Management Plan Review Strategic Environmental Assessment Environment Report Cotswolds AONB

Management Plan Review Strategic Environmental Assessment Environment Report Cotswolds AONB Craggatak Consulting 10 October 2018

THE CRAGG, SATTERTHWAITE Nr ULVERSTON, CUMBRIA LA12 8LW 01229 860269 enquiries@craggatak.co.uk www.craggatak.co.uk Contents Acknowledgements... ii Strategic Environmental Assessment Non-technical Summary... iv 1. Background... 1 Strategic Environmental Assessment... 1 Purpose of the Environment Report... 2 Cotswolds AONB... 2 Cotswolds Conservation Board... 2 Management Plan review... 3 Relationships with other assessments... 4 Relationship to other policies, plans and programmes... 5 Legislation, Conventions and national advice... 6 Local Authorities... 7 Government Agencies... 8 2. Environmental baseline information... 8 Key local environmental trends... 8 Relevant environmental problems... 9 3. Environmental Assessment... 9 Methodology... 9 Compatibility between Management Plan policies... 10 Consistency with SEA Objectives... 12 Consistency of Management Plan Policies to combined SEA Objectives... 13 Consistency of combined Management Plan Policies to SEA Objectives... 13 Findings... 14 Review of alternative policies... 14 i P a g e CRAGGATAK Consulting www.craggatak.co.uk

4. Monitoring... 14 Monitoring of significant environmental effects... 14 Monitoring Measures... 15 Data limitations... 15 5. Technical review... 15 Quality of existing baseline data... 16 6. Response to Environmental bodies comments... 17 7. Conclusion... 17 8. Appendices... 19 Appendix 1: Management Plan Policy Cascade... 19 Appendix 2: List of relevant plans and policies... 31 Appendix 3: Outline of future trends in the Cotswolds AONB... 34 Appendix 4: Key indicators and data sources... 36 Appendix 5: SEA Objectives and Environmental Issues... 38 Appendix 6: Review of alternative policies... 41 Appendix 7: SEA Objectives and links to State of the AONB Reporting... 58 Appendix 8: Précis of consultation responses... 61 Acknowledgements Craggatak Consulting prepared this report with the close support of staff from the Cotswolds Conservation Board. ii P a g e CRAGGATAK Consulting www.craggatak.co.uk

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Strategic Environmental Assessment Non-technical Summary Introduction This is a summary of the Strategic Environmental Assessment (SEA) of the Cotswolds Area of Outstanding Natural Beauty (AONB) Management Plan Review. Strategic Environmental Assessment is a legal requirement 1 to identify, describe and evaluate any significant environmental effects arising from implementing the management plan, or any reasonable alternatives. It highlights any significant beneficial effects and records any residual negative effects taking into account any mitigating measures. There are five stages to a Strategic Environmental Assessment: Stage A: Setting the context, establishing the baseline and deciding on the scope Stage B: Developing and refining options and assessing effects Stage C: Preparing the Environmental Report Stage D: Consultation with the public and consideration of the SEA findings by the decision maker; and Stage E: Monitoring the significant effects of implementing the plan The Cotswolds AONB Conservation Board has a legal duty to prepare and publish a Management Plan for the AONB 2. The plan sets out a framework that gives guidance and direction towards achieving the long term Vision for the Cotswolds AONB. The Management Plan has a cascade of 24 policies falling under three themes. Environmental baseline information Baseline environmental information has been developed and refined since the start of the process in order to establish the context of the Management Plan and predict how the conditions would progress in the absence of that plan. The assessment uses eight Environmental Objectives to represent the local environmental issues. They test whether the Management Plan objectives (or their absence) create adverse impacts on the special qualities of the Cotswolds AONB. Summary of the appraisal The proposed objectives are compatible. There are no tensions or sensitivities arising from where two or more objectives interact. The proposed policy cascade has a beneficial, and in parts a significantly beneficial, effect on the SEA Environmental Objectives. When analysed in combination, the policies show the greatest consistency with the SEA Objectives to conserve and enhance natural beauty, biodiversity and local distinctiveness. This reflects the purpose of AONB designation. A particularly welcome finding is that working in partnership, natural capital and rural land management also have strong positive relationships. This suggests that the plan is seeking to deliver the Government s priorities for the countryside, as set out in A Green Future (2018). The sustainability topics all receive positive treatment within the management plan but their subject areas have a narrow definition. The result is that they show fewer relationships. The weakest relationship is with quality of life. There are no adverse effects on the SEA Environmental Objectives so there is no need to consider measures to increase the beneficial effects but opportunities exist to do so. There is no recommendation for mitigating actions. 1 Directive 2001/42/EC on the assessment of the effects of certain plans and programmes on the environment. Transposed into law by Statutory Instrument 2004 No. 1633 The Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA Regulations ), http://www.opsi.gov.uk/si/si2004/sch1 2 Section 89 of the Countryside and Rights of Way Act 2000 iv P a g e CRAGGATAK Consulting www.craggatak.co.uk

The proposed objectives consistently give greater environmental benefits than the do-nothing situation. However, the benefits are only marginally better than the do-nothing scenario for the socio-economic and community trends. The objectives can deliver a sustainable programme for the management of the Cotswolds AONB. Monitoring The SEA Regulations require monitoring measures for all the significant effects, both positive and negative, identified in the assessment. The SEA of the draft management plan has identified no significant negative effects that are likely to arise from the implementation of management plan. Some significant positive effects are likely to arise from the implementation of the plan. The assessment has also identified some areas of uncertainty over the significance of some of the predicted effects and monitoring has therefore been considered to cover these effects as well. The monitoring requirements will become a part of the State of the AONB Report. Forty eight indicators are proposed, twenty four of which are already in the State of the AONB Report. The overall assessment of the current baseline data is that it is adequate. The weakness is in the reliance on indicative data. Very little information about water and air quality, or climate change is presented. The traditional concerns of an AONB are covered well (landscape character, biodiversity and heritage). Consultation The SEA Scoping Report went out for consultation in February 2018 and Natural England, the Environment Agency and Historic England each gave written comments. Their comments were generally supportive but each suggested additional material. These suggestions are accepted and the text modified. The SEA Environmental Report went out for consultation in July 2018 and Natural England, the Environment Agency and English Heritage were supportive of the SEA approach and findings. The Environment Agency (and Oxfordshire County Council) noted the finding that very little information about water and air quality, or climate change is presented in the Management Plan. The Environment Agency also identified flood risk as being a further weakness. Although Natural England did not comment on these issues in relation to the SEA, it did suggest (when commenting on the Management Plan) that the climate change section could be strengthened. In response, these sections of the Management Plan were redrafted to make them stronger. The changes made do not require a formal re-assessment of the SEA as they reflect the SEA conclusions. However, a short proofing test showed that the Management Plan now aligns even more closely to the SEA Objectives. This is due to the strengthening of the sections relating to climate change, air quality, water and flood risk. Conclusion There is nothing in the management plan that will undermine the special qualities of the AONB. There is no conflict with objectives in one part of the plan with those in another. Implementation of the proposed Management Plan will have environmental benefits for the Cotswolds AONB. A full version of the SEA Environmental Report is available from: The Cotswolds Conservation Board, The Old Police Station, Cotswold Heritage Centre, Northleach, GLOUCESTERSHIRE. GL54 3JH v P a g e CRAGGATAK Consulting www.craggatak.co.uk

1. Background 1.1. This Environmental Report has been prepared as part of the Strategic Environmental Assessment (SEA) of the Cotswolds Area of Outstanding Natural Beauty (AONB) Management Plan Review. The statutory consultation bodies (Natural England, Historic England and the Environment Agency) must agree the scope and level of detail to be contained in the Environmental Report. The SEA Scoping Report went out for consultation during February and March 2018. 1.2. Natural England, the Environment Agency and Historic England each gave written comments. Their comments were generally supportive but each suggested additional material. These suggestions are accepted and the text modified. Since the SEA Scoping Report was finalised, Natural England has advised that a pragmatic and proportionate approach be taken, focussing on the most significant environmental impacts. As AONB Management Plans are not the subject of Sustainability Appraisals, we reduced the number of SEA objectives from seventeen to eight, focussing on those topics that are an essential component of an SEA for an AONB Management Plan 3. Strategic Environmental Assessment 1.3. Strategic Environmental Assessment is a statutory requirement 4 to ensure that land-use plans and programmes that are likely to have significant effects on the environment are the subject of a strategic assessment of options and alternative courses of action during plan preparation in order to avoid or mitigate any adverse effects. The approach for carrying out the SEA of the AONB Management Plan Review is based on current best practice and the following guidance: HMSO (September 2005) A Practical Guide to the SEA Directive, Office of the Deputy Prime Minister, Scottish Executive, Welsh Assembly Government, Department of the Environment for Northern Ireland. Dodd et al (2007) The Appropriate Assessment of Spatial Plans in England: a guide to why, when and how to do it, RSPB. Natural Scotland (September 2006) Strategic Environmental Assessment Toolkit. Scottish Executive. Countryside Council for Wales (2008) The Areas of Outstanding Natural Beauty in Wales - Guidance on the Review of Management Plans Richard Partington et al (January 2008) Guidance to English AONB Conservation Board s and Boards on Strategic Environmental Assessment (SEA) of AONB Management Plans, Natural England 1.4. In order to integrate fully the SEA process with the production of the Management Plan there is close collaboration with the review team. There are five stages to a Strategic Environmental Assessment: Stage A: Scoping and consultation with Environmental Bodies 3 Natural England (2008) Guidance to English AONB Partnerships and Boards on Strategic Environmental Assessment of AONB Management Plans. 4 Directive 2001/42/EC on the assessment of the effects of certain plans and programmes on the environment. Transposed into law by Statutory Instrument 2004 No. 1633 The Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA Regulations ), http://www.opsi.gov.uk/si/si2004/sch1 1 P a g e CRAGGATAK Consulting www.craggatak.co.uk

Stage B: Stage C: Stage D: Stage E: Assessment of plan content and analysis of alternatives Preparation of an Environmental Report Consultation with the public and consideration of the SEA findings by the decision maker; and Monitoring the performance of the plan against the SEA findings. 1.5. This report supports Stages B and C. The SEA Scoping Report consultation responses have been considered and used to inform relevant sections of the SEA Environmental Report (this document). Purpose of the Environment Report 1.6. This Environmental Report sets out the findings of the Strategic Environmental Assessment for the Cotswolds AONB Management Plan review. Its primary purpose is to identify, describe and evaluate any significant environmental effects arising from implementing the management plan, or any reasonable alternatives. Any significant beneficial effects are highlighted, as well as recording any residual negative effects once mitigating measures are taken into account. 1.7. This assessment follows the requirements of the European Directive 2001/42/EC 5 and the Environmental Assessment of Plans and Programmes Regulations 2004 6. The methodology used follows the guidance set out in paragraph 1.3. Cotswolds AONB 1.8. Designation of the Cotswolds AONB was in 1966 with an extension in 1990. At 2038 sq. kms, it is the largest of the AONBs and third largest protected landscape in England, including the National Parks. It is an area shaped by its geology and thousands of years of human activity resulting in a unique landscape of remarkable visual unity and scenic diversity. Many features of the Cotswolds evoke strong images. Its central feature is the Cotswolds Hills that rise gently from the broad, green meadows of the upper Thames to crest in a dramatic escarpment above the Severn Valley and Evesham Vale. Rural England at its most mellow, the landscape draws a unique warmth and richness from the famous limestone beauty of its buildings. 1.9. Since designation in 1966, much has changed in the Cotswolds. Many things drive this change. The main factors are technological advances in agriculture, increasing commodity prices and demand, population growth and migration, changes in employment and communications. Government policy and financial support have had an influence on all these factors. To retain the characteristics that define the Cotswolds, there is a need to manage and guide landscape change. Cotswolds Conservation Board 5 European Directive 2001/42/EC on the assessment of the effects of certain plans and programmes on the environment, known as the Strategic Environmental Assessment or SEA Directive. 6 SEA Directive, 2001/42 transposed into English law through the Environmental Assessment of Plans and Programmes Regulations 2004 (Statutory Instrument No 1633) 2 P a g e CRAGGATAK Consulting www.craggatak.co.uk

1.10. The Cotswolds Conservation Board was established by Parliament in 2004 and has two statutory purposes: 7 to conserve and enhance the natural beauty of the AONB; and to increase the understanding and enjoyment of the special qualities of the AONB. In fulfilling these roles, the Board has a duty to seek to foster the economic and social wellbeing of people living in the AONB. Management Plan review 1.11. Section 82 of the Countryside and Rights of Way (CRoW) Act 2000 establishes the primary purpose of AONB designation as the conservation and enhancement of natural beauty. Section 85 of the CRoW Act places a duty on all public bodies to have regard to the purpose of conserving and enhancing the natural beauty of the area of outstanding natural beauty. Under Section 89, the relevant local authorities must prepare and publish a Management Plan for each AONB. 1.12. The Cotswolds Conservation Board is the relevant body under the CRoW Act in respect of AONB Management Plans for the Cotswolds AONB. The Management Plan is a statutory document and presents an agreed agenda for the AONB, setting out objectives and policies for the local authorities, statutory agencies and people who live and work in the area. The plan does not dictate actions within the designated area and does not control agriculture, business or economic development activities but seeks to manage change positively. 1.13. The current AONB Management Plan is for the 2013-18 period. CRoW requires a formal review of each Management Plan at intervals of not more than five years. The Board is now preparing the 2018-2023 Management Plan. Following consultation with local communities, public bodies and agencies with an interest in the area, the Management Plan will present a vision and the special qualities of the AONB; and determine what actions are required to ensure their conservation and enhancement. 1.14. The plan sets out a framework that gives guidance and direction towards achieving the long term Vision for the AONB. The Vision and Special Qualities come from extensive study and consultation. The Vision for the Cotswolds Area of Outstanding Natural Beauty by 2038 A distinctive, unique living, accessible landscape treasured for its diversity which is recognised by all for its wide open views, dry stone walls, intimate valleys, flower rich grasslands, ancient woodlands and distinctive Cotswold stone architecture. A thriving collaborative, pioneering, proactive place, sustained by the passions of residents, visitors and businesses alike where rural communities and the local economy are grounded in its special qualities. 7 Section 87, Countryside and Rights of Way Act 2000 as amended by the NERC Act 2006. 3 P a g e CRAGGATAK Consulting www.craggatak.co.uk

1.15. At its heart, the Management Plan has three overarching themes upon which to base topic specific outcomes and policies. These core themes act as golden threads running throughout the plan and are: Cross Cutting Conserving and Enhancing Increasing Understanding and Enjoyment 1.16. They set the wider context for all policies across the whole plan. The current draft of the Management Plan contains 3 themes and 24 policies. The list of policies is in Appendix 1. Fourteen outcomes support the themes: A. Cross Cutting 1. Working Together 2. Natural and Cultural Capital and Ecosystem Services 3. Climate Change B. Conserving and Enhancing 4. Landscape 5. Local Distinctiveness 6. Tranquillity 7. Dark Skies 8. Historic Environment 9. Biodiversity 10. Rural Land Management 11. Development and Transport C. Understanding and Enjoying 12. Sustainable Tourism, 13. Access and Recreation 14. Health and Wellbeing 1.17. In this draft, there is no list of actions. Instead, it states that actions the Board intends to take will be set out in its three-year rolling business plan. The business plan is not a part of this assessment. Relationships with other assessments Habitat Regulation Assessment 1.18. The EU Natura 2000 network provides ecological infrastructure for the protection of sites that are of exceptional importance in respect of rare, endangered or vulnerable natural habitats and species within the European Community. These sites, known as European sites, consist of Special Areas of Conservation (SAC), Special Protection Areas (SPA) and Offshore Marine Sites. It is common practice to treat RAMSAR sites (Internationally Important Wetlands) as if they were European sites. The guidance recommends taking into consideration European sites within the plan area and within 15km of its boundary. 1.19. There are 5 European sites within the AONB and 15 within 15km of its boundary. During the Scoping exercise, the presumption was that 13 European sites were within 15km of the 4 P a g e CRAGGATAK Consulting www.craggatak.co.uk

boundary. The number is updated following an analysis using MAGIC Map 8. The relevant European sites for the Cotswolds AONB are: European Sites within the AONB boundary Special Areas of Conservation Bath and Bradford on Avon Bats SAC Bredon Hill SAC Cotswold Beechwoods SAC Dixton Woods SAC Rodborough Common SAC European Sites within 15km of the AONB boundary Special Areas of Conservation Avon Gorge Woodlands SAC Cothill Fen SAC Mells Valley SAC Mendip Woodlands SAC North Meadow and Clattinger Farm SAC Oxford Meadows SAC Salisbury Plain SAC Severn Estuary SAC Wye Valley and Forest of Dean Bat Sites SAC Special Protection Areas & RAMSAR Chew Valley Lake SPA Salisbury Plain SPA Severn Estuary RAMSAR Severn Estuary SPA Walmore Common RAMSAR Walmore Common SPA 1.20. Habitat Regulations Assessment is a statutory requirement 9 to ensure that the protection of the integrity of European sites is a part of the planning process at a regional and local level. Any plan or project not directly connected to the management of the European site but likely to have a significant effect upon it (either individually or in combination with other plans or projects) shall be the subject of an appropriate assessment of its implications for the European site in view of the site s conservation objective. The Cotswolds AONB Management Plan is the subject of an appropriate assessment. Relationship to other policies, plans and programmes 1.21. A key element in the SEA process is to review relevant international, national, regional and local policy guidance, plans and strategies, in order to: Ensure the Management Plan proposals and the SEA are consistent with and comply with the requirements of relevant plans and policies, especially where they refer to environmental priorities; Identify environmental objectives, key targets and indicators that should be reflected in the SEA; Provide evidence for the SEA rationale. The selection criteria were: International documents having the status of an EU plan, policy or programme National documents having the status of a national strategy or a White Paper outlining intended policy Regional and local documents having the status of strategy or policy 8 The Government s open-access mapping service at http://magic.gov.uk/ 9 Council Directive 92/43/EEC of 21st May 1992 on the conservation of natural habitats and of wild fauna and flora. Transposed into law by the Conservation (Natural Habitats) Regulations 1994 (Habitats Regulation) as amended in 1997 and in 2000 (in England only) as amended in 2017 (SI 1012). 5 P a g e CRAGGATAK Consulting www.craggatak.co.uk

Other documents not having a statutory status but policy documents published by the statutory bodies Appendix 2 presents a list of the documents reviewed. Full reference details and a brief assessment of each document are in the SEA Scoping Report. Legislation, Conventions and national advice 1.22. Area of Outstanding Natural Beauty is a statutory landscape designation. The National Parks and Access to the Countryside Act 1949, as modified by the Countryside and Rights of Way Act 2000, provides the primary legislation for the designation of Areas of Outstanding Natural Beauty. From the Acts, a particular set of objectives is developed for AONBs 10 : The primary purpose of designation is to conserve and enhance natural beauty. In pursuing the primary purpose of designation, account should be taken of the needs of agriculture, forestry, other rural industries and of the economic and social needs of local communities. Particular regard should be paid to promoting sustainable forms of social and economic development that in themselves conserve and enhance the environment. Recreation is not an objective of designation, but the demand for recreation should be met so far as this is consistent with the conservation of natural beauty and the needs of agriculture, forestry and other uses. 1.23. The European Landscape Convention was ratified by the UK in November 2006 and became binding on the 1 March 2007. The Convention aims to ensure the proper protection, management and planning of landscapes across Europe and aims to bring all countries up to the standard of the best. 1.24. In 2012, Defra and Natural England gave advice to AONB Conservation Board s and Relevant Authorities on management plan reviews in the form of a note. The note highlights four themes that may require some policy response. They are: 1. Natural Environment White Paper (NEWP) Many objectives of NEWP have direct relevance for Protected Landscapes. The Defra Biodiversity 2020 Delivery Plan also encourages large-scale initiatives in AONBs and has the milestone: AONB Conservation Board s to integrate Biodiversity 2020 and ecosystem targets into all AONB Management Plan Reviews by March 2014. 2. Climate change mitigation There is a need to assess the opportunities and threats to protected landscapes, given the progress made in renewable energy production and the development of adaptation measures. 3. Setting of Protected Landscapes There is a greater imperative to consider the effect of development in the setting of protected landscapes. 4. Historic Environment Cultural features, particularly those of historic interest, can profoundly influence our perception of natural beauty. For this reason, it is appropriate for AONB Management Plans to include policies and provisions supporting conservation of the historic environment. 10 Countryside Agency (2006), Guidance for the review of AONB Management Plans, CA221, Cheltenham, August 2006 6 P a g e CRAGGATAK Consulting www.craggatak.co.uk

1.25. Following the passing of the European Union (Notification of Withdrawal) Act 2017, the UK s extraction from the European Union (Brexit) will take place during the life of the Management Plan. The 30 th September 2018 is the target date for agreeing the Brexit Terms and the 29 th March 2019 is set to be the day of Brexit. However, these dates can change by agreement; and the UK Government has the option of stopping the exit process at any time. By the end of September 2018 there will be a more certain understanding of the implications of Brexit. 1.26. The natural environment of the Cotswolds currently benefits from considerable support from EU budgets. That support is very likely to stop unless the UK government gives a clear undertaking to match the existing funding. There could be a period of inertia whilst building new resources and structures. 1.27. In January 2018, the Defra Secretary of State spoke to the NFU conference. He said that he anticipates guarantees to protect the amount Defra allocates to farming support right up until the end of this Parliament in 2022. He expressed the wish to simplify the support schemes and eventually replace basic farm payments with a system of public money for public goods. The Secretary of State only discussed agricultural support; he gave no views on the other areas of EU funding. 1.28. In 2018, the Government launched its 25-year plan for the environment 11 that includes an action to work with AONB Conservation Board s and Conservation Boards to deliver environmental enhancement, including through demonstrator projects, and engaging with communities through their statutory management plans. There is also a strong desire to develop a natural capital approach to ensure that policies align with environmental outcomes and yield the best return on every pound spent. The Government believes that investments in natural capital assets can deliver significant value for money and generate economic returns that rank favourably with those generated by more traditional infrastructure investments. Defra expect the AONB Management Plan to secure the right mix of public and private funding and financing for projects that protect and enhance natural assets. Local Authorities 1.29. The AONB lies with the bounds of 15 local authorities. These are of three types, Unitary Authorities, County Councils and District (or Borough) Councils. The County Councils have many responsibilities but two have a direct effect on the AONB. As the minerals and waste authorities, they produce minerals and waste local plans. They also deal with local transport, highways and tourism. The District Councils are required to produce development plans to guide spatial change and growth within their areas. These plans set out the vision and framework for future development in their area. They address needs and opportunities in relation to the economy, housing, community facilities and infrastructure; as well as provide a basis for safeguarding the environment 11 The Government (2018) A Green Future: Our 25 Year Plan to Improve the Environment, HMSO 7 P a g e CRAGGATAK Consulting www.craggatak.co.uk

(including the AONB), adapting to climate change and securing good design. The Unitary Councils have both the County and the District responsibilities. Government Agencies 1.30. There is a range of Government Agencies whose actions impact upon the AONB. Their strategies set high-level policy and generally cover the whole of the country. Any mention of a particular site, such as the Cotswolds, within these policies indicates the high national importance of the topic. The Environment Agency has an interest in the protection of inland surface waters (rivers and ponds) and groundwater in the AONB. This includes the quality and supply of water and flood defences. There is protection for around 4% of the area for wildlife and there are two National Trails, with Natural England monitoring management. Historic England has an interest in the registered parks and gardens, registered battlefields, scheduled monuments and the many listed buildings in the area. 2. Environmental baseline information Key local environmental trends 2.1. The SEA Directive requires detailed baseline information to be gathered as part of the assessment process. Information must be gathered 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)). 2.2. The baseline data is also required to highlight 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)). 2.3. To assess future trends there is a need to establish a baseline. The AONB team maintains a State of the AONB Report that presents an assessment of the area s condition and the forces for change. For developing this SEA Report, we use the State of the AONB Reports, Natural England s State of the Environment (South West) Report, Natural England s Cotswolds National Character Area Profile 107 12 and the evidence-base attached to the preparation of the local authority Local Development Plans. 2.4. The key issues associated with the environmental trends within the AONB and the likely outcomes if no action is taken are shown in Appendix 3. 2.5. Baseline information was collected in line with the Schedule 2 of the SEA Regulations. During the SEA Scoping exercise, 61 key indicators found in the base-line table were grouped under eight SEA topics identified as being of particular relevance to the environmental assessment. The eight topics are: 1) Landscape 12 Note that a number of National Character Area profiles apply to the Cotswolds. The dominant profile is Area 107 (Cotswolds) but see also Areas 95, 96, 106, 117 and 118. All can be read at: https://www.gov.uk/government/publications/national-character-area-profiles-data-for-local-decisionmaking/national-character-area-profiles 8 P a g e CRAGGATAK Consulting www.craggatak.co.uk

2) Biodiversity 3) Heritage 4) Local Distinctiveness 5) Soils, Air and Water 6) Climate Change 7) Quality of Life 8) Cumulative Impacts Following the initial assessment there was a reduction of the list to 48 indicators. The indicators are in Appendix 4. Relevant environmental problems 2.6. The State of the AONB Report assesses the current condition of the area s special features. For the SEA Assessment, eight SEA Environmental Objectives were developed 13. They represent the local environmental issues and they will test whether the Management Plan policies (or their absence) create adverse impacts on the special qualities of the Cotswolds AONB. Appendix 5 presents the SEA Environmental Objectives, complete with the associated issues. 3. Environmental Assessment Methodology 3.1. Step 1 is to consider the Management Plan draft text and test the compatibility of its objectives and policies. The intent is to identify potential tensions or sensitivities where two or more objectives interact. We collect the findings in a Compatibility Matrix and summarise them in a chart. 3.2. Using professional judgement, each relationship is plotted as: = strong positive = positive +/- = mixed or uncertain Blank or 0 = minimal interaction = negative A commentary develops the findings to take account of the varying environmental sensitivities of the different topic areas. The consideration of the compatibility of the vision for the AONB and the defined special qualities of the area is a part of this stage. We express this as a Policy Cascade supported by the commentary. 3.3. Step 2 is to check each objective against the full range of SEA Objectives, as identified in the SEA Scoping Report. The intent is to measure the significance of the effect in terms of: Beneficial or adverse effects; 13 See Paragraph 1.2: number reduce from x to 8 as there is no Sustainability Assessment 9 P a g e CRAGGATAK Consulting www.craggatak.co.uk

Magnitude of the effects; Reversible or irreversible effects. 3.4. The findings emerge in a Consistency Matrix. A plot of each relationship uses the same discipline as for the Compatibility Matrix. 3.5. Step 3 is to consider Alternative Solutions to the issues identified during the management planning process. As there is no alternative solution published, we make a do-nothing comparison. The purpose is to show that the chosen pathway is the most sound in terms of the environment and wider sustainability. This analysis tests the proposed actions and the donothing scenario against the trends identified in the SEA Scoping Report (as shown in Appendix 3). 3.6. Finally, Conclusions are drawn and presented. Compatibility between Management Plan policies 3.7. The first task was to check each Policy of the management plan against each other in a Compatibility Matrix to see whether there were any potential tensions or sensitivities arising where two or more interact. The full list of policies is set out in Appendix 1. The Policies show few tensions or sensitivities between them. Table 1 shows the findings. 3.8. The data runs both horizontally and vertically. The grey squares are where each separate policy meets and is not a part of the assessment. Squares close to the grey band represent policies that lie together in the plan. It is no surprise to find dark green (strong positive interaction) squares along this axis. The striking impression is the number of white squares (minimal interaction). This suggests a narrow focus for many of the interventions that may 10 P a g e CRAGGATAK Consulting www.craggatak.co.uk

operate in isolation. This is a common occurrence when policies have a narrow focus to express a plan s ambitions. 3.9. There are no negative impacts although three interactions have negative uncertainties. The bold borders in Table 1 highlight these interactions. 3.10. Both Policy CE11 (Major Development) and CE13 (Waste Management) can affect CE4 (Tranquillity). There is a narrow definition of tranquillity in the plan, only the reduction of noise in mentioned. There is no mention of light, movement, people or power and energy infrastructure (the negative impacts in tranquillity mapping). However, even with the plan s narrow definition, it is possible that if major development or waste disposal occurs, there will be an increase in noise. Policy CE11 (Major Development) also affects CE5 (Dark Skies). CE5 focuses on reducing light pollution and securing the Dark Sky designation. Any major development within the area has the potential to increase light pollution. However, both development policies have strong caveats on protecting the area s special qualities. Hence the marking of a minimal impact. 3.11. It is also important to consider the strong positive relationships. These are what will focus the plan. The long bands of green in Table 1 suggest that there are some strong links with certain policies. This is clearer in Chart 1; a chart showing the indicative strengths of each policy. 3.12. The Policies that have the strongest positive relationships with other policies are CC1 (Landscape-led Approach) and CE1 (Landscape). This is of no surprise. The AONB is a landscape designation and the Management Plan focuses tightly on the purpose of designation. 3.13. Policies CC3 (Working in Partnership), CC4 (Natural Capital) and CE8 (Rural Land Management) also have strong positive relationships. This is a very welcome finding because it shows that the plan is seeking to deliver the Government s priorities for the countryside, as set out in A Green Future (2018). 3.14. The least interactive policies are CE2 (Geology), CE4 (Tranquillity) and CE9 (Problem Species). These policies each have a very narrow focus. It is therefore of no surprise to find that they work in isolation. 3.15. A number of relationships between policies are marked as uncertain. Generally, this is where the policies are narrow in their intent with no link Policy Referenec CC1 CC2 CC3 CC4 CC5 CC6 CC7 CC8 CE1 CE2 CE3 CE4 CE5 CE6 CE7 CE8 CE9 CE10 CE11 CE12 CE13 UE1 UE2 UE3 Chart 1: Compatibility between Policies Relative compatibility 11 P a g e CRAGGATAK Consulting www.craggatak.co.uk

made to other aspirations in the plan. In-combination effects will offset this so it is not a weakness. 3.16. Those policies allowing development do have a negative impact on other policies but it is only minimal. In any case, applying the policies in-combination annuls the effect. It is possible to achieve higher compatibility by combining and redrafting policies to give each a wider focus but there is no need to do this. As there is compatibility between all the policies, there is no need to consider measures to reduce any tensions or sensitivities. Consistency with SEA Objectives 3.17. The next task is to check the proposed Policies of the management plan against the SEA Environmental Objectives in a Consistency Matrix. This was to see whether there were any significant beneficial or adverse effects; and to gage the magnitude of that effect. Where appropriate, there is consideration as to whether the effect is reversible. Table 2 supports this analysis. Table 2: Consistency Matrix Management Plan Policies SEA Objectives CC1 Landscape-led CC2 Duty of Regard CC3 Partnership CC4 Natural Capital CC5 Soils CC6 Water CC7 Climate Mitigation CC8 Climate Adaption CE1 Landscape CE2 Geology CE3 Distinctiveness CE4 Tranquillity CE5 Dark Skies CE6 Historic CE7 Biodiversity CE8 Land Management CE9 Pests & Diseases CE10 Development & Transport CE11 Major Development CE12 Development Priorities CE13 Waste UE1 Sustainable Tourism UE2 Access & Recreation UE3 Health & Well-being E1 Landscape E2 Biodiversity E3 Heritage E4 Local Distinctiven ess E5 Soils, Air and Water E6 Climate Change E7 Quality of Life E8 Cumulative Impacts 3.18. A number of strong relationships between the Management Plan Policies and the SEA Objectives stand out. There are no negative impacts but quite a few instances of minimal or 12 P a g e CRAGGATAK Consulting www.craggatak.co.uk

no impact on the SEA objectives. It is useful to consider the material in Table 2 in two ways. Firstly to study the interactions of each plan policy against the combination of the SEA Objectives (Chart 2); and then of the combination of each policy against each SEA Objective (Chart 3). Consistency of Management Plan Policies to combined SEA Objectives 3.19. All the Management Plan Policies are consistent with the combined SEA Objectives, albeit to varying degrees. The policy with the greatest beneficial effect on Chart 2: Consistency of Management the SEA Objectives is CC4 Plan Policies to combined SEA (Natural Capital). This is an allembracing Objectives environmental policy Relative consistency and so one would expect a strong CC1 Landscape-led link. CC2 Duty of Regard 3.20. Likewise, CC1 (Landscape-led), CC2 (the Duty) and CE1 (Landscape) each cover a range of SEA topics and so show a high relationship with the SEA Objectives. Of particular note is the contribution of policies CE8 (Rural Land Management), CE10 (Development and Transportation) and UE1 (Sustainable Tourism). These policies address issues that CC3 Partnership CC4 Natural Capital CC5 Soils CC6 Water CC7 Climate Mitigation CC8 Climate Adaption CE1 Landscape CE2 Geology CE3 Distinctiveness CE4 Tranquillity CE5 Dark Skies CE6 Historic can have a significant effect on CE7 Biodiversity the AONB s natural beauty and CE8 Land Management special qualities. Their strong CE9 Pests & Diseases consistency with the SEA CE10 Development & Objectives suggests a tight focus CE11 Major Development of the Management Plan on its CE12 Development Priorities environmental objectives. CE13 Waste 3.21. A few Management Plan Policies show a low contribution to the combined SEA Objectives. These policies are generally narrow in UE1 Sustainable Tourism UE2 Access & Recreation UE3 Health & Well-being their focus, such as CE2 (Geology) and UE3 (Health and Well-being), and it is no surprise that they only support a few of the SEA Objectives. Consistency of combined Management Plan Policies to SEA Objectives Management Plan Policies 3.22. Each SEA Objective gains support from the Management Plan Policies operating in combination. Given the purposes of AONB designation, it is no surprise that SEA Objective E1 (Landscape) gains the most benefit from the Management Plan Policies, followed closely by E2 Biodiversity. Of greater significance, SEA Objective E8 (Cumulative Impacts) also receives significant benefits from the aspirations of the Management Plan. This again suggests a tight focus of the Management Plan on its environmental objectives. The SEA Objective securing least support is E6 (Climate Change), though there is still good consistency. This is partly 13 P a g e CRAGGATAK Consulting www.craggatak.co.uk

Findings because an AONB Management Plan can only influence a limited range of climate change interventions. 3.23. There are no adverse effects and some significant beneficial effects. There is no need to consider measures to increase the beneficial effects but opportunities exist to do so. There is scope to widen the focus of some Management Plan Policies. SEA Objectives Chart 3: Consistency of combined Management Plan Policies to SEA Objectives E1 Landscape E2 Biodiversity E3 Heritage E4 Local Distinctiveness E5 Soils, Air and Water E6 Climate Change E7 Quality of Life E8 Cumulative Impacts Realative consistency Review of alternative policies 3.24. To meet with the requirements of the SEA Directive, the assessment needs to consider alternative options to determine whether the chosen pathway is the most sound in terms of the environment and wider sustainability. There is no record of any alterative options considered as a part of the management planning process. 3.25. In this situation, the approach is to compare the effect of the proposed objectives with a donothing scenario informed by the trends identified in the SEA Scoping Report (as shown in Appendix 3). The task is to establish the environmental and sustainability benefits of the proposed objectives over the do-nothing situation. This comparison is set out in Appendix 6 with an assessment for each trend. 3.26. The findings are that the proposed policies consistently give greater environmental benefits than the do-nothing situation, though there is not always a significant difference. There are two factors affecting this. Firstly, some of the forces for change are of such a scale as to be beyond the influence of the AONB working alone. Secondly, though the Management Plan policy cascade covers all the SEA topics, the definition of some Policies is very narrow. Though this has the advantage of making clear the action to take, it limits the scope of those actions. The Policies do not address the breadth of some issues. An example is tranquillity. Noise is not the only factor affecting tranquillity. Much of the impact of the Management Plan will come from its action plan and other supporting documents and advice the Board develops. 4. Monitoring Monitoring of significant environmental effects 4.1. The SEA Regulations require monitoring measures for all the significant effects, both positive and negative, identified in the assessment. The SEA of the draft management plan has identified no significant adverse effects that are likely to arise from the implementation of management plan. Some significant positive effects are likely to arise from the implementation 14 P a g e CRAGGATAK Consulting www.craggatak.co.uk

of the plan. The assessment has also identified some areas of uncertainty over the significance of some of the predicted effects and monitoring will cover these effects as well. 4.2. There are likely to be several benefits in monitoring any environmental effects arising from the implementation of the management plan, including: Identifying when action should be taken to reduce or offset any potential environmental effects of the plan; Enhancing understanding of how the environment is changing in the AONB; Tracking whether the plan has had any unforeseen environmental effects; and Providing baseline data for future SEAs. The advice is to incorporate the monitoring requirements of the SEA Regulations into the existing State of the AONB Report. Monitoring Measures 4.3. The SEA Scoping Report identified 62 potential indicators to monitor the environmental effects of implementing the Management Plan, 24 of which are included in the State of the AONB Report. Following the initial assessment there was a reduction of the list to 48 indicators. These are described Appendices 5 and 7. The list still includes the 24 State of the AONB Report indicators. Data limitations 4.4. The Strategic Environmental Assessment uses a combination of quantitative information from a number of sources (e.g. National Statistics and commissioned studies) and qualitative assessment using considered judgement. The qualitative approach is robust, given the strategic nature of the Management Plan. Detailed quantitative information relating to the effects of the plan is likely only to be available at a later stage. 4.5. Monitoring data are often subject to changes in methodology or reporting that may prevent the establishment of trend data from a known baseline date. Trend data and targets are the significant data gaps and these affect certain topics; in particular, effective and up-to-date reporting on pollution emission trends and aspects of air, soil (including contaminated land) and water quality are lacking. Consequently, the effects of diffuse pollution and other environmental impacts, such as recreation damage, are often difficult to ascertain. Funding cuts due to the recession may create additional burdens in terms of environmental monitoring and exacerbate this problem. The statutory agencies are seeking to address this issue with the development of a protected landscapes monitoring framework. 5. Technical review 5.1. The prime purpose of the SEA process is to review the potential impacts of the Management Plan on the key environmental aspects of the Cotswolds AONB. There is also a requirement, however, to monitor the implementation of the Management Plan and its impact on the environment over time. The baseline indicators (Appendix 4) were selected with this in mind. They are expected to be a part of the State of the AONB reporting. 15 P a g e CRAGGATAK Consulting www.craggatak.co.uk

Quality of existing baseline data 5.2. The assessment of the 48 SEA indicators is by a five-point quality scale. The analysis identifies where required data is weak or absent, so providing a framework for future data collection. Indicator 5-point quality scale 1 Fit for purpose Comment 2 Adequate Some minor improvements desirable 3 Indicative only Not considered accurate 4 Inadequate Little relevance to the AONB 5 Absent No available data The full assessment of each indicator against the eight SEA Objectives is set out in Appendix 7. Of the 48 SEA indicators, 56% are fit for purpose (27 indicators) and 19% are adequate (9 indicators). The remaining 25% (12 indicators) are indicative. Table 4 shows the assessment for each of the eight SEA Objectives. Table 4: Quality of base-line data Average score per SEA Objective 1 = data fit for purpose 3 = data indicative only 0 0.5 1 1.5 2 2.5 3 3.5 E2 Biodiversity E3 Heritage SEA Objectives E1 Landscape E5 Soils, Air and Water E4 Local Distinctiveness E6 Climate Change E7 Quality of Life E8 Cumulative Impacts 5.3. Apart from E8 (Cumulative Impacts), each SEA Objective has a different range of indicators, the plot is of the average score per Objective. E8 does not have any indicators but monitoring will be by an analysis of the State of the AONB reporting (consequently it is give a score of 3 (indicative)). Each Objective has some monitoring data. Four of the eight objectives appear to show adequate monitoring data as they all score below two. Objectives E2 (Biodiversity) and E3 (Heritage) both have data entirely fit for purpose. Objectives E1 (Landscape) and E5 (Soils, Air and Water) have good data but some parts rank as adequate. The other three objectives rely on indicative data. This is useful for spotting trends but it is not accurate. 16 P a g e CRAGGATAK Consulting www.craggatak.co.uk

6. Response to Environmental bodies comments 6.1. The report was subject to consultation with Natural England, Historic England, the Environment Agency (the statutory consultees) and other key stakeholders between the 10 th July and 14 th August 2018. All three statutory consultees, six local authorities and one parish council responded. A summary of their comments are set out in Appendix 8. 6.2. All the respondees agreed with the conclusions of the SEA report (or indicated that they had no substantive comments to make). Most of the consultees who commented on the SEA also agreed that no amendments to the Management Plan would be required because of the SEA conclusions. The consultation bodies were supportive of the SEA approach and findings. 6.3. The Environment Agency and Oxfordshire County Council picked up on the statement in paragraph 5.8 that very little information about water and air quality, or climate change is presented in the Management Plan. The Environment Agency identified flood risk as being a further weakness. It suggested that it would be a positive step to address these weaknesses within the Management Plan. Although Natural England did not comment on these issues in relation to the SEA, it did suggest (when commenting on the Management Plan) that the climate change section could be strengthened. 6.4. In response, the Board redrafted sections of the Management Plan to address these concerns. The changes made do not require a formal re-assessment of the SEA, as they reflect the SEA conclusions. However, a short proofing test showed that the Management Plan now aligns even more closely to the SEA Objectives. This is due to the strengthening of the sections relating to climate change, air quality, water and flood risk. 7. Conclusion 7.1. The Management Plan has a cascade of 24 policies falling under three themes. The proposed policies are compatible. There are no tensions or sensitivities arising from where two or more interact. The proposed policy cascade has a beneficial, and in parts, a significantly beneficial, effect on the SEA Environmental Objectives. 7.2. When analysed in combination, the policies show the greatest consistency with the SEA Objectives to conserve and enhance natural beauty, biodiversity and local distinctiveness. This reflects the purpose of AONB designation. A particularly welcome finding is that working in partnership, natural capital and rural land management also have strong positive relationships. This suggests that the plan is seeking to deliver the Government s priorities for the countryside, as set out in A Green Future (2018). The sustainability topics all receive positive treatment within the management plan but their subject areas have a narrow definition. The result is that they show fewer relationships. The weakest relationship is with quality of life. 7.3. There are no adverse effects on the SEA Environmental Objectives so there is no need to consider measures to increase the beneficial effects but opportunities exist to do so. There is no recommendation for mitigating actions. 7.4. The proposed policies consistently give greater environmental benefits than the do-nothing situation. In some case, the benefits are only marginally better than the do-nothing scenario. 17 P a g e CRAGGATAK Consulting www.craggatak.co.uk