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SECTION 4: ASSESSMENT OF ENVIRONMENTAL EFFECTS AND PROPOSED MITIGATION MEASURES

4.1 Introduction and scope of assessment

The main difference between the SEA process and Environmental Impact Assessment ( EIA) is that the former is used to assess relatively broad strategies rather than site specific proposals. It is expected that the level of detail provided in the SEA should be broadly consistent with the scale of the plan which is being assessed. On this basis the approach adopted in terms of this Environmental Report is a high level assessment which effectively provides a framework for further more detailed environmental appraisal through the SPR and also at the regional and local level where there is greater certainty regarding the exact location, nature and specifications of different measures, especially in terms of proposals for new infrastructure.

The assessment framework used for the purposes of this SEA adopted a criterion-based approach, the scope of which was consistent with the criteria listed in Schedule 2 of the Regulations. In view of the range of potential environmental impacts associated with the NTS, no criterion was scoped out and on this basis the following topics were incorporated within the assessment framework:

• Biodiversity
• Population
• Human Health
• Soil
• Water
• Air quality
• Climatic factors
• Material assets
• Cultural heritage
• Landscape

Table 7 provides an outline of the scope of the assessment for each of the criteria listed.

Table 7 - Scope of Assessment

Additional Environmental Issues

A range of environmental effects are recognised as a key consideration to the STAG process, including the criteria listed in section 4.1. In addition, two further criteria are also included within the STAG process and for the purposes of continuity were integrated within the scope of the assessment framework adopted in this Environmental Report:

Visual amenity: Transport proposals can have a significant impact on the quality of panoramas, specific views and the visual environment of sensitive areas. This is particularly evident where new infrastructure is introduced, intensity of traffic movements is increased or new lighting is provided. Overlooking of existing private spaces ( e.g. gardens, residences) should also be taken into account.

Noise and vibration: Noise exposure can have an adverse impact on the living environment, this includes negative effects on human health, the built environment and wider natural environment. In a transport context, noise issues arise both from the movement of different modes and development of new infrastructure. Tolerance to noise exposure varies greatly between individuals and different environmental settings.

4.2 SEA objectives for the assessment

On the basis of the scope of the assessment a series of SEA objectives were developed. These are detailed in Table 8 and provide the framework against which the impacts of the NTS were identified and evaluated.

Table 8 - SEA Objectives

For each objective a series of questions were set to ensure there was consistency to the assessment process. The specific questions for each objective are detailed below:

Biodiversity - to conserve biodiversity at all levels and accord to the protection of statutory conservation areas.

• Does the policy have significant implications for the conservation of biodiversity?
• Does the policy encourage the proper assessment of the biodiversity implications of future developments?
• Does the policy encourage the protection of existing natural habitats and the creation of quality sustainable habitats?
• Does the policy encourage increased biodiversity?

Population - to improve the living environment for all communities.

• Does the policy have significant implications for the population?
• Does the policy encourage the proper assessment of the population implications of future developments?

Human health - to promote the health of the human population.

• Does the policy have significant implications for human health?
• Does the policy encourage the proper assessment of the human health implications of future developments?
• Does the policy encourage the protection of human health?
• Does the policy encourage improvement to human health?

Soil - to safeguard the quality and quantity of the soil resource.

• Does the policy have significant implications for the conservation of the soil resource?
• Does the policy encourage the proper assessment of the soil implications of future developments?
• Does the policy encourage the protection of the existing soil resource?
• Does the policy encourage improvements to the soil resource?

Water - to reduce the impact on the quality and quantity of the water environment resulting from transport infrastructure.

• Does the policy have significant implications for the conservation of the water resource?
• Does the policy encourage the proper assessment of water related implications associated with future developments?
• Does the policy encourage the protection of the existing water resource?
• Does the policy encourage improvements to the water resource?

Air quality - to improve air quality through reducing emissions and pollution.

• Does the policy have significant implications for air quality?
• Does the policy encourage the proper assessment of air quality associated with future developments?
• Does the policy encourage the protection of air quality?
• Does the policy encourage improvements to air quality?

Climatic factors - to reduce energy consumption and CO₂ emissions and the associated impacts of climate change ( e.g. flooding).

• Does the policy have significant implications for reducing CO₂ emissions ?
• Does the policy encourage the proper assessment of CO₂ emissions arising from future developments?

Material assets - to promote efficient use of the existing transport infrastructure and the efficient use of resources in the development of new infrastructure.

• Does the policy have significant implications for improving efficiency in the use of material assets?
• Does the policy encourage the proper assessment of the impact of future developments on material assets?
• Does the policy encourage the protection of the existing material asset resource?

Cultural heritage - to safeguard features of the historic environment

• Does the policy have significant implications for safeguarding cultural heritage?
• Does the policy encourage the proper assessment of the impact of future developments on cultural heritage?
• Does the policy encourage the protection of cultural heritage?

Landscape - to safeguard the character, diversity and unique qualities of the landscape.

• Does the policy have significant implications for safeguarding the landscape?
• Does the policy encourage the proper assessment of the impacts of future developments on the landscape?
• Does the policy encourage the protection of the existing landscape?
• Does the policy encourage increasing the value of the landscape?

Visual amenity - to safeguard the quality of the visual amenity.

• Does the policy have significant implications for safeguarding the visual amenity?
• Does the policy encourage the proper assessment of the impact of future developments on visual amenity?
• Does the policy encourage the protection of the existing visual amenity?

Noise - to limit noise related nuisances from operation of the transport system and development of new infrastructure.

• Does the policy have significant implications for limiting noise nuisance?
• Does the policy encourage the proper assessment of noise nuisance arising from future developments?

4.3 Alternatives to which the SEA was applied

The SEA Regulations require that the consistency of the NTS with the environmental criteria scoped within the assessment framework is assessed as a means of ensuring areas of potential conflict are highlighted. Both the overarching objectives of the strategy and different policy options, as detailed in the NTS at publication in April 2006, have been assessed in accordance with the SEA Regulations. Further details on these elements are provided below.

In summary, the overarching objectives of the strategy are as follows:

• Promote economic growth;
• Promote social inclusion;
• Protect our environment and improve health;
• Improve safety of journeys; and
• Improve integration.

More detailed information is provided in section 2 to this report.

In terms of content, the NTS does not explicitly detail alternative policy options but rather presents, for consultation, a series of potential measures for inclusion within the final Strategy. The measures presented are based on the goals of the strategy which broadly support the high level objectives detailed in section 2 to this report. In summary, the goals look to:

• Facilitate economic growth;
• Promote accessibility
• Promote choice and raise awareness of the need for change;
• Promote modal shift;
• Promote new technologies;
• Manage demand;
• Reduce the need for travel; and
• Promote road safety.

Table 9 details the policy options for each goal included within the consultation paper. The current status of the NTS as a consultation paper means that the environmental effects of the measures reported here are reflective of the content of the consultation paper as at publication in April 2006 and it should therefore be recognised that they may not all necessarily form part of the finalised strategy to be published later in 2006. Furthermore, new policy options may emerge through the public consultation process. Any additions, amendments or deletions of this nature will be reported within the SEA post-adoption statement, together with changes which have resulted from consultation on this Environmental Report.

Table 9 - Policy options for the NTS (based on the eight goals of the NTS)

4.4 Assessment results - summary

The overarching objectives and policy options listed in section 4.1 were assessed using the framework shown in section 4.2. A summary of the key outcomes from the assessment is provided in this section, and the full findings are detailed in Appendix B.

Overarching Objectives

The strategic objectives of the NTS seek to achieve an appropriate balance between social, economic and environmental considerations. The NTS recognises that maintaining and enhancing the quality of Scotland's environment is a critical requirement in the short, medium and long-term.

It is our intention that all the objectives will have some positive impact on the environment, albeit to varying degrees. For example, a commitment to protecting the environment can directly improve the living environment and the health of all communities, and in so doing also positively contribute to social inclusion and economic growth. In terms of support for economic growth, both positive and negative effects on the environment can be expected. Increased economic growth can lead to a higher quality of life, improved infrastructure and enhanced environment, however it is also important that development (including transport infrastructure) to support such growth complements and reinforces the environmental principles which underpin the Strategy.

Facilitate Economic Growth

Strengthening international connectivity by sea and air is likely to lead to an increase in passenger travel and freight transport. With the emphasis of the Air Route Development fund being to provide more direct flights from Scotland there is some scope to reduce the length of air journeys, however benefits of this nature are likely to be countered by an overall increase in travel arising from the wider range of services which would become available. This would have particular implications in terms of CO₂ emissions and the secondary impact on biodiversity, soils and water through effects associated with climate change. Improved connectivity by sea and associated increase in traffic could potentially increase the risk of accidental spillages and pose a threat to the integrity of the marine environment. Marine transport is also subject to less stringent sulphur related emission regulations. For example, regulations require that fuel containing less than 0.1% sulphur is used at berth in port which is 20 times higher than for road transport fuels with aviation fuel and rail diesel having a sulphur content somewhere between that of road and maritime fuels ¹⁰.

Addressing the balance between competing needs of freight and passenger transport on the road and rail network provides an opportunity for more efficient use of existing networks with anticipated benefits to the business community. Further information would be required as the exact specifications of individual projects are established to determine whether this would lead to an overall increase in freight transport, and associated environmental implications.

Promote accessibility

Access to a reliable transport system has an important bearing on the opportunities and quality of life available to individuals. The promotion of accessibility should be of benefit to the population in terms of reducing severance and improving access to transport, services and opportunities. There would also be benefits to human health through improved access to health facilities and the promotion of healthy living ( e.g. walking and cycling). Partnership working and service integration between healthcare and other providers would ensure access to healthcare was maximised.

Determination of the impact on wider aspects of the environment requires greater certainty regarding how and whether journeys arising from measures to promote accessibility were made previously. In this respect it is important that the environmental credentials of such measures are addressed alongside their social and economic merits at the project level. For example, in rural areas public transport is often not as prevalent in comparison to urban areas and car ownership is often considered a necessity rather than a choice.

Promote choice and raise awareness of the need to change travel behaviour

Rising incomes and dispersed patterns of living have created an increasing demand for faster and more flexible transport, characterised by growing dependency on the private car.

A number of measures have been developed to influence the travel behaviour of individuals and increase travel by more sustainable alternatives to the private car, namely walking, cycling and public transport. Such measures are more widely known as "Smarter Choices" and include school, workplace and individual travel planning, improvements to public transport, car club, tele-working and travel awareness campaigns. Increased investment in such measures would help encourage modal shift towards more sustainable modes. Research published by the Department for Transport in July 2004 demonstrated that Smarter Choices can be effective in changing attitudes and behaviours if consistently applied ¹¹.

A reduction in reliance on the private car in favour of walking, cycling and public transport could also bring positive benefits in terms of air quality and climatic factors through reducing traffic levels.

However, for the full environmental benefits to be realised there would be a need to ensure induced traffic does not occupy the roadspace freed by those moving to more sustainable modes. There is also evidence to suggest modes of transport such as buses can emit greater levels of NO₂ in contrast to the private car and accordingly low emission vehicles should be promoted where possible. It is also important to ensure that promotion of sustainable travel, as well as encouraging an intended shift from the private car, does not also promote movement from walking and cycling towards motorised transport as this would potentially result in an overall increase in traffic volumes and create a net negative impact.

Promote modal shift

Where improvements are made to encourage the use of alternative modes of transport to the private car positive benefits for the environment can be expected. The promotion of policies to effect a reduction in overall traffic volumes would be particularly beneficial in terms of carbon emissions and air pollutants with a tonne of carbon emitted by just over a year's average driving ¹². This would also bring indirect benefits in terms of biodiversity, water and soil through lessening the impact associated with climate change. Walking and cycling are also directly beneficial in terms of human health by increasing levels of physical activity. Improving and encouraging the use of public transport could also have indirect benefits in terms of physical fitness through encouraging walking or cycling to the bus stop or rail station. The inclusion of policies to effect a stabilisation in overall traffic volumes would benefit the population in terms of road safety as would measures to promote safety and security for users of all modes. There would also be benefits through reduced noise levels.

Promoting modal shift would also encourage more efficient use of the existing network and thereby have direct benefits on biodiversity, water and soil by removing the need for large-scale infrastructure projects which can have a damaging impact on such aspects of the environment.

In the context of modal shift it is recognised that for long-distance journeys internal to the UK rail offers a more environmentally sound alternative to aviation, particularly in terms of CO₂ emissions. A tonne of carbon is emitted by around 20 return journeys by plane from Edinburgh to London or around 70 return journeys by train from Edinburgh to London ¹³. A tonne of carbon can be saved by 26 people taking the return journey from Edinburgh to London by train instead of flying. While domestic air travel emissions account for less than 2% of all UK transport emissions, they have increased by 65% since 1990. Improvements in reliability, speed of journey and integration are key issues to be addressed. Within the UK aviation remains a reserved matter, however the Scottish Executive is directly responsible for the following areas: lifeline air links to and from Scottish Islands; Air Route Development Fund; planning issues relating to airports; surface access to airports and sponsorship of Highlands and Islands Airports Limited. On other matters (aviation regulation and policy) the Scottish Executive seeks to influence policy-making at the UK level through existing mechanisms.

Alongside these potential benefits it is also important to recognise that modal shift may result in extra transport demand. The environmental impact of modal shift towards bus and rail is largely dependent on the manner in which this has been achieved. With the development of new infrastructure or reduction in public transport fares intended modal shift from car to public transport could be accompanied by a shift from walking or cycling to motorised public transport, with the environmental gains from the targeted modal shift being exceeded by the negative impact of this unintended shift. There is also evidence to suggest modes of transport such as buses can emit greater levels of NO₂ in contrast to the private car and accordingly low emission vehicles should be promoted where possible. It is therefore important that the contribution of each modal shift project to a reduction in transport emissions is carefully examined prior to implementation at the project level.

As with passenger transport, the environmental performance of different modes is a strong argument for modal shift within the freight sector. Within a freight context the environmental performance of different modes is dependent on technology and logistical characteristics rather than the actual mode. Road transport has a strong competitive advantage over other modes in that it is generally faster, more reliable and flexible; significant factors as just-in-time delivery and the production of high value goods increases. Taking account of these factors, it is feasible that certain shifts from road to rail may increase the environmental burden. For example emission regulations are less strict for marine transport where in port the sulphur limit for the average marine fuel is 0.1% - 20 times higher than for road transport. There is also scope that measures adopted to encourage modal shift within the freight sector, such as new rail infrastructure may increase rail transport without decreasing road transport, thereby bringing about an overall net increase in emissions. Again, it is therefore important that the contribution of each modal shift project to a reduction in transport emissions is carefully examined prior to implementation at the project level.

For the environmental benefits associated with modal shift to be fully realised there is the need to ensure that the additional capacity made available does not result in new/induced traffic. A key requirement in this respect is for measures to promote modal shift to be supported by policies on demand management, such as those detailed in Table 4.

Promote new technologies and cleaner fuels

The energy intensive nature of the transport sector is particularly unsustainable and gives rise to particular problems in terms of air quality and greenhouse gas emissions. New engine and vehicle technologies together with tighter emission standards can cut emissions and fuel consumption. However, the environmental gains achieved are being offset by the continued growth in traffic volume. Therefore for maximum benefits to be achieved, there is a need for the promotion of new technologies and tighter standards to be supported by other measures centred on, for example, modal shift and demand management.

Concern over energy use and security of supply has encouraged the development of biofuels. Biofuels are made from biomass which absorbs carbon during growth and are therefore considered to be a more environmentally sound fuel source. However, the cultivation of biomass through tilling, harvesting and fertilising actually generates carbon emissions. Also, large areas of land are required for the production of biomass leading to competition with other uses such as agriculture and forestry with a potential side-effect of increased carbon emissions. ¹⁴ These issues could be partly addressed in the medium term through the development of more advanced production processes enabling biofuels to be derived from a wider variety of plants. In the longer-term biomass could potentially provide a feedstock in the production of hydrogen for fuel cells. This would carry significant environmental benefits, especially in terms of air quality as the only by-product would be water. However, the levels of production required to make a significant impact on emissions are a long-term goal and dependent on hydrogen being produced in a sustainable manner. ¹⁵

Again the production of biofuels does not address continued growth in overall traffic volumes. Therefore, for maximum benefits to be achieved, there is a need for the promotion of new technologies and tighter standards to be supported by other measures centred on, for example, modal shift and demand management.

Manage demand

Growing incomes and dispersed patterns of living have created an increasing demand for faster and more flexible transport, characterised by growing dependency on the private car. This has been compounded by a pricing structure where the cost of private transport does not take into account of the true external impact which would place it on a more comparative footing in financial terms with other modes.

On average people tend to spend a fixed share of their income and time on transport. An increase in income can be expected to encourage more expensive travel habits leading to greater uptake of faster and flexible transport - private car, air travel and high-speed rail. In terms of time, additional infrastructure will be used if it enables faster travel, which while meeting demand may also encourage an overall increase in traffic.

Demand management measures have the potential to improve carbon emissions and air quality by reducing overall traffic volumes. They would also help maximise the potential environmental benefits arising from modal shift through effective management of the additional capacity released on the road network. This would in turn assure the released capacity did not result in induced traffic.

Development of park and ride could successfully encourage a shift from the private car to public transport, particularly in urban areas. However, there is the potential for a rise in traffic to occur through people driving to the site, including new car journeys that would previously have been made by different modes or not at all. This would be particularly detrimental in terms of carbon related emissions and air pollution more generally. These issues would need to be clearly examined at the project level following proposal of a site. Activities associated with the construction of new transport infrastructure, including extraction of material and energy use, may also impose negative impacts on the environment and would also need to be fully assessed at the project level.

Depending on the exact location of a site there is the potential that biodiversity, cultural heritage, soil and water may be negatively effected, this would require further investigation at the regional or local level following identification of a specific site. There may also be negative implications on material assets with soil loss/erosion and the use of aggregates.

Support for innovation in demand management on the local and trunk road network would have positive benefits for the environment in terms of the immediate area where these measures were in place. There is the potential however that the introduction of measures of this nature would result in peripheral roads receiving more traffic as drivers seek to avoid roads subject to demand management initiatives. In this respect the environmental problems in one area could merely be displaced to another with there being no overall net benefit. This issue would require further investigation at the project level following decisions on location and nature of measures to be introduced.

Reduce the need to travel

Where people choose to live and where businesses, hospitals, supermarkets and other activities choose to locate has a bearing on the transport system and how it is used. For example, if more people chose to live on the outskirts of a city and commute in by car, there would be more cars on the roads than if people had chosen or had the opportunity to live closer to their workplace.

Transport is primarily a form of derived demand - it is a means to an end. Supply and demand patterns which exist today reflect a previous lack of integration between transport and land-use planning. This has resulted in dispersed living patterns, growing demand for transport and an increasing dependence on the private car.

Emphasis on reducing the need to travel would have widespread benefits on the environment. Where travel was necessary greater consideration in the location of new facilities relative to the transport network would give rise to shorter journeys of a distance more conducive to travel by sustainable modes.

Reducing the need to travel would create a less congested, safer and cleaner environment for the population. Less demand for travel would reduce the need for new infrastructure and the direct effects of air, water, noise and soil pollution and loss of biodiversity that might arise from new development.

Promote safety

Emphasis on reducing the need to travel and demand management measures would be of particular benefit to the population with a reduction in traffic levels improving road safety. Measures seeking to promote the safety and security of all modes would also have direct benefits in this respect.

4.5 Issues to be taken into account at the regional and local level

Overall the NTS has the potential to positively benefit the wider environment. The overarching objectives of the strategy seek to achieve an appropriate balance between economic, social and environmental considerations with the pursuit of sustainable development being a key driver for change.

This Environmental Report has sought to provide an overview of the likely significant environmental effects arising from the strategy. Taking account of the strategic context of the NTS and the site specific nature of a number of the environmental criteria included within the scope of the assessment a relatively high level approach has been adopted to the assessment and it is recognised that this constrains the level of detail possible. However, it is inherently difficult to provide for a detailed analysis where there is a considerable degree of uncertainty regarding the location and exact nature of activity that would arise from the measures proposed in the NTS Consultation Paper. On these grounds this Environmental Report provides the context for more detailed environmental assessment which would be expected to be taken forward at the national level through the SPR and the regional and local level by Regional Transport Strategies ( RTSs) and Local Transport Strategies ( LTSs) respectively.

Furthermore, the NTS does not consider new infrastructure, rather it provides the framework for the SPR which will identify, appraise and prioritise the key strategic projects across all modes of transport and reflect the principles and priorities set out in the NTS. In effect the SPR will translate the NTS into rail and road (or other strategic projects). This approach will give a structure against which questions of investment can be judged and is consistent with best practice at the international level which is objective-led ("what is transport for and what do we want it to do?") rather than infrastructure-project led ("what can we build this year?"). The SPR process will itself be appraised in accordance with the SEA Regulations with individual projects being subject to STAG appraisal and/or EIA where appropriate.

Given that the NTS will provide a framework for the SPR, it would be expected that the findings detailed within this Environmental Report would feed into the SEA process for the SPR and related project level assessments as required with the details given in Table 4 providing the premise for the scope of assessment undertaken. In terms of output, projects arising from the SPR would be included within the appropriate Development Plan which will also be subject to appraisal through the SEA, STAG and EIA process as required.

The NTS will also set a context within which the RTPs will develop their RTSs. Local Authorities are currently undertaking a revision of their LTSs which will also be of benefit to the RTS development process as the LTSs can feed upwards into their respective RTS. The RTSs will also be subject to the SEA process and it would be expected they too will take account of this Environmental Report, particularly where the assessment of certain environmental topics has been highlighted to be more applicable to the regional or local level. In terms of LTSs, where the implementation of individual schemes requires project level environmental appraisal it would be expected that reference is made to the assessment framework outlined within this Environmental Report with particular regard to criteria where detailed appraisal has been identified to be more applicable at the local level. In essence the aforementioned interactions will take place on an iterative basis - RTS with the NTS, LTS with RTS.

In summary, with the NTS providing the framework for transport policy at the regional and local level this Environmental Report effectively provides the framework for the corresponding environmental appraisal work within the transport hierarchy. On this basis it would be expected that this Environmental Report, in particular the scope of the assessment, is taken into account in undertaking environmental appraisal at other levels within the transport hierarchy.

4.6 Assessment of alternatives - cumulative and synergistic effects

Given the hierarchy of transport policy development it is inherently difficult at the strategic level to consider with explicit detail the cumulative effects of the strategy, and accordingly Table 10 provides a general overview of the key issues identified for each environmental topic considered within the assessment process.

Table 10 - Summary of cumulative environmental effects of the NTS

4.7 Assessment of alternatives - compatibility with other plans and programmes

The overall aim of the NTS is to promote economic growth, social inclusion, health and protection of our environment through a safe, integrated, effective and efficient transport system. The strategy will in turn outline a series of plans and policies which broadly reflect this overall aim. It is recognised that an overarching aim of this nature and associated policy measures may not be complimentary in all respects. The challenge for the NTS is to identify a comprehensive package of policies, balanced across all relevant sectors, which will lead to a transport system that is compatible with sustainable development.

A particular area of tension identified by stakeholders during the pre-draft consultation process is the balance of economic growth and protection of the environment. It is widely perceived that continued growth in the economy in recent years has meant a higher demand for goods and services and a higher demand for transport. Breaking the link between the two is one of the key challenges of the strategy. The NTS must help maintain and build on Scotland's economic growth, without causing further traffic growth, pollution and congestion. It is also important to recognise that while in one respect there may be tension between the promotion of economic growth and protection of the environment in another regard they may actually complement each other. For example, measures to promote modal shift and raise awareness of the need for change are inherently positive in environmental terms and also in an economic sense - encouraging those who have the option to use sustainable alternatives would free up road space for those who have no alternative, including freight and other business needs and in doing so allow for improved productivity through reduced congestion on the road network, reduced personal stress levels and general improvement to health.

In considering specific policies there is also the potential for tension. For example, managing demand and promoting accessibility could be perceived to be moving in different directions. However, within the NTS policies to promote accessibility are not focused on increasing travel per se but rather look to address social exclusion and ensure that all communities have access to the services and transport they require. In addition measures to manage demand are not tailored to reducing travel as such but are intended to encourage individuals to think about their travel options and use their car in a more sensible manner, the offset being a reduction in traffic volumes and congestion on the trunk and local road network.

In a similar context, a number of inter-related effects can be identified and are largely dependent on the nature of the measures proposed. For example, measures to promote modal shift and promote choice and raise awareness of the need for change have shown a number of inter-related effects on population and human health in terms of improving accessibility and levels of physical activity. These measures can also potentially reduce demand for roadspace and in doing so offset the negative impacts on biodiversity, noise, the landscape, cultural heritage and material assets associated with the development of new infrastructure necessitated by saturation of the existing network.

Demand management measures, for example park and ride sites and road pricing, have also demonstrated possible inter-related effects on local air quality, noise and climatic factors through the introduction of traffic into new areas (in terms of road pricing this may occur as people try to avoid roads subject to charging) and water and soil by the introduction of new pollution emissions to areas.

One of the principles underpinning the NTS is that investment should be targeted where the overall balance of impacts is positive, taking into account all five high-level objectives. A key challenge for the NTS is to ensure there is balance across all sectors and that the strategy will provide for a transport system that complements and reinforces sustainable development.

4.8 Proposed mitigation measures

Schedule 2 of the Regulations 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 11 details proposed mitigation measures to address potential environmental problems which may arise from policies contained in the final NTS.

Table 11 - Mitigation measures

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