Environmental Report for the Draft Orkney Core Paths Plan

Orkney Islands Council

February 2008

IMAGE: The Orkney Islands Council crest and logo, with the motto “Boreas Domus Mare Amicus” and the words “ORKNEY ISLANDS COUNCIL”.

Contents of the Environmental Report

1. Non-technical summary
2. Introduction
   1. Purpose of this Environmental Report and key facts
   2. SEA activities to date
3. Context
   1. Outline and objectives of the draft Orkney Core Paths Plan
   2. Aims and objectives of the Core Paths Plan
   3. Relationship with other PPS and environmental protection objectives
   4. Relevant aspects of the current state of the environment
   5. Environmental problems
   6. Likely evolution of the environment without the Core Paths Plan
   7. SEA Objectives
4. Assessment of environmental effects and measures envisaged for the prevention, reduction and offsetting of significant adverse effects
   1. Alternatives to which SEA was applied
   2. Assessment of Proposed Core Paths
   3. Measures envisaged for the prevention, reduction and offsetting of significant adverse effects
5. Monitoring
6. Next steps

Appendix A. Links to Other PPS and Environmental Objectives

Appendix B. Environmental Baseline

Appendix C. Assessment of Core Paths

1. Non-Technical Summary

1.1 Background

A key component of the Land Reform (Scotland) Act 2003 is the duty for all local authorities to draw up a draft Core Paths Plan. The purpose of the plan is to identify a system of key routes for outdoor access, giving the public reasonable provision throughout their area.

A Strategic Environmental Assessment (SEA) of the draft Core Paths Plan is required by the Environmental Assessment (Scotland) Act 2005. This Act is the implementing legislation for the European Directive, known as the SEA Directive.

The purpose of SEA is to ensure that during the preparation of a plan, programme or strategy (pps) the significant environmental effects of the pps are taken into account. Its aim is to prevent, reduce and offset any negative environmental impacts of the plan.

The SEA legislation requires that the findings of the SEA are published in an Environmental Report, which sets out the likely significant environmental effects of the plan. This is the non-technical summary of the Environmental Report for the draft Orkney Core Paths Plan.

Consultation is an important element of the SEA process, so the Environmental Report is presented for public consultation, along with the Plan.

1.2 SEA Methodology

SEA identifies a number of environmental topics or factors against which the likely significant effects of a plan should be assessed. These are:

• biodiversity, fauna and flora
• population and human health
• air
• soil
• water
• climatic factors
• landscape
• cultural heritage
• material assets

For each of these topics, SEA objectives have been developed and the impacts of the draft Core Paths Plan have assessed against these objectives. The SEA objectives are shown in Table 1 below.

The plan’s environmental effects are looked at in terms of short, medium and long term effects; positive and negative effects; permanent and temporary effects; and cumulative impacts. Alternatives to the plan are also considered as part of this assessment process.

1.3 Assessment of the Core Paths Plan

Assessment of Core Paths has been carried out at three levels:

a) Assessment of the Core Paths Plan objectives against SEA topics. This was to look the objectives of the plan in terms of their affect on the environmental topics. The impact of the Core Paths Plan objectives were found to be largely neutral, or slighly positive.

b) Assessment of the Core Paths selection criteria against SEA objectives. The criteria used for selecting proposed Core Paths were assesed against the SEA objectives to ensure that they were compatible. None of the selection criteria were found to be incompatible with the SEA objectives.

c) Assessment of individual Core Paths and Core Paths Networks against SEA objectives. For each island and parish of Orkney the proposed Core Paths have been assessed against the SEA objectives developed for each SEA topic. For each objective the likely significant impact of the path network is assessed and detailed comments on individual routes are provided where appropriate. These assessments can be found in Appendix C.

A summary of the overall findings of the Core Paths network assessments is given in the main body of the Environmental Report. The likely significant impacts of the individual Core Paths and the path networks were found to be neutral in most cases, with some positive impacts.

The vast majority of the proposed Core Paths are existing, well used routes, where no new infrastructure or path upgrades are required. No new routes, where significant amounts of new infrastructure would be required, are included in the plan. This approach to the Plan has helped to minimise any significant adverse impacts on the environment.

Where it is envisioned that promotion of Core Paths could increase their usage and potentially have an adverse impact on the environment, ways of minimising or mitigating the impact have been identified.

1.4 Mitigation

Mitigation measures are developed to avoid, reduce or offset predicted negative impacts. The environmental effects of the draft Core Paths Plan are largely neutral.

Where the promotion of Core Paths could have an adverse impact on the natural heritage this will be addressed through awareness raising and interpretation to promote responsible behaviour.

1.5 Monitoring

Monitoring the effects of implementing the Core Paths Plan will include regular inspections of Core Paths by the local authority. This monitoring will include any impacts of the paths on the environment, such as erosion, damage to vegetation adjacent to the path, littering etc. Incidents of disturbance to wildlife as a result of access users will also be monitored.

1.6 Consultation

Comments on this Environmental Report can be sent to the address below until Friday 2 May 2008.

Christine Skene
Policy and projects
Department of Development Services
Orkney Islands Council
Council Offices
School Place
Kirkwall
Orkney
KW15 1NY

Comments may also be sent by fax to 01856 886466 or submitted by email to christine.skene@orkney.gov.uk

A copy of this Environmental Report and the draft Supplementary are available to download at http://www.orkney.gov.uk

2. INTRODUCTION

2.1 Purpose of this Environmental Report and key facts

The Environmental Assessment (Scotland) Act 2005 implements EC Council Directive 2001/42/EC (the Strategic Environmental Assessment (SEA) Directive) on the assessment of the effects of certain plans and programmes on the environment.

The Act requires that plans such as the draft Orkney Core Paths Plan must be subject to a process of identifying and taking into account the environmental effects of the plan. The SEA involves examining the Plan in relation to its environmental aims, identifying its likely consequences and, if necessary, undertaking adjustment to reduce any likely significant adverse effects of the Plan on the environment.

SEA is a systematic method for considering the likely environmental effects of certain Plans Programmes and Strategies (PPS) and is a process, not a product. SEA aims to:

• integrate environmental factors into PPS preparation and decision-making;
• improve PPS and enhance environmental protection;
• increase public participation in decision making; and
• facilitate openness and transparency of decision-making.

SEA is required by the Environmental Assessment (Scotland) Act 2005. The key SEA stages are:

The purpose of this Environmental Report is to:

• provide information on the draft Orkney Core Paths Plan
• identify, describe and evaluate the likely significant effects of the draft Orkney Core Paths Plan
• provide an early and effective opportunity for the Consultation Authorities and the public to offer views on any aspect of this Environmental Report.

The key facts relating to draft Orkney Core Paths Plan are set out in Table 1 below.

Table 1: Key facts relating to the draft Orkney Core Paths Plan

2.2 SEA activities to date

Table 2 summarises the SEA activities to date in relation to the draft Orkney Core Paths Plan.

Table 2: SEA activities to date

3. CONTEXT

3.1 Outline and objectives of the draft Orkney Core Paths Plan

Schedule 3 of the Environmental Assessment (Scotland) Act 2005 requires that the Environmental Report includes “an outline of the contents and main objectives of the plan or programme”. The purpose of this section is to explain the nature, contents, objectives and timescale of the plan.

The Land Reform (Scotland) Act 2003 created a new right of responsible access over most land and inland water. While establishing this wider access right the legislation acknowledged that paths play a very important role in managing outdoor access and that the majority of people do prefer to use defined routes. As a result one of the key duties in the Act is for local authorities to produce a draft Core Paths Plan.

The purpose of the draft Core Paths Plan is to identify a framework of paths that will provide local residents and visitors with reasonable access throughout their local authority area. Core Paths will form the basic network of paths that allow people to enjoy and get around the countryside. This framework of routes will link to, and support, other networks of paths and the wider countryside.

The Core Paths Plan should include a wide range of routes suitable for different types of users, including walkers, cyclists and horse riders, as well as providing access opportunities for people of varying ability.

A Core Paths network has been identified for each island and parish of Orkney and together these constitute the overall Core Paths Plan for the Orkney Islands area. The Plan includes maps of all the proposed Core Paths in each area or island.

The draft Core Paths plan documents the process that has been followed to determine which paths should be included as Core Paths. This process has included extensive public consultation and assessment of potential Core Paths.

All candidate routes have been assessed against a series of Core Paths selection criteria to determine their suitability as candidate Core Paths. Once adopted, the plan will provide a basis for managing access throughout Orkney.

3.2 Aims and Objectives of the Core Paths Plan

The vision for outdoor access in Orkney as identified in Orkney’s Outdoor Access Strategy is:

‘To promote enjoyment of the outdoors by providing high quality, sustainable access provision, which satisfies the needs and aspirations of the local community and visitors to the islands.’

The aim of the Core Paths Plan will be to work towards this vision by helping to fulfil a number of key objectives for outdoor access in Orkney. These are:

• to provide a co-ordinated, actively promoted and well maintained network of paths
• to provide a range of opportunities suitable for different user groups and people of all abilities which are safe, welcoming and enjoyable
• to work with land managers to achieve a balance between the needs of access users and the needs of those living and working on the land.
• to promote sustainable access which safeguards the natural, built and cultural heritage.

These objectives are assessed in the SEA, as are the Core Paths Networks for each island and parish.

3.3 Relationship with other PPS and environmental protection objectives

Schedule 3 of the Environmental Assessment (Scotland) Act 2005 requires that the Environmental Report includes an outline of the PPS relationships with other relevant PPS, and how environmental protection objectives have been taken into account in the PPS preparation.

This section covers these issues and describes the policy context within which the PPS operates, and the constraints and targets that this context imposes on the PPS.

The draft Orkney Core Paths Plan will form part of the suite of planning policy and guidance documents for Orkney, all of which must be consistent with other plans, strategies and policy statements at a higher level.

This information is summarised in Relevant plans, programmes and strategies (PPS) and environmental protection objectives, and their relationship with draft Orkney Core Paths Plan which is presented as Appendix A to this Environmental Report. These plans, programmes and strategies are also listed below:

• UN Framework Convention on Climate Change & its Kyoto Protocol
• UN Convention on Biological Diversity (1992)
• Conservation of Wild Birds Directive (79/409/EEC)
• Conservation of Natural Habitats and of Wild Fauna and Flora Directive (92/43/EEC)
• Water Framework Directive (2000/60/EC) (WFD)
• EU Sustainable Development Strategy (2001)
• The Scottish Outdoor Access Code
• Scotland’s National Transport Strategy (2006)
• SPP11 Open Space and Physical Activity
• National Cycling Strategy 1996
• Report of the Disability Working Group 2006
• Hitrans Regional transport Strategy
• SPP 17 Sustainable Transport
• The Water Environment (Controlled Activities) (Scotland) Regulations 2005
• Scottish Biodiversity Strategy
• NPPG14 Natural Heritage
• SEPA Policy 21 Stategy for Implementing Actions under the UK Biodiversity Action Plan
• National Waste Strategy (Scotland)
• The UK’s Shared Framework for Sustainable Development (2005)
• NPPG10 Planning and Waste Management
• SEPA Policy 26 on the culverting of watercourses
• Scottish Executive Marine and Coastal Strategy (2005)
• NPPG5 Archaeology and Planning
• PAN 42 Archaeology – The Planning Process and Scheduled Monument Procedures
• NPPG18 Planning and the Historic Environment
• Scottish Historic Environment Policy 1
• Scottish Historic Environment Policy 2.
• Memorandum of Guidance on Listed Buildings and Conservation Areas, Historic Scotland 1998
• OIC Biodiversity Action Plan (2002)
• OIC Structure Plan
• The Orkney Local Plan (2004)
• OIC 2020 Community Plan (2007)
• Orkney Outdoor Access Strategy
• Orkney Environmental Strategy and Action Plan
• Orkney Local Transport Strategy 2008-2010

Analysis of these plans, programmes and strategies has highlighted the following environmental considerations which are relevant to the Core Paths Plan:

• The duty of Orkney Islands Council to incorporate and implement appropriate biodiversity targets, and to ensure that the biodiversity, fauna and flora of Orkney is taken into account in fulfilling the objectives of the Core Paths Plan, in particular species and habitats which are afforded special protection, e.g. under Natura 2000 and European Protected Species;
• The need to ensure that protecting and, where appropriate, enhancing the historic and natural heritage environment is recognised in the development of Core Paths;
• The need to maintain a clean, healthy, safe, productive and biologically diverse marine and coastal environment and to consider any implications for coastal erosion relating to the potential siting of core paths;
• The Core Paths Plan should support the overarching vision for Orkney which is set out in Orkney’s Community Plan, 2020.

In a local context, the Orkney Core Paths Plan supports Policy LP/S2 in the Orkney Local Plan 2004. Work is now commencing to review the Orkney Local Plan with a view to publishing the final Development Plan in late 2009 or early 2010.

By integrating and being consistent with the Structure Plan and Local Plan, the Orkney Core Paths Plan is compatible with other local strategies and programmes which have been, or are being, integrated with the development plan, including the Community Plan, the Orkney Outdoor Access Strategy, the local Biodiversity Action Plan and the Local Transport Strategy.

3.4 Relevant aspects of the current state of the environment

Schedule 3 of the Environmental Assessment (Scotland) Act 2005 requires that the Environmental Report includes a description of “the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme”, and “the environmental characteristics of areas likely to be significantly affected”. This section aims to describe the environmental context within which the PPS operates and the constraints and targets that this context imposes on the PPS.

An Environmental Baseline of the Orkney Islands has been compiled and is presented as Appendix B.

Table 3 below presents a summary of the data collected and the relevant sources.

Table 3: Summary of data collected in compiling an environmental baseline of the Orkney Islands

The following summarises the likely gaps and/or unreliability of the SEA baseline data, and how they were minimised:

There are some gaps or other deficiencies, especially in respect of the links between land use, planning and environmental issues relating to climatic factors, air quality and human health.

The air quality report for 2005-2006 is the most up-to-date available. Monitoring re-commenced in August 2007 following an 18-month gap.

• Results are proving to be very similar to those of 2005 and any change is negligible. As it becomes available, future data will be incorporated in the monitoring programme of this SEA.

Information about the extent and location of habitats of nature conservation importance, protected and other species listed as priority species in Biodiversity Action Plans may not be complete or up-to-date owing to the large and remote geographic area covered by the Plan and the dynamic nature of some of these resources.

• Natura sites and SSSIs are periodically monitored by SNH through its Site Condition Monitoring programme. A further monitoring programme is currently underway for the Local Sites of Local Nature Conservation Interest, whereby most of the mainland sites and much of the linked South Isles sites have been covered. The North Isles and remaining South Isles still have to be visited.
• Where development may take place in more remote locations of environmental sensitivity, it is likely that a full projects environmental impact statement will be required.

There is no soil quality data available for the Orkney Islands.

• If in future a soil monitoring programme is established, the resulting data will be used to monitor the environmental performance of the SPG.

Information about the extent and location of archaeological resources may be incomplete. Sensitive archaeological remains may extend beyond the confines of many ancient monuments and both arable and non-arable areas may contain sensitive and important monuments.

Population data for the Isles is based on Census data; the most recent information is from the 2001 Census.

Health data is fairly subjective and can only give an indication of peoples’ perception of their own health. However, it is considered a useful indicator for the purposes of this report.

3.5 Environmental problems

Schedule 3 paragraph 4 of the Environmental Assessment (Scotland) Act 2005 requires that the Environmental Report includes a description of existing environmental problems, in particular those relating to any areas of particular environmental importance. Table 4 contains a list of environmental problems or issues which are relevant to the development of the Core Paths Plan.

Table 4: Existing Environmental Problems Relevant to Core Paths

3.6 Likely evolution of the environment without the Orkney Core Paths Plan

Without the Orkney Core Paths Plan it is considered that the likely future changes to the area would be as described below:

Climatic factors and local air quality

Without the increase in outdoor access opportunities provided by the Core Paths Plan it is unlikely that there will be any decrease in the use of motorised vehicles for recreation in the countryside or for accessing facilities and services in and around settlements.

Biodiversity

Without the focus of developing formal Core Paths access routes could be developed in Orkney in an ad hoc manner, without consideration of their impacts on biodiversity and the natural heritage. The assessment of Core Paths through SEA will ensure the environmental impacts of these routes are thoroughly considered.

Water /Soil

If paths were developed/promoted without going through the Core Paths assessment process it is possible that there could be localised negative effects on hydrology, water supply, water quality and the soil environment from new routes or pressure from access users.

Landscape

If paths were developed/promoted without going through the Core Paths assessment process it is possible that there could be localised negative effects on the landscape from new path infrastructure or path surfacing.

Cultural Heritage

Without the focus of developing formal Core Paths access routes could be developed in Orkney in an ad hoc manner, without consideration of their impacts on the cultural heritage, Scheduled Ancient Monuments and other historic sites. The assessment of Core Paths through SEA will ensure the impacts of these routes on the historic environment are thoroughly considered.

Human health

Without the increase in outdoor access opportunities provided by the Core Paths Plan there will be more limited options for residents to keep active and healthy by walking and cycling.

3.7 SEA Objectives

A set of objectives and environmental criteria has been identified which will be used as measures by which the environmental impacts of the PPS may be assessed.

These objectives and environmental criteria are presented in Table 5 below.

Table 5: Environmental objectives and criteria against which the Core Paths networks will be tested

4. Assessment of environmental effects and measures envisaged for the prevention, reduction and offsetting of significant adverse effects

4.1 Alternatives to which SEA was applied

Assessment of Alternatives

The Environmental Report is required to consider alternatives to the proposed plan as part of the SEA process, as stated in the SEA Directive and the Environmental Assessment (Scotland) Act.

The Core Paths Plan is a statutory requirement of the Land Reform (Scotland) Act 2003 so a ‘do nothing’ alternative to the Plan is not an option. However, throughout the preparation of the Core Paths Plan, a wide range of possible routes have been considered for inclusion in the draft plan.

Assessment of these routes against the objectives of the plan, the selection criteria for the plan and the SEA objectives has helped to refine the candidate routes to those included in this Plan. In addition the consultation process has helped to select the key routes that stakeholders wish to see included in the plan.

The vision and strategic objectives of the plan were developed to reflect the Orkney Outdoor Access Strategy 2004, in accordance with the relevant legislation and with reference to the stakeholder and community consultation carried out as part of the Core Paths planning process.

A number of possible objectives were considered during the development phase, but were refined to those included in this report. The SEA process also informed the selection of the plan objectives, so that one of the objectives is ‘to promote sustainable access which safeguards the natural, built and cultural heritage‘.

All the Core Paths Plan objectives were assessed against the SEA objectives to ensure there were no incompatibilities between them.

The objectives of the plan and stakeholder consultation then helped to define the selection criteria for proposed Core Paths. Different options for selection criteria were assessed against the objectives of the plan before choosing those which appeared to reflect best the strategic objectives and the aspirations of the community, and were also compatible with the legislation.

All candidate Core Paths were assessed against these criteria before final selection was made.

All candidate Core Paths and the Core Paths networks were also assessed against the SEA objectives and the specific criteria developed from the SEA objectives.

A number of other factors were taken into account in selecting Core Paths. Specifically it was important to consider the ‘reasonable provision of access’ as defined in the Land Reform (Scotland) Act 2003. For each area it was important to consider what was required to achieve this reasonable provision and to select paths accordingly.

In developing a Core Paths Plan local authorities are also required to provide access for a variety of different access users. The selection of routes in the plan therefore reflects this need to provide access opportunities for different activities and different abilities.

It was essential to balance the needs of access users with those of land managers. Some paths were rejected on the grounds of land management issues which could not be resolved in the timescale of the development of the plan.

In addition the practicalities of the local authority being able to resource the signage and promotion of the Core Paths Network had to be considered as a factor in terms of the number of Core Paths to be included in the plan. It is also accepted that much of the maintenance of the network will fall to the Council and this too had to be considered when assessing the level of provision.

The type of paths which were considered as potential Core Paths included public rights of way; paths promoted by the Council; paths developed by landowners; other informal but well used routes; and quiet sections of roads particularly on the outer isles.

A number of completely new routes were suggested as potential Core Paths during the consultation process. These were considered where agreement could be reached with relevant landowners and the paths could be implemented within two years of the adoption of the plan.

Certain of these routes have been classified as ‘aspirational’ routes, which could be developed at a later date and be included in a future review of the plan.

The consultation process identified community and stakeholder priorities for outdoor access. In particular there was considerable community demand shown for coastal paths, access to amenity and heritage sites and circular routes. This demand has helped shape the development of the draft Plan and the selection of routes.

4.2 Assessment of Proposed Core Paths

Assessment of Core Paths has been carried out at three levels:

a) Assessment of the Core Paths Plan objectives against SEA topics

b) Assessment of the Core Paths selection criteria against SEA objectives and criteria

c) Assessment of individual Core Paths and Core Paths Networks against SEA objectives and criteria.

a) Core Paths Plan Objectives

The overall Core Paths Plan objectives have been assessed against the SEA topics to ensure that at a strategic level the Plan does not have significant adverse impacts on the environment. The results of this assessment are presented in Table 6 below.

Table 6: Assessment of Core Paths Plan Objectives

9 positive
† neutral
X negative

b) Core Paths Selection Criteria

A series of criteria have been developed to assist in the selection of Core Paths for the draft Core Paths Plan. All candidate Core Paths have been scored against these criteria before being included in the plan. It is therefore important that the Core Paths selection criteria are compatible with the SEA objectives and criteria.

The Core Paths selection criteria are given below and Table 7 assesses these against the SEA objectives.

Core Paths Plan Selection Criteria

1. Community Demand

   • demand identified in consultations
   • high level of current usage
   • already promoted path

2. Safe and fit for purpose

   • path design and infrastructure is adequate for the intended usage
   • major improvements are not needed to make the Core Path safe and fit for purpose

3. Consistent with access strategy

   • Core Paths should contribute to the aims of the Orkney Outdoor Access Strategy

4. Potential for multi use

   • a good percentage of Core Paths should be suitable for more than one use
   • all Core Paths should be as barrier free as possible to permit usage by a wide range of users eg gates instead of stiles

5. Provides access to amenity sites and/or sites with heritage interests

   • high demand in Orkney for access to coastal sites, including beaches
   • high demand for access to sites of natural, historical or cultural heritage

6. Avoids/mitigates land management or privacy issues

   • Core Paths over enclosed farmland should help to reduce conflicts between access users and land management, especially where there are livestock
   • Core Paths should not interfere with local resident’s privacy and peace of mind

7. Assists management of the heritage of the area

   • Core Paths and/or access users should not have a negative impact on the natural, cultural or built heritage
   • where possible they should have a positive management effect on the heritage

8. Links and supports wider path networks or wider access rights

   • Core Paths should link with wider path networks
   • Core Paths may provide links through enclosed farmland to open areas where access rights apply eg hill ground

9. Community Links

   • where settlements exist there should be Core Paths which are easily accessible from the town or village, without the use of a car
   • in settlements Core Paths should help people to access local amenity sites
   • in villages and towns Core Paths should help residents to access facilities such as schools, colleges, shops, sports centres etc.

Table 7: Assessment of Core Paths Selection Criteria against SEA objectives

9 core path criterion and SEA objective are compatible with each other
† core path criterion and SEA objective are not specifically linked
X core path criterion and SEA objective are incompatible.

c) Assessment of individual Core Paths and Core Path Networks

For each island and parish of Orkney the proposed Core Paths have been assessed against the SEA objectives developed for each SEA topic. For each objective the likely significant impact of the path network is assessed and detailed comments on individual routes are provided where appropriate.

These assessments can be found in Appendix C. A summary of the overall findings of the Core Paths network assessments is given in Table 8 below.

Table 8: Assessment of Core Paths Networks against SEA objectives

4.3 Measures envisaged for the prevention, reduction and offsetting of significant adverse effects

Schedule 3 paragraph 7 of the Environmental Assessment (Scotland) Act 2005 requires an explanation of “the measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme.”

Table 9 sets out any environmental problems that are likely to remain on implementation of the PPS and summarises proposed measures for the prevention, reduction and offset of significant adverse effects.

Table 9: Measures envisaged for the prevention, reduction and offsetting of any significant adverse effects

5. Monitoring

Monitoring the effects of implementing the Core Paths Plan will include the following:

• Regular inspections of Core Paths by the local authority. A regime is already in place for monitoring the condition of paths and recording this on a database. This monitoring will be extended to include any impacts of the paths on the environment, such as erosion, damage to vegetation adjacent to the path, littering etc.
• Recording of incidents of disturbance to wildlife as a result of access users. For example incidents of dogs not under proper control, disturbing breeding birds.
• People counters installed on key routes to monitor increased usage of paths as a result of promotion of the Core Paths Plan.

6. Next steps

Table 10 lists future milestones in the development of the PPS and its SEA, and the dates when these are expected to be completed.

Table 10: Anticipated plan-making and SEA milestones

Appendix A. Links to Other PPS and Environmental Objectives

Appendix B. Environmental Baseline

Appendix C. Assessment of Core Paths