increasing carbon dioxide emissions?

3. Protect and enhance Will the LTP Review… Biodiversity, Climatic protected habitats,  Lead to the direct physical loss of valued habitat and populations of factors (HRA) sites, species, protected/scarce species? valuable ecological  Avoid indirect damage or disturbance to valued habitat and populations of

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No ISA Objective Assessment aid questions SEA topic (relevance to HIA, EqIA, CSA and HRA shown in brackets) networks and protected/scarce species promote ecosystem  Protect the integrity of designated sites including enhancement for SACs, SPAs, resilience and Ramsar sites, SSSIs, Local Wildlife Sites and National Nature Reserves, including functionality those of potential or candidate designation?  Manage highway operational and maintenance pressures on designated sites and valued habitat and populations of protected/scarce species on locally designated sites, including Key Wildlife Sites and Local Nature Reserves?  Deliver biodiversity net gain?  Provide opportunities to improve / enhance sites designated for nature conservation?  Protect and enhance Gloucestershire’s ecological networks (the Nature Recovery Network)?  Protect and enhance priority habitats, and the habitat of priority species?  Protect and enhance green infrastructure and avoid severance of habitats links?  Minimise habitat fragmentation and severance of species migration and commuter routes?  Promote new habitat creation or restoration and linkages with existing habitats?  Increase the resilience of biodiversity to the potential effects of climate change?

4. Protect, enhance and Will the LTP Review… Landscape promote geodiversity  Protect or enhance SSSIs designated for their geological interest?  Promote accessibility to the county’s designated sites of geological interest?  Seek to avoid the degradation and removal wherever possible of Regionally Important Geological and Geomorphological Sites (RIGS)?

5. Protect and enhance Will the LTP Review… Landscape / the character and  Protect or enhance nationally and locally designated landscape and townscape and Townscape; quality of landscapes their settings? Biodiversity; Climatic and townscapes and  Conserve, protect and enhance natural environmental assets (e.g. parks and green factors visual amenity spaces, common land, woodland / forests etc)? (HIA/EqIA)  Be consistent with the management plans, objectives and other guidance of relevant AONBs?  Promote / protect Public Rights of Way (PRoW)?

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No ISA Objective Assessment aid questions SEA topic (relevance to HIA, EqIA, CSA and HRA shown in brackets)  Affect the intrinsic character or setting of local landscapes or townscapes through changes to views or indirectly through changes to tranquillity, light pollution and traffic?

6. Conserve and Will the LTP Review… Cultural Heritage; enhance heritage  Affect the integrity of designated heritage assets and their settings (Scheduled Landscape / assets and the wider Monuments, Listed Buildings and structures, Registered Parks and Gardens, Townscape historic environment Registered Battlefields and Conservation Areas)? including buildings,  Affect the significance of non-designated heritage assets (e.g. locally important structures, buildings and archaeological remains, including newly discovered heritage assets) landscapes, and their settings? townscapes and  Lead to harm to the significance of heritage assets, for example from the archaeological generation of noise, pollutants and visual intrusion? remains and their  Maintain or improve access to heritage assets? settings  Promote transport schemes which tackle traffic congestion in Gloucestershire’s historic villages, towns and city?  Maintain or improve the interpretation, understanding and appreciation of the significance of heritage assets?

7. Protect and enhance Will the LTP Review… Water; Biodiversity the water  Protect ground and surface water quality in line with Water Framework Directive environment requirements?  Safeguard the availability of water resources (surface and groundwater)?  Protect and enhance green infrastructure contributing to improvements in the quality of surface water run-off?  Promote the minimisation of the use of impermeable hard surfacing and promote the use of SuDS and upstream storage NFM?  Provide opportunities to improve Green / blue infrastructure?  Provide opportunities to improve water body status?

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No ISA Objective Assessment aid questions SEA topic (relevance to HIA, EqIA, CSA and HRA shown in brackets) 8. Conserve soil and Will the LTP Review… Landscape agricultural  Assist in facilitating the re-use of previously developed land? resources and seek  Avoid permanent (irreversible) loss of the most highly productive agricultural soils? to remediate / avoid  Avoid transport-related infrastructure development upon the best and most land contamination versatile agricultural land?  Ensure the protection of soil resources and reduce soil quality degradation during transport-related infrastructure construction activities?  Seek to remediate contaminated land?

9. Reduce risk of Will the LTP Review… Climatic factors; Water flooding and increase  Minimise the risk of flooding by the design and implementation of SuDS and Material Assets resilience of the upstream storage NFM when possible? transport network to  Minimise the risk of flooding by avoiding areas of flood risk / flood plain when the effects of a possible? changing climate  Ensure provision of appropriate compensatory measures are in place when there is no other option to landtake from areas of flood plain?  Lead to development that is flood resilient over its lifetime, taking into account the effects of climate change, without increasing the flood risk elsewhere and identifying opportunities to reduce the risk overall?  Encourage design for successful adaptation (including through green and blue infrastructure) to the predicted changes in weather conditions and frequency of extreme events (freezing, heat waves, intense storms), from a changing climate?

10. Promote prudent use Will the LTP Review… Material Assets of finite natural  Seek to reduce the consumption of primary, natural resources through encouraging resources from the use of recycled and / or secondary materials with transport-related infrastructure primary sources, projects? maximise the use of  Encourage resource efficiency during the whole project life cycle of transport- alternative, secondary related infrastructure projects i.e. from concept through design and operation to and recycled decommissioning? materials, reduce the  Seek to reduce fuel use through fuel efficiency measures and a shift towards more level of waste sustainable forms of transport in the delivery of transport-related infrastructure generated projects;

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No ISA Objective Assessment aid questions SEA topic (relevance to HIA, EqIA, CSA and HRA shown in brackets)  Improve accessibility to the county’s waste management infrastructure, particularly those facilities that support recycling, composting and material recovery;  Promote the use of local suppliers that use sustainably-sourced and locally produced materials with transport-related infrastructure projects?  Promote increasingly more sustainable waste management practices with transport-related infrastructure projects in line with the waste hierarchy?  Support the delivery of a network of sustainable waste management facilities and mineral infrastructure needed to deliver growth?

11. Reduce the need to Will the LTP Review… Population; Material travel, particularly by  Reduce the need to travel? Assets, Human Health car or move goods  Encourage modal shift to more sustainable forms of transport? (HIA- ISA Objective by road, and promote  Minimise dependence on the private car? 16/EqIA- ISA Objective sustainable modes of  Promote a wider travel choice through quality integrated facilities and services, 15) transport and walking and cycling improvements, demand management, network management, patterns of travel planning and intelligent transport systems? movement  Promote transportation of freight and goods using waterways and rail? (see also ISA  Meet the transport needs of those that live in rural areas? Objective 15 for  Ensure linkages to sustainable transport networks beyond the Authorities’ health impacts) boundaries to promote sustainable regional trips?

Economy

12. Promote economic Will the LTP Review… Population growth and job  Support economic activities in areas of high growth pressures? (HIA- ISA Objective creation, and  Support economic activities in rural areas? 16/EqIA- ISA Objective improve access to  Support improved availability and accessibility to good quality education, training 15) jobs for all and employment opportunities, particularly in high unemployment areas?  Contribute to establishing an effective transport network that increases investment?  Reduce congestion and improve / enhance journey time reliability on the highways and rail network?

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No ISA Objective Assessment aid questions SEA topic (relevance to HIA, EqIA, CSA and HRA shown in brackets) 13. Coordinate land use Will the LTP Review… Population and transport  Support the development of new compact, higher density mixed use development planning across that reduces the need to travel by private car, coordinated with public transport Gloucestershire and active travel / walking and cycling infrastructure and results in shortened trip distances, particularly for employment and education purposes?  Support housing and employment development in areas that are or will be served by rail transport or other forms of public transport? Minimise cumulative and synergistic effects resulting from the in-combination effects of transport proposals and new development areas?

Social

14. Promote greater Will the LTP Review … Population equality of opportunity  Promote greater equality of opportunity to the varying age groups of residents (the (see EqIA sub- for all citizens, with the older population and younger travellers), disabled people, different nationalities and objectives) desired outcome of ethnic groups, different religious groups, low income and unemployed people, achieving a fairer different sex and sexual orientation groups? society (EqIA specific  Have a differential negative impact on any groups of residents as described above? objective)

15. Improve health and Will the LTP Review … Human Health well-being for all  Promote health and well-being, including of vulnerable groups (children and (see HIA sub- citizens and reduce adolescents; older people; disabled people and people with long term health objectives) inequalities in health conditions; low-income groups and communities with high levels of deprivation; (HIA specific cyclists, pedestrians, commuters by public transport, drivers) and of the wider objective) population (residents, workers, commuters, tourists and visitors)?

16. Promote community Will the LTP Review… Population (CSA) safety and reduce  Promote initiatives that enhance safety and personal security for all, without fear or crime and fear of hindrance from crime and disorder? crime for all citizens  Promote the application of 'Secured by Design' principles aimed at designing out (CSA specific crime in transport development schemes?  Contribute to improvements to levels of natural surveillance in the public realm to

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No ISA Objective Assessment aid questions SEA topic (relevance to HIA, EqIA, CSA and HRA shown in brackets) objective) create a more welcoming environment for travel, physical activity, and accessing key services, facilities and amenities?  Improve personal security on public transport accessing key services, facilities and amenities?  Lead to a low crime rate and a reduction in anti-social behaviour?  Reduce the risk of being injured or killed on the road?

Table 7-2 EqIA Sub-Objectives

EqIA Objective EqIA sub-objectives Assessment aid questions

To promote greater equality Improve accessibility to services, facilities and amenities Will the LTP Review... of opportunity for all citizens, for all, in particular by active travel modes  Improve access to essential facilities, including with the desired outcome of employment, healthcare and education, achieving a fairer society particularly for those in the most deprived areas (20% most deprived nationally), older and

disabled people?

 Improve public realm and overall environment including green infrastructure in the most deprived areas (20% most deprived nationally)?  Improve walking, cycling and public transport

measures in the most deprived areas (20% most deprived nationally)?

 Provide transport services/ initiatives that are

accessible and affordable for all, including those

with a physical or learning disability and those with limited mobility? (this includes physical access to services and provision of accessible information on transport service)

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EqIA Objective EqIA sub-objectives Assessment aid questions  Provide transport services that are welcoming for all groups of society to increase availability of travel options?

 Provide initiatives that improve perceptions of transport, and therefore increase range of travel options available?  Take due regard of requirements for travel by disabled and mobility impaired people?

Improve affordability of transport Will the LTP Review...   Provide transport services that are financially accessible for all, specifically those in the most income deprived areas nationally or those on limited incomes?  Provide transport services or initiatives that improve the affordability of travel options in the area, specifically the most deprived areas and vulnerable users?  Provide transport services that provide appropriate and/or statutory fare structures for vulnerable users (i.e. concessionary fares on public transport services)?  Promote use of technology to reduce transport costs for users i.e. integrated ticketing and smart cards?

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EqIA Objective EqIA sub-objectives Assessment aid questions

Improve road safety and reduce the number of accidents Will the LTP Review... and other incidents  Ensure safe paths for walking and cycling?  Promote training for drivers to promote safe driving?  Ensure initiatives aiming to reduce traffic speeds in residential areas?  Promote road safety awareness with children and young people  Reduce the total killed and seriously injured in traffic accidents, particularly for vulnerable users in terms of accidents – children, young males, older people and those from deprived areas?  Reduce the total slight casualties?  Improve the safety of vulnerable road users such as pedestrians, motorcyclists and cyclists?

Reduce severance Will the LTP Review...  Improve access to essential facilities to reduce any existing severance issues?  Improve accessibility between communities?  Improve access to information for all users to promote a range of travel options, including active travel, available for all?  Reduce the physical and perceived impact of the transport system on the local environment? (particularly for the most vulnerable population in terms of severance – including older children and disabled people)

Reduce air, noise and light pollution from transport Will the LTP Review...  Improve impact of transport on the local environment to create more welcoming areas for travel?  Provide transport options that improve / do not worsen air and noise pollution levels, particularly for the most vulnerable groups such as deprived

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EqIA Objective EqIA sub-objectives Assessment aid questions residents and children (as air quality and noise impacts are known to adversely impact learning ability of children in extreme cases)?  Reduce traffic levels and congestion and promote more sustainable transport patterns across the area, particularly focusing on areas with low air quality (e.g. AQMAs)?  Promote sustainable travel to reduce the environmental impact of transport for vulnerable groups?

Table 7-3 HIA Sub-Objectives

HIA Objective HIA sub-objectives Assessment aid questions

Improve health and well- Improve accessibility to services, facilities and amenities Will the LTP Review... being for all citizens and for all, in particular by active travel modes  Ensure that (new and existing) developments are reduce inequalities in health accessible (particularly on foot, by cycling or public transport) to health and care services, education, employment and other essential

services, particularly for the most vulnerable groups?  Promote and enable measures to help all residents to adopt healthy lifestyles (eg. active

travel through walking and cycling)?

 Promote accessibility (particularly on foot or by cycling or public transport) to open space and

recreational activities (e.g. playing fields, sports

facilities, footpaths etc), particularly for vulnerable groups?  Protect and enhance green infrastructure, a network of linked, multifunctional green spaces in

and around the area’s towns and cities, thus

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HIA Objective HIA sub-objectives Assessment aid questions creating new or improved public green space?  Support publicity or awareness-raising campaigns and/or education and practical offers to promote active modes of transport or physical

activity?

 Provide overall accessibility improvements that also enhance community connectedness (feeling of belonging) thus improving the quality of life for all?

Improve affordability of transport Will the LTP Review...  Provide affordable transport options to ensure accessibility to vital health services, work, education, social activities?  Provide affordable transport options to ensure accessibility to key facilities such as open spaces, employment locations etc.?  Promote use of technology to reduce transport costs for users i.e. integrated ticketing and smart cards?  Provide transport services that provide appropriate and/or statutory fare structures (i.e. concessionary fares on public transport services) to ensure the most vulnerable groups in terms of health (children, older), can afford to use transport options to access healthcare and other key facilities?

Improve road safety and reduce the number of accidents Will the LTP Review... and other incidents  Provide initiatives that enhance road safety and therefore reduce the number of accidents, particularly for vulnerable users– children, older people, disabled people, and those in deprived areas?

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HIA Objective HIA sub-objectives Assessment aid questions

Reduce severance Will the LTP Review...  Improve access to essential facilities such as healthcare services to reduce any existing severance issues?  Improve accessibility between communities?  Reduce the physical and perceived impact of the transport system on the local environment? (particularly for the most vulnerable population in terms of severance and health – including older and disabled people)

Reduce air, noise and light pollution from transport Will the LTP Review...  Aim to minimise air, noise and light pollution during construction and operation?  Reduce transport impact on air quality and noise, particularly around vulnerable users such as children, older people and deprived areas?  Promote practices, equipment and materials which reduce vibration and air, noise and light pollution to assist in improving health levels?

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8. Compatibility between LTP Objectives and ISA Objectives

8.1. Introduction To help ensure that the Objectives of the LTP are as closely aligned with the ISA Objectives as possible, a test of their compatibility has been undertaken early on in the ISA process. This test helps identify potential synergies and inconsistencies and refine the LTP Objectives.

An early draft LTP Review document (as at August 2019) identified the following strategic objectives that link to the expected outcomes:  Support sustainable economic growth  Enable community connectivity  Conserve the environment  Improve community health and well-being

The objectives of the ISA are as follows: 1. Improve air quality 2. Reduce carbon dioxide emissions from transport 3. Protect and enhance protected habitats, sites, species, valuable ecological networks and promote ecosystem resilience and functionality 4. Protect, enhance and promote geodiversity 5. Protect and enhance the character and quality of landscapes and townscapes and visual amenity 6. Conserve and enhance the heritage assets and the wider historic environment including buildings, structures, landscapes, townscapes and archaeological remains and their settings 7. Protect and enhance the water environment 8. Conserve soil and agricultural resources and seek to remediate / avoid land contamination 9. Reduce risk of flooding 10. Promote the prudent use of finite natural resources from primary sources, maximise the use of alternative, secondary and recycled materials, reduce the level of waste generated minimise the production of waste and support re-use and recycling 11. Reduce the need to travel by car or move goods by road and promote sustainable modes of transport 12. Promote economic growth and job creation, and improve access to jobs for all 13. Coordinate land use and transport planning across Gloucestershire 14. Improve health and well-being of all citizens and reduce inequalities in health 15. Promote greater equality of opportunity for all citizens, with the desired outcome of achieving a fairer society 16. Promote community safety and reduce crime and fear of crime for all citizens

The compatibility assessment results are presented in the Table 8-1 and a discussion of the results follows.

Overall, a certain degree of compatibility was found between the early draft LTP Review objectives with the ISA objectives focused on promoting economic growth, job creation and improving access to jobs for all and improving health and well-being of all citizens and reducing inequalities in health.

However, for all the early draft LTP Review objectives it was found that they either beard an uncertain relationship or no relationship with the following ISA objectives: - Reduce the risk of flooding - Promote community safety and reduce crime and fear of crime for all citizens

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Potential areas of conflict on air quality improvement and reduction of transport emissions were identified for two LTP Review plan objectives as: 1) Support sustainable economic growth and 2) Enable community connectivity.

There were also a number of unclear outcomes for each of the early draft LTP Review objectives, in particular with regards to early draft LTP Review objective 1- Support Sustainable Economic Growth, and to a lesser degree for early draft LTP Review objective 4 Improve Community Health and Well-being.

When each LTP Review objective was assessed individually against the ISA Objectives, the degree of compatibility between the two sets of objectives was very patchy as particular plan objectives clearly pursued particular ISA objectives, with the compatibility against other aspects of sustainability unclear. Recommendations were provided in order to improve the compatibility between early draft LTP Review objectives and ISA objectives. These are discussed in turn below.

8.2. LTP Review Objective 1: Support Sustainable Economic Growth

From the initial assessment, the draft LTP Review objective 1 was found to broadly compatible with some ISA objectives which aim to: - Promote economic growth and job creation across the subregion and improve access to jobs for all - Coordinate land use and transport planning across Gloucestershire - Improve health and well-being of all citizens and reduce inequalities in health - Promote greater equality of opportunity for all citizens, with the desired outcome of achieving a fairer society

As this draft objective is highly likely to promote interventions such as new road schemes, road network developments, road widening, transport facility improvements, etc, which will facilitate more movement of people and goods and in this way support economic growth. On the other hand, this could result in increased air pollution and carbon emissions - at least in the short to medium term, which is likely to result in potential conflicts with ISA objectives 1 and 2.

It is important to note that the nature of the LTP means that it will inherently result in a series of transport infrastructure interventions which in many cases will require considerable civil and other engineering works across large areas and the nature of these works will have environmental implications – as such there is always likely to be tension between economic growth and environmental issues such as air pollution and carbon emissions and the protection of the environment.

It was unclear how compatible this objective would be against ISA Objectives 3 – 11 which are focused on environmental impacts and ISA Objective 16 focused on promoting community safety and reducing crime. The level of compatibility regarding these objectives is dependent upon the nature of the implementation measures and policy actions, with the potential for either broad compatibility or potential for conflict. The implementation of measures and actions relating to other LTP3 Review objectives will have a bearing in terms of the overall level of compatibility, in particular between LTP Objective 3 Conserve the Environment and the ISA Objectives (see below).

No recommendations for this draft LTP3 Review Objective.

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Table 8-1 Initial compatibility assessment results

y and reduce reduce and y

being of all all beingof

id land contamination id land

Gloucestershire LTP Review 2015 - rshire

2041 Objectives (early draft)

er historic environment including historic including erenvironment

Reduce the need to travel by car or move move or to by Reducecar need travel the

ecosystem resilience and resilience ecosystem functionality

ISA Obj 1 Improve ISA air quality Obj 2 from Reduce ISA emissions carbon dioxide transport habitats, Obj 3 Protect protected enhance ISA and and sites,networks species, ecological valuable promote Obj geodiversity 4 Protect,enhance promote ISA and and Obj 5 Protect the enhance ISA character and visual qualityand townscapes ofand landscapes amenity Obj 6 Conserve heritage ISA enhance the and assets wid andthe and landscapes, buildings,townscapes structures, their archaeologicalremains and settings Obj 7 Protect the enhance ISA water and environment Obj 8 resourcesConserve ISA agricultural soil and avo andremediate seek / to Obj 9 Reduce ISA flooding risk of Obj finiteuse 10 natural thePromote ISA of prudent maximiseuse resources primary from the sources, andofmaterials, recycled alternative, secondary reducegenerated level of the waste Obj 11 ISA of modes sustainable roadgoodspromote by and transport Obj 12 and growth economic Promote ISA job for creation,to andall jobs improve access Obj transport 13 useCoordinate ISA and land planningGlouceste across Obj 14 and Improve ISA health well healthcitizensand in reduce inequalities Obj 15 ofgreaterPromote ISA opportunity equality of forachieving theoutcome all desired citizens, with afairer society Obj 16 Promote ISA safet community all citizens crimeof for fear crime and

Support Sustainable Economic X X ? ? ? ? ? ? ? ? ?     ? Growth

X X ? ? ? ? ? ? ? ?      ? Enable Community Connectivity

        ?  ?  ?  NR NR Conserve the Environment

Improve Community Health and Well-   ? ?  ?  ? ? ?   ?  ? ? being

Key:  Broadly Compatible X Potential Conflict Depending upon the nature of ? implementation measures NR Not Relevant / No Relationship

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8.3. LTP Review Objective 2: Enable Community Connectivity

The draft LTP Review objective 2 expressed a clear commitment to enable community connectivity, and therefore showed good compatibility with the ISA objectives 11-15 that relate to:

- Reduce the need to travel by car or move goods by road and promote sustainable modes of transport - Promote economic growth and job creation across the subregion and improve access to jobs for all - Coordinate land use and transport planning across Gloucestershire - Improve health and well-being of all citizens and reduce inequalities in health - Promote greater equality of opportunity for all citizens, with the desired outcome of achieving a fairer society

A number of uncertain outcomes were identified against some ISA objectives pursuing the protection of the environment (ISA objectives 3-10) but there is no expectation that LTP Review Objective 2 would address this sort of issues.

A shortfall was identified with regards to ensuring community safety (ISA objective 16) which an LTP Review objective such as this would need to cover. In addition, affordability of transport is an important consideration from an equalities perspective and was missing from the objective.

Recommendations: To improve compatibility with the ISA objective 16, it was suggested that the following amendments be made to the LTP Review objective 2. The terms ‘Safe’ and ‘Affordable’ be added in the objective to offer clarity on the purpose of the objective by wording it as follows: ‘Enable Safe and Affordable Community Connectivity’.

8.4. LTP Review Objective 3: Conserve the Environment

The draft LTP Review Objective 3 was found to be broadly compatible with the following ISA Objectives: - Improve air quality - Reduce carbon dioxide emissions from transport - Protect and enhance protected habitats, sites, species, valuable ecological networks and promote ecosystem resilience and functionality - Protect, enhance and promote geodiversity - Protect and enhance the character and quality of landscapes and townscapes and visual amenity - Protect and enhance the water environment - Conserve soil and agricultural resources and seek to remediate / avoid land contamination - Promote economic growth and job creation, and improve access to jobs for all - Promote the prudent use of finite natural resources from primary sources, maximise the use of alternative, secondary and recycled materials, reduce the level of waste generated. - Improve health and well-being of all citizens and reduce inequalities in health

The ISA Objectives related to equalities and community safety (ISA Objectives 15 and 16) bear no relationship to the draft LTP Review objective 3. However, these aspects are picked up through LTP Review objectives 1 and potentially 2, subject to the recommendation set out above with regards to draft LTP Review objective 2.

However, the objective presented two shortfalls: 1) The first was that it only refers to ‘conserve’ when most ISA objectives are aimed at ‘protecting and enhancing’ so the aspect of enhancement of the environment is lacking.

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2) Secondly, the term – ‘Environment’ can limit the scope to Natural environment alone, hence it was felt important to specify this refers to both the natural and built environment, as both need to be protected from the impacts of transport and enhanced.

Recommendations: In order to improve the overall compatibility with the ISA objectives, it was recommended that the meaning of the term – ‘Environment’ is clarified and that the scope includes both conservation and enhancement of the environment. Hence it is suggested that the LTP Review objective 3 should be reworded as – “Protect and Enhance the Natural and Built Environment”.

8.5. LTP Review Objective 4: Improve Community Health and Well-being

The draft LTP Review objective 4 was found to be broadly compatible with the following ISA objectives: - Improve air quality - Reduce carbon dioxide emissions from transport - Protect and enhance the character and quality of landscapes and townscapes and visual amenity - Protect and enhance the water environment - Reduce risk of flooding - Promote the prudent use of finite natural resources from primary sources, maximise the use of alternative, secondary and recycled materials, reduce the level of waste generated. Reduce the need to travel by car or move goods by road and promote sustainable modes of transport - Promote economic growth and job creation, and improve access to jobs for all - Improve health and well-being of all citizens and reduce inequalities in health

The compatibility between the ISA objectives (3-6, 8) focused on environmental protection and the draft LTP Review objective 4 was deemed uncertain and further detail on proposed implementation measures and actions in the LTP Review would be required to establish the positive or negative compatibility between them. These ISA objectives have been listed below as: - Protect and enhance protected habitats, sites, species, valuable ecological networks and promote ecosystem resilience and functionality - Protect, enhance and promote geodiversity - Conserve and enhance the heritage assets and the wider historic environment including buildings, structures, landscapes, townscapes and archaeological remains and their settings - Conserve soil and agricultural resources and seek to remediate / avoid land contamination

In addition, the compatibility between the draft LTP Review objective and ISA Objective 15 ‘Promote greater equality of opportunity for all citizens, with the desired outcome of achieving a fairer society’ was unclear and it was felt that it needed to be strengthened given that this objective deals with societal issues.

Recommendations: In order to improve the overall compatibility with ISA Objectives, it was recommended that the LTP Review Objective is amended slightly to include ‘promote equality of opportunity’. This would ensure that as well as health, the LTP Review will address issues such as promoting and ensuring a fairer society.

For each draft LTP Review objective, and as a final recommendation, further explanatory text is added to the document as to the reasons why each objective is important in the context of Gloucestershire and the key challenges that lie ahead was recommended. This would improve the understanding of the reader of GCC’s intentions, provide further clarification in terms of sustainability compatibility relationships between objectives and ultimately lead a well-formulated and encompassing policies.

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8.6. Conclusions

The final Draft LTP Review Objectives after the consideration of the recommendations by GCC are set out below:

Early draft LTP Review Objective Final Draft LTP Review Objective Enable Community Connectivity Enable Safe and Affordable Community Connectivity Conserve the Environment Protect and Enhance the Natural and Built Environment Improve Community Health and Well- Improve Community Health and Well-being and being Promote Equality of Opportunity

This further development of the LTP Objectives substantially improved the degree of compatibility between the two sets of objectives (see Table 8.2), with only a very small number of areas of uncertainty and potential conflict remaining. In addition, the logic map that has been inserted in the LTP Overarching Strategy in support of the revised Draft LTP Objectives provides the context of the LTP Objectives to the LTP Challenges and the LTP policies and further supporting has been added providing a justification to the importance of each of the LTP Objectives.

The main areas of uncertainty identified in the assessment, as well as areas of potential conflict, relate to the LTP Objective to ‘Support Sustainable Economic Growth’. This is not entirely surprising as probable interventions arising from implementation of this objective have the potential for both negative and positive sustainability outcomes. However, as the updated LTP include three strengthened Objectives to ‘Protect and Enhance the Built and Natural Environment’, ‘Improve Community Health and Well-being and Promote Equality of Opportunity’ and ‘Enable Safe and Affordable Community Connectivity’, these three enhanced ‘cross cutting’ Objectives should help to ensure that areas of uncertainty, or areas of potential conflict arising out of the implementation of the LTP objective to ‘Support Sustainable Economic Growth’, can be addressed as further implementation details are set out in the developing LTP. The three ‘cross cutting’ Objective thus provide a strong imperative in the LTP for maximising sustainable outcomes. The compatibility assessment therefore concluded that the revised Draft LTP Objectives provided a firm underpinning to help ensure that the sustainability performance of the plan could be maximised.

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Table 8-2 Final compatibility assessment results

ngs

being of all all beingof

e character and echaracter

Gloucestershire LTP Review 2015 from eemissions

mic growth and job micand growth job - 2041 Objectives (Final draft for erof opportunity equality

consultation)

m primary sources, maximiseuse m primary the sources,

ISA Obj 1 Improve ISA air quality Obj 2 Reduce ISA carbon dioxid transport habitats, Obj 3 Protect protected enhance ISA and and sites,networks species, ecological valuable promoteand resilience ecosystem functionality Obj geodiversity 4 Protect,enhance promote ISA and Obj 5 Protect th enhance ISA and visual qualityand townscapes ofand landscapes amenity Obj 6 Conserve heritage ISA enhance the and assetshistoric including wider andenvironment the and landscapes, buildings,townscapes structures, their archaeologicalremains and setti Obj 7 Protect the enhance ISA water and environment Obj 8 resourcesConserve ISA agricultural soil and contamination avoid andremediate land seek / to Obj 9 Reduce ISA flooding risk of Obj finiteuse 10 natural thePromote ISA of prudent resourcesfro andofmaterials, recycled alternative, secondary reducegenerated level of the waste move Obj or 11 to by Reduce ISA car need travel the of modes sustainable roadgoodspromote by and transport Obj 12 econoPromote ISA for creation,to andall jobs improve access Obj transport 13 useCoordinate ISA and land planningGloucestershire across Obj 14 and Improve ISA health well healthcitizensand in reduce inequalities Obj 15 greatPromote ISA of forachieving theoutcome all desired citizens, with afairer society reduce Obj 16 andPromote ISA safety community all citizens crimeof for fear crime and

X X ? ? ? ? ? ? ? ? ?     ? Support Sustainable Economic Growth

Enable Safe and Affordable Community ? ? ? ? ? ? ? ? ? ?       Connectivity Protect and Enhance the Natural and Built           ?    NR NR Environment

Improve Community Health and Well-being   ? ?  ?  ? ? ?   ?    and Promote Equality of Opportunity

Key:  Broadly Compatible X Potential Conflict Depending upon the nature of ? implementation measures NR Not Relevant / No Relationship

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9. Assessment of Alternatives

9.1. Introduction In conducting the ISA, account has been taken of the SEA Directive requirement that the Environmental Report should consider:

‘reasonable alternatives taking into account the objectives and the geographical scope of the plan or programme’ and ‘give an outline of the reasons for selecting the alternatives dealt with’ (Article 5.1 and Annex lh)’.

It is the intention that the LTP sets the long term strategy for transport in Gloucestershire, with the current LTP (LTP 2015-2031) adopted in Jun 2016. This LTP is now being reviewed, with the intention to reflect national, regional, county and local priorities that have changed during the plan period and to extend the time horizon of the LTP to 2041.

9.2. Defining the alternatives Previously in Gloucestershire, a district-based approach to Local Transport Plan delivery was undertaken, which focused on policies and interventions within individual existing administrative boundaries in Gloucestershire, notably the six districts and boroughs present in the county. For the purposes of the LTP 2015-2031 review, it was considered that the district-based approach should be replaced by a ‘Link and Place’ approach. The ‘Link and Place’ approach differed from the previous district-based perspective through introducing travel-focused strategy areas based on connections. This approach advocates the consideration of roads and railways as movement conduits (links) through and to places, with the identification of travel corridors, each of which with distinctive transport opportunities and pressures, in an approach termed ‘Connecting Places Strategy (CPS). Six CPS areas have been identified in Gloucestershire: Central Severn Valley, Forest of Dean, North Cotswold, South Cotswold, Stroud and Tewkesbury.

As such, as part of the SEA undertaken to inform the development of Gloucestershire’s LTP 2015-203190, two strategic and reasonable alternatives were considered:

 Option 1: Continue the existing district-based perspective to the LTP3; and  Option 2: Deliver a Connecting Places Strategy approach.

For the purposes of this current LTP review, the evidence base underpinning the ISA of the LTP Review has been updated and this has led to the development of a new, up to date, robust ISA Framework which contains a new set of ISA Objectives and a new series of assessment aid questions. As such, a review has been undertaken of the two strategic and reasonable alternatives examined previously, in the light of the new ISA Framework, to check that the previous findings are still valid.

9.3. Assessing the Alternatives The strategic alternatives of ‘Option 1 Continue the existing district based perspective to LTP3’ and ‘Option 2 Deliver a Connecting Places Strategy’ have been assessed using the ISA framework.

90 Gloucestershire LTP 2015-2031 SEA Environmental Report, AECOM 2015

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As previously, and to support the assessment findings, the two options have been ranked in terms of their sustainability performance relative to each other, with ranking 1 considered more sustainable than ranking 2. However, whereas previously, the two options were considered against environmental themes only, a more detailed approach has been taken, based on the full range of ISA Objectives set out in the new ISA Framework.

9.4. Alternatives assessment summary A discussion of the findings of the alternatives’ assessment follows. A summary of the results is shown in Table 9-1. Detailed assessment tables are set out in Appendix C.

Table 9-1 Summary of findings of Assessment of Alternatives

The focus of Option 2 on a number of wider geographical areas sharing transport and socio-economic features means that this option is likely to perform better and be more sustainable across the range of ISA Objectives for which it was possible to make a differentiation. For ISA Objective ‘Improve Air Quality’ the wider geographical approach will allow a clear focus on the eight AQMA within Gloucestershire, as well as a focus for such innovations such as developing an EV infrastructure network and green infrastructure such as cycling and walking routes. Similarly, it is considered that Option 2 will provide reduced carbon emissions (ISA Objective ‘Reduce CO2 emissions from Transport’) by more readily allowing consideration of individual pinch points, or those areas considered for ‘major growth’ and which are likely to lead to increased emissions. For ISA Objective ‘Protect and enhance protected habitats, sites, species, valuable ecological networks and promote ecosystem resilience and functionality’, it is considered that the wider geographical focus of Option 2 will provide more opportunities for biodiversity net gains and green infrastructure improvements. It is recognised though, that many biodiversity impacts can only be addressed in light of knowledge of individual transport schemes. For the same reasons, Option 2 is likely to benefit flood resilience of transport schemes and elsewhere (Reduce risk of flooding and increase resilience of the transport network to the effects of a changing climate) and efficient use of resources (Promote prudent use of finite natural resources from primary sources, maximise the use of alternative, secondary and recycled materials, reduce the level of waste generated). For a number of ISA Objectives, however, it is not possible to discern any difference between Option 1 and Option 2 as potential effects depend on the detailed location, design and layout of new infrastructure. Differences will depend on the detail of any schemes or initiatives being implemented and the specific nature of the local environment in which these will be placed. They are ISA Objectives ‘Protect, enhance and promote geodiversity’, ‘Protect and enhance the character and quality of landscapes and townscapes and visual amenity’, ‘Conserve and enhance heritage assets and the wider historic environment including buildings, structures, landscapes, townscapes and archaeological remains and their settings’ and ‘Conserve soil and agricultural resources and seek to remediate / avoid land contamination’. In addition to the wider geographical approach of Option 2 benefitting a range of environmental issues, largely through more opportunities to deliver environmental benefits such as biodiversity net gains and flood resilience, compared to Option 1, Option 2 provides a clearer focus on where people live and where they want to travel and the corridors along which these movements take place. These corridors dictate the link type, e.g. national, primary or district links and Option 2 allows detailed consideration of each of these corridor links and the characteristics of it, alongside the environment and such issues as ambience and place. As such, Option 2 would provide clear benefits (relative to Option 1) in terms of ‘Reduce the need to travel by car or move goods by road and promote sustainable modes of transport’, ‘Promote economic growth and job creation, and improve access to jobs for all’, ‘Co-ordinate land use and transport planning across Gloucestershire’. Similarly it is considered that Option 2 will provide benefits (relative to Option 1) in terms of ‘Promote greater equality of opportunity for all citizens, with the desired outcome of achieving a fairer society’, ‘Improve health and well-being for all citizens and reduce inequalities in health’ and ‘Promote community safety and reduce crime and fear of crime for all citizens’. These benefits will be derived from

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Option 2 allowing a closer reflection of the relevant infrastructure needs and measures required in each of the areas rather than administrative boundaries. This will provide increased potential to promote accessibility to services, facilities and amenities by a range of transport modes and meet the needs of the various communities of Gloucestershire. In conclusion, it is considered that Option 2 ‘Deliver a Connecting Places Strategy’ approach remains the favoured alternative for the development of the LTP. The focus of Option 2 on a number of wider geographical areas sharing transport and socio-economic features means that this option is likely to perform better and be more sustainable across the range of ISA Objectives for which it was possible to make a differentiation. For ISA Objective ‘Improve Air Quality’ the wider geographical approach will allow a clear focus on the eight AQMA within Gloucestershire, as well as a focus for such innovations such as developing an EV infrastructure network and green infrastructure such as cycling and walking routes. Similarly, it is considered that Option 2 will provide reduced carbon emissions (ISA Objective ‘Reduce CO2 emissions from Transport’) by more readily allowing consideration of individual pinch points, or those areas considered for ‘major growth’ and which are likely to lead to increased emissions. For ISA Objective ‘Protect and enhance protected habitats, sites, species, valuable ecological networks and promote ecosystem resilience and functionality’, it is considered that the wider geographical focus of Option 2 will provide more opportunities for biodiversity net gains and green infrastructure improvements. It is recognised though, that many biodiversity impacts can only be addressed in light of knowledge of individual transport schemes. For the same reasons, Option 2 is likely to benefit flood resilience of transport schemes and elsewhere (Reduce risk of flooding and increase resilience of the transport network to the effects of a changing climate) and efficient use of resources (Promote prudent use of finite natural resources from primary sources, maximise the use of alternative, secondary and recycled materials, reduce the level of waste generated). For a number of ISA Objectives, however, it is not possible to discern any difference between Option 1 and Option 2 as potential effects depend on the detailed location, design and layout of new infrastructure. Differences will depend on the detail of any schemes or initiatives being implemented and the specific nature of the local environment in which these will be placed. They are ISA Objectives ‘Protect, enhance and promote geodiversity’, ‘Protect and enhance the character and quality of landscapes and townscapes and visual amenity’, ‘Conserve and enhance heritage assets and the wider historic environment including buildings, structures, landscapes, townscapes and archaeological remains and their settings’ and ‘Conserve soil and agricultural resources and seek to remediate / avoid land contamination’. In addition to the wider geographical approach of Option 2 benefitting a range of environmental issues, largely through more opportunities to deliver environmental benefits such as biodiversity net gains and flood resilience, compared to Option 1, Option 2 provides a clearer focus on where people live and where they want to travel and the corridors along which these movements take place. These corridors dictate the link type, e.g. national, primary or district links and Option 2 allows detailed consideration of each of these corridor links and the characteristics of it, alongside the environment and such issues as ambience and place. As such, Option 2 would provide clear benefits (relative to Option 1) in terms of ‘Reduce the need to travel by car or move goods by road and promote sustainable modes of transport’, ‘Promote economic growth and job creation, and improve access to jobs for all’, ‘Co-ordinate land use and transport planning across Gloucestershire’. Similarly it is considered that Option 2 will provide benefits (relative to Option 1) in terms of ‘Promote greater equality of opportunity for all citizens, with the desired outcome of achieving a fairer society’, ‘Improve health and well-being for all citizens and reduce inequalities in health’ and ‘Promote community safety and reduce crime and fear of crime for all citizens’. These benefits will be derived from Option 2 allowing a closer reflection of the relevant infrastructure needs and measures required in each of the areas rather than administrative boundaries. This will provide increased potential to promote accessibility to services, facilities and amenities by a range of transport modes and meet the needs of the various communities of Gloucestershire. In conclusion, it is considered that Option 2 ‘Deliver a Connecting Places Strategy’ approach remains the favoured alternative for the development of the LTP.

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10. Assessment of Revised Draft LTP Policy Proposals

10.1. Introduction This section predicts and evaluates the likely sustainability effects arising from the policy proposals in the Revised Draft LTP (draft dated September 2019), puts forwards recommendations in order to address shortfalls identified during the assessment and then considers the amendments made to the policies by GCC to address the recommendations.

Contained within the Revised Draft LTP are a series of policies which aim to ensure that the Vision and Objectives that have been set out are achieved. For the purposes of assessment, these policies have been assessed on an individual basis, in terms of those policies which are considered ‘cross cutting’ and as such apply across the whole of the Revised Draft LTP, or on a grouped ‘themed’ basis, in terms of those policies which are considered to be focused on and address key elements of transportation. The policies were considered as set out on Table 10-1.

Table 10-1 Draft Revised Draft LTP Policies (as at September 2019)

Policy Type

Policy Policy Text

Large PD3.1 Gloucestershire’s Freight GCC in its role as Local Highway Authority will work in partnership with Infrastructure Network Highways England, neighbouring highway authorities, Network Rail, – Rail & Parish/Town/District Councils and the Police to maintain a functioning freight network, by ensuring the safe and expeditious movement of goods vehicles

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Highways using the highway, whilst working towards decarbonising road and rail freight by 2050.

PD3.3 Driver Facilities (Freight) GCC will support facilities for drivers to rest. These will be provided at suitable locations on or near the primary route corridors used by HGV traffic.

PD4.2 Highways Network GCC will provide a resilient highway network that can withstand unforeseen Resilience events, including extreme weather events and long term changes to the climate.

PD1.1 Gloucestershire’s Bus GCC will take appropriate action to develop and maintain a comprehensive bus Network network in line with the standards set out below.

Tier 1 A route that is one or more of:

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PD1.3 Bus Priority To manage the use and develop bus priority to facilitate the free movement of buses along congested routes, ensuring the safe movement of all highway users.

PD1.5 Community Transport GCC will support those with limited travel choice and support local communities to develop innovative responses to local transport need.

PD6.3 Pedestrian Asset GCC will manage pedestrian infrastructure in line with the Highways Asset Management Management Framework and other guidance or

policies such as the Code of Practice for Well Managed Highways Infrastructure

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with partners to improve personal safety perceptions of using the transport network services and promote the use of public and active travel options to contribute to enjoyment and psychological wellbeing

10.2. Assessment of Cross Cutting policies As noted in Table 10-1, the identified cross cutting policies were:

 PD0.1 Reducing Transport Carbon Emissions  PD0.2 Local Environmental Protection  PD0.3 Maximising Investment in a Sustainable Transport Network  PD0.4 Integration with land use planning and new development  PD0.5 Community Health & Wellbeing  PD0.6 ThinkTravel - Influencing Travel Behaviour (considered alongside ‘PD1.7 Communicating Travel Information’ and ‘PD2.3 Active Travel: Safety, Awareness and Confidence’. These policies act to address issues relating to reducing transport carbon emissions, protecting the environment, maximising sustainable investment, integrating land use planning and community health and wellbeing across all elements of the LTP.

The assessment results (as set out in Table 10-2 and detailed in Appendix D) identified a considerable number of areas of strength, in terms of sustainability performance, for each of the cross cutting policies. prior to consideration of the recommendations made by the ISA.

Table 10-2 Assessment of Draft Revised Draft LTP Cross Cutting Policies (as at September 2019)

Plan Element ISA Objective 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Policies Cross Cutting PD0.1 Reducing Transport Carbon Emissions ++ + + 0 + + 0 0 - + + + 0 + + 0 PD0.2 Local Environmental Protection ++ ++ + + ------++ ++ + 0 ++ ++ 0 + + PD0.3 Maximising Investment in a Sustainable + + + + + + + + + + ++ + ++ + + + Transport Network PD0.4 Integration with land use planning and new + + + + + 0 0 0 + 0 ++ + ++ + + 0 development PD0.5 Community Health & Wellbeing ++ ++ 0 0 0 0 0 0 0 0 ++ ++ 0 ++ ++ + PD0.6 Influencing Travel Behaviour ++ ++ 0 0 0 0 0 0 0 0 ++ 0 0 ++ ++ ++ +

ISA Objective

1 Improve Air Quality

2 Reduce carbon dioxide (CO2) emissions from transport

3 Protect and enhance protected habitats, sites, species, valuable ecological networks and promote ecosystem resilience and functionality

4 Protect, enhance and promote geodiversity

5 Protect and enhance the character and quality of landscapes and townscapes and visual amenity

6 Conserve and enhance heritage assets and the wider historic environment including buildings, structures, landscapes, townscapes and archaeological remains and their settings.

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