DRAFT Sustainability Appraisal Report for the Emerging Local Plan ...

2013 

DRAFT Sustainability Appraisal Report for 

the Emerging Local Plan of Runnymede 

Borough Council 

Sustainability Appraisal Report 

(incorporating an SEA Environmental Report) 

Runnymede Borough Council 

February 08, 2013

This Draft Sustainability Appraisal Report of the emerging Local Plan has been prepared by Runnymede 

Borough Council pursuant to Section 19(5) of the Planning and Compulsory Purchase Act 2004 and 

Regulation 12 of the Environmental Assessment of Plans and Programmes Regulations 2004. It has been 

prepared with all reasonable skill, care, and diligence within the terms of its duty and within the limitations 

of the resources available to the Council. 

It is based on the information provided to and or held by Runnymede Borough Council including various 

other stakeholders and statutory consultation bodies. 

This report is made available to specific consultees and Runnymede Borough Council accepts no 

responsibility whatsoever for comments made by third parties whom this report may reference. 

Runnymede Borough Council does not accept responsibility whatsoever to third parties to whom this 

report, or any part thereof, is made known. Any such party relies upon the opinion at their own risk. 

The fact that Runnymede Borough Council has produced this report shall not preclude the Council from 

subsequently modifying, altering, or adding to it should and if further information in connection with any 

element within the report becomes available.

Draft Sustainability Appraisal Report for 

Runnymede Borough Council’s 

Local Plan 2013 – 2026 

February 2013 


Technical Services 

Runnymede Civic Centre 

Station Road 

Addlestone 

Surrey KT15 2AH 

Telephone: 01932 838383 

Facsimile: 01932 425271 

DX 46350 ADDLESTONE 

Web Site: www.runnymede.gov.uk 

Further copies of this publication can be obtained from the above address, 

or email: iau@runnymede.gov.uk

Page | 4 Runnymede BC FINAL Sustainability Appraisal Report – Feb 2013

CONTENTS 

List of Tables ............................................................................................................................................10 

List of Figures ............................................................................................................................................11 

Commenting on this report ........................................................................................................................13 

List of Abbreviations...................................................................................................................................14 

Glossary of terms........................................................................................................................................15 

SECTION 1. INTRODUCTION TO SA/SEA REPORT FOR THE LOCAL PLAN...................................................... 17 

Section 1 Purpose of this Document ..................................................................................................17 

Section 2 Legal and Statutory Requirements .....................................................................................17 

Section 3 Framework and Methodology ............................................................................................18 

Section 4 Assessment of RBC’s Local Plan against the SA Framework and Consideration of Alternatives 

............................................................................................................................................18 

Section 5 ‐ 14 [ER01] Natural Environment and Biodiversity ....................................................................18 

Section 15 Cumulative & Synergistic Effect Assessment......................................................................18 

Section 16 Conclusions.........................................................................................................................19 

Section 18 Data Uncertainty and Risks.................................................................................................19 

Section 19 Plan Uncertainty and Risks .................................................................................................19 

Section 20 Monitoring..........................................................................................................................19 

Section 21 Next Stages ......................................................................................................................... 19 

SECTION 2. LEGAL AND STATUTORY REQUIREMENTS................................................................................. 21 

Legal Requirement for a Sustainability Appraisal (SA) ...............................................................................21 

Legal Requirement for Strategic Environmental Assessment (SEA)...........................................................22 

Sustainable Community Strategy and Local Development Frameworks....................................................24 

National Planning Policy Framework (NPPF 2012) .....................................................................................26 

Regional Spatial Strategy – South East Plan (SEP 2006 ‐ 2026) ..................................................................26 

Incorporating the Requirements of SEA into the SAR ................................................................................26 

Consideration of the Habitats Regulations.................................................................................................27 

Summary of SA/SEA Consultation, Appraisal and Assessment to Date......................................................28 

SECTION 3. FRAMEWORK AND METHODOLOGY ........................................................................................ 31 

Introduction ............................................................................................................................................31 

Level 1 Assessment – Pre‐Screening ..........................................................................................................31 

Level 2 Assessment – Impact Identification (Screening and Scoping)........................................................32 

Level 3 Assessments – Sustainability Appraisal..........................................................................................32 

Level 4 Assessments – Meeting the requirements of the SEA Directive ....................................................33 

SEA Environmental Receptor Framework...............................................................................................38 

Assessment of Local Plan vision, objectives and implementation measures..........................................40 

Cumulative Effects Assessment (CEA) – incorporating consideration of Synergistic Effects ..................41 

Level 5 Assessment – Environmental Impact Assessment (EIA).................................................................44 

Level 6 Assessment – Habitats Regulations Assessment/Appropriate Assessment (HRA) ........................45 

SECTION 4. ASSESSMENT OF RBC’S LOCAL PLAN AGAINST THE SA FRAMEWORK AND CONSIDERATION OF 

ALTERNATIVES................................................................................................................................................ 47 

Link between the SCS and LDF ...................................................................................................................47 

Wider strategic context ..............................................................................................................................48 

Local Plan Strategic Context Fit ..................................................................................................................48 

Background to Runnymede Borough Council’s Local Plan .........................................................................50 

Local Plan Strategic alternatives.................................................................................................................51 

Location Policy 1 (LP01) – Strategy for the Location of Development....................................................52 

Location Policy 2 (LP02) – Housing Provision and Distribution...............................................................53 

Location Policy 3 (LP03) – Development in Addlestone Urban Area.......................................................53 

Location Policy 4 (LP04) – Development in Egham/Englefield Green Urban Area .................................54 

Location Policy 5 (LP05) – Royal Holloway UOL......................................................................................55 

Location Policy 6 (LP06) – Development in Chertsey Urban Area...........................................................55 

Location Policy 7 (LP07) – Development in Virginia Water Urban Area .................................................56 

Location Policy 8 (LP08) – The Former DERA Site Longcross ..................................................................56 


Strategic Policy 1 (SP01) – Green Belt Areas ..........................................................................................57 

Strategic Policy 2 (SP02) – Affordable Housing ......................................................................................58 

Strategic Policy 3 (SP03) – Gypsy, Travellers and Travelling Showpeople ..............................................58 

Strategic Policy 4 (SP04) – Provision and Retention of Infrastructure and Services ...............................59 

Strategic Policy 5 (SP05) – Design ..........................................................................................................60 

Strategic Policy 6 (SP06) – Tourism, Recreation, and Leisure.................................................................61 

Strategic Policy 7 (SP07) – Thames Basin Heath Special Protection Area ..............................................61 

Strategic Policy 8 (SP08) – Employment Development...........................................................................62 

Strategic Policy 9 (SP09) – Sustainable Transport ..................................................................................63 

Strategic Policy 10 (SP10) – Development and Flood Risk......................................................................63 

SECTION 5. [ER01] NATURAL ENVIRONMENT AND BIODIVERSITY .............................................................. 65 

Introduction ............................................................................................................................................65 

Applicable SA/SEA Objective/Factor.......................................................................................................65 

Current Policy Context................................................................................................................................65 

International...........................................................................................................................................66 

National..................................................................................................................................................66 

Regional..................................................................................................................................................67 

County.....................................................................................................................................................67 

Local........................................................................................................................................................67 

Current Baseline Condition ........................................................................................................................68 

Evolution of Baseline in Absence of Plan....................................................................................................73 

Potential Impact Pathways.........................................................................................................................74 

Consideration of Implications of Plan and Alternatives on Receptor ER01................................................74 

Cumulative Effects Assessment..................................................................................................................81 

Mitigation/Enhancement Recommendations ............................................................................................81 

Suggested Monitoring Regime ...................................................................................................................82 

SECTION 6. [ER02] WELFARE, HEALTH AND WELL‐BEING............................................................................ 83 

Introduction ............................................................................................................................................83 

Current Policy Context................................................................................................................................84 


National..................................................................................................................................................85 

Regional..................................................................................................................................................85 

County.....................................................................................................................................................85 



Evolution of Baseline in Absence of Plan....................................................................................................86 

Potential Impact Pathways.........................................................................................................................87 

Consideration of Policy and its Alternatives...............................................................................................88 

Cumulative Effects Assessment..................................................................................................................96 

Mitigation /Enhancement Recommendations ...........................................................................................96 

Suggested Monitoring Regime ...................................................................................................................96 

SECTION 7. [ER03] LAND AND SOIL RESOURCES ......................................................................................... 97 

Introduction ............................................................................................................................................97 

Applicable SA/SEA Objective/Factor.......................................................................................................97 

Policy Context 97 


National..................................................................................................................................................98 

Regional..................................................................................................................................................98 

County.....................................................................................................................................................99 



Evolution of Baseline condition in Absence of Plan .................................................................................101 

Potential Impact Pathways....................................................................................................................... 101 

Consideration of Policy and its Alternatives on ER03...............................................................................101 

Cumulative Effects Assessment................................................................................................................106 

Mitigation/Enhancement Recommendations ..........................................................................................106 

Suggested Monitoring Regime .................................................................................................................106 


SECTION 8. [ER04] WATER RESOURCES AND MANAGEMENT ................................................................... 109 

Introduction ..........................................................................................................................................109 

Applicable SA/SEA Objective/Factor.....................................................................................................109 

Current Policy Context..............................................................................................................................109 

International.........................................................................................................................................110 

National................................................................................................................................................110 

Regional................................................................................................................................................110 

County...................................................................................................................................................110 

Local......................................................................................................................................................111 

Current Baseline Condition ...................................................................................................................... 111 

Evolution of Baseline in Absence of Plan..................................................................................................114 






SECTION 9. [ER05] AIR QUALITY ............................................................................................................... 123 

Introduction ..........................................................................................................................................123 


Policy Context 123 


National................................................................................................................................................124 

Regional/County...................................................................................................................................125 



Potential impact pathways....................................................................................................................... 127 




Current Planning Controls Background ‐ Planning Policy and the draft 2012 Air Quality Plan (AQAP)....135 


SECTION 10. [ER06] CLIMATE CHANGE ................................................................................................... 143 

Introduction ..........................................................................................................................................143 




National................................................................................................................................................145 

Regional................................................................................................................................................146 

County...................................................................................................................................................146 





Consideration of Policy and its Alternatives on ER06 Climate Change.....................................................150 




SECTION 11. [ER07] MATERIALS EFFICIENCY AND WASTE....................................................................... 161 

Introduction ..........................................................................................................................................161 




National................................................................................................................................................162 

Regional................................................................................................................................................162 

County...................................................................................................................................................162 




Evolution of Baseline Condition ...............................................................................................................163 






SECTION 12. [ER08] BUILT ENVIRONMENT ............................................................................................. 171 

Introduction ..........................................................................................................................................171 




National................................................................................................................................................172 

Regional................................................................................................................................................172 

County...................................................................................................................................................172 








SECTION 13. [ER09] HISTORIC ENVIRONMENT AND ARCHAEOLOGY ...................................................... 181 

Introduction ..........................................................................................................................................181 




National................................................................................................................................................182 

Regional................................................................................................................................................182 

County...................................................................................................................................................182 





Consideration of Policies and its Alternatives ..........................................................................................184 




SECTION 14. [ER10] LANDSCAPE AND VISUAL AMENITY......................................................................... 193 

Introduction ..........................................................................................................................................193 




European ..............................................................................................................................................194 

National................................................................................................................................................194 

Regional................................................................................................................................................195 

County...................................................................................................................................................195 









SECTION 15. CONCLUSIONS.................................................................................................................... 203 

Introduction 203 


Local Plan Policy Context Conclusion .......................................................................................................203 

SA Sustainability Objectives Conclusion...................................................................................................203 

SEA Environmental Receptor Conclusion .................................................................................................204 

ER01 – Natural Environment and Biodiversity......................................................................................205 

ER02 – Welfare, Health & Well‐being...................................................................................................206 

ER03 – Land& Soil Resource .................................................................................................................207 

ER04 – Water Resources & Management ............................................................................................208 

ER05 – Air Quality.................................................................................................................................209 

ER06 – Climate Change......................................................................................................................... 211 

ER07 – Materials Efficiency & Waste....................................................................................................212 

ER08 – Built Environment .....................................................................................................................213 

ER09 – Historic Environment & Archaeology........................................................................................214 

SEA and SA Conclusion of the Local Plan Policies.....................................................................................217 

Location Policy 1 (LP01) – Strategy for the Location of Development..................................................217 

Location Policy 2 (LP02) – Housing Provision and Distribution.............................................................218 

Location Policy 3 (LP03) – Development in Addlestone Urban Area.....................................................219 

Location Policy 5 (LP05) – Royal Holloway UOL....................................................................................221 

Location Policy 6 (LP06) – Development in Chertsey Urban Area.........................................................222 

Location Policy 7 (LP07) – Development in Virginia Water Urban Area ...............................................222 

Location Policy 8 (LP08) – The Former DERA Site Longcross ................................................................223 

Strategic Policy 1 (SP01) – Green Belt Areas ........................................................................................224 

Strategic Policy 2 (SP02) – Affordable Housing ....................................................................................224 

Strategic Policy 3 (SP03) – Gypsy, Travellers and Travelling Showpeople ............................................225 

Strategic Policy 4 (SP04) – Provision and Retention of Infrastructure and Services .............................226 

Strategic Policy 5 (SP05) – Design ........................................................................................................227 

Strategic Policy 6 (SP06) – Tourism, Recreation, and Leisure...............................................................227 

Strategic Policy 7 (SP07) – Thames Basin Heath Special Protection Area ............................................228 

Strategic Policy 8 (SP08) – Employment Development.........................................................................229 

Strategic Policy 9 (SP09) – Sustainable Transport ................................................................................229 

Strategic Policy 10 (SP10) – Development and Flood Risk....................................................................230 

Overall Policy Conclusions .................................................................................................................... 231 

SECTION 16. DATA, DATA UNCERTAINTY AND RISKS.............................................................................. 233 

Data Used .............................................................................................................................................233 

Data Uncertainty ..................................................................................................................................233 

Data Risks .............................................................................................................................................233 

SECTION 17. PLAN UNCERTAINTY AND RISKS ......................................................................................... 235 

SECTION 18. MONITORING..................................................................................................................... 237 

SECTION 19. NEXT STAGES ..................................................................................................................... 239 

List of Appendices 

Appendix 1 – Annex 3: Documents replaced by the NPPF…………………………………………………………………. A01:1‐1 

Appendix 2 – L2 Assessment Outputs…………...…………………..……………….…..…………………….…………… A02:1‐1300 

Appendix 3 – Level 3 SA Summary Table …..………………………….………………………………………….…………….… A03:1‐2 

Appendix 4 – Level 4 SEA Summary Table………………………………..………………………………………….………….… A04:1‐2 

Appendix 5 – What is an effect……………….…………………………….………………………………………….…………….… A05:1‐1 

Appendix 6 – Regional Sustainability Framework………………….………………………………………….…………… A06:1‐28 

Appendix 7 – Level 5 SDC – Modified…………………………….………………………………………….…………….………… A07:1‐26 

Appendix 8 – HRA Screening Report (2012).………………………….………………………………………….………………A08:1‐108 

Appendix 9 – HRA Report of Local Plan………………………….………………………………………….…………….……….A09:1‐471 

Appendix 10 – Relevant Plans, Policies and Programmes..………………………………………….…………….…….… A10:1‐4 

Appendix 11 – References and Data Used in SAR…………….………………………………………….…………….…….… A11:1‐67 

Appendix 12 – Cumulative Assessment Flow Diagram …….………………………………………….…………….…….… A12:1‐1 

Appendix 13 – Constraints Map of Runnymede ..…………….………………………………………….…………….…….… A13:1‐1 

Appendix 14 – Current Air Quality in Runnymede..………….………………………………………….…………….…….… A14:1‐10 

Appendix 15 – Emission Reductions ……………………………….………………………………………….…………….…….… A15:1‐5 

Appendix 16 – LP08 DERA Level 5 Output………………….…….………………………………………….…………….…….… A16:1‐9 

Appendix 17 – SAR Consultation Report…………………….…….………………………………………….…………….…….… A17:1‐6 


List of Tables 

Table 1 – SEA Factors..................................................................................................................................24 

Table 2 – Assessment Chapter Components ..............................................................................................27 

Table 3 – SA/SEA Timeline and Effect on Plan............................................................................................28 

Table 4 – SAR Team Members....................................................................................................................29 

Table 5 – SA Objectives and Current Condition..........................................................................................36 

Table 6 – Meeting the requirements of the Strategic Environmental Assessment Directive ....................37 

Table 7 – Analytical framework for the Strategic Environmental Assessment...........................................38 

Table 8 – Impact classifications used for the SEA.......................................................................................41 

Table 9 – Examples of cumulative effects (Adapted from US Council on Environmental Quality, 1997) ..42 

Table 10 – Additive and interactive effects (Adapted from James E, et al. (2003).....................................43 

Table 11 – Cumulative effects assessment of Policies in the Local Plan ....................................................43 

Table 12 – Local Plan Strategic Policy Objectives .......................................................................................48 

Table 13 – Local Plan Strategic Fit ..............................................................................................................49 

Table 14 – Local Plan Policies .....................................................................................................................50 

Table 15 – LP01 Policy Options Considered ...............................................................................................52 








Table 23 – SP01 Policy Options Considered ...............................................................................................57 










Table 33 – Applicable SA/SEA Objective/Factor for ER01 ..........................................................................65 

Table 34 – ER01 Policy Context Summary ..................................................................................................66 

Table 35 – ER01 Summary Key Environmental Issues and Challenges.......................................................68 

Table 36 – European sites located within or close to Runnymede (Source: NE 2012)...............................69 

Table 37 – SSSIs located within Runnymede (Source: Natural England June 2012)...................................70 

Table 38 – Summary of Local Plan Policies and alternatives on ER01........................................................80 

Table 39 – CEA ER01...................................................................................................................................81 

Table 40 – ER01 CEA Summary...................................................................................................................81 

Table 41 – Suggested Monitoring of Impacts and Effects of the LP on ER01.............................................82 

Table 42 – Applicable SA/SEA Objective/Factor ER02................................................................................83 


Table 44 – ER02 Summary Key Environmental Issues and Challenges.......................................................86 

Table 45 ‐ Delivery Period Population Projections .....................................................................................87 

Table 46 – Summary of Local Plan Policies and alternatives on ER02........................................................95 

Table 47 ‐ Suggested Monitoring of Impacts and Effects of the LP on ER02..............................................96 

Table 48 – Applicable SA/SEA Objective/Factor to ER03............................................................................97 


Table 51 – ER03 Summary Key Environmental Issues and Challenges.....................................................100 

Table 52 – Summary of Local Plan Policies and alternatives on ER03......................................................105 

Table 53 – Suggested Monitoring of Impacts and Effects of the LP on ER03...........................................107 

Table 54 – Applicable SA/SEA Objective/Factor to ER04..........................................................................109 

Table 55 – ER04 Policy Context Summary ................................................................................................109 



Table 58 – CEA ER04 – Water Resources and Management ....................................................................121 


Table 59 – ER04 – Water Resource and Management CEA Summary .....................................................121 

Table 60 ‐ Suggested Monitoring of Impacts and Effects of the LP on ER04............................................122 



Table 63 – ER05 Key Environmental Issues and Challenges Summary.....................................................126 


Table 65 – ER05 CEA.................................................................................................................................135 

Table 66 – ER05 CEA Summary.................................................................................................................135 


Table 68 – Applicable SA/SEA Objective/Factor to Climate Change ........................................................143 



Table 71 – Existing Planning Policies Connected with Climate Change....................................................149 


Table 73 – ER06 CEA.................................................................................................................................157 

Table 74 – ER06 CEA Summary.................................................................................................................157 


Table 76 – Applicable SA/SEA Objective/Factors to ER07 ........................................................................161 















Table 91 – Applicable SA/SEA Objective on ER10.....................................................................................193 




Table 95 ‐ Suggested Monitoring of Impacts and Effects of the LP on ER10............................................202 

Table 96 – SEA Stages B and C..................................................................................................................239 

List of Figures 

Figure 1 ‐ UK Governments Guiding Sustainable Development Principles……………………………………………… 21 

Figure 2 ‐ Five‐stage approach to Sustainability Appraisal…………………………………………………………………….. 22 

Figure 3 ‐ The DPD/SA Preparation Process…………………………………………………………………………………………… 34 

Figure 4 ‐ Compatibility between SA Objectives and SEA Factors……………………………………………………………35 

Figure 5 ‐ Environmental network analysis of cumulative impacts of LP……………………………………………….. 44 

Figure 6 ‐ RBC Assessment Framework…………………………………………………………………………………………………. 46 

Figure 7 ‐ Development and delivery of the SCS, LDF and LAA………………………………………………………………. 47 

Figure 8 ‐ Projected Population in Runnymede 2031…………………………………………………………………………….. 88 

Figure 9 ‐ Thames Watershed (River Basin)…………………………………………………………………………………………. 112 

Figure 10 ‐ Source Protection Zones in Surrey…………………………………………………………………………………….. 113 

Figure 11 ‐ Source Protection Zone in Runnymede……………………………………………………………………………… 114 

Figure 12 ‐ Hierarchy of methods for addressing air pollution…………………………………………………………….. 137 

Figure 13 ‐ EU Waste Hierarchy (2010)………………………………………………………………………………………………...212 


Specific Consultee list for: 

Sustainability Appraisal Report (SAR) for the Runnymede Borough Council‘s Local Plan (Local Plan). 

Date Issued to: Name 

14/02/2013 Natural England consultations@naturalengland.org.uk 

14/02/2013 Environment Agency planning-wallingford@environment-agency.gov.uk 

14/02/2013 English Heritage Peter.kendall@english-heritage.org.uk 

14/02/2013 Highways Agency Patrick.blake@highways.gsi.gov.uk 

14/02/2013 Surrey County Council Sue.janota@surreycc.gov.uk 

14/02/2013 Spelthorne Borough 

Council 

14/02/2013 Elmbridge Borough 

Council 

14/02/2013 Woking Borough 

Council 

14/02/2013 Surrey Heath Borough 

Council 

14/02/2013 Royal Borough of 

Windsor & 

Maidenhead 

14/02/2013 RBC Website – Coconsultation 

with the 

Local Plan 

14/02/2013 RBC Internal 

Circulation List 

Planning.policy@spelthorne.gov.uk 

tplan@elmbridge.gov.uk 

DevelopmentManagement@woking.gov.uk 

Michelle.fielder@surreyheath.gov.uk 

Planning.maidenhead@rbwm.gov.uk 

http://www.runnymede.gov.uk/portal/site/runnymede/planning_policy/ 

N/A 

14/02/2013 RBC File Copy N/A 


Commenting on this SAR Report 

Please send comments on any aspect of the report before Thursday 28 th March 2013 to: 

Director of Technical Services 


Civic Centre 

Station Road 

Addlestone 

Surrey KT15 2AH 

Fax: 01932 425271 

If you have any questions or would like clarification of any aspect of the report, please do not hesitate to 

contact: 

John Willmott-French 

Tel: 01932 425277 

Email: john.willmott‐french@runnymede.gov.uk 


List of Abbreviations 

AAP Area Action Plan MoD Ministry of Defence 

AMR Annual Monitoring Report NE Natural England 

AURN Automatic Urban and Rural Network NERC Natural Environment Research Council 

BAP Biodiversity Action Plan NPPF National Planning Policy Framework 

BREEAM 

Building Research Establishment Environmental 

Assessment Method 

ODPM 

Office of the Deputy Prime Minister 

CEA Cumulative Effect Assessment PDL Previously developed Land 

CEH Centre for Ecology and Hydrology PAS Planning Advisory Service 

CHP Combined Heat and Power PINS Planning Inspectorate 

CIL Community Infrastructure Levy PPG Planning Policy Guidance 

CPRE Council for the Protection of Rural England PPP Plans, Policies and Programmes 

CS Core Strategy PPS Planning Policy Statements 

CSH Code for Sustainable Homes PSA Public Service Agreement 

DCLG Department of Communities and Local Government RBC Runnymede Borough Council 

DEFRA Department for Environment, Food and Rural Affairs RE Regional Economy 

DERA Defence Evaluation research Agency RSF Regional Sustainability Framework 

DfT 

Department for Transport DPD‐ Development Plan 

Document 

RSS 

Regional Spatial Strategy 

DPD Development Plan Document SA Sustainability Appraisal 

DPH Dwellings per Hectare SAC Special Area of Conservation 

EA Environment Agency SANGS Suitable Alternative Natural Green Space 

EH English Heritage SAP Standard Assessment Procedure 

ELR Employment Land Review SCC Surrey County Council 

ER Environmental Report SCI Statement of Community Involvement 

ES Environmental Statement SEA Strategic Environmental Assessment 

GI Green Infrastructure SEEDA South East England Development Agency 

GOSE Government Office for the South East SEERA South East England Regional Assembly 

GTAA Gypsy Traveller Accommodation Assessment SEP South East Plan 

HA Highways Agency SFRA/FRA Strategic Flood Risk Assessment 

HRA Habitats Regulations Assessment SHLAA Strategic Housing Land Availability Assessment 

IRF Integrated Regional Framework SHMA Strategic Housing Market Assessment 

LDD Local Development Document SNCI Site of Nature Conservation Importance 

LDF Local Development Framework SPA Special Protection Area 

LDS Local Development Scheme SPD Supplementary Planning Document 

LF London Fringe SRN Strategic Road Network 

LNR Local Nature Reserve SSSI Site of Special Scientific Interest 

LP Local Plan SUDS Sustainable Urban Drainage System 

LPA 

Local Planning Authority 

SWLW 

SPA 

South West London Waterbodies SPA and Ramsar 

Site 

LSP 

Local Strategic Partnership 

TAP&C 

SAC 

Thursley, Ash, Pirbright and Chobham SAC 

LTP Local Transport Plan TBH SPA Thames Basin Heath SPA 

MDS Major developed Site TC Town Centre 

MGB Metropolitan Green Belt WF&GP Windsor Forest and Great Park SAC 


Glossary of terms 

TERM 

Baseline Data 

Biodiversity 

Cumulative Effect Assessment 

DCLG 

Development Plan 

Development Plan Document 

(DPD) 

European Site 

Habitats Directive 

DESCRIPTION 

The data is used as a reference with which to compare future observations or 

results 

The richness and variety of living things (i.e. plants and animals), which exist 

in a given area, and the habitats that support them 

An assessment carried out to consider the significance of a number of 

combined insignificant impacts from multiple programmes and strategies 

across a number of proximities that can eventually result in a significant effect 

on a receptor 

Department of Communities and Local Government 

Consists of the Regional Spatial Strategy and Development Plan Documents 

contained within the Council’s Local Plan. Until the Local Plan is fully in place it 

will also include ‘saved’ policies from the Council’s Local Plan 2001 

A spatial planning document within the Council’s Local Development 

Framework which set out policies for development and the use of land. 

Together with the Regional Spatial Strategy they form the development plan 

for an area. They are subject to independent examination 

A site that is designated under the Habitats Directive for the protection of 

fauna and flora. 

Council Directive 92/43/EEC on the Conservation of natural habitats and of 

wild fauna and flora 

Habitats Regulations The Conservation of Habitats and Species Regulations 2010 

Habitats Directive Assessment 

(Appropriate Assessment) 

Indicator 

Local Development Framework 

Local Sustainability 

Framework (LSF) 

Local Plan 

LPAs 

Natural England 

National Planning Policy 

Framework 

Sustainable Development 

Objective 

Planning Policy Guidance Note 

Planning Policy Statement 

PPPs 

Regional Planning Guidance 

Reasonable Alternative 

An assessment made of the implication of plan, programme or strategy will 

have on a Natura 2000 (also known as “European Sites”) site pursuant to 

Regulation 102 and 103 of the Habitats Regulations 

Measure of variables over time, often used to measure achievement of 

objectives 

Consists of a number of documents which together form the spatial strategy 

for development and the use of land (superseded by the Local Plan) 

A framework document that the Council is developing to act as a replacement 

for the Regional Strategic Framework (RSF) 

A borough-wide planning document setting out policies for development and 

the use of land. 

Local Planning Authorities 

From October 2006 English Nature, the environment activities of the Rural 

Development Service and the Countryside Agency’s Landscape, Access and 

Recreation division were united in a single body called Natural England 

A planning policy guidance document issued by the Government, setting out 

policy guidance on different aspects of planning. The NPPF replaced Planning 

Policy Guidance Notes and Planning Policy Statements 

A statement of what is intended, specifying the desired direction of change in 

trends 

A series of planning notes issued by the Government, setting out policy 

guidance on different aspects of planning (superseded by NPPF) 

A series of notes issued by the Government, setting out policy guidance on 

different aspects of planning. They will replace Planning Policy Guidance Notes 

(superseded by NPPF) 

Plans, Policies and Programmes 

Planning Guidance produced at a regional level to tackle issues of strategic 

importance that can be best dealt with over a larger area 

An alternative that could reasonably meet the objectives of a policy – such as 

providing development at an alternative site 


TERM 

Scoping 

SEA Directive 

DESCRIPTION 

The process of deciding the scope and level of detail of a SA, including 

sustainability effects and alternatives which need to be considered, the 

assessment methods to be used, and the structure and contents of the SA 

report 

European Directive 2001/42/EC ‘On the assessment of the effects of certain 

plans and programmes on the environment’ 

SEA Regulations The Environmental Assessment of Plans and Programmes Regulations 2004 

South East Plan 

Strategic Environmental 

Assessment 

Sustainability Appraisal 

Sustainable Development 

Target 

Trajectory 

Trend 

A plan produced by the South East England Regional Assembly 

A tool for integrating environmental considerations into decision making by 

ensuring that significant environmental effects of the decision are taken into 

account 

Appraisal of plans, strategies, and proposals to test them against broad 

sustainability objectives 

Development that meets the needs of the present without compromising the 

ability of future generations to meet their own needs (Brundtland 1987) 

The overall aim of the objective 

The process of charting the objective over time in relation to the target 

Provides a guide to the speed and direction in which indicators should move 

to achieve objectives 


Section 1. 

Section 1 

Introduction to SA/SEA Report for the Local Plan 

Purpose of this Document 

1.1 This report forms part of the Sustainability Appraisal (SA) and Strategic Environmental Assessment 

(SEA) for Runnymede Borough Council’s (the Council) Local Plan (Local Plan) Preferred Options 2013 – 

2026. 

1.2 The Local Plan will replace the Council’s existing Local Plan (2001). Up until the summer of 2010, the 

Council was preparing a Core Strategy to replace its existing Local Plan. However, the Governments 

decision to revoke all Regional Plans including the South East Plan (SEP), introduce the Localism Act 

(2011) and refine considerably all planning policy guidance in to the concise National Planning Policy 

Framework (NPPF) has resulted in the Council moving towards the preparation of a new style Local 

Plan. This new Local Plan will supersede and complement all work done to date on previous versions. It 

also uses previous evidence, research and consultations undertaken on the Core Strategy to inform its 

emerging policies. Conclusions reached as a result of these earlier assessments and appraisals are used 

to inform this report. However, where conclusions no longer reflect current baseline or policy 

conditions, they have been updated. 

1.3 The requirements of Section 39 (2) of the Planning and Compulsory Purchase Act 2004 made the 

delivery of sustainable development central to the reform of the planning system. The purpose of SA, 

which was made mandatory under S19(5) of the same 2004 Act, is intended to promote sustainable 

development through the integration of social, environmental and economic considerations into the 

preparation and revisions of Development Plan Documents (DPD) and Supplementary Planning 

Documents (SPD). 

1.4 Pursuant to Section 19(5) of the Planning and Compulsory Purchase Act 2004, a SA must be carried out 

during the plans preparation. In addition, there is also a requirement to carry out an SEA pursuant to 

the Strategic Environmental Assessment Regulations (2004) ( 1) 

(SEA Regulations). The SEA Regulations 

transpose the requirements of the EU Directive 2001/42/EC on the assessment of the effects of certain 

plans and programmes on the environment (SEA Directive) into national law. 

1.5 PAS advises 2 that, PPS12 at paragraph 4.40 states: “Sustainability appraisal fully incorporates the 

requirements of the European Directive on Strategic Environmental Assessment. Provided the 

sustainability appraisal is carried out following the guidelines in the A Practical Guide to the Strategic 

Environmental Assessment Directive and the Plan‐Making Manual there will be no need to carry out 

a separate SEA.” 

1.6 Government advice advocates integrating the SEA requirements into the SA as part of the plan 

preparation process. In essence these statutory requirements are met in that the preparation of the SA 

has occurred over two key stages between 2007 and 2012; 

 

 

A number of Scoping Reports set out and updated the scope of the Sustainability Appraisal 

(see Table 3 and Appendix 17); and, 

the production of this Sustainability Appraisal Report. (SAR) 

1.7 This SA Report (SAR) concludes the Government requirement for a SA and the corresponding 

environmental report (ER) in respect of the SEA Regulations. It is published alongside the Council’s 

Local Plan (Publication Draft Version) pursuant to Regulation 27 of the Town and Country Planning 

(Local Development) (England) (Amendment) Regulations 2008, and prior to submission for 

examination by the Secretary of State’s appointed inspector. 

1.8 The remainder of this section describes what is covered in the main body of this document. 

Section 2 

Legal and Statutory Requirements 

1.9 This section describes the legal and statutory requirements impacting on the production of the 

Council’s Local Plan. Ensuring that all legal and statutory requirements are addressed during the 

production of this Local Plan is an important objective of the council. The main relevant legal 

instruments are: 

1 The Environmental Assessment of Plans and Programmes Regulations 2004, Statutory Instrument 2004 No. 1633, HM Government, 

London. 

2 Source: http://www.pas.gov.uk/pas/core/page.do?pageId=152497, Last accessed 26 Nov. 12 


Section 3 

Section 19(5) of the Planning and Compulsory Purchase Act 2004; 

 

 

Directive 2001/42/EC on the assessment of the effects of certain plans and programmes on 

the environment; 

The Environmental Assessment of Plans and Programmes Regulations 2004, Statutory 

Instrument 2004 No. 1633; and, 

Regulations 102, 103 and 105 of the Conservation of Habitats and Species Regulations 2010 3 , 

under which an element of the plan would have to be likely to result in a significant effect on a 

qualifying feature present on a Natura 2000 site. 

Framework and Methodology 

1.10 The methodology used in this appraisal and assessment has evolved over a period of years and is 

described within this section. The analytical framework enabled the assessment of interactions and 

likely significant environmental impacts plus the potential cumulative environmental impacts of the 

Local Plan. 

1.11 The outline originally provided of the proposed structure and contents in terms of the extent and 

depth of analysis of the ER on the assessment carried out of the new Local Plan has also evolved. 

Section 4 

Assessment of RBCs Local Plan against the SA Framework and Consideration of Alternatives 

1.12 This section describes analysis and examination of the likely fit of the proposed Local Plan in terms of 

its stated objectives and policies. This analysis is carried out within a context of higher tier goals and 

objectives set out in other policies, strategies and legislation. 

1.13 Local Plan policies and where relevant their strategic alternatives are finally introduced, however, 

readers are advised that this introduction is brief and only serves as a aide memoir for the full policy 

description contained within the Local Plan. Accordingly, this SAR and in particular Sections 4 to 16 

must be read in conjunction with the Local Plan. 

Section 5 ‐ 14 

[ER01] Natural Environment and Biodiversity 

1.14 In line with the SA Framework and Methodology described in Section 3, this SA and SEA is based upon 

as environmental receptor assessment approach. Each Local Plan policy and where relevant its 

strategic alternatives is systematically and thoroughly assessed against an environmental receptor 

identified in Table 1. Each section commences with a brief introduction to the environmental receptor 

and applicable SA/SEA objectives and factors before drawing together and considering the following: 

 

 

 

 

 

 

 

 

Current Policy Context (international to local); 

Current Baseline Condition; 

Evolution of Baseline in Absence of Plan; 

Potential Impact Pathways; 

Consideration of Policy and its Alternatives (on specific environment receptor); 

Cumulative Effect Assessment (CEA); 

Mitigation/Enhancement Recommendations; and, 

Suggested Monitoring Regime. 

1.15 The current environmental baseline of Runnymede is summarised within this section and includes 

references to the environment, economy and society by way of an existing baseline of data set against 

25 Sustainability Appraisal (SA) Objectives and 10 SEA Environmental Receptors. Where possible, 

sources of data have been constant through the appraisals and assessments. Where problems were 

encountered during its collection and compilation, surrogate data has been used. 

Section 15 

Cumulative & Synergistic Effect Assessment 

1.16 The CEAs made in Sections 5 – 15 are summarised in Section 15 and detail the consideration given 

towards identifying and assessing the significance of a number of combined impacts from multiple 

programmes and strategies across a number of proximities to the receptor. Where appropriate it 

includes an appraisal of other development / transport plans, e.g. the spatial/transport plans of 

neighbouring authorities that may act in combination with the Local Plan. 

3 http://www.legislation.gov.uk/uksi/2010/490/regulation/1/made. Last accessed 26 Nov. 12 


Section 16 

Conclusions 

1.17 This section presents an overall conclusion of the ability of the Local Plan to contribute to the 

achievement of sustainable development. It concludes both the SA and SEA. 

Section 18 

Data Uncertainty and Risks 

1.18 This section presents how data uncertainty and risks are handled within this SAR. 

Section 19 

Plan Uncertainty and Risks 

1.19 This section presents how plan uncertainty and risks are handled within this SAR. 

Section 20 

Monitoring 

1.20 Monitoring is considered an integral component of the SEA Directive. This section summarises the 

requirements and methods described in Sections 5 – 15 and will form the basis to be employed as part 

of the Council’s monitoring regime for the SEA and Local Plan. 

Section 21 

Next Stages 

1.21 This section describes the next stages in the development of the Local Plan and its accompanying SAR. 



Section 2. 

Legal and Statutory Requirements 

Legal Requirement for a Sustainability Appraisal (SA) 

2.1 The concept of sustainable development is commonly defined by what has become known as the 

‘Brundtland Report Definition’ ( 4) : 

“…development that meets the needs of the present without compromising 

the ability of future generations to meet their own needs”. 

2.2 The Government’s strategy, ‘Securing the future – delivering UK sustainable development strategy’ 

(2005) identified five principles that focus explicitly on environmental limits and four priorities 

necessary to achieve sustainable development. The principles are presented in Figure 1 ‐ UK 

Governments Guiding Sustainable Development Principles below and the four priorities are; 

 

 

 

 

Sustainable Consumption and Production; 

Climate Change and Energy; 

Natural Resource Protection and Environmental Enhancement; and, 

Sustainable Communities. 

Figure 1 ‐ UK Governments Guiding Sustainable Development Principles 

2.3 These principles and priorities were translated into the Regional Sustainability Frameworks (RSF) which 

set the context for sustainable development in the region of the South East of England within which the 

Borough of Runnymede is located. The Council aligned itself to the South East of England RSF [ 5] 

objectives for the purposes of SA assessments’ as well as providing a framework for its baseline 

monitoring. Following the announcement of the Government’s abolition of the Regional Assemblies 

and the publication of the Localism Bill at the end of 2010, the Council is in the process to replace the 

RSF. In the interim it will continue to use the RSF as the framework for carrying out SAs. 

2.4 The requirements of S.39 (2) of the Planning and Compulsory Purchase Act 2004 (P&CP Act 2004) make 

the achievement of sustainable development central to previous reforms of the planning system. The 

purpose of SA was a mandatory legal requirement under S.19 (5)(a) and (b) of the same Act. The P&CP 

Act’s intention has been to promote sustainable development through the integration of social, 

environmental and economic considerations into the preparation and revisions of DPD and SPD 

through a five stage process as outlined in Figure 2 ‐ Five‐stage approach to Sustainability Appraisal 

below. The Council’s LDF was caught by the requirements of this act and it follows that components 

such as the Local Plan are also subjected to the same rigor. 

4 World Commission on Environment and Development (1987). “Our Common Future”. Oxford University Press. 

5 

The South East Regional Sustainability Framework: Towards a Better Quality of Life, SEERA, 2008 [originally available from: 

http://www.southeast‐ra.gov.uk/sustainability_rsf.html] 


Figure 2 ‐ Five‐stage approach to Sustainability Appraisal 

Stage A 

Assemble the evidence base to inform the 

appraisal. 

Establish the framework for undertaking 

the appraisal (in the form of Sustainability 

objectives). 

Scoping 

Report 

Stage B 

Appraise the plan objectives, options 

and preferred options/policies against 

the framework taking into account the 

evidence base. 

Propose mitigation measures for 

alleviating the plan’s adverse effects 

as well as indicators for monitoring the 

plans sustainability. 

Stage C 

Prepare a sustainability appraisal 

report documenting the appraisal 

process and findings 

Sustainability 

Appraisal Report 

(SAR) 

Stage D 

Consult stakeholders on the plan and 

SA Report 

Stage E 

Monitor the implementation of the plan 

(including its sustainability effects.) 

LP 

Monitoring 

Report (AMR) 

2.5 The link from SA to SEA is provided by S.39 of the P&CP Act 2004 by the fact that it ‘requires planning 

bodies, in preparing plans, to contribute to the achievement of sustainable development’ thus directly 

replicating the explicit duty expressed in Article 1 of the SEA Directive. This is achieved by ensuring the 

plan‐making process enables objectives and their resulting implementation to be clearly defined and 

assessed in terms of sustainability during the production of the plan. For this reason, the objectives of 

SA and SEA are considered mutual. 

Legal Requirement for Strategic Environmental Assessment (SEA) 

2.6 The legal authority for SEA to be carried out on the Local Plan derives from the SEA Directive ( 6) . The SEA 

Directive requires the systematic assessment and evaluation to be carried out of likely significant 

6 

Directive 2001/42/EC on the assessment of the effects of certain plans and programmes on the environment(http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2001:197:0030:0037:EN:PDF 

). The Environmental Assessment of Plans and Programmes 

Regulations 2004, Statutory Instrument 2004 No. 1633, HM Government, London. 


effects on the environment of certain plans and programmes and the findings taken into account in the 

decision making process. Under the European Communities Act 1972 (7) , the requirements of the SEA 

Directive are transposed into UK law in England in 2004 by virtue of the Environmental Assessment of 

Plans and Programmes Regulation 2004 (SEA Regulations) ( 8) . 

2.7 Where an SEA is required under the Regulations, the authority responsible for the production of the 

plan must follow a specified procedure during its preparation. A major deliverable of this procedure is 

the production of the ER. The ER must be prepared which examines likely significant effects of the 

proposed plan, programme or strategy, including reasonable alternatives, as well as the information 

listed in Schedule 2 to the Regulations and Annex I of the SEA Directive. 

2.8 SEA is not defined in law, however, the full requirements of an environmental assessment under the 

SEA Directive are summarised in Box 1 below. The SEA process is frequently quoted as being: 

‘the formal, systematic and comprehensive process of evaluating the effects 

of a proposed policy, plan or programme or its alternatives, including the 

written report on the findings of that evaluation, and using the findings in 

publicly accountable decision making’. 

2.9 In order to avoid duplication of effort between the various assessment processes ( 9) work carried out in 

completing this SA Report for the Local Plan will not be replicated in subsequent RBC LDF DPDs or SPDs. 

2.10 The Council’s Local Plan and its accompanying SA Report incorporate the SEA ER. As required by the 

regulations, the SA Report is being made available in two formats ‐ a full report which includes 

technical appraisal and assessment detail, and a non‐technical summary (NTS). Both consider the 

following: 

 

 

 

 

 

A description of the plan and analysis of its relationship with other relevant plans and 

programmes, and an outline of the alternatives to the proposed plan that will be subjected to 

an assessment in parallel to the plan to enable the comparative analysis of its impact on the 

environment; 

A description of the current state of the environment in the area covered by the Local Plan, 

including aspects that are likely to be significantly affected and any relevant existing 

environmental problems, and an analysis of its likely future condition in the absence of the 

proposed plan. 

Description and assessment of the likely significant effects of the proposed plan on the 

following SEA Directive Factors. For the purposes of this assessment, the factors have been 

modified to facilitate a source‐pathway‐receptor method of assessment. The resulting 

modification is outlined in Table 1 – SEA Factors. 

The effects of the plan will be described and assessed in terms of their duration (short, 

medium or long term, and permanent or temporary), their consequence (beneficial or 

adverse), their status (direct, indirect or induced) and their capacity to contribute to 

cumulative and synergistic impacts. Summaries of these assessments are presented in table 

form. 

Description of measures that could be taken to prevent, minimise or compensate for any 

significant adverse effects that the proposed plan is expected to have on the environment, 

and of the steps that should be taken to monitor and report on the actual environmental 

performance of the plan when it is implemented. 

7 The European Communities Act 1972 (c. 68) 

8 The Environmental Assessment of Plans and Programmes Regulations 2004, Statutory Instrument 2004 No. 1633, HM Government, 

London. 

9 Article 4(3) of the SEA Directive makes explicit reference to avoiding duplication of assessment where a plan or programme forms part of a 

hierarchy as is the case with the RBC SCS and its CS DPD. 


Table 1 – SEA Factors 

SEA Directive Factor 

SEA Environmental Receptor 

biodiversity [ER01] Natural Environment and Biodiversity 

population [ER02] Welfare, Health and Well‐being 

human health [ER02] Welfare, Health and Well‐being 

fauna [ER01] Natural Environment and Biodiversity 

flora [ER01] Natural Environment and Biodiversity 

soil [ER03] Land and Soil Resources 

water [ER04] Water Resources and Management 

air [ER05] Air Quality 

climatic factors [ER06] Climate Change 

material assets [ER07] Materials Efficiency and Waste 

[ER08] Built Environment 

 

cultural heritage including architectural and 

archaeological heritage 

 

[ER09] Historic Environment and 

Archaeology 

landscape [ER10] Landscape and Visual Amenity 

 

and the interrelationship between the above 

factors 

Sustainable Community Strategy and Local Development Frameworks 

 

[ER11] Cumulative Effect Assessment 

2.11 The Local Plan must have regard to any Sustainable Community Strategy (SCS) for its area. The Borough 

of Runnymede is covered by two such strategies; ‘Surrey Strategic Partnership Plan – Standing Up For 

Surrey’ (2010) 10 and Runnymede’s Sustainable Community Strategy ‐ A Vision for Runnymede (2012) 11 . 

2.12 The purpose of the SCS 2012, is stated as being: 

"The key objective of this document is to build on the success of Runnymede 

in the next few years and to describe how we will meet the challenges facing 

us." 

2.13 Effectively, the SCS tells the ‘story of the place’ – the distinctive vision and ambition of the area, backed 

by clear evidence and analysis. It follows that a SCS should contain the following elements: 

 

 

the long‐term high level vision based firmly on local future needs – this will be underpinned by 

a shared evidence base informed by community aspirations 

key priorities for the local area, based upon this vision which may realistically be achieved in 

the medium term. 

2.14 It also provides a policy steer and outline for which the cooperation of other levels of planning 

processes both above and below it is required, such as: 

 

 

strategies at a higher geographic level, such as sub‐regional plans, multi‐area agreements 

(MAAs), or plans originating from the newly formed Local Enterprise Partnerships (LEPs); and, 

Lower tier plans such as this ‘Local Plan’ for the local development framework – the spatial 

and land use plan for the area. 

2.15 The SCS 2012 sets the strategic direction and long‐term vision for the Local Plan, by reference to its 

principle aim of: 

"To create a better place to live, with the local services that our citizens need 

and expect, in a borough that is fit for the 21st century.” 

10 http://www.surreycc.gov.uk/your‐council/how‐the‐council‐works/council‐policies‐and‐strategies/surrey‐strategic‐partnershipssp/surrey‐strategic‐partnership‐plan‐standing‐up‐for‐surrey 

11 http://www.runnymede.gov.uk/portal/site/runnymede/Making_a_difference/ 


Box 1 ‐ Elements of an Environmental Assessment under the SEA Directive (2001/42/EC) 

Preparation of an environmental report in which the likely significant effects on the environment of 

implementing the plan or programme, and reasonable alternatives taking into account the objectives and 

geographical scope of the plan, are identified, described and evaluated (Art. 3). The information to be given is 

(Art. 5 and Annex I): 

 

 

 

 

 

 

 

 

an outline of the contents, main objectives of the plan, and relationship with other relevant plans and programmes; 

the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of 

the plan or programme; 

the environmental characteristics of areas likely to be significantly affected; 

any existing environmental problems which are relevant to the plan including, in particular, those relating to any areas 

of a particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC and 92/43/EEC; 

the environmental protection objectives, established at international, Community or national level, which are relevant 

to the plan and the way those objectives and any environmental considerations have been taken into account during its 

preparation; 

the likely significant effects on the environment, including on issues such as biodiversity, population, human health, 

fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological 

heritage, landscape and the interrelationship between the above factors (these effects should include secondary, 

cumulative, synergistic, short, medium and long‐term, permanent and temporary, positive and negative impacts); 

the measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the 

environment of implementing the plan; 

an outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was 

undertaken including any difficulties (such as technical deficiencies or lack of know‐how) encountered in compiling the 

required information; 

a description of the measures envisaged concerning monitoring in accordance with Art. 10; 

 

a non‐technical summary of the information provided under the above headings. 

The report shall include the information that may reasonably be required taking into account current 

knowledge and methods of assessment, the contents and level of detail in the plan, its stage in the decisionmaking 

process and the extent to which certain matters are more appropriately assessed at different levels in 

that process in order to avoid duplication of the assessment (Art. 5.2) 

Consultation: 

 

 

 

authorities with environmental responsibilities. when deciding on the scope and level of detail of the information which 

must be included in the environmental report (Art. 5.4) 

authorities with environmental responsibilities and the public, which shall be given an early and effective opportunity 

within appropriate time frames to express their opinion on the draft plan and the accompanying environmental report 

before the adoption of the plan (Art. 6.1, 6.2) 

other EU Member States where the implementation of the plan is considered likely to have significant effects on the 

environment of those States (Art. 7) 

The environmental report and consultations must be taken into account in decision‐making (Art. 8) 

Provision of information on the decision (Art. 9): 

When the plan is adopted, the public and any EU Member State consulted under Art.7 shall be informed and 

the following items made available to those so informed: 

 

 

the plan or programme as adopted 

a statement summarising how environmental considerations have been integrated into the plan and how the 

environmental report of Article 5, the opinions expressed pursuant to Article 6 and the results of consultations entered 

into pursuant to Art. 7 have been taken into account in accordance with Art. 8, and the reasons for choosing the plan as 

adopted, in the light of the other reasonable alternatives dealt with; and, 

the measures decided concerning monitoring (Art. 9) 

Monitoring of the significant environmental effects of the plan’s implementation (Art. 10) 

Quality assurance: environmental reports should be of a sufficient standard to meet the requirements of the 

SEA Directive (Art. 12.2) 

Original source: 

http://www.communities.gov.uk/documents/planningandbuilding/pdf/summaryrequirementssea.pdf 


National Planning Policy Framework (NPPF 2012) 

2.16 Since the Council suspended production of its draft Core Strategy in 14 July 2010, and recommenced 

production with this Local Plan on the 22 February 2012, the National Planning Policy Framework 

(NPPF) was published in England on 27 March 2012. It gives a clear indication of the Government’s 

direction of travel and is a material consideration in terms of planning policy and decision making. 

2.17 The NPPF has resulted in the withdrawal of almost all Planning Policy Statements (PPS) and Planning 

Policy Guidance (PPGs). A list of withdrawn planning guidance is contained in Annex 3 of the document 

and replicated in Appendix 1 of this SAR. 

2.18 A significant component has been the “presumption in favour of sustainable development” 12 . This is 

taken to mean that development proposals should ordinarily be approved promptly unless they would 

compromise key sustainable development principles as set out in the Framework. 

2.19 The NPPF directs Local Plans to plan positively for development, looking ahead to a 15 year time 

horizon. Planning authorities should ensure that there is a rolling five year (+ 5% to 20%) housing land 

supply and a clear idea of where land for housing is going to be provided in years 6‐15. 

2.20 The NPPF places a clear emphasis on increasing the supply of housing across the country, whilst 

protecting local environmental assets and Green Belt boundaries plus designated environmental areas. 

2.21 There is also a continuing requirement for Sustainability Appraisal under the new NPPF; 

“A sustainability appraisal which meets the requirements of the European 

Directive on strategic environmental assessment should be an integral part of 

the plan preparation process, and should consider all the likely significant 

effects on the environment, economic and social factors.” 13 . 

Regional Spatial Strategy – South East Plan (SEP 2006 ‐ 2026) 

2.22 The South East Plan is the Regional Spatial Strategy for the South East of England and replaced the 

Surrey Structure Plan 2004. It is Government’s policy intention to revoke all existing regional strategies 

outside London subject to the outcome of the SEA. The weight that can be giving to any policies within 

the SEP 2006 – 2026 as a material consideration in decision making depends on their consistency with 

the NPPF. 

Incorporating the Requirements of SEA into the SAR 

2.23 The purpose of SA is clearly to ensure that the principles of sustainable development are fully taken 

into account when preparing relevant plans such as the Runnymede Local Plan. The SA identifies and 

reports inter alia on the extent to which implementation of the plan will achieve the social, 

environmental and economic objectives of sustainable development. The main objective is to ensure 

that the process integrates sustainability objectives into plan making, in order to produce better, more 

sustainable plans as a result. Ultimately, this objective must encapsulate the principle of embedding 

the delivery of sustainable development into the organisational culture that will consider future 

development projects against the Local Plan policies. This SA Report catalogues how these objectives 

are met in this particular case. 

2.24 SEA Regulations, on the other hand require the production of an Environmental Report (ER) on the 

likely significant effects the Local Plan might have on a number of environmental factors that are 

presented in Table 1 above. Each factor has been paired to a related receptor, and each receptor has a 

dedicated chapter set out against the framework described in Table 2. 

12 See paragraph 11 of the National Planning Policy Framework, (accessed on 05/04/2012 from: 

http://www.communities.gov.uk/publications/planningandbuilding/nppf ) 

13 See paragraph 165 of the National Planning Policy Framework, accessed on 05/04/2012 from: 

http://www.communities.gov.uk/publications/planningandbuilding/nppf ) 


Table 2 – Assessment Chapter Components 

Chapter 

Component 

Introduction 

Current policy 

context 

Current baseline 

condition 

Evolution of 

baseline in 

absence of plan 

Potential Impact 

Pathways 

Implications of 

the new LP on 

receptors and 

objectives 

Description 

This section introduces the receptor with a brief definition and overview of the 

range of issues which are considered. It also outlines the identified Impact 

pathways which were identified during scoping and preliminary appraisals and 

assessments. 

This takes account of relevant policies that inform the plan covering international to 

local levels. They have been assembled from various Scoping and preliminary 

assessment Reports and Core Strategy / Local Plan Evidence Papers. Saved 

planning policies including other relevant Council policies are also identified. 

This section details the key baseline sustainability and environmental issues 

identified during scoping and preliminary appraisals and assessments. It includes 

any updated baseline information, including the Core Strategy / Local Plan Evidence 

Papers. 

This section reports on the ‘business as usual scenario’, as required in the ODPM SA 

Guidance 14 . The effect of the saved planning policies (and any other relevant 

Council policies) are considered in terms of how they will affect the future receptor 

condition – this is usually a declining effect, as policies become out of date and are 

replaced. 

Identifying impact pathways are critical to both the assessment and later monitoring 

of the plan. 

This section assesses the potential impact the various policies including reasonable 

alternatives will have on SEA receptors and SA objectives, as identified in the matrix 

in the methodology section. A basic table is used to present this information, using 

the following key, as set out below and described in Table 8: 

Significant 

Beneficial 

Beneficial Mixed Neutral Uncertain Adverse 

Significant 

Adverse 

/ 0 ? 

Cumulative impact 

Assessment 

Mitigation and/or 

Enhancement 

Recommendations 

A suggested 

monitoring 

regime. 

This section identifies and assesses the significance of combined impacts from 

multiple programmes and strategies that can act cumulatively with the Plan on this 

receptor. 

This section records the changes required to mitigate and enhance effects. This 

approach ensures that the ’whole plan’ assessment does not miss some of the 

subtleties that in-depth policy appraisal allows, without replicating the disjointed 

assessment that results from considering policies in silos. 

This section suggests a means of monitoring those policies that have an impact on 

the SEA receptor and SA objective(s). 

2.25 The findings and conclusions of the assessments of policies and reasonable alternatives of the Local 

Plan and considered in Sections 4‐14 of this SAR are summarised in Section 16. 

2.26 SEA findings are incorporated into this SAR in the form of an environmental receptor layout. These are 

used to inform relevant considerations and conclusions of the SA. Habitats Regulations Assessment 

(HRA) is considered below. 

Consideration of the Habitats Regulations 

2.27 In order for a HRA to be triggered pursuant to Regulations 102, 103 and 105 of the Conservation of 

Habitats and Species Regulations 2010, element(s) of the Local Plan would have to be screened as 

being likely to result in a significant effect on a qualifying feature present on a European site 15 if 

implemented. 

2.28 In August 2012, following the conclusions of a pre‐screening exercise and full screening assessment, 

against the requirements of the Conservation of Habitats and Species Regulations 2010, and in 

consultation with Natural England, Officers concluded that policies LP01, LP02 and LP08 triggered the 

14 Para 2.3.11 indent 1 of “Sustainability Appraisal of Regional Spatial Strategies and Local Development Documents – Guidance for Regional 

Planning Bodies and Local Planning Authorities. ODPM, 2005. 

15 European site is defined by Article 3 of the Habitats Directive referring to Natura 2000 site and Regulation. 8 of the 2010 Regulations with 

refers to these sites as “European sites” ‐ from here on reference made to European sites will be taken to cover all applicable sites. 


equirement for a HRA. At the same time the Council considered that the Local Plan was not directly 

connected with or necessary to the management of any of the potentially affected European Site’s 

nature conservation objectives. 

2.29 The HRA requirement was triggered in LP01 and LP02 by virtue of LP08 – DERA. The redevelopment of 

DERA (LP08) is being promoted by a team lead by Crest Nicholson Ltd (Crest). Crest has been working 

with the Council in the assembly and production of the data used to support this policy, including the 

information for the HRA. HRA data was made available to the Council on 17 October 2012 and relied 

upon information within an Environmental Statement for a planning application (RU.12/1120) for the 

DERA North Site that was registered (therefore made public) on the 31 October 2012. 

2.30 In consultation with Natural England, officers carried out an initial review to consider the technical 

adequacy of the information and data submitted to the Council in support its HRA and its appropriate 

assessment. This review determined that at this time a conclusion of ‘no likely adverse affect on the 

integrity of either TBH Special Protection Area (SPA) or TAP&C Special Area of Conservation (SAC) as a 

result of implementing Local Plan policies LP01, LP02 and LP08’ could not be supported. 

2.31 Following a request for further information and data was issued on the 14 November 2012; the Council 

was able to conclude its Level 6 HRA assessment. It felt that with sufficient evidence was provided to 

enable it to ascertain no adverse affect on the integrity of either Thames Basin Heaths SPA or Thursley, 

Ash, Pirbright and Chobham SAC as a result of the implementation of the Local. The Level 6 HRA Report 

is presented in Appendices 8 and 9. 

Summary of SA/SEA Consultation, Appraisal and Assessment to Date 

2.32 Both SA and SEA scoping consultations commenced in 2005 and concluded with an issue of a Draft SEA 

Scoping Report for the Council’s SCS in April 2011. The SA scoping consultations considered social and 

economic effects and the environmental effects pursuant to the SEA of Local Plan policies and their 

alternatives. In addition, the SA is considered representative of the relationship between the Local Plan 

and the principles of the Government’s Sustainable Development Strategy. 

2.33 The evolution of the Local Plan and its likely effects on the sustainability of the Borough and key 

environmental receptors were predicted and evaluated through the SA/SEA. Extensive consultation on 

the scope of the SAR occurred and is presented in Table 3 . This same Table summarises how the 

SA/SEA process affected the development of the Plan. 

Table 3 – SA/SEA Timeline and Effect on Plan 

Date Key stage in SA/SEA Effect on Plan 

Apr 2005 Consultation carried out on the Combined Draft Scoping Report of 

the Core Strategy, Housing DPD, and Development Control DPD a 

summary of the consultation is included at Appendix 17. 

 

Core Strategy objectives compared to sustainability objectives to 

see how compatible they are. 

Jun 2005 Adopted the Combined Scoping Report for the Sustainability 

Appraisal and Environmental Assessment 

Sept 2005 Version of Plan was considered to have possible significant negative 

impacts on flood risk, resource consumption, climate change, 

biodiversity on derelict land, and infrastructural capacity. 

Dec 2005 Plan is identified as having the potential to have or likely to have 

significant negative impacts on UK and EU protected biodiversity 

sites, risk to people if a flood occurs, sustainable resource 

consumption, biodiversity on derelict land sites and cumulative 

impacts of transport on pollution on climate change. 

Difficult to assess the effect 

these early consultations had on 

the evolution of the plan, other 

than to say that they informed a 

common baseline. 

Noted. 

Set common baseline. 

Noted. 

Changes made. 

 

Area profiles assessed for most and least sustainable areas based 

on a number of criteria 

Most sustainable areas used. 

Jan 2006 SA for Core Strategy Core Strategy stalled. 

Feb 2006 Screening opinions required on all EU and UK protected nature 

conservation sites to determine impact of plan prior to submission. 

To be advised prior to 

submission. 

Nov 2008 Scoping Report for the SA and SEA issued Document issued – revised 

baseline. 

May 2009 Sustainability Progress Report issued. Noted. 


Date Key stage in SA/SEA Effect on Plan 

http://ww2.runnymede.gov.uk/business/ImpactAssess/site/SA%20SEA% 

20PROGRESS%20REPORT.ASP 

Apr 2011 Updated SEA Scoping Report for the SCS Update SAR Scope 

Aug 2012 SEA and SA Review – Chosen Policies and Alternatives 

2.34 The SA/SEA has been carried out be a team of Council Officers lead by the Council’s Senior Impact 

Assessment Officer and presented in Table 4. 

Table 4 – SAR Team Members 

Officer 

Relevant Education and 

Qualifications 

Job Title 

SAR Work Function 

John Willmott- 

French 

BA Architecture (First Class Honours) 

MSc Risk Analysis 

MRTPI 

MIEMA 

PRINCE2 Practitioner 

Senior Impact 

Assessment Officer 

Over Project Management of 

the SAR 

Karen Merredew 

BA Politics and Sociology 

AIEMA 

Impact Assessment 

Officer 

Assessment Coordinator 

Anna Czerska 

BSc Environmental Studies 

MSc Environmental Technology 

Air Quality Officer 

Assessment Team Member 

Lucy Hawkings BSc Environmental Services Contaminated Land 

Officer 

Assessment Team Member 

Jane Peberdy 

BSc(Hons) 

Dip Town Planning 

MRTPI 

Planning Policy 

Officer 

Assessment Team Member / 

Policy Team Member 

Cheryl Brown 

MA Planning Policy and Practice 

(expected to complete Jan 2013) 


Officer 



Babatunde Adebutu 

BA 

MA 


Officer 



Bob Etheridge 

BSc (Hons) 

MRTPI 

MBA 

Policy & 

Implementation 

Manager 



Richard Ford 

BA (Hons) 

MRTPI 


Team Leader 


Policy Team Lead 



Section 3. 

Introduction 

Framework and Methodology 

3.1 The following chapter describes the methodology used to carry out the SA and assess likely significant 

effects resulting from the implementation of the Local Plan. In line with Government Guidance 16 the 

assessment methodology integrates both the SA appraisal and SEA impact assessment to function 

within a hierarchy of assessments. The Council has refined this assessment hierarchy into a six level 

assessment procedure ranging from basic Level 1 – pre‐screening assessment to the highly detailed 

Level 6 – feature level assessments ( 17) . 

3.2 The SA framework methodology used for the appraisal and monitoring implementation of the Local 

Plan is based on a number of sustainability objectives aligned originally to the Integrated Regional 

Framework. (18) These were realigned following an update in 2008 to the Regional Strategic Framework 

(RSF) which is available at Appendix 6. Current sustainability objectives and their current condition are 

listed in Table 5 below. 

3.3 Sustainability objectives describe different aspects of concept of sustainability. The overriding 

presumption is that together when met, the result will be a sustainable borough. Obviously, it would 

be difficult for Runnymede to be sustainable in an otherwise un‐sustainable world. To this end some 

objectives appear more compatible with the locally specific conditions found in Runnymede than 

others. All however generally promote the goal of sustainable development, and an expected strong 

compatibility was found between sustainability objectives and SEA Factors and is presented in Figure 4. 

For this reason, it is reasonable to use relevant assessments across SA and SEA frameworks. 

3.4 However, the RSF was developed, updated and reviewed by the now abolished South East of England 

Regional Assembly (SEERA). Following the Government’s decision to abolish SEERA, the Council has had 

to commence work to replace the RSF in the form of a Local Sustainability Framework (LSF) which will 

incorporate a set of Sustainable Development Indicators and will be consulting on the shape of this 

replacement in the near future. Until the Council adopts its new LSF, it makes prudent sense to 

continue to use the RSF to continue to provide the sustainability framework with which to appraise 

relevant Council plans. It is also noted that the Government has recently launched a consultation on a 

new set of ‘Sustainable Development Indicators’ 19 , the outcome of this consultation will be monitored 

for similarity. 

3.5 Whilst neither the SEA Directive nor the SEA Regulations prescribe who is to carry out an SEA, it is 

normally a task of the Responsible Authority who is preparing and/or adopting a plan or programme 

such as the Local Plan. However, paragraph 2.21 of the Government’s guidance on SEA suggests that 12 : 

“Good practice emphasises the value of integrating the assessment with the plan‐ or 

programme‐making process. Many benefits of SEA may be lost if it is carried out as a 

completely separate work‐stream or by a separate body…” 

3.6 The Council adopted this good practice and developed its own in‐house team with the capacity to carry 

out both SA and SEA. All assessments of policy effects 20 have been carried out by members of the 

Impact Assessment, Policy and Environmental Health (Contaminated Land and Air Quality Officers) 

teams using a semi‐controlled ‘blind’ evaluation technique. The whole process has been overseen by 

the Council’s Senior Impact Assessment Officer. By doing so it ensured the concept of 

integrating/embedding sustainable development and environmental impact assessment into the plan 

making process has been achieved. This SA Report has been produced by the Council’s in house Impact 

Assessment Team. 

Level 1 Assessment – Pre‐Screening 

16 

ODPM et al. (2005) A Practical Guide to the Strategic Environmental Assessment Directive 

17 Level 6 assessments are carried out pursuant to Regulation 61 and 102 of the Conservation of Habitats and Species Regulations 2010 

depending on whether a plan or projects are being considered. 

18 

The Integrated Regional Framework (IRF) that sets the context for sustainable development in the South East of England: 

http://www.southeast‐ra.gov.uk/our_work/planning/sus_dev/irf.html. (no longer available) 

19 http://www.defra.gov.uk/consult/2012/07/24/sus‐dev‐indicators/ 

20 See Appendix 1 for standardised definition of effects 


3.7 All Local Plan policies have been subjected to a Level 1 pre‐screen. This was a basic officer assessment 

of potential legislative triggers and interactions, and assumed that all other policy objectives were 

realised. Level 1 Pre‐Screening Assessments were by their nature ‘quick’, and only intended to provide 

a focus for subsequent more detailed screening and scoping assessments. These early results were 

discussed with the policy team via a series of internal meetings that took place during the early 

evolution of the Local Plan. 

Level 2 Assessment – Impact Identification (Screening and Scoping) 

3.8 A more detailed Level 2 Screening and Scoping assessment was triggered as a result of the Level 1 Pre‐ 

Screening work. This identified relevant sustainability objectives that could be realised from the plan as 

well as those policies likely to have significant effects 21 on environmental receptors as a result of 

implementation of the plan. Again as with Level 1 the assumption is based on the assumption that all 

relevant objectives of the plan are met. It included recommendations for the plan to be modified to 

ensure greater positive relevancy to SA objectives and what other assessments might be required and 

were discussed with the policy team via a series of internal meetings. 

3.9 The output of a Level 2 Screening and Scoping assessment included an Impact Assessment Matrix (IAM) 

for each of the impacts and/or effects identified. These outputs informed the subsequent L3 to L6 

assessments contained within Appendix 2 and summarised in Appendices 3 and 4. This assessment 

included a brief description of the anticipated effect. In addition, cumulative effects were identified 

and briefly described. The conclusion and output of the Level 2 assessments resulted in the production 

and consultation of a number of draft Scoping Reports during the period 2005 – 2011 and are detailed 

in Table 3 above. 

Level 3 Assessments – Sustainability Appraisal 

3.10 Generally this level of assessment only considered the range of impacts/effects identified, described, 

and consulted upon in previous Level 2 where they are deemed to be significantly beneficial or 

significantly adverse to the sustainability objectives of the borough. The intention has been in the case 

where significant effects were described and well understood through data and/or precedent to 

quantitatively evaluate the effect on thresholds using quantitative threshold assessments. However, 

due to a general lack of robust quantitative data and threshold targets, this method proved to be less 

used than other methods. 

3.11 The majority of effects identified were not sufficiently well understood through data to be 

quantitatively evaluated. As such a qualitative investigation was undertaken, guided by the following 

set of key questions: 

 

 

 

 

What is the anticipated effect? 

What is the evidence base? 

What assumptions have been made in determining this impact? 

Is there any precedent or literature that indicates the impact’s severity or likelihood? 

3.12 Following the outcome of these investigations which generally occurred either as a result of the 

scoping consultation or as a result of the normal update of the Council State of the Borough Report, 

recommendations were made that research was conducted to allow impact evaluation to be carried 

out. Primarily these tended to focus on Transport Impact Assessments, and Air Quality Assessments. 

However, the economic down turn has limited the Council’s ability to fund these assessments. 

3.13 Clearly, an important requirement in carrying out Level 3 assessments has been the condition of the 

baseline including its trends towards or away from the sustainability targets base on an analysis of the 

available data. Where the data was either lacking or not of a high resolution, the assessment team 

concluded the assessment based on professional judgment of the Council’s in‐house assessment team 

outlined in Table 3 above. 

3.14 Where an impact was evaluated as having a potential for a significantly negative impact on the 

sustainability of the borough, a statement recommending mitigation measures to be introduced and 

monitored has been produced. 

3.15 Where an impact was identified as not likely to either have a significant negative or positive effect, the 

impact will be monitored as part of the Runnymede State Report and or in the Annual Monitoring 

Report of the LP. 

21 What is an effect is considered against Appendix 5 


3.16 Monitoring reports will be augmented with data derived from planning applications for Environmental 

Impact Assessment (EIA) developments considered by the Council and where applicable neighbouring 

authorities. 

3.17 At all stages throughout Level 2 and Level 3 assessments where data was lacking or missing, there 

necessitated a reliance to be placed upon the professional assumptions made by the assessment team. 

Level 4 Assessments – Meeting the requirements of the SEA Directive 

3.18 An SEA assessment is an assessment of likely significant effects, where as, an SA is an appraisal against 

sustainable development objectives. As indicated above the Government believes that an integrated 

assessment framework simultaneously meets the requirements of the SEA and the SA and is thus its 

preferred method. In practice this is difficult to achieve as it requires considerable structure to be 

embedded around both processes. Specific to SEA, and in order to meet the requirements of the SEA 

Directive, each policy was subjected a series of questions related to how the policy could interact with 

the impact pathway of the relative environmental receptor, as set out in Table 6 . 

3.19 This is not to say that the requirements of SA have been overlooked, on the contrary Figure 4 – 

Compatibility between SA Objectives and SEA Factors indicates substantial compatibility between the 

SA Objectives and the SEA Factors. This table also presents the current baseline condition of the SA 

Objectives as indicated by a change in the border colour 22 . 

3.20 Experience suggests that the objectives of an emerging plan such as the Local Plan evolve over time 

rather than appearing in a precise form at the start of the process. Inevitably this lag period has to be 

accommodated within the appraisal/assessment framework. This was done by applying a process to 

consider various broad development parameters within a number of scenarios and consider predicted 

impacts where it is possible to do so. 

3.21 The preliminary phases of the Core Strategy identified the wider scope of the assessment that was 

carried out as the plan emerged. It is considered to be a preferable approach to waiting for a 

completed first draft that has its direction largely fixed. This iterative approach ensures that 

consideration is given to the plans ability to positively and negatively affect indicators and receptors. 

Together with an opportunity to identify gaps in baseline data and impact uncertainties. Where 

possible, data gaps were filled and or recommendations made for the establishment of a programme of 

work required through monitoring, further data collection or generic impact studies. This information 

will be used to refine the progression of the final SA and SEA. 

3.22 In November 2005 the Government published its guidance on the preparation of SA for LDFs and how 

this process would interface with the DPD [plan making] process. This process has recently been 

amended and captured in Figure 3 below. The Council has largely followed this process in undertaking 

the preparation of its Local Plan. 

22 Figure 4 – Compatibility between SA Objectives and SEA Factors border colour key; Red = Currently not meeting SO target, Amber = 

Uncertainty whether or not SO target can be met, and Green = SO target likely to be met. 


Figure 3 ‐ The DPD/SA Preparation Process 

DPD Process 

SA Process 

0 Pre 

Production 

Evidence Gathering 

Stage A: Setting the context, 

establishing the baseline and 

deciding on scope 

Key 

Process 

Reg 25 

Prepare issues and 

alternative options in 

consultation 

(ongoing engagement) 

Stage B: Developing and 

refining options and assessing 

effects 

Stage C: Preparing the SA 

Report 

Ongoing 

engagement 

Statutory consultation 

(6 weeks) 

Years 

1 Production 

Community involvement 

(as outlined in Part 2 Regulations) 

Reg 26 

Reg 27 

Reg 28 

Public participation on preferred 

options (statutory consultation) 

Representations on preferred 

options 

Preparation of Submission DPD 

Submission of DPD 

(statutory consultation) 

Stage D: Consulting on the 

DPD and SA Report 

Reg 29 

Representations on submitted 

DPD 

2 Examination 

Representations and 

participation in 

examination 

Pre examination meeting 

Independent Examination 

Binding Report 

3 Adoption 

Adoption and Monitoring 

Stage E: Monitoring the 

significant effects of 

implementing the DPD 


Figure 4 – Compatibility between SA Objectives and SEA Factors 

SEA 

Environmental 

Receptor 

SEA Factors 

SA Objectives 

(Relevant ER) 

(Colour Key: See Footnote) 

[ER01] Natural 

Environment & 

Biodiversity 

FA01 Biodiversity 

(8,18,19,24) 

SO 1 – Housing Provision (2,4,7,8) 

SO 2 – Health Inequality (2) 

[ER02] 

Welfare, Health 

& Well-being 

FA02 Population 

(1,3,4,5,6,7,9,10,12,13) 

SO 3 – Poverty & Social Exclusion (2) 

SO 4 – Educational Attainment (2) 

[ER03] 

Land & Soil 

Resources 

[ER04] Water 

Resources & 

Management 

FA03 Human Health 

(2,15,16,18,24) 

FA04 Fauna 

(17,19,20,24) 

FA05 Flora 

(17,19,20,24) 

SO 5 – Crime Perception (2) 

SO 6 – Community Vibrancy (2) 

SO 7 – Access to Services (2) 

SO 8 – Cultural Engagement (1,9) 

SO 9 – Employment Stabilisation (2) 

SO 10 – Economic Growth (2) 

[ER05] 

Air Quality 

FA06 Soil 

(14,22,23) 

SO 11– Economic Revival (7,8) 

SO 12 – Knowledge Based Economy (2) 

[ER06] 

Climate Change 

FA07 Water 

(1,15,18,19,22,24) 

SO 13 – Workforce Skills (2) 

SO 14 – Land & Materials Efficiency 

(3,7,8) 

[ER07] Materials 

Efficiency & 

Waste 

[ER08] Built 

Environment 

[ER09] Historic 

Environment & 

Archaeology 

[ER10] 

Landscape & 

Visual Amenity 

FA08 Air 

(16,17,19,21,22,25) 

FA09 Climatic 

Factors 

(16,17,18,19,21,25) 

FA10 Material 

Assets (1,11,14,21,23) 

FA11 Cultural 

Heritage Inc. 

Architectural & 

Archaeological 

Heritage 

(8,20) 

FA12 Landscape 

(20) 

SO 15 – Flood Risk Reduction (2,4) 

SO 16 – Air Quality Improvement (2,5,6) 

SO 17 – Climate Change Mitigation 

(1,5,6) 

SO 18 – Climate Change Adaptation 

(1,2,4,6) 

SO 19 – Biodiversity Conservation 

(1,4,5,6) 

SO 20 – Protection of the Historic 

Environment (1,9,10) 

SO 21– Transportation Efficiency 

(5,6,7,8) 

SO 22 – Resource Use Reduction 

(3,4,5) 

SO 23 – Waste Management (3,7,8) 

SO 24 – Water Quality (1,2,4,7,8) 

SO 25 – Energy Efficiency (5,6) 

[ER11] 

Cumulative 

Effect 

Assessment 

FA13 

Interrelationship 

between factors 

Footnote: Current condition relates to the potential for this SO’s target to be met, and is defined by the colour key representing an analysis of this 

target reaching its potential; 

Red = Currently not meeting SO target Amber = Uncertainty whether or not SO target can be met Green = SO target likely to be met 


Table 5 – SA Objectives and Current Condition 

RSF# 

(SO#) 

RSF Sustainability Objective 

Current 

Condition 23 

1 ‘To ensure that everyone has the opportunity to live in a decent, sustainably constructed and 

affordable home suitable to their need’ 

2 ‘To improve the health and well being of the population and reduce inequalities in health’ G 

R 

3 ‘To reduce poverty and social exclusion and, by improving their performance, close the gap 

between the most deprived areas in the borough and the rest of the region’ 

A 

4 ‘To raise educational achievement levels across the borough and develop opportunities for 

everyone to acquire the skills needed to find and remain in work’ 

5 ‘To reduce crime and perceptions of disorder’ G 

G 

6 ‘To create and sustain vibrant communities which recognise the needs and contributions of all 

individuals’ 

7 ‘To improve accessibility to all services and facilities including the countryside and the historic 

environment’ 

8 ‘To encourage increased engagement in cultural activity across all sections of the community in 

Runnymede and promote sustainable tourism’ 

9 ‘To ensure high and stable levels of employment so everyone can benefit from the economic 

growth of the borough’ 

A 

G 

A 

G 

10 ‘To sustain economic growth and competitiveness across the borough by focusing on the 

principles of smart growth: raising levels of enterprise, productivity and economic activity’ 

11 ‘To stimulate economic revival in deprived areas’ A 

G 

12 ‘To develop a dynamic, diverse and knowledge based economy that excels in innovation with 

higher value impact activities’ 

13 ‘To develop and maintain a skilled workforce to support long‐term competitiveness of the borough 

and region’ 

14 ‘To improve efficiency in land use through the appropriate re‐use of previously developed land 

and existing buildings – including re‐use of materials from buildings – and encourage urban 

renaissance’ 

G 

G 

G 

15 ‘To reduce the risk of flooding and the resulting detriment to public well‐being, the economy and 

the environment’ 

16 ‘To improve air quality and ensure it continues to improve’ R 

17 ‘To address the causes of climate change through reducing emissions of greenhouse gases’ R 

18 ‘Ensure that Runnymede is prepared for the impacts of climate change’ R 

19 ‘To conserve and enhance the boroughs and region’s biodiversity’ A 

20 ‘To protect and enhance the borough’s countryside and historic environment’ G 

R 

21 ‘To improve the efficiency of transport networks by enhancing the proportion of travel by 

sustainable modes and by promoting policies which reduce the need to travel’ 

A 

22 ‘To reduce the global social and environmental impact of consumption of resources by using 

sustainably and ethically produced, local or low impact products’ 

23 ‘To reduce waste generation and disposal, and achieve the sustainable management of waste’ G 

G 

24 ‘To maintain and improve the water quality of the borough’s and region’s rivers, ground waters 

and coasts , and achieve sustainable water resources management’ 

25 ‘To increase energy efficiency, security and diversity of supply and the proportion of energy 

generated from renewable sources in the borough and region’ 

A 

A 

23 

Current condition relates to the potential for this SO’s target to be met. The colour key is represented by an analysis of this target 

reaching potential: Red = Currently not meeting SO target; Amber = Uncertainty whether or not SO target can be met; and Green = SO 

target likely to be met. 


Table 6 – Meeting the requirements of the Strategic Environmental Assessment Directive 

Key requirements of the SEA Directive (the ‘environmental report’ must 

include…) 

“an outline of the contents, main objectives of the plan or programme and 

relationship with other relevant plans and programmes” (Annex 1(a))[emphasis added] 

“an outline of the contents, main objectives of the plan or programme and relationship 

with other relevant plans and programmes “(Annex 1(a))[emphasis added] 

“the environmental protection objectives, established at international, Community or 

Member State level, which are relevant to the plan or programme and the way those 

objectives and any environmental considerations have been taken into account during 

its preparation;” (Annex I(e))[emphasis added] 

“the relevant aspects of the current state of the environment and the likely evolution 

thereof without implementation of the plan or programme;” (Annex I(b))[emphasis 

added] 

“ the environmental characteristics of areas likely to be significantly affected;” 

(Annex I(c)) [emphasis added] 

“ 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 and 

92/43/EEC;” (Annex I(d)) [emphasis added] 

“the relevant aspects of the current state of the environment and the likely evolution 

thereof without implementation of the plan or programme;” (Annex I(b))[emphasis 

added] 

“the likely significant effects(1)_ on the environment, including on issues such as 

biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, 

material assets, cultural heritage including architectural and archaeological heritage, 

landscape and the interrelationship between the above factors;”(Annex I(f))[emphasis 

added] 

“(1) these effects should include secondary, cumulative, synergistic, short, medium and 

long‐term permanent and temporary, positive and negative effects”(Annex I(f) 

footnote) [emphasis added]. 

“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;”(Annex I(g)) [emphasis added] 

“an outline of the reasons for selecting the alternatives dealt with, and a description of 

how the assessment was undertaken including any difficulties (such as technical 

deficiencies or lack of know‐how) encountered in compiling the required 

information;”(Annex I(g)) [emphasis added] 

“an outline of the reasons for selecting the alternatives dealt with, and a description of 

how the assessment was undertaken including any difficulties (such as technical 

deficiencies or lack of know‐how) encountered in compiling the required 

information;”(Annex I(g)) [emphasis added] 

“a description of the measures envisaged concerning monitoring…”(Annex 

I(i))[emphasis added] 

“a non‐technical summary of the information provided under the above 

headings.”(Annex I(i))[emphasis added] 

Questions for each 

policy 

What’s its objective? 

How does it fit with 

other plans or 

programmes with similar 

objectives? 

What are the key 

sustainability objectives 

that need to be 

considered? 

What is the situation 

now? 

(including any existing 

problems) 

What will the situation 

be like without the plan? 

(the ‘business‐as‐usual’ 

option) 

What will the situation 

be like with the plan? 

If significant adverse 

effects are identified, 

how are these effects 

being mitigated against? 

What alternatives were 

considered? 

How was the assessment 

carried out? 

What monitoring 

measures are being put 

in place? 

Has a Non Technical 

Summary been 

provided? 


SEA Environmental Receptor Framework 

3.23 The proposed SEA framework is in line with what officers consider to be recent good examples of SEA 

framework methodologies (24) . This has resulted in a receptor focused method being used to carry out 

the SEA. It was used to identify, examine and report significant risks to and opportunities for the 

environment that might arise from the implementation of the Local Plan. The receptors used are 

generic and relate directly to the topics/factors identified as being important for the environment by 

European and UK law (25) . 

3.24 Assessment of the Local Plan against this analytical framework contributes to the plan‐making process 

by identifying risks of significant impacts to which different environmental receptors might be exposed, 

and suggesting opportunities for avoiding or mitigating those risks. The assessment can also inform the 

development of a monitoring framework that would enable the Council to evaluate actual performance 

of the Plan in relation to the environment against that which the SEA predicted, including unforeseen 

effects. 

3.25 Ten receptors form the analytical framework for the SEA and are listed in Table 7. For each receptor a 

number of impact pathways have been identified. 

Table 7 – Analytical framework for the Strategic Environmental Assessment 

Environmental Receptor 

ER01 Natural Environment and Biodiversity: The receptor covers effects 

on the natural environment in terms of plants, animals and earth 

heritage assets, and on biodiversity in terms of habitats and species. A 

separate report will be prepared in which the potential for the Local Plan 

to give rise to significant adverse impacts on sites of European or 

International nature conservation importance. This report will address 

compliance as required by the EU Habitats Directive and the UK Habitats 

Regulations 2010. 

 

 

Listed as ‘biodiversity’, ‘fauna’ and ‘flora’ in paragraph (f) of Annex I to EU 

Directive 2001/42/EC 

Listed as ‘biodiversity’, ‘fauna’ and ‘flora’ in paragraph (6)(a),(d) and(e) of 

Schedule 2 to UK Statutory Instrument 2004 No.1633 

Impact Pathways 

NEB1: Impacts on habitats and species due 

to land take 


to changes in air quality 

NEB3: Impact of habitats and species due to 

changes in water quality 


to disturbance 

ER02 Welfare, Health and Well‐being: The receptor covers effects on the 

human population resident in the area covered by the plan in terms of 

impacts on their welfare, health and well‐being (e.g. noise, odour, light 

pollution, etc.). The chapter of the Environmental Report for the new 

Runnymede Local Plan on ‘Welfare, Health, and Well‐being’ will fulfil the 

requirement for the Plan to be subject to Health Impact Assessment in 

addition to SEA. 

 

 

Listed as ‘population’ and ‘human health’ in paragraph (f) of Annex I to EU 

Directive 2001/42/EC 

Listed as ‘population’ and ‘human health’ in paragraph (6)(b) and (c) of 

Schedule 2 to UK Statutory Instrument 2004 No.1633 

WHWB1: Risks of death and serious injury 

WHWB2: Risks to respiratory health related 

to air pollution 

WHWB3: Risks to health and well‐being 

from environmental noise 

WHWB4: Risks to health and well‐being 

from environmental stress 

WHWB5: Opportunities to increase physical 

activity 

24 Surrey County Council’s Environmental Report of the Surrey Transport Plan (LTP3) January 2011 and West Lancashire Borough Council’s 

Local Plan 2012 ‐ 2027 

25 Directive 2001/42/EC on the assessment of the effects of certain plans and programmes on the environment (http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2001:197:0030:0037:EN:PDF 

). The Environmental Assessment of Plans and Programmes 

Regulations 2004, Statutory Instrument 2004 No. 1633, HM Government, London. 



ER03 Land and Soil Resources: The receptor covers the effects of 

development on land use, and the safeguarding of soil quality and 

mineral resources. 

 

 

Listed as ‘soil’ in paragraph (f) of Annex I to EU Directive 2001/42/EC 

Listed as ‘soil’ in paragraph (6)(f) of Schedule 2 to UK Statutory Instrument 

2004 No.1633 


LSMR1: Reduction of land through 

development 

LSMR2: Reduction of soil through 

development and potential contamination 

LSMR3: Pressure to increase the use of 

mineral resources 

ER04 Water Resources and Management: The receptor covers effects on 

the biological and chemical quality of surface waters and ground waters, 

the use and management of water resources, and the management of 

flooding and flood risk. 

 

 

Listed as ‘water’ in paragraph (f) of Annex I to EU Directive 2001/42/EC 

Listed as ‘water’ in paragraph (6)(g) of Schedule 2 to UK Statutory Instrument 

2004 No.1633 

ER05 Air Quality: The receptor covers impacts on air quality in terms of 

levels of sulphur dioxide (SO2), nitrogen dioxide (NO2), particulate matter 

(PM10 and PM 2.5 ), ground level ozone (O3), dust and other sources of 

localised air pollution. 

 

 

Listed as ‘air’ in paragraph (f) of Annex I to EU Directive 2001/42/EC 

Listed as ‘air’ in paragraph (6)(h) of Schedule 2 to UK Statutory Instrument 

2004 No.1633 

WRM1: Impacts on the flow of water 

WRM2: Impacts on water quality 

WRM3: Demand for water resources 

AQ1: Emissions to air associated with 

changes in the total volume and distribution 

of traffic on Runnymede’s roads 

AQ2: Emissions to air associated with the 

construction and/or maintenance of 

transport, residential and commercial assets 

/ networks and other infrastructure in 

Runnymede. 

AQ3: Emissions to air associated with 

heating and resulting from the proposed 

residential and commercial property 

development in Runnymede. 

ER06 Climate Change: The receptor covers emissions of greenhouse 

gases associated with the generation of energy by conventional and 

alternative means, and the use of energy for heating, lighting, power and 

transportation. 

 

 

Listed as ‘climatic factors’ in paragraph (f) of Annex I to EU Directive 

2001/42/EC 

Listed as ‘climatic factors’ in paragraph (6)(i) of Schedule 2 to UK Statutory 

Instrument 2004 No.1633 

CC1 Greenhouse gas emissions associated 

with changes in the total volume and the 

distribution of traffic on Runnymede’s roads. 


with the construction and/or maintenance 

of transport, residential and commercial 

assets / networks and other infrastructure in 

Runnymede. 


with heating, electricity use and waste 

management and resulting from the 

proposed residential and commercial 

property in Runnymede. 

ER07 Materials Efficiency and Waste: The receptor covers effects on the 

generation and management of wastes, including waste disposal, 

recovery, reuse and recycling of materials, and the efficiency with which 

existing infrastructure is used. 

 

 

Listed as ‘material assets’ in paragraph (f) of Annex I to EU Directive 

2001/42/EC 

Listed as ‘material assets’ in paragraph (6)(j) of Schedule 2 to UK Statutory 


MEW1: Use of resources 

MEW2: Generation of wastes 



ER08 Built Environment: The receptor covers effects on the quality and 

character of the built environment in existing and new developments, 

and in the provision of new and maintenance of existing infrastructure. 

 

 

Listed as ‘material assets’ in paragraph (f) of Annex I to EU Directive 

2001/42/EC 

Listed as ‘material assets’ in paragraph (6)(j) of Schedule 2 to UK Statutory 



BE1: Quality of design in new development 

BE2: Impacts on built structures 

BE3: Impacts on the ambience of 

settlements 

ER09 Historic Environment and Archaeology: The receptor covers effects 

on the historic environment in terms of archaeological assets and sites, 

buildings, structures and features of historic significance and value. 

 

 

Listed as ‘cultural heritage including architectural and archaeological 

heritage’ in paragraph (f) of Annex I to EU Directive 2001/42/EC 

Listed as ‘cultural heritage including architectural and archaeological 

heritage’ in paragraph (6)(k) of Schedule 2 to UK Statutory Instrument 2004 

No.1633 

HEA1: Impacts on heritage assets due to 

land take 


inappropriate development in its proximity 

HEA3: Impacts on heritage due to decreased 

air quality and related climate change 


disturbance 

ER10 Landscape and Visual Amenity: The receptor covers effects on the 

character and integrity of the rural and urban landscapes and the effects 

that changes as a result of plan implementation on visual amenity. 

 

 

Listed as ‘landscape’ in paragraph (f) of Annex I to EU Directive 2001/42/EC 

Listed as ‘landscape’ in paragraph (6)(l) of Schedule 2 to UK Statutory 


LVA1: Impacts arising from new 

development and infrastructure 

LVA2: Impacts arising from development 

and infrastructure maintenance and 

improvement 

ER11 Cumulative Effects: The receptor covers cumulative effects on 

various factors as result of plan implementation in combination with 

other plans project and processes that may on their own be considered 

unlikely to result in significant effects but when considered together are 

likely. 

 

 

Listed as ‘interrelationship between the above factors’ in paragraph (f) of 

Annex I to EU Directive 2001/42/EC 

Listed as ‘interrelationship between the issues referred to in sub‐paragraphs 

(a) to (l)’ in paragraph (6)(m) of Schedule 2 to UK Statutory Instrument 2004 

No.1633 

CEA1: Impacts arising from new 

development and infrastructure likely to 

result in an effect that can act cumulatively 

with other similar effects 

Assessment of Local Plan vision, objectives and implementation measures 

3.26 Different policies that together form the Local Plan have been assessed by examining each individual 

policy against both the SEA Impact Pathway (Table 7) and the SA Objective (Table 5). These were then 

assessed (where sufficient information exists) to determine their likely capacity to give rise to risks of 

adverse impacts or possible opportunities for beneficial effects against the analytical framework 

outlined in this document. 

3.27 During the early stages of drafting the proposed/evolving policies did not contain sufficient detail to 

enable measures that may be used in their implementation, timing, or location to be properly assessed. 

This uncertainty was addressed using a qualitative exercise, which determined whether a proposed 

measure would have the potential, based on the available information, to result in actions that could 

affect a given receptor. 

3.28 The assessment of each emerging policy proposed in the Local Plan and the reasonable alternatives 

considered are included within the attached Appendix 2 – L2 to L6 Outputs of this SAR. In line with the 

strategic level of SEAs and similar to other assessment methodologies, a simple system has been used 

against which to categorise impacts and effects, as detailed in Table 8 – Impact classifications used for 


the SEA. Each policy and its alternative(s) where applicable have been scored against this ‘Effect 

Classification’ for both SEA (Level 4) and SA (Level 3). 

3.29 The findings of the assessment for the proposed policy set for inclusion in the Local Plan is summarised 

against each of the environmental receptors and is presented within Section 4 to Section 16 of this SAR 

report. 

Table 8 – Impact classifications used for the SEA 

Impact and Effect 

Classification 

Explanation 

Significant 

Beneficial 

 

Where the potential opportunities for beneficial effects arising from implementation of 

policy measures has been determined to be significant, a judgement will be made on 

the basis that individual projects delivered under the policy measure would be 

responding to known and significant problems (e.g. shortage of affordable housing). 

Beneficial 

 

Where the types of actions/reaction that might be pursued or expected under 

implementation of policy measures that are determined to have the potential to give 

rise to beneficial effects on an environmental receptor via a specified and identifiable 

pathway, but would not be addressing location specific issues where the effects have 

been classified as non-significant. 

Mixed 

/ 


implementation of policy measures that are determined could potentially give rise to 

both beneficial and adverse effects on an environmental receptor via a specified and 

identifiable pathway, but would not be addressing location specific issues where the 

effects have been classified as non-significant. 

Neutral 0 

Where the types of actions that might be taken under a measure have been 

determined to be unlikely to give rise to risks of adverse impacts or opportunities for 

beneficial effects on an environmental receptor via a specified pathway, or where 

insufficient information has been provided about the measure to make a judgement as 

to the types of actions that its implementation might involve, a conclusion of ‘no 

impact or effect’ has been recorded. 

Uncertain ? 


implementation of policy measures that can not at this stage be determined to have 

the potential to give rise to either beneficial or adverse or any mix of the two on an 

environmental receptor via a specified and identifiable pathway. 

Adverse 

 

Where the types of actions/reactions that might be pursued or expect under 

implementation of policy measures that are determined to have the potential to give 

rise to adverse impacts on an environmental receptor via a specified pathway, but 

would not be likely to require either and/or an Environmental Impact Assessment 

(EIA) or Appropriate Assessment (AA) at the project consent stage those impacts have 

been classified as non-significant. 

Significant 

Adverse 

 

Where the potential risk of an adverse impact arising from implementation of the 

policy measure has been determined to be significant, a judgement will be made on 

the basis that an individual project delivered under the policy measure would be likely 

to require either and/or an Environmental Impact Assessment (EIA) or Appropriate 

Assessment (AA) with respect to the environmental receptor or any feature of that 

receptor concerned as part of any subsequent project consent. 

Cumulative Effects Assessment (CEA) – incorporating consideration of Synergistic Effects 

3.30 The aim of the cumulative effects assessment (CEA) is to identify and assess the significance of 

combined impacts from multiple plans, policies and programmes (PPPs) that form the component 

parts of the new Local Plan and other development / transport plans, e.g. the spatial/transport plans of 

neighbouring authorities. Individual impacts from a single plan or programme may not be significant on 

their own; however they could become significant when combined with other impacts ( 26) . 

26 

Cooper L. M. (2004) Guidelines for Cumulative Effects Assessment in SEA of Plans, EPMG Occasional 

Paper 04/LMC/CEA, Imperial College London. 


3.31 CEA is considered to be one of the most difficult types of assessment to be carried out in the SAR. The 

methodology used for the assessment followed a review of existing guidance ( 27) and available research 

methods ( 28) . The general approach is described in the text below and illustrated in Table 11 andFigure 

5. 

3.32 The first stage of the CEA has been to identify potential sources ‐ that is individual policies from within 

the Local Plan. This is followed by the identification of other spatial / transport plans that are likely to 

give rise to environmental impacts or cause significant environmental receptor change. This process 

was commenced at Level 2. 

3.33 The result of this analysis is presented in Appendix 12 in the form of a flow diagram model. This model 

tracks the cumulative effects from source to target through a series of perturbations that end with an 

environmental receptor. It was concluded that the environmental receptors themselves by and large 

cumulative effects, such as biodiversity, air quality and climate change, as well as water quality and 

management. 

3.34 As cumulative effects occur in various forms (James et al. 2003), it is important to clarify the typology 

that is applicable as a result of implementation of the Local Plan. Table 9 has been adapted from that 

used in the James et al. 2003. 

Table 9 – Examples of cumulative effects (Adapted from James et al. 2003) 

Type Main characteristics Example 

Time crowding 

Frequent and repetitive effects 

on an environmental system 

Disturbance rate exceeds breeding / replacement rate 

Time lags Delayed effects Exposure to carcinogens or emissions where an effect is not 

expressed in the short term 

Space 

crowding 

Crossboundary 

High spatial density of effects 

on environmental system 

Effects occur away from the 

source 

Pollution discharges into water courses from non-point sources 

Acidic precipitation as a result of emission to the airshed. 

Reduction in water quantity where the watershed is located 

across a wide location 

Fragmentation Change in landscape pattern Fragmentation of ancient woodland or habitats 

Compounding 

effects 

Indirect 

effects 

Triggers and 

thresholds 

Effects arising from multiple 

sources or pathways 

Secondary effects 

Fundamental changes in 

system behaviour or structure 

Synergism among pesticides 

Synergism among atmospheric pollutants 

Induced development following construction of infrastructure 

Land quality improvements in regeneration areas eg 

contaminated areas cleaned up contributing to property value 

increases. 

Global climate change 

3.35 James E, et al. (2003) also pointed out the fact that “Effects also impact upon receptors in different 

ways.” Going on to identify “additive or interactive” processes, as outlined in the modified examples is 

given in Table 10. It should be noted that the assessment of the Local Plan’s synergistic effects is an 

SEA Directive requirement. 

27 Examples of used guidance include: 

ODPM (2006) A Practical Guide to the Strategic Environmental Assessment Directive. Office of the Deputy Prime Minister, London. 

Cooper L. M. (2004) Guidelines for Cumulative Effects Assessment in SEA of Plans, EPMG Occasional 

Paper 04/LMC/CEA, Imperial College London. 

28 Examples of reviewed research methods include: 

James E, etal (2003) Final Report – Literature Review/ Scoping Study on Cumulative Effects Assessment and the Strategic Environmental 

Assessment Directive. Unpublished Project Report PR SE/730/03. 

Tricker R. C. (2007) Assessing Cumulative Environmental Effects From Major Public Transport Projects. Transport Policy 14 (4), 293‐305. 

Canter, L.W. (2008): Conceptual Models, Matrices, Networks And Adaptive Management – Emerging Methods For CEA. Presented at 

Assessing and Managing Cumulative Environmental Effects, Special Topic Meeting, International Association for Impact Assessment, 

November 6‐9, 2008, Calgary, Alberta, Canada. 


Table 10 – Additive and interactive effects (Adapted from James E, et al. (2003) 

Action Type Additive Process Interactive / Synergistic Process 

Single Action 

Multiple Actions 

Repeated effects from a 

single proposal e.g. affect 

of emissions a power plant 

on terrestrial eco-systems. 

Repeated effects from 

multiple sources e.g. 

Effects of various emitters 

from different locations 

into the same catchment 

Effects from a single action that interact with the resource in a 

complex manner e.g. bio-accumulation of nitrates from various 

sources within the airshed catchment. 

Effects from multiple sources affecting resources in a non-linear 

manner, e.g. increase of nutrients from point discharges 

(sewage works) and non point discharges leading to algal 

blooms and lowering of dissolved oxygen or providing a more 

suitable habitat for a competing species. 

3.36 In general the significance of all adverse and beneficial impacts will be assessed for each identified 

policy of the Local Plan in relation to the specific receptors of the SEA: ER01‐ Natural Environment and 

Biodiversity, ER04 – Water Resources & Management, ER05 – Air Quality, and ER06 – Climate Change. 

3.37 Present baselines for each ER have already been characterised in ‘The State of the Environment’ 

chapters of Sections 7 ‐ 16 of this SAR. Indicators presented in individual sections were determined for 

individual receptors to monitor any changes to the state of the receptor prior to implementation of the 

Local Plan. This data was enhanced where it become apparent that further information was needed to 

assess the significance of cumulative effects – transportation and air quality. Adverse affects as 

determined by the SEA assessment process for the individual impact pathways/mechanisms for effect 

were used as thresholds – that is limits beyond which cumulative change becomes an important 

concern. 

3.38 Pathways of impacts between the sources and receptors have been identified as shown in Table 11 – 

Cumulative effects assessment of Policies in the Local Plan. Linkages between the impacts were 

determined in the process of a network analysis of impacts and cause‐effect pathways – as shown by 

way of example in Figure 5. Causes of impact are presented on the left of the diagram. The directness 

of impact of the Local Plan is decreasing towards the right. Lower order impacts, when combined, can 

result in higher order effects – for example, climate and ecosystems. 

3.39 The significance of combined impacts of multiple policies and projects (inter‐policy impacts) (last 

column of Table 11) is assessed against the established benchmark. 

Table 11 – Cumulative effects assessment of Policies in the Local Plan 

Potential 

Receptor 

Policies within 

the Local Plan 

with potential 

to impact 

Receptor 

Other plans & 

projects with 

potential to 

impact 

Receptor 

Pathway 

Potential 

Cumulative 

Effects 

Significance 

ER01‐ Natural Environment 

and Biodiversity; 

ER02 ‐ Welfare, Health and 

Well‐being. 

ER03‐ Land and Soil 

Resources; 

ER04 Water Resources and 

Management; 

ER05 ‐ Air Quality; 

ER06 ‐ Climate Change; 

ER07 ‐ Materials Efficiency 

and Waste; 

ER08 ‐ Built Environment; 

ER09 ‐ Historic Environment 

and Archaeology; 

ER10 ‐ Landscape and Visual 

Amenity; 

Individual 

programmes of 

the Local Plan 

likely to impact 

the receptor 

refer to Figure 5. 

Individual 

programmes of 

other plans and 

projects likely to 

impact the 

receptor refer to 

Figure 5. 

Impact 

pathways 

relevant 

to 

receptor 

refer to 

Figure 5. 

All negative and 

positive effects that 

may arise through 

the specified 

pathways as a result 

of the plans and 

projects being 

implemented refer 

to Figure 5. 

Overall significance of 

impacts assessed 

against the thresholds 

as described in text 

above. 

The significance will be 

assessed as: 

Significant 

Beneficial 

Beneficial 

Mixed 

 

 

/ 

Neutral 0 

Uncertain ? 

Adverse 

Significant 

Adverse 

 

 


Figure 5 ‐ Environmental network analysis of cumulative impacts of LP 

Level 5 Assessment – Environmental Impact Assessment (EIA) 

3.40 Where plans or policies relate to specific sites such as LP08, a Level 5 assessment was carried out. 

Level 5 assessments are considerably more detailed site specific assessments that use either EIA 

procedures in the case of projects, or a derivative of SEEDA’s Sustainable Development Checklist (SDC) 

in the case of plans as the basis for their assessment methods. 

3.41 Level 5 strategic site assessments are appraised using a modified SDC (see: Appendix 7). The SDC has 

the potential to be locally weighted using data derived from within the Runnymede State Report and 

local agreed sustainable development objectives that will make its deployment at either strategic, 

outline or detailed planning application stages possible. In terms of this SAR, no weighting has been 

applied. 

3.42 An assessment of development achievements is based on data related to developments approved in 

combination with other data within the Runnymede State Report and Annual Monitoring Report 

(AMR). It is then used to develop and fix a Standard Assessment Development Profile (SADP) for each 

alternative site or group of sites. The SADP is generated so that the site or site grouping can be 

assessed against a specific set of questions closely aligned to the Level 5 SDC. The answers to these 

questions are where possible supported by local data already available to the Council or other data 

provided by site promoters. For example, development densities can be assessed using what has 

actually been achieved through development approved or what is within relevant policy. Development 

proximity to transportation nodal points and development proximity to services are all derived from 

data analysed using the Council’s in‐house GIS Team. Impacts on infrastructure are considered against 

the Council’s Infrastructure Delivery Plan (IDP). The SDC has been run for identified potential 

development sites such as DERA [Policy LP08] and its three reasonable alternatives. 


3.43 In terms of environment, assessments at Level 5 would have triggered site specific policies or 

constraints that had potential for adverse effects on the receiving environment. As such the process 

can follow and assist procedures pursuant to the relevant EIA regulations 29 . 

Level 6 Assessment – Habitats Regulations Assessment/Appropriate Assessment (HRA) 

3.44 Habitats Regulations Assessment (HRA) is triggered pursuant to Regulations 102, 103 and 105 of the 

Conservation of Habitats and Species Regulations 2010 (see also paragraph 2.26 above) where 

elements of the Local Plan are likely to result in significant effect on a qualifying feature present on a 

European site 30 . 

3.45 The HRA is only triggered where the Council is unable to conclude that there is no likelihood of a 

significant effect to environmental feature(s) alone or in combination with other plans or projects with 

a similar mechanism for effect (MfE). In addition, the plan must not be directly connected with or 

necessary to the management of the site’s nature conservation objectives. 

3.46 Given the complexity involved in dealing with regulatory compliance of this regime, it is necessary to 

consider the effect the Local Plan through its individual policies will potentially have on European sites 

as a standalone exercise. These regulations were triggered following the conclusions of a pre‐screening 

and screening assessment, against the requirements of the Conservation of Habitats and Species 

Regulations 2010 ( 31) . In consultation with Natural England, a separate HRA screening and scoping 

report was adopted on August 3, 2012 a copy of which is available at Appendix 8. A HRA report has 

also been produced and accompanies the Council’s Local Plan submission documents as a stand alone 

component to the SEA and this SAR and is available at Appendix 9. 

29 Town and Country Planning (Environmental Impact Assessment) Regulations 2011 (Statutory Instrument 2011 No.1824). 

30 A European Site means sites established pursuant to Article 3(1) of the Habitats Directive and Regulation 8 of the Conservation of 

Habitats and Species Regulations 2010 (Statutory Instrument 2010 No.490). 

Ibid., Regulation 102. 


Figure 6 ‐ RBC Assessment Framework 


Section 4. Assessment of RBC’s Local Plan against the SA Framework and Consideration 

of Alternatives 

Link between the SCS and LDF 

4.1 As stated in Section 2, the Local Plan is produced within and must have regard to an existing and 

changing and complex policy, legislative and economic environment policy framework. It is vital that 

the plan addresses local priorities and concerns, whilst being able to demonstrate consistency with, 

and where appropriate to make contributions to, the aims and objectives of the wider range of policies, 

strategies, and laws. 

4.2 The most important relationship the Local Plan has is with the SCS, as defined by paragraph 4.34 of PPS 

12 which stating that: 

“…district authorities should align and coordinate the Core Strategy [Local 

Plan] of the LDF with their Sustainable Community Strategies.” 

4.3 This relationship is not however limited to the delivery of the SCS objectives. It is also a component in 

the delivery mechanisms as captured in Figure 7 – Development and delivery of the SCS, LDF and LAA 

below, that takes account of potential future changes. 

Figure 7 – Development and delivery of the SCS, LDF and LAA 

Joining up the SCS, LDF and LAA [Revised 2012] 

1. Shared 

inputs and 

evidence 

National 

goals 

Regional 

strategies 

Data and 

spatial 

analysis 

Local 

priorities 

agreed 

by LSP & 

LEP 

SUSTAINABLE 

COMMUNITY 

STRATEGY 

(SCS 2012) 

LDF LOCAL PLAN 

(Formally Core 

Strategy) 

2. Aligned 

place-shaping 

strategies 

LOCAL AREA 

AGREEMENT 

(3-year delivery plan) 

(or similar replacement) 

3. Delivery 

mechanisms 

LSP, LEP 

& Partner 

Actions 

Inward 

Investment 

Planning 

decisions 

Area Action 

Plans 

S.106 CIL 

Infra 

Structure & 

assets 

Community Engagement 

DUTY TO INVOLVE 

(Statement of Community Involvement) 

Source: DCLG, 2009. Planning Together - Updated practical guide for local strategic partnerships and planners. 

http://www.pas.gov.uk/pas/core/page.do?pageId=110054 

4. LAA 

outcomes 

(or Replacement) 


4.4 PPS 12 further attempts to clarify the relationship in terms of the community it serves, in that it states: 

“The core strategy [Local Plan] is critical in delivering corporate and 

community aspirations…” 

4.5 The Planning Advisory Service (PAS) describes the relationship between the Local Plan (formally LDF) 

and the SCS as: 

4.6 Going on to say that: 

“The role of the local development framework is to turn the sustainable 

community strategy’s strategic vision into policy that guides and shapes 

development over 15 to 20 years after the plan’s adoption.” 

“The core strategy [Local Plan] should act as the spatial vision of the 

sustainable community strategy and it should aim to cover a wide range of 

policies and programmes.” 

4.7 In terms of the Local Plan, Government guidance on SEA advises local planning authorities to test the fit 

of proposed plans with the policies, strategies, and legislation that comprise the context in which those 

plans will be delivered. The aims of such an exercise are as follows. 

Wider strategic context 

 

“To ensure that proposed plans are consistent with the higher tier goals and objectives that 

have been set in relation to the specific issue (or issues) that afford the principal focus for the 

plan.” 

4.8 Clearly, ascertaining whether or not the Local Plan takes account of environmental protection goals 

and objectives and delivers sustainable development as set out in policy and strategy is important. 

Numerous local, regional, national, and European policies including laws at the national and European 

levels are set out in Appendix 10. 

Local Plan Strategic Context Fit 

4.9 Based on Local Plan objectives listed in Table 12, a strategic high‐level review of the Local Plan has 

been undertaken against policies, strategies, plans, and laws listed in Appendix 10, and have been 

summarised in the Table 13. Each environmental receptor chapter contains a more focused evaluation 

of this policy context fit. 

Table 12 – Local Plan Strategic Policy Objectives 

LP Objective 

Strategic Policy Objectives of the Local Plan 

1 To make best use of previously developed land (PDL) in the urban areas of Runnymede, 

particularly Addlestone, Chertsey and Egham. 

2 To create a vibrant and sustainable new community at the former DERA site, Longcross. 

3 To provide sufficient housing in Runnymede’s urban areas to help deliver regional housing targets 

and meet the needs of local people. 

4 To support the local economy for the future benefit of businesses, residents, and those who work 

in Runnymede. 

5 To protect existing well located employment areas within Runnymede. 

6 To protect and enhance the vitality and viability of the retail centres of Addlestone, Chertsey, 

Egham and Virginia Water and maintain the local shopping areas. 

7 To protect and enhance Runnymede’s open spaces for recreational, leisure and tourism purposes 

while conserving their biodiversity. 

8 To protect and enhance the Green Belt so as to maintain openness and visual amenity, and to 

prevent urban sprawl and the coalescence of Runnymede’s urban areas. 

9 To manage and mitigate the flood risk that is faced by people and property particularly in the areas 

of Addlestone, Chertsey, Egham and Thorpe. 

10 To conserve, protect and enhance Runnymede’s natural and historic environments. 

11 To ensure that all new development in Runnymede is of high quality design and complements and 

improves the character and the quality of the built environment. 

12 To help tackle the causes and effect of climate change, encouraging sustainable construction, 

energy efficient design, renewable energy provision, sustainable travel and recycling. 


LP Objective 

Strategic Policy Objectives of the Local Plan 

13 To ensure that the physical and social infrastructure needed to support new development is 

provided in a timely fashion. 

14 To promote the use of public transport, cycling and walking and reduce the need to travel, ensuring 

that new development is sustainably located. 

15 To protect natural resources and minimise the effects of all forms of pollution on the local 

community and the environment. 

4.10 Consequently, the conclusions drawn about the extent of the plan’s consistency with the objectives of 

the policies, strategies and plans that define its strategic context only relate to its apparent capacity to 

contribute to their stated goals. The extent to which that capacity is realised in practice will depend on 

the way in which the Local Plan is implemented. 

Table 13 – Local Plan Strategic Fit 

Strategic context – sources of 

relevant objectives and goals 

International Policy: Johannesburg Declaration on 

Sustainable Development. 

European Policy: European Sustainable 

Development Strategy. 

UK Policy: Securing the Future: the UK 

Government Sustainable Development Strategy. 

Regional Strategy and Policy: Regional 

Sustainability Framework for the South East; 

London's Spatial Development Strategy (London 

Plan); Bracknell Forest CS (2008), Wokingham CS 

(2010), The South East Plan 

Surrey Strategy and Policy: Surrey Strategic 

Partnership Plan 2010 - 2020; The Surrey Waste 

Plan (2008); Epsom and Ewell CS (2007), Mole 

Valley CS (2009) , Spelthorne CS (2009), 

Tandridge CS (2008), Surrey Heath CS (2012), 

Elmbridge CS (2011), Woking CS (2012). 

Runnymede Strategies and Plans: RBC 

Sustainable Community Strategy; A Vision for 

Runnymede (2012); Runnymede Statement of 

Community Involvement (2006); Runnymede Local 

Plan Saved Policies (2007), Runnymede Emerging 

Local Sustainability Plan 

Local Plan Relevant objectives and 

comments 

Objectives: All 

Comment: The objectives within Local Plan when considered 

as a whole will contribute toward the delivery of the main 

high level strategic sustainable development objectives of 

this policy which aims to meet the needs of society today 

without compromising the ability of future generations to 

meet their needs. 


Comment: Similar to the Rio Declaration, the objectives 

within Local Plan when considered as a whole will contribute 

toward the delivery of this European high level strategic 

sustainable development objectives of this strategy which 

also aims to meet the needs of society today without 

compromising the ability of future generations to meet their 

needs 


Comment: The impact of poor air quality on the cumulative 

effects of climate change is now widely recognised. The 

objectives within Local Plan when considered as a whole will 

contribute positively to addressing the UK‘s sustainable 

development objectives. 


Comment: The aims of the identified regional strategies are 

adhered to in the Local Plan objectives. 


Comment: The aims of Surrey strategies are adhered to in 

the Local Plan objectives. 


Comment: The aims of local strategies are adhered to in the 

Local Plan objectives 

4.11 Preliminary analysis of the strategic fit of the Local Plan with the wider context of sustainable 

development policy (Table 13) indicates that the proposed plan has considerable potential to 

contribute to a wide range of strategic goals. A more detailed analysis will made under each ER Section 

and will identify specific environmental protection policy goals and targets to which the proposed Local 

Plan could reasonably be expected to contribute to. 

4.12 It should be noted that there are likely to be significant differences between the Local Plan’s potential 

contributions and its actual contributions to the realisation of broader policy goals. The Local Plan’s 


actual contributions will be subject to the influences of a range of factors, including the legislative and 

market conditions, partnership working and Council resources. 

Background to Runnymede Borough Council’s Local Plan 

4.13 The RBC Local Plan (Local Plan) is an essential part of the Council's policy and delivery planning 

framework and it should be read in conjunction with this SAR. It provides an explicit statutory link to 

the Borough’s Sustainable Community Strategy (SCS). In addition, it will inform and be informed by the 

direction taken by the Council on the emerging Local Enterprise Partnerships (LEP), as well as the 

requirement for both its Infrastructure Delivery Plan (IDP) and the Community Infrastructure Levy (CIL) 

charge. 

4.14 Nationally, government policy is another key driver in the formation of this Local Plan, and is currently 

seeking to prioritise the promotion of sustainable economic growth in order to mitigate the effects of 

the economic downturn. The Council as a local government body must follow national policy unless it 

has significant evidence that would lead it to conclude otherwise. 

4.15 The Council’s evidence base suggests that in terms of housing, the economy and employment land, and 

the retail sector ‐ future requirements in the Borough might best be met from within the Borough. The 

results of these studies have led the Council to conclude that planned growth can be met sustainably 

from within its existing urban areas and a number of extant planning permission (LP02) plus the 

comprehensive redevelopment of the Ex‐MOD Defence Evaluation and Research Agency (DERA) site at 

Longcross (LP08). 

4.16 The Local Plan is underpinned by a cross section of 18 policies comprising of 8 ‘Location Policies (LP01 – 

LP08)’ and 10 Strategic Policies (SP01 – SP10), as detailed below in Table 14 – Local Plan Policies. These 

policies reflect key broad considerations that directly relate to development in Runnymede. With the 

exception of the former DERA site (LP08), the policies promote development within the existing urban 

areas with the main focus on the town centres (LP01) of Addlestone (LP03), Chertsey (LP06), Egham/ 

Englefield Green (LP04). It also promotes the continued protection of the Green Belt (SP01) and the 

maintenance and enhancement of the employment base (SP08). A level of 25% (SP02) affordable 

housing on qualifying sites is will be periodically reviewed following adoption. 

4.17 In terms of housing numbers, the Local Plan is not proposing to allocate any strategic sites (LP02). It is 

of the view, that the current rate of housing completions coupled with the existing level of approved 

schemes adequately meets its proposed quantum of 161 units per annum. This conclusion is predicated 

on the successful redevelopment of the DERA site and the delivery of up to 1,500 residential units in 

the second half of the plan period (LP08). 

4.18 The 116 hectare DERA site was originally a MoD research establishment for testing military vehicles 

and was decommissioned in 2001, a small area of which is within the administrative boundary of Surrey 

Heath Borough Council (SHBC). The South East Plan identified and allocated it for redevelopment for a 

mix of uses, including 2,500 new homes, all of which would be within the Borough of Runnymede. The 

Borough’s SCS states that the site provides a unique opportunity to provide a mixed use community 

with: 

 

 

 

headquarter development for a global high‐tech enterprise; 

a new sustainable ‘village’ with homes of varying size and tenure which meet the housing 

needs of the borough; and, 

modern sustainable infrastructure as well as a site of major employment opportunity. 

4.19 Other policies consider issues such as Gypsy and Traveller provision (SP03), Design (SP04) and 

Development and Flood Risk (SP10). All are assessed in terms to their contribution to towards meeting 

the objectives of sustainable development where the baseline condition is set out in Table 5. 

Table 14 – Local Plan Policies 

No. 

Policy 

Location Policies 

LP01 

LP02 

LP03 

Strategy for the Location of Development 

Housing Provision and Distribution 

Development in Addlestone Urban Area 


No. 

Policy 

LP04 Development in Egham / Englefield Green Urban Area 

LP05 Royal Holloway UOL 

LP06 Development in Chertsey Urban Area 

LP07 Development in Virginia Water 

LP08 The former DERA site, Longcross 

Strategic Policies 

SP01 Green Belt Areas 

SP02 Affordable Housing 

SP03 Gypsy and Travelling Populations 

SP04 Provision and Retention of Infrastructure and Service 

SP05 Design 

SP06 Tourism, Recreation and Leisure 

SP07 Thames Basin Heaths Special Protection Area 

SP08 Employment Development 

SP09 Sustainable Transport 

SP10 Development and Flood Risk 

Local Plan Strategic alternatives 

4.20 The policies put forward in the Local Plan are considered to be the preferred alternatives which have 

been derived from a series of considerations and consultations on issues and options facing 

Runnymede. The Planning Inspectorate 32 advise that; 

“Meaningful options should be developed on such matters as the broad 

location and balance of development across the authority area, the 

management of housing supply, the balance between employment and 

housing and the delivery of affordable housing.” 

4.21 Formally, reasonable alternatives require consideration pursuant to Article 5(1) Annex I (f) of the SEA 

Directive as transposed into UK law by regulation 12(2)(b) requires the plan maker to identify, describe 

and evaluate the likely significant effects on the environment of the reasonable alternatives to the 

chosen policy taking into account the geographical scope of the plan. 

4.22 Clearly the duty to identify, describe, and evaluate the likely significant effects of reasonable 

alternative is triggered following a determination of its likely significant effects on an environmental 

receptor. It follows, that where a conclusion of no likely significant effect is reached, then there can be 

no effect and therefore will not be subjected to this consideration. 

4.23 In the case of the Local Plan, not all policies resulted in the generation and therefore consideration of 

alternatives. The Council considered that ‘no alternative exists’ for Strategic Policy SP01, SP04, SP05, 

SP07, SP09 and SP10. This conclusion is based on the argument that there are no useful choices 

available to the policy authors at this time. 

4.24 Where reasonable alternatives exist and considered to be likely to result in significant effects on the 

environment, they have been subjected to both an SA and SEA the results of which have been attached 

to Appendix 2 and are summarised in Appendices 3 and 4. These results are incorporated into the SAR 

introduced in a table describing each Local Plan policy and its alternative against L3, L4, L5 and L6, for 

example environmental receptor ER01 the relevant table is Table 38 ‐ Summary of Local Plan Policies 

and alternatives on ER01. 

32 

Planning Inspectorate (2007). Local Development Frameworks: Lessons Learnt Examining Development Plan Documents 

[online]: http://www.pas.gov.uk/pas/aio/41411 (accessed May 2012). 


Location Policy 1 (LP01) – Strategy for the Location of Development 

4.25 The Local Plan considered three policy options for Policy LP01 to deliver its objective. These have been 

summarised in Table 15. 

4.26 At the heart of the National Planning Policy Framework is a presumption in favour of sustainable 

development, which should be seen as a golden thread running through both plan‐making and 

decision‐taking. For the Local Plan this means that local planning authorities should positively seek 

opportunities to meet the development needs of their area. 

4.27 The policies in the Local Plan are underpinned by the presumption in favour of sustainable 

development so that development which is sustainable can be expedited. The Local Plan is based upon 

and reflects the presumption in favour of sustainable development, with clear policies that will guide 

how the presumption should be applied locally. 

4.28 Evidence based material has informed the production of the Local Plan. The retail study has 

demonstrated the opportunities for investment within the Borough’s town centres to meet future 

need. However, the housing and employment land reviews that examined the future requirements in 

the Borough concluded that the identified requirements cannot be met solely from within existing 

urban areas. 

Table 15 – LP01 Policy Options Considered 

Policy and Alternatives Considered 

Assessment 

ID. 

Policy/Alternative Policy Text 


This approach will result in focusing development within the existing urban areas with the 

exception of a new centre at DERA. 

LP01‐A1 No additional growth but to respond to development schemes as they arise 

following the guidance in the NPPF to permit sustainable development. (This ignores 

the SCS, excludes DERA for housing as it would remain in the green belt, but it would 

include the extant permission for commercial development. However, under the 

policy L02 further work is required to consider the consequences of choosing the 

housing options that require green belt releases) 

LP01‐A2 To focus solely on Addlestone for promoting significant development using the 2012 

quanta of developments (that formed the early work on the SCS) and let other areas 

respond to development as option 2. This would exclude DERA for housing as it 

would remain in the green belt, but it would include the extant permission for 

commercial development. 

4.29 The approach in LP01 directs new development towards previously developed land within the existing 

urban settlements, to the former DERA site at Longcross, and to meet the growth aspirations of Royal 

Holloway University of London on the main London Road campus. Full consideration will be given to 

the impact on the transport network, to the risk of flooding, and to the potential impact of residential 

development on the Thames Basin Heaths Special Protection Area. Proposals will make appropriate 

provision for affordable housing. Where relevant, consideration will be given to any effect on areas of 

nature conservation importance, and on open space and recreational facilities. 

4.30 The approach in LP01 – A1 proposes no additional growth but to respond to development schemes as 

they arise following the guidance in the NPPF to permit sustainable development. (This ignores the SCS, 

excludes DERA for housing as it would remain in the green belt, but it would include the extant 

permission for commercial development). 

4.31 The approach in LP01 – A2 focuses solely on Addlestone for promoting significant development using 

the 2012 quantum’s of developments (that formed the early work on the SCS) and let other areas 

respond to development as option A1. This would exclude DERA for housing as it would remain in the 

green belt, but it would include the extant permission for commercial development and focus solely on 

Addlestone for major growth. 


Location Policy 2 (LP02) – Housing Provision and Distribution 

4.32 The Local Plan considered seven policy options for Policy LP02 to deliver its objective. These have been 


4.33 Planning for future homes in Runnymede is a key function of this Strategy and a major component of 

the Sustainable Community Strategy (SCS). A range of housing is needed to meet the future needs of 

the population in the Borough; this includes homes for families and for first time buyers, and for the 

elderly, who are forming a growing proportion of the total population. There is a particularly strong 

need to provide affordable housing to meet the needs of those who cannot afford to buy or rent at 

market levels. Previous consultations on the Core Strategy have identified support for the location of 

new homes within urban areas, including in the town centres 

4.34 It is important to note that the Borough allocations are not set at a maximum level, and where there is 

an identified local housing need, and other sustainability criteria can be met, national policy 

encourages the provision of increased numbers of dwellings. No provision has been made for windfall 

sites in the Plan but they are an integral part of supply and will need to taken into account as part of 

the Infrastructure Delivery Plan, the Community Infrastructure Levy and when recognising the 

requirements for the Thames Basin Special Protection Area (TBHSPA). 

4.35 There is a need to balance local constraints (that always formed part of the approach in the SEP and 

previous higher level plans) with future demand and need. It will be necessary to consider how to 

balance local constraints with demand/need within the context of the new localism agenda. 



Assessment 

ID. 



This approach aims to deliver on average 161 units per annum between the years 2011 and 2026 

based on extant permissions; windfall estimates and includes 1,500 units on DERA. 

LP02‐A1 The approach would be to deliver 145 p/a is based on extant permissions, identified 

commitments and windfall estimates. 

LP02‐A2(a) The approach is to deliver 161+ p/a units based on extant permissions, windfall and 

1500 units on the urban edge green belt sites. 

LP02‐A2(b) The approach is to deliver 161 +units p/a based on extant permissions, windfall, and 

reserve sites. 

LP02‐A2(c) The approach is to deliver 161 +units p/a based on extant permissions, windfall and 

2400 units on DERA. 

LP02‐A3(a) The approach is to deliver 550 units p/a based on extant permissions, windfall, DERA 

and SHLAA green belt sites. 

LP02‐A3(b) The approach is to deliver 550 units p/a based on extant permissions, windfall and 

higher density on reserve sites. 

Location Policy 3 (LP03) – Development in Addlestone Urban Area 

4.36 There are a number of issues that are relevant to all the urban area policies LP03, LP04, LP06 and LP07 

and have been captured in Box 2. 

Box 2 – Common Urban Area Development Issues 

During the Issues and Options stage, there was strong support for retaining, protecting, and enhancing 

the existing centres within the borough. This, along with the findings of the retail study, indicates that 

there is no need to pursue policies that promote out of town development. 

The retail study clearly demonstrates that the three main centres provide a day to day focus and that 

this should be enhanced, rather than seeking large scale retail development that would result in the 

towns changing to higher order centres in the retail hierarchy. 

This approach was supported by the SEP, which indicates that individuality is the key to the success of 

market plans, and so it is important to focus upon strengthening what each town has to offer. It is 

therefore not necessary to promote policies that would seek to create major retail expansion of our 

retail centres to elevate a centre in the retail hierarchy. 


4.37 The Vision for Addlestone and the southern urban areas of the Borough is that it will see the majority 

of new growth over the early period of this plan. The town centre will provide a range of facilities for 

the needs of its residents and businesses, as well as for the surrounding areas and will take 

opportunities for improvement and regeneration presented by vacant sites and underutilised sites 

along Station Road and adjoining area. Existing infrastructure will need to be enhanced and supported 

to accommodate this redevelopment. 



Assessment 

ID. 


Location Policy 3 (LP03) – Development in Addlestone 

This approach promotes Addlestone as an area for ‘new town centre development’ that will largely 

replicate the form and function of the existing town centre. 

LP03‐A1 

LP03‐A2 

No additional growth proposed, but responds to development schemes as they arise 

in the context of the approach to be taken to sustainable development as set out in 


Significant development to be promoted in Addlestone (using the base information 

that formed the early work on the Sustainable Community Strategy). In other areas, 

development schemes would be responded to as A1. 

4.38 Three policy approaches have been considered: 

 

 

The approach in policy LP03 is to promote Addlestone as an area for ‘new town centre 

development’. This will see changes to the scale of development in the town centre; 

The approach suggested by alternative A1 is that no additional growth is planned growth is 

identified but the Council will respond to development as it arises and is considered to be a 

reactive approach; and, 

The approach in alternative A2 is to promote significant development to be promoted in 

Addlestone. This would see the focus of most additional development in the Borough to be 

focused in Addlestone and as such would become the lead centre. 

Location Policy 4 (LP04) – Development in Egham/Englefield Green Urban Area 

4.39 There are a number of issues that are relevant to all the urban area policies. These have been captured 

in Box 2. 

4.40 The vision for Egham/Englefield Green is to recognise the growth potential and links of the College with 

the town. The focus of the policy is to direct development to Egham town centre to secure long term 

viability and vitality. The town centre is expected to provide a range of facilities for the needs of its 

residents and businesses as well as for the surrounding areas and will take opportunities for 

improvement and regeneration. Existing infrastructure will need to be enhanced and supported to 

accommodate this redevelopment. The policy approach is considered to be a more ad hoc approach to 

development and is summarised in Table 18. 



Assessment 

ID. 


Location Policy 4 (LP04) – Development in Egham and Englefield Green 

This approach makes specific reference to Royal Holloway UoL but it would act as a development 

control policy for the town centre in that any development coming forward will have to largely 

replicate the existing form and function of the existing town centre. 

LP04‐A1 No additional growth proposed, but responds to development schemes as they arise 




4.41 The approach in Policy LP04 acts as a development control policy for the town centre in that any 

development coming forward will have to largely replicate the existing form and function of the 

existing town centre. 

4.42 Whereas the alternative approach is to not to promote planned growth but to respond to market 

driven demand. 

Location Policy 5 (LP05) – Royal Holloway UOL 

4.43 Royal Holloway University of London brings educational, economic, and social benefits to the Borough, 

and one of the Council’s aspirations is therefore to retain RHUL in the Borough. However, in common 

with other higher education establishments, RHUL is under increased pressure to develop and grow. 

The University is committed to both enhancing its reputation and to maintaining its national position 

and Government Policy supports the University’s desire for the future growth of the college. The 

university is therefore developing a masterplan to allow the University to grow and maintain its 

position, making provision for additional floorspace for academic and research purposes, student 

residences and ancillary support purposes. 

4.44 The University wish to remain on the campus but indicate that it is too constrained to accommodate 

their growth aspirations. The Council has always wished to retain the campus within the Borough and 

to accommodate growth where consistent with policy. It is therefore necessary to consider how we can 

develop a policy to reasonably accommodate the aspirations of the university and retain the institution 

in the Borough, whilst affording a level of control over future development. At present the site is 

occupied by College buildings and gardens and has a mixture of college uses. The main College campus 

includes the Grade I listed Founder’s Building 

4.45 The Local Plan considered three policy options for Policy LP05 to deliver its objective and have been 

summarised in Table 19. The preferred policy is to allow the university to expand on the site whilst 

remaining in the Green Belt. 



Assessment 

ID. 


Location Policy 5 (LP05) – Royal Holloway UoL 

This approach provides Royal Holloway UoL with a level of weight in order to relax the strict Green 

Belt policy to permit this education provider to meet a goal to accommodate 45% of its students on 

site 

LP05‐A1 Maintain the Green Belt designation and not allow the site to expand. 

LP05‐A2 Remove the site from the Green Belt and allow the site to expand. 

4.46 Royal Holloway UOL Policy LP05 relies upon a ‘Master Plan’ coming forward in order to set the context 

of the future development requirements. It is reported to include the development of the playing field 

area to permit the accommodation of 45% of the total student population by 2031. LP02‐A1 maintains 

a strict green belt approach, whilst LP05 –A2 would remove the site from the green belt. 

Location Policy 6 (LP06) – Development in Chertsey Urban Area 

4.47 Chertsey’s urban area has a wide ranging, diverse and complex character containing town centre uses 

and large areas of housing, as well as notable areas of commercial and light industrial areas, all of 

which contribute to the viability and vitality of the urban area. The Council has identified eight broad 

character areas in Chertsey as follows: the historic town centre core, which equates to the 

Conservation Area; a central area of open space; the Gogmore Lane commercial/industrial area; the 

former Chertsey Revitalisation Area in proximity to the centre and the station; the Hanworth Lane 

reserve housing site south of the railway line; an area of late C19 housing off Station Road; an area of 

predominantly post‐war housing to the west side of the urban area; and an area of housing of mixed 

period to the east side of the urban area. 

4.48 Chertsey town centre is, in the main, a convenience and service centre. The lack of a significant 

comparison goods offer is not in itself a cause for concern, as a town’s vitality can be driven by several 

factors and a strong service and convenience goods offer can perform this function, so long as the 

needs of the town’s catchment in these regards are met. However, although the centre is both lively 


and viable, it is some way from meeting its full potential as a retail centre, and would therefore benefit 

from the development of an enhanced offer. 

4.49 The Local Plan considered two policy options for Policy LP06 to deliver its objective. These have been 




Assessment 

ID. 


Location Policy 6 (LP06) – Development in Chertsey 

This approach promotes the continued protection of Chertsey as the historic area supported by its 

current mix of uses found in and around the existing town centre. 

LP06‐A1 No additional growth proposed, but responds to development schemes as they arise 



4.50 The approach in policy LP06 would support and enhance the vitality and viability of Chertsey whilst 

maintaining the diversity of uses, having regard to its recognised distinctive historic character and 

appearance, and to promote regeneration and redevelopment as appropriate to further improve the 

needs of business and enhance the local environment. 

4.51 The approach in alternative A1 is that no additional planned growth is proposed, and the Council will 

respond to development as it arises. 

Location Policy 7 (LP07) – Development in Virginia Water Urban Area 

4.52 The vision for Virginia Water is to make the most of the natural attraction of the area, including The 

Great Park, the Virginia Water Lake and the Wentworth Golf Course. There is a desire to retain retail 

expenditure that leaks from the main centre. The alternative adopts a reactive response to 

development. Policy options for Policy LP07 to deliver its objective have been summarised in Table 21. 



Assessment 

ID. 


Location Policy 7 (LP07) – Development in Virginia Water 

This approach promotes the continued protection of Virginia Water as a high quality environment 

supported by its current mix of uses found in the existing village centre that are being enhanced by 

a major development of a former car park. 

LP07‐A1 

No additional growth proposed, but responds to development schemes as they arise 



4.53 The policy approach in LP07 is to promote the continued maintenance of the urban area of Virginia 

Water as a high quality environment supported by the current mix of uses and to enhance its vibrancy 

and attraction through redevelopment opportunities. New development, including additional housing, 

will be in keeping with its surroundings. Opportunities for regeneration and redevelopment will be 

explored within the area adjoining Virginia Water Station to better meet local needs. 

4.54 The approach in alternative A1 is that no additional planned growth proposed is proposed but the 

Council will respond to development schemes as they arise. 

Location Policy 8 (LP08) – The Former DERA Site Longcross 

4.55 The South East Plan allocated a new mixed use, including 2,500 new homes on the 116 hectare former 

DERA site located in the Green Belt at Longcross. The site is divided by the M3 motorway. Policy LP08 

seeks to provide for a similar mixed use development as per the South East Plan, but with a reduced 

provision of housing units. 


4.56 Policy LP08 seeks to provide “…up to 1,500 high quality dwellings of a mixed tenure and type 

including the provision of affordable housing.” It is worth noting that LP02 is predicated on the fact 

that this development will come forward. 

4.57 The site has a number of constraints, such as being located within the Green Belt as well as being 

located adjacent to the European protected sites of the Thames Basin Heaths SPA and Thursley Ash 

Pirbright and Chobham SAC. 

4.58 Policy LP08 removes the DERA Site from the Green belt and, similar to other location policies, it sets 

out a number of development control outcomes the Council will look for in connection with new 

development in this area. 

4.59 The Local Plan considered four policy options for Policy LP08 to deliver its objective. These have been 




Assessment 

ID. 


Location Policy 8 (LP08) – The former DERA site, Longcross 

This approach promotes removal of the DERA site from the Green Belt to allow its redevelopment 

for a mixed use development that includes up to 1,500 new homes and in the region of 79,000 m 2 

of onsite mixed employment uses. 

LP08‐A1 

LP08‐A2 

LP08‐A3 

1500 dwellings to be developed on land at Great Grove Farm, Ottershaw. 

1500 dwellings to be developed on at least two sites of a minimum size. 

1500 dwellings to be developed on schemes as they arise in the context of the 

approach to be taken to sustainable development as set out in the NPPF. 

4.60 To summarise, Policy LP08 promotes removal of the DERA site from the Green Belt to allow its 

redevelopment for a mixed use development that includes in the region of 1,500 new homes. The 

alternatives consider the provision of 1500 in other locations. 

Strategic Policy 1 (SP01) – Green Belt Areas 

4.61 During the Issues and Options consultation 66% of respondents agreed or strongly agreed that future 

development should be in accessible urban locations rather than in the Green Belt and 60% agreed or 

strongly agreed that future development should be on previously developed sites of major developed 

sites. 

4.62 With the exception of two policies (LP05 and LP08) the Council’s policy out in SP01 is to primarily locate 

new development within existing urban areas, thus maintaining the extent and existing boundaries of 

the current Green Belt. In the case of the two exceptions LP05 proposes to relax the strictness of policy 

SP01 to permit development around the University site. LP08 removes the DERA site from the Green 

Belt. 

4.63 The Local Plan considered one policy option for Policy SP01 to deliver its objective and has been 


Table 23 – SP01 Policy Options Considered 


Assessment 

ID. 



This approach promotes the strict protection of the Green belt following a general relaxation in 

terms of Royal Holloway UOL and the removal of the DERA site. 

‐ Alternatives not considered relevant to this policy. 

4.64 In consideration of there being no alternatives to Policy SP01, the Local Plan policy team state that: 

“The policy provides a local perspective on the guidance set out in the NPPF in 

terms of green belt protection. Section 9 of the NPPF (paragraphs 86 to 92) 

emphasises the need to avoid inappropriate development that will, by definition, 


e harmful to the green belt. The policy approach specifically reflects the position 

for major developed sites, site specific guidance and the context for meeting the 

possible needs of the gypsy and traveller community. Apart from the reference to 

major developed sites it brings together matters dealt with in separate policy 

guidance in the Local Plan. So whilst the policy does not seek to set a new 

approach it does set out clearly that there is a local character to green belt policy.” 

4.65 To summarise, Policy SP01 promotes strict protection of the Green belt following a general relaxation 

in terms of Royal Holloway UOL and the removal of the DERA site. 

Strategic Policy 2 (SP02) – Affordable Housing 

4.66 The Local Plan considered three policy options for Policy SP02 to deliver its objective. These have been 




Assessment 

ID. 



This approach requires 25% affordable housing to be provided on qualifying sites (greater than 12 

net additional dwellings) and provide financial contributions on all non‐qualifying developments 

SP02‐A1 This approach provides for no affordable housing 

SP02‐A2 This approach provides for meeting 500 units p/a 

4.67 Policy SP02 requires 25% affordable housing to be provided on qualifying sites (greater than 12 net 

additional dwellings) and provide financial contributions on all non‐qualifying developments. SP02 – A1 

provides for no affordable housing, whilst A2 looks to provide 500 units p/a. 

4.68 Given the fact that the plan does not propose to bring forward any new developments other than that 

which is already authorised except for LP08 DERA. The proposed 1,500 units could be expected to 

generate a planned total of 375 affordable units over the life of the plan. 

Strategic Policy 3 (SP03) – Gypsy, Travellers and Travelling Showpeople 

4.69 The Government’s policy statement, ‘Planning policy for traveller sites’ (PPTS), issued in March 2012, 

requires that local planning authorities should set pitch targets for gypsies and travellers. These should 

address the likely accommodation needs of travellers in their area and be developed in collaboration 

with neighbouring local planning authorities. 

4.70 Runnymede has the largest Gypsy and Traveller numbers in the North Surrey area according to the 

April 2007 North Surrey GTAA and also the highest proportion of Gypsies/Travellers in relation to the 

general population. Two caravans are equivalent to a pitch and the GTAA suggested that of the 49 

additional Gypsy and Traveller pitches required in North Surrey, 20 of these should be in Runnymede. 

4.71 In March 2012 the Government issued it National Planning Policy Framework (NPPF) along with its 

policy on Travellers. It is assumed that the Local Plan has taken account of compliance with this new 

policy framework in promoting a policy which safeguards existing sites with the location of additional 

provision as suggest in the GTAA being considered between 2016 and 2026 in the form of a subsequent 

Sites DPD. 

4.72 The Local Plan considered two policy options for Policy SP03 to deliver its objective. These have been 




Assessment 

ID. 



This approach promotes the safeguarding of existing sites. It suggests additional provision between 

the years 2016 – 2026 be considered in a future DPD 

SP03‐A1 This approach provides for no additional provision 


4.73 To summarise, Policy SP03 promotes the safeguarding of existing sites. It suggests additional provision 

between the years 2016 – 2026 be considered in a future DPD. This is in line with the requirements of 

the Government’s PPTS. SP03 –A1 does not provide any additional provision. 

Strategic Policy 4 (SP04) – Provision and Retention of Infrastructure and Services 

4.74 The provision and retention of infrastructure in the Borough will be key in delivering the development 

requirements set out in the Local Plan Core Strategy and meeting the essential infrastructure 

requirement in the Infrastructure Delivery Plan. 

4.75 The NPPF highlights that Local Plans should be positively prepared, and based on a strategy that seeks 

to meet objectively assessed development and infrastructure requirements, and the Sustainable 

Community Strategy (SCS) supports the approach of the NPPF. 

4.76 As the Borough will inevitably see an increase in development over the plan period, the Council 

requires all new development required to mitigate their impacts will be required to contribute towards 

the delivery of social, physical and green infrastructure needed to support new development. A Local 

Plan policy is deemed necessary to support a new charging schedule under The Community 

Infrastructure Levy Regulations 2010 and The Community Infrastructure Levy (Amendment) 

Regulations 2011. 

4.77 The Local Plan considered one policy option for Policy SP04 to deliver its objective and this has been 




Assessment 

ID. 

Policy/Alternative Policy Text CFR Comment 


Policy SP04 requires new development to contribute to the delivery of infrastructure identified in 

the Infrastructure Delivery Plan whilst promoting partnership working secure the same. 


4.78 The Local Plan promotes no alternatives to Policy SP04, stating that: 

“The policy provides a local perspective on the guidance set out in The NPPF 

which says in paragraph 179 that it is important that planned infrastructure 

is delivered in a timely fashion. It is important for local planning authorities to 

understand the borough wide development costs at the time Local Plan are 

drawn up. For this reason infrastructure and development policies should be 

planned at the same time, in the Local Plan. In paragraph 175 it says that 

where practical, Community Infrastructure Levy (CIL) should be worked up 

and tested alongside the Local Plan. This is the proposed approach of the 

Local Plan. Policy SP04 seeks to set the context for the Infrastructure Delivery 

Plan (IDP) that underpins the CIL charging regime with the former being an 

integral part of the Local Plan process. It is recognised that the development 

policies in the Local Plan will identify the quantum of development and 

provide the guidance for assembling the IDP.” 

4.79 As no alternative was put forward for Provision and Retention of Infrastructure and Services policy, 

therefore the only policy made available for consideration to SA/SEA is SP04. The policy requires the 

Council to work with its partners to secure appropriate contributions and provision of infrastructure 

and mitigation to support new development, secure the retention of existing infrastructure that meets 

local needs. 

4.80 At the Issues and Options stage considerable support was received for the proposal that development 

should help fund infrastructure and services, for example the Council’s Yellow Bus Scheme (transport 

for school children), general bus services and traffic management measures. 

4.81 During the evolution of the Local Plan, the Council considered the alternative to a policy on community 

infrastructure would be to rely on guidance as set out in Circular 05/05 and the use of the Community 

Infrastructure Levy (CIL) when it is introduced. It concluded that this would leave the provision of 

infrastructure to be dealt with on a case by case basis through the planning application process. The 


Council’s involvement in the Surrey collaboration project and its adoption of the “planning tariff” 

approach is supported by a policy LF10 in the SEP. This policy support s the small scale site tariff, and 

our proposed approach builds on this. 

4.82 It was considered important to address the provision of community facilities at the Local Plan level as it 

contributes towards maintaining the sustainability of locations and helps with community cohesion. 

However, given the fact that the Government has replaced Circular 05/2005 with the NPPF coupled 

with the fact that the CIL Regulations 2010 are being implemented following the adoption of the Local 

Plan – it is questionable as to the effectiveness of this policy that largely replicates higher legislation in 

terms of CIL, s106 Obligations (Planning Act) and Section 278 (Highways Act). 

4.83 To summarise, Policy SP04 requires new development to contribute to the delivery of infrastructure 

identified in the IDP whilst promoting partnership working to secure the same. 

Strategic Policy 5 (SP05) – Design 

4.84 Design has a key role to play in planning, in helping to meet the requirements of sustainable 

development, which is a key element of the NPPF and supported by the Sustainable Community 

Strategy. As the Borough will see an increase in built development, the Council requires that all 

development proposals respect and improve the quality of the environment in the Borough. 

Therefore, a Local Plan policy is necessary to require built design to be of a high quality. 

4.85 No alternative was put forward for the Built Design, Accessibility and Sustainable Construction policy, 

therefore the only policy made available for consideration to SA/SEA is SP05. The policy encourages the 

continued replication of the existing form and function of the built environment found in Runnymede, 

contributing to local distinctiveness and reducing the potential for crime and fear of crime. The policy 

also favours that proposals will be permitted that incorporate measures to minimise energy 

consumption. 

4.86 At the Issues and Options stage there was considerable support (over 80% agreed or strongly agreed) 

with the premise that future development should enhance the built and natural environment with high 

quality design. 

4.87 The Local Plan considered one policy option for Policy SP05 to deliver its objective, which has been 

summarised inTable 27. 



Assessment 

ID. 



Policy SP05 encourages the continued replication of the existing form and function of the built 

environment found in Runnymede. 



“The NPPF establishes that design should contribute positively to making 

places better for people. It adds (paragraph 58) that Local Plans should 

develop robust and comprehensive policies that set out the quality of 

development that will be expected for the area. Policy SP05 sets out how the 

Council has provided an approach that reflects local circumstances and links 

into the Council’s Urban Area Appraisal 2009. The provision of an alternative 

policy approach is not considered appropriate.” 

4.89 The policy team do consider that a main alternative approach could have been to rely on the now 

outdated government guidance, regional policies, the Surrey Design Guide or the production of 

supplementary documents regarding design issues. Having considered the importance of design locally 

and taking on board the advice of the Commission for Architecture and the Built Environment (CABE), 

the Council considered that it is important to have a policy in the Core Strategy that covers this issue, 

and this consideration has transferred to this Local Plan. 


4.90 However, the policy appears to be ‘all things to all men’, in that it main thrust is on the continued 

respect of the existing built, natural and historic environment with little scope for innovation that 

accompanies ‘exceptional quality design’ promoted by both the SCS and NPPF. 

4.91 To summarise, Policy SP05 encourages the continued replication of the existing form and function of 

the built environment found in Runnymede. 

Strategic Policy 6 (SP06) – Tourism, Recreation, and Leisure 

4.92 Tourism, recreation and leisure all have a key role in supporting sustainable communities, which is 

supported in the Council’s Sustainable Community Strategy. As the Borough has a number of tourist 

attractions and recreation and leisure facilities, the Council wishes to retain these to enhance residents 

quality of life and encourage visitors to the Borough by revitalising the area to create healthy and 

vibrant communities. Therefore, a Local Plan policy is necessary to plan for tourism, recreation and 

leisure in the Borough for the future. 





Assessment 

ID. 



This approach will (subject to other material considerations) provide encouragement for the 

continued use of heritage and waterways and the development of more hotel accommodation as 

contributors to the attractions of Runnymede. 

SP06‐A1 To support sustainable tourism, recreation and leisure in the area and to ensure that 

it remains a strong element of the Borough’s economy, the Council will: 

1. Support existing hotels and the improvement of the quality of existing visitor 

attractions where this can secure their continued viability without 

compromising the amenities of local residents or the objectives of the 

guidance in NPPF on green belt development; 

2. Promote all new built tourism, recreation and leisure development on 

previously developed land within or adjacent to town and district centres or 

visitor attractions; 

3. Require new tourism, recreation and leisure development to be accessible by 

public transport. 

4.94 Two policy approaches have been made available for consideration. SP06 supports the retention, 

improvement and provision of regional and local visitor attractions and facilities, and the promotion of 

local town centre focused facilities, whilst encouraging the promotion of heritage and waterways 

assets and protecting Green Belt (subject to other material considerations) as well as supporting the 

development of more hotel accommodation. 

4.95 SP06‐A1 promotes the use of previously developed land within or adjacent to town and district centres 

or visitor attractions for new tourism, recreation and leisure opportunities to be accessible by public 

transport. The alternative also supports existing hotels and the improvement of the quality of existing 

visitor attractions where this can secure their continued viability without compromising the amenities 

of local residents or the Green Belt. 

Strategic Policy 7 (SP07) – Thames Basin Heath Special Protection Area 

4.96 The NPPF requires that “Distinctions should be made between the hierarchy of international, national 

and locally designated sites, so that protection is commensurate with their status and gives appropriate 

weight to their importance and the contribution that they make to wider ecological networks” (par. 

113). The approach to be taken with regard to residential development proposals that could have an 

effect on the SPA has been agreed with Natural England. There is therefore no scope to give 

consideration to alternative approaches. 

4.97 Natural England’s objection to housing development within 5km of this SPA has been a major 

constraint to development over the past few years and had the effect of halting development in local 

authority areas adjacent to it, including Runnymede. The SEP set out a comprehensive policy covering 


the main approach that needs to be taken with regard to the SPA. Similar to all other Councils, 

Runnymede also put in place interim supplementary planning guidance on its approach to 

development in the SPA which it uses when determining residential development proposals in the 5km 

SPA zone of influence (Supplementary Planning Guidance in 2008 (Revised 2009)). 

4.98 The Local Plan considered one policy option for Policy SP07 to deliver its objective which has been 




Assessment 

ID. 


Strategic Policy 7 (SP07) – Thames Basin Heaths Special Protection Area 

Policy SP07 replicates advice approved by Natural England which is currently being followed by the 

Council that permits the approval of residential development with 5 km of the TBH SPA. 

Development at DERA is singled out as ‘exceptional’, in that it requires a bespoke solution. 


4.99 The policy replicates the advice as set out in its Supplementary Planning Guidance in 2008 (Revised 

2009). It identifies development at the DERA site as requiring a bespoke solution. 

4.100 To summarise, Policy SP07 replicates advice approved by Natural England and currently being followed 

by the Council that permits the approval of residential development within 5 km of the TBH SPA. 

Development at DERA is singled out as ‘exceptional’, in that it requires a bespoke solution. 

Strategic Policy 8 (SP08) – Employment Development 

4.101 Runnymede benefits from a strong local economy that has developed over the past 10 to 15 years and 

spread over a number of major sites as well as within its urban centres. Safeguarding these existing 

sites is seen as key to protecting its existing economy. 

4.102 At the Issues and Options stage of consultation 55% of respondents strongly agreed or agreed with 

more intensive high value business development throughout Runnymede, particularly in town centres 

and major employment locations. 

4.103 Over 70% were in favour of improving the quality of business space by allowing mixed use 

redevelopment and changes of use to existing business premises. However, there was no particular 

support for allowing those vacant business premises not situated in town centres or business areas to 

be redeveloped for housing. These results suggest that there is support for new and improved business 

development throughout the borough. 

4.104 The NPPF advises that the Government is committed to securing economic growth in order to create 

jobs and prosperity. Local authorities are required to support existing business sectors and to plan for 

new or emerging sectors likely to locate in their area. Runnymede Borough is part of the London Fringe 

area of the South East Region. One of the key themes of the Council’s Sustainable Community Strategy 

is Revitalisation, fostering economic prosperity and strong local businesses. In 2007, Runnymede 

Borough had approximately 47,500 jobs, reflecting a job growth rate of approximately 25% over the 

previous ten years. The Borough is also fortunate in having a much higher skilled and better qualified 

workforce than the South East region as a whole, 





Assessment 

ID. 



This approach promotes the continued safeguarding of the existing employment and town centre 

sites including DERA. Travel plans encouraging including home working provision will be 

encouraged. 



Assessment 

ID. 

SP08‐A1 


In view of the scale of provision to be made on the former DERA site a relaxed 

attitude will be taken towards the loss of employment land for alternative uses. 

Appropriate development of employment sites will be expected to follow the 

principles of sustainable development. 

4.106 The approach in SP08 promotes the continued safeguarding of existing employment sites and supports 

employment generating development in the town centres of Addlestone, Chertsey and Egham, 

providing there is no loss of retail floorspace. Also promotes the proposed employment floorspace at 

the former DERA site to meet a significant part of the identified need for additional floorspace. Travel 

plans will be encouraged to include approaches aimed at reducing travel journeys during peak times. 

4.107 SP08‐A1 takes a relaxed attitude towards the loss of employment land for alternative uses in view of 

the scale of provision to be made on the former DERA site. The appropriate development of 

employment sites will be expected to follow the principles of sustainable development. 

Strategic Policy 9 (SP09) – Sustainable Transport 

4.108 In the issues and options public consultation, over half of the respondents to transport related 

questions agreed residential development should make a financial contribution towards improving the 

Yellow Bus Scheme. Over half also agreed that all development should make a financial contribution 

towards improving existing (or providing new) bus services. 

4.109 Nearly half agreed that development should make a contribution towards improving paths, and cycle 

routes, and almost two thirds of the respondents agreed that large commercial developments, public 

buildings, and schools should have Travel Plans. Respondents also supported the suggestion that 

development should contribute towards improving the travelling facilities and services at railways 

stations. 

4.110 Specific comments also suggested that reducing car parking provision would only reduce travel demand 

by car if alternative arrangements such as car sharing were made. Points were also raised about the 

need to improve connectivity across the borough and with cross boundary areas. 

4.111 On the basis of its consultations, the Council considered it necessary to include a sustainable transport 

policy for Runnymede. An alternative would have been to prepare a sustainability principles policy. 

However, as transport is considered to be such a major issue for Runnymede, the approach was taken 

to set out the key elements or criterion required in order to work towards creating sustainable 

development. 

4.112 The purpose of the policy approach is therefore to improve accessibility by sustainable modes of 

transport to town centres, local centres, and facilities needed on an everyday basis to reduce reliance 

on the private car. 

4.113 The Local Plan considered one policy option for Policy SP09 to deliver its objective, and summarised in 

Table 31. 



Assessment 

ID. 



Policy SP09 effectively outlines a set of 8 ‘good to have’ criteria that will “…achieve sustainability…” 

that could apply to any location within the borough. 


4.114 To summarise, Policy SP09 effectively outlines a set of 8 ‘good to have’ criteria that will “…achieve 

sustainability…” that could apply to any location within the borough. 

Strategic Policy 10 (SP10) – Development and Flood Risk 


4.115 The planning system has an important role to play in reducing flood risk to people and property in 

Runnymede. The River Thames forms the eastern and northern boundaries of the Borough whilst the 

River Wey and the Basingstoke canal are to the south with the Chertsey Bourne and the Addlestone 

Bourne running from west to east through the Borough. 

4.116 Much of the east of the borough is within the lower Thames flood plain where the Environment Agency 

(EA) modelling has identified areas at high, medium and Low risk of flooding. There are no formal flood 

defences within the Borough, though some major structures do impede the flow of flood waters. 

4.117 The EA has produced a Thames Catchment Flood Management Plan (January 2009). This identifies the 

following mechanisms for managing future flood risk; 

 

 

 

 

Planning policies and allocations in Core Strategies should ensure that land is not released for 

development in the flood plain; 

Where regeneration and development of existing buildings is necessary in the flood plain, the 

development management process should look to reduce both the site specific and the 

overall risk of flooding; 

The construction of a flood relief channel through Runnymede that will protect existing 

settlements and clusters of properties that are at risk from flooding and reduce the overall 

impact of a major flood event; 

Improved flood warning, emergency planning and public education. 

4.118 The National Planning Policy Framework requires that planning authorities take a sequential approach 

to allocating land and permitting development, looking to the lowest risk areas first. In the case of 

Runnymede the three main urban settlement areas are all affected by flooding. Flooding represents a 

major issue in Runnymede and the Council has undertaken a strategic flood risk assessment. This 

defines the functional floodplain and is the area in which water flows at times of flood. This mainly 

affects undeveloped parts of the urban areas but does cover a large number of existing properties and 

businesses in the Egham and Chertsey areas. 

4.119 The NPPF provides a technical appendix addressing flooding issues. The Council does not wish to depart 

from national advice and this is set out in policy. 

4.120 Current data suggest that Runnymede has increased levels of commercial and residential properties at 

risk of flooding. In October 2011 there were 21,633 combined commercial and residential properties at 

risk of flooding. 

4.121 The Local Plan considered one policy option for Policy SP10 to deliver its objective. These have been 




Assessment 

ID. 



Policy SP10 largely refers to the implementation of the sequential and exception tests in PPS25. 

This guidance has now been replaced by NPPF Technical Guidance. 


4.122 No alternatives were considered relevant to this policy 


Section 5. 

Introduction 


5.1 The following sections (Section 5 – 16) reports on the assessment that has been undertaken by the 

Council’s assessment team. 

5.2 The natural environment and biodiversity receptor covers the effects on the natural environment in 

terms of plants, animals and geological assets and biodiversity in terms of habitats and species. This 

receptor captures the factors of ‘biodiversity, fauna and flora’ as required by the SEA Directive and UK 

SEA Regulations and incorporates a number of SA sustainable development objectives as outlined in 

Table 33. 

5.3 The receptor covers effects on the natural environment in terms of plants, animals and generalised in 

terms of habitats and species. A separate Habitats Regulations Assessment (HRA) report has been 

prepared covering the potential for the Local Plan to give rise to significant adverse impacts on sites of 

European or International nature conservation importance. 

5.4 Biodiversity is the term given to the diversity of life on Earth. This includes the plant (flora) and animal 

(fauna) species that make up our wildlife and the habitats in which they live. It also includes microorganisms 

and bacteria. Formally, the Convention on Biological Diversity defines biodiversity as: 

“The variability among living organisms from all sources including terrestrial, 

marine and other aquatic ecosystems, and the ecological complexes of which 

they are part, this includes diversity within species, between species and 

ecosystems 33 . 

5.5 This report will address compliance as required by the EU SEA Directive and the UK SEA Regulations 

2004. 

 

 

Listed as ‘biodiversity’, ‘fauna’ and ‘flora’ in paragraph (f) of Annex I to EU Directive 2001/42/EC 

Listed as ‘biodiversity’, ‘fauna’ and ‘flora’ in paragraph (6)(a),(d) and(e) of Schedule 2 to UK 

Statutory Instrument 2004 No.1633 

Applicable SA/SEA Objective/Factor 

Table 33 – Applicable SA/SEA Objective/Factor for ER01 

Objective/Factor 

Relevant SA Objective(s) 

No. Title Status 

SO08 

To encourage increased engagement in cultural activity across all sections of the community in 

Runnymede and promote sustainable tourism 

A 

SO18 Ensure that Runnymede is prepared for the impacts of climate change R 

SO19 To conserve and enhance the borough’s and region’s biodiversity A 

SO24 

To maintain and improve the water quality of the borough’s region’s rivers , ground waters and 

coasts , and achieve sustainable water resources management 

G 

Relevant SEA Factor(s) 

FA01 Biodiversity A 

FA04 Fauna A 

FA05 Flora A 

Current Policy Context 

33 CBD (1993). Convention on Biological Diversity [online] available at: http://www.cbd.int/convention/articles/?a=cbd-02 

(accessed 10 th February 2012). 


5.6 There are a range of policies relevant to the natural environment and biodiversity topic at the 

international, national, regional and local levels. The key policy documents are set out below and 

summarised in Table 34 – ER01 Policy Context Summary. 

Table 34 – ER01 Policy Context Summary 

Strategic Context – Sources of relevant objectives and 

goals 

Local Plan Relevant objectives 

and comment 


International Policy: Convention on Climate Change and Biological Diversity- 

Earth Summit, Ramsar Convention on Wetlands of International Importance 

European Policy: European Sixth Environmental Development Programme 

UK Policy: Working with the Grain of Nature, Thames Waterway Plan, England 

Rural Development Programme, National Planning Policy Framework 

Surrey Policy: Surrey Woodland Habitat Action Plan, Surrey’s Countryside, The 

Future: Action Plan Rural Strategy, Surrey Biodiversity Action Plan, Surrey 

Design, Surrey Urban Habitat Action Plan, BAP report on species and habitats 

review. 

Runnymede Policy: Runnymede Borough Council (Saved) Local Plan 2007 

European Law: European SEA Directive, European Directive Conservation of 

Natural Habitats, European Birds Directive 

UK Law: SEA Regulations, 

Objective: Protect and enhance biodiversity 

assets, parks and open spaces in Runnymede 

(7, 10). 

Comment: There is a general implicit objective 

to protect and enhance existing biodiversity 

assets and parks in Runnymede. Impacts on 

valuable environmental receptors and open 

spaces will be mitigated against. In terms of 

open spaces, where these have little 

community or environmental value at present, 

it is reasonable to expect that an approach to 

the protection of these assets will be agreed as 

part of regeneration objectives. 

International 

5.7 Internationally, the Convention on Biological Diversity (1992) signified the world community's growing 

commitment to sustainable development. It represented a dramatic step forward in the conservation 

of biological diversity, the sustainable use of its components, and the fair and equitable sharing of 

benefits arising from the use of genetic resources. 

5.8 The Convention on Wetlands of International Importance especially as Waterfowl Habitat (Ramsar 

Convention or Wetlands Convention) was adopted in Ramsar, Iran in February 1971 and came into 

force in December 1975. The Convention covers all aspects of wetland conservation and wise use 

concept. The UK ratified the Convention in 1976, and has generally chosen to underpin the designation 

of its Ramsar sites through prior notification of these areas as Sites of Special Scientific Interest (SSSIs). 

Accordingly, these receive statutory protection under the Wildlife & Countryside Act 1981(as 

amended). Government have issued policy statements relating to the special status of Ramsar sites. 

This extends the same protection at a policy level to listed Ramsar sites in respect of new development 

as that afforded to sites which have been designated under the EC Birds and Habitats Directives as part 

of the EU Natura 2000 network. 

5.9 The Sixth Environment Action Programme of the European Community 2002‐2012 (6th EAP) was 

adopted by the European Parliament and the Council on 22nd July 2002. It sets out the framework for 

environmental policy‐making in the European Union for the period 2002‐2012 and outlines actions that 

need to be taken to achieve them. Nature and Biodiversity is one of its four priority areas that 

promotes full integration of environmental protection requirements into all Community policies and 

actions and provides the environmental component of the Community's strategy for sustainable 

development. 

5.10 Other relevant legislative include: 

 

 

European Birds Directive (Directive 2009/147/EC – codified version of Directive 79/409/EEC) 

European Habitats Directive (Directive 92/43/EEC) 

National 

 

European SEA Directive (Directive 2001/42/EC) 

National Planning Policy Framework (NPPF) (2012) 

5.11 Section 11 NPPF: Conserving and enhancing the natural environment, paragraph 109 states that the 

planning system should contribute to and enhance the natural and local environment by: 


Protecting and enhancing valued landscapes, geological conservation interests and soils; 

Recognising the wider benefits of ecosystem services; 

Minimising impacts on biodiversity and providing net gains on biodiversity where possible, 

contributing to the Government’s commitment to halt the overall decline in biodiversity, 

including by establishing coherent ecological networks that are more resilient to current and 

future pressures; 

Prevent both new and existing development from contributing to or being put at 

unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water 

noise pollution or land instability; and 

Remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, 

where appropriate. 

5.12 NPPF paragraph 99 states that Local Plans should take account inter alia of the potential to avoid 

increasing the vulnerability importance of biodiversity conservation and enhancement to the 

promotion of sustainable development. It prioritises the need to avoid, mitigate and compensate for 

harm to biodiversity and incorporate ways to restore and enhance it. 

Natural Environment and Rural Communities Act 2006 

5.13 The Natural Environment and Rural Communities Act provide legislation for the protection of the 

natural environment in Britain. More specifically, it legislates in relation to nature conservation, 

wildlife, Sites of Special Scientific Interest, National Parks and Broads, rights of way and inland 

waterways. 

5.14 Other relevant legislative include: 

Regional 

 

 

Thames Waterway Plan, 

England Rural Development Programme, 

Regional Sustainability Framework 

The Regional Sustainability Framework (RSF) sets out a common vision, 25 objectives as set out in Table 5, and 

four priorities that will help guide development in the South East. 

The South East of England Plan Regional Spatial Strategy to 2026 (2009) 

5.15 The Regional Spatial Strategy for the South East of England (known as the South East Plan (SEP)) sets 

out the long term spatial planning framework for the region over the years 2006‐2026. The plan was to 

be a key tool to help achieve more sustainable development, protect the environment and combat 

climate change. 

County 

Surrey Biodiversity Action Plan (2008‐2013) 

5.16 The purpose of the Surrey Biodiversity Action Plan is to safeguard and enhance the biodiversity found 

in the urban areas of Surrey, and in doing so improve the quality of people’s lives through contact with, 

appreciation of and involvement in nature conservation. 

Surrey’s Countryside, the Future: Action Plan Rural Strategy (2003) 

5.17 This rural strategy, building on the previous countryside strategies, highlights key issues facing rural 

Surrey and through partnership working will promote action to deal with these issues, looking at the 

following areas: living in the countryside, working in the countryside and countryside conservation and 

access. 


Runnymede Borough Council Saved Plan (2007) 

5.18 The Runnymede Borough Local Plan (Second Alteration) was adopted in April 2001, and a number of 

the policies were saved in 2007. These policies are used to assess planning applications, providing they 

are conformant with the NPPF. The Local Plan (Second Alteration) will remain relevant until the new 

Local Plan is adopted. 


Current Baseline Condition 

5.19 The SEA Directive and UK SEA Regulations require that an account be given of the current and likely 

future composition and condition of the environment in the area covered by the proposed plan. The 

environmental baseline presented in this section has been compiled from available sources of primary 

and secondary data that in the main relate to RSF Indicators that have been monitored by the Council 

in one form or another since 2004. 

5.20 Where appropriate data is available from both electronic and printed sources, it has been used. 

However, it must be understood that the range and quality of data that is available at the level of the 

borough is in a number of instances limited. This can be a problem across a number of the 

environmental topics/receptors being assessed in the course of a SEA. In some cases, it has been 

possible to collect consistent good quality data at a slightly lower resolution such as the county, 

regional, and national levels. This data is presented in Appendix 11. 

5.21 This section looks at the existing baseline in terms of natural environment and biodiversity assets 

(including biodiversity designations, habitats and species) present within, and/or close to, Runnymede. 

The emerging Runnymede Local Plan will be required to incorporate policies that will continue to 

protect and enhance the existing habitats and species identified in the Borough and promote the 

extension and creation of new habitats. The Local Plan does not have an explicit policy to meet this 

requirement. 

5.22 Table 35 provides a summary of the key environmental issues and challenges that have been identified 

as having particular relevance to the Council’s emerging Local Plan. Those issues and challenges have 

been identified from the baseline environmental information as well as through discussion with various 

officers within the Council and external statutory and non‐statutory consultees. 

Table 35 – ER01 Summary Key Environmental Issues and Challenges 

Receptor 

[ER01] Natural Environment 

and Biodiversity 

Key Issues, challenges and potential responses for the Local Plan 

Summary: Flora, fauna are considered to be integral components of the Natural 

Environment and Biodiversity environmental receptor. Runnymede contains a relatively 

small but important biodiversity asset base in its protected sites and species in terms of 

lowland heathland and wetland, including its ancient woodland. 

Issues and Challenges: Runnymede is characterised by a diverse natural environment 

and is extensively wooded. The rate of species loss observed in Surrey over the last 

hundred years has been substantial, with 31 species of plants having become extinct. 

Losses have also been substantial in terms of natural habitats, such as lowland heath 

land, which has decreased in the county by 85% since 1762. There has also been a 

12% loss of all ancient woodland including semi-natural. 

Possible LP Response: The LP could bring forward proactive policies to minimise risks 

to habitat condition, fragmentation and loss that might arise as a consequence of the 

construction or use of new development and supporting infrastructure. Policies could 

include proactive management of nature conservation sites to preserve and enhance 

biodiversity. 

How LP Responded: The local plan does not include a policy set for Biodiversity. It 

could be argued that biodiversity would be protected through the other policies which 

focus development in existing town centres (with the exception) of DERA as well as the 

tourism policy (SP06). 


Sites of International Importance and European Importance 

5.23 Special Protection Areas (SPAs) are areas which have been identified as being of international importance for the breeding, feeding, wintering or the migration of rare 

and vulnerable species of birds found within the European Union Countries. In addition Special Areas of Conservation (SACs) contribute to the ‘Natura 2000’ network 

of habitats of European importance. Runnymede has a number of sites that have been designated as requiring protection under the terms of the European Wild Bird’s 

Directive Special Protection Areas (SPAs) and the Habitats Directive Special Areas of Conservation (SACs) and the Ramsar Convention of Wetlands of International 

Importance. These are: 

 

 

 

South West London Waterbodies SPA and Ramsar Site which includes Thorpe Park No1 Gravel Pit SSSI; 

Thames Basin Heath SPA (TBH SPA) which includes Chobham Common SSSI adjacent to Runnymede; 

Thursley, Ash, Pirbright and Chobham SAC which also includes Chobham Common SSSI and other components of the TBH SPA; and, 

Windsor Forest and Great Park SAC, which is composed of Windsor Forest and Great Park SSSI. 

5.24 Four European sites are considered relevant to this Local Plan are set out in the Table 36 and Table 37 below. 

Table 36 – European sites located within or close to Runnymede (Source: NE 2012) 

Site, 

Designation, 

and Code 

SLWB SPA 

[UK9012171] 

& RAMSAR 

[UK11065] 

WF & GP SAC 

[UK0012586] 

Area 

(ha) Reason for designation Site Condition 34 

828.14 Site of resident and migratory populations of European important bird populations 

of Gadwall (Anas strepera) and Shoveler (Anas clypeata). 

1687.26 The area is considered to support a significant presence of Atlantic acidophilous 

beech forests with Ilex and sometimes also Taxus in the shrublayer (Quercion 

roboripetraeae or Ilici‐Fagenion). As well as Old acidophilous oak woods with 

Quercus robur on sandy plains the site also hosts a small population of violet click 

beetles (Limoniscus violaceus). 

South West London Waterbodies records the following conditions in June 

2012: 

Thorpe No.1 Gravel Pit: favourable 

Staines Moor: 67% favourable and 33% unfavourable recovering 

Knight and Beesborough Reservoirs: favourable 

Wraysbury Reservoir: favourable 

Wraysbury and Hythe End Gravel Pits: unfavourable recovering 

Wraysbury No.1 Gravel Pit: unfavourable recovering 

Windsor Forest and Great Park SSSI records the following condition in June 

2012: 

46.45% is favourable 

53.55% is unfavourable recovering 

34 Current Condition (July 2006 Condition Survey) 

Page | 69 Runnymede BC DRAFT Sustainability Appraisal Report – Feb 2013

Site, 

Designation, 

and Code 

TBH SPA 

[UK9012141] 

Area 

(ha) Reason for designation Site Condition 34 

8274.72 The site consists of both dry and wet heathland, mire, oak, birch, acid woodland, 

gorse scrub and acid grassland. In addition it supports three breeding populations 

of lowland healthland bird species, Nightjar (Caprimulgus europaeus), Woodlark 

(Lullula arborea), and Dartford Warbler (Sylvia undata). 

Three components are also included within the TAP & C SAC. 

Chobham Common records the following conditions in June 2012: 

2.15% favourable, 92.29% unfavourable recovering and 5.56% unfavourable 

no change 

Horsell Common SSSI records the following conditions in June 2012: 

16.61% favourable, 60.89% unfavourable recovering , 22.5% unfavourable 

no change 

Ockham & Wisley Commons SSSI records the following condition in June 

2012: 

33.19% favourable and 66.81% unfavourable recovering 

TAP & C SAC 

[UK0012793] 

5138.00 Comprised of a series of large fragments of – dwarf gorse (Calluna vulgaris – Ulex 

minor) dry heathland, and transitions to wet heath and valley mire, scrub, 

woodland and acid grassland, including types rich in annual plants. 

This site supports the sole area of lowland northern Atlantic wet heath in southeast 

England. The wet heath at Thursley is mainly cross‐leaved heath – bog‐moss 

(Erica tetralix‐Sphagnum compactum) and contains several rare plants. 

Depressions on peat substrates of the Rhynchosporion are widespread, both in 

bog pools, mires and in flushes where they occur as part of a mosaic associated 

with valley bog and wet heath. 

Three components are also included within the TBH SPA. 

Chobham Common records the following conditions in June 2012: 

2.15% favourable, 92.29% unfavourable recovering and 5.56% unfavourable 

no change 

Ash to Brookwood Heaths: 13.47% favourable , 85.56% unfavourable 

recovering and 0.97% unfavourable declining 

Thursley , Hankley and Frensham Commons: 51.27% favourable , 48.61% 

unfavourable recovering and 0.11% area unfavourable no change 

Pirbright Common – status unknown 

Sites of National Importance 

5.25 Sites of Special Scientific Interest (SSSI) are considered to contain the country’s best wildlife and geological assets and need active management to maintain their 

conservation interest. There are 5 SSSIs located within Runnymede, which are set out in Table 37 below: 

Table 37 – SSSIs located within Runnymede (Source: Natural England June 2012) 

SSSI Area (ha) Reason for designation Condition 

Langham Pond 25.9 ha Langham Pond and its surrounding alluvial meadows lie on the Thames flood plain and represent a habitat of a type and quality 

unknown elsewhere in Southern England. The combination of alluvial soils and the calcareous influence of the chalk parent rock 

has led to the development of rich aquatic, marginal and meadow floras. The pond supports several nationally scarce 

invertebrates. Woodland on adjacent higher ground above the flood plain lies on London Clay and supports a rich community of 

breeding birds. 

63.21% 

favourable 

and 36.79% 

unfavourable 

recovering 


SSSI Area (ha) Reason for designation Condition 

Thorpe Hay 

Meadow 

Thorpe Park No.1 

Gravel Pit 

6.62 ha Thorpe Hay Meadow is a small, five‐sided meadow lying on the alluvial gravels of the Thames Flood Plain, surrounded by ditches 

and high hedges. Much of the surrounding land has been used for gravel extraction. The site is thought to be the last remaining 

example of a Thames valley hay meadow in Surrey. It contains a range of lime‐loving (calcicole) plants which are characteristic of 

this type of meadow. 

42.17 ha Thorpe Park No. 1 Gravel Pit is a former gravel pit which has now matured to a relatively stable ecological state, the banks being 

almost entirely dominated by trees and shrubs. The site also supports a number of other species of wintering waterfowl including 

goldeneye Bucephala clangula and smew Mergus albellus which occur regularly in small but significant numbers. 

100% 

favourable 

100% 

Favourable 

Basingstoke Canal 23 ha The Basingstoke Canal SSSI has three components – 

1. The navigation channel. 

2. Off‐channel areas, referred to in the Conservation Objectives as Off‐channel Reserves and comprising a collection of water 

bodies such as flashes and ponds associated with and mostly connected to the main channel, together with their marshy 

surrounding areas. 3. Pondtail Heath. 

At the time of its most recent re‐designation in 1995, the Canal SSSI had 87 species of native aquatic higher plant species 

(approximately half the UK total), five of which are nationally scarce and the canal may have been botanically the most species 

rich aquatic SSSI in England. 24 species of dragonfly were recorded on the canal, two of which are nationally rare. A range of other 

notable invertebrates have been found, both aquatic and in the marshy areas. Some of these also are scarce or rare. 

16.66% 

favourable , 

10.41% 

unfavourable 

recovering, 

45.31% 

unfavourable 

no change 

and 27.62% 

unfavourable 

declining 

Windsor Forest & 

Great Park 

(Units 10 & 11) 

100 ha A range of habitats are represented, from coniferous and mixed plantations through mature and over‐mature broadleaved 

woodland to wood pasture and parkland Relicts of the primary forest still survive as ancient oak pollards scattered throughout the 

Park and Forest. Veteran trees occur with a mosaic of unimproved and semi‐improved grassland and grass‐heath. Many of these 

ancient trees are over 500 years old and some reputed to be up to 800 years. Of equal importance, although not reaching such a 

great age, are numerous over‐mature beech trees Fagus sylvatica. Being partially hollow and decayed, the oaks and beech afford 

habitats for a number of extremely rare and specialised insects, particularly beetles, some of which are unknown elsewhere in the 

British Isles, as well as nesting sites for several species of hole‐nesting birds. Groves of hornbeam Carpinus betulus are favoured by 

hawfinches Coccothraustes coccothraustes including one of the largest wintering flocks of this species in Britain. 

100% 

Unfavourable 

Recovering 

(Units 10 and 

11) 

Sites of Local Importance 

5.26 Runnymede contains two Local Nature Reserves (LNR) (Chertsey Meads and Riverside Walk) and 51 Sites of Nature Conservation Importance (SNCI). 

Ancient Woodlands 

5.27 Runnymede contains approximately 201 hectares of ancient semi natural woodland and approximately 111 hectares of replanted woodland on ancient woodland. 



Evolution of Baseline in Absence of Plan 

5.28 The Surrey Biodiversity Action Plan identifies the range of habitats that are facing challenges 

currently and in the future. In respect to Runnymede, lowland heathland and wetland 

habitats are considered to be the most vulnerable. Development is likely to continue to affect 

these in the future. 

5.29 For the lowland heathland habitats the main problem historically has been succession to 

scrub and forest as a consequence of inappropriate land management practices. The key 

challenges for the habitat include continued encroachment by scrub, trees, bracken and 

grass, growing recreational pressures, growing demand for water leading to increased 

abstraction with adverse effects on wet heathland and mires, unplanned and uncontrolled 

burning, acidification and nitrogen enrichment from air pollution, habitat fragmentation and 

loss due to development, and conversion to forestry. 

5.30 For the wetland habitats of the borough the key challenges include the effects of 

development in respect of excessive abstraction, loss of habitat, changes in hydrology, and 

water quality etc. In addition the effect of changes in agricultural practices is not considered 

significant at this time due to the limited scale of operation within the borough. However, 

development changes in land drainage and hydrology, habitat fragmentation, degradation 

and loss, remain considerations for this habitat. These changes can result in deterioration in 

water suitability, as well as the effects of invasion of alien species on native fauna and flora, 

the effects of recreational use, and the effects of climate change. 

5.31 Woodland habitats also have key challenges which include: 

 

 

 

changes in management practices (i.e. neglect, inappropriate management, etc.), 

habitat destruction and fragmentation; 

changes in habitat composition (i.e. replanting with non‐native stock), climate 

change; and, 

changes in air quality, effects of damage (i.e. by squirrels, deer, rabbits, etc.) or plant 

disease, and the effects of invasive plant species (e.g. rhododendron, sycamore, 

etc.). 

5.32 For the wood pasture and parkland habitats the largest of these being Windsor Forest and 

Great Park SAC, the key challenges include: 

 

 

 

changes in management practices; 

changes in woodland structure (e.g. lack of younger trees, losses of old and ancient 

trees); and, 

changes in hydrology and water availability leading to drought stress, habitat 

isolation and fragmentation, loss of pasture habitat through conversion to arable 

and other land uses, invasion by non‐native species, and the effects of air pollution. 

5.33 For the open water and large reedbed habitats of the borough the key challenges include: 

 

 

 

 

changes in water quality and increasing risks of eutrophication; 

changes from plant to algal dominated waters, over‐stocking with fish; 

changes in the types and distribution of ponds, introduction of or invasion by alien 

species of plants and animals; and, 

changes in water abstraction and land drainage practices, climate change, and the 

lack of management or inappropriate management. 

5.34 For the grassland habitats (unimproved acid and neutral grasslands) of the borough the key 

challenges include: 

 

 

the intensification of agricultural practices; and, 

changes in traditional management practices, development and recreational 

pressures, atmospheric pollution and climate change. 


Potential Impact Pathways 

Impact Pathway NEB1: Impact on habitats and species due to land take 

5.35 Further development of the borough’s assets and infrastructure could, depending on location 

and scale, result in the loss / fragmentation of areas of natural habitat as a consequence of 

land take. The scale and extent of any adverse effects would depend on the location, 

maintenance, and use of the new development and the nature conservation characteristics 

and value of the area affected (i.e. designated nature conservation sites). 

Impact Pathway NEB2: Impact on habitats and species due to changes in air quality 

5.36 The continued use and development of the transport network and carbon based energy 

provision will give rise to atmospheric emissions, which contribute to air pollution at the local 

and regional scales. These pollutants have impacts on sensitive habitats (e.g. nitrogen 

deposition on heathland habitats such as Thursley, Ash, Pirbright and Chobham SAC). The 

scale and extent of adverse effects depend on the location and contribution of the sources 

such as proximity to an intensively used transport route or other emission source and the 

sensitivity of the surrounding natural environment to emissions to air. 

Impact Pathway NEB3: Impact of habitats and species due to changes in water quality 

5.37 Further development of the borough’s assets and infrastructure could, depending on location 

and scale, result in changes in water quality and quantity and lead to an increased risk of 

eutrophication. Water habitats are vulnerable to the water table levels which are affected by 

abstraction volumes required to support an increased population. Climate change coupled 

with a lack of management (or inappropriate management) will exacerbate this risk. 

Impact Pathway NEB4: Impact of habitats and species due to disturbance 

5.38 The continued use of existing development and infrastructure, and its maintenance and 

further development can result in the disturbance of species due to recreation, noise, 

vibration, and light pollution. The scale and extent of any adverse effects depend on the 

location and scale of any new development or maintenance activities and the location and 

vulnerability and sensitivity of the ecological components to the disturbance being produced. 

Consideration of Implications of Plan and Alternatives on Receptor ER01 

Policy LP01: Strategy for the Location of Development 

5.39 Three policy approaches within the SEA have an overall uncertain impact on ER01 (Appendix 

4). However, this overall conclusion masks the adverse effect on impact pathway NEB1, NEB2 

and NEB4. Whilst this raises concern it is an inevitable consequence of increasing the 

quantum of development outside the urban area. It is noted that the concentration of 

development in Addlestone significantly reduces the impact on the receptors. 

5.40 The Level 6 HRA assessment has provided the Council with sufficient evidence for it to 

ascertain no adverse affect on the integrity of either Thames Basin Heaths SPA or Thursley, 

Ash, Pirbright and Chobham SAC as a result of the implementation of the Local Plan. The 

Level 6 HRA Report is presented in Appendices 8 and 9. 

5.41 Having regard to the conclusion of SA in Appendix 3, overall, all the policy approaches have a 

mixed beneficial impact. It is noted that the impact on the air quality is adverse (RSF 16), 

whilst it also has a negative impact on the desire to conserve and enhance the region’s biodiversity 

(RSF 19). 

5.42 The different approaches overall do not have a significantly different impact on this pathway. 

Policy LP02: Housing Provision and Distribution 

5.43 All the policy approaches in the SEA (Appendix 4) have at least an uncertain impact, but LP02‐ 

A3(a) has an adverse impact on all the pathways. It is inevitable that development will have 

varying degrees of impact on the natural environment and bio‐diversity. It will always be a 

balance to ensure that the impact on ER01 is considered with the requirements for future 

development. It is inevitable that an unplanned approach to development (a no plan 


scenario) will have a similar impact on the receptors. It will invariably come down to the 

appropriate scale of development to meet the needs of future generations. 






neutral impact. It is noted that the impact on RSF 14 (the reuse of urban land) is undermined 

by the green field alternatives, whilst the impact on air quality is adverse (RSF 16) for all 

alternatives. There is again an adverse impact on RSF 20 – the impact on the natural and 

heritage environment. The need to accommodate growth will have a consequence for all the 

receptors, but the impact of the alternatives is not different for planned or unplanned 

growth. 

5.46 LP02 in the SA consideration does not have a different impact to the alternatives. They are all 

neutral. 

Policy LP03: Development in Addlestone Urban Area 

5.47 With regard to the SEA (Appendix 4) LP03‐A1 and LP03‐A2 have an uncertain impact, whilst 

LP03 has a neutral impact. The impact of the alternatives on the pathways is generally 

neutral, but LP03‐A1 and LP03‐A2 have an adverse impact on NEB2 – effect on habitats due 

to changes in air quality. This is overall a contained impact as the development is 

concentrated in the urban area. However, any development will have a wider impact on the 

natural environment and this is difficult to avoid as a result of the overall change in air 

quality. 


neutral impact. The impact on air quality is uncertain/adverse (RSF 16) for all alternatives and 

this is reflected on the impact on the pathways. The need to accommodate growth will have a 

consequence for all the receptors, but the impact of the alternatives is not different for 

planned or unplanned growth. 

Policy LP04: Development in Egham / Englefield Green Urban Area 

5.49 The preferred options are noted to have a neutral impact on this receptor and individual 

with regard to the SEA (Appendix 4) 


neutral impact. The need to accommodate growth will have a consequence for all the 


growth. 

5.51 The overall impact of the alternatives in the SA consideration does not have a different 

impact, i.e. positive. 

Policy LP05: Royal Holloway UOL 

5.52 The SEA conclusion (Appendix 4) for policy LP05 –A is that the policy will have an uncertain 

effect overall, whereas LP05‐A1 will have a neutral effect and LP05‐A2 will have an adverse 

effect. 

5.53 With regard to impact pathway NEB1, impacts on habitats and species due to land take, the 

LP05 –A and LP05‐A2 both score an adverse effect, whereas LP05‐A1 scores a neutral effect. 

This is because LP05‐A1, to retain the college in the Green Belt, will not involve any further 

land take, and therefore the status quo is maintained with regard to habitats and species on 

the site. LP05 and LP05‐A2 will both involve land take and therefore habitats and species will 

be affected, whether the development is the subject of a master plan or not. 

5.54 NEB2, impacts on habitats and species due to change in air quality scored a neutral effect for 

LP05 – A and LP05‐A1, and an adverse effect for LP05‐A2. LP05‐A1 maintains the status quo, 

which explains the neutral score, and although LP05 will involve development, the effects on 

air quality will be minimised by the control afforded by the masterplan (e.g. student numbers 


and cars on the site). LP05‐A2 will not afford a sufficient level of control to be sure at this 

stage that air quality will not be affected, and so scores an adverse effect. 

5.55 NEB3, impact on habitats and species due to changes in water quality, again scores a neutral 

effect for the preferred option and LP05‐A1, and an uncertain effect for LP05‐A2. The reasons 

for these scores are the same as for NEB2, but the lack of information available for the site at 

this stage means that an uncertain effect is recorded for LP05‐A2. 

5.56 NEB4, impacts on habitats and species due to disturbance, records an uncertain effect for 

LP05 – A because even with a masterplan more details of locations and habitats will be 

required to guide the development. LP05‐A1 scores a neutral effect because of the 

presumption against development afforded by green belt policy, and LP05‐A2 records an 

adverse effect because having no control over the comprehensive development of the site 

will inevitably lead to disturbance. 

5.57 Overall, with regard to the SEA, LP05‐A1 scores slightly better than LP05 – A , having a 

neutral rather than an uncertain effect. However, LP05‐A1 would not allow the college to 

expand and this may lead to it moving from the Borough, which would have a negative effect 

on the Borough’s economy. LP05‐A2 gives rise to an adverse effect because without the 

green belt designation there will be little control over the level of expansion, inevitably giving 

rise to an adverse impact on biodiversity. 

5.58 With regard to SA, overall, LP05 has a mixed effect on SA objectives, and the other 

alternatives both have a neutral effect. With regard to RSF objectives, the preferred option 

and LP05‐A2 have a beneficial effect on RSF 8 (encourage increased engagement in cultural 

activity and promote sustainable tourism) but an adverse effect on RSF 20 (protect and 

enhance the region’s countryside and historic environment) whereas LP05‐A1 has a neutral 

effect. This reflects the fact that the preferred option and LP05‐A2 would involve 

development whereas LP05‐A1 maintains the status quo by retaining the site in the Green 

Belt, thereby having no effect. For RSF 19 (to conserve and enhance the region’s biodiversity) 

the LP05 has an adverse effect and LP05‐A2 a significantly adverse effect, whereas LP05‐A1 

again has a neutral effect. However, as with the SEA, these particular RSF objectives do not 

take account of the economic benefits of facilitating the expansion of the university in the 

borough, whilst retaining control over the level of development on the site. The overall SA 

score (mixed) does take this into account, although the lack of weighting of the objectives 

does not reflect the priorities for the Borough. 

Policy LP06: Development in Chertsey Urban Area 

5.59 With regard to the SEA (Appendix 4) receptor ER01, the overall conclusion for the LP06 ‐ A is 

a neutral effect on the receptor. This is because it has been judged that natural environment 

and biodiversity are unlikely to be of significant concern in the settlement area. 

5.60 The overall SA concludes that the impact of the policy is mixed positive for both alternatives 

(Appendix 3). With regard to the individual RSF’s it is the policy option LP06‐ A1 that has an 

uncertain impact on RSF 12 (a diverse economy), RSF 16 ((reduce air pollution), RSF 17 

(climate change), RSF 22 (reduce impact on consumption of resources) and RSF 23 (reduce 

waste). Notwithstanding these uncertain issues the overall impact is similar, especially when 

compared with the outcome of the SEA. 

Policy LP07 – Development in Virginia Water 

5.61 The policy option LP07 – A has a neutral impact, whilst the uncertain impact of policy option 

LP07‐ A1 is noted (Appendix 4). LP07 ‐ has a neutral or beneficial affect on the pathways, 

whilst policy option LP07‐A1 has an uncertain impact on the pathways due to land take , 

changes in water quality and species disturbance. 


neutral/positive impact. The need to accommodate growth will have a consequence for all 

the receptors, but the impact of the alternatives is not different for planned or unplanned 

growth. 


5.63 LP07 overall in the SA consideration does not have a different impact to the alternative, apart 

from being more positive. 

Policy LP08: The former DERA site, Longcross 

5.64 Policy option LP08 has an adverse impact, whilst LP08‐A1 to LP08‐A3 have an uncertain 

impact. When considering the affect on the pathways policy option LP08 has s significant 

affect on NEB1 and 4 and an adverse affect on NEB2. However, policy option LP08‐A1 and 

LP08‐A1 have an adverse affect on NEB1 

5.65 When considering the affect on the pathways it is highlighted that LP08 will have an impact 

on habitats due to land take (NEB1), air pollution (NEB2) and disturbance (NEB4). Alternatives 

LP08‐A1 and LP08‐A2 impact on habitats due to land take. LP08‐A3 has uncertain impacts on 

NEB1, 3 and 4. 

5.66 The nature of the proposal to develop the former DERA site will have a significant impact due 

to the nature of the site compared to the other policy options. Whilst the impact will need to 

be assessed in the round when all the affects on the receptors are examined, it is considered 

that this will be a key issue that will require detailed consideration to enable any scheme to 

proceed. 



Ash, Pirbright and Chobham SAC as a result of the implementation of the Local. The Level 6 

HRA Report is presented in Appendices 8 and 9. 

5.68 Each of the alternatives will impact on the receptors given the quantum of development. 

Some impact on the receptors differently depending on location, but the overall assessment 

does not give rise to a clear preferred policy approach. 

5.69 The overall conclusion of the SA is that the policy option LP08 is mixed but the other policy 

options are all neutral. The overall SEA conclusion is that the policy options LP08, LP08‐A1 

and LP08‐A3 are uncertain and LP08‐A2 is neutral. Within the context of the SA policy option 

LP08 has a significant adverse affect on RSF 9 (create employment), RSF 16 – significantly 

adverse (improve air pollution), but the other RSF are generally well accommodated. 

However, the policy options LP08‐A1 and LP08‐A2 have an adverse affect on RSF 14 (improve 

reuse of land/building)., RSF 19 ((enhance biodiversity), and RSF 20 protect countryside), 

Alternative A3 has an affect on RSF 17 (impact on climate change). There are therefore a 

diversity of impacts from policy options. In conclusion the option LP08 is more favourable. 

Compared to the SEA conclusions the options are generally uncertain, but the LP08‐A2 is 

neutral reflecting the spread of development across green field sites. 

Policy SP01: Green Belt Areas 

5.70 The preferred option does not have any alternatives. The whole strategy of the Plan depends 

upon some significant development schemes coming forward in the green belt to meet future 

demand. 

5.71 No SEA Discussion 

5.72 No SA Discussion 

Policy SP02 – Affordable Housing 

5.73 With regard to the SEA (Appendix 4) the impact of policy options SP02 and SP02‐A1 is 

neutral on the ER01. However, the impact of SP02‐A2 is adverse and this is reflected in the 

affect on the pathways that is adverse on all four elements. 

5.74 Having regard to the conclusion of SA in Appendix 3, overall, the policy approaches SP02 and 

SP02‐A2 have a positive impact. However, there is an uncertain affect form the option SP02‐ 

A1 on RSF 1 (providing decent homes), RSF 2 (improving health), RSF 3 (reducing poverty) , 

RSF 6 (creating vibrant communities), and RSF 9 and 11 (stimulating the economy). The 

option SP08‐A1 is less acceptable in the SA analysis. However, A does have an affect on RSF 

16((reducing air pollution). The need to accommodate affordable housing will have a 


consequence for all the receptors, but the impact of the alternative SP02‐A1 is uncertain and 

so the options SP02 and SP02‐A2 are clearly more acceptable. 

5.75 The impact of the policy options in the SA consideration does not have an overall different 

impact (Appendix 3). However, the SEA with regard to SP02‐A2 has an adverse impact on the 

pathways. 

Policy SP03: Gypsy and Travelling Populations 

5.76 With regard to SEA receptor ER01, the overall conclusion for SP03 is an unknown effect on 

the receptor (Appendix 4). This is because it has been judged that Impact NEB1 ‐ land take 

and NEB3 ‐ water quality cannot be known at this time in the absence of firm proposals. 

Policy option SP03‐A1 records a neutral impact, as no pathway will be affected on account of 

there being no development involved. However, the alternative of not providing any traveller 

provision is clearly not meeting need and the social needs must outweigh the negative impact 

on ER01. 


Policy SP04: Provision and Retention of Infrastructure and Service 

5.78 SP04 does not have any alternatives. Overall in terms of SEA (Appendix 4) SP04 is deemed to 

have a positive effect on the environmental receptors. The assessment team considered that 

implementation of this policy would result in relevant beneficial effects in terms of ER01, 

ER05 and ER06. 

5.79 In terms of SA, the assessment team concluded that overall implementation of this policy 

would potentially result in mixed effects (Appendix 3), with broadly beneficial effects 

recorded against individual sustainability objectives. 

Policy SP05: Design 

5.80 With regard to SEA (Appendix 4) receptor ER01, the overall conclusion for the policy is a 

mixed effect on the receptor. Policy SP05 has a neutral effect on impact pathway NEB1 

(impacts on habitats and species due to land take), as land take (in relation to habitats and 

species) is not necessarily caused by the design of a proposal as design is primarily concerned 

with the quality of what is proposed. 

5.81 Policy option SP05 has a beneficial effect on NEB2 (impacts on habitats and species due to 

changes in air quality) as well designed development that the policy requires can enhance air 

quality. 

5.82 Policy option SP05 has a beneficial effect on impact pathway NEB3 (impacts on habitats and 

species due to changes in water quality), as high quality design that the policy requires may 

make improvements to water quality. 

5.83 Policy option SP05 has a neutral effect on impact pathway NEB4 (impacts on habitats and 

species due to disturbance). This is because the quality of design does not itself impact on 

disturbance, as this policy focuses on the quality of what is proposed, rather than what is 

proposed or its location. 


Policy SP06: Tourism, Recreation and Leisure 



Policy SP07: Thames Basin Heaths Special Protection Area 

5.87 There is no reasonable alternative to the policy, however, the overall impact on the receptors 

is neutral tested mechanism to facilitate development (Appendix 4). 



Policy SP08 – Employment Development 

5.89 With regard to the SEA (Appendix 4)SP08 has a mixed /neutral impact. The affect of policy 

approach SP08‐A1 on the pathways is neutral or positive. 


neutral/positive impact. However, there is an adverse affect form the alternative SP08‐A1 on 

RSF 3 (reducing poverty) , RSF 6 (creating vibrant communities), RSF 9 and 11 (stimulating the 

economy), and RSF 12 (developing a dynamic economy), RSF 13 (maintaining a skilled 

workforce), RSF 21 (improving transport), SP08‐A1 is less acceptable in the SA analysis. The 

need to accommodate growth will have a consequence for all the receptors, but the impact 

of the alternatives is different in a negative way and so SP08 is clearly more acceptable. 

5.91 The impact of the alternatives in the SA consideration does not have an overall different 

effect. 

Policy SP09: Sustainable Transport 

5.92 With regard to SEA receptor ER01 (Appendix 4), the overall conclusion for the policy is a 

neutral effect on the receptor by policy approach SP09. SP09 has a neutral effect on impact 

pathway NEB1 (impacts on habitats and species due to land take), as the policy does not have 

direct impacts on habitats and species due to the taking of land, and the location is not 

specified to assess land take impacts as the policy is focused on sustainable transport 

provision associated with development, rather than the development itself. 

5.93 Policy approach SP09 has a beneficial effect on NEB2 (impacts on habitats and species due to 

changes in air quality) as the policy seeks development that generates a high number of trips 

to be accessible by public transport, and includes measures to reduce car use as appropriate, 

therefore the policy’s negative impacts on air quality are low. 

5.94 Policy approach SP09 has a neutral effect on impact pathway NEB3 (impacts on habitats and 

species due to changes in water quality), as the policy does not have direct impacts on 

habitats and species due to its having any effects on water quality. 

5.95 Policy approach SP09 has a neutral effect on impact pathway NEB4 (impacts on habitats and 

species due to disturbance), as the policy does not have direct impacts on habitats and 

species due to disturbance, as the policy focuses on sustainable transport provision 

associated with development, rather than the development itself, and therefore no locations 

are specified to ascertain if will be associated disturbance of habitats and species. 

5.96 Overall, Policy approach SP09 has a mixed effect on SA objectives. With regard to RSF 

objectives, the policy has a neutral, beneficial or significantly beneficial effect in SA terms, 

with the exception of RSF8 (to encourage increase engagement in cultural activity across all 

sections of the community in Runnymede, and promote sustainable tourism), where the 

policy has an uncertain effect on the objective. This effect is seen because promoting 

sustainable tourism is difficult when the tourism policy does not require recreation and 

leisure facilities to be accessible by public transport. In addition, the transport policy although 

has sustainable principles, makes no specific requirement for tourism facilities to be 

accessible by public transport, therefore its effects would be unknown. 

Policy SP10: Development and Flood Risk 

5.97 No alternatives. 

5.98 No SEA Discussion. 

5.99 No SA Discussion. 


Table 38 – Summary of Local Plan Policies and alternatives on ER01 

No. Policy Impact 35 

Location Policies L3 L4 L5 L6 

LP01 Strategy for the Location of Development / ? 0 

Alternative LP01‐A1 ? ? 

Alternative LP01‐A2 0 ? 

LP02 Housing Provision and Distribution 0 ? 0 


Alternative LP02‐A2 (a) ? ? 

Alternative LP02‐A2 (b) 0 ? 

Alternative LP02‐A2 (c) 0 ? 

Alternative LP02‐A3 (a) ? 


LP03 Development in Addlestone Urban Area / 0 


Alternative LP03‐A2 / ? 

LP04 Development in Egham / Englefield Green Urban Area / 0 

Alternative LP04‐A1 0 0 

LP05 Royal Holloway UOL 0 ? 


Alternative LP05‐A2 0 

LP06 Development in Chertsey Urban Area / 0 


LP07 Development in Virginia Water / 0 


LP08 The former DERA site, Longcross / 0 

Alternative LP08‐A1 0 ? 

Alternative LP08‐A2 0 ? 

Alternative LP08‐A3 0 ? 0 


SP01 Green Belt Areas 0 

SP02 Affordable Housing 0 0 

Alternative SP02‐A1 0 0 

Alternative SP02‐A2 0 

SP03 Gypsy and Travelling Populations 0 ? 


SP04 Provision and Retention of Infrastructure and Service 

SP05 Design / 

SP06 Tourism, Recreation and Leisure 0 ? 

Alternative SP06‐A1 / 

SP07 Thames Basin Heaths Special Protection Area / 0 

SP08 Employment Development 0 0 

Alternative SP08‐A1 0 / 

SP09 Sustainable Transport / 0 

SP10 Development and Flood Risk / 0 

35 Impact Key (See: Table 8 – Impact classifications used for the SEA) 

Significant 

Beneficial 


Significant 

Adverse 

/ 0 ? 


Cumulative Effects Assessment 

5.100 The natural environment and biodiversity receptors are potentially impacted from a number 

of sources. ER01 encompasses biodiversity, fauna and flora into a single receptor. In terms of 

cumulative effects, analysis suggests that these receptors are most sensitive to effects arising 

from the following impact pathways as detailed in Table 39. 

Table 39 – CEA ER01 

ER Group IP/MfE Type of CE Additive or Synergistic 

ER01 – Natural 

Environment 

and Biodiversity 

ER04 – Water 

Resources and 

Management 

ER05 – Air 

Quality 

NEB1: Land Take Fragmentation Additive 

NEB2: Air Quality Cross‐boundary Synergistic 

NEB3: Water Quality Cross‐boundary Additive 

NEB4: Disturbance Time crowding Additive 

WRM1: Water Flow Time lag Additive 

WRM2: Water Quality Cross‐boundary Synergistic 

WRM3: Water Demand Cross‐boundary Additive 

AQ1: Transport Emissions Cross‐boundary Synergistic 

AQ2: Construction Emissions Cross‐boundary Synergistic 

AQ3: Energy Emissions Cross‐boundary Synergistic 

5.101 Table 40 – ER01 CEA Summary suggests that overall the Local plan potentially results in a 

considerably negative cumulative effect on this receptor as it would appear to have the 

capacity to act spatially across boundaries in terms of both air and watersheds. This is 

particularly concerning as the ability of the plan to respond is extensively curtailed. 

Table 40 – ER01 CEA Summary 

ER01 

ER04 

ER05 

IP/MfE 

LP01 

LP02 

LP03 

LP04 

LP05 

LP06 

LP07 

LP08 

SP01 

NEB1 0 0 0 0 0 ? 0 0 0 0 0 

NEB2 0 0 0 0 0 0 0 ? 0 0 0 

NEB3 0 0 ? 0 0 

/ 

0 0 0 

NEB4 0 0 ? 0 0 0 ? 0 ? 0 0 ? 

WRM1 0 0 0 0 0 0 0 0 0 0 0 0 

WRM2 0 0 0 0 0 0 0 0 0 0 0 0 0 0 ? 

WRM3 ? 0 0 0 0 0 0 0 0 ? 0 0 

/ 

/ 

/ 

AQ1 ? 0 0 0 0 0 0 0 

/ 

/ 

/ 

AQ2 ? 0 0 0 0 0 0 0 

/ 

/ 

AQ3 0 ? 0 0 ? 0 0 0 0 0 0 0 

/ / 

? ? 0 ? ? 0 0 ? 0 0 0 ? 0 0 ? ? 

SP02 

SP03 

SP04 

SP05 

SP06 

SP07 

SP08 

SP09 

SP10 

5.102 Given the spatial extent of the areas of influence over which the identified potential 

cumulative effects could originate from, coupled with the Local Plan’s inability to control 

these effects, it is not considered appropriate nor beneficial for the CEA to go any further at 

this time. To do so would be to place a disproportionate burden on the Council. 

Mitigation/Enhancement Recommendations 

5.103 Mitigation and enhancement is suggested through the July 2012 meetings (See: Appendix 2) 

whereby the policy set LP01 ‘Strategy for the Location of Development’ notes the opportunity 

to improve water quality at proposed locations for development. The opportunity to improve 

water quality is also noted in LP03 ‘Development in Addlestone’, LP06 ‘Development in 

Chertsey’, LP07 ‘Development in Virginia Water’’ 

5.104 It is noted that the policy set SP05 ‘Design’ notes that good design can enhance air quality. 


Suggested Monitoring Regime 

Table 41 – Suggested Monitoring of Impacts and Effects of the LP on ER01 

Indicator to be monitored 

Frequency 

of data 

collection 

When should remedial 

action be taken? 

What remedial action should 

be taken? 

Extent and conditions of key habitats for 

which biodiversity action plans (baps) 

have been established (LSF Indicator) 

Rivers of Good or Fair Chemical and 

biological water quality (LSF Indicator) 

Annual 

Annual 

When data shows a 

negative trend. 



Population of wild birds (LSF Indicator) Annual When data shows a 


Condition of sites of special scientific 

interest (LSF Indicator) 

Annual 



Raise query with 

responsible 

department/authority 


responsible 



responsible 



responsible 



Section 6. 

Introduction 

[ER02] Welfare, Health and Well‐being 

6.1 The Welfare, Health and Well‐being receptor covers effects on the welfare, health and well 

being of the local population, including perceived risks to people’s health and well‐being (e.g. 

noise, odour, light pollution, etc.) or of ill‐health or injury (e.g. increased exposure to air 

pollution), and the capacity to create opportunities for people to engage in activities that 

could give rise to health benefits. The receptor covers the topic of ‘population’ and ‘human 

health’ as required by the European Directive and UK Regulations on the environmental 

assessment of plans and programmes and incorporates a number of SA sustainable 

development objectives as outlined in Table 42. 

6.2 The risks to the welfare, health and well‐being receptor directly associated with land use 

development arise as a number of consequences of use of development and infrastructure 

exacerbated by cumulative and synergistic lifestyle risks. Use of the highways network 

increases the exposure to air pollution whilst the use itself contributes to the hazard. 

Conversely, using the highways network can facilitate gainful employment which can improve 

well‐being and life chances. 

6.3 This receptor will also take account of the effect of being a Runnymede resident has on the 

individual ‘Life Chances’ to improve their quality of life and the effect that the SCS can have 

on this factor. 

Table 42 – Applicable SA/SEA Objective/Factor ER02 




SO01 

SO02 

SO03 

SO04 

To ensure that everyone has the opportunity to live in a decent, sustainably 

constructed and affordable home suitable to their need 

To improve the health and well being of the population and reduce inequalities 

in health’ 

To improve the health and well being of the population and reduce inequalities 

in health 

To raise educational achievement levels across the borough and develop 

opportunities for everyone to acquire the skills needed to find and remain in 

work 

SO05 To reduce crime and perceptions of disorder G 

R 

G 

A 

G 

SO06 

SO07 

SO09 

SO10 

SO12 

SO13 

To create and sustain vibrant communities which recognise the needs and 

contributions of all individuals 

To improve accessibility to all services and facilities including the countryside 

and the historic environment 

To ensure high and stable levels of employment so everyone can benefit from 

the economic growth of the borough 

To sustain economic growth and competitiveness across the borough by focusing 

on the principles of smart growth: raising levels of enterprise , productivity and 

economic activity 

To develop a dynamic , diverse and knowledge based economy that excels in 

innovation with higher value impact activities 

To develop and maintain a skilled workforce to support long‐term 

competitiveness of the region 

A 

G 

G 

A 

G 

A 





SO15 

To reduce the risk of flooding and the resulting detriment to public well‐being, 

the economy and the environment 

SO16 To improve air quality and ensure it continues to improve R 


R 

SO24 

To maintain and improve the water quality of the region’s rivers , ground waters 

and coasts , and achieve sustainable water resources management 

A 


FA01 Population A 

FA02 Human Health G 


6.4 There is a range of policies relevant to welfare, health and well being at the international, 

national, regional and local level. The key policy documents are set out below and 




goals 

Local Plan Relevant 

objectives and comment 

[ER02] Welfare, Health and Well‐being 

International Policy: United Nations Convention on Human Rights 

UK Policy: Sport and Recreation , Health and Neighbourhood Renewal 

Guidance, UK Climate Change Programme, Air Quality Strategy for England, 

Game Plan- A Strategy for Delivering Sport in England, Gypsy and Traveller 

Circular 01/2006, PPS10-Planning for Sustainable Waste Management, 

National Planning Policy Framework 

Regional Policy: The South East Plan, The South East Region Inclusion 

Statement 

Surrey Policy: The Surrey Waste Plan, Surrey Climate Change Strategy, Surrey 

Strategic Partnership Plan. 

Runnymede Policy: Runnymede Sustainable Community Strategy and 

Corporate Plan, Runnymede Statement of Community Involvement, Retail 

needs study , Runnymede equality study, Strategic flood risk assessment , 

Runnymede equality policy and action plan, Runnymede homelessness 

strategy, Runnymede housing strategy, Runnymede community safety 

strategy, Runnymede fuel poverty strategy and Runnymede private sector 

housing renewal strategy. 

UK Law: Human Rights Act 

European Law: European Nitrates Directive 

Objective: Support people in need, 

tackling income and health 

inequalities, and provide activities 

to keep older people fit and 

healthy. Create a vibrant borough 

with re-invigorated town centres 

(3, 4, 5, 6, 7, 13, 14 and 15). 

Comment: Creating a vibrant 

borough with town centres reinvigorated 

will create 

opportunities for economic 

development and boost local 

employment. Continuing to provide 

affordable housing in a variety of 

different tenures and sizes will 

address well-being, and will target 

support for people in need will 

continue to address existing 

inequalities in Runnymede. 

International 

United Nations Conventions on Human Rights (1948) 

6.5 The United Nations Convention on Human Rights provides legal protection for privacy, rights, 

freedom of opinion and freedom of assembly. 


European Nitrates Directive (1991) 

6.6 The European Nitrates Directive aims to protect water quality across Europe by preventing 

nitrates from agricultural sources polluting ground and surface water and by promoting the 

use of good farming practices. 

National 

Human Rights Act (1998) 

6.7 The Human Rights Act requires public authorities to comply with the Human Rights 

Convention. Individuals have the right to take court proceeding if they think that their 

convention right have been breached. 

National Planning Policy Framework (2012) 

6.8 This document sets out the Governments planning policies for England and how these are 

expected to be considered in terms of planning policy and development management with a 

presumption in favour of sustainable development. 

Regional 

The South East Plan (2009) 

6.9 Although likely to be revoked before the plan is adopted this document takes account of 

housing provision for the South East including Runnymede. 

The South East Region Inclusion Statement (2002) 

6.10 The statement identifies a number of issues related to housing, transport, crime, education 

and skills, enterprise, health and ‘quality of life’ issues. 

County 

Surrey Strategic Partnership Plan (2010) 

6.11 The Surrey Strategic Partnership Plan identifies improvements to Surrey in relation to living, 

working and business in the county. 


Runnymede Sustainable Community Strategy and Corporate Plan (being replaced 2012) 

6.12 The sustainable community strategy and corporate plan identifies the following needs: 

maintaining clean and safe streets, increasing access to health and social support facilities, 

supporting vulnerable people, promoting sports and leisure facilities and supporting 

communities. 

Runnymede Equality Policy and Action Plan 

6.13 The Runnymede Equality Policy and Action Plan supports the Council’s aim to ensure that its 

services are equally accessible by all people who need them, irrespective of gender, race, 

disability, religion, belief, sexual orientation or age. 

Runnymede Fuel Poverty Strategy 

6.14 The Runnymede Fuel Poverty Strategy looks at ways to reduce fuel poverty within the 

borough. 


6.15 The SEA Directive and UK SEA Regulations require that an account be given of the current and 

likely future composition and condition of the environment in the area covered by the 

proposed plan. The environmental baseline presented in this section has been compiled from 

available sources of primary and secondary data that in the main relate to RSF Indicators that 

have been monitored by the Council in one form or another since 2004. 


6.16 Runnymede contains a total population 80,500 which is made up of 32,700 households (2011 

census). Within the total population of Runnymede the majority of the population is aged 

between 25 and 64 (51.55%). 

6.17 The Public Health Observatories health profile (2012) shows that Runnymede records higher 

than the national average life expectancy for men and women. The Health Profile identifies 

road injuries and deaths, alcohol and hip fractures as priorities within Runnymede. 

6.18 There are health inequalities within the area. In general life expectancy for both men and 

women in the borough is high. However, life expectancy for men and women from the most 

deprived areas is around five years lower than for those from the least deprived areas. 

6.19 Over the last 10 years, all cause mortality rates have fallen. Early death rates from cancer and 

from heart disease and stroke have also fallen and the latter is better than the England 

average. Almost 1 in 5 adults smoke and almost 1 in 4 are obese and the rate of death and 

serious injury on the roads is slightly lower than England’s average. ( 36) 

6.20 Table 44 provides a summary of the key issues and challenges that have been identified as 

having particular relevance to the Council’s emerging Local Plan on this receptor. Those issues 

and challenges have been identified from the baseline environmental information as well as 

through discussion with various officers within the Council and external statutory and nonstatutory 

consultees. 


Receptor 

[ER02] Welfare, Health and 

Well‐being 

Key Issues, challenges and potential responses for the Local 

Plan 

Summary: Runnymede records high levels of life expectancy. The average life 

expectancy for woman in Runnymede is 83.7 years and 80.7 years for men 

(data taken from 2007-9) 

However, 12.2% of children within Runnymede live in poverty. 

Issues and Challenges: National statistics health profile indicates that men and 

women resident in Runnymede have a higher than average life expectancy. 

According to the health profile the priorities for Runnymede include; road 

injuries and deaths, alcohol over-use and hip fractures. 

Possible LP Response: The LP could bring forward policies to prioritise the 

enablement of physically activities that improve welfare, health, and well-being, 

including user education schemes, as well as physical improvements and joint 

schemes with neighbouring boroughs and providers. Policies could be included 

that requires developers to adopt both the “Lifetime Homes and Lifetime 

Neighbourhoods” standards for all developments. Policies could be included that 

requires developers to recognise and exploit the wider health and leisure 

opportunities created by regeneration and supporting infrastructure. Policies 

could also be taken to enhance access by public transport, cycling and walking, 

linking with the health agenda to improve overall quality of life. 

How LP Responded: The LP does not contain a policy set on health. It could be 

argued that links to health within polices are of a secondary nature such as 

development and access to facilities enhancing well-being. 


6.21 The population of Runnymede is growing; data suggests that between 1991 and 2001 there 

was a growth rate of 8.7%, mainly due to net inward migration rather than a natural increase. 

At the time of the 2001 Census there were considered to be around 32,000 households in the 

borough, accommodating a population of 78,033. The 2011 Census shows that the population 

has increased to 80,500 in 32,700 households. 

6.22 By projecting the population growth rate between the three censuses periods of 1991, 2001 

and 2011 and assuming a similar rate of population increase over this period, the population 

will have potentially risen to around 86,000 in 2026 (See: Figure 8). 

36 All data taken from the APHO 2010 Health Profile http://www.apho.org.uk/resource/aphosearch.aspx 


Figure 8 ‐ Projected Population in Runnymede 2031 

6.23 Table 45 is taken from the Infrastructure Delivery Plan 2012 (IDP 2012) and sets out the 

projected population against the infrastructure delivery periods in the Local Plan. 

Table 45 ‐ Delivery Period Population Projections 

Delivery Period 

Total 

Population 

Population 

Increase 

% Change 

Baseline 2011 82,500 

Projection (2013/14 – 

2017/18) 


2022/23) 

84,244 +3,744 4.6% 

86,507 +2,263 2.7% 


2025/26) 

87,496 +989 1.1% 

Total Projected Population Increase +6,996 8.5% 

6.24 The 2012 Health Profile for Runnymede identifies a range of key issues and challenges that 

need to be addressed with respect to the overall health and well being of the population. 

6.25 The priorities for action that have been identified for Runnymede by the APHO include road 

injuries and deaths, alcohol and hip fractures. 

6.26 In the absence of the Local Plan, the saved policies of the Runnymede Borough Council Local 

Plan (2007) would be used when considering development proposals. Whilst the health of 

residents within Runnymede is likely to remain high the absence of a new plan may limit 

opportunity to implement policies that have further positive effects on health. 

6.27 It is possible that the existing set of policies could produce effects that contribute to 

increased levels of health within the borough such as access to greenspace and low levels of 

deprivation. 


WHWB1: Opportunities to improve life‐chances 

6.28 Life‐chances are described by Wikipedia as “…the opportunities each individual has to 

improve his or her quality of life.” ( 37) . Introduced by German sociologist Max Weber, the 

37 http://en.wikipedia.org/wiki/Life_chances 


concept is a probabilistic description of how likely it is, given certain factors such as access to 

resources, education and health care that an individual's life will turn out a certain way. 

Clearly, the lack of opportunities resulting from inappropriate or dysfunctional existing 

development or infrastructure can be rectified by providing new development and thus 

improving the life‐chances of Runnymede residents. 

WHWB2: Risks respiratory health related to air pollution 

6.29 Continued use of development and some infrastructure such as transport, can give rise to 

increases in the risk of respiratory illness in the population. The council has designated three 

areas as Air Quality Management Areas (AQMAs) as a result of poor air quality and these 

have been detailed in Section 11. 

WHWB3: Risks to health and well‐being from environmental noise 

6.30 According to the EU, noise above a certain volume threshold (from 60Ldn dB(A)) affects both 

health and well‐being of individuals. Continued use of existing and new development and 

infrastructure (including transport) will give rise to an increased risk of noise exposure. 

WHWB4: Risks to health and well‐being from environmental stress 

6.31 Stress is a common feature of the daily lives of individuals. Whilst some stress can be 

considered positive, prolonged or frequent bouts of stress can have a negative impact on 

health and well‐being. Continued use of existing inappropriate or dysfunctional development 

and infrastructure (including transport) congestion will give rise to an increased risk of stress 

exposure. 

WHWB5: Opportunities to increase physical activity 

6.32 The lack of physical activity is also a common feature of the daily lives of many individuals. 

Whether it is due to location fear, motivation or an underlying condition, the benefits to 

health and well‐being of engaging in some physical activity have been widely documented. 

The lack of opportunities that are a result of inappropriate or dysfunctional existing 

development and infrastructure can be rectified by new or re‐development. 

Consideration of Policy and its Alternatives 


6.33 The overall impact of all alternatives range between uncertain and neutral within the SEA for 

the policy options (see Appendix 4). However, this masks the impact of LP01 on pathway 

WHWB 2 that considers effect of air pollution, as well as LP01‐A2 having a significant adverse 

impact on the same receptor. With regard to LP01‐A1 and LP01‐A2 and their impact on 

pathway WHWB 3 – the risk to health due to noise pollution – both have scored adverse. All 

other receptors are in the range of uncertain to beneficial. In view of the mix of impacts, no 

policy approach avoids a negative impact on this receptor. Overall the effect of any new 

development will have both a positive and negative impact on ER02. 

6.34 Having regard to the conclusion of SA in Appendix 3, overall, the policy approaches have a 



(RSF 19). 

6.35 Overall LP01 does not have a significantly different either worse or better impact to its 

alternatives as considered. 


6.36 Considering the conclusions of the SEA in Appendix 4, alternatives LP02 and LP02‐A3(b) have 

neutral impacts on this environmental receptor. LP02‐A2(a) – LP02‐A3(a) all would result in a 

mixed positive effect and LP02‐A1 has an uncertain impact. The effect on the pathways of the 

alternatives is varied but none exhibit significantly adverse effects. LP02‐A2(a) does exhibit 

potentially adverse effects on WHWB1 – the opportunities for life chances. This probably 

reflects the scattering of development on the urban perimeter and the lesser opportunities 


for community gain. Across the range of other pathways there are in there are in the round 

general positive impacts. 

6.37 With regard to the conclusion of SA in Appendix 3, overall, all the policy approaches have a 





receptors, but the impact of the alternatives is not overall significantly different. 

6.38 Overall policy LP02 in the SA consideration will not result in a different impact to that of its 

alternatives. In contrast in terms of the SEA on this particular environmental receptor, LP02 

appears to score less well than 4 of its other alternatives. 

Policy LP03 – Development in Addlestone Urban Area 

6.39 In terms of SEA, LP03 has an uncertain impact in comparison to the neutral impacts of LP03‐ 

A1 and LP03‐A2. With regard to the impact on the pathways it is noted that all alternatives 

adversely affect WHWB2 ‐ the health risk associated with air pollution (see Appendix 4). Any 

level of growth will give rise to this impact and so it is an impact that has to be mitigated in 

the most effective way when detailed schemes are submitted. 


neutral impact. The impact on air quality is uncertain/adverse (RSF 16) for all alternatives, 

reflecting the resulting impact on the air quality pathways. The need to accommodate growth 

in housing will have potential consequences for all receptors, however, in SA terms the 

impact of the alternatives is no different. 

6.41 Overall policy LP03 in SA terms does not have a different impact to its alternatives ‐ all have 

potentially mixed beneficial effects. In contrast, LP03 scores lower than either of its 

alternatives in terms of SEA. 

Policy LP04: Policy Development in Egham / Englefield Green Urban Area 

6.42 In terms of SEA, both LP04 and LP04‐A1 score a neutral impact on this environmental 

receptor (see Appendix 4), this is in spite of a potential adverse effect on WHWB2 from LP04‐ 

A1. 

6.43 Having regard to the conclusion of SA in Appendix 3, overall, all the policy approaches also 

have a neutral impact. The need to accommodate growth presents opportunities to have a 

consequence for all the receptors, and this is borne out by the uncertainty in terms of RSF 16 

– Air Quality. 

6.44 Overall policy LP04 in SA terms has a more beneficial effect in contrast to its alternative. In 

terms of SEA both approaches score equal. 


6.45 The SEA conclusion is that LP05 and LP05‐A1 will have a neutral effect, whilst alternative 

LP05‐A2 is considered to result in an uncertain effect (see Appendix 4). 

6.46 Alternative LP05‐A1 scores a neutral effect on all the impact pathways except for WHWB1 – 

opportunities for life chances. This neutral effect is because the alternative presumes against 

development, and so there is little effect on risks to health, and there is no change to 

opportunities to increase physical activity. This alternative scores a mixed effect for 

opportunities for life chances because the alternative effectively maintains the status quo; 

some opportunities will be lost by the lack of the expansion and development of the 

academic facility, to be weighed against a less developed site with fewer people using it and 

more open space available. There would also be a mixed effect for the wider community from 

this option, in terms of an increase in the local population versus increased facilities available 

locally. The other two options, the LP05 and LP05‐A2 both provide a beneficial score, 

reflecting the enhanced offer that would be available to a greater number of people both on 

the site and off. 


6.47 WHWB2, risks to respiratory health related to air pollution, scores a neutral effect for the 

preferred option and LP05‐A1, compared to an adverse effect scored by LP05‐A2. This is an 

obvious score for LP05‐A1 because it would give rise to little or no development and thus no 

air pollution. The preferred option will give rise to development but the pre‐planning of this 

development through the production of a master plan will draw in methods of construction 

and controls on car use on the site to minimise any possible causes of air pollution. This 

would apply to both the on site and off site communities. LP05‐A2 scores an adverse effect 

because removing the site from the Green Belt thus allowing unlimited amounts of 

development will contribute to air pollution both from the additional building and the 

increase in vehicles using the site both on site and in the wider area. 

6.48 With regard to WHWB3 and WHWB4, risks to health and well‐being from environmental 

noise and environmental stress, policy LP05 and LP05‐A1 score a neutral effect. This is self 

explanatory for LP05‐A1, to retain the Green Belt designation with no expansion, and for the 

preferred option the pre‐planning of the site through the production of a master plan will 

control these risks. LP05‐A2 scores a mixed effect for the risk from noise, because the effects 

of the alternative cannot quantified at this stage due to the site being taken out of the green 

belt and the lack of a master planning requirement. With regard to risks from environmental 

stress, LP05‐A2 scores a beneficial effect because one of the elements of stress can be the 

need to travel for facilities. The alternative allows unconstrained development and therefore 

more facilities could be available on site, reducing an element of stress. The preferred 

alternative is therefore not the best one for minimising the effect of this impact pathway, but 

in mitigation it is possible for the master plan to deal with this issue although to require this 

may be outside the remit of the plan. 

6.49 WHWB5, opportunities to increase physical activity, scores a neutral effect for both the 

alternatives, because to retain the site in the Green Belt (LP05‐A1) maintains the status quo 

and so will not provide new opportunities, whilst LP05‐A2, to remove the site from the Green 

Belt, will allow a much larger scale of development to increase student accommodation and 

academic facilities in line with the college’s aspirations, and does not suggest opportunities to 

increase physical activity. The preferred option scores an uncertain effect because at this 

stage the content of the master plan is unknown and so we do not know how the policy will 

influence this impact pathway. It could be argued that the two alternatives score better than 

the preferred policy, but the uncertain score for the preferred alternative purely reflects a 

lack of information at this stage. The required master plan will rectify this. 

6.50 Overall, the LP05 and LP05‐A1 score equally, and better than LP05‐A2, but LP05‐A1 will not 

allow the college to achieve its aspirations which may lead to its loss from the Borough, to the 

detriment of the overall economic and social well being of the Borough. 

6.51 With regard to SA, Appendix 3 indicates overall, the policy LP05 has a mixed effect on SA 

objectives, and both LP05‐A1 & A2 have neutral effects. With regard to the relevant RSF 

objectives, the LP05 and LP05‐A2 have a beneficial effect on RSF 1 (to ensure that everyone 

has the opportunity to live in a decent, sustainably constructed and affordable home), RSF 6 

(to create and sustain vibrant communities recognising the needs and contributions of all) 

and RSF 13 (to develop and maintain a skilled workforce) but an adverse effect on LP05‐A1 

reflecting the fact that retaining the site in the Green Belt is not the best option when 

considering the social and economic well‐being of the Borough’s population. RSF 4 (to raise 

educational achievement levels across the Borough), RSF 9 (to ensure high and stable levels 

of employment) and RSF 10 (to sustain economic growth and competitiveness across the 

Borough) also have a beneficial score for the LP05 and LP05‐A2, supporting the aspiration for 

the proposed policy, to keep the college in the borough. LP05‐A1 has a neutral effect on 

these objectives. LP05 and LP05‐A2 also have a beneficial effect RSF 12 (to develop a 

dynamic, diverse and knowledge based economy) but LP05‐A1 scores a significantly adverse 

effect. This reinforces the view that if we keep the campus in the Green Belt and not allow 

the university to expand it will have a detrimental effect on the Borough’s economy. RSF 3 (to 

reduce poverty and social exclusion) and RSF 16 (to reduce air pollution and ensure continued 

air quality improvement) both score an uncertain effect for the LP05 while LP05‐A1 again has 

a neutral effect. For RSF 16 LP05‐A2 scores an adverse effect, reflecting the fact that this 

alternative would lead to a greater degree of development on the site. In this respect, the 


alternative to leave the site in the Green Belt would be the best option but as with the SEA, 

these particular RSF objectives do not take account of the economic benefits of facilitating 

the expansion of the university in the borough. The overall SA score (mixed) does take this 

into account, although the lack of weighting of the objectives does not reflect the priorities 

for the Borough. 


6.52 With regard to SEA receptor ER02, the overall conclusion for LP06 and LP06‐A1 is a neutral 

effect on the receptor (Appendix 4). This is because it has been judged that welfare, health 

and wellbeing matters are unlikely to be materially affected by the scale of development 

envisaged for the settlement area. 

6.53 The overall SA concludes that the impact of the policy is mixed positive for both alternatives 

(Appendix 3). With regard to the individual RSF’s LP06‐A1 that has an uncertain impact on 

RSF 12 (a divers economy), RSF 16 ((reduce air pollution), RSF 17 (climate change), RSF 22 

(reduce impact on consumption of resources) and RSF 23 (reduce waste). Notwithstanding 

these uncertain issues the overall impact is similar, especially when compared with the 

outcome of the SEA. 

Policy LP07 –Development in Virginia Water ‐ Impact of policy alternatives 

6.54 The neutral impact of LP07 and LP07‐A1 is noted (see Appendix 4). However, on the affect on 

the pathways is generally benign. 


neutral/positive impact. 


6.56 Policy LP08 and LP08‐A2 have a mixed positive impact on the receptors; whilst LP08‐A1 and 

LP08‐A3 return neutral impacts (see Appendix 4). However, when considering the affect on 

the pathways the impact is mixed. LP08 has a significant beneficial affect on WHWB1 (life 

changes) and WHWB5 (increased physical activity), a mixed beneficial on WHWB2 (reduce 

respiratory risk) and uncertain affect on WHWB3 (risk to health) and WHWB4 (impact of 

environmental stress). However, when assessing the impact of the alternatives on the 

pathways there is a mixed impact that does not lead to an overriding solution. 

6.57 The nature of the proposal to develop the former DERA site will have an impact due to the 

nature of the site compared to the other policy alternatives. Whilst the impact will need to be 

assessed in the round when all the affects on the receptors are examined, it is considered 

that this will be a key issue that will require detailed consideration to enable any scheme to 

proceed. 

6.58 Each of the alternatives will impact on the receptors given the quantum of development. 



6.59 The overall conclusion of the SA is that the LP08 will result in a mixed positive effect, all other 

alternatives are all neutral (see Appendix 3). Within the context of the SA LP08 is expected to 

result in a significantly beneficial affect on RSF 9 (create employment), but countered with a 

significant adverse impact on RSF16 (improve air pollution) with other RSFs generally well 

accommodated. LP08‐A1 and A2 are expected to result in an adverse affect on RSF 14 

(improve reuse of land/building), RSF 19 ((enhance biodiversity), and RSF 20 protect 

countryside), policy LP08‐A3 has an adverse affect on RSF 17 (impact on climate change). 

There are therefore a diversity of impacts from the alternatives. Compared to the SEA 

conclusions, the alternatives are generally uncertain, but LP08‐A2 is neutral reflecting the 

spread of development across green field sites. 

6.60 A Level 5 assessment has also been carried out on this policy and with the results largely 

replicating that of the Level 3 and 4 as described above. The output of the Level 5 assessment 

can be seen at Appendix 16. 


6.61 This policy has also been subject to a Level 6 assessment – HRA (see Appendix 8 and 9). The 

factors considered in the HRA are not directly relevant to this environmental receptor. 


6.62 This policy SP01 does not have any alternatives. The whole strategy of the Plan depends upon 

some significant development schemes coming forward in the green belt to meet future 

demand. A balance needs to be struck to recognise the potential impact of future 

development on ER02 compared to the other assessments. 



Policy SP02: Affordable Housing 

6.65 Policy SP02 has a positive impact where as the expected effects of SP02‐A1 and SP02‐A2 is 

uncertain (see Appendix 4). Policy SP02‐A2 has a significantly adverse impact on pathways 

WHWB 2 (respiratory illness due to air pollution), WHWB 3 (risk to health ‐ noise), and 

WHWB 4 risk to health – environmental stress). Policy SP02‐A1 is expected to result in a 

significant adverse impact on WHWB 1 (opportunities for life chances). 

6.66 Having regard to the conclusion of SA in Appendix 3, overall, the policy approaches of SP02 

and SP02‐A2 are considered to result in a positive impact. However, there is an uncertain 

affect from policy SP02‐A1 on RSF 1 (providing decent homes), RSF 2 (improving health), RSF 

3 (reducing poverty) , RSF 6 (creating vibrant communities), and RSF 9 and 11 (stimulating 

the economy). The alternative SP02‐A1 is less acceptable in the SA analysis. However, policy 

SP02 does have an affect on RSF 16(reducing air pollution). The need to accommodate 

affordable housing will have a consequence for all the receptors, but the impact of the 

alternative SP02‐A1 is more uncertain and therefore policy SP02 or SP02‐A2 are clearly more 

acceptable. However, in terms of SEA SP02 performs better against this environmental 

receptors. 


6.67 In terms of SEA (see Appendix 4) and the impacts this policy could be expected to have on 

environmental receptor ER02, the overall conclusion for policy SP03 is a mixed effect. This 

derives from a significant beneficial effect in respect of the WHWB1 Impact Pathway, 

Opportunities for life chances, and the remainder of the Impact Pathways being neutral. 

Policy alternative SP03‐A1 returns a conclusion of unknown effect, with three Impact 

Pathways being recorded as neutral effect and two – WHWB1 and WHB4 Risk to health from 

environmental stress – being recorded as adverse effect. Policy alternative SP03‐A1 does not 

to provide any traveller provision is clearly not meeting need and the social needs must 

outweigh the negative impact on ER02. 

6.68 In terms of SA (see Appendix 3) SP03 performs much better against SP03‐A1 in the key RSF 

objectives of RSF 01, 03, and 06. 


6.69 Policy SP04 does not have any alternatives to consider in either the SEA or SA. 

6.70 In terms SEA overall for this receptor (ER02) the effect of policy SP04 is expected to be 

uncertain – this is true for all impact pathways (Appendix 4). 

6.71 In terms of SA overall policy SP04 returns an expected mixed effect, scoring significantly 

beneficial effects on a number of key RSF objectives (Appendix 3). 



6.73 The overall conclusion for policy SP05 is a mixed effect on ER02, largely as a result of having a 

potentially beneficial effect on WHWB1 (opportunities for life chances) including the same 

result for WHWB2 and WHWB4 (Appendix 4). It is considered that this is due to the fact that 


the policy requires all development proposals should respect and improve the quality of the 

environment in the Borough, and provide high quality and inclusive layouts. 

6.74 Policy SP05 is considered to have a beneficial effect on WHWB2 (risk to respiratory health, 

related to air pollution) as well designed development can contribute to improving air quality. 

It is expected to result in a neutral effect on impact pathway WHWB3 (health and wellbeing 

from environmental noise) because whilst parking provision will be appropriately located in 

new development (to perhaps reduce noise), good design can not prevent cars and other 

noise pollution generating sources from occurring. It is expect to result in a beneficial effect 

on impact pathway WHWB4 (risks from environmental stress) because the policy encourages 

new development be inclusive, and parking provision and storage of waste in new 

development will be appropriately located to serve the development, which will reduce 

stress. 

6.75 With regard to WHWB5 (opportunities to increase physical activity), the policy has a neutral 

effect on the impact pathway because design itself can not influence the opportunities for 

physical activity, although the policy can maximise opportunities for linkages to surrounding 

areas and services, it is the location of development that can do this. 



6.77 Policy SP06 has one alternative policy SP06‐A1 to consider in addition to itself either the SEA 

(see Appendix 4) or SA (see Appendix 3). 

6.78 The overall conclusion for policy SP06 is a neutral effect on ER02. Whilst both policies return 

potentially neutral effects the comparison is not represented within individual impact 

pathway scores. Policy SP06 has a beneficial effect on WHWB1 (opportunities for lifechances) 

as the provision of tourism facilities will enhance employment opportunities. The 

same positive impact on WHWB1 is noted for SP06‐A1 as sustainable tourism, recreation and 

leisure would retain a strong economy for the Borough. 

6.79 Policy SP06 has an adverse effect on WHWB2 (risk to respiratory health, related to air 

pollution) as the provision and improvement of more recreation, leisure and tourism facilities 

will be made in the Borough, and people will access these facilities by modes of transport 

including the private car. The same effect was identified in SP06‐A1 as encouraging visitor 

numbers to the Borough, and if some new buildings are required to facilitate this, their 

development will be able to contribute to a decrease in air quality. Both policy options 

encourage more people in to the Borough. Although public transport may be made available, 

not all facilities/attractions are available by public transport, so the private car is used. 

6.80 Policy SP06 has a neutral effect on impact pathway WHWB3 (health and wellbeing from 

environmental noise) because all tourism‐focused development is encouraged in town 

centres, and so any related noise will be concentrated in areas that are already subject to 

environmental noise. Policy SP06‐A1 has an adverse impact due to increased traffic around 

potential new tourism, as the scope of the alternative covers district centre areas and areas 

near existing visitor attractions, as well as town centres. 

6.81 Policy SP06 has a neutral effect on impact pathway WHWB4 because negative impacts of 

other tourism/recreation/leisure are countered by the fact that the Thames and other water 

bodies will be improved to reduce environmental stress. Policy SP06‐A1 has an uncertain 

effect on WHWB4 as it is difficult to quantify the extent/location of tourism related 

development/facilities, and therefore the level of environmental stress that may be caused 

by this. 

6.82 With regard to WHWB5 (opportunities to increase physical activity), policy SP06 has an 

uncertain effect as it is not known the extent to which the improvements to the Thames will 

increase physical activity. In contrast policy SP06‐A1 has a positive effect as tourism sites 

including those outside the Borough could encourage an increase in physical activity, as the 

policy looks specifically at the improvement of access to the River Thames and waterways, 

which are part of public pathway routes. However, despite a reduced score on this impact 

pathway ‐ policy SP06 has a worse impact, than policy SP06‐A1, on the basis of the impacts of 


the policy on all the other pathways within this receptor, the accepted policy was considered 

more sustainable than the alternative. 

6.83 With regard to SA, overall, the preferred policy has a neutral effect on SA objectives, and the 

alternative has mixed effects. With regard to RSF objectives, where the preferred policy and 

the alternative differ in their evaluation, is RSF objective 15 (reduce risk of flooding and 

resulting detriment to public well‐being, the economy and the environment). Alternative one 

has a neutral impact on RSF15, but the preferred policy has a significantly beneficial effect 

because it encourages proposals that enhance the use and access of waterways, that would 

lead to their improvement. The preferred policy is not very different to alternative one, as 

more hotel provision will be viewed positively, and existing facilities will be utilised more, 

making a contribution towards social aspects within Runnymede. 



6.85 The policy team felt that there was no reasonable alternative to the policy, as it provides a 

tested mechanism to facilitate development. However, the overall impact on the receptors is 

mixed positive. 

6.86 In terms of SA (Appendix 3) policy SP07 returns a neutral impact. 


Policy SP08: Employment Development 

6.88 Policy SP08 has one alternative policy SP08‐A1 to consider in addition to itself in terms of SEA 

and SA. 

6.89 Both policy SP08 and SP08‐A1 result in an overall neutral impact (Appendix 4). The impact on 

the pathways is generally uncertain. 

6.90 Having regard to the conclusion of SA in Appendix 3, overall, all policy SP08 and SP08‐A1 have 

a neutral/positive impact. However, there is an adverse affect expected from SP08‐A1 on RSF 

3 (reducing poverty) , RSF 6 (creating vibrant communities), RSF 9 and 11 (stimulating the 


workforce), RSF 21 (improving transport). Policy SP08‐A1 is less acceptable in the SA analysis. 

The need to accommodate growth will have a consequence for all the receptors, but the 

impact of the alternatives is different in a negative way which would imply that SP08 is clearly 

more acceptable. 



6.92 The overall conclusion for policy SP09 is a mixed effect on environmental receptor ER02 

(Appendix 4). The policy has a beneficial effect on WHWB1 (opportunities for life chances) as 

the opportunity to use varied modes of transports will make the Borough generally more 

accessible to more people. 

6.93 The policy is expected to result in a beneficial effect on WHWB2 (risk to respiratory health, 

related to air pollution), as the policy requires high trip generated development to be 

accessible by more sustainable modes of transport than the car, with the desired effect of 

reducing car trips, and therefore having positive impacts on air pollution. 

6.94 The policy is expected to result in mixed effects on impact pathway WHWB3 (health and 

wellbeing from environmental noise), as environmental noise will be reduced through the 

policy as it requires to reduce car use, however there could be associated increases in noise 

from other more sustainable modes of transport. 

6.95 The policy is expected to result in a beneficial effect on impact pathway WHWB4 (risks from 

environmental stress) as the policy with its requirements to reduce car use, provision of new 

public transport and making on site provision for cycle parking in new high trip‐generating 

development will be capable of increasing health and well‐being. 


6.96 With regard to WHWB5 (opportunities to increase physical activity), the policy is expected to 

have a neutral effect on the impact pathway because although the policy requires provision 

for cycle parking to be made on high trip‐generating development, there is no requirement 

for people to cycle rather than use their cars. 




6.99 In terms of SEA policy SP10 is expected to result in a mixed beneficial impact on this 

environmental receptor (Appendix 4). 

6.100 In terms of SA policy SP10 is expected to result in a mixed beneficial impact (Appendix 3), 

broadly replicating the conclusions of the SEA. 




LP01 Strategy for the Location of Development / 0 0 


Alternative LP01‐A2 / 0 0 

LP02 Housing Provision and Distribution 0 0 


Alternative LP02‐A2 (a) 0 / 

Alternative LP02‐A2 (b) 0 / 

Alternative LP02‐A2 (c) / / 

Alternative LP02‐A3 (a) / / 

Alternative LP02‐A3 (b) 0 0 

LP03 Development in Addlestone Urban Area / ? 

Alternative LP03‐A1 / 0 


LP04 Development in Egham / Englefield Green Urban Area / 0 


LP05 Royal Holloway UOL 0 

Alternative LP05‐A1 ? 0 

Alternative LP05‐A2 / / 

LP06 Development in Chertsey Urban Area / 0 




LP08 The former DERA site, Longcross / / 0 

Alternative LP08‐A1 / 0 

Alternative LP08‐A2 / / 

Alternative LP08‐A3 0 0 0 


SP01 Green Belt Areas / 0 

SP02 Affordable Housing / / 


Significant 

Beneficial 


Significant 

Adverse 

/ 0 ? 




Alternative SP02‐A1 ? ? 

Alternative SP02‐A2 / ? 

SP03 Gypsy and Travelling Populations 0 / 

Alternative SP03‐A1 0 ? 

SP04 Provision and Retention of Infrastructure and Service ? 

SP05 Design / / 

SP06 Tourism, Recreation and Leisure / 0 


SP07 Thames Basin Heaths Special Protection Area 0 / 

SP08 Employment Development 0 

Alternative SP08‐A1 ? 0 

SP09 Sustainable Transport / / 

SP10 Development and Flood Risk / / 


6.101 Cumulative effects not considered likely the result from this receptor. 

Mitigation /Enhancement Recommendations 

6.102 Mitigation/enhancement is suggested through the June 2012 meetings (See: Appendix 2) 

through the provision of SANGS in policy set SP07 ‘Thames Basin Heath SPA’ will increase 

opportunity to increase physical activity. 


Table 47 ‐ Suggested Monitoring of Impacts and Effects of the LP on ER02 


Frequency of 

data 

collection 

When should 

remedial action be 

taken? 

What remedial 

action should 

be taken? 

APHO Health Profiles (Currently 2012 

Edition) 

Early death rates for circulatory 

disease, cancer, accidents and 

suicide (LSF Objective) 

Annual 

Annual 

When negative trend is 

observed in data. 



Infant mortality rates (LSF Objective) Annual When negative trend is 


Raise query to 

health providers. 





Under 18 conception rates (LSF 

Target) 

Annual 





Life expectancy (LSF Target) Annual When negative trend is 


Alcohol related deaths (LSF Target) Annual When negative trend is 







Section 7. 

Introduction 

[ER03] Land and Soil Resources 

7.1 The land, soil and minerals receptor covers the effects on land use, the use of mineral 

resources and safeguarding of soil quality and resources (e.g. best and most versatile 

agricultural land). The receptor covers the factor of ‘soil’ as required by the European 

Directive and UK Regulations on the environmental assessment of plans and programmes and 

incorporates a number of SA sustainable development objectives as outlined in Table 48. 


Table 48 – Applicable SA/SEA Objective/Factor to ER03 




SO14 

SO22 

SO23 

To improve efficiency in land use through the appropriate re‐use of previously 

developed land and existing buildings – including re‐use of materials from 

buildings – and encourage urban renaissance 

To reduce the global social and environmental impact of consumption of 

resources by sustainably and ethically produced , local or low impact products 

To reduce waste generation and disposal , and achieve the sustainable 

management of waste 

G 

G 

G 


FA06 Soil G 

Policy Context 






goals 



[ER03] Land, Soil and Mineral Resources 

National Policy: National Planning Policy 

Framework 

Regional Policy: Regional Sustainability 

Framework 

Surrey Policy: Surrey Waste and Minerals 

Strategy, Surrey Design , Surrey Minerals 


European Law: European Waste Framework 

Directive , European Landfill Directive, 

European Soils Framework Directive (Draft) 

Objective: No explicit objective at present, however making efficient 

use of land, soil and mineral resources is key to delivering 

sustainability. 

Comment: There is no objective that relates directly to land, soil, 

and mineral resources, but there is an implicit assumption that the 

aspiration for sustainable development will seek to protect these 

resources as far as possible. Regeneration and housing growth will 

have an effect on these resources, but existing policies already 

prevent these emerging objectives from having undue or 

disproportionate effects. 


International 

European Waste Framework Directive 

7.3 The European Waste Framework Directive aims to ensure that all provisions relating to waste 

management should enhance the protection of human health and the environment against 

harmful effects caused by the collection, transport, storage and tipping of waste. 

European Landfill Directive 

7.4 The European Landfill Directive aims to prevent or reduce as far as possible negative effects 

on the environment, particular the pollution of surface water, groundwater, soil and air, and 

on the global environment, including the greenhouse effect as well as any resulting risk to 

human health, from the land filling of waste during the whole life‐cycle of the landfill. 

7.5 The proposed European Soil Framework Directive was introduced in 2006 by the European 

Commission. Its purpose is to increase the level of soil protection across the EU. Negotiations 

continue under the EU Presidencies, however agreement is yet to be reached and 

negotiations have stalled since 2010. 

National 


7.6 The National Planning Policy Framework has within the document an environmental role 

whereby it will be contributing to protecting and enhancing our natural, built and historic 

environment; and, as part of this, helping to improve biodiversity, use natural resources 

prudently, minimise waste and pollution, and mitigate and adapt to climate change including 

moving to a low carbon economy. 

7.7 The planning system has a role to control future development. As a minimum land which has 

been remediated under the planning regime, should not be capable of being determined as 

contaminated land under Part 2A of the Environmental Protection Act 1990 (NPPF Para 121). 

7.8 Contamination is a material consideration in local development decisions which should 

ensure that: 

The Planning system should contribute to and enhance the natural and local 

environment by: preventing both new and existing development from contributing to 

or being put at unacceptable risk from, or being adversely affected bu unacceptable 

levels of soil, air, water or noise pollution or land instability; and remediating and 

mitigating despoiled, degraded, derelict, contaminated and unstable land, where 

appropriate (NPPF Para 109) 

7.9 In terms of specific sites, contamination is generally considered a material consideration in 

local development decisions which should ensure that: 

“the site is suitable for its new use taking account of ground conditions and land 

instability, including from natural hazards or former activities such as mining, 

pollution arising from previous uses and any proposals for mitigation including land 

remediation or impacts on the natural environment arising from that remediation” 

and; “adequate site investigation information, prepared by a competent person, is 

presented” (NPPF Para 121). 

7.10 Under NPPF Para 111 the effective re‐use of Brownfield land should be encouraged. 

Regional 


7.11 The Regional Sustainability Framework (RSF) sets out a common vision, 25 objectives and four 

priorities that will help guide development in the South East. 


County 

7.12 Surrey Waste Plan (2008) 

This plan seeks to move away from landfilling towards more acceptable ways of dealing with 

waste. 

7.13 Surrey Minerals Plan (2010) 


This plan provides a means of meeting the need for minerals from the sites which have the 

lowest overall impacts when considering the county as a whole. 

7.14 There are no specific local policies in relation to land and soil resources, however 

Runnymede’s Contaminated Land Strategy aims to improve soil condition through 

remediation of contamination encountered via planning regimes and specific contaminated 

land legislation. 







Land and Soil in Runnymede 

7.16 Large areas of the 7,804ha of Runnymede are rural in character. In 2003 1,755.7 ha of land 

was being used for agricultural purposes accounting for nearly a quarter of total land area. 

78% of the borough has been designated as greenbelt. Agricultural land cover in the borough 

leads to a band running through the middle of the borough where the highest concentrations 

of agricultural holdings are found which are covered by Nitrate Vulnerable Zones (NVZs). 

7.17 Agricultural land in England and Wales is classified using a system of grades, which denote 

the land’s suitability for long‐term agricultural use. The grade given to an area of agricultural 

land reflects the following factors: 

 

 

 

The Climate: in terms of temperature, rainfall, aspect, exposure and frost risk; 

The Site: in terms of gradient, micro‐relief and flood risk; and, 

The Soil: in terms of texture, structure, depth and stoniness, and chemical properties 

which cannot be corrected. 

7.18 Natural England manages the Agricultural Land Classification ( 39) , which includes five grades 

for agricultural land. Grades 1 and 2 land is that which is most flexible, productive and 

efficient in response to inputs and which can best deliver future crops for food and non food 

uses such as biomass, fibres and pharmaceuticals. Local planning authorities are advised that 

if significant development of agricultural land is unavoidable, poorer quality land should be 

used in preference to that of higher quality. 

7.19 Most farm types found in Runnymede are classified as other (as per Defra agricultural census 

2003). The main finding was Foxhills contained 15 holdings classified as other and 8 holdings 

as cattle and sheep, lowland. Chertsey St Ann’s contained six holdings as other and three 

holdings as cattle and sheep, lowland. Thorpe contained 5 holdings classified as other and 

five holdings classified as horticulture. Therefore, data would suggest that there is no 

agricultural land of Grades 1 or 2 present within Runnymede. 

Previously developed land and contaminated land in Runnymede 

7.20 Runnymede has an improving track record in the use of previously developed land for the 

provision of new development. In terms of new dwellings, in 2003, 76% of new houses in 

39 Natural England Technical Information Note TIN049 


Runnymede were built on previously developed land, compared with 67% for the South East 

region and 65% for England ( 40) , this figure rose to 85% 2006‐2009. According to the National 

Land Use database Runnymede contains no previously developed vacant land or 1ha of 

vacant building. 

7.21 Land contaminated as a consequence of previous or historical industrial use (e.g. landfill, 

chemical works, etc.) may pose a risk to the environment and human health. Once 

contaminated, a site may be seen as less favourable for further development due to residual 

risks and the cost of remediation. 

7.22 Runnymede Borough Council has a duty to enable the remediation of contaminated land 

through the planning system (NPPF) and to maintain a register of statutory contaminated 

sites. Whilst Runnymede has no statutory contaminated sites to date (due to lack of 

resources to investigate potential areas), there are currently 430 areas (this value is 

constantly changing) of potentially contaminated land, in varying stages of investigation. The 

Council keeps a contaminated land register of statutory contaminated land as well as a list of 

areas of potential contaminated land to be investigated, and more data will become available 

as that work progresses. 

Mineral resources in Runnymede 

7.23 Mineral workings make an important contribution to the needs of society by supplying 

materials for the building and construction industry. However they can give rise to serious 

environmental impacts both in terms of the extraction activity itself and the heavy traffic 

connected with transportation. This conflict is apparent in areas such as Runnymede where 

mineral workings lie within or close to urban areas but it depends on how reclamation is 

managed. 

7.24 Table 50 provides a summary of the key environmental issues and challenges that have been 

identified as having particular relevance to the Council’s emerging Local Plan on this receptor. 

Those issues and challenges have been identified from the baseline environmental 

information as well as through discussion with various officers within the Council and 

external statutory and non‐statutory consultees. 


Receptor 

[ER03] Land and Soil 

Resources 



Summary: The natural landscape of the borough is characterised by the Thames 

Basin Lowland and urban fringe location that maintains a rural appearance 

including tree and woodland cover. 

The underlying geology is a mixture of light clay or sandy soils, gravels in the 

Thames Valley, and poor sandy, acidic solids in the heath and woodlands areas in 

the west of the borough. 

Issues and Challenges: There is scope (albeit small) for revitalisation of town 

centres and supporting infrastructure, including transportation, to affect the 

quality and usability of land and soil, and the accessibility of mineral resources. 

However, Runnymede has no good quality agricultural land, in this respect the 

ability of the LP to directly affect the land and soil receptor is low. The borough’s 

geology determines it is one of the few locations in Surrey for mineral resources. 

Primarily this consists of sands and gravels, which are considered an important 

input to the Surrey economy and protected by the Surrey Minerals Plan (2011). 

Possible LP Response: The LP could bring forward policies to prioritise the 

minimisation of the reduction in primary aggregates use in development and 

supporting infrastructure. Policies could be included that requires aggregate 

developers to adopt a phased approach to working mineral resource locations and 

planning the integration open space and leisure activities that provide additional 

capacity for climate change events such as flooding. 

How LP Responded: The LP makes no specific references to land and soil 

resources. 

40 http://www.communities.gov.uk/planningandbuilding/planningbuilding/planningstatistics/livetables/landusechange/. 


Evolution of Baseline condition in Absence of Plan 

7.25 As Runnymede continues to experience pressure for further development, impact on land, 

soil and mineral resources are inevitable. This may adversely affect land by changing its use 

from agriculture to urban and thus its usability for food production. Runnymede has no good 

quality agriculture land or soils, so it is unlikely that development approved in Runnymede 

will have a significant adverse affect on this receptor. On the other hand in terms of 

contaminated land, development can be the vehicle to initiate its clean‐up and restoration. 

Pressure to develop will inevitably increase the use of resources particularly mineral 

resources and thus increasing adverse effects on the environment that can result from 

extraction. 

7.26 It is unreasonable to think that all contaminated land within the borough will be eradicated or 

that large volumes of contaminated land will be gained, there will therefore be limited 

evolution of the baseline as only small pockets of contaminated land will be encountered and 

remediated. 


LSMR1 Reduction of land through development 

7.27 Pressure for development may increase the removal of land that is currently open to be 

developed for other purposes. 

LSMR2 Reduction of soil through development and potential contamination 

7.28 The pressure for development may require the removal of soil for development. If this is on 

land that has not been previously developed it may result in adverse impacts. In contrast 

there is little high quality soil in the borough, and therefore a reduction in agricultural 

opportunities is unlikely. 

LSMR3 Pressure to increase use of mineral resources 

7.29 The increased use of minerals resources increases damage to the local environment within 

Runnymede at extraction locations. It also has wider implications in the collection of these 

resources for removal such as increased traffic contributing to a reduction in air quality as 

well as increasing number of areas needing reclamation. 

Consideration of Policy and its Alternatives on ER03 


7.30 With regard to the SEA (Appendix 4) the impact of the policy approaches is mixed and 

neutral. This does not give a definitive view on the preferred alternative. The effect on the 

individual pathways does not highlight any particularly adverse impacts. 




(RSF 19). 

7.32 LP01 overall does not have a significantly different impact to the alternatives. 


7.33 With regard to the SEA the policy option LP02 is neutral; while the other policy options have 

an uncertain through to a significantly adverse impact. This impact is illustrated by the impact 

on the pathways where alternatives LP02‐A2(b), LP02‐A2(c) and LP02‐A3(a) have a particular 

impact on LSMR 1,2 and 3 uncertain However, this reflects the impact on land use, soil and 

the increase on resources arising from different scales of development. This assessment has 

implications for the alternatives LP02‐A2(b), LP02‐A2(c) and LP02‐A3(a) that have a 

particularly detrimental impact LP02 performs more positively and has less impact 








growth. 

7.35 The effect of the alternatives in the SA consideration does not have an overall different 

impact. 


7.36 With regard to the SEA (Appendix 4) LP03 has a neutral impact. The pathways do show some 

variation but not in a way that would cause particular concern 


neutral impact. The impact on air quality is uncertain/adverse (RSF 16) for all alternatives. 

and this is reflected on the impact on the pathways. The need to accommodate growth will 

have a consequence for all the receptors, but the impact of the alternatives is not different 

for planned or unplanned growth. 

7.38 LP03 overall in the SA consideration does not have a different impact to the alternatives. 


7.39 With regard to the SEA (Appendix 4) The neutral impact of LP04 and LP04‐A1 is noted. The 

affect of the alternatives on the pathways is benign. 




growth. 




7.42 The conclusion of the SEA (Appendix 4) for this receptor is that the LP05 and LP05‐A1 will 

have a neutral effect while LP05‐A2 scores an uncertain effect. 

7.43 LP05‐A1 scores a neutral effect for all the impact pathways in this receptor, which is to be 

expected because the option presumes against development and so there will be no effect on 

land or soil resources. 

7.44 LP05 and LP05‐A2 score an adverse effect on impact pathway LSMR1 – reduction of land 

through development ‐ which is to be expected as both options would allow development. 

LSMR2, reduction of soil through development and potential contamination, scores a 

beneficial effect for the preferred option and an uncertain effect for alternative 2. The 

beneficial score reflects the fact that controlled development (through the requirement for a 

master plan) should not involve soil reduction or contamination and may allow the cleansing 

of any existing contaminated soil. LP05‐A2 on the other hand will give less control over the 

form and amount of development and its effects cannot therefore be so easily quantified at 

this stage. 

7.45 LSMR3, pressure to increase use of material resources, has an uncertain score for both the 

preferred option and LP05‐A2, reflecting the fact that both of these options will involve 

development, but at this stage it is difficult to quantify resources without clear plans for the 

site. 

7.46 Again the overall SEA conclusion for this policy is the same for policy options to leave the site 

in the Green Belt, both scoring better than to take the site out of the Green Belt. However, 

again this is only taking environmental considerations into account and to leave the site in the 

Green Belt does not meet the economic or social aspirations of the college or the plan. 

7.47 With regard to SA (see: Appendix 3), overall, the LP05 has a mixed effect on SA objectives, 

and the alternatives both have a neutral effect. With regard to the relevant RSF objectives, all 

3 options score an uncertain effect except for RSF 14 (to improve efficiency in land use 


through the appropriate re‐use of previously developed land) which has an adverse effect for 

LP05, a significantly adverse effect for LP05‐A2 and a beneficial effect for LP05‐A1. This 

reflects the fact that environmentally retaining the site in the green belt with its presumption 

against development may be the better course of action, but having control over a certain 

level and form of development as intended in the preferred option is a better alternative 

than the one to remove the site from the Green Belt. The overall SA score (mixed) takes the 

economic benefits of the preferred policy into account. 


7.48 With regard to SEA receptor ER03, the overall conclusion for the preferred policy is a neutral 

effect on the receptor (Appendix 4). This is because it has been judged that land and soil 

resources are unlikely to be materially affected by the scale of development envisaged for the 

settlement area. 


Policy LP07: Development in Virginia Water 

7.50 with regard to the SEA (Appendix 4) LP07 has a mixed positive impact, whilst LP07‐A1 has a 

neutral impact. The benign impact of LP07‐A1 is noted. 




growth. 




7.53 With regard to the policy options in the SEA a neutral impact is recorded (See: Appendix 4). 

However, LP08‐A1 and LP08‐A2 have a significant adverse impact on LSMR1 (reduction of 

land through development). This indicates the DERA site already has significant areas 

committed and this will give rise to decontamination of a site that potentially has significant 

contamination. Additionally, each of the alternatives have an uncertain impact on LSMR3 

(increased use of resources) – this is a consequence of any form of development to meet the 

quantum of development. 

7.54 Each of the policy options will impact on the receptors given the quantum of development. 


does not give rise to a clear preferred policy approach 

7.55 The overall conclusion of the SA (See: Appendix 3) is that LP08 is mixed positive but the other 

alternatives are all neutral. The overall SEA conclusion is that LP08, LP08‐A1 and LP08‐A3 are 

uncertain and LP08‐A2 is neutral. Within the context of the SA Alternative A has a significant 

adverse affect on RSF 9 (create employment), RSF 16 – significantly adverse (improve air 

pollution), but the other RSF are generally well accommodated. However, LP08‐A1 and LP08‐ 

A2 have an adverse affect on RSF 14 (improve reuse of land/building), RSF 19 ((enhance 

biodiversity), and RSF 20 protect countryside), Alternative, LP08‐A3 has an affect on RSF 17 

(impact on climate change). There are therefore a diversity of impacts from the alternatives. 

In conclusion LP08 is more favourable. Compared to the SEA conclusions the alternatives are 

generally uncertain, but the LP08‐A2 is neutral reflecting the spread of development across 

green field sites. 


7.56 With regard to the SA (Appendix 3) and the SEA (Appendix 4) SP01 does not have any 

alternatives. The whole strategy of the Plan depends upon some significant development 

schemes coming forward in the green belt to meet future demand 





7.59 Policy SP02 and SP02‐A1 have a neutral impact on the receptor (See: Appendix 4). SP02‐A2 

has an uncertain impact and this is highlighted with significantly adverse affect on the 

pathway LSMR1 (the reduction of land through development). This is a consequence of an 

alternative that seeks to meet a very high housing provision. 


SP02‐A2 have a positive impact. However, there is an uncertain affect from the alternative 

SP02‐A1 on RSF 1 (providing decent homes), RSF 2 (improving health), RSF 3 (reducing 

poverty) , RSF 6 (creating vibrant communities), and RSF 9 and 11 (stimulating the economy). 

The alternative SP02‐A1 is less acceptable in the SA analysis. However, SP02 does have an 

affect on RSF 16((reducing air pollution). The need to accommodate affordable housing will 

have a consequence for all the receptors, but the impact of the alternative SP02‐A1 is 

different is uncertain and so the alternative SP02 and SP02‐A2 are clearly more acceptable. 

7.61 SP02 overall in the SA consideration does not have an overall different impact to the 

alternative SP02‐A2. However, the SEA has an adverse impact on the pathways. 


7.62 With regard to SEA receptor (Appendix 4) ER03, the overall conclusion for the SP03 is an 

unknown effect on the receptor. This is because it has been judged that Impact Pathways 1 

for land reduction and 2 for soil reduction cannot be known at this time in the absence of 

firm proposals. SP03‐A1 records a neutral impact, as a pathway will be affected on account of 

there being no development involved. However, the alternative of not providing any traveller 


on Land SR. 

7.63 No discussion on SA. 



have an uncertain effect on the environmental receptors. 



7.66 With regard to SEA receptor ER03 (Appendix 4), the overall conclusion for SP05 is a mixed 

effect. SP05 has a mixed effect on impact pathway LSMR1 (reduction of land through 

development) as impacts would depend on the precise location of development. SP05 has an 

uncertain effect on impact pathway LSMR1 as related development will be promoted on 

previously developed land, however the scope of location for related development is wider 

than the preferred policy. Therefore, the overall effects on LSMR1 are uncertain. 

7.67 SP05 has a beneficial effect on impact pathway LSMR2. SP05 has the potential to improve soil 

quality and reduce contamination around the River Thames and other water bodies, and 

through development of new hotel accommodation. SP05 has uncertain effects on impact 

pathway LSMR2 as this is dependent on how much additional tourism is proposed and its 

location. 

7.68 Uncertain effects are found for the SP05 on impact pathway LSMR3 (pressure to increase us 

of material resources), as it is difficult to quantify the amount of development related to the 

policies. For the alternative, it depends on when and where the development will be located. 



7.70 No consideration is given. 





7.73 There is no reasonable alternative to the policy, as it provides a tested mechanism to 

facilitate development. However, the overall impact on the receptors is neutral for SP07 on 

SEA (Appendix 4) and SA (Appendix 3). 


7.74 With regard to the SEA (Appendix 4) the alternatives have a neutral and mixed impact. The 

impact on the pathways of the LP08 and LP08‐A1 is generally benign. Given that this is 

promoting employment growth it is encouraging. 


neutral/positive impact. However, there is an adverse affect form the alternative A on RSF 3 

(reducing poverty) , RSF 6 (creating vibrant communities), RSF 9 and 11 (stimulating the 


workforce), RSF 21 (improving transport), SP08 is less acceptable in the SA analysis. The need 

to accommodate growth will have a consequence for all the receptors, but the impact of the 

alternatives is different in a negative way and so SP08‐A1 is clearly more acceptable. 

7.76 SP08 overall in the SA consideration does not have an overall different impact to SP08‐A1 but 

it is more positive. 


7.77 With regard to SEA receptor ER03 (Appendix 4), the overall conclusion for the policy SP09 is 

a neutral effect. The policy SP09 has a neutral effect on impact pathway LSMR1 (reduction of 

land through development) as the policy focuses on transport services, rather than the 

development itself, and the effect is dependent on the exact location of the development. 

7.78 The policy SP09 has a neutral effect on impact pathway LSMR2 (reduction of soil through 

development and potential contamination), as the introduction of transport infrastructure 

would not increase or decrease the amount of soil available, this effect would be dependent 

on the type of development, and the details of this is currently unknown. 

7.79 Neutral effects are identified for the policy SP09 on impact pathway LSMR3 (pressure to 

increase use of material resources), as it is difficult to quantify the amount of material 

sources used, as this would be dependent on the amount and type of development. 



7.81 SP10 has a neutral impact in relation to SA (Appendix 3) and SEA (Appendix 4). 




LP01 Strategy for the Location of Development 0 0 

Alternative LP01‐A1 0 / 






Significant 

Beneficial 


Significant 

Adverse 

/ 0 ? 




Alternative LP02‐A2 (b) ? 




LP03 Development in Addlestone Urban Area 0 0 



LP04 Development in Egham / Englefield Green Urban Area 0 0 


LP05 Royal Holloway UOL ? 0 


Alternative LP05‐A2 ? 

LP06 Development in Chertsey Urban Area 0 0 


LP07 Development in Virginia Water 0 / 


LP08 The former DERA site, Longcross 0 0 

Alternative LP08‐A1 ? 0 

Alternative LP08‐A2 ? 0 



SP01 Green Belt Areas 0 0 




SP03 Gypsy and Travelling Populations 0 ? 


SP04 Provision and Retention of Infrastructure and Service 0 ? 

SP05 Design ? 

SP06 Tourism, Recreation and Leisure 0 / 


SP07 Thames Basin Heaths Special Protection Area 0 0 

SP08 Employment Development / 0 



SP10 Development and Flood Risk 0 0 


7.82 Cumulative effects not considered likely to result from this receptor. 


7.83 Mitigation and enhancement was suggested through the June 2012 meetings (See: Appendix 

2). It is noted in LP01 ‘Strategy for the location of development’ that soil quality may be 

improved, as the development will include the use of previously developed land. This factor is 

also noted in other policy sets. 

7.84 It is recommended that in LP01 ‘ Strategy for the location of development’ that the plan 

quantifies where resources for building works are to be sourced from in reference to the 

mechanism for effect ‘pressure to increase use of mineral resources’ although it is noted in 

other policy sets this may be difficult to quantify. 




Indicator to be 

monitored 

Frequency 

of data 

collection 

When should 


taken? 

What remedial 

action should be 

taken? 

Development on previously 

developed land (LSF Indicator) 

Annual 

When contamination 

confirmed 

Specific to site 

Previously developed land that 

has been vacant or derelict for 

more than five years (LSF 

Indicator) 

Annual 

When contamination 

confirmed 

Specific to site 



Section 8. 

Introduction 

[ER04] Water Resources and Management 

8.1 The water resources and management receptor covers effects on the biological and chemical 

quality of surface water and ground waters, the safeguarding , use and management of water 

resources, and the management of flood risk to and arising from the transport network and 

associated infrastructure and incorporates a number of SA sustainable development 

objectives as outlined in Table 53. 






SO01 

SO15 



To reduce the risk of flooding and the resulting detriment to public well‐being, 

the economy and the environment 

R 

R 


SO19 To conserve and enhance the region’s biodiversity A 

SO22 

SO24 



To maintain and improve the water quality of the region’s rivers , ground waters 

and coasts , and achieve sustainable water resources management 

G 

A 


FA07 Water R 







goals 



[ER04] Water Resources and Management 

National Policy: Thames Waterway Plan, Thames Corridor Catchment 

Abstraction Management Strategy, Environment Agency-Water Resources for 

the Future, National Planning Policy Framework 

Regional Policy: Regional Sustainability Framework 

Local Policy: Strategic Flood Risk Assessment 

European Law: European Water Framework Directive 

UK Law: Water Act 

Objective: Prepare for, manage, 

and alleviate flood risk and protect 

and conserve water resources. 

Comment: No specific policy on 

water resources. 


International 

European Water Framework Directive (2000) 

8.3 The European Water Framework Directive came into force in December 2000 and became part of UK 

law in December 2003. It provides an opportunity to plan and deliver a better water environment, 

focusing on ecology and will assist in protecting and enhancing water bodies. The framework replaces a 

range of European legislation and aimed to introduce a simpler approach which will result in greater 

protection. 

National 


8.4 The NPPF and its technical flood risk methodology has replaced PPS25 – Development and 

Flood Risk, with the following relevant sections: 94, 100, 109, 110, and 165, which generally, 

 

 

‘support the transition to a low carbon future in a changing climate, taking full 

account of flood risk and coastal change, and encourage the reuse of existing 

resources, including conversion of existing buildings, and encourage the use of 

renewable resources (for example, by the development of renewable energy);’ 

‘promote mixed use developments, and encourage multiple benefits from the use of 

land in urban and rural areas, recognising that some open land can perform many 

functions (such as for wildlife, recreation, flood risk mitigation, carbon storage, or food 

production);’ 

8.5 Section 10 relates specifically to meeting the challenge of climate change, including flooding 

and coastal change with the following relevant paragraphs: 94, 99 – 104, 156, 162 and 166. 

Thames Waterway Plan 

8.6 The vision of the Thames Waterway Plan is to encourage healthy growth in the use of the 

freshwater Thames for communities, wildlife, leisure and business. Its main aims are to 

improve and promote access and information for all users (on water 

and land); 

• improve and maintain the river infrastructure, facilities and services 

for all users; 

contribute to enhanced biodiversity, heritage, and landscape value in the 

waterway corridor; and, 

 

increase use of the river and its corridor. 

Thames Corridor Catchment Abstraction Management Strategy 

8.7 Is a strategy for management of water resources at a local level and sets out the current 

status of water resources in the River Thames 

Environment Agency – Water Resources for the Future 

8.8 This strategy replaces the 2001 'Water resources for the future: A strategy for England and 

Wales'. It sets out how the Environment Agency believes water resources should be managed 

over the coming decades so that water can be abstracted and used sustainably. The strategy 

includes a series of actions that they it is believed need to be taken to deliver secure water 

supply and safeguard the environment. 

Regional 

8.9 Regional Sustainability Framework (2008) 

County 

The Regional Sustainability Framework (RSF) sets a common vision, 25 objectives and four 

priorities that will help guide sustainable development in the South East. 

8.10 No Specific Policies. 



8.11 Strategic Flood Risk Assessment (2009) 

This document provides an assessment of flood risks associated with areas considered for 

future development. 







8.13 Runnymede is located with the Thames Watershed (River Basin) (see. Figure 9). Covering an 

area of some 16,133 square kilometres and encompasses the River Thames and its tributaries 

from its source in Gloucestershire through Runnymede to London and eventually to the North 

Sea. 

Flood Management 

8.14 In Runnymede trend data suggests that there are increased levels of commercial and 

residential properties at risk of flooding. Current data shows that in October 2011 

Runnymede reported 21,633 combined commercial and residential properties at risk of 

flooding. 

Water Quality 

8.15 The River Thames forms the north and eastern boundary of the borough, with the southeastern 

boundary being formed by the River Wey (tributary of the Thames). The River 

Figure 9 – Thames Watershed (River Basin) 

Bourne, a small river having its source in Windsor Great Park, runs through Wentworth, 

Thorpe, Chertsey and Addlestone Bourne areas within the Wey catchment. 

8.16 The rivers in Runnymede are generally of good or very good quality (42) in terms of their 

chemical and biological standards, however their nutrient levels remain high. 

42 Environment Agency ‐ 2009 River Quality data. 


8.17 The levels of nitrates for the river sites sampled by the Environment Agency within 

Runnymede are generally in the grade range of 4‐6 (43) (moderate – very high) and phosphates 

are generally graded 4‐5 (44) (high – very high). Sources of nutrients in the Thames and Wey 

catchment areas include effluent from sewage treatment works and agricultural pollution (45) . 

8.18 Within the Thames Basin region, eight out of 46 groundwater bodies are at good status 

overall; 20 water bodies have been classified at good chemical status, and 16 at good 

quantitative status ( 46) . These results are not expected to change by 2015. The main reasons 

for poor status of groundwater quality are high level of nitrates, sources of which include 

agriculture, effluent from waste and contaminated land sites, and vehicle emissions across 

the basin. The main reasons for poor quantitative status are very high abstraction levels – 

mainly for drinking water – which exceed the rate at which aquifers recharge ( 47) . 

Water Resources 

8.19 Water in Runnymede is supplied by Affinity Water for domestic and commercial purposes. 

8.20 In London and the South East, groundwater accounts for around 70% of the total water 

supply. The Environment Agency has produced Groundwater Source Protection maps for 

Surrey and Runnymede (See: Figure 10 – Source Protection Zones in Surrey and Figure 11 – 

Source Protection Zone in Runnymede). 

8.21 The Environment Agency has subdivided groundwater source catchments into four zones. 

Two of these are determined by the travel time of potential pollutants, the third by the 

source catchment area itself, and the fourth is a ‘Zone of Special Interest’. This fourth zone 

highlights areas where known local conditions mean that potentially polluting activities could 

impact on a groundwater source even though the area is outside the normal catchment of 

that source. 

8.22 Thames Region is one of the driest regions in the UK with average annual rainfall of 690mm 

as compared to the annual average for England and Wales of 890mm ( 48) . High population 

density and dry climate mean that the region is classified as water stressed, having less water 

available per person than other regions in the country. Catchment Abstraction Management 

Strategies prepared by the Environment Agency for the Thames Region show that there is no 

water available in the majority of the catchments and some catchments are assessed as overabstracted. 

Figure 10 – Source Protection Zones in Surrey 

43 Ibid. 

44 Environment Agency ‐ 2009 River Quality data. 

45 Environment Agency (2009) River Basin Management Plan, Thames River Basin District. 

46 Ibid. 

47 Environment Agency (2009) River Basin Management Plan, Thames River Basin District. 


Figure 11 – Source Protection Zone in Runnymede 

8.23 Affinity Water’s data for its central supply area (covering areas to the north and south‐west of 

London – which includes Runnymede) for the year 2007 show the average daily usage per 

capita of 159.8 l for metered households and 175.6 l for unmetered households ( 49) . 

8.24 It is the objective of the new Water Resources Strategy for England and Wales (2009) to 

reduce the average daily water consumption per capita in England to 130 l by 2030 ( 50) . Affinity 

Water’s modelling predictions for 2030 are 152.2 l for metered households and 170.0 l for 

unmetered households 51 . Therefore, various water conservation measures will need to be 

considered to achieve the Water Resources Strategy’s objective. 







Receptor 

[ER04] Water Resources and 

Management 



Summary: The South East records a decrease in the per capita consumption 

of water with data taken in 2008/9 showing an average usage of 156 litres 

pppd. 

There are 31km of waterways within Runnymede. The water quality of the 

borough’s rivers is generally good and the Thames records 100% compliance 

with the EC Bathing Waters Directive (data from 2009) 

48 Environment Agency (2009) Water Resources Strategy Regional Action Plan for Thames Region. 

49 Veolia Water Central (2010) Water Resources Management Plan. Main Report. 

50 Environment Agency (2009) Water for People and the Environment. Water Resources Strategy for England and Wales. 

51 Veolia Water Central (2010) Water Resources Management Plan. Main Report. 


Receptor 



In February 2012 21,603 residential and commercial properties within the 

borough were at risk of flooding. 

Issues and Challenges: Urban development and supporting infrastructure 

networks, such as those being proposed, and are likely to be enhanced as a 

result of induced development. All of which can affect both the use and 

quality of the water environment. The siting of urban development and 

supporting infrastructure such as roads can interrupt the natural flows of both 

surface and ground waters, and can add to problems on flood plains. 

Common construction practice is to use piling which creates preferential 

pathways for groundwater. The quality of both ground and surface water can 

be affected by the run-off which is often laden with pollutants including fuel 

oils and as well as seasonal road treatments (e.g. salt in the winter). 

Possible LP Response: The LP could tighten the policies that it is bringing 

forward policies to further minimise the risks of development and 

infrastructure interfering with the water regime by not only avoiding 

inappropriate development in flood plains but proactively encouraging 

appropriate development and flood protection. Policies could also propose 

that all developments incorporate systems to capture and filter surface water 

run-off into the design of urban hard landscapes, roads and other supporting 

infrastructure as appropriate. 

How LP Responded: Policy SP10 looks specifically to address inappropriate 

development in areas likely to flood. It confines itself to the standards as set 

in the NPPF. 


8.26 The projected impacts of climate change for the South East of England, coupled with a 

growing population, would have a range of implications for the freshwater environment and 

water resources. If average temperatures were to increase in the projected range, and 

summers to become hotter and drier the region’s water resources and freshwater 

environments would be placed at increased risk of adverse effect due to scarcity of resource 

coinciding with a likely increase in demand from the population. 

8.27 High demand in periods of hot weather coupled with restricted availability of surface water 

supplies could also adversely affect groundwater and aquifers, the depletion of which would, 

in turn adversely affect the base flows of rivers and streams. There have been several 

hosepipe bans over the last few years to conserve water resources lasting from spring until 

late summer. 

8.28 In the event of the projected scenario of warmer and wetter winters being realised, the likely 

surfeit of incident rainfall could result in a rise in the risks of flooding from fluvial sources and 

non‐fluvial sources (i.e. surface water runoff during periods of heavy rain). 

8.29 Whilst there is a cumulative effect potential on this receptor, the situation is unlikely to be 

significantly affected by the absence of the plan alone. The ‘effect lock‐in’ of climate change, 

means that the effects over the life of the plan, i.e. up to 2026 are already set. 


WRM1: Impacts on the flow of water 

8.30 The physical provision of development and supporting infrastructure within Runnymede will 

increase the risk of adverse effects as a result of changes to water flow through impedance or 

acceleration of flow of generally surface water. 

WRM2: Impacts on water quality 

8.31 Pressure for development within Runnymede will increase the risk of adverse effects to water 

quality through the development process and use of buildings 

WRM3: Demand for water resources 


8.32 An increase in population within Runnymede will increase demand for water resources which 

in turn will increase scarcity. 



8.33 With regard to the SEA (Appendix 4) all policy options have an adverse impact on the 

receptors. The implication is that any development is likely to have an impact on water 

resource and management due to the scale of development and the potential supply issues. 

The adverse impact on pathways WRM1 and 3 have regard to technical issues on water flow 

and water supply. However, this is a technical issue that can be resolved with the provision of 

investment in the infrastructure. 








(RSF 19). 



8.37 With regard to the SEA (Appendix 4) alternatives LP02 and LP02‐A1 have a neutral impact. 

The remaining policy options have an adverse impact. It is not clear why the policy options 

vary in their impact but it is likely that the comprehensive approach that is offered by the 

former DERA site addresses the key infrastructure issues. The assessment however clearly 

supports an option that is able to positively address the physical infrastructure issues. 











growth. 


They are all neutral. 


8.41 With regard to the SEA (Appendix 4) LP03 has a neutral impact, whilst LP03‐A1 and LP03‐A2 

have an adverse impact. When consideration is given to the affect on the pathways LP03‐A1 

and LP03‐A2 have an adverse impact on pathway WRM 1 – the flow of water and WRM 3 – 

the demand for water. These issues are not present with the alternative A reflecting the 

proposed modest planned approach to development in the town. The reactive impact of 

LP03‐A1 and the larger impact of the significant development are less easy to quantify and 

manage. 







8.43 LP03 overall in the SA consideration does not have a different impact to the alternatives. The 

overall SA conclusion is mixed positive. 


8.44 With regard to the SEA (Appendix 4) the adverse impact of the policy options is a reflection of 

the impact of built development. This is particularly noted on pathways WRM1 and WRM2 

that address the flow and supply of water. However, these are infrastructure issues that will 

need to be dealt with as part of detailed development submissions. 




growth. 




8.47 The SEA conclusion (Appendix 4) for the water resources and management receptor is that 

the policy option LP05 will have an adverse effect while other policy options will have a 

neutral effect. 

8.48 These scores are reflected across all the impact pathways for this receptor, except for WRM2, 

impacts on water quality, which is neutral for all the options. 

8.49 WRM1, impacts on the flow of water, and WRM3, demand for water resources score 

adversely for the preferred option. This is because development will always impact on the 

flow of water and demand for water when compared with the option for no development. 

However, in mitigation, measures can be taken to minimise the effects of the flow of water to 

reduce the numbers and effect on properties at risk of flooding (furthermore, the site is not 

in the functional flood plain), and to maximise the efficient use of water resources, including 

through the use of sustainable building techniques. 

8.50 With regard to SA, overall, the policy LP05has a mixed effect on SA objectives and the 

alternatives both have a neutral effect (Appendix 3). With regard to RSF objectives, the 

preferred option and alternative 2 have a beneficial effect on RSF 1 (to ensure that everyone 

has the opportunity to live in a decent, sustainably constructed and affordable home), but an 

adverse effect on LP05‐A1 reflecting the fact that retaining the site in the Green Belt is not 

the best option when considering the social and economic well‐being of the Borough’s 

population. Conversely, LP05 has an adverse effect and LP05‐A2 a significantly adverse effect 

on RSF 19 – to conserve and enhance the region’s biodiversity. LP05‐A1 has a neutral effect. 

Allowing controlled development of the site to achieve the aspirations of the university may 

have a detrimental effect on the biodiversity of the site, but mitigating measures can be 

taken to minimise or avoid this including the assessment of any new development against 

environmental legislation. The overall SA score (mixed) takes the economic benefits of the 

preferred policy into account. 


8.51 With regard to SEA receptor ER04, the overall conclusion for policy LP06 is an adverse effect 

on the receptor (Appendix 4). This is because it has been judged that additional new 

development must necessarily affect WRM1 pathways 1 (Impacts on the flow of water) and 3 

(Demand for Water resources). Policy LP06‐A1 produces the same conclusion, i.e. adverse 

effect . 

8.52 No discussion on SA. 


8.53 With regard to the SEA (Appendix 4) the adverse impact on the receptors by policy options 

will need to be considered along with the fuller assessment. However, the adverse affect of 

the policy options on the pathways WRM1 and 3 reflect the impact on new development. 

However, these are technical infrastructure matters that will need to be addressed as part of 


the final development schemes. There is a need to accommodate new development to meet 

the needs of the population. 




growth. 




8.56 With regard to the SEA (Appendix 4) the policy options have an overall neutral impact on the 

receptors. The policy options have an overall benign affect on the pathways. This is a 

reflection of the fact that the impact on the pathways can be mitigated through the 

development process for all the policy options. The flow of water (WRM1) the impact on 

water quality (WRM 2), and the demand for water (WRM3) will need to form an integral part 

of the design solution to ensure mitigation. 




8.58 The overall conclusion of the SA (Appendix 3) is that the alternative LP08 is mixed positive 

but the other alternatives are all neutral. The overall SEA conclusion is that policy LP08, LP08‐ 

A1 and LP08‐A3 are uncertain and LP08‐A2 is neutral. Within the context of the SA LP08 has a 

significant adverse affect on RSF 9 (create employment), RSF 16 – significantly adverse 

(improve air pollution), but the other RSF are generally well accommodated. However, the 

LP08‐A1 and LP08‐A2 have an adverse affect on RSF 14 (improve reuse of land/building)., RSF 

19 (enhance biodiversity), and RSF 20 (protect countryside). Alternative LP08‐A3 has an 

affect on RSF 17 (impact on climate change). There are therefore a diversity of impacts from 

the alternatives. 



Ash, Pirbright and Chobham SAC as a result of the implementation of the Local. The Level 6 

HRA Report is presented in Appendices 8 and 9. 

8.60 In conclusion LP08 is more favourable. Compared to the SEA conclusions the alternatives are 




8.61 Policy SP01 does not have any alternatives. The whole strategy of the Plan depends upon 


demand. 




8.64 With regard to the SEA (Appendix 4) the policy options have a neutral impact on the 

receptors and this is reflected in the benign affect on the individual pathways. It is assumed 

that these are technical issues that can be addressed. 




poverty) , RSF 6 (creating vibrant communities), and RSF 9 and 11 (stimulating the 

economy). The alternative SP02‐A1 is less acceptable in the SA analysis. However, SP02 does 

have an affect on RSF 16(reducing air pollution). The need to accommodate affordable 


housing will have a consequence for all the receptors, but the impact of the alternative SP02‐ 

A1 is different and so the alternative SP02 and SP02‐A2 are clearly more acceptable. 

8.66 Policy SP02 overall in the SA consideration does not have an overall different impact to the 



8.67 With regard to SEA receptor ER04, the overall conclusion for SP03 is a neutral effect on the 

receptor (Appendix 4). This is because it has been judged that natural environment and 

biodiversity are unlikely to be significantly affected by the implementation of the policy. 

8.68 No SA discussion. 



have a neutral effect on the environmental receptors. 



8.71 With regard to SEA receptor (Appendix 4) ER04, the overall conclusion for the policy is a 

neutral effect. Policy SP05 has a neutral effect on impact pathway WRM1 (Impacts on the 

flow of water), as the location of development will have an impact on the flow of water, 

rather than its design. However, the policy does state that development will be permitted 

that successfully incorporates flood resilient design measures in areas at risk from flooding, 

and any development that does come forward will need to meet the requirements of 

technical guidance set out in the NPPF and by the Environment Agency. 

8.72 SP05 also has a neutral effect on impact pathway WRM2 (impacts on water quality) as design 

itself will not necessarily have an impact on water quality, although the construction of a 

development might, and so design would need to be carefully thought out to minimise 

adverse impacts on water quality. 

8.73 In relation to impact pathway WRM3 (demand for water resources), SP05 has a neutral effect 

on the impact this pathway as the area already suffers from water stress, however well 

designed development can reduce the demand for water resources. 



8.75 With regard to SEA receptor ER04 (Appendix 4), the overall conclusion for SP06 is an adverse 

effect. The policy option SP06 has a neutral effect on impact pathway WRM1 (Impacts on the 

flow of water). SP06‐A1 also has a neutral effect because any impacts of new development 

that are in areas of flooding will have to meet the requirements of EA standing advice. In 

relation to WRM2 (impacts on water quality), SP06 has an adverse effect as development and 

associated facilities related to tourism, recreation and leisure could be on a large scale, and 

will encourage more people and so could decrease water quality if not managed properly. In 

relation to SP06, water quality could be adversely affected by encouraging activity at the 

River Thames and other water bodies in the Borough. Cumulative effects caused by the 

preferred policy impact on the impact pathway. Impacts on water quality would also be 

affected by the impacts of the SP06‐A1. In relation to impact pathway WRM3 (demand for 

water resources), there will inevitably be an adverse impact on demand for water in an area 

already suffering from water stress. SP06 and its alternative have an adverse effect on impact 

pathway WRM3 because it encourages tourism in the Borough. Cumulative effects caused by 

the SP06 impact on the impact pathway. 

8.76 With regard to SA, overall, SP08 policy has a neutral effect on SA objectives, and the 

alternative has mixed effects (Appendix 3). With regard to RSF objectives, where SP06 and 

the alternative differ in their evaluation, RSF objective 15 (reduce risk of flooding and 

resulting detriment to public well‐being, the economy and the environment). Alternative one 

has a neutral impact on RSF15, but SP06 has a significantly beneficial effect because it 


encourages proposals that enhance the use and access of waterways, that would lead to their 

improvement. SP06 is not very different to alternative one, as more hotel provision will be 

viewed positively, and existing facilities will be utilised more, making a contribution towards 

social aspects within Runnymede. 



facilitate development. However, the overall impact on the receptors is neutral with regard 

to the SEA (Appendix 4) and the SA (Appendix 3). 


8.78 Policy SP08 has a mixed positive impact, whilst the SP08‐A1 has an uncertain impact The 

affect of the alternatives on the pathways are generally benign. This is encouraging given the 

policy is promoting employment growth. 


neutral/positive impact. However, there is an adverse affect from the alternative SP08‐A1 on 



workforce), RSF 21 (improving transport), The alternative SP08‐A1 is less acceptable in the SA 

analysis. The need to accommodate growth will have a consequence for all the receptors, but 

the impact of the alternatives is different in a negative way and so the alternative A is clearly 


8.80 SP08 overall in the SA consideration does not have an overall different impact to the SP08‐A1 

but it is more positive. 


8.81 With regard to SEA receptor (Appendix 4) ER04, the overall conclusion for the policy is a 

mixed effect. The preferred policy has a neutral effect on impact pathway WRM1 (Impacts on 

the flow of water), this policy largely does not effect impacts on the flow of water due to the 

type of infrastructure it is. 

8.82 SP09 also has a beneficial effect on impact pathway WRM2 (impacts on water quality) as the 

thrust of the policy is to require less cars on the roads, therefore less new roads may be 

required to be built. Less cars on the road would result in less water run‐off polluting the 

water courses. 

8.83 In relation to impact pathway WRM3 (demand for water resources), the policy has a neutral 

effect on the impact pathway as this type of infrastructure would not require a large amount 

of water resources. 




have a positive effect on the environmental receptors. 






LP01 Strategy for the Location of Development 0 0 



LP02 Housing Provision and Distribution 0 0 0 


Alternative LP02‐A2 (a) 0 

Alternative LP02‐A2 (b) 0 

Alternative LP02‐A2 (c) 0 


Alternative LP02‐A3 (b) 0 

LP03 Development in Addlestone Urban Area 0 0 



LP04 Development in Egham / Englefield Green Urban Area 0 


LP05 Royal Holloway UOL 0 



LP06 Development in Chertsey Urban Area 0 


LP07 Development in Virginia Water 0 


LP08 The former DERA site, Longcross 0 0 0 

Alternative LP08‐A1 0 0 

Alternative LP08‐A2 0 0 



SP01 Green Belt Areas / 0 




SP03 Gypsy and Travelling Populations 0 0 


SP04 Provision and Retention of Infrastructure and Service / 0 

SP05 Design 0 

SP06 Tourism, Recreation and Leisure 0 


SP07 Thames Basin Heaths Special Protection Area 0 0 

SP08 Employment Development 0 ? 


SP09 Sustainable Transport 0 / 

SP10 Development and Flood Risk 


Significant 

Beneficial (3) 

Beneficial (2) Mixed (1) Neutral (0) Uncertain (-1) Adverse (-2) 

Significant 

Adverse (-3) 

/ 0 ? 



8.87 The ER04 receptor is potentially impacted from a number of sources. In terms of cumulative 

effects, analysis suggests that these receptors are most sensitive to effects arising from the 

following impact pathways as detailed inTable 57. This incorporates the potential impact on 

this receptor of atmospheric pollutants and its ability to affect the quality of the water 

resource. Analysis presented in Appendix 12 indicates that there are a number of feedbacks 

from ER04 – Water Resources & Management to impacts on health and ecosystems. 

Synergistic cross‐boundary appears to represent the principle type of cumulative effect on 

this receptor. 

Table 57 – CEA ER04 – Water Resources and Management 

ER Group IP/MfE Type of CE 

Additive or 

Synergistic 



Environment and 

Biodiversity NEB3: Water Quality Cross‐boundary Additive 

ER04 – Water Resources 

and Management 

ER05 – Air Quality 

ER06 – Climate Change 

WRM1: Water Flow Time lag Additive 

WRM2: Water Quality Cross‐boundary Synergistic 

WRM3: Water Demand Cross‐boundary Additive 




CC1: Emissions from traffic Cross‐boundary Synergistic 

CC2: Emissions from residential 

and commercial developments 

Cross‐boundary 

Synergistic 

8.88 Table 58 suggests that overall the Local plan potentially results in a considerably negative 

cumulative effect on this receptor as a result of policies LP01, LP02 LP04, LP05 and LP08. 

These location policies promote the increase in numbers that will potentially add to the 

pressure placed on a receptor that is already stressed. In the strategic policy range, policy 

SP06 appears to result in a negative cumulative effect. Policy SP09 appears to have a 

potentially positive effect on this receptor. 

8.89 All policies would appear to have the capacity to act across‐boundaries in terms of both air 

and watersheds. 

Table 58 – ER04 – Water Resource and Management CEA Summary 

ER 

Group 

ER01 

ER04 

ER05 

ER06 

IP/MfE 

LP01 

LP02 

LP03 

LP04 

LP05 

LP06 

LP07 

LP08 

SP01 

NEB2 0 0 0 0 0 0 0 ? 0 0 0 

NEB3 

0 0 ? 0 0 

/ 

 

0 0 0 

WRM1 0 0 0 0 0 0 0 0 0 0 0 0 

WRM2 0 0 0 0 0 0 0 0 0 0 0 0 0 0 ? 

WRM3 ? 0 0 0 0 0 0 0 0 ? 0 0 

/ 

/ 

/ 

 

? 0 0 

0 0 0 0 

AQ1 

 

 

 

0 

/ 

/ 

/ 

 

? 0 0 

0 0 0 

AQ2 

 

 

 

0 0 

/ 

/ 

0 

? 0 0 ? 0 0 0 0 0 

AQ3 

 

 

0 0 

/ 

/ 

/ 

 

? 0 0 

0 0 0 0 

CC1 

 

 

 

0 

/ 

/ 

/ 

 

? 0 0 

0 0 0 

CC2 

 

 

 

0 0 

/ 

/ 

0 

? 0 0 ? 0 0 0 0 

CC3 

 

 

0 0 

? ? 

/ 

/ / 

/ 

/ 

? ? 0 0 ? 0 0 0 

0 

0 

 

 

 

 

SP02 

SP03 

SP04 

SP05 

SP06 

SP07 

SP08 

SP09 

SP10 

8.90 As stated in paragraph 5.102 above given the spatial extent of the areas of influence over 

which the identified potential cumulative effects could originate from, it is not considered 


appropriate for the CEA to go any further. To do so would be to place a disproportionate 

burden on the Council. 


8.91 No specified mitigation/enhancement has been suggested. 




monitored 

Frequency 

of data 

collection 

When should 

remedial action 

be taken? 

What remedial action should 

be taken? 

Population within 

water resource zones 

that are in deficit 

(LSF Indicator) 

Rivers of good 

chemical and 

biological water 

quality (LSF Indicator) 

Compliance with EC 

Bathing Waters 

Directive (LSF 

Indicator) 

Annual 

When a planning 

application is 

submitted. 

When annual review of 

inland water quality 

shows results below 

‘good’ water quality 

standard. 


bathing water quality 

shows unsatisfactory 

results. 

Appropriate water conservation 

measures will need to be considered. 

Promote development, which meets 

Code for Sustainable Homes Levels 3, 4, 

and 5 and commercial buildings meeting 

BREEAM ‘very good standard’. 

Would be specific to the identified cause. 

Would be specific to the identified cause. 

Per Capita 

Consumption of 

Water (LSF Indicator) 


water consumption 


results. 

Promote water conservation measures 

and development, which meets Code for 

Sustainable Homes Levels 3, 4, and 5 and 

commercial buildings meeting BREEAM 

‘very good standard’. 

Number of new 

developments 

utilising SuDs and/or 

water efficiency 

measures to 

minimise water 

consumption 


water consumption 


results. 

Promote water conservation measures 

and development, which meets Code for 

Sustainable Homes Levels 3, 4, and 5 and 

commercial buildings meeting BREEAM 

‘very good standard’. 

Properties at risk of 

flooding (LSF 

Indicator) 



submitted. 

At the planning application stage, a Flood 

Risk Assessment (FRA) will be required 

for development proposals of 1 hectare 

or greater in Flood Zone 1 and all 

proposals for new development located 

in Flood Zones 2 and 3. Assessment of 

surface water, drainage, and residual risk 

will be required as part of a FRA. 

New developments will be encouraged to 

use Sustainable Drainage Systems (SuDs) 

to manage runoff and reduce flood risk. 


Section 9. 

Introduction 

[ER05] Air Quality 

9.1 The air quality receptor can be defined as the current and likely future air quality in 

Runnymede. Air pollution can affect human health and natural and built environment. Air 

quality limit values were set for individual pollutants to protect sensitive human and 

ecological receptors, which include: 

 

 

Residential areas, schools and hospitals; 

Ecosystems, designated species or habitats within a designated conservation site; and, 

 

Commercial operations (that may be sensitive to dust). 

9.2 The receptor covers the ‘air factor’ as required by the European Directive and UK Regulations 

on the environmental assessment of plans and programmes and incorporates a number of SA 

sustainable development objectives as outlined in Table 60. This can include the following 

areas: 







SO17 

To address the causes of climate change through reducing emissions of 

greenhouse gases 

R 


SO21 

SO22 

SO25 

To improve the efficiency of transport networks by enhancing the proportion of 

travel by sustainable modes and by promoting policies which reduce the need to 

travel 



To increase energy efficiency , security and diversity of supply and the 

proportion of energy generated from renewable sources in the region 

A 

G 

A 


FA08 Air R 

Policy Context 

9.3 There is a range of policies relevant to air quality at the international, national, regional and 

local level. The key policy documents are set out below and summarised in Table 61 – ER05 

Policy Context Summary. 



goals 




International Policy: Kyoto Protocol on Climate Change 

European Policy: The Sixth Environment Action Programme 

Objective: Enhancing air quality 

will in turn enhance the 



goals 



UK Policy: Air Quality Strategy for England, UK Climate Change Programme, 


Regional/County Policy: Surrey (Partnership) Climate Change Strategy, Surrey 

Transport Plan: Air Quality Strategy, Surrey Transport Plan: Climate Change 

Strategy, Clearing the Air: The Mayor’s Air Quality Strategy 

Local Policy: Runnymede’s Draft Air Quality Plan 

European Law: European Directive on ambient air quality and cleaner air for 

Europe, European Directive relating to arsenic, cadmium, mercury, nickel and 

polycyclic aromatic hydrocarbons in ambient air 

UK Law: The Environment Act, The Air Quality (England) Regulations, The Air 

Quality Standards Regulations, Clean Air Act 

International 

environment and quality of life. 

Comment: The objective gives an 

opportunity to enable the plan to 

take steps to meet its other 

objectives in ways that address 

development related air pollution 

problems and enhance local air 

quality. 

Directive 2008/50/EC on ambient air quality and cleaner air for Europe (“Air Quality Directive”) 

9.4 The “Air Quality Directive” merged most of the previous EU air quality legislation into a single 

directive (except for the fourth daughter directive). The directive sets legally binding limits 

(based on WHO guidelines) for concentrations in outdoor air of major air pollutants that 

impact human health and the environment. These limit values comprise a concentration 

value for the pollutant, an averaging period over which it is measured and the date by which 

the limit values are to be achieved. 

Directive 2004/107/EC relating to arsenic, cadmium, mercury, nickel and polycyclic aromatic 

hydrocarbons in ambient air (Fourth Daughter Directive) 

9.5 The Fourth Daughter Directive completes the list of pollutants described in the “Air Quality 

Directive”. Target values for all pollutants except mercury are defined for the listed 

substances. The only monitoring requirements are specified for mercury. 

The Sixth Environment Action Programme 2002‐2012 "Environment 2010: Our Future, Our Choice" 

9.6 The Sixth Environment Action Programme adopted seven thematic strategies including air 

pollution, which are based on a global approach, by theme. The Air Pollution Thematic 

Strategy of the Programme sets objectives for air pollution and proposes measures for 

achieving them by 2020: modernising the existing legislation, placing the emphasis on the 

most harmful pollutants, and involving to a greater extent the sectors and policies that may 

have an impact on air pollution. 

National 

Environment Act (1995) 

9.7 This act established the Environment Agency and Scottish Environment Protection Agency 

and associated obligations. 

The Air Quality (England) Regulations (2000), as amended by the Air Quality (England) 

(Amendment) Regulations (2002) 

9.8 The requirement by local authorities to carry out regular reviews and assessment of air 

quality in their area against standards and objectives. 

The Air Quality Standards Regulations (2010) 

9.9 The “Air Quality Directive” has been transposed into English law by the Air Quality Standards 

Regulations 2010. These Regulations include criteria for determining how achievement with 

the limit values should be assessed, including consideration of locations and relevant 

exposure. 

Clean Air Act (1993) 

9.10 This act controls smoke emissions. 

The Air Quality Strategy for England, Scotland, Wales and Northern Ireland (2007) 


9.11 The Air Quality Strategy for England provides the Government’s policy framework for air 

quality management and assessment in the UK. It identifies air quality standards and 

objectives for key air pollutants which are designed to protect health and the environment 

and sets out measures for their achievement. 


9.12 The National Planning Policy Framework sets out the Governments Planning policies for 

England. 

Regional/County 


9.13 The Regional Sustainability Framework (RSF) sets a common vision, 25 objectives and four 

priorities that will help guide sustainable development in the South East 

Surrey (Partnership) Climate Change Strategy (2009) 

9.14 The Strategy highlights the potential impacts of climate change and their relevance to Surrey. 

Surrey Transport Plan (2011) 

9.15 The aim of this plan is to help people meet their transport and travel needs effectively, 

reliably, safely and sustainably within Surrey; in order to promote economic vibrancy, protect 

and enhance the environment and improve the quality of life. 

Clearing the Air: The Mayor’s Air Quality Strategy (2010) 

9.16 The strategy sets out a framework for improving London’s air quality and measures aimed at 

reducing emissions from transport, homes, offices and new developments as well as raising 

awareness of air quality issues. 


Runnymede Draft Air Quality Plan (2012) 

9.17 Document in draft 




proposed plan (See Appendix 13). The environmental baseline presented in this section has 

been compiled from available sources of primary and secondary data that in the main relate 

to RSF Indicators that have been monitored by the Council in one form or another since 2004 

(See Appendix 11). 

9.19 Air quality in Runnymede is generally good although two traffic related Air Quality 

Management Areas (AQMAs) have been declared for nitrogen dioxide (NO 2 ) and particulate 

matter (PM 10 ): one adjacent to the M25 (and consisting of two sections) and the other along 

busy congested roads in Addlestone town centre (See Appendix 14 – Current Air Quality in 

Runnymede). 

9.20 Transport (mostly road transport) is a major source of air pollutant emissions, having 

contributed 66% of the total nitrogen oxides (NO x ) and 67% of the total particulates (PM 10 ) in 

2010 53 (see Appendix 14). Runnymede records high levels of car ownership at approximately 

1.5 cars per household ( 54) . The borough also records high levels of traffic travelling to and 

through the borough which contributes to adverse air quality. 

9.21 Runnymede Council monitors nitrogen dioxide using a network of diffusion tubes. The 

existing diffusion tube network provides sufficient data to assess the levels of nitrogen 

dioxide at key sites in the borough including the AQMAs, and to analyse the trends. In 

53 NAEI maps: All emissions by UNECE sectors ‐ 2010 

54 2001 Census – Key Statistics (Cars or Vans) 


addition, an air quality monitoring analyser had been providing continuous NO 2 / PM 10 data 

from Vicarage Road in Egham, between February 2011 and August 2011. 

9.22 Particulate matter concentrations are assumed to follow the national decreasing trends. The 

PM 10 results from the Egham continuous monitoring site showed the average PM 10 

concentration of 25.7 μg/m 3 for the six‐month monitoring period in 2011, well below the 

annual mean objective of 40 μg/m 3 . 

9.23 Nitrogen dioxide concentrations can be of concern close to busy roads and in town centres. 

Two thirds of Runnymede’s roadside nitrogen dioxide diffusion tube monitoring sites had 

been showing average annual concentrations close to (over 36 µg/m3) or exceeding 

objectives for 2011 and 2012 (monitoring results provided in Appendix 14). 

9.24 Although background concentrations of nitrogen oxides and nitrogen dioxide in Runnymede 

are below the limit values for the protection of human health, the current levels still can 

affect the sensitive ecological receptors. Runnymede area lies within a short distance of 

Chobham Common, site designated both as a Site of Special Scientific Interest (SSSI) and as a 

National Nature Reserve (NNR). Chobham Common is also a component of two International 

Sites (European or Natura 2000 sites), the Thames Basin Heaths Special Protection Area (SPA) 

and Thursley, Ash, Pirbright and Chobham Special Area of Conservation (SAC). The Thursley, 

Ash, Pirbright and Chobham SAC currently exceeds the minimum critical loads for nitrogen 

deposition and NO x levels. The Thames Basin Heaths SPA exceeds the minimum and 

maximum range of critical loads and NOx levels (results presented in Appendix 14). 






Table 62 – ER05 Key Environmental Issues and Challenges Summary 

Receptor 




Summary: Background air quality in Runnymede is generally good. The main air 

pollutants are nitrogen dioxide and particulate matter. Particulate matter 

concentrations are assumed to follow the national decreasing trends, however 

nitrogen dioxide concentrations can be of concern close to busy roads and in 

town centres. Results from the roadside nitrogen dioxide diffusion tube network 

have shown exceedences of the annual mean objective at several sites. 

Runnymede contains two Air Quality Management Areas, one running along the 

M25 (north and south of junction 11) and the other located in Addlestone town 

centre. 

High levels of car ownership and use are recorded within Runnymede. 


Issues and Challenges: Traffic flows in Runnymede, whilst not the highest of 

the Surrey boroughs have remained constant with consequent impacts on local 

air quality. Air quality is poor in some areas of the Borough, particularly those 

adjacent to the motorway network, with levels of pollutants likely to exceed the 

national air quality standards set for nitrogen dioxide. 

Possible LP Response: The LP could bring forward policies to manage traffic and 

minimise demand so that the number of vehicles on the local road network is 

positively reduced to ease congestion and improve local air quality. 

How LP Responded: The LP does not contain a specific policy set for Air 

Quality. 

9.26 Particulate matter (PM 10 ) concentrations across the UK decreased for the past two decades. 

Urban background particulate concentrations declined from a peak of 35 μg/m 3 in 1992 to 20 

μg/m 3 in 2011. Roadside particulate concentrations declined from a peak of 39 μg/m 3 in 1997 


to 23 μg/m 3 in 2011 55 . It is assumed that PM 10 concentrations in Runnymede have followed 

the national trends and will continue falling should existing level of development be 

maintained. 

9.27 The annual mean nitrogen dioxide concentrations across the UK averaged for all background 

urban and traffic urban sites (both including long‐running sites) in the AURN (Automatic 

Urban and Rural Network – national monitoring network) showed a decrease over time, 

however the average for traffic urban long‐running sites showed a slight increase in recent 

years 56 . Long‐running nitrogen dioxide diffusion sites in Runnymede reflect the above trend – 

with roadside locations showing slight increases between the years 2006‐2010. It is forecast 

that roadside concentrations will reduce over time, following higher availability and uptake of 

clean vehicle and fuel technologies, however this may not happen as fast as predicted by 

national modelling. 

9.28 Regarding the AQMA in Addlestone, dispersion modelling was carried out for Addlestone 

town centre using ADMS Roads and the NO 2 / PM 10 concentrations were modelled for the 

future year of 2015. The predicted concentrations for 2015 showed exceedences at the 

junction of the main roads in the town centre, however the reduction required for 

compliance with the objectives was predicted to be relatively low (below 5%). Future 

monitoring in the area in the following years will be used to verify the predicted 

concentrations and used to make a decision with regard to future extent of the AQMA. 

9.29 It can be argued that the current levels of congestion in the borough are unlikely to decrease. 

This can be for a number of reasons including increased car dependency, delivery traffic and 

lack of transport infrastructure, which in turn will adversely affect air quality. 

9.30 Opportunities for improvement in relation to air quality can be through enhanced traffic 

management systems. Air quality can be improved through public transport provision in 

relation to reliability, accessibility, cost, affordability, information, and frequency of service. 

Further opportunities to improve air quality could additionally be found in encouraging 

community transport initiatives as well as travel schemes to increase the use of local services 

and reduce unnecessary travel. It may also be suggested that development that cannot 

mitigate air quality issues, even if this conflicts with the objectives of the Sustainable 

Community Strategy, be avoided. 

Potential impact pathways 

9.31 Air quality is affected by several potential pathways. 

AQ1 Emissions to air associated with changes in the total volume and distribution of traffic on 

Runnymede’s roads. 

9.32 High levels of car ownership within Runnymede at approximately 1.5 cars per household and 

traffic travelling into and through the borough contribute to adverse air quality. Increased 

residential development within Runnymede can be expected to further add to traffic 

volumes. 

9.33 New commercial development – shops and services – can be expected to generate additional 

trips to and from the development through attracting customers and visitors from 

neighbouring areas. Additional emissions can also be generated from delivery trips to new 

businesses. 

9.34 Another factor to be considered is the regeneration of town centres which will create new 

jobs in the borough, which in turn will contribute to increased traffic. 

AQ2 Emissions to air associated with the construction and/or maintenance of transport, residential 

and commercial assets / networks and other infrastructure in Runnymede. 

9.35 Runnymede contains approximately 32,700 households (2011 Census) as well as commercial 

development. Runnymede also contains an extensive variety of infrastructure from built 

55 DEFRA (2012): Air Quality Statistics In The UK, 1987 To 2011 ‐ Provisional 

56 DEFRA (2011) Air Pollution in the UK 2010 


infrastructure such as motorways and roads to social facilities such as libraries. 

9.36 Bringing new retail and residential development into the town centres may require upgrading 

or expanding existing infrastructure networks. It is reasonable to expect these commercial 

uses would require energy, which in turn will contribute cumulatively to adverse air quality 

within Runnymede. 

AQ3 Emissions to air associated with heating and resulting from the proposed residential and 

commercial property in Runnymede. 

9.37 An increase in residential and commercial development will increase the amount of energy 

usage which will in turn decrease air quality. Whilst it may be argued that new stock will be 

more likely to be energy efficient in relation to older housing and commercial stock, increased 

stock will still contribute to energy usage and in turn adverse air quality. 



9.38 With regard to the SEA (Appendix 4) LP01 has an uncertain impact on ER05, but LP01‐A1 and 

LP01‐A2 have an adverse impact on the receptor. Within the pathways LP01 and LP01‐A1 

have an adverse impact on pathway AQ1‐2, but LP01 has a neutral impact on AQ3. Marginally 

LP01 has a lesser impact than the other alternatives. In the round the scale of development 

proposed will by its very nature have a negative effect. In general LP01 has a lesser impact 

than the other alternatives. (See Appendix 4). 








(RSF 19). 



9.42 With regard to the SEA (Appendix 4) the impact of all policy options on air quality is for the 

most part uncertain or adverse. However, it is noted that alternatives LP02‐A3 (a) and LP02‐ 

A3(b) have a significantly adverse impact that should be an important factor when 

considering the alternatives. The impact on the pathways is particularly noted for the LP02 

A3(a) and LP02 –A3(B) alternatives – this reflects the larger quantum of development. It is 

particularly noted that the LP02 A3(a) and LP02 A3(b) alternatives have significantly adverse 

effect on pathways AQ1‐3 – Whilst LP02 has an adverse impact on AQ3 (emissions to air 

resulting from new development) (See Appendix 4). It is inevitable that additional 

development will give rise to an impact on air quality – this can not be avoided, but can be 

better managed by a planned approach. 











growth. 





9.46 The adverse impact of LP02‐A2 is noted. The particular issue to examine is the impact of 

LP02‐ A2 on the pathways AQ1‐3, whilst LP02‐A1 impacts adversely on AQ1‐2. The particular 

impact on air quality reflects the impact of increased traffic, construction and heating, etc 

derived from the forms of development (See Appendix 4). The lesser impact of LP02 ‐ is a 

significant factor when reaching a final view. 






9.48 LP03 overall in the SA consideration does not have a different impact to the alternatives. The 

alternatives have a mixed positive impact. 


9.49 The adverse implication of LP04 may require attention when the fuller assessment is 

undertaken. However, the key impact on the pathways of LP04 is due to the quantum of 

growth versus no growth in LP04‐A1 (See Appendix 4). The need to meet growth reflects the 

imperative for planned expansion in the town. 




growth. 




9.52 The SEA conclusion for the Air Quality receptor, is that LP05 will have an uncertain effect, 

LP05‐A1 will have a neutral effect and LP05‐A2 will have an adverse effect (See Appendix 4). 

This reflects the level of development likely to take place under each option, LP05‐A1 

presuming against any development, the preferred option allowing a controlled amount of 

development subject to an approved masterplan, and LP05‐A2 taking the site out of the 

Green Belt and thereby removing all constraint to development. The SA reflects a similar 

pattern, scoring a neutral effect for LP05 and LP05‐A1, and an uncertain effect for LP05‐A2. 

9.53 These scores are reflected in those for the impact pathways AQ1 and AQ2, emissions to air 

associated with traffic on the roads in the borough, and emissions to air associated with 

construction/maintenance of the Borough’s infrastructure, including residential and 

commercial assets. Again these scores are to be expected against the level of development 

proposed by each option. 

9.54 The third impact pathway, emissions to air associated with heating proposed residential and 

commercial property in Runnymede (AQ3), has scores an uncertain effect for both LP05 and 

LP05‐A2 and a neutral effect for LP05‐A1. This is because LP05‐A1 to keep the site in the 

Green Belt will presume against development and so will have no effect on this pathway (or 

on AQ1 and AQ2) while the other two options will involve development. However quantities 

or methods of heating are not known at this stage, so an uncertain score must be given. 

9.55 Policy option LP05 therefore has an uncertain score across all the impact pathways because 

until the type and level of development is known the effects cannot be assessed or 

quantified. LP05‐A1 has scored better across the receptor because we know that no 

development will have a neutral effect. However, as identified across this proposed policy, 

the aspiration of the plan (and therefore the policy) is to allow the college to develop and 

grow, and LP05‐A1 does not meet this aspiration. 


9.56 With regard to SA, overall, the preferred policy has a mixed effect on SA objectives, and the 

alternatives both have a neutral effect. RSF 16 (to reduce air pollution and ensure continued 

air quality improvement) scores an uncertain effect for the preferred option while alternative 

1 has a neutral effect. Alternative 2 scores an adverse effect. For RSF 19 – to conserve and 

enhance the region’s biodiversity – LP05 has an adverse effect and LP05‐A2 a significantly 

adverse effect. LP05‐A1 again has a neutral effect. For both these objectives LP05‐A1 scores 

better than LP05 but again these are environmentally based objectives and do not take 

account of the social and economic benefits of the preferred policy option. Mitigating 

measures can be taken to enable any development of the site meet these environmental 

objectives. 


9.57 With regard to SEA receptor ER05, the overall conclusion for LP06 is a neutral effect on the 

receptor (See Appendix 4). This is because it has been judged that air quality is unlikely to be 

materially affected by the scale of development envisaged for the settlement area. 

9.58 The policy alternatives have a neutral and positive impact. The only uncertain impact relates 

to RSF 22 and RSF 23. However, this is probably has universal implications across all policies 

considered. 


9.59 The neutral impact of both policy options are noted with regard to the SEA (Appendix 4). The 

actual impact on the pathways is also neutral. The need to accommodate growth will have an 

impact on air quality but it is pleasing to note that it is neutral. 




growth. 




9.62 All the policy options have an adverse impact on the receptors (See Appendix 4). The affect 

of the policy options on the pathways addressing air quality is one of the three receptors that 

is particularly critical. In the round the alternatives have a adverse/significantly adverse affect 

on all the pathways, and it is noted that alternative LP08‐A2 has an adverse affect on 

receptorAQ1‐2. 

9.63 The assessments reflect the impact pathways AQ1 and AQ2, emissions to air associated with 

traffic on the roads in the borough, and emissions to air associated with 

construction/maintenance of the Borough’s infrastructure, including residential and 

commercial assets. Again these scores are to be expected against the level of development 

proposed by each option. 

9.64 The third impact pathway, emissions to air associated with heating proposed residential and 

commercial property in Runnymede (AQ3), has an adverse impact effect for all policy options. 

This is because the consequences of new development are to generate requirements for 

heating. However quantities or methods of heating are not known at this stage, but it can be 

expected that the consequences these impacts are relatively predictable. 









9.67 The overall conclusion of the SA is that the LP08 is mixed positive but the other alternatives 

are all neutral. The overall SEA conclusion is that Alternatives LP08, LP08‐A1 and LP08‐A3 are 

uncertain and LP08‐A2 is neutral. Within the context of the SA Alternative A has a significant 

adverse affect on RSF 9 (create employment), RSF 16 – significantly adverse (improve air 

pollution), but the other RSF are generally well accommodated. However, LP08‐A1 and LP08‐ 

2 have an adverse affect on RSF 14 (improve reuse of land/building), RSF 19 ((enhance 

biodiversity), and RSF 20 protect countryside), LP08‐A3 has an affect on RSF 17 (impact on 

climate change). There are therefore a diversity of impacts from the alternatives. In 

conclusion LP08 is more favourable. Compared to the SEA conclusions the alternatives are 




9.68 SP01 does not have any alternatives. The whole strategy of the Plan depends upon some 

significant development schemes coming forward in the green belt to meet future demand. 

9.69 This policy has a general neutral or positive impact on the RFS’s (Appendix 3). 

9.70 No SEA discussion. 


9.71 Policy options SP02 and SP02‐A1 have a neutral impact on the receptors with regard to the 

SEA (Appendix 4), but SP02‐A2 has an uncertain impact (See Appendix 4). This is reflected on 

the impact on the air quality pathways AQ 1 (additional traffic), AQ2 (construction) and AQ3 

(additional heating). These reflect the higher amount of residential development under this 

option. 

9.72 Having regard to the conclusion of SA in Appendix 3, overall, the policy approaches A and A2 

have a positive impact. However, there is an uncertain affect from the alternative A1 on RSF 1 

(providing decent homes), RSF 2 (improving health), RSF 3 (reducing poverty) , RSF 6 (creating 

vibrant communities), and RSF 9 and 11 (stimulating the economy). The alternative A1 is less 

acceptable in the SA analysis. However, SP02 does have an affect on RSF 16(reducing air 

pollution). The need to accommodate affordable housing will have a consequence for all the 

receptors, but the impact of the SP02‐A1 is different and so the SP02 and SP02‐A2 are clearly 


9.73 SP02 overall in the SA consideration does not have an overall different impact to SP02‐A2. 

However, the SEA has an adverse impact on the pathways. 


9.74 Overall the policy alternatives have a neutral or positive affect (Appendix 3). However, for 

RSF 6 the lack of gypsy provision has an impact on community vibrancy. With SP03 RSF 22 has 

a adverse impact. 



9.76 Across the SEA assessment most are affected by the policy alternatives in a neutral or positive 

way (Appendix 4). However, there are some issues with SP03 – A1 in that it impacts on 

elements of ER02 dealing with health and well being . This reflects the potential impact on 

health of the lack of gypsy provision 



9.78 Regarding SEA receptor ER05, the overall conclusion for the preferred policy is a mixed effect 

(See Appendix 4). The policy has a neutral effect on impact pathway AQ1 (emissions to air 

associated with changes in the total volume and distribution of traffic on Runnymede’s roads) 

as the design policy is more focused on the quality of development than its location, it 

therefore would cause neither a positive or negative effect on the impact pathway. 


9.79 The policy has a beneficial effect on impact pathway AQ2 (emissions to air associated with 

construction/maintenance of transport, residential, commercial 

assets/networks/infrastructure in Runnymede), as the policy is concerned with high quality 

development, that includes sustainable design and construction as any development that 

comes forward would need to meet these standards to help reduce emissions to air. 

9.80 SP05 has a beneficial effect on impact pathway AQ3 (emissions associated with heating and 

resulting from proposed residential and commercial property in Runnymede). High quality 

design would result in more efficient development, and the policy proposals will be permitted 

where sensitively incorporated measures to minimise energy consumption, conserve 

resources and provide for renewable energy generation where required are approved. 

9.81 Overall SP05 has a beneficial effect on SA objectives (Appendix 3). The policy has a beneficial 

or significantly beneficial effect in SA terms on all the RSF objectives, with the exception of 

RSF4, RSF8, RSF9, RSF11, RSF13, RSF15, RSF21, RSF25 where the impacts on the objectives 

are neutral. On some of these objectives, this is due to the design policy not being concerned 

with economic development. RSF objectives that are not directly linked to the economy, but 

which the policy has a neutral effect on include RSF25 (increase energy efficiency), although 

the policy looks to sensitively incorporate measures to minimise energy consumption and 

provide for renewable energy generation. 


9.82 Regarding SEA receptor ER05, the overall conclusion for SP06 is a neutral effect (See 

Appendix 4). SP06 has a neutral effect on impact pathway AQ1 (emissions to air associated 

with changes in the total volume and distribution of traffic on Runnymede’s roads). SP06 

could lead to more cars on the road because of existing tourist attractions being located in 

unsustainable locations. However, more local town centre‐focused facilities are promoted, so 

distribution of traffic would be largely unaffected. In addition, the alternative also has a 

positive effect on AQ1 as it has a requirement that new provision for tourism, recreation and 

leisure development be accessible by public transport, and in, or adjacent to, town/district 

centres. Although SP06‐A1 has a more positive effect on the impact pathway, overall the 

preferred policy is more sustainable and has more beneficial impacts on the SEA receptors. 

9.83 SP06 has a neutral effect on impact pathway AQ2 (emissions to air associated with 

construction/maintenance of transport, residential, commercial 

assets/networks/infrastructure in Runnymede), the same applies to the alternative. This is 

because any development that comes forward would need to meet BREEAM standards. 

9.84 SP06 has a neutral effect on impact pathway AQ3 (emissions associated with heating and 

resulting from proposed residential and commercial property in Runnymede), the same 

applies to the alternative. This is because any development that comes forward would need 

to meet BREEAM standards. 

9.85 With regard to SA, overall, SP06 has a neutral effect on SA objectives, and SP06‐A1 has mixed 

effects (see Appendix 3). SP06‐A1 has a beneficial effect on RSF 17 (to address the cause of 

climate change through reducing emissions of greenhouse gases), however SP06 has an 

adverse impact, as the alternative promotes tourism recreation and leisure to be accessible 

by public transport (and reduce the need to travel by car). Overall, SP06 has a neutral effect 

on SA objectives, and SP06‐A1 has mixed effects. SP06 is not very different to SP06‐A1, as 

more hotel provision will be viewed positively, and existing facilities will be utilised more, 

making a contribution towards social aspects within Runnymede. 



facilitate development. However, the overall impact of the receptor is mixed in terms of SEA 

(See Appendix 4) and neutral in term of SA (see Appendix 3). 



9.87 The positive mixed impact of SP08 is noted (See Appendix 4). The impact of SP08 on the 

pathways is generally benign. This is encouraging given the promotion of employment 

growth. 


neutral/positive impact. However, there is an adverse affect from the alternative A1 on RSF 3 





of the alternatives is different in a negative way and so the alternative A is clearly more 

acceptable. 

9.89 In terms of the SA consideration the alternatives do not have an overall different impact but 

SP08 is more positive. 


9.90 Regarding SEA receptor ER05, the overall conclusion for SP09 is a significantly beneficial 

effect (See Appendix 4). The policy has a significantly beneficial effect on impact pathway 

AQ1 (emissions to air associated with changes in the total volume and distribution of traffic 

on Runnymede’s roads) as the policy has a requirement for relevant development to 

contribute where appropriate to new public transport, new development to be located in 

accessible locations, and reduce car use, therefore the policy’s impacts on emissions to air 

due to the amount of traffic will be significantly reduced. 

9.91 SP09 has a significantly beneficial effect on impact pathway AQ2 (emissions to air associated 

with construction/maintenance of transport, residential, commercial 

assets/networks/infrastructure in Runnymede), as contributing positively to new transportrelated 

infrastructure will reduce harmful emissions associated with air pollution. 

9.92 SP09 also has a significantly beneficial effect on impact pathway AQ3 (emissions associated 

with heating and resulting from proposed residential and commercial property in 

Runnymede), as the policy requires the location of the relevant development to be 

sustainably located, and therefore reduce energy consumption from vehicles, which are 

associated with new residential and commercial development. The combination of indirect 

benefits on this impact pathway results in a significantly beneficial effect. 

9.93 SP09 has a neutral or positive impact on the RSF’s. It is only RSF 8 where there is an uncertain 

impact. 


9.94 No alternatives considered. 

9.95 SP10 has a neutral or positive impact on the RSF’s (Appendix 3). 





LP01 Strategy for the Location of Development 0 ? 0 


Significant 

Beneficial 


Significant 

Adverse 

/ 0 ? 




Alternative LP01‐A1 ? 







Alternative LP02‐A3 (a) 


LP03 Development in Addlestone Urban Area 0 / 










LP07 Development in Virginia Water 0 0 


LP08 The former DERA site, Longcross 0 0 





SP01 Green Belt Areas 0 / 






SP04 Provision and Retention of Infrastructure and Service / 

SP05 Design / / 

SP06 Tourism, Recreation and Leisure ? 0 


SP07 Thames Basin Heaths Special Protection Area / / 

SP08 Employment Development / / 


SP09 Sustainable Transport 



9.97 Receptor ER05 – Air Quality is one of the most likely receptors to be potentially impacted 

from a number of sources cumulatively. Analysis suggests that this receptor is as with ER06 – 

Climate Change the most sensitive to effects arising from the following impact pathways as 

detailed in Table 64 – ER05 CEA. This incorporates the potential impact on this receptor of 

atmospheric pollutants and their ability to affect Air Quality. Analysis presented in Appendix 

12 indicates that there are a number of feedbacks from ER05 – Air Quality most notably to 


and from ER06 Climate change. Synergistic cross‐boundary appears to represent the principle 

type of cumulative effect on this receptor. 

Table 64 – ER05 CEA 


Additive or 

Synergistic 














Synergistic 

9.98 Table 65 mirrors the conclusions of ER06 Climate Change suggesting that overall the Local 

plan potentially results in a considerably negative cumulative effect on this receptor as a 

result of policies LP01, LP02 LP04, LP05 and LP08. These location policies promote the 

increase in numbers that will potentially add to the pressure placed on a receptor that is 

already stressed. In the strategic policy range, no policy appears to result in a negative 

cumulative effect. Policy SP09 appears to have a potentially positive effect on this receptor. 

9.99 All policies would appear to have the capacity to act across‐boundaries in terms of airshed. 






ER 

Group 

IP/MfE 

LP01 

LP02 

LP03 

LP04 

LP05 

LP06 

LP07 

LP08 

SP01 

SP02 

SP03 

SP04 

SP05 

SP06 

SP07 

SP08 

SP09 

SP10 

ER01 

ER05 

ER06 

NEB2 0 0 0 0 0 0 0 ? 0 0 0 

NEB3 0 0 ? 0 0 

/ 

 

0 0 0 

AQ1 

/ 

/ 

/ 

? 0 0 

0 0 0 0 

 

 

 

0 

AQ2 

/ 

/ 

/ 

? 0 0 

0 0 0 

 

 

 

0 0 

AQ3 0 

/ 

/ 

? 0 0 ? 0 0 0 0 0 

 

 

0 0 

CC1 

/ 

/ 

/ 

? 0 0 

0 0 0 0 

 

 

 

0 

CC2 

/ 

/ 

/ 

? 0 0 

0 0 0 

 

 

 

0 0 

CC3 0 

/ 

/ 

? 0 0 ? 0 0 0 0 0 

 

 

0 0 

? ? 

/ 

 

? ? 0 0 ? 0 0 0 

/ 

 

/ 

 

0 

/ 

 

0 

/ 

 


Current Planning Controls Background ‐ Planning Policy and the draft 2012 Air Quality Plan (AQAP) 

9.101 Following the example of London Air Quality Strategy, our aim is to ensure that the new 

development is either air quality neutral or better. New development gives rise to emissions 

from the new buildings and the transport movements related to the development. Emissions 

from buildings can be minimised by using low energy design strategies, energy efficiency 

measures and zero emissions heating technologies. To mitigate traffic emissions, new 

development can encourage the use of low emission fuels and technologies. 

9.102 Currently, however, the Council does not have policies specifically addressing air pollution or 

greenhouse gas emissions (‘Renewable Energy’ Interim Advice Note (2010) includes the 


equirement for 10% of energy for all new developments to come from renewable sources, 

however the Note has not been the subject of public consultation) and the measures 

proposed in the draft 2012 Air Quality Plan (AQAP) cannot be implemented without 

substantial funds. It is therefore recommended that the mitigation strategy proposed in this 

section is introduced as a Supplementary Planning Document (SPD) addressing both air 

pollution and greenhouse gas emissions. The aim of the SPD would be to provide guidance on 

air quality and climate changes mitigation measures required to ensure the sustainability of 

the new development as proposed in the policies of the emerging Local Plan. The air quality 

measures that the Council intends to take are already set out in the draft 2012 AQAP. The 

SPD would take account of the issue of cumulative effects and interactions and possible 

trade‐offs between climate change and air pollution mitigation measures. 

Air Pollution / Carbon Reduction Strategy 

9.103 Appropriate mitigation can ensure 

that adverse impacts of 

developments are avoided, 

minimised or offset, in line with the 

National Planning Policy Framework: 

“Local planning authorities should 

seek opportunities to achieve each of 

the economic, social and 

environmental dimensions of 

sustainable development, and net 

gains across all three. Significant 

adverse impacts on any of these 

dimensions should be avoided and, 

wherever possible, alternative 

options which reduce or eliminate 

such impacts should be pursued. 

Where adverse impacts are 

Figure 12 ‐ Hierarchy of methods for addressing air 

pollution 

unavoidable, measures to mitigate the impact should be considered. Where adequate 

mitigation measures are not possible, compensatory measures may be appropriate” (s. 152 of 

the NPPF). 

9.104 The hierarchy of methods for addressing air quality and greenhouse gas emission issues is 

shown in Figure 12. Any adverse impacts should be avoided in the first place. This means that, 

for instance, locations where current air pollution levels are high should be avoided. If 

alternative sites cannot be identified, the development design, layout and location should be 

looked at in terms of potential reductions in air quality impacts and greenhouse gas 

emissions. If redesign measures are not sufficient to fully reduce the impacts to an acceptable 

level then mitigation can be used to either protect sensitive receptors (from existing or future 

pollutant concentrations) or reduce total air pollutant / greenhouse gas emissions from the 

proposed development. As it is assumed that every development will add to overall air 

emissions and, in some cases, introduce new exposure to an area of poor air quality, 

offsetting measures will provide money for schemes that improve overall air quality. 

9.105 Specific measures should be suited to development’s scale, predicted magnitude of air quality 

impacts and existing pollutant concentrations. A generic (non‐exhaustive) list of mitigation 

and offsetting measures, grouped into categories, has been compiled from available guidance 

documents (Appendix 15). This list should be read alongside its Table 1 where the type of 

measures was assigned to developments according to their size/predicted impact and existing 

pollutant concentrations. 

9.106 Under the current system only the largest developments or developments within or adjacent 

to an AQMA are required to go through an Air Quality Assessment. However, even in the case 

of large developments located in areas poor air quality, the predicted changes in nitrogen 

dioxide / particulate matter concentrations modelled by the developer continue to show 

negligible or insignificant impacts. The following are possible reasons for this. 


The dispersion software used to model future concentrations assume large 

reductions in emissions in future years associated with cleaner vehicles – so even 

with a large increase in vehicle numbers developers can still report an improvement 

in air quality. 

Developers do not take into account the cumulative impacts of other proposed (or 

already permitted) developments for the area. 

As there is no official national guidance on determining the significance of air quality 

impacts, describing significance remains an issue of contention. For instance, 

developers can interpret increases in concentrations of up to 0.4 µg/m 3 as 

imperceptible or negligible following Development Control: Planning For Air Quality 

(2010 Update). 

9.107 As it is assumed that every development will add to overall air emissions, be it emissions from 

buildings or additional traffic, it is proposed that every new development meeting the CIL’s 

definition of a dwelling is required to contribute towards the cost of tackling poor air quality. 

These financial contributions secured through Community Infrastructure Levy (CIL) would be 

then spent on offsetting measures (as listed in Appendix 15). 

9.108 In addition, to minimise site‐specific direct emissions from new developments and reduce 

exposure of new residents to poor air quality, developers will be required to implement 

redesign and mitigation measures according to the magnitude of impacts and existing 

pollutant concentrations at the development site. The assumed scale of impact was related to 

the predicted increase in car numbers and based on the study of available guidance 

documents – listed in Table 2 of Appendix 15. 

9.109 Small development of up to 10 units to be located at sites where air pollutant levels are close 

to or exceeding objectives can be required to make improvements to the development design 

and layout (redesign measures in Appendix 15), for example, ensure that at busy roads 

appropriate distance is maintained between the building and the road; place sensitive uses 

(bedrooms, children play areas) in the least polluted parts of the site; limit car parking spaces; 

provide cycling facilities (e.g. shelters) and look into improving building insulation (above 

current regulations) and/or increasing the proportion of energy generated from renewable 

sources (above current regulations). Small developments in background locations where 

current air pollution levels remain well below objectives can still be required to look into 

design improvements and, for example, provide shelters for bicycles and improve building 

thermo efficiency. These design improvements will be secured through planning conditions. 

9.110 The direct impact of slightly larger developments of 11‐50 units is also considered to be low; 

however, if located at sites of relatively poor air quality, they may be required to make 

changes to design and layout (similar to small developments). They could also use some of 

the mitigation measures in Appendix 15 to encourage sustainable modes of transport, for 

example, by providing new residents with information of public transport, routes/times and 

walking and cycling routes. Mitigation measures will be secured through planning obligations. 

9.111 It is assumed that developments of 50‐100 units will have the potential for a low to medium 

impact on air quality, depending on the existing pollutant concentrations in the area. It is 

suggested that higher adverse impact of these development is managed by a broader range 

of redesign and mitigation measures. In addition to the measures described above for smaller 

developments, the measures to be applied by larger developments could, for example, 

include reduced parking provision and /or preference given to low emission / car club 

vehicles and improvements to traffic management or road layout at the development site. 

9.112 Unless proven otherwise, potentially significant adverse air quality impacts of developments 

of a size above 100 units will be presumed. Developers will be required to use a broad range 

of redesign and mitigation measures. Redesign measures to be considered by large 

developments include walking and cycling routes/facilities; provision of facilities for public 

transport, such as bus stops and lay‐bys, communal combined heat and power and improved 

building insulation (above current regulations). Part L of the Building Regulations identifies 

the legal minimum a development needs to meet in terms of energy efficiency in the UK. The 

Council could introduce more stringent demands for larger developments. In addition, a 


oad range of mitigation measures will be used, for example, provision of a car club or car 

share scheme; provision of electric charging points or biogas facilities; improvements to 

public transport fleet (low emission buses); agreements with service vehicles to achieve 

specified emissions standards. 

Development in Runnymede – Policy LP01 

9.113 Redevelopment of former DERA site (1500 residential units) will constitute the largest 

development in Runnymede (one third of the total number of units). Large developments of 

over 100 units (other than DERA) will constitute another third of the total. The final third of 

all development will consist of applications for up to 100 residential units, of which 96% will 

be applications for up to 50 units (all data IDP): 

DERA development – 33% 

Other developments over 100 units – 33% 

Developments of 50‐100 units – 4% 

Developments of up to 50 units – 30% 

Development in Addlestone – Policy LP03 

9.114 According to the IDP, 60% of the proposed developments in Addlestone are applications for 

medium‐size developments of above 100 units. The further 18% are applications for 11‐50 

units and the remainder are expected be for small applications of below 10 units. 

9.115 It is recommended that applications for larger developments are accompanied by the 

following assessments: 

 

 

 

Transport Assessment ‐ to provide details of transport impacts and identify traffic 

issues. 

Air Quality Assessment – to assess air quality impacts. 

Energy Assessment – to provide details of energy efficiency and carbon reduction 

measures. 

9.116 The findings of the above assessment should be used to take a decision regarding appropriate 

mitigation / offsetting measures. Road layout (e.g. for the junction of the High Street and 

Station Road) and traffic management (e.g. traffic light optimisation) are examples of 

schemes aimed at improving traffic flows in the town centre and benefiting air quality. Larger 

developments could also be required to prioritise low‐emission vehicles for parking 

spaces/deliveries and contribute to cycling infrastructure (shelters, dedicated paths), public 

transport improvements and alternative fuel provision. 

Development in Chertsey – Policy LP06 

9.117 Larger developments over 100 units have been proposed for Pretoria Road, Hanworth Lane 

and Franklands Drive in Addlestone. 

9.118 Franklands Drive development has already commenced and the site is located out of the main 

town centre, at the south outskirts of Chertsey (Row Town). It can be expected that the new 

residents will commute on the M25, which may cause further delays at Junction 11 of the 

M25 – nearest to the development. 

9.119 Future residents of both Pretoria Road and Hanworth Lane developments can be expected to 

commute on the A320 (to reach the M25), A317 and A318 to destinations in Woking, 

Weybridge and Byfleet. In an unlikely scenario where all new residents of Pretoria Road and 

Hanworth Lane developments (altogether 271 residential units) choose to commute on the 

A317, this would increase the existing traffic by approximately 3% i ,well below the 

significance threshold determined by the Highways Agency (Appendix 16, Table 2). 

9.120 It is recommended that applications for larger developments are accompanied by Transport, 

Air Quality and Energy Assessments. The development at Pretoria Road already has a full 

planning permission. However, the Hanworth Lane development of 150 residential units has 


not been approved yet and can be required to implement/contribute to suitable redesign, 

mitigation and offsetting measures. 

Development in Egham and Englefield Green – Policy LP04 

9.121 About 50% of the proposed residential developments in Egham will consist of applications for 

less than 50 units. Two larger developments of over 100 units were already granted a 

planning permission– Wapshott Road a full planning permission and, very recently, Brunel 

University was granted an outline permission. 

9.122 An application for a development of 90 residential units at Wick Road, Englefield Green, has 

been recently submitted. It is recommended that the developer carry out traffic and air 

quality assessments to determine traffic and air quality impacts on the A30 and the Egham 

By‐Pass and Runnymede roundabouts. 

Redevelopment of the former DERA site – Policy LP08 

9.123 New development at the former DERA site will by far constitute the largest development in 

the Borough. An application for the development of the northern site has been recently 

submitted to the Council. The application is supported by Transport and Air Quality 

Assessments. Several points should be raised regarding the provided assessments. 

9.124 The assessments demonstrated negligible transport and air quality impacts. This conclusion 

was reached after comparing the Proposed Development scenario (up to 76,970 sqm and up 

to 200 dwellings) with the already Consented Development scenario (approximately 90,000 

sqm of office space with ancillary uses). The developer’s argument is that compared to the 

development that has already been consented, the Proposed Development will not produce 

additional traffic. Therefore, when compared to the Consented Development, the Proposed 

Development will have a neutral effect on air quality in respect of both human health and 

ecological receptors. 

9.125 It is recommended that the developer resubmits the transport and air quality assessments, 

taking into account the fact that neither commercial nor residential development exists so far 

at the site. Therefore, the traffic baseline should not include either the permitted (but not yet 

built), or the proposed developments. 

9.126 Another issue to be raised is that the developer has not considered the whole site (northern 

and southern part) in the assessment. Traffic and air quality impacts should be considered 

cumulatively and take account of the total number of residential units proposed for the 

whole site, which amounts to 1,500. 

9.127 In addition, as nitrogen dioxide in Runnymede have not been reducing as predicted by 

national models, it is recommended that 2012 emission factors are used to determine air 

quality impacts of the development as a worse‐case scenario. Should the development be 

completed in 2020, nitrogen dioxide concentrations will be higher than when modelled for 

2035. The developer has not considered the fact that (part or all of) the development might 

be completed earlier than 2035. Finally, given the sensitivity of the location, it is suggested 

that the significance criteria used to assess the magnitude of change in concentration for 

annual mean NO 2 and PM 10 should be more stringent than the ones adopted by EPUK 58 and 

used by the Developer in their Air Quality Assessment. 

9.128 Regarding the Energy Statement prepared to support the application for the development of 

DERA’s northern site, the developer proposed to achieve compliance with Code for 

Sustainable Homes Level 3 and expressed commitment to exceed by at least 10% the carbon 

reductions mandated under Part L of the 2010 Building Regulations. It is also proposed to 

provide 10% of the of energy demand from renewable sources, with preference given to 

incineration and gas – fired Combined Heat and Power. 

9.129 In response to this Energy Statement, it is recommended that the developer meets CSH Level 

4 as CSH level 3 energy standard is already incorporated in the 2010 Building Regulations. 

Since level 4 of the Code will be required from 2013 under 2013 Building Regulations, it 

58 EPUK (2010) Development Control: Planning For Air Quality (2010 Update) 


would be reasonable to require it in 2012 for a large development. CHS Level 4 is expected to 

reduce carbon emissions by 25% compared with a dwelling built according to the 2010 

Building Regulations (which higher than the proposed 10%) and is considered optimal in 

terms of air quality benefits, especially if ultra NO x boilers and solar hot water or heat pumps 

are used 59 . The proposed waste incineration as a heating technology needs to be assessed in 

terms of its potentially adverse air quality impacts. The same applies to gas‐fuelled Combined 

Heat and Power as these systems need to run more intensely in order to supply power to the 

building, which in turn results in elevated NO x emissions 60 . 


9.130 SEA monitoring involves measuring air quality indicators to assess a causal link between the 

implementation of the plan and its likely significant effects as reflected in the measured 

values of the indicators. 

9.131 Monitoring the Local Plan to ensure that any adverse effects which arise during 

implementation, whether or not they were foreseen, can be identified and that action can be 

taken by Runnymede Borough Council to deal with them. 

9.132 Air quality assessments for proposed developments need to be based on monitoring data as 

opposed to background pollution data obtained from Defra’s national maps. 

59 Par Hill Research Ltd (2012) 14 Cost Effective Actions to Cut Central London Air Pollution 





monitored 

Frequency 

of data 

collection 

When should 


be taken? 

What remedial action should be 

taken? 

Levels of NO 2 / PM 10 

in AQMAs and at 

worst‐case sites with 

relevant exposure. 

Annual 

When levels of these 

two pollutants exceed 

the objectives. 

If the objectives are not being met an AQMA 

will be declared and a Local Air Quality 

Action Plan will be produced to improve air 

quality within that area 

Days when air 

pollution is moderate 

or high (LSF 

Indicator). 

Continuous 

When the number of 

days when 1‐hour 

mean for NO 2 and 24‐ 

hour mean for PM 10 

exceed the objectives 

is higher than 

permitted. 



Action Plan will be produced to improve the 

air quality. 

Levels of NO2 / PM 10 

at or near sites 

planned for future 

development. 

Annual 

At the stage of air 

quality assessment if 

levels of these two 

pollutants exceed the 

objectives. 

Greater weight must be given to the 

consideration of air quality impacts and 

their mitigation. 

This should address not only the impacts in 

the immediate vicinity of the development 

but also the wider impacts on air quality 

within the AQMA. 

Change in number 

and extent of 

designated AQMAs 

Annual 

At the stage of air 

quality assessment if 

levels of NO 2 / PM 10 

have continuously 

exceeded the 

objectives 



Action Plan will be produced to improve the 

air quality within that area. 

Total NO x and PM 10 

emissions 

Annual 

When levels of these 

two pollutants show 

no reductions over 

the years of the Plan’s 

implementation. 

If levels of NO 2 and/or PM 10 emissions ‐show 

no reductions it will be necessary to identify 

the cause and undertake an appropriate 

remedial action. 

Section 10. 



Section 11. 

Introduction 

[ER06] Climate Change 

11.1 The climate change receptor covers effects on the atmosphere in terms of emissions of 

greenhouse gases in relation to the generation of energy and its use for heating, lighting, 

power, and transportation. The receptor covers ‘climatic factors’ as required by the European 

Directive and UK Regulation on the environmental assessment of plans and programmes and 


11.2 The predicted changes in climate and global weather patterns have the capacity to affect 

agriculture, plant life, and ecosystems. In addition, the occurrence of extreme weather events 

such as storms, floods, heat waves and pests can constitute a threat to human health and life. 

11.3 The consideration of climate change can effectively be split into two separate areas: 

 

Climate Change Adaptation – Consideration of the effects that are expected to 

occur over the next 30 years, irrespective of the actions taken to reduce climate 

change emissions (the ‘Lock in effect’); and, 

 


Climate Change Mitigation – This area considers measures designed to reduce 

dependency on the main contributors to climate change emissions and operates 

in the 30+ year time horizon. 

Table 67 – Applicable SA/SEA Objective/Factor to Climate Change 





SO17 

To address the causes of climate change through reducing emissions of 

greenhouse gases 

R 



SO21 

SO25 



travel 

To increase energy efficiency , security and diversity of supply and the 

proportion of energy generated from renewable sources in the region 

A 

A 


FA09 Climatic Factors R 








goals 


objectives and 

comment 


International Policy: Convention on Climate Change and 

Biological Diversity: Earth Summit, Kyoto Protocol on Climate 

Change 

European Policy: European Sustainable Development 

Strategy, The Sixth Environment Action Programme, EU 

Energy Efficiency Plan 

UK Policy: UK National Energy Efficiency Action Plan, UK 

Renewable Energy Strategy, UK National Renewable Energy 

Action Plan, ABI The Vulnerability of UK Property to 

Windstorm Damage, Energy White Paper, UK Carbon Plan 

,UK Communication Strategy for Climate Change, White 

Paper – Meeting the energy challenge, National Planning 

Policy Framework 


Surrey Policy: Surrey Climate Change Strategy, Surrey 

Strategic Partnership Plan, Surrey Transport Plan: Climate 

Change Strategy 

Local Policy: Runnymede Renewable Energy Interim Advice 

Note 

European Law: European Renewable Energy Directive, 

European Cogeneration Directive, European Energy Services 

Directive, , European Energy Performance of Buildings 

Directive, European Landfill Directive 

UK Law: Climate Change Act, Energy Act, Building 

Regulations 

Objective: Mitigating against the long-term 

dangerous effect of climate change, and 

implement measures to adapt to the impact of 

‘locked-in’ change in next forty years. 

Comment: Whilst the objective is at the heart of 

the aspirations of the SCS, it does not appear to 

have the same status in its Local Plan. The Local 

Plan does seek to prevent development in areas 

likely to flood (aligned to national policy) but it is 

unclear how it will assist in improving the Council’s 

response to emergencies such as flooding, 

heating, cold and storminess. Indirect potentially 

negative public health issues that will be 

exacerbated in an ageing population will need to 

be addressed, including enhancing potential 

positive benefits such as increased tourism. In 

addition, the Local Plan could have provided an 

opportunity to deliver development in the flood 

zone by which fund improved flood defences that 

would counter some the potential impact on asset 

values already in areas likely to flood. 

International 

Convention on Climate Change and Biological Diversity: Earth Summit (1992) 

11.5 The United Nations Framework Convention on Climate Change came into force in 1994 and 

requires developed countries to take measures aimed at returning emissions of greenhouse 

gases (in particular carbon dioxide) to 1990 levels by 2000 and to provide assistance to 

developing countries. The Convention set no mandatory limits on greenhouse gas emissions 

for individual countries and contains no enforcement mechanisms. Instead, the treaty 

provides for updates ("protocols") that would set mandatory emission limits. 

Kyoto Protocol on Climate Change (1992) 

11.6 Under the Kyoto Protocol on Climate Change, the UK government has agreed a legally binding 

target to reduce greenhouse gas emissions by 12.5 % below the base year (1990) level over 

the period 2008 – 2012. This target was reached: UK emissions were 22% lower in 2008 than 

in the base year. 

European Renewable Energy Directive (2009) 

11.7 The 2009 Renewable Energy Directive sets a target for the UK to achieve 15% of its energy 

consumption from renewable sources by 2020. 

European Energy Efficiency Directive (2012) 

This Directive establishes a common framework of measures for the promotion of energy 

efficiency to ensure target of 20% improvement in the EU's energy efficiency is achieved. The 

directive repeals the Cogeneration Directive (2004) and Energy Services Directive (2006). 

European Energy Performance of Buildings Directive (2002) 


11.8 The Directive requires buildings to be made more energy efficient. The Member States must 

ensure the certification of buildings energy performance and require the regular inspection of 

boilers and air conditioning systems in buildings. 

European Landfill Directive (1999) 

11.9 The Directive is intended to prevent or reduce the adverse effects of the landfill of waste on 

the environment, in particular on surface water, groundwater, soil air and human health. 

The Sixth Environment Action Programme 2002‐2012 

11.10 The Sixth Environment Action Programme sets an objective to reduce greenhouse gases to a 

level that will not cause unnatural variations of the earth's climate. In the short term, the 

European Union's aim is to achieve the objectives of the Kyoto Protocol, i.e. to reduce 

greenhouse gas emissions by 8 % by 2008‐2012 compared with 1990 levels. In the longer 

term, by 2020 it will be necessary to reduce these emissions by 20 to 40 % by means of an 

effective international agreement. To meet the challenges of climate change the EU will strive 

to achieve the following objectives: the integration of climate change objectives into various 

policies, in particular energy policy and transport policy; reduction of greenhouse gases by 

means of specific measures to improve energy efficiency, increased use of renewable energy 

sources, agreements with industry and to make energy savings; establishment of an EU‐wide 

emissions trading scheme; improved research on climate change; improvement of the 

information provided to the public on climate change; review of energy subsidies and their 

compatibility with climate change objectives; preparing society for the impact of climate 

change. 

EU Energy Efficiency Plan (2011) 

11.11 The EC adopted the Communication "Energy Efficiency Plan 2011" for saving more energy 

through concrete measures aimed at creating substantial benefits for households, businesses 

and public authorities. 

National 

Climate Change Act (2008) 

11.12 The Act sets the target for greenhouse gas emissions to be cut by at least 34% by 2020, and 

by at least 80% by 2050, below 1990 levels. The Act introduced five‐year carbon budgets as a 

tool to achieve this target and set up the independent Committee on Climate Change. 

Energy Act (2011) 

11.13 The Act makes provisions for energy efficiency measures to homes and businesses – Green 

Deal (scheme aimed at improvements to the energy efficiency of households and nondomestic 

properties) and private rented sector energy efficiency improvements ‐ and 

provides measures to enable and secure low‐carbon energy supplies and fair competition in 

the energy markets. 

Part L of Building Regulations (2010) 

11.14 Building Regulations cover emissions from energy use through heating, hot water and 

building services. 

National Planning Policy Framework (Ch. Meeting the challenge of climate change, flooding and 

coastal change ‐ Ss. 93, 94, 95, 96, 97 ) 

11.15 Local planning authorities should adopt proactive strategies to mitigate and adapt to climate 

change, supporting the delivery of renewable and low carbon energy and associated 

infrastructure. 

National Planning Policy Framework (Core planning principles – S.17) 

11.16 Planning should support the transition to a low carbon economy and encourage the reuse of 

existing resources and the use of renewable resources ; seek to secure high quality design 

and a good standard of amenity for all existing and future occupants of land and buildings 

and contribute to conserving and enhancing the natural environment and reducing pollution. 


National Planning Policy Framework (Ch. Promoting sustainable transport – S. 30) 

11.17 Encouragement should be given to solutions which support reductions in greenhouse gas 

emissions and reduce congestion. All developments that generate significant amounts of 

traffic should be supported by a Transport Statement or Transport Assessment. 

The Carbon Plan: Delivering our low carbon future (2011) 

11.18 The document sets out the Government's plans for achieving the emissions reductions 

committed to in the first four carbon budgets, on a pathway consistent with meeting the 

2050 target. 

Renewable Energy Strategy (2009) 

11.19 The Renewable Energy Strategy sets out measures to increase the amount of energy from 

renewable sources from 1% of UK’s total energy use in 2005 to 15% by 2020. This target can 

be achieved through increasing electricity generated from renewables to over 30% by 2020 

(from 5.5% in 2008), increasing heat generated from renewables to 12% by 2020 (from less 

than 1% in 2008) and increasing transport energy generated from renewables to 10% by 2020 

(from less than 3% in 2008). 

National Renewable Energy Action Plan (2010) 

11.20 The National Renewable Energy Action Plan is based on the UK Renewable Energy Strategy 

and provides details on a set of measures that would enable the UK to meet its 2020 target 

for 15% of its energy consumption to come from renewable sources. 

National Energy Efficiency Action Plan (2007) 

11.21 This Action Plan sets out the package of policies and measures to deliver improvements in 

energy efficiency in the UK in order to contribute to the achievement of UK climate and 

energy policy objectives. 

White Paper ‐ Meeting the energy challenge (2007) 

11.22 The document sets out the Government’s international and domestic energy strategy to 

address the long term energy challenges and deliver four energy policy goals: cutting CO2 

emissions; maintaining the reliability of energy supplies; promoting competitive markets in 

the UK and beyond and ensuring that every home is adequately and affordably heated. 

Regional 




County 

Surrey (Partnership) Climate Change Strategy (2009) 

11.24 Surrey Climate Change Strategy, produced in 2009 by the Surrey Climate Change Partnership 

(SCCP), seeks to provide a framework to effectively address climate change across Surrey 

over the period to 2020. The Strategy is delivered by the members of the SCCP ‐ all eleven 

Surrey’s district and borough councils and Surrey County Council. The Strategy has three core 

objectives: emission reductions, adapting to climate change and raising awareness. Under 

these three objectives, the Strategy identified a range of Programmes and Deliverables based 

on government performance indicators and targets for carbon reduction and climate change 

adaptation. 

Surrey Transport Plan (2011): Climate Change Strategy 

11.25 Surrey Transport Plan (2011) consists of several specific strategies. The purpose of each 

strategy is to set out the most cost‐effective measures, interventions and policy tools to 

tackle problems and address objectives and targets. The aim of the Climate Change Strategy 

is to reduce carbon dioxide emissions from transport in Surrey and from the transport 

infrastructure and activities of Surrey Strategic Partnership. The objectives of the Strategy are 



to reduce distance travelled by reducing the need to travel, increase the proportion of travel 

by sustainable modes, maintain public transport patronage and increase vehicle occupancy, 

switch to lower carbon vehicles, encourage efficient driving and manage traffic flows, reduce 

energy use of transport infrastructure and services and manage the risks posed to transport, 

by forecasted effects of climate change. The specific targets are to reduce emissions of 

carbon dioxide from all road transport (except motorway traffic) by 10% by 2020 as 

compared with 2007 baseline(to be composed of approximately 7% from national measures 

and 3% from local measures), and increasing to 25% reduction by 2035 on 2007. Another 

target is to reduce emissions of carbon dioxide by 28% reduction from SCC business travel by 

2013/14 as compared with 2008. 

Runnymede Renewable Energy Interim Advice Note (2010) 

11.26 The Renewable Energy’ Interim Advice Note (2010) includes the requirement for 10% of 

energy for all new developments to come from renewable sources and provides advice to 

developers on the range of renewable energy technologies, which may be incorporated into 

developments to achieve this aim. The Note has not been the subject of public consultation. 







Climate Change Impacts 

11.28 Climate change occurs naturally over long periods of time; however since the industrialised 

era a period from the 18 th to the 19 th century, emissions of large amounts of greenhouse 

gases have caused an acceleration of global climate change. The effects tend to result in rapid 

variation in temperatures leading to heat stress and cold stress, increased number of extreme 

weather events that lead to increased instances of flooding and drought putting additional 

pressure on water supply and quality. 

11.29 The UK is located in the path of the warm, wet westerly winds associated with the Gulf 

Stream and the climate reflects this maritime position. Runnymede lies in the county of 

Surrey within the south east corner of the British Isles and therefore furthest away from the 

influences of the North Atlantic’s weather systems. 

11.30 Runnymede’s geographical location means it benefits from a mild climate that is normally 

characterised by cool summers, with average temperatures of around 15 o C, mild winters, 

with average temperatures in excess of 5 o C, and relatively low rainfall, of around 500 

millimetres per year, and no marked dry season ( 61) . 

11.31 It is likely that adverse effects identified in the Council’s Draft Local Climate Impacts Profile 

(LCLIP) 2009 will continue with increased frequency and magnitude as the climate continues 

to change. The borough will need to continue to adapt to climate change particularly to the 

effects of increased temperatures overall and increased risk of flooding. It is also possible for 

Runnymede to decrease its contribution the causes of future climate change (i.e. 30‐year plus 

climate change time horizon), and thus in time contribute to an overall reduction in adverse 

effects on the climate change receptor. 

Greenhouse Gas Emissions 

11.32 Road transport is a major source of carbon emissions. In 2009 this sector contributed 49% to 

total emissions of carbon dioxide in Runnymede. Domestic electricity and gas emissions were 

the second largest source of carbon dioxide in 2009 contributing 24% to the total 62 . Within 

61 Rising to the Challenge: The impacts of climate change in the South East (Technical Report), 1999. S Wade, J Hossell, M Hough 

and C Fenn (ed.s). 

62 NAEI maps: CO2 emissions by energy users/suppliers ‐ 2009 


the transport sector in Runnymede, the majority of carbon emissions can be attributed to 

motorway traffic. Traffic volumes on Surrey’s motorways have been steadily increasing over 

the last 20 years and the average traffic flows have been much higher than the national 

average. The average daily traffic flow on the M25, between junctions 11 and 12 in 2007 

Runnymede was 177,034 (63) vehicles per day as compared to the national average of 77,400 

(64) vehicles per day. 

11.33 Emissions for Runnymede in 2008 were estimated at 6.6 t per capita (source: NI186), showing 

a reduction of 4% since 2005. The above data exclude emissions over which local authorities 

do not have direct influence ‐ that is emissions from motorways and diesel railways and 

emissions associated with existing lawful land use. 







Receptor 




Summary: Summary: Road transport is a major source of carbon emissions. 

The second largest source is domestic gas and electricity consumption. 

Although traffic on principal roads in Surrey has continued to decrease from 

2003 levels, traffic volumes on Surrey’s motorways have been steadily 

increasing over the last 20 years and the average traffic flows have been 

much higher than the national average. Within the transport sector in 

Runnymede, the majority of carbon emissions is attributed to motorway 

traffic. Meeting the considerable challenges presented by a volatile climate 

with a built fabric and infrastructure that has been developed in absence of 

this consideration will be difficult. The Local Plan proposals will potentially 

modify 4.5% of the residential stock, 95.5% of residential stock will remain 

outside the plans range. 

Issues and Challenges: Issues of climate change can be divided into two 

distinct groups; mitigation and adaptation. Mitigation addresses a 30+ year 

time horizon and involves reduction in emissions and improvements in energy 

efficiency. Adaptation deals with the ‘locked-in’ climate up to 30 years and 

generally involves adaptation measures. Urban development resulting in 

energy and transport use is a major source of carbon emissions, and 

consequently a significant contributor to climate change for the borough. 

Total traffic on major roads within Surrey has remained constant between 

2000-2010.The proximity of two major airports is a major draw for road 

traffic. The impacts of climate change or the effects that effective adaptation 

can reduce are difficult to predict, but for Runnymede is likely to include an 

increased risk of flooding and subsidence [see: LCLIP]. 

Possible LP Response: The LP could bring forward policies to manage energy 

use plus traffic levels and demand for transport. It could identify objective 

targets to reduce new development and redevelopment carbon emissions. 

The LP could bring forward a policy that ensures the Boroughs infrastructure 

network capacity is capable of coping with the expected consequences of 

climate change. The LP could bring forward a policy that protects the ability of 

the main urban centres to install ‘district heating systems’. 

How LP Responded: The LP does not have a policy set on Climate Change. 

The most relevant is Policy SP10 that deals with flooding. 


11.35 A changing climate may lead to hotter drier summers, warmer wetter winters, higher sea 

levels and an increase in extreme events such as heat waves, droughts and floods. It has been 

projected that this change will affect boroughs such as Runnymede 

63 Traffic count data for roads in Runnymede, 2006‐2008 as supplied by Surrey County Council. 

64 Surrey County Council (2011) The Surrey Transport Plan (LTP3) Environmental Report. 


11.36 By the 2050s, it has been projected that the South East of England may experience ( 65) : 

 

 

 

 

 

 

An estimated increase in average summer temperatures of 1.5 – 3.5 o C relative to the 

baseline period of 1961‐1990; 

An estimated increase in average winter temperatures of 1.0 – 2.0 o C relative to the 

baseline period of 1961‐1990; 

An estimated increase in winter rainfall of 0 to 20% relative to the baseline period of 

1961‐1990; 

An estimated decrease in summer rainfall of 10 to 40% relative to the baseline period of 

1961‐1990; 

An estimated overall increase in temperature and rainfall variability compared with the 

1961‐1990 period; and, 

More frequent and extreme summer heat waves and very wet winters compared with 

the 1961‐ 1990 period. 

11.37 Main challenges and opportunities for greenhouse gas emissions reductions in Runnymede 

are set out in Table 70 below. 

Table 70 – Existing Planning Policies Connected with Climate Change 

Challenge / Opportunity 

Details 

Renewable Energy Resources • In Runnymede, the most cost effective options for micro 

renewable generation appear to be solar thermal water heating 

systems, solar photovoltaic panels, air source heat pumps and 

ground source heat pumps and biomass. Wind turbines are less 

cost effective in Runnymede as the area is less exposed to strong 

winds than for example a coastal or upland location, and the 

economic return on wind turbine installation would be longer. 

• Runnymede’s Renewable Energy Interim Advice Note requires all 

new commercial developments (over 300 square metres floor 

space) and single residential units including replacement dwellings, 

to be designed so that at least 10% of the on site installed energy 

requirement is provided from a renewable source. 

Energy Efficiency The policy is to improve energy efficiency performance of new 

and existing buildings and influence behaviour of occupants. 

 

It remains to be decided whether the Council will collect a tariff 

from major developments that would be paid into a fund for home 

energy efficiency improvements. 

Emissions Reduction • It is promoted to seek zero carbon development by 2016. 

Combined Heat and Power (CHP) 

Energy Sources 

• It is promoted to encourage the integration of combined heat 

and power (CHP), including mini and micro–CHP, in all 

developments and district heating infrastructure in large scale 

developments in mixed use. 

Biomass • The use of biomass fuel will be investigated and promoted 

where possible. 

65 Arkell, B., Darch, G., Wilson, E. and Piper, J. (2004) South East Climate Threats and Opportunities Research Study (SECTORS). 

Technical Report for the South East England Development Agency, Guildford. 


Challenge / Opportunity 

Details 

Insulation • The Council will seek to continue to offer each householder who 

has loft or cavity wall insulation installed in their home £60 off 

their Council Tax for one year, which is the current agreement 

with British Gas. Higher contributions from British Gas towards 

Council Tax may also be available for the installation of Solar 

Thermal Hot Water and Solar Photovoltaics. 

Transport • The policy is to seek to reduce the need to travel and ensure good 

accessibility to public and other sustainable modes of transport. 

Sustainability and Waste 

Management 

• It is promoted for new developments to be built to Code for 

Sustainable Homes and BREEAM ‘excellent’ standards. 

Flood Management • New development will be allocated in sequential order with priority 

given to sites of low annual probability of flooding. Development on 

other land at higher risk of flooding must demonstrate that 

appropriate flood mitigation measures will be implemented and 

that any residual risk can be safely managed. 

• The use of Code for Sustainable Homes and BREEAM ‘excellent’ 

standards are recommended. 


CC1 Greenhouse gas emissions associated with changes in the total volume and the distribution of 

traffic on Runnymede’s roads. 

11.38 High levels of car ownership and changes in the number of vehicles travelling on the road 

network in Runnymede will affect the volume of greenhouse gas emissions that can be 

attributed to road transport. For example a net increase in vehicle number could result in an 

increase in emissions of greenhouse gases, although that would be dependent on the types of 

vehicles that accounted for this increase. 

CC2 Greenhouse gas emissions associated with the construction and/or maintenance of transport, 

residential and commercial assets / networks and other infrastructure in Runnymede. 

11.39 Runnymede contains approximately 32,700 households (2011 Census) as well as commercial 

development. Runnymede also contains an extensive variety of infrastructure from built 

infrastructure such as motorways and road to social facilities such as libraries. Bringing new 

retail and residential development into the town centres may require upgrading or expanding 

of the existing infrastructure networks. It would be therefore expected that premises would 

require energy use which will increase emissions of greenhouse gases within Runnymede. 

CC3 Greenhouse gas emissions associated with heating, electricity use and waste management and 

resulting from the proposed residential and commercial property in Runnymede. 

11.40 An increase in residential and commercial development will increase the amount of energy 

usage which will in turn increase emissions of greenhouse gases. Whilst it may be argued that 

new stock will be more likely to be energy efficient in relation to older housing and 

commercial stock however increased stock; will still contribute to energy usage and in turn 

increased emissions. 

11.41 The plan provides for increased development which will contribute to emissions and in turn 

climate change. It can be discussed that due to the location of Runnymede it is likely that 

contributions to climate change will continue to rise despite the implementation of the plan. 

Consideration of Policy and its Alternatives on ER06 Climate Change 


11.42 The policy options have a varied overall impact on the receptor with regard to the SEA 

(Appendix 4). However, the individual pathways do have some notable trends. LP01‐A2 has a 

significantly adverse impact on CG1‐2, whilst LP01 and LP01‐A1 have an adverse impact. This 


is a reflection of the scale of development and the consequences of increased traffic 

movement and other impacts of development on greenhouse emissions. It is difficult to 

moderate this impact until detail proposals are in place but they are issues that need 

consideration during detailed discussion. 








(RSF 19). 



11.46 The LP02‐A2 alternatives have an uncertain impact with regard to the SEA (Appendix 4). 

However, it is noted that LP02 and LP02‐A2(c) have an adverse impact and LP02‐A3(a) and 

LP02‐A3(b) have a significantly adverse impact. The impact of the options is particularly 

adverse when the pathways CG1‐3 are assessed. Large scale additional development will have 

an impact on greenhouse emissions. It is lessened for the lower impact options but these do 

not meet future need that may arise through further unplanned development. 







by the greenfield alternatives, whilst the impact on air quality is adverse (RSF 16) for all 




growth. 




11.50 The policy option LP03 has a mixed positive affect (Appendix 4). The impact of LP03‐A1 is 

uncertain and the adverse impact of LP03‐A2 is noted It is of note that the alternative LP03‐ 

A2 is particularly adverse – illustrating the scale of development on green house emissions. 

For A1 the impact is less but reflects the unplanned nature of the growth. LP03 is favoured as 

its planned approach will enable the issues associated with climate change to be addressed. 


neutral impact. The impact on air quality is uncertain/adverse (RSF 16) for all the policy 

options and this is reflected on the impact on the pathways. The need to accommodate 

growth will have a consequence for all the receptors, but the impact of the alternatives is not 

different for planned or unplanned growth. 



11.53 With regard to the SEA (Appendix 4) the adverse impact of LP04 will need to be considered in 

the fuller assessment. The full impact of the LP04 on the pathways CG1‐3. This is a 

consequence of additional development and the impact on climate change and in particular 

greenhouse gas emissions. This is a consequence of meeting the needs of the future 


population as it requires some form of growth. This requires an acceptance that mitigation is 

required as part of future development schemes. 




growth. 

11.55 The preferred approach overall in the SA consideration does not have a different impact to 

the alternative, apart from being more positive. 


11.56 The SEA conclusion for ER06 (Appendix 4), Climate Change, is that the policy LP05 will have 

an uncertain effect. LP05‐A1 scores a neutral effect and alternative LP05‐A2 an adverse 

effect. These scores are reflected across the individual impact pathways CC1 and CC2, relating 

to greenhouse gas emissions associated with changes in the volume and distribution of traffic 

and the construction/maintenance of infrastructure in Runnymede, including transport, 

residential and commercial. Similarly, impact pathway CC3, greenhouse gas emissions 

associated with heating, electricity use and waste management from residential and 

commercial use in the borough, scores an uncertain effect and a neutral effect respectively 

for LP05 and LP05‐A1 but also an uncertain effect for LP05‐A2. These scores reflect the fact 

that LP05‐A1, to keep the site in the Green Belt will presume against development and so will 

not give rise to greenhouse gas emissions, hence the neutral score, whereas development, as 

suggested by LP05 and LP05‐A2, may give rise to emissions. LP05 suggests a limited amount 

of development relating solely to the academic use of the site, the uncertain scores reflecting 

the lack of detail at this stage in order to ascertain if the level and type of construction will 

give rise to greenhouse gas emissions across the impact pathways. LP05‐A2 would allow 

greater levels and type of development, hence the overall adverse score in this respect. 

11.57 Again the conclusion can be drawn from the SEA that LP05‐A1 is the best alternative because 

it can be determined with certainty that it will not give rise to greenhouse emissions, but this 

alternative does not meet the aspirations of the plan to retain the college in the borough. The 

uncertain score for LP05 indicates that this option may not give rise to greenhouse gas 

emissions, and methods to mitigate this effect will be considered as a part of implementation 

of this policy. 


alternatives both have a neutral effect. RSF 16 (to reduce air pollution and ensure continued 

air quality improvement) scores an uncertain effect for LP05 while LP05‐A1 has a neutral 

effect. LP05‐A2 scores an adverse effect. For RSF 19 – to conserve and enhance the region’s 

biodiversity – LP05 has an adverse effect and LP05‐A2 a significantly adverse effect. LP05‐A1 

again has a neutral effect. For both these objectives LP05‐A1 scores better than the preferred 

option but again these are environmentally based objectives and do not take account of the 

social and economic benefits of the preferred policy option. Mitigating measures can be 

taken to enable any development of the site meet these environmental objectives. 


11.59 With regard to SEA receptor ER06, the overall conclusion for LP06 is a neutral effect on the 

receptor (Appendix 4). This is because it has been judged that climate change is unlikely to be 

materially affected by the scale of development envisaged for the settlement area. LP06‐A1 is 

categorised as uncertain, as the location and scale of not specified in the policy. 

11.60 No SA discussion 


11.61 With regard to the SEA (Appendix 4) the neutral impact is noted on LP07. LP07 also has a 

neutral impact on the pathways. Given that there is a neutral impact on climate change this 

can be viewed as a positive signal about development. 





growth. 




11.64 With regard to the SEA (Appendix 4) all the policy options have an adverse impact on the 

receptors. The affect of all policy options is to have an adverse impact on pathways CG1 (due 

to traffic volumes), and CG2 (due to infrastructure enhancements), whilst pathway CG3 (due 

to increased electricity use and waste management) have an uncertain impact due to the 

requirement for further information about the type and style of development. However, the 

overall impact on the receptors is a consequence of the quantum of development. It is 

necessary to ensure that development will need to have mitigation measures to seek to 

reduce the impact on climate change. This is a policy objective of the Local Plan and will need 

to underpin any development submissions. This is one of the receptors that is of particular 

concern, but the overall SEA conclusion is that the impact is uncertain. 








11.67 The overall conclusion of the SA is that the alternative A is mixed positive but the other 

alternatives are all neutral (Appendix 3). The overall SEA conclusion is that LP08, LP08‐A1 and 

LP08‐A3 are uncertain and LP08‐A2 is neutral. Within the context of the SA LP08 has a 

significant adverse affect on RSF 9 (create employment), RSF 16 – significantly adverse 

(improve air pollution), but the other RSF are generally well accommodated. However, the 

LP08‐A1 and LP08‐2 have an adverse affect on RSF 14 (improve reuse of land/building)., RSF 

19 ((enhance biodiversity), and RSF 20 protect countryside), LP08‐A3 has an affect on RSF 17 

(impact on climate change). There are therefore a diversity of impacts from the alternatives. 

In conclusion LP08 is more favourable. Compared to the SEA conclusions the alternatives are 






11.69 No SA/SEA discussion 


11.70 SP02 and SP02‐A1 have a neutral impact on the receptors (Appendix 4), whilst SP02‐A2 has 

an uncertain impact. The uncertain impact of SP02‐A2 is reflected in the pathways CG1 

(impact of traffic), CG2 (impact of construction), and CG3 (impact of energy use). This reflects 

the affect of the higher level of development. 


have a positive impact. However, there is an uncertain affect form the SP02‐A1 on RSF 1 


vibrant communities), and RSF 9 and 11 (stimulating the economy). SP02‐A1 is less 



receptors, but the impact of the alternative SP02‐A1 is different and so the alternative SP02 

and SP02‐A2 are clearly more acceptable. 





11.73 With regard to SEA receptor ER06 (Appendix 4), the overall conclusion for the preferred 

policy is a neutral effect on the receptor. This is because it has been judged that climate 

change is unlikely to be significantly affected by the implementation of the policy. The 

alternative to the preferred option is also recorded as neutral. 




have a mixed effect on the environmental receptors. 



11.77 With regard to SEA receptor ER06 (Appendix 4), the overall conclusion for the impact of SP05 

on climate change is mixed. SP05 has a neutral effect on impact pathway CC1 (traffic on 

Runnymede’s roads), as the design policy is more focused on the quality of development than 

its location or its ability to generate traffic. 

11.78 SP05 has a beneficial effect on impact pathway CC2 (Greenhouse gases associated with the 

construction and/or maintenance of transport, residential and commercial assets/networks 

and other infrastructure in Runnymede), as development needs to be of a high quality design, 

minimising energy consumption and providing for renewable energy generation. 

11.79 SP05 has a beneficial effect on impact pathway CC3 (associated with heating, electricity and 

waste management resulting form proposed residential and commercial property in 

Runnymede), as development needs to be of a high quality design, minimising energy 

consumption, conserving resources and providing for renewable energy generation. 

11.80 Overall SP05 has a beneficial effect on SA objectives (Appendix 3). SP05 has a beneficial or 

significantly beneficial effect in SA terms on all the RSF objectives, with the exception of RSF4, 

RSF8, RSF9, RSF11, RSF13, RSF15, RSF21, RSF25 where the impacts on the objectives are 

neutral. On some of these objectives, this is due to the design policy not being concerned 


which the policy SP05 has a neutral effect on include RSF25 (increase energy efficiency), 

although SP05 looks to sensitively incorporate measures to minimise energy consumption 

and provide for renewable energy generation. 


11.81 With regard to SEA receptor ER06 (Appendix 4), the overall conclusion for the policy option 

SP06 on climate change is neutral. SP06 has a neutral effect on CC1 (traffic on Runnymede’s 

roads). SP06‐A1 has a positive effect because it requires new tourism and associated facilities 

to be accessible by public transport. SP06 could lead to more cars on the road because of 

existing tourist attractions being located in unsustainable locations. However, more local 

town centre‐focused facilities are promoted, so distribution of traffic would be largely 

unaffected. In addition, the policy option SP06‐A1 also has a positive effect on CC1 as it has a 

requirement that new provision for tourism, recreation and leisure development be 

accessible by public transport, and in, or adjacent to, town/district centres. Although SP06‐A1 

has a more positive effect on the impact pathway, overall SP06 is more sustainable and has 

more beneficial impacts on the SEA receptors. 

11.82 SP06 has a neutral effect on impact pathway CC2 (Greenhouse gases associated with the 

construction and/or maintenance of transport, residential and commercial assets/networks 

and other infrastructure in Runnymede), the same applies to SP06‐A1. This is because any 

development that comes forward would need to meet BREEAM standards, and therefore 

construction of new development would not have a negative effect on the impact pathway 

because it would need to be sustainably constructed. 


11.83 SP06 has a neutral effect on impact pathway CC3 (associated with heating, electricity and 

waste management resulting form proposed residential and commercial property in 

Runnymede), the same applies to the alternative. This is because any development that 

comes forward would need to meet BREEAM standards and therefore construction of new 

development would not have a negative effect on the impact pathway as it would need to 

reach the minimum standards of construction and it would be required to be energy efficient. 

11.84 Having regard to SA, overall, (Appendix 3) the preferred policy has a neutral effect on SA 

objectives, and the alternative has mixed effects. AP06‐A1 has a beneficial effect on RSF 17 

RSF objective 17 (to address the cause of climate change through reducing emissions of 

greenhouse gases), however SP06 has an adverse impact, as SP06‐A1 discusses tourism 

recreation and leisure to be accessible by public transport (and reduce the need to travel by 

car). Overall, the SP06 has a neutral effect on SA objectives, and SP06‐A1 has mixed effects. 

SP06 is not very different to SP06‐A1, as more hotel provision will be viewed positively, and 

existing facilities will be utilised more, making a contribution towards social aspects within 

Runnymede. 



facilitate development. However, the overall impact on the receptor is mixed positive with 

regard to the SEA (Appendix 4) 

11.86 No discussion of SA 


11.87 With regard to the SEA (Appendix 4) the positive mixed impact of SP08 is noted,. The affect 

of LP08‐A1 on the pathways is generally benign. This is encouraging for a policy that 

promotes employment growth. 


neutral/positive impact. However, there is an adverse affect form the alternative SP08‐A1 on 



workforce), RSF 21 (improving transport), The alternative SP08‐A1 is less acceptable in the SA 

analysis. The need to accommodate growth will have a consequence for all the receptors, but 

the impact of the alternatives is different in a negative way and so the SP08 is clearly more 

acceptable. 

11.89 The preferred approach overall in the SA consideration does not have an overall different 

impact to the alternative but it is more positive. 


11.90 With regard to SEA receptor ER06 (Appendix 4), the overall conclusion for the impact of the 

policy on climate change is significantly beneficial. SP09 has a significantly beneficial effect on 

impact pathway CC1 (traffic on Runnymede’s roads), as the policy has a requirement for 

relevant development to contribute where appropriate to new public transport, new 

development to be located in accessible locations, and reduce car use, therefore the policy’s 

impacts on traffic will be significantly reduced. 

11.91 SP09 has a significantly beneficial effect on impact pathway CC2 (Greenhouse gases 

associated with the construction and/or maintenance of transport, residential and 

commercial assets/networks and other infrastructure in Runnymede), as contributing 

positively to new transport-related infrastructure will reduce greenhouse gases. 

11.92 SP09 has a neutral effect on impact pathway CC3 (associated with heating, electricity and 

waste management resulting from proposed residential and commercial property in 

Runnymede), as SP09 requires the location of the relevant development to be sustainably 

located, and therefore reduce energy consumption from vehicles, which are associated with 

new residential and commercial development. The combination of indirect benefits on this 

impact pathway results in a significantly beneficial effect. 




11.94 With regard to the SEA (Appendix 4) policy option SP10 has a neutral impact. 





LP01 Strategy for the Location of Development 0 ? 0 







Alternative LP02‐A2 (c) 0 



LP03 Development in Addlestone Urban Area 0 / 










LP07 Development in Virginia Water 0 0 


LP08 The former DERA site, Longcross 0 0 





SP01 Green Belt Areas 0 / 






SP04 Provision and Retention of Infrastructure and Service / 

SP05 Design / 

SP06 Tourism, Recreation and Leisure ? 0 



Significant 

Beneficial 


Significant 

Adverse 

/ 0 ? 




SP07 Thames Basin Heaths Special Protection Area / / 

SP08 Employment Development / / 


SP09 Sustainable Transport / 



11.96 Receptor ER06 is another receptor with the potential to be impacted from a number of 

sources cumulatively. Analysis suggests that this receptor is as with ER05 most sensitive to 

effects arising from the following impact pathways as detailed in Table 72 – ER06 CEA. This 

incorporates the potential impact this receptor receives as a result of atmospheric pollutants 

and their ability to affect climate change. Analysis presented in Appendix 12 indicates that 

there are a number of feedbacks from ER06 most notably to ER05 Air Quality. Synergistic 

cross‐boundary type effects appear to represent the principle type of cumulative effect on 

this receptor. 

Table 72 – ER06 CEA 


Additive or 

Synergistic 














Synergistic 

11.97 Table 73 – ER06 CEA Summary mirrors the conclusions of ER05 Air Quality. Similarly this 

would suggest that overall the Local plan potentially results in a considerably negative 

cumulative effect on this receptor as a result of policies LP01, LP02 LP04, LP05 and LP08. 

These location policies promote the increase in numbers that will potentially add to the 

pressure placed on a receptor that is already stressed. In the strategic policy range, no policy 

appears to result in a negative cumulative effect. Policy SP09 appears to have a potentially 

positive effect on this receptor. 

11.98 All policies would appear to have the capacity to act across‐boundaries in terms of airshed. 


ER 

Group 

IP/MfE 

LP01 

LP02 

LP03 

LP04 

LP05 

LP06 

LP07 

LP08 

SP01 

SP02 

SP03 

SP04 

SP05 

SP06 

SP07 

SP08 

SP09 

SP10 

ER01 

ER05 

ER06 

NEB2 0 0 0 0 0 0 0 ? 0 0 0 

NEB3 0 0 ? 0 0 

/ 

 

0 0 0 

AQ1 

/ 

/ 

/ 

? 0 0 

0 0 0 

 

 

 

0 

AQ2 

/ 

/ 

/ 

? 0 0 

0 0 

 

 

 

0 0 

AQ3 0 

/ 

/ 

? 0 0 ? 0 0 0 0 

 

 

0 0 

CC1 

/ 

/ 

/ 

? 0 0 

0 0 0 

 

 

 

0 

CC2 

/ 

/ 

/ 

? 0 0 

0 0 

 

 

 

0 0 

CC3 0 

/ 

/ 

? 0 0 ? 0 0 0 0 

 

 

0 0 

? ? 

/ 

 

? 0 0 ? 0 0 0 

/ 

 

/ 

 

/ 

 

0 

/ 

 







11.100 This section should also be read alongside Section 11 – Air Quality Mitigation/Enhancement 

Recommendations. The following paragraphs supplement Section 11 by specifically 

addressing reduction of greenhouse gas emissions. 

Climate Mitigation 

11.101 Additional reductions in carbon emissions can be delivered using higher ratings of the Code 

for Sustainable Homes (CSH) – as shown in Table 3 of Appendix 15. Carbon emission 

reductions under Building Regulations and different standards for the sustainable design and 

construction are shown in Figure 1 of Appendix 15. Affordable housing is funded by the 

Homes and Community Agency that requires homes to be built to code level 3. In addition, 

the 2010 Building regulations already include CSH level 3 energy standard. Level 4 of the Code 

will be required from 2013 under the new Part L of Building Regulations; therefore 

developers could be required to achieve level 4 rating in 2012. 

11.102 Developers can be required to provide 10‐15% of the development’s total predicted energy 

requirements from renewable energy sources. This 10‐15% requirement will ensure that 10‐ 

15% reduction in carbon dioxide emissions from the development is achieved through the 

supply of onsite renewable energy. Suitable technologies are described in (‘Renewable 

Energy’ Interim Advice Note (2010). It is worth to note that some heating technologies, 

although beneficial in terms of carbon reductions, can have potentially adverse effects on air 

quality (increase emissions of NO x and PM 10 ). It is considered that requiring CSH Level 4 and 

encouraging heating technologies like solar hot water or heat pumps will ensure optimal 

results in terms of both carbon and air pollution emissions reductions 67 . 

Climate Adaptation 

11.103 New development will have to adapt to the potentially negative effects of weather patterns 

caused by climate change. Design measures to be potentially required from new 

development will include: 

 

 

 

 

Sustainable drainage systems to be applied where practicable to reduce the risk 

of flood downstream of the development; 

Passive building strategies, for instance passive ventilation and appropriate 

orientation of buildings to reduce risk of overheating; 

Planting trees and shrubs in and around developments at locations where the 

vegetation may help reduce overheating in the summer and reduce heat loss in 

winter; 

Installing water efficient systems and appliances to help conserve water. Also 

installing equipment that increases on site self‐sufficiency in water. 






monitored 

Frequency of 

data collection 

When should 


taken? 

What remedial action should be taken? 

Impacts 

Emissions of CO 2 by 

source (LSF Indicator) 

Annual 

When annual total 

emissions of CO 2 by 

source show 

unfounded increases. 

If levels of CO 2 emissions by source show 

unexpected increases it will be necessary 

to identify the cause and undertake an 

appropriate remedial action. 

Per capita reduction 

in CO 2 emissions 

(NI186) 

Annual 

When expected 

reduction in CO 2 

emissions per capita is 

not achieved. 

When reduction in CO 2 emissions per 

capita is not achieved it will be necessary 

to identify the cause and undertake an 


Energy use per capita 


Annual 

When expected 

reduction in energy 

use per capita is not 

achieved. 

When reduction in energy use per capita 

is not achieved it will be necessary to 

identify the cause and undertake an 


Electricity and heat 

production from 

renewable energy 

sources and CHP 

located in the area 

Annual 



submitted and shows 

inadequate levels of 

energy provision from 

a renewable source. 

Greater weight will be given to the 

consideration of air quality and climate 

change impacts and their mitigation. 

Conditions will be imposed to increase the 

provision of energy from renewable 

sources. 

% new homes 

achieving Code for 

Sustainable Homes 

Levels 3, 4, and 5 and 

commercial buildings 

meeting BREEAM 

‘very good’ or 

‘excellent’ standards. 

Annual 



submitted. 

Encourage improvement in sustainable 

home building and promote development, 

which meets Code for Sustainable Homes 

Levels 3, 4, and 5 and commercial 

buildings meeting BREEAM ‘very good’ or 

‘excellent’ standards. 

Adaptation 

Properties at risk of 

flooding (LSF 

Indicator) 

Number of schemes 

with flood mitigation 

measures 

Number of additional 

homes where flood 

risk has been 

reduced (LSF 

Indicator) 

Annual 



submitted. 

At the planning application stage, a Flood 

Risk Assessment (FRA) will be required for 

development proposals of 1 hectare or 

greater in Flood Zone 1 and all proposals 

for new development located in Flood 

Zones 2 and 3. Assessment of surface 

water, drainage, and residual risk will be 

required as part of a FRA. 

New developments will be encouraged to 

use Sustainable Drainage Systems (SUDS) 

to manage runoff and reduce flood risk. 

Number of planning 

permissions granted 

in accordance with 

the advice of the 

Environment Agency 

on flood defence 

grounds (LSF 

Indicator) 



monitored 

Frequency of 


When should 


taken? 

What remedial action should be taken? 

New development 

with sustainable 

drainage installed 


Population that 

within water 

resource zones that 

are in deficit (LSF 

Indicator) 

Annual 



submitted. 

Promote the installation of water 

efficiency measures. Encourage 

improvement in sustainable home building 

and promote development, which meets 

Code for Sustainable Homes Levels 3, 4, 

and 5 and commercial buildings meeting 

BREEAM ‘very good’ or ‘excellent’ 

standards. 


Section 12. 

Introduction 

[ER07] Materials Efficiency and Waste 

12.1 The materials efficiency and waste receptor covers effects on the total volume of material 

moving through Runnymede’s economy, the generation of wastes, the recovery, reuse and 

recycling of material and the management of waste disposal. The receptor covers ‘Material 

Assets’ as required by the European Directive and UK Regulation on the environmental 

assessment of plans and programmes and incorporates a number of SA sustainable 



Table 75 – Applicable SA/SEA Objective/Factors to ER07 




SO01 



R 

SO11 To stimulate economic revival in deprived areas A 

SO14 

SO21 

SO23 






travel 



G 

A 

G 


FA10 Material Assets A 







goals 



[ER07] Materials Efficiency and Waste 

International Policy: , Convention on Climate Change and 

Biological Diversity: Earth Summit 

European Policy: European Sixth Environmental Action 

Programme 

National Policy: Environment Agency - Water Resources for 

the Future, PPS10 - Planning for Sustainable Waste 

Management, Waste Strategy for England, National Planning 

Policy Framework 


Surrey Policy: Surrey Design, The Surrey Waste Plan, Surrey 

Strategic Partnership Plan, Surrey Climate Change Strategy 

Objective: To reduce residual waste and increase 

recycling to improve environmental sustainability in 

Runnymede, and to increase energy efficiency and 

reduce unsustainable forms of transport. 

Comment: Reducing waste and increasing materials 

efficiency are key objectives for the SCS and 

emerging corporate vision. Measures include 

continuing to improve the energy efficiency of the 

Council’s housing stock and working to improve 

energy efficiency in private housing. Local energy 

generation (with related income opportunities) is a 

measure to be considered in the coming years. 



goals 



Local Policy: Runnymede Sustainable Community Strategy 

and Corporate Plan, Runnymede (Saved) Local Plan 2007 

European Law: European Waste Framework Directive 

International 

European Waste Framework Directive(2010) 

These objectives do not appear to be translated into 

the Local Plan. 

12.3 The aim of the Directive is to promote waste prevention, increase recycling and ensure better 

use of resources, while protecting human health and the environment. 

European Waste Incineration Directive(2010) 

12.4 The aim of the Directive is to prevent or limit negative effects on the environment, in 

particular pollution by emissions into air, soil, surface and groundwater and the resulting risks 

to human health from the incineration of waste. 

National 

PPS10 – Planning for Sustainable Waste Management(2005) 

12.5 This document discusses the sustainable management of waste. 

Waste Strategy for England (2007) 

12.6 The aim of this strategy is to reduce waste by making products with fewer natural resources. 

Waste Minimisation Act(1998) 

12.7 This act enables local authorities to make arrangements to minimise the generation of waste 

in their area and for related purposes. 

Regional 

Regional Sustainability Framework(2008) 


principles that will help guide sustainable development in the South East. 

Regional Planning Guidance Waste and Minerals 

12.9 This guidance is focused upon sustainable design and waste reduction 

County 

Surrey Design(2002) 

12.10 The purpose of this design guide is to promote high quality design of new development in 

Surrey 

The Surrey Waste Plan(2008) 

12.11 The aim of this strategy is to reduce waste 


Runnymede Sustainable Community Strategy and Corporate Plan (2012) 

12.12 This document aims to build on success and make Runnymede a more sustainable and 

thriving community in the future. 








12.14 With regard to waste management data in Runnymede, the 2011/12 National Indicator (NI) 

returns for NI 192 shows that 6479 tonnes of recycling was collected from household 

kerbsides, and a total of 47% of all waste was recycled, including kerbside recycling, green 

garden waste and food waste. 

12.15 Regionally inter regional movement of waste can also be looked at to provide a baseline. In 

the South East in 2007 2,173,311 tonnes were land filled from London to the South East. 68 







Receptor 

[ER07] Materials Efficiency 

and Waste 



Summary: A considerable amount of materials used in the construction and 

maintenance of the built environment are non-renewable. Equally, a 

considerable proportion of the waste sinks into which current waste is stored 

are finite. These two problems will become more acute as time progresses 

through the plan period. 

Evolution of Baseline Condition 

Issues and Challenges: Runnymede generates significant volumes of waste. The 

majority of waste is dealt with in-county, along with waste imported to the 

county from London and other parts of the South East. 

Possible LP Response: The LP could bring forward policies to reduce further the 

amount of waste that is generated and to increase the use of recycled or 

recovered materials in the maintenance or construction of urban developments 

and supporting infrastructure. 

How LP Responded: The LP does not have a policy for materials efficiency and 

waste. 

12.17 Domestic and commercial waste is generated in Runnymede. A reduction in the amount of 

waste that is generated from processes within the borough and the steps used to process this 

waste could, depending upon how this is implemented, result in adverse or positive effects. 


MEW1: Use of Resources 

12.18 Depending upon how material resources are used within the borough will indicate adverse or 

beneficial effects in relation to materials efficiency. 

MEW2: Generation of wastes 

12.19 The generation of waste within Runnymede have the potential to cause adverse or positive 

effects depending upon how they are managed. 



12.20 With regard to the SEA (Appendix 4) the policy options will all have an adverse impact. 

When consideration is given to the impact on the pathways the adverse effect is clear. It is an 

inevitable consequence of new development that the use of materials and the generation of 

waste will be negative. It is difficult to avoid this conclusion, but the Plan needs to ensure that 

future development is accommodated. Without the Plan development will take place so 

there will be no known acceptable alternatives. 

68 South East Partnership AMR 2007 





(RSF 19). 

12.22 The preferred approach overall does not have a significantly different impact to the 

alternatives. 


12.23 With regard to SEA (Appendix 4) all alternatives have at least an uncertain impact. However, 

it is noted that LP02‐A2 (c) and LP02‐A3 (a) have significantly adverse impacts. The impact on 

the pathways is particularly noticeable on the alternatives LP02‐A2(c) and LP03‐A3(a). This is 

a reflection of the impact of additional development and the requirement for resources. 

Irrespective of the selected policy option, the need for resources can not be avoided. 







growth. 


the alternatives. They are all neutral. 


12.26 Policy option LP03‐ A1 has a neutral impact whilst the uncertain impact of LP03 and LP03‐A2 

is noted in the SEA (Appendix 4). With regard to the pathways LP03 and LP03‐A2 have an 

uncertain effect, but the LP03‐A1 have a neutral effect. Pathways MEW1 and MEW2 ‐ the 

use of materials and generation of waste ‐ are affected as this is a consequence of new 

development. 







the alternatives. 


12.29 The uncertain impact of the two policy options is noted and will contribute to the final SEA 

assessment (Appendix 4). The uncertainty continues to the individual pathways. There is a 

need to accommodate new growth and this will have an impact on materials and waste. 




growth. 




12.32 This environmental receptor scores an overall SEA conclusion of an uncertain effect for LP05 

and LP05‐A2 and a neutral effect for LP05‐A1 (Appendix 4). These scores are reflected across 

the two impact pathways. This is to be expected because LP05‐A1 presumes against 

development whereas LP05 and LP05‐A2 both involve development, and therefore may 

involve the use of material resources (impact pathway MEW1) and generation of waste 


(MEW2). However, the impact is uncertain because details of any future development are not 

available at this stage, and this is true for both the preferred option and alternative LP05‐A2. 

LP05 requires the production and agreement of a master plan which will control the level of 

development on the site whereas LP05‐A2 will not afford such a degree of control and is 

therefore more likely to lead to an adverse effect on this receptor. 


alternatives both have a neutral effect (Appendix 3). With regard to RSF objectives, LP05 and 

LP05‐A2 have a beneficial effect on RSF 1 (to ensure that everyone has the opportunity to live 

in a decent, sustainably constructed and affordable home) and RSF11 (to stimulate economic 

revival in depressed areas of the borough) and for both objectives LP05‐A1 has an adverse 

effect. These objectives have a socio‐economic basis, and therefore the alternatives involving 

development of the site will have the scope to meet the objectives, whereas keeping the site 

in the Green Belt and presuming against development will not help achieve these objectives, 

and may even have a negative effect as suggested by the appraisal. Conversely, RSF 14 (to 

improve efficiency in land use through the appropriate re‐use of previously developed land) 

records an adverse effect for LP05, a significantly adverse effect for LP05‐A2 and a beneficial 

effect for LP05‐A1. This reflects the fact that the objective has an environmental basis and 

therefore retaining the site in the green belt with it’s presumption against development may 

be preferable. This highlights the issue that weighting of the objectives is needed when 

assessing policies against the objectives and aspirations of the local plan. 


12.34 With regard to SEA receptor ER07, the overall conclusion for LP06 is an uncertain effect on 

the receptor (Appendix 4). This is because it has been judged that it is not possible to know 

the scale s of material use and waste in the absence of firm information on the proposals for 

development. LP06‐A1 also provides an uncertain impact, for the same reason. 



12.36 The uncertain impacts of the two policy options are noted. The affect on the individual 

pathways is again universally uncertain (Appendix 4). However, overall the effect on the built 

environment will need to be considered at the design stage. 




growth. 

12.38 LP07 overall in the SA consideration does not have a different impact to LP07‐A1, apart from 

being more positive. 


12.39 All the policy options have adverse impact on the receptors. The policy options have an 

adverse effect on all the pathways. The pathway BE1 (use of materials) and BE2 (generation 

of waste) are a consequence of the quantum of development for all alternatives. There will 

be a need for the detailed submission for any scheme to indicate how the impact on the 

pathways can be mitigated. The use of materials will need to be sustainably sourced and the 

generation of waste will require bespoke measures to reduce the impact. 





are all neutral. The overall SEA conclusion (Appendix 3) is that LP08, LP08‐A1 and LP08‐A3 are 

uncertain and LP08‐A2 is neutral. Within the context of the SA LP08 has a significant adverse 

affect on RSF 9 (create employment), RSF 16 – significantly adverse (improve air pollution), 

but the other RSF are generally well accommodated. However, SP08‐A1 and SP08‐A2 have an 

adverse affect on RSF 14 (improve reuse of land/building)., RSF 19 (enhance biodiversity), and 


RSF 20 protect countryside), SP08‐A3 has an affect on RSF 17 (impact on climate change). 

There are therefore a diversity of impacts from the alternatives. In conclusion the LP08 is 

more favourable. Compared to the SEA conclusions the alternatives are generally uncertain, 

but the SP08‐A2 is neutral reflecting the spread of development across green field sites. 






12.44 The benign impact of the policy approaches is reflected in the affect on the pathways with 

regard to the SEA (Appendix 4). This reflects the use of material and general waste but is an 

impact that would arise with any level of development. 


SP02‐A2 have a positive impact. However, there is an uncertain affect form the SP02‐A1 on 

RSF 1 (providing decent homes), RSF 2 (improving health), RSF 3 (reducing poverty) , RSF 6 

(creating vibrant communities), and RSF 9 and 11 (stimulating the economy). SP02‐A1 is less 



receptors, but the impact of the SP02‐A1 is different is uncertain and so SP02 and SP02‐A2 

are clearly more acceptable. 

12.46 SP02 overall in the SA consideration does not have an overall different impact to the SP02‐A2. 



12.47 With regard to SEA (Appendix 4) receptor ER07, the overall conclusion for SP03 is a neutral 

effect on the receptor. This is because it has been judged that the matter of materials 

efficiency and waste is unlikely to be significantly affected by the implementation of the 

policy. SP03‐A1 also records a neutral effect on this receptor. However, SP03‐A1 is not 

proposing to provide any traveller provision is clearly not meeting need and the social needs 

must be addressed. 








beneficial effect on the receptor. The policy has a beneficial effect on MEW1 (use of material 

resources), as the policy seeks to conserve resources where required. 

12.52 Policy SP05 has a beneficial effect on MEW2 (generation of wastes) as the high quality design 

required for new development includes minimising energy consumption. 






which the policy has a neutral effect on are RSF14 (flood risk), although the policy requires 

flood resilient design measures in areas at risk from flooding. 



12.54 With regard to SEA receptor ER07 (Appendix 4), the overall conclusion for the SP06 is an 

adverse effect on the receptor. SP06 has an adverse effect on MEW1 (use of material 

resources). This is caused by an increase in activity related to transport, recreation, and 

leisure, and related infrastructure requirements, built out by material resources. The policy 

option SP06‐A1 also has an adverse effect, for a similar reason as they are similar in this 

regard. 

12.55 SP06 has an adverse effect on MEW2 (generation of wastes). This is inevitably caused by the 

increase in infrastructure and materials used associated with tourism, recreation and leisure 

activities, including through any appropriately located hotel accommodation that may come 

forward. LP06 does not provide detail of how wastes will be dealt with, and would not be 

appropriate to do so. SP06‐A1 also has an adverse effect on the impact pathway, for similar 

reasons. 




facilitate development. However, with regard to the SEA (Appendix 4) the impact on the 

receptors is neutral. 



12.59 It will be important to consider the neutral impact of both alternatives. The impact of the 

alternatives on the pathways is generally benign (Appendix 4). 


neutral/positive impact. However, there is an adverse affect form the SP08‐A1 on RSF 3 





of the alternatives is different in a negative way and so the SP08 is clearly more acceptable. 

12.61 The preferred approach overall in the SA consideration does not have an overall different 

impact to the alternative but it is more positive. 


12.62 With regard to SEA receptor ER07 (Appendix 4) , the overall conclusion for the policy is a 

neutral effect on the receptor. SP09 has a neutral effect on MEW1 (use of material 

resources), as the exact transport infrastructure requirements are not specified in the policy. 

12.63 SP09 has a neutral effect on MEW2 (generation of wastes) as the transport policy does not 

directly contribute to material waste. If waste is considered as emissions to the air, 

sustainable transport will have a more positive than negative effect. 



12.65 Policy SP10 has neutral impact with regard to the SEA (Appendix 4) 






LP01 Strategy for the Location of Development / 

Alternative LP01‐A1 / 


LP02 Housing Provision and Distribution / ? 


Alternative LP02‐A2 (a) 0 ? 


Alternative LP02‐A2 (c) / 


Alternative LP02‐A3 (b) / ? 

LP03 Development in Addlestone Urban Area / ? 



LP04 Development in Egham / Englefield Green Urban Area / ? 





LP06 Development in Chertsey Urban Area / ? 


LP07 Development in Virginia Water / ? 


LP08 The former DERA site, Longcross / 



Alternative LP08‐A3 


SP01 Green Belt Areas / 

SP02 Affordable Housing / 0 


Alternative SP02‐A2 / 0 



SP04 Provision and Retention of Infrastructure and Service 0 ? 

SP05 Design 



SP07 Thames Basin Heaths Special Protection Area ? 0 

SP08 Employment Development / 





Significant 

Beneficial 


Significant 

Adverse 

/ 0 ? 



12.67 Cumulative effects are possible, but not considered likely to be significant from this receptor 

at this time. 


12.68 Mitigation and enhancement is suggested through the June 2012 meetings (See: Appendix 2) 

through the policy set SP05 ‘Design’ which recommends the use of sustainable resources with 

regard to the type of resources used in development. 


12.69 Within the Level 2 policy set it is noted that potential negative effects might be noted for the 

built environment in relation to prevention of development other than residential. However 

this is not considered significant as other development is linked to residential within 

Runnymede. 



monitored 

Frequency of 


When should 


taken? 

What remedial 


taken? 

Total type of all waste 

rising and the method 

used for its management 


Annually 

When the target is 

exceeded 

Appropriate to 

exceedence 

Inter regional movement 

of waste (LSF Indicator) 

Annually 

When the target is 

exceeded 

Appropriate to 

exceedence 



Section 13. 

Introduction 


13.1 The built environment receptor covers the effects on the quality and character of the built 

environment in the maintenance and restoration of existing structures and the construction 

of new developments. This receptor captures the factor of ‘material assets’ as required by the 

SEA Directive and UK SEA Regulations and incorporates a number of SA sustainable 







SO01 



R 

SO11 To stimulate economic revival in deprived areas A 

SO14 

SO21 

SO23 






travel 



G 

A 

G 


FA10 Material Assets G 







goals 




UK Policy: ABI The Vulnerability of UK Property to 

Windstorm Damage, Circular 04/07 Planning for Travelling 

Showpeople, , PPS10 - Planning for Sustainable Waste 

Management, UK Sustainable Development Strategy, 

Gypsy and Traveller Circular 01/2006, White Paper: Our 

Towns and Cities – The Future , National Planning Policy 

Framework 

Regional Policy: South East Plan, South East Region Social 

Inclusion Statement, South East Regional Housing 

Strategy, Sustainable Communities for the South East, 

Sustainable Communities: Building for the future 

Surrey Policy: Surrey Community Strategy, Surrey 

Strategic Partnership Plan, Surrey Design 

Objective: Improve the public realm and regenerate 

town centres to deliver revitalised and a vibrant 

borough fit for the 21 st century 

Comment: The built environment is a key focus of the 

emerging corporate vision. Regeneration of town 

centres will provide an opportunity to build to the 

latest quality and efficiency standards. 



goals 



Runnymede Policy: Runnymede Borough Council (Saved) 

Local Plan 2007, Runnymede Economic Strategy, 

Runnymede Fuel Poverty Strategy, Runnymede 

Homelessness Strategy, Runnymede Housing Strategy, 

Runnymede Private Sector Housing Renewal Strategy, 

Runnymede Sustainable Community Strategy and 

Corporate Plan, Strategic Housing Land Availability 

Assessment, Strategic Housing Market Assessment 

International 

European Directive on the Energy Performance of Buildings 2002 

13.3 This directive requires member states to comply with several articles regarding inspections of 

boilers and air conditioning systems. 

National 


13.4 The planning policy framework acts as guidance for local planning authorities and decision 

makers, both in drawing up plans and making decisions about planning applications. 

White Paper – Our Towns and Cities, The Future (2000) 

13.5 This paper aims to offer a high quality of life and opportunity to those in towns, cities and 

suburbs. 

Regional 

Regional Sustainability Framework (2007) 



South East Plan(2009) 

13.7 The Regional Spatial Strategy (RSS) for the South East of England (known as the South East 

Plan) sets out the long term spatial planning framework for the region over the period 2006‐ 

2026. 

South East Regional Housing Strategy 

13.8 This document aims to ensure everyone in the region has access to a decent home at a 

suitable price. 

County 

Surrey Design Guide(2002) 

13.9 The purpose of this design guide is to promote high quality design of new development in 

Surrey. 


Runnymede Sustainable Community Strategy and Corporate Plan 



Runnymede Strategic Housing Land Availability Assessment 

13.11 This documents land availability for the delivery of new homes. 

Runnymede Strategic Housing Market Assessment 

13.12 This document addresses the housing market 


Runnymede Urban Area Character Appraisal 2009 

13.13 This document is intended to aid urban design policy formulation for the development and 

improvement of Runnymede Borough where the built environment primarily consists of 

housing development 







13.15 The built environment in Runnymede is dominated by a selection of small towns on the fringe 

of London. It largely comprises of residential and commercial development, plus supporting 

infrastructure, of which transportation is the most prominent. There are slightly more 

detached and semi‐detached properties in the borough than flats and terraced houses, with 

more detached properties located in the affluent areas of in Virginia Water, Ottershaw, 

Woodham, and Thorpe, and more semi‐detached in New Haw, Egham and Addlestone. In 

general, the condition of Runnymede’s housing stock is in good state of repair. 

13.16 There is a number of Industrial and Business Parks located throughout the borough. These 

are generally situated close to and with easy access to the M25. This is reflective of the 

general reliance of transportation by vehicle for both workers and goods. 

13.17 In terms of housing provision, latest available data for Runnymede shows that 201 housing 

completions occurred in 2011/12 to include 94 affordable housing units. Runnymede records 

a low number of non‐decent homes per 1000 dwellings. 

13.18 Runnymede also records high levels of development on previously developed land against a 

low amount of land that has been vacant or derelict for more than five years. Runnymede 

also records no built heritage assets of grade 1 and 2 at risk (see Section 15). 

13.19 However Runnymede has recorded increasing levels of commercial and residential properties 

at risk of flooding. 







Receptor 




Summary: In Runnymede 172 additional net dwellings built in 2010/11. In 

2009 133 affordable housing units were completed within Runnymede. 

In June 2011 there were 2,672 households on the housing register indicating 

a demand for housing within the borough. 

The combined number of commercial and residential properties in Runnymede 

at risk of flooding is 21,603. 

Issues and Challenges: Runnymede’s population has increased annually and 

the trend of population growth is expected to continue 70 . Car ownership is 

also higher than the national average, at 1.5 cars per household 71 , and its 

road network is extensively used for private and business travel, as well as 

moving significant volumes of freight. As with the rest of Surrey, the type of 

freight moved, the need to safeguard the rail network for passenger services, 

and the lack of interchange facilities, limits the scope for moving freight by 

70 ONS Midyear Population Estimates 



Receptor 



rail. Consequently the volume of traffic that makes use of the existing road 

network and that which passes through the borough, its towns, and villages is 

high. This volume of traffic can have adverse impacts on the condition of 

buildings and supporting infrastructure. The current condition of the built 

environment of a number of towns is considered to be of poor quality, 

therefore there is the opportunity to improve the condition of this receptor 

significantly. 

Possible LP Response: The Local Plan could bring forward policies that ensure 

the production of a set of coherent Area Action Plans to enhance the quality 

and offer of the towns as well as improve the integration of land use and 

infrastructure planning at both the strategic and the local levels. Policies could 

ensure that supporting infrastructure is brought forward to enable and 

enhance the towns in terms of access for communities and the quality of the 

public realm and townscape. 

How LP Responded: The Local Plan does not contain a specific policy set for 

the built environment, instead it relies upon a group of policies that focus 

upon developing urban areas such as LP04 – LP08 the comprehensive 

redevelopment of the former DERA site. 


13.21 It can be expected that the population in Runnymede, as within the South East, will continue 

to grow. This will increase demand for housing, employment space and supporting social and 

community infrastructure (e.g. schools, hospitals and health centres, retail provision etc). 


BE1 Quality of Design of new development 

13.22 Changes to the built environment could change an area from a design and aesthetics 

perspective. The scale and extent of any effects would depend on the location, nature and 

scale of any new development or maintenance works and the characteristics of the affected 

area. 

BE2 Impacts on built structures 

13.23 The built environment is subject to change over time and needs to be regularly maintained. 

Adverse impacts can affect the quality of the built environment such as available resources 

for maintenance 

BE3 Impacts on the ambience of settlements 

13.24 Pressure to develop within Runnymede could affect the characteristics of the built 

environment within existing settlements potentially in both negative and positive ways 

depending upon how development is situated. 



13.25 With regard to the SEA (Appendix 4) all policy options have a generally positive impact. 







growth. 




13.28 The impact of all alternatives on the BE are all positive (Appendix 4). 



neutral impact. The impact on air quality is uncertain/adverse (RSF 16) for all alternatives 






13.31 The positive impact with regard to all policy options in relation to the SEA (Appendix 4). 








13.34 The mixed beneficial impact is noted with regard to the SEA (Appendix 4). The impact on the 

pathways is positive, but the impact on the ambience of the built environment may be 

difficult to judge at this stage. 




growth. 

13.36 Overall LP04 in the SA consideration does not have a different impact to the alternative, apart 



13.37 The overall SEA conclusion for this receptor is a mixed score for LP05 and LP05‐A2 and a 

neutral score for LP05‐A1 (Appendix 4). 

13.38 LP05‐A1, to retain the site in the Green Belt, has a neutral score across all the impact 

pathways because they refer to the quality and impact of development and this policy option 

presumes against development. 

13.39 For impact pathway BE1, quality of design in new development, both LP05 and LP05‐A2 have 

a beneficial score. This is because both will involve development, and a high standard of 

design would be expected whatever the level of development, particularly in this sensitive 

location in the grounds of a Grade 1 listed building. Similarly, a beneficial score is achieved by 

LP05 and LP05‐A2 for BE2, impacts on built structures. With regard to the third impact 

pathway, BE3 impacts on the ambience of settlements, LP05 and LP058‐A2 both have an 

uncertain score. This is because any effect cannot be gauged without knowing the precise 

form of the development, to determine how it may affect those located within and outside 

the campus. LP05 is chosen because it requires the production and agreement of a master 

plan which will control the level of development on the site whereas LP05‐A2 will not afford 

such a degree of control. 

13.40 With regard to SA, overall (Appendix 3), LP05 has a mixed effect on SA objectives, and other 

policy options both have a neutral effect. With regard to the relevant RSF objectives, LP05 

and LP05‐A2 have a beneficial effect on RSF 1 (to ensure that everyone has the opportunity to 

live in a decent, sustainably constructed and affordable home) and RSF11 (to stimulate 

economic revival in depressed areas of the borough) and for both objectives LP05‐A1 has an 

adverse effect. These objectives have a socio‐economic basis, and therefore the alternatives 

involving development of the site will have the scope to meet the objectives, whereas 

keeping the site in the Green Belt and presuming against development will not help achieve 

these objectives, and may even have a negative effect as suggested by the appraisal. 

Conversely, RSF 14 (to improve efficiency in land use through the appropriate re‐use of 


previously developed land) records an adverse effect for LP05, a significantly adverse effect 

for LP05‐A2 and a beneficial effect for LP05‐A1. This reflects the fact that the objective has an 

environmental basis and therefore retaining the site in the green belt with it’s presumption 

against development may be preferable. This highlights the issue that weighting of the 

objectives is needed when assessing policies against the objectives and aspirations of the 

local plan. 


13.41 With regard to SEA receptor ER08 (Appendix 4), the overall conclusion for the preferred 

policy is a positive effect on the receptor. This is because it has been judged that, overall, new 

development will be capable of being used to maintain and enhance the physical 

environment. 



13.43 The mixed positive impact of both policy options are noted with regard to the SEA (Appendix 

4) . The impact of the policy options on the pathways is generally benign. It is noted that the 

affect on pathway BE3 – the ambience of settlements will need to be considered at the 

design stage. 


mixed impact. The need to accommodate growth will have a consequence for all the 


growth. 




13.46 Policy option LP08 has a beneficial impact, whilst LP08‐A1 and LP085‐A2 are neutral, with 

LP08‐A3 mixed beneficial (Appendix 4). The policy options have a benign affect on the 

pathways, apart from LP08‐A1 that has a significantly adverse affect on BE3 (impact on the 

ambience of settlements). This is a consequence of a wholly green field scheme adjacent to 

existing urban areas. 





are all neutral. The overall SEA conclusion is that LP08, LP08‐A1 and LP08‐A3 are uncertain 

and LP08‐A2 is neutral. Within the context of the SA LP08 has a significant adverse affect on 

RSF 9 (create employment), RSF 16 – significantly adverse (improve air pollution), but the 

other RSF are generally well accommodated (Appendix 3). However, LP08‐A1 and LP08‐A2 

have an adverse affect on RSF 14 (improve reuse of land/building)., RSF 19 (enhance 









13.50 No SA/SEA Discussion. 


13.51 Policy options SP02 and SP02‐A2 have a mixed impact, whilst SP02‐A1 has a neutral impact. 

The policy options have a benign or positive affect on the pathways (Appendix 4). 



SP02‐A2 have a positive impact. However, there is an uncertain affect form the alternative 




affect on RSF 16(reducing air pollution). The need to accommodate affordable housing will 



13.53 SP02 overall in the SA consideration does not have an overall different impact to the SP02‐A2. 



13.54 With regard to SEA receptor ER08, the overall conclusion for SP03 is a neutral effect on the 

receptor (Appendix 8). This is because it has been judged that the built environment is 

unlikely to be materially affected by the scale of development envisaged for the settlement 

area. SP03‐A1 is also recorded as neutral. However, policy option SP03‐A1 of not providing 

any traveller provision is clearly not meeting need and the social needs must be addressed. 




have a beneficial effect on the environmental receptors. 




beneficial effect on the receptor. The policy has a beneficial effect on impact pathway BE1 

(quality of design in new development). This is because it is accepted that good quality design 

is part of good planning, and good quality design would be expected in any design proposals 

as part of new development that comes forward. 

13.59 Policy SP05 has a beneficial effect on BE2 (impacts on built structures). New development will 

need to be of a high quality, and the potential to improve existing infrastructure and public 

realm will have a beneficial effect. 

13.60 SP05 also has a beneficial effect on impact pathway BE3 (impacts on the ambience of 

settlements), as the policy requires new development to achieve a positive relationship with 

adjoining properties, maximise opportunities for linkages to surrounding areas and services, 

as well as making a positive contribution to the character of the area where development 

takes place, thereby having a beneficial effect on the impact pathway. 






which the policy has a neutral effect on include RSF14 (flood risk), although the policy 

requires flood resilient design measures in areas at risk from flooding. 


13.62 With regard to SEA receptor ER08, the overall conclusion for SP06 is a beneficial effect on the 

receptor (Appendix 4). SP06 has a beneficial effect on impact pathway BE1 (quality of design 

in new development). SP06‐A1 also has a beneficial effect. This is because it is accepted that 

good quality design is part of good planning, and good quality design would be expected in 

any design proposals related to tourism, recreation and leisure. 

13.63 SP06 has a beneficial effect on BE2 (impacts on structures). SP06‐A1 also has a beneficial 

effect on the impact pathway, as new built infrastructure will need to be of a high standard 


and the potential to improve existing infrastructure and public realm will have a beneficial 

effect. SP06‐A1 also looks to the improvement of the quality of existing visitor attractions, 

and therefore the impacts on built structures may also be improved in this way. 

13.64 SP06 has an uncertain effect on impact pathway BE3 (impacts on the ambience of 

settlements), as the effect would be dependent on the location of tourism, recreation and 

leisure facilities and the level of related development, in particular around the River Thames. 

SP06‐A1 has a positive effect on impact pathway BE3, but it also depends on the location and 

proposal of development. However, SP06‐A1 has a beneficial effect on the impact pathway as 

it supports the improvement of the quality of existing visitor attractions. Although SP06‐A1 

has a more beneficial effect on impact pathway BE3, overall SP06 is more beneficial to the 

environment. 



13.66 No reasonable alternative to the policy SP07 were considered, as it provides a tested 

mechanism to facilitate development. With regard to the SEA (Appendix 4) the overall 

impact on the receptors is mixed . 



13.68 The neutral impact of the policy options with regard to the SEA (Appendix 4) is noted. 









alternative but it is more positive. 


13.71 With regard to SEA receptor ER08 (Appendix 4), the overall conclusion for SP09 is a neutral 

effect on the receptor. SP09 has a neutral effect on impact pathway BE1 (quality of design in 

new development), as the policy doesn’t specify the location or design of sustainable 

transport infrastructure within developments, and is more focused on the provision of new 

public transport, around the Borough more generally. However, the design policy does 

discuss the provision of transport –related infrastructure in new development. 

13.72 SP09 has a neutral effect on BE2 (impacts on built structures). This is due to new transport 

infrastructure and maintenance of existing transport infrastructure not being a built 

structure, such as buildings, and the policy considers the way of transporting people between 

different buildings, and so a neutral effect is recorded. 

13.73 SP09 has a neutral effect on impact pathway BE3 (impacts on the ambience of settlements), 

as the policy relies on improvements to the existing provision of public transport, provision of 

new public transport, and schemes/travel plans, rather than new buildings, and so it is 

considered the policy would have a relative neutral impact on the ambience of settlements. 



13.75 Policy SP10 has neutral impact with regard to the SEA (Appendix 4). 






LP01 Strategy for the Location of Development / 



LP02 Housing Provision and Distribution / / 


Alternative LP02‐A2 (a) 0 0 

Alternative LP02‐A2 (b) 0 / 

Alternative LP02‐A2 (c) / / 

Alternative LP02‐A3 (a) 0 / 

Alternative LP02‐A3 (b) / 

LP03 Development in Addlestone Urban Area / 



LP04 Development in Egham / Englefield Green Urban Area / / 


LP05 Royal Holloway UOL 0 / 



LP06 Development in Chertsey Urban Area / 


LP07 Development in Virginia Water / / 





Alternative LP08‐A3 / / / 


SP01 Green Belt Areas / / 

SP02 Affordable Housing / / 


Alternative SP02‐A2 / / 



SP04 Provision and Retention of Infrastructure and Service 0 

SP05 Design 



SP07 Thames Basin Heaths Special Protection Area ? / 

SP08 Employment Development / 0 



SP10 Development and Flood Risk 0 / 


Significant 

Beneficial 


Significant 

Adverse 

/ 0 ? 



13.77 Cumulative effects not considered likely from this receptor. 


13.78 A number of mitigation and enhancement to the then emerging Core Strategy were 

suggested to the policy team as a result of the Level 2 considerations in October 2009 and 

July 2012 (See: Appendix 2). These have either been integrated and accounted for in this 

version of the Local Plan or noted by the Policy Team. 

13.79 Within the Level 3 Appraisals and Level 4 Assessments it was noted that development might 

be restrained through locations principles. It is argued that this may be a minor factor as the 

policy sets encourages a variety of development. 

13.80 Within this SAR it is suggested that potential negative effects might be noted for the built 

environment in relation to prevention of development other than residential. However this is 

not considered significant as other development is encouraged within Runnymede. 



monitored 

Frequency 

of data 

collection 

When should 


taken? 

What remedial 


taken? 

Net additional dwellings for 

the current year (LSF Indicator) 

Affordable housing 

completions (LSF Indicators) 

Number of non decent homes 

per 1,000 dwellings (LSF 

Indicators) 

Development on previously 

developed land (LSF Indicator) 

Previously developed land that 

have been vacant or derelict 

for more than five years (LSF 

Indicator) 

Properties at risk of flooding 


Designated heritage assets (LSF 

Indicators) 

Annual 

Annual 

Annual 

Annual 

Annual 

Annual 

Annual 


identified 


identified 

When positive trend is 

identified 


identified 


identified 


identified 


identified 

Commence Policy 

review. 


review. 


review. 


review. 


review. 


review. 


review. 


Section 14. 

Introduction 

[ER09] Historic Environment and Archaeology 

14.1 The historic environment can be defined as archaeological assets (both known and unknown) 

alongside sites, structures, and features of historic significance and value. This receptor 

captures the factor of ‘cultural heritage including architectural and archaeological heritage’ as 

required by the SEA Directive and UK SEA Regulations and incorporates a number of SA 

sustainable development objectives as outlined in Table 85. 

14.2 The historic environment and archaeology receptor is at risk from land take, disturbance, and 

adverse air quality. 






SO08 

To encourage increased engagement in cultural activity across all sections of the 

community in Runnymede and promote sustainable tourism 

G 

SO20 To protect and enhance the borough’s countryside and historic environment G 


FA11 Cultural Heritage including Architectural and Archaeological Heritage G 







goals 


objectives and 

comment 

[ER09] Historic Environment and Archaeology 

International Policy: Valetta Convention (Archaeological) 

UK Policy: Biodiversity Strategy for England, Good Practice 

Guide on Planning for Tourism, UK Climate Change 

Programme, White Paper: Planning for a Sustainable Future, 

The Historic Environment: A Force for our Future, Thames 

Waterway Plan and Sustainable Communities: Building for the 

Future 

Regional Policy: South East Plan, South East Regional Minerals 

Strategy, Regional Minerals Strategy for Waste and Minerals 

Surrey Policy: The Surrey Waste Plan, Surrey Urban Habitat 

Action Plan, Surrey’s Countryside The Future Action Plan Rural 

Strategy, Surrey Woodland Habitat Action Plan, Surrey 

Biodiversity Action Plan, Surrey Wetland Habitat Action Plan, 

Surrey Climate Change Strategy, Surrey Local Transport Plan, 

Surrey Heritage Strategy. 

Runnymede Policy: Runnymede Sustainable Community 

Strategy and Corporate Plan 

European Law: European Directive EIA, European Directive 

SEA, European Water Framework Directive 

Objective: ‘Once it is gone – it is gone for good’ 

protecting historic environments are key policy 

objectives across a number of geo-political 

regimes. The Council’s SCS objective to ‘Put 

Runnymede on the Map’ potentially captures the 

historic sealing of the Magna Carta event in 

Runnymede. These objectives are captured in 

the Local Plan Objective 10. 

Comment: There are a number of 

archaeologically and historically valuable assets 

in Runnymede, none of which are intended to be 

impacted by the Local Plan. There is potential to 

facilitate the founding of a Magna Carta Visitor’s 

Centre, but this is not a Local Plan Policy. 

Development in Chertsey (LP06) along with 

impacts of other policy objectives such as 

minerals extraction coupled with the effects of 

climate change all with the potential to affect 

efforts to protect this resource. 


International 

Valetta Convention (Archaeological)(1992) 

14.4 The convention looks toward the protection, preservation and scientific research of 

archaeological heritage in Europe 

National 


14.5 The planning policy framework acts as guidance for local planning authorities and decision 

makers, both in drawing up plans and making decisions about planning applications. 

Planning (Listed Buildings & Conservation Areas) Act 1990 

14.6 This act consolidates certain enactments relating to special controls in respect of buildings 

and areas of special architectural or historic interest. 

The Historic Environment: A Force for our Future (2000) 

14.7 This strategy looks toward the promotion and protection of the historic environment 

Regional 

Regional Sustainability Framework(2007) 



South East Plan(2009) 

14.9 The Regional Spatial Strategy (RSS) for the South East of England (known as the South East 

Plan) sets out the long term spatial planning framework for the region over the 2006‐2026. 

County 

Surrey Heritage Strategy(2001) 

14.10 This strategy is based on the need for a coordinated approach to efforts to protect, manage 

and promote interest in Surrey’s heritage. 


Runnymede Community Strategy and Corporate Plan(2012) 



RBC Urban Area Character Appraisal 2009 

14.12 This document is intended to aid urban design policy formulation for the development and 

improvement of Runnymede Borough where the built environment primarily consists of 

housing development. 










informatio9 as well as through discussion with various officers within the Council and external 

statutory and non‐statutory consultees. 



Receptor 

[ER09] Historic Environment 

and Archaeology 



Summary: Runnymede contains 307 statutory listed buildings, including 4 

grade I properties: Runnymede Park,Tite Hill; Founders Building, Royal 

Holloway College, Egham Hill;Great Fosters, Stroude Road and Holloway 

Sanatorium, Strode Road. A further 19 properties merit Grade II listing. 

It also contains a number of areas of archaeological interest, 7 areas of 

conservation 

Issues and Challenges: Runnymede has a diverse historic heritage, in terms of 

buildings, archaeology and some landscapes. There is scope for urban 

regeneration to adversely affect the historic environment, through the effects of 

construction and use through vibration on structural integrity and the impacts 

that the deposition of chemicals can have on the fabric of buildings. The historic 

landscape can be affected by the construction of new supporting infrastructure 

or more likely by changes to the volume of existing provision. 

Possible LP Response: The Local Plan could bring forward policies to minimise 

the risks to the historic environment by proactively planning for its 

development. Risks to it that might arise from climate change and the 

construction and use of new development and supporting infrastructure on the 

historic environment and archaeology can be assessed and mitigation factored 

into proposals in advance. 

How LP Responded: Whilst the Local Plan references the protection of the 

historic character such as in the Egham and Englefield Green Area (LP04) and 

Chertsey (LP06) there is no specific policy to protect the wider historic 

environment. 

Archaeology 

14.15 Runnymede contains 57 areas of high archaeological potential found throughout the 

borough. A Bronze Age settlement, west of the Runnymede Bridge is regarded to be at risk 

from scrub and tree growth, reported by English Heritage in 2011 as being in a declining 

condition. 

14.16 Archaeological sites are likely to experience risk due to increased development as a result of 

land take, disturbance and loss. 

The Built Heritage 

14.17 Runnymede contains 307 statutory listed buildings including four grade I properties: 

Runnymede Park, Tite Hill; Founders Building, Royal Holloway College, Egham Hill; Great 

Fosters, Stroude Road and Holloway Sanatorium, Stroude Road. A further 19 properties merit 

grade II* listing. In addition to those buildings listed by English Heritage there are also a 

number of locally listed structures. 

14.18 Runnymede has seven designated conservation areas within the borough. These are: 

Basingstoke Canal; Chertsey; Egham Hythe; Egham Town Centre; Englefield Green; Thorpe 

and Wey Navigation. These streets, buildings and locations are of special architectural 

interest or historic interest, and they receive additional protection from the Council. 

14.19 Data from English Heritage shows that currently (February 2012) there are no buildings of 

Grade I and Grade II* listed at risk within Runnymede. 

14.20 Built heritage is also likely to experience an increase in risk as a result of increased 

development, decreased air quality and risk of land take that will contribute to an adverse 

effect. The effects of climate change can compound these effects. 

The Historic Environment 

14.21 The borough has a considerable number of important historic parks and gardens, having 

more Grade I and II* than any other Surrey District. Historic Parks and Gardens are 

particularly vulnerable to insensitive development that affects views from within their 


oundaries. The largest area of historic parks and gardens is represented by Windsor Great 

Park partially located within an area to the northwest of the borough. 

14.22 Data from the English Heritage’s at Risk Register in 2012 shows that Woburn Farm in 

Addlestone, a Grade II listed Historic Park and Garden is at risk and in declining condition. 

14.23 Historic parks and gardens are vulnerable to similar pressures as listed structures. 


14.24 Runnymede has a diverse heritage in terms of buildings, archaeology and landscapes. 

Situated in the densely populated South East, the trend in population growth for Runnymede 

can be expected to continue to increase (as exemplified by the latest Census data (2011)) 

which in turn will result in increased demands for housing, employment space, and 

supporting infrastructure (e.g. transportation, schools, hospitals and health centres, retail 

provision etc). The demand for development will place the borough’s historic heritage assets 

at increased risk of disturbance, damage and irretrievable loss. 

14.25 In addition, likely effects will be amplified as a result of changes in the UK’s climate, which 

may be severe. Those changes include long periods of hot dry weather during the summer 

months and increased precipitation during winter periods. Coupled with extreme weather 

events and storminess all having cumulative and synergistic affects on both archaeological 

and built heritage assets (see Section 12). 


14.26 Historic Environment and Archaeology could be affected by several adverse potential 

pathways 

HE1 Impacts on heritage assets due to land take 

14.27 Depending upon where development is located and the type of development being 

proposed, adverse effects resulting from loss or damage to heritage and archaeological assets 

can occur. 

E2 Impacts on heritage assets due to inappropriate development in its proximity 

14.28 Similarly to HE1 the location of development coupled with its type can result in adverse 

effects due to siting. 

HE3 Impacts on heritage assets due to decreased air quality and related climate change 

14.29 The historic built environment can be adversely affected by the deposition of atmospheric 

pollution caused by carbon base energy use in transport and domestic consumption. The 

quality of Runnymede’s air is largely a product of its location and the fact that is has both the 

M25 and M3 motorways running through it (see: Section 11). 

14.30 Changes in the weather from increased periods of dry weather as well as other climatic 

factors such as flooding have the potential to adversely affect heritage assets (see: Section 

12). 

HE4 Impacts on heritage assets due to disturbance 

14.31 Meeting the development pressure will lead to increased numbers of residents, employees, 

and visitors to heritage assets. 

Consideration of Policies and its Alternatives 


14.32 The policy options have an uncertain or neutral impact with regard to the SEA (Appendix 4). 

With regard to the pathways it is noted that LP01 has an adverse impact on HEA4 heritage 

disturbance. This recognises that some aspects of our heritage assets may be disturbed. This 

signals that consideration will need to be given to detailed submissions to ensure that such 

assets are given due consideration. 





(RSF 19). 



14.35 There are a variety of impacts for the policy options with regard to the SEA (Appendix 4) The 

impact on the historic environment pathways is particularly noted on HEA1‐4 for LP02‐A2(c) 

illustrating the impact of the largest quantum of development. It is difficult to avoid an 

impact on the pathways of new development. This will reflect the need to balance future 

community need with the impact on the historic environment. 







growth. 

14.37 LP02 overall in the SA consideration does not have a different impact to the alternatives, all 

record a neutral effect. 


14.38 The neutral impact is noted across the policy options with regard to the SEA (Appendix 4). 








14.41 The uncertain impact of the policy options with regard to the SEA (Appendix 4) is noted. 

However, the affect on the pathways is generally uncertain, but is a reflection of the impact 

of new built development on the built environment. This is a matter that should be addressed 

at the design stage of new schemes. 

14.42 Having regard to the conclusion of SA in Appendix 3, overall, all policy approaches have a 



growth. 




14.44 With regard to the Historic Environment and Archaeology receptor, the overall SEA 

conclusion for the preferred policy is of an adverse effect for all of the pathways (Appendix 

4). LP05 scored adversely for HEA1, impact on the asset due to land take, because by 

removing the site from the Green Belt, more development will take place on the site which 

could have an impact on the setting and integrity of the Listed Building. LP05‐A2 has an 

uncertain score because while the preferred option requires a master plan, this alternative 

would suggest individual planning applications rather than a comprehensive scheme for the 

site, so although land take would be inevitable to some degree; its level cannot be quantified. 

LP05‐A1 will limit the amount of development on the site, with the knock‐on result of 

minimising the effect on the listed building and the historic setting. This alternative therefore 

scores a neutral effect. LP05 is therefore not the best one for minimising the effect of this 

impact pathway. However, in mitigation, any new development on the site will be assessed 


against a legislative background that will protect the effect of any new development on the 

listed building and more importantly in terms of land take, its setting. LP05 also requires the 

production and agreement of a master plan which will help to ensure that effects are 

minimised. 

14.45 Impact pathway HEA2, impact on the asset due to inappropriate development in its 

proximity, again provides an adverse score for LP05 and also for LP05‐A2. This will be for the 

same reasons as above – i.e. allowing more development on the site could have a detrimental 

effect on the Grade I listed building and its setting. LP05‐A1 would again preserve the status 

quo and so could be considered the best option. However, the mitigating circumstance for 

LP05 is again the fact that a master plan will be produced, and legislation would serve to 

protect the building. 

14.46 With regard to impact pathway 3, impacts on heritage due to decreased air quality and 

related climate change, both LP05 and LP05‐A2 record adverse effects, whereas LP05‐A1 

would have a neutral effect, which is to be expected because this alternative does not 

facilitate development of the site. Air quality would be affected by LP05 and LP05‐A2 both 

because there would be building activity on the site possibly for a prolonged period, and the 

resulting buildings would lead to more emissions from the processes carried out in the 

building compounded by the increase in the number of people on the site. However, the 

requirement for a master plan will enable us to mitigate against this through the use of 

sustainable building techniques and methods of construction. It would be more difficult to 

mitigate against this effect with LP05‐A2 as the local authority would have less control over 

the phasing of development and therefore any cumulative effects. 

14.47 Impact pathway 4 of this receptor refers to impacts on heritage assets due to disturbance. 

Again LP05 and LP05‐A2 score an adverse effect, while LP05‐A1 scores a neutral effect, 

because it presumes against development. The adverse effect reflects the fact that 

development will cause disturbance. Legislation protecting the heritage asset would again 

mitigate against the effects of development allowed by LP05 and LP05‐A2, but the 

requirement for a master plan in LP05 provides opportunities to further mitigate against 

potential effects whilst LP05‐A2 does not afford this opportunity. 

14.48 With regard to SA, overall, the policy LP05 has a mixed effect on SA objectives, and the other 

policy options both have a neutral effect (Appendix 3). With regard to the relevant RSF 

objectives, for RSF 8 (to encourage increased engagement in cultural activity…and support 

sustainable tourism), LP05 and LP05‐A2 show a beneficial effect and LP05‐A1 a neutral effect, 

indicating that some development of the site would help achieve this objective, whilst 

preserving the site in the Green Belt would have no effect. Conversely RSF20 (to protect and 

enhance the region’s countryside and historic environment) scores an adverse effect for LP05 

and LP05‐A2 and again a neutral effect for LP05‐A1. This suggests that development would be 

detrimental to the historic fabric of the site but the production of a master plan for LP05 and 

legislation protecting the heritage asset would mitigate against potential effects. 


14.49 With regard to SEA receptor ER09 (Appendix 4), the overall conclusion for LP06 is an 

uncertain effect on the receptor. This is because it has been judged that it is not possible to 

know the scale s of any of the four Impact Pathways in the absence of firm information on the 

proposals for development. LP06‐A1 also provides an uncertain impact, for the same reason. 



14.51 The neutral impact of the policy options is noted with regard to the SEA (Appendix 4). This 

continues through to the individual pathways where the affect is neutral. The impact on the 

historic heritage will need to be considered at the design stage. 




growth. 





14.54 Alternative LP08 and LP08‐A3 have a significantly adverse impact on the receptors with 

regard to the SEA (Appendix 4). LP08‐A1 has an uncertain impact, whilst LP08‐A2 has a mixed 

beneficial. The impact on the pathways of the policy options are mixed, but LP08 and LP08‐ 

A3 are adverse. The historic environment and archaeology are potentially more likely to be 

adverse on are with built settlements or known areas of former settlement. This is noted but 

is not an unusual matter to deal with as part of development proposals. This should not be an 

issue that should preclude development. The affect of alternative LP08 is to have an adverse 

impact on HEA 1 (loss of heritage assets), HEA 2 (impact on heritage assets due to proximity 

of development), HEA 3 (Impact on heritage due to decrease on CG) and HEA 4 impact due to 

disturbance). This is not an issue for LP08‐A2 where a choice of green field sites is yet to be 

made. 

14.55 Whilst the impact on the receptors clearly favours LP08‐A2, but this does not take into 

account the mitigation that will need to be introduced. 

14.56 The overall conclusion of the SA is that LP08 is mixed positive but the other alternatives are 

all neutral. The overall SEA conclusion is that LP08, LP08‐A1 and LP08‐A3 are uncertain and 

LP08‐A2 is neutral. Within the context of the SA LP08 has a significant adverse affect on RSF 9 

(create employment), RSF 16 – significantly adverse (improve air pollution), but the other RSF 

are generally well accommodated. However, the LP08‐A1 and LP08‐A2 have an adverse affect 

on RSF 14 (improve reuse of land/building)., RSF 19 (enhance biodiversity), and RSF 20 

protect countryside), LP08‐A3 has an affect on RSF 17 (impact on climate change). There are 

therefore a diversity of impacts from the alternatives. In conclusion LP08 is more favourable. 

Compared to the SEA conclusions the alternatives are generally uncertain, but the LP08‐A2 is 

neutral reflecting the spread of development across green field sites. 


14.57 Policy SP01 does not have any alternatives. The whole strategy of the Plan depends upon 


demand. 



14.59 The policy options have a neutral impact on the receptors and this is reflected in the affect on 

the pathways with regard to the SEA (Appendix 4). 







receptors, but the impact of SP02‐A1 is different is uncertain and so the SP02 and SP02‐A2 





14.62 With regard to SEA receptor ER09 (Appendix 4), the overall conclusion for the policy option 

SP03 is an unknown effect on the receptor. This is because it has been judged that Impact 

Pathways HEA1 land take , HEA2 inappropriate development in proximity and HEA4 

disturbance to heritage assets cannot be known at this time in the absence of firm proposals. 

Policy option SP03‐A1 records a neutral impact, as no pathway will be affected on account of 

there being no development involved. However, in SP03‐A1 not providing any traveller 



on ER09. 








neutral effect. The policy has a neutral effect on impact pathway HEA1 (impacts on heritage 

assets due to land take). The Planning (listed buildings and conservation areas) as the design 

policy is focused on the quality of development, rather than its location, and so effects on the 

impact pathway due to land take are not considered relevant to this policy. 

14.67 SP05 has a neutral effect on impact pathway HEA2 (impacts on heritage assets due to 

inappropriate development). National regulations would prevent inappropriate development 

occurring near heritage assets. SP05 also supports this by permitting proposals that respect 

the historic environment, including preserving or enhancing the special interest of national 

heritage assets and their settings. 


decreased air quality and related climate change) because minimising energy consumption 

may prevent decreases in air quality, but the policy does not go as far as to say reducing 

energy consumption will have a positive effect on the impacts of climate change, and 

therefore the effect on this impact pathway is considered to be neutral. 

14.69 Policy SP05 has a neutral effect on impact pathway HEA4 (impacts on heritage assets due to 

disturbance), as the policy is focused on the quality of development, rather than the impacts 

of development (including through disturbance). This would apply to impacts on heritage due 

to disturbance, and therefore the policy is considered largely irrelevant to this impact 

pathway, and a neutral effect is recorded. 



14.71 Having regard to SEA receptor ER09, the overall conclusion for SP06 is a neutral effect. The 

policy has a beneficial effect on impact pathway HEA1 (impacts on heritage assets due to land 

take). The Planning (listed buildings and conservation areas) Regulations 1990 regulate 

development in relation to listed buildings and conservations areas, which are heritage 

assets. Any application for listed building consent or conservation area consent will be 

assessed for its impacts on character and setting. Policy SP06 encourages projects that 

broaden the appreciation of heritage assets, and therefore reduces impacts of heritage assets 

due to land take. Policy SP06 also has a beneficial effect and promotes new tourism on 

previously developed land, so any impacts due to land take would be minimal. 

14.72 SP06 has a beneficial effect on impact pathway HEA2 (impacts on heritage assets due to 

inappropriate development). This is again because national regulations prevent this occurring 

and the policy encourages the appreciation of heritage assets. SP06‐A1 also has a beneficial 

effect, as the policy promotes the improvement of the quality of existing visitor attractions 

including heritage visitor attractions. 

14.73 SP06 has an adverse effect on HEA3 (impacts on heritage assets due to decreased air quality 

and related climate change) because the increase in visitor numbers arriving by car will add 

particulates to the air that will impact on the quality of listed buildings through rain 

deposition or extreme’s in weather associated with climate change. SP06‐A1 also has an 

adverse effect on HEA3, although it encourages new tourism to be accessible by public 

transport, existing facilities are not necessarily and vehicles would therefore contribute to 

decreases in air quality, impacting adversely on heritage assets. 


14.74 SP06 has an adverse effect on impact pathway HEA4 (impacts on heritage assets due to 

disturbance), as the boost in tourist numbers visiting heritage assets (including the River 

Thames and other water bodies) if not managed properly could adversely impact on these 

assets due to disturbance. SP06‐A1 also has an adverse effect on the impact pathway for the 

same reason as the preferred policy. 



14.76 There are considered to be no reasonable alternative to the policy, as it provides a tested 

mechanism to facilitate development. However, the impact on the receptor is neutral with 

regard to the SEA (Appendix 4) 



14.78 With regard to the SEA (Appendix 4) both policy SP08 and SP08‐A1 have an uncertain impact. 











14.81 With regard to SEA receptor ER09, the overall conclusion for the policy is an adverse effect 

(Appendix 4). The policy has an adverse effect on impact pathway HEA1 (impacts on heritage 

assets due to land take), as the provision of new roads may negatively impact on existing 

heritage assets. 

14.82 SP09 has an adverse effect on impact pathway HEA2 (impacts on heritage assets due to 

inappropriate development), as the routes of new roads/existing roads could be near to 

heritage assets, and would therefore cause disturbance. 

14.83 Policy SP09 has an adverse effect on impact pathway HEA3 (impacts on heritage assets due to 

decreased air quality and related climate change), because the amount and location of new 

infrastructure provision is not stated in this policy, and although SP09 requires more use of 

sustainable modes of transport, the existing amount of particulates in the air has already 

caused damage to heritage assets, such as listed buildings. However, new infrastructure may 

minimise energy consumption and prevent increases in poor air quality, and the policy makes 

provision for new development (where it is appropriate to do so) be located near to 

sustainable forms of transport. 


disturbance), as the roads that already exist in locations near to heritage assets and will be 

used regardless of the amount of public transport put in place. 

14.85 Overall policy SP09 has a mixed effect on SA objectives (Appendix 3). With regard to RSF 

objectives, the policy has a neutral, beneficial or significantly beneficial effect in SA terms, 

with the exception of RSF8 (to encourage increase engagement in cultural activity across all 

sections of the community in Runnymede, and promote sustainable tourism), where the 

policy has an uncertain effect on the objective. This effect is seen because promoting 

sustainable tourism is difficult when the tourism policy does not require recreation and 

leisure facilities to be accessible by public transport. In addition, the transport policy although 

has sustainable principles, makes no specific requirement for tourism facilities to be 

accessible by public transport, therefore its effects would be unknown. 



14.86 Flood Risk – no alternative. 

14.87 Policy SP10 has an adverse impact (Appendix 4). 

14.88 No SA/SEA discussion. 




LP01 Strategy for the Location of Development ? 



LP02 Housing Provision and Distribution ? 



Alternative LP02‐A2 (b) ? ? 

Alternative LP02‐A2 (c) ? 


Alternative LP02‐A3 (b) ? ? 

LP03 Development in Addlestone Urban Area 0 


Alternative LP03‐A2 0 

LP04 Development in Egham / Englefield Green Urban Area / ? 


LP05 Royal Holloway UOL 0 



LP06 Development in Chertsey Urban Area ? 





Alternative LP08‐A1 ? ? 

Alternative LP08‐A2 ? / 



SP01 Green Belt Areas 0 0 




SP03 Gypsy and Travelling Populations ? ? 


SP04 Provision and Retention of Infrastructure and Service / ? 

SP05 Design / 0 

SP06 Tourism, Recreation and Leisure 0 


Significant 

Beneficial 


Significant 

Adverse 

/ 0 ? 




Alternative SP06‐A1 0 

SP07 Thames Basin Heaths Special Protection Area / 0 

SP08 Employment Development 0 ? 


SP09 Sustainable Transport 0 

SP10 Development and Flood Risk / 




14.90 A number of mitigation and enhancement to the previous emerging Core Strategy were 

suggested to the policy team as a result of the Level 2 considerations in October 2009 and 

July 2012 (See: Appendix 2). These have either been integrated and accounted for in this 

version of the Local Plan or noted by the Policy Team. 

14.91 Within the Level 3 appraisals and Level 4 Assessments it was noted that development would 

support the conservation of historic assets. Within this SAR it is suggested that potential 

negative effects might be noted for the heritage assets as they are continually being exposed 

to the effects of poor air quality and climate change. However this is not considered 

significant as other development is encouraged within Runnymede. 

14.92 Mitigation and enhancement was suggested through the October 2009 presentations such as 

the DERA policy set supports SO20 to conserve the historic environment by focusing 

development within a specific area. It is recommended that the policy set references 

structure of development. 

14.93 The emerging policy on gypsy and travelling populations (SP03) had the possibility to have a 

negative effect in relation to development in the green belt (including historic environment) 

in special circumstances. It was recommended that the policy define what would constitute 

special circumstances. The policy SP03 was modified to an extent that it now scores a neutral 

effect for this receptor. 

14.94 It is noted that the publication of the NPPF and in turn the planning policy for traveller sites 

notes the requirement to protect the greenbelt and this potential adverse effect is now 

downgraded to neutral within the level 4 assessment results. 




Frequency of 

data 

collection 

When should 


be taken? 

What remedial 


taken? 

Number and area of sites damaged/destroyed 

by development (LSF Indicator) 

Area of land covered by HLS and ELS 

environmental stewardship schemes 

Annual 

Annual 

When effect 

identified 

When effect 

identified 

Change in the character of the landscape Annual When effect 

identified 

Designated heritage assets Annual When effect 

identified 

Depends on nature 

of effect identified 









Section 15. 

Introduction 

[ER10] Landscape and Visual Amenity 

15.1 The landscape and visual amenity receptor covers the effects on the character and the 

integrity of the landscape (such as areas designated as warranting protection on the grounds 

of their natural beauty). This receptor can also include the urban landscape and visual 

amenity. The receptor covers the topic of ‘landscape’ as required by the European Directive 

and UK Regulations on the environmental assessment of plans and programmes and 


15.2 The risks to the landscape and visual amenity receptor are directly associated with the 

development and supporting infrastructure that arise as a consequence of the production of 

new inappropriate development. Equally, adverse effects are prolonged by maintaining 

visually inappropriate development. These risks are to a large extent reversible and can be 

avoidable if steps were taken to reduce the potential effects on the landscape and the visual 

character the areas affected in advance of the development going on ground. 

15.3 In some instances the urban component of the receptor can be quite vulnerable to 

inappropriate development. However, this is not always the case as the majority of the 

townscapes in Runnymede lack any warrant of national protection. 

15.4 Therefore, conversely, the opportunities exist for the landscape and visual amenity receptor 

that are directly associated with the development and supporting infrastructure arise as a 

consequence of the production of new development. The opportunities would be missed if 

new development did not come forward. 


Table 90 – Applicable SA/SEA Objective on ER10 




SO20 ‘To protect and enhance the borough’s countryside and historic environment’ G 


FA12 Landscape G 







goals 



[ER10] Landscape and Visual Amenity 

UK Policy: White Paper-Our Countryside: A Fair Deal for Rural England, 

Biodiversity Strategy for England, Good Practice Guide on Planning for 

Tourism, UK Climate Change Programme, White Paper: Planning for a 

Sustainable Future, The Historic Environment: A Force for our Future, 

Thames Waterway Plan and Sustainable Communities: Building for the 

Future , England Rural Development Plan. 

Regional Policy: South East Plan, South East Regional Minerals 

Strategy , Regional Minerals Strategy for Waste and Minerals 

Objective: Improve the public realm and 

regenerate town centres to deliver a 

vibrant borough fit for the 21 st century 

Comment: Landscape, townscapes, and 

visual amenity are a key focus of the SCS 

and the Local Plan. Regeneration of town 

centres will provide an opportunity to 

improve visual amenity in town centres, as 



goals 



Surrey Policy: The Surrey Waste Plan, Surrey Urban Habitat Action 

Plan, Surrey’s Countryside The Future Action Plan Rural Strategy, 

Surrey Woodland Habitat Action Plan, Surrey Biodiversity Action Plan, 

Surrey Wetland Habitat Action Plan , Surrey Climate Change Strategy, 

Surrey Local Transport Plan 

Runnymede Policy: Runnymede Sustainable Community Strategy and 

Corporate Plan, Runnymede Borough Council (Saved) Local Plan 2007 

European Law: European Directive EIA , European Directive SEA , 

European Water Framework Directive 

International 

15.6 Convention on Climate Change and Biodiversity (1992) 

will other improvements to the public 

realm. Certain areas of the greenbelt, 

waterways and other landscape, though 

protected or environmentally valuable, are 

not of high visual quality and can be 

addressed as part of the aspirations of the 

emerging vision. 

15.7 This convention focused upon the need for conservation of biological diversity, the 

sustainable use of its components, and the fair and equitable sharing of benefits arising from 

commercial and other utilisation of genetic resources. The agreement covers all ecosystems, 

species and genetic resources. 

European 

15.8 European Sustainable Development Strategy (2009): This strategy focuses upon a reduction 

in climate change and the promotion of a low carbon economy. It also looks to the reduction 

of unsustainable trends such as the need to decrease high energy consumption in the 

transport sector and to reverse the current loss of biodiversity and natural resources. 

15.9 European Conservation of Natural Habitats (1992): The main aim of the Habitats Directive is 

to promote the maintenance of biodiversity by requiring member states to take measures to 

maintain or restore natural habitats and wild species listed on the Annexes to the Directive at 

a favourable conservation status, introducing robust protection for those habitats and species 

of European importance. In applying these measures Member States are required to take 

account of economic, social and cultural requirements, as well as regional and local 

characteristics. 

National 

15.10 National Planning Policy Framework (2012): This framework sets out government aims to 

achieve Sustainable development. This focus’s upon the following areas: 

 

 

 

 

 

 

 

 

 

 

 

 

 

Building a strong , competitive economy 

Ensuring the vitality of town centres 

Supporting a prosperous rural economy 

Promoting sustainable transport 

Supporting high quality communications infrastructure 

Delivering a wide choice of high quality homes 

Requiring good design 

Promoting healthy communities 

Protecting green belt land 

Meeting the challenge of climate change , flooding and coastal change 

Conserving and enhancing the natural environment 

Conserving and enhancing the historic environment 

Facilitating the sustainable use of minerals 


15.11 Soil Strategy for England (2009): This strategy require all England’s soils will be managed 

sustainable and degradation threats tackled successfully by 2030. This will improve the 

quality of England’s soils and safeguard their ability to provide essential services for future 

generations. 

Regional 

15.12 South East Regional Minerals Strategy ( 2009): This underlines the requirement to: 

County 

 

 

 

Safeguard the region’s naturally occurring minerals and encourage the use of 

suitable alternative construction materials where appropriate 

Protect the environment and local amenity 

Minimise the adverse impacts of the transport of minerals and construction 

materials 

15.13 Surrey County Council Rural Strategy (2010): The main objectives for the above strategy are: 


 

 

 

 

 

 

An equality in policy and investment with the urban areas 

Empowered and self sufficient communities 

Thriving rural economy and land‐based sector 

Bio‐diverse and well‐managed countryside 

Adequate and dependable infrastructure – including roads, water and housing 

Resilience to adverse impact – including climate change, flooding, disease and 

energy costs. 

15.14 Runnymede Borough Council Open Space Study (2012): This study defines the nature and 

distribution of open space sites in the Borough, and identifies the classifications and broad 

locations where there is under provision, or where quality could be improved. This study 

makes recommendations to remedy historical deficits and to cater for growth. 







15.16 The landscape of Runnymede is characterised as ‘Thames Basin Lowland’, urban fringe, which 

is of gently undulating vale of small‐scale field interspersed by woods, shaws ponds, 

meadows and heath. Typically the rural landscape gives the perception that farming 

enterprises within the borough are in a state of decline. Areas around towns and villages have 

a generally unkempt appearance. The majority of the borough (78%) comprises of greenbelt, 

which includes 281 hectares covered by environmental stewardship schemes. 

15.17 In terms of the urban landscape the major towns are Addlestone, Chertsey, Egham, and 

Virginia Water. The 2007 Saved Local Plan highlighted the need for revitalisation within the 

town centres within Runnymede. This conclusion is replicated within the Council emerging 

SCS. 








Receptor 

[ER10] Landscape and Visual 

Amenity 

Key Issues, challenges and potential responses for the Local Plan 

Summary: Runnymede is typified as a London urban fringe area constrained by Green 

Belt, flooding and nature protection. 

Issues and Challenges: No landscapes in Runnymede are protected under the Area of 

Outstanding Natural Beauty. 78% of the land area of Runnymede is designated as 

metropolitan Green Belt and generally considered as being urban fringe in nature. 

Pockets of high quality urban environments pepper an otherwise non-distinct urban 

realm. Urban development and supporting infrastructure developments and schemes 

have the capacity to significantly affect the quantity of both the borough’s Green Belt 

and its urban environments. 

Possible LP Response: The LP could bring forward policies to replace poor quality 

environments, enhance good quality environments, and strictly protect those limited 

environments that are deemed excellent. The LP could bring forward policies that 

make possible the development of places fit for the 21 st Century living, whilst 

controlling the risk to the character and integrity of Runnymede’s landscape. 

How LP Responded: The LP contains no specific landscape and visual polices. The 

importance of retaining landscape and protecting visual amenity is expressed in several 

policies on town centre development and the tourism policy set. 


15.19 Pressure for development from the built environment within Runnymede has the potential to 

affect Runnymede both positively and negatively depending upon how development is 

structured. In the absence of the Local Plan development decisions would be made in light of 

the NPPF and its presumption in favour of sustainable development. Which for the interim 

(that is until the Council develops and adopt its LSF) will mean additional development 

volumes and of types that might not be what would come forward had there been an 

adopted Local Plan. 


LVA1: Impacts arising from new development and infrastructure provision 

15.20 The provision of new development and infrastructure (e.g. park and ride sites) could, 

dependent on location and scale, result in impacts on the landscape and visual character of 

the area affected. The scale and extent of any adverse effects would depend on the location 

of any new development and the character of the landscape and area affected (i.e. 

designated landscapes). For these reasons this effect could also be significantly positive. 

LVA2: Impacts arising from development and infrastructure maintenance and improvement 

15.21 Maintaining existing development and infrastructure (e.g. highway networks, water, and 

flood defence) can, dependent on location and scale, result in impacts on the landscape and 

visual character of the area affected. The scale and extent of any adverse effects would 

depend on the location and suitability of any existing development and the character of the 

landscape and area affected (i.e. designated landscapes). For these reasons this effect could 

also be significantly positive if the result removed an existing blight on the landscape. 



15.22 The adverse impact of policy option LP01 has to be recognised, particularly as it impacts on 

the pathways LVA1 and LVA2 (Appendix 4). The impact of LP01 cannot be underestimated as 

it involves part development of a green field (DERA) and the impact is likely to be significant. 

However, this must be balanced with the overall benefits of the alternative in terms of the 

wider community gain. 





(RSF 19). 

15.24 LP01 overall does have a significantly different impact to the alternatives, but this needs to be 

balanced with the overall benefits of the policy. 


15.25 The policy options have an uncertain impact (Appendix 4). However, the effect on the 

pathways are mixed but not in a way that is unacceptable given that development will have 

to take place. 







growth. 




15.28 The impact of all policy options is limited being both beneficial to uncertain (Appendix 4). 

LP03 has the most beneficial effect on the pathways. 








15.31 The uncertain impact of LP04 is noted, however, the impact on the pathways is overall 

neutral(Appendix 4). This reflects the consequences of new built development to meet future 

need. 




growth. 




15.34 With regard to the Landscape and Visual Amenity receptor, LP05 scored a neutral effect 

overall and for both impact pathways, impacts arising from new development and 

infrastructure (LVA1) and impacts arising from development and infrastructure maintenance 

and improvement (LVA2) (Appendix 4). LP05‐A1 scored a beneficial effect overall and across 

both pathways and LP05‐A2 scored an uncertain effect overall and across both pathways. This 

bears out the conclusions reached for the previous receptor; LP05‐A1 scores best because it 

presumes against development, whereas LP05‐A2 scores an uncertain effect because any 

development would take place on a piecemeal basis which without a comprehensive scheme 

up front cannot be quantified and its effect assessed. LP05 scores a neutral effect because 

although it will involve development, this will be on a planned basis by virtue of the 

requirement for a masterplan, and so effects on the landscape and visual amenity can be 

addressed from the outset. LP05‐A1 (maintaining the Green Belt designation) would 

therefore again have the least effect but it would not take in to account the reason behind 


the policy; the college needs to expand to at the least maintain and preferably enhance its 

reputation and national position, an aspiration that is supported by the Government. This 

receptor solely considers the physical effect of the proposed policy, but this is only one 

dimension of the policy; the economic and social effects must also come in to play, and LP05‐ 

A1 would not allow any expansion of the college, and this may lead to it moving from the 

Borough, which would have a negative effect. 

15.35 With regard to SA, overall, LP05 has a mixed effect on SA objectives, and the alternatives both 

have a neutral effect (Appendix 3). The relevant RSF objective, RSF20 (to protect and 

enhance the region’s countryside and historic environment) scores an adverse effect for LP05 

and LP05‐A2 and a neutral effect for LP05‐A1. This suggests that development would be 

detrimental to the amenity of the site but the production of a master plan for the preferred 

option and legislation protecting the setting of the site would mitigate against potential 

effects. 


15.36 With regard to SEA receptor ER10 (Appendix 4), the overall conclusion for policy LP06 is a 

neutral effect on the receptor. This is because it has been judged that Landscape and Visual 

Amenity are unlikely to be of significant concern in the settlement area. . 



15.38 The neutral impact is noted on the policy options are noted with regard to the SEA (Appendix 

4). The policy options have an overall neutral affect on the pathways. 




growth. 




15.41 LP08 has an uncertain impact with regard to SEA (Appendix 4). LP08‐A1 and LP08‐A2A3 have 

a neutral impact on the receptors. LP08‐A2 has a significantly adverse impact. LP08‐A2 has a 

neutral impact. However, consideration of the impact on the pathways is less clear. LP08 has 

a significantly adverse affect on LVA2 (impact of infrastructure maintenance), whilst LP08‐A1 

and LP08‐A2 have an adverse affect on LVA 1 (impact of new development). To some extent 

this is a subjective assessment, but it is something that will need to be considered as part of 

any detailed schemes. The overall view is that uncertainty arises as a result of the mix of 

impacts on the individual pathways. The positives affects are balanced by the negative 

affects. From this receptor the LP08‐A2 has the most negative impact. 




15.43 The overall conclusion of the SA is that LP08 is mixed positive but the other alternatives are 

all neutral (Appendix 3). The overall SEA conclusion is that LP08, LP08‐A1 and LP08‐A3 are 

uncertain and LP08‐A2 is neutral. Within the context of the SA LP08 has a significant adverse 

affect on RSF 9 (create employment), RSF 16 – significantly adverse (improve air pollution), 

but the other RSF are generally well accommodated. However, the SP08‐A1 and LP08‐A2 

have an adverse affect on RSF 14 (improve reuse of land/building)., RSF 19 (enhance 










15.45 No SA/SEA Discussion. 


15.46 The policy options all have a neutral impact on the receptors, and this is reflected in the 

impact on the pathways with regard to the SEA (Appendix 4). 

15.47 Having regard to the conclusion of SA in Appendix 3, overall, the policy SP02 and SP02‐A2 






receptors, but the impact of the AP02‐A1 is different is uncertain and so SP02 and SP02‐A2 


15.48 SP02 overall in the SA consideration does not have an overall different impact to SP02‐A2. 

However, the overall SEA has an uncertain impact on the pathways. 


15.49 With regard to SEA receptor ER10 (Appendix 4), the overall conclusion for SP03 is a positive 

effect on Landscape and Visual Amenity. This is because the delivery of sites to meet needs 

should help to ensure that there will be no unsightly unauthorised developments or 

encampments in the countryside that detract from Landscape and Visual Amenity. Policy 

SP03‐A1 a neutral effect, as no new development is involved. 




have a significantly beneficial effect on the environmental receptors. 



15.53 With regard to SEA receptor ER10 (Appendix 4), the overall conclusion for policy SP05 is a 

beneficial effect. The policy has beneficial effects on impact pathway LVA1 (impacts from new 

development and infrastructure). Whilst this depends on the type, amount and location of 

new development, high standards of design would be assessed in any planning application to 

ensure visual amenity is enhanced. 

15.54 SP05 has beneficial effects on impact pathway LVA2 (impacts from development and 

infrastructure maintenance/improvement). High design standards would be expected for new 

development, which would enhance existing visual amenity and landscape. 



15.56 Regarding SEA receptor ER10 (Appendix 4), the overall conclusion for SP06 is a mixed effect. 

SP06 has mixed effects on impact pathway LVA1 (impacts from new development and 

infrastructure). This depends on the type, amount and location of development that will be 

proposed in relation to tourism recreation and leisure, and it is too early a stage to identify 

this. However, high standards of design would be assessed in any planning application to 

ensure visual amenity is enhanced. SP06‐A1 also has mixed effects for the same reason as the 

preferred policy. 


15.57 SP06 has mixed effects on impact pathway LVA2 (impacts from development and 

infrastructure maintenance/improvement). This depends on the extent of improvements 

required. However high design standards would be expected to improve visual amenity. 

SP06‐A1 also has mixed effects for the same reason as the preferred policy. 




facilitate development. However, the overall impact on the receptor is beneficial with regard 

to the SEA receptor (Appendix 4) for policy SP07. 



15.61 The beneficial impact of policy SP08 and SP08‐A1 is noted with regard to SEA (Appendix 4). 












beneficial effect. The policy has a beneficial effect on impact pathway LVA1 (impacts from 

new development and infrastructure), as new transport‐related infrastructure will make a 

positive contribute towards visual amenity. 

15.65 The policy has beneficial effects on impact pathway LVA2 (impacts from development and 

infrastructure maintenance/improvement), as existing infrastructure will make a positive 

contribute towards landscape and visual amenity. 




have a neutral effect on the environmental receptors. 





LP01 Strategy for the Location of Development 

Alternative LP01‐A1 ? / 

Alternative LP01‐A2 ? / 


Significant 

Beneficial 


Significant 

Adverse 

/ 0 ? 




LP02 Housing Provision and Distribution / 


Alternative LP02‐A2 (a) ? 

Alternative LP02‐A2 (b) ? 

Alternative LP02‐A2 (c) / 

Alternative LP02‐A3 (a) 0 

Alternative LP02‐A3 (b) ? 0 

LP03 Development in Addlestone Urban Area 



LP04 Development in Egham / Englefield Green Urban Area 0 


LP05 Royal Holloway UOL 0 



LP06 Development in Chertsey Urban Area 0 


LP07 Development in Virginia Water 0 


LP08 The former DERA site, Longcross / ? 





SP01 Green Belt Areas / / 




SP03 Gypsy and Travelling Populations 


SP04 Provision and Retention of Infrastructure and Service 0 

SP05 Design 

SP06 Tourism, Recreation and Leisure / / 

Alternative SP06‐A1 / / 

SP07 Thames Basin Heaths Special Protection Area 

SP08 Employment Development 0 


SP09 Sustainable Transport 

SP10 Development and Flood Risk 0 




15.70 No specific mitigation/enhancement recommendations for the landscape and visual receptor 

were proposed as a result of any of the levels of assessment or appraisals. 



15.71 Monitoring has been suggested and has been outlined in Table 94 below. 



Frequency 

of data 

collection 

When should 

remedial 

action be 

taken? 

What remedial 

action should 

be taken? 

Access to natural Greenspace (LSF Indicator) 

Number and area of sites damaged/destroyed 

by development (LSF Indicator) 

Area of land covered by HLS and ELS 

environmental stewardship schemes (LSF 

Indicator) 

Changes in the character of the landscape (LSF 

Indicator) 

Annual 

Annual 

Annual 

Annual 

Negative trend 

detected 


detected 


detected 


detected 

Consider policy 

review 


review 


review 


review 


Section 16. 

Introduction 

Conclusions 

16.1 As required by legislation, this SAR presents how the SEA assessment (see Appendix 4) and 

the SA appraisals (see Appendix 3) has been applied and carried out for the production of 

Runnymede Borough Councils Local Plan. It documents this process that commenced 

production in 2004. Both SA and SEA has been carried by in‐house by the Council’s impact 

assessment, policy and environmental health teams. This cross departmental working 

arrangement has provided the means of embedding the considerations of environmental, 

social, and economic impacts on a number of receptors and objectives as a result of 

implementing its plan into the Council. By doing so the Council has met the primary objective 

of both sustainable development practice and Article 1 of the SEA Directive with states that; 

“The objective of this Directive [SEA Directive] is to provide for a 

high level of protection of the environment and to contribute to the 

integration of environmental considerations into the preparation 

and adoption of plans and programmes with a view to promoting 

sustainable development… (Emphasis added)’ 

16.2 The process has neither been straightforward, nor simple and the main issue related to the 

fact that both plan and assessment/appraisal practice emerged around the same time ‐ 2004. 

The process was further complicated due to an extremely long timeframe involved in the 

production of the Local Plan 2004 ‐ 2013; the inevitable lack of clarity inherent within 

emerging preliminary drafts policies, coupled with a general lack of quantitative data to carry 

out the assessments resulted in a largely qualitative approach being employed. Issues around 

data and plan uncertainty and the risks associated are discussed in more detail in Sections 17 

and 18 below. 

16.3 The overall conclusions of both the SEA and SA of the Local Plan are now considered in the 

remainder of this section. 

Local Plan Policy Context Conclusion 

16.4 Preliminary analysis of the strategic fit the Local Plan has with the wider context of 

sustainable development policy (Table 13) indicates that the proposed plan had the potential 

to contribute to a wide range of strategic goals and objectives. A more detailed analysis was 

carried out within each of the 10 environmental receptors and showed that in general, the 

Local Plan implicitly rather than explicitly addresses relevant sustainability objectives. This is 

considered normal for such a plan at this level. 

16.5 It is also worth noting that there are likely to be significant differences between the Local 

Plan’s potential contributions to objectives and its actual contributions to the realisation of 

broader sustainability policy goals. The Local Plan’s actual contribution will be subject to the 

influences of a range of factors outside both the Council’s and Local Plan’s control, including 

constantly evolving legislative and market conditions, partnership working and local 

governance and resource availability. 

SA Sustainability Objectives Conclusion 

16.6 The Local Plan was subjected to a total of a 1,025 individual appraisals in respect of its SA. 

The output of these assessments are summarised in Appendix 3. Overall, and mindful of the 

caveat outlined in paragraph 16.9 and 16.10 below, the accepted Local Plan policies are 

considered to be slightly more beneficial than adverse. This conclusion implies that 

implementation of the Local Plan would neither ‘trail blaze’ the achievement of the 

sustainable development objectives as set out in Table 5, nor significantly adversely affect the 

environmental receptors considered by the SEA. 

16.7 The slight difference in the overall conclusions of the SEA (neutral) and SA (beneficial) for the 

accepted policies is considered to be as a result of the fact that the SA includes wider 

consideration of social and economic objectives, were as the SEA largely considers 

environmental receptors (see Figure 4). 


16.8 This effect could also be derived from a plan with policies whose detail remains largely 

unspecified in terms of quanta and locations of development, but also unspecified in terms of 

what development could do to further the principles of sustainable development or the 

enhancement and protection of vulnerable environmental receptors. This is highlighted by 

the contrast policies promoting growth like LP08 re‐development of DERA are considerably 

more beneficial across a greater number of sustainable objectives reflecting the positive 

impact in economic and social terms that generally accompany large scale redevelopment 

opportunities and generally do not perform as well in SEA assessments. 

SEA Environmental Receptor Conclusion 

16.9 As outlined in Figure 6 in Section 3 above, the assessment framework used on this Local Plan 

involves carrying out a number of different assessments/appraisals at any of the six levels 

identified in this flow diagram. It must be stressed that whilst these are individual assessment 

in their own right – they are ultimately integrated into the whole overall SAR process. For 

example Level 6 (HRA) was required to be completed, prior to Level 4 (SEA) and likewise Level 

3 (SA). This integrated method ensures that the SEA efficiently and effectively takes into 

account likely significant effects the Local Plan will have on for example the ER01 – Natural 

Environment and Biodiversity. The SA and SEA are thus fully informed by an assessment of 

the most sensitive European Sites of TBH SPA and TAP&C SAC; an appropriate assessment at 

Level 6 and attached at Appendices 8 and 9. 

16.10 Overall, across the 10 environmental receptors identified in Table 1, a total of 1,230 

individual Level 4 SEA assessments were carried out on the combined 18 accepted policies 

and the 23 reasonable alternatives within this Local Plan. The results of this considerable 

effort on the part of the assessment team are contained within Appendix 2 and presented in 

Appendix 4. 

16.11 Whilst these assessments provide ‘a general insight in terms of potential effects’, it is at 

varying degrees of usability. Generally, greater confidence can be placed on assessments that 

are closest to particular impact pathway, and correlates in the main to accepted industry 

practice. It follows that by combining results in a form of summary, the resulting score needs 

to be considered with this conclusion caveat and thus can only be an indication of the likely 

effect implementation of the Local Plan might have on the environment as a whole. This is 

not to say that inferences cannot be drawn from the overall summary; on the contrary there 

would be little point in carrying out an extensive exercise such as this if one could not. It is 

possible for the summaries to provide an indication of the possible ramifications the Local 

Plan could have on a particular environmental receptor and/or overall environment. 

16.12 This lack of certainty is in markedly contrasted in terms of the conclusions that can be drawn 

from the Level 6 HRA assessments. Only a conclusion of ‘no adverse affect on the integrity of 

the relevant European Site’ in these assessments will permit the Council to be able to agree 

to continue with and adopt the Local Plan. 

16.13 With the above cautions in mind, it is concluded that overall polices within the Local Plan are 

likely to result in a neutral effect on the environment of Runnymede. This neutral effect is 

largely derived from the plan where its policies are those which lack detail in terms of quanta 

and locations of development and are apparitional in nature. There are a few exceptions to 

this conclusion. In the main the exceptions relate to land‐use policies: such as Policy LP01, 

LP02, LP04, LP05, and Policy LP08 re‐development of DERA. The green belt relaxation 

promoted by Policy LP05 – RHUL is also considered to result in an overall uncertain adverse 

affects on the environment. Once implemented, these policies will result in the promotion of 

development towards environmentally constrained locations and thus the uncertainty. In 

contrast, environmentally constrained polices, Policy LP03 – Development in Addlestone 

Urban Area is considered to result in an overall neutral effect. These conclusions have been 

considered in detail by the Local Plan policy drafting team and were taken into account in the 

selection of preferred policies and rejection of other alternatives where applicable. This 

consideration is detailed within Sections 4 to 15 above under the heading ‘Consideration of 

Policy and its Alternatives on ER01 to ER10’ and has again been summarised in the 

paragraphs following the SA Conclusions. 


16.14 Cumulative effects are considered at the end of each of the 10 Environmental Receptors and 

have been accounted for in the conclusions below. The following paragraphs consider both 

SA and SEA conclusions in terms of the environmental receptors including a consideration on 

what the Local Plan could do in response to the particular issues facing Runnymede. It is 

followed by a consideration of what the Local Plan is proposing to do in terms of individual 

policies. 

ER01 – Natural Environment and Biodiversity 

16.15 The Natural Environment and Biodiversity receptor covers effects on plants, animals which 

are generalised in terms of habitats and species. Biodiversity is the term given to the diversity 

of life on Earth and includes the plant (flora) and animal (fauna) species as well as microorganisms 

and bacteria. 

16.16 Current indicator data suggests (see: Table 33) that the condition of this environmental 

receptor is overall unfavourable. The data supporting the indicator regarding the 

preparedness of the Borough to the impacts of climate change suggest considerable concern. 

Stresses in this indicator inevitably lead to additional impacts as a result of the amplification 

effect on vulnerable biodiversity factors. 

16.17 Runnymede has a relatively small but important biodiversity asset base contained within its 

protected sites and species in terms of lowland heathland and wetlands, and its ancient 

woodland. These features help characterise the Borough as a diverse natural environment 

that is extensively wooded. Whilst high resolution data at a local level is not readily available, 

data covering Surrey is. The rate of species loss observed in Surrey over the last hundred 

years has been substantial, with 31 species of plants having become extinct. Losses have also 

been substantial in terms of natural habitats, such as lowland heath land, which has 

decreased in the county by 85% since 1762. There has also been a 12% loss of all ancient 

woodland including semi‐natural. These timeframes may be considered to be well outside the 

time horizons of the Local Plan – up to 2026, but they are indicative of the difficulty in 

planning for, and protecting this receptor. 

16.18 The Local Plan could have brought forward a specific overarching proactive policy that 

focused on minimising the risks to habitat condition, fragmentation, and loss that might arise 

as a consequence of the construction or use of new development and supporting 

infrastructure. Policy could have incorporated a focus on the proactive management of 

nature conservation sites to preserve and enhance biodiversity, rather than the predictable 

reactive approach. 

16.19 In response, the Local Plan does not include a policy covering biodiversity. Plan makers 

argued that biodiversity is adequately protected through other polices which focus 

development in existing town centres (with the exception) of DERA LP08 and the tourism 

policy SP06. Policy SP07 ‘Thames Basin Heaths Special Protection Area’, could also be 

considered in this manner, as it promotes the use of Suitable Alternative Natural Green‐space 

(SANGs). It is predicated on the premise that the provision of SANGs between 400m – 5km 

from Thames Basin Heaths SPA’s boundary guarantees no net increase in the recreational use 

of this site. The conclusion is less difficult to agree with in terms of the area with 400m of the 

boundary ‐ this total exclusion zone does prevent future residential development 

contributing to any net gain in recreational disturbance. It is unclear how pressure from 

commercial development is controlled within either zone. The belief is that SANG works, and 

thus prevents further deterioration of this valuable and vulnerable asset. 

16.20 Consideration of the implementation of the Local Plan identified a number of likely significant 

effects on ER01. The most serious of these effects i.e. the ‘likely significant effects’ on Thames 

Basin Heaths Special Protection Area SPA and Thursley, Ash, Pirbright and Chobham SAC were 

captured within a Screening and Scoping Report that was issued by the Council under 

separate cover on the August 3, 2012 (see Appendix 8). As a result of this screening, the 

Council has carried out a separate Habitats Regulations Assessment (HRA) (see Appendix 9). 

16.21 The Council’s HRA considered three Local Plan policies – LP01, LP02 and LP08 and their ability 

alone or in combination with other plans or projects to adversely affect the integrity of two 

European site – Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC. 


Based on the information available but against the advice of Natural England, the Council was 

able to ascertain that implementation of policies LP01, LP02 and LP03 would not alone or in 

combination with other plans or projects adversely affect the integrity of either European 

site. 

16.22 Overall, policies LP01, LP02, LP08, SP01 and SP06 and a number of their alternatives were 

identified as having potentially adverse effects on ER01. In contrast, policy SP04 was 

considered to result in a beneficial effect on ER01. 

16.23 In terms of LP01 and its two alternatives, the majority of assessments exhibit considerable 

volatility, on some receptors the effect was considered to be significantly adverse (NEB1 – 

Land take) against beneficial (NEB3 – water quality). Overall the SEA rightly assess the 

potential effect level as uncertain. This uniformity was not replicated within the SA Level 3 

appraisal – policy LP01 returned a mixed result which was better than either of its 

alternatives. The SA Level 3 appraisals are expected to return a more favourable result than 

the SEA Level 4 assessments due in part to the wider social, economic in addition to the 

mainly environmental considerations of SEA . 

16.24 Policy LP02 and its six alternatives, exhibit quite a mixture of effects in terms of all receptors 

ER01, but similar to LP01 overall are expected to result in a uncertain effect across all policy 

options with the exception of LP02‐A3(a). Again the easing of expected effects was observed 

in the SA Level 3 appraisal results 

16.25 Policy LP08’s three alternatives all exhibit the same overall potential effect of uncertain in 

respect of SEA Level 3. This is in comparison to LP08, which the assessment team return an 

adverse affect, by virtue of negative impact on all receptors. These conclusions were reached 

prior to the conclusion of the HRA. In light of the HRA being able to ascertain that LP08 would 

not adversely affect the integrity of either the Thames Basin Heaths SPA or the Thursley, Ash, 

Pirbright and Chobham SAC, it is reasonable to assume that the assessment team might be 

more lenient. In contrast to SEA Level 4 the SA Level 3 returned a mixed effect, in terms of 

LP08 which was an improvement over its alternatives. 

16.26 Policy SP01 did not have any alternatives presented against it. As with a number of the 

locational policies, a difference is apparent between the SEA and SA Levels. The SEA was 

assessed as potentially resulting in an adverse effect as a result of two significantly adverse 

affects expected in terms of NEB1 and NEB4. The same policy returned a neutral effect in 

terms of its Level 3 SA appraisal. 

16.27 Policy SP04 did not have any alternatives presented against it. Overall in terms of ER01 policy 

SP04 was assessed as potentially resulting in an beneficial effect in terms of SEA Level 4, and 

in this case the same policy returned a beneficial effect in terms of SA Level 3. 

16.28 Policy SP06 and its one alternative, exhibit considerable difference between effects across all 

its levels of assessment. In terms of SEA Level 4, policy SP06 returns a more beneficial effect 

than its alternative policy SP06‐A1 ‐ which was considered adverse. In terms of SA Level 3, the 

opposite is true, policy SP06‐A1 returning a more beneficial effect than SP06. 

16.29 The potential for cumulative effects has also been considered in terms of this environmental 

receptor (see: Table 39). This CEA concludes that policies LP01, LP02, LP04, LP05, LP08 SP06, 

SP09 and SP10 have the potential to cumulatively act in a negative manner on this receptor, 

however, given the spatial extent of the area of influence over which the Local Plan has 

influence, it was not considered appropriate for the CEA to be taken any further at this time. 

16.30 Overall, the effect of the accepted policies contained within this Local Plan on ER01 is 

considered to be neutral. 

ER02 – Welfare, Health & Well‐being 

16.31 Welfare, Health and Well‐being receptor covers effects on the welfare, health and well being 

of the local population and is covered by 15 sustainability objectives and two environmental 

factors. It includes perceived risks to people’s health and well‐being (e.g. noise, odour, light 

pollution, etc.) or of ill‐health or injury (e.g. increased exposure to air pollution). In addition it 


covers the capacity to create opportunities for people to engage in activities that could give 

rise to health benefits. 


receptor overall is neutral, however, this masks some considerable internal variation in terms 

of concern regarding SO01 – Housing Provision, SO15 – Flooding Risks, SO16 – Air Quality and 

SO18 – Preparedness of the Borough to the impacts of climate change and the inevitable 

additional impact this will have on this environmental receptor. 

16.33 In terms of baseline and measured in terms of life expectancy, residents in Runnymede can 

expect to live longer than the average for England. With average life expectancy for woman in 

Runnymede of 83.7 years and 80.7 years for men (data taken from 2007‐9), suggesting a 

relatively affluent location. However, according to the Public Health Profile for Runnymede 

(2009) ‐ 12.2% of children within Runnymede live in poverty. Issues affecting residents 

include, road injuries and deaths, alcohol over‐use and hip fractures. 

16.34 Overall, the Local Plan policies score reasonably well against this environmental receptor, 

however, with the exception of the all to predictable impact on health from poor air quality 

WHWB2. Given the Local Plan promotes development that will cumulatively lead to a 

deterioration in air quality, it is surprising that it does not contain any specific policies 

targeted at this issue. It is possible that the plan authors believe that there is an adequate 

policy framework in place in order to prevent a deterioration in Runnymede’s air quality. In 

terms of this SAR, these affects are considered in more detail in ER05 and ER06 below. 

16.35 Policy LP01 and its two alternatives exhibit similarities with no overall difference in terms of 

LP01 and LP01‐A2. LP01‐A1 was considered to result in an uncertain effect. In terms of SA 

Level 3, all policy options return a positive effects with the exception of the impacts on air 

quality and climate change. 

16.36 Policy LP02 and its six alternatives, exhibit an mixture of effects overall, which is more 

pronounced in terms of the SEA Level 4 particularly in respect of LP02‐A1. This mixture is less 

evident in the SA where the effects range from neutral to mixed. Similar to policy alternative 

LP02‐A3(b), policy LP02 scores neutral across both assessment levels. In contrast alternatives 

LP02‐A2(c) and LP02‐A3(a) score the a mixed effect. 

16.37 Policy LP08 and its three alternatives, all exhibit the same overall potential effects across the 

range of assessments L2 – L5. In terms of SEA Level 4, policy LP08 was assessed as having the 

potential to result in mixed and neutral effects achieved by alternative LP08‐A2. The 

remaining alternatives have been assessed as being of a greater negative impact of neutral. In 

terms of SA Level 3, LP08 scores equally good to all but one of its alternatives – alternative 

LP08‐A3 which the assessment team felt was neutral. Given the fact that this policy allocates 

a specific site within the Local Plan, it was necessary to carry out an additional Level 5 

assessment of three strategic alternatives to this site. The Level 5 did not differentiate 

significantly between LP08 or its alternatives with the exception of LP08‐A3. 

16.38 Policy SP01 did not have any alternatives presented against it. The SEA Level 4 was assessed 

as potentially resulting in an neutral effect, whereas the same policy returned an improved 

mixed effect in terms of SA Level 3. 

16.39 Policy SP06 promotes the encouragement of recreational and leisure infrastructure which 

could be beneficial in terms of this environmental receptor as if implemented it would 

enablement physically activities that improve welfare, health, and well‐being. It is possible 

that the Local Plan could have included policies requiring developers of new residential 

development to adopt both the “Lifetime Homes and Lifetime Neighbourhoods” standards 

for all developments of residential properties in the Borough. 



ER03 – Land& Soil Resource 

16.41 The land, soil, and minerals receptor covers the effects on land use, the use of mineral 

resources and safeguarding of soil quality and resources (e.g. best and most versatile 


agricultural land). The natural landscape of the borough is characterised by the Thames Basin 

Lowland and urban fringe location that maintains a rural appearance including tree and 

woodland cover. Its underlying geology is a mixture of light clay or sandy soils, Thames Valley 

gravels, and poor sandy, acidic solids in the heath and woodlands areas in the west of the 

borough. 

16.42 Current indicator data suggests that the condition of this land and soil receptor is in overall 

favourable condition (see: Table 48). There appears to be scope (albeit small) for 

revitalisation of town centres and supporting infrastructure, including transportation, to 

affect the quality and usability of land and soil, and the accessibility of mineral resources. 

However, Runnymede has no good quality agricultural land, in this respect the ability of the 

Local Plan to directly affect the land and soil receptor is low. The borough’s geology 

determines it is one of the few locations in Surrey for mineral resources. Primarily this 

consists of sands and gravels, which are considered an important input to the Surrey 

economy and protected by the Surrey Minerals Plan (2011). 

16.43 The Local Plan could have brought forward policies to prioritise the minimisation of the 

reduction in primary aggregates use in development and supporting infrastructure. Policies 

could have been included that requires aggregate developers to adopt a phased approach to 

working mineral resource locations and planning the eventual integration open space and 

leisure activities that provide additional capacity for climate change events such as flooding. 

The Local Plan makes no specific references to either the protection, minimisation of use, 

extraction management or site restoration of land and soil resources. 

16.44 The pattern of potential impacts policies and their alternatives’ are expected to have on this 

environmental receptor is similar to those displayed in ER01 and ER02. This presents as a 

limited number of policies and some alternatives having potentially adverse effects on ER03. 

16.45 LP01 is considered to result in a neutral effect on this receptor, in comparison to the more 

positive mixed effect expected from both alternatives. The assessment team did not expect 

any difference between policy or alternatives in terms of SA. 

16.46 Policy LP02 and its six alternatives, exhibit a considerable mixture of effects overall for this 

environmental receptor. This is more pronounced in terms of the SEA particularly in respect 

of LP02‐A2(b) and LP02‐A3(a). The most severe effect was expected from LP02‐A3(a) which 

has been assessed as significantly adverse. This mix and therefore differentiation is less 

evident in terms of SA where the effects range from uncertain to neutral. 

16.47 Policy LP08 and its three alternatives, all exhibit similar overall potential effects across the 

range of assessments L2 – L5. In terms of SEA, policy LP08 and its three alternative is assessed 

as having the potential to result in a neutral effect. In terms of SA, LP08 scores equal to LP08‐ 

A3 being considered to result in a neutral effect on ER03. Alternatives LP08‐A1 and A2 both 

score uncertain. The Level 5 assessment did not differentiate significantly between any of the 

policies. 



ER04 – Water Resources & Management 

16.49 The water resources and management receptor covers effects on the biological and chemical 

quality of surface water and ground waters. It included consideration of safeguarding, use 

management and the management of flood risk. 

16.50 The South East the per capita consumption of water with data taken in 2008/9 showing an 

average usage of 156 litres per person per day (pppd). There are 31km of waterways within 

Runnymede with the water quality of the borough’s rivers generally good. The Thames region 

also records 100% compliance with EC Bathing Waters Directive (2009 data). 

16.51 In contrast it is noted that in February 2012; 21,603 residential and commercial properties 

within the borough were at risk of flooding. 


receptor overall is unfavourable. The data suggests particular concern regarding the SO01 


Provision of sustainable homes for all, SO15 progress towards a reduction in the risk of 

flooding and SO18 the preparedness of the Borough to the impacts of climate change. 

16.53 Urban development and supporting infrastructure networks, such as those being proposed 

with the Local Plan and which are likely to be enhanced as a result of induced development, 

all potentially affect both the use and quality of the water environment. The impact this 

might have on sensitive and vulnerable European sites is considered in the HRA of the Local 

Plan was considered within the Council HRA (2013) (see Appendix 9). 


to adversely affect the integrity of two European site – Thames Basin Heaths SPA and 

Thursley, Ash, Pirbright and Chobham SAC. Based on the information available to it and 

against the advice of Natural England, the Council was able to ascertain that implementation 

of policies LP01, LP02 and LP03 would not alone or in combination with other plans or 

projects adversely affect the integrity of either European site arising as a result of WRM3. 

16.55 The sitting of urban development and supporting infrastructure such as roads can interrupt 

the natural flows of both surface and ground waters, and can add to problems on flood 

plains. Common construction practice is to use piling which creates preferential pathways for 

groundwater. The quality of both ground and surface water can be affected by the run‐off 

which is often laden with pollutants including fuel oils and as well as seasonal road 

treatments (e.g. salt in the winter). 

16.56 The Local Plan could tighten the policies that it is bringing forward to further minimise the 

risks of development and infrastructure interfering with the water regime in addition to the 

statutory avoidance of inappropriate development in flood plains but proactively encouraging 

appropriate development and flood protection in the flood plain. Policies could also propose 

that all developments incorporate systems to capture and filter surface water run‐off, into 

the design of urban hard landscapes, roads and other supporting infrastructure as 

appropriate. The Local Plan makes no specific references to either the protection, 

minimisation of use, extraction management or site restoration of land and soil resources. 

16.57 A limited number of policies and some alternatives are identified as having potentially 

adverse effects on ER04, this is particularly apparent within the location set of policies. 

16.58 LP01 and its both alternatives are considered to result in a mixed adverse effect on this 

receptor. This is in comparison to the more positive neutral effect expected from policy LP01 

and its alternatives in terms of SA. 

16.59 Policy LP02 and one of its six alternatives (LP02‐A1) exhibit the same pattern of effects overall 

on ER04, in contrast to the five remaining alternatives LP02‐A2(a) – LP02‐A3(b). All these have 

scored adverse effects on all impact pathways. The SEA scores are not replicated in the SA 

with all policy and alternatives scoring neutral. Policies LP03 – LP07 and SP06 and a number 

of their alternatives, all exhibit the adverse affect on ER04 across the SEA. In contrast to these 

policies, with the exception of SP08, all remaining score neutral or mixed. Neutral, mixed or 

beneficial effects have been recorded by the assessment team in terms of the SA. 


receptor (see: Table 57). This CEA concludes that policies LP01, LP02, LP04, LP05 and LP08 

have the potential to cumulatively act in a negative manner on this receptor, however, given 

the spatial extent of the area of influence over which the Local Plan has influence, it was not 

considered appropriate for the CEA to be taken any further at this time. 




16.62 The air quality receptor is defined as the current and likely future air quality in Runnymede. 

Air pollution at various concentrations affect human health, natural and built environments. 

Air quality limit values are set for individual pollutants to protect sensitive human and 

ecological receptors. 


16.63 Current indicator data suggests (see: Table 60 ) that the condition of this environmental 

receptor is overall unfavourable. A number of its sustainable development objectives are 

considered to be in a severely unfavourable condition, such as SO16 – Air quality 

improvement; SO17 – Addressing the causes of climate change. This condition assessment 

has also transferred to its SEA Factor status. It is accepted that protecting the quality of air in 

the Borough is exceptionally difficult due to the cumulative nature and geographic range of 

the stressor. 

16.64 The main background air quality in Runnymede is generally considered to be good; however, 

Runnymede has declared 2 Air Quality Management Areas (AQMA) as a result of poor air 

quality). One AQMA runs along the entire length of the M25 (north and south of junction 11) 

and the second is located in Addlestone town centre (see: Section 9 – ER05 Air Quality above 

and Appendix 14). The main air pollutants of concern are nitrogen dioxide (NO 2 ) and 

particulate matter (PM 10 ) and potentially (PM 2.5 ). Particulate matter concentrations are 

assumed to follow the national decreasing trends, however nitrogen dioxide concentrations 

can be of concern close at busy roads and in town centres. 

16.65 Results from the roadside nitrogen dioxide diffusion tube network indicate that exceedences 

of the annual mean objective has occurred at several sites. The most likely causes are the 

cumulative increases in emissions from traffic and energy use from residential and 

commercial developments which the Local Plan is proposing to increase. To counter likely 

cumulative effects the Local Plan could have included policies that result in the management 

of traffic that will actually minimise demand so that the number of vehicles on the local road 

network. A positive reduction to ease congestion will in turn improve local air quality. The 

Local Plan does not contain a specific policy on Air Quality. 

16.66 Road traffic vehicle emissions accounts for a high proportion of air pollution in the Borough. 

High levels of car ownership and use within and around Runnymede are therefore generally 

associated with poor air quality. Runnymede has high levels of car ownership with 

approximately 1.5 cars per household – based on the 2001 Census 75 , which equated to 

approximately 45,616 cars/vans in the borough. Between 2001 and 2011 this figure has 

increased by approximately 4% to 47,403 cars/vans 76 . Given the fact that the Local Plan 

essentially promotes development that can only add to the overall Runnymede car and van 

fleet, it is unsurprising that a number of its policies and alternatives are identified as having 

potentially adverse effects on receptor ER05. 

16.67 The impact the Local Plan could have in terms of air quality on two European sites – Thames 

Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC was also considered through 

a Level 6 HRA assessment. The Council’s HRA considered three particular Local Plan policies – 

LP01, LP02 and LP08 and their ability to adversely affect the integrity of the European sites 

due to contributions to poor air quality. Based on the information available to it and against 

the advice of Natural England, the Council was able to ascertain that implementation of 

policies LP01, LP02 and LP03 would not alone or in combination with other plans or projects 

adversely affect the integrity of either European site. 

16.68 Policy LP01 and its two alternatives are considered will result in significantly adverse effects 

on this receptor as all options will result in increased contributions of traffic volume and 

increased energy use from buildings and infrastructure once operational. These adverse 

effects are less when policy LP01 and its alternatives are considered in terms of the Level 3 

SA. 

16.69 Policy LP02 and its six alternatives, exhibit some similarity of effects overall where the 

alternatives would result in increased volumes of traffic and energy use. Similar to policy LP01 

adverse effects are less when the policy and its alternatives are considered in terms of the 

Level 3 SA. 


76 2011 Census Data (Source: http://www.ons.gov.uk/ons/rel/census/2011‐census/key‐statistics‐for‐local‐authorities‐inengland‐and‐wales/rft‐table‐ks404ew.xls) 

Accessed 29/01/2013. 


16.70 Policy LP03 and its two alternatives, all exhibit a range of effects from mixed through to 

adverse for alternative LP03‐A2 which if implemented would result in considerably more 

development coming forward in Addlestone. As with other environmental receptors, the 

effects observed in the Level 4 SEA are not same always replicated in the wider Level 3 SA 

appraisal. This is similar for LP05 – LP07. 

16.71 Policy LP08 and its three alternatives, all exhibit the same effect profile and all result in an 

adverse affect on this receptor. In terms of the Level 3 SA, with the exception of alternative 

LP08‐A3 all score neutral effects on ER04; LP08‐A3 scored uncertain. The Level 5 assessment 

did not differentiate significantly between any of the policies. 

16.72 The strategy policy set SP01 – SP10 scored between mixed and uncertain across the range of 

assessments Level 4 SEA and Level 3 SA 


receptor (see: Table 65). This CEA concludes that policies LP01, LP02, LP04, LP05 and LP08 

have the potential to cumulatively act in a negative manner on this receptor, however, given 

the spatial extent of the area of influence over which the Local Plan has influence, it was not 

considered appropriate for the CEA to be taken any further at this time. 




16.75 The climate change receptor covers the cumulative effects on the atmosphere in terms of 

emissions of greenhouse gases as a result of the generation of energy and its use for heating, 

lighting, power, and transportation. The climate change receptor is closely aligned to the air 

quality receptor ER05. 

16.76 Issues of climate change are divided into two distinct groups; mitigation and adaptation. 

Mitigation addresses a 30+ year time horizon and involves reduction in emissions and 

improvements in energy efficiency. On the other hand, adaptation deals with the ‘locked‐in’ 

climate we can expect to get up to 30 years and generally involves adaptation measures. The 

impacts of climate change or the effectiveness adaptation measures are difficult to assess as 

they are outside the bounds of certainty required to trigger any meaningful action at this 

local level. In terms of impacts, Runnymede can expect an increased risk of fluvial and pluvial 

flooding, increased storminess, extremes of heat and cold. 


receptor is unfavourable. A number of its sustainable development objectives are considered 

to be in a severely unfavourable condition, such as SO16 – Air quality improvement; SO17 – 

Addressing the causes of climate change; and SO18 – Runnymede’s preparedness for the 

impact of climate change. This condition assessment has also transferred to its SEA Factor 

status. Similar to ER05, it is also accepted that mitigating through restricting/preventing 

further contributions to climate change, not to mention adapting to the inevitable impacts is 

exceptionally difficult at the level of a Borough due in part to the cumulative nature and 

geographic range of the stressor and the lack of expressed governance at this level. 

16.78 Urban development such as promoted by LP01, LP02 and LP08 that are intended to result in 

development that will required and use carbon based energy and transport; all major sources 

of carbon emissions, will consequently be a significant contributor to emissions resulting in 

climate change from the borough. This has been reflected in the Level 4 SEA were 

alternatives promoting increased development volume result in more adverse affects. This 

assessment consideration was not replicated in the more strategic Level 3 SA appraisal. 

16.79 The Local Plan could have brought forward policies that promote the active management of 

energy use plus traffic levels and demand for transport. It could have identified objective 

targets to reduce carbon emissions from new development and redevelopment and a policy 

that protects the ability of the main urban centres to install and run ‘district heating systems’. 

The Local Plan could have brought forward a policy that ensures the Boroughs infrastructure 

network capacity is capable of coping with the expected consequences of climate change – 

however, it did not. 


16.80 The Local Plan does not have any policy on Climate Change but claims that “An integral part 

of the Local Plan is to meet the challenges of climate change and this has underpinned 

policy development.” The most relevant most relevant policy that appears to deal with 

climate change is Policy SP10 dealing with flooding. 

16.81 The potential for cumulative effects has not been considered in terms of this environmental 

receptor as it is considered to be a cumulative effect receptor in its own right. It is 

considered within ER01 and ER05 explicitly. Given the spatial extent of the area of influence 

over which the Local Plan has influence, it was not considered appropriate for the CEA to be 

taken any further at this time. 



ER07 – Materials Efficiency & Waste 

16.83 The materials efficiency and waste receptor covers effects on the total volume of material 

moving through Runnymede’s economy, the generation of wastes, the recovery, reuse and 

recycling of material and the management of waste disposal. 


receptor is largely favourable. Only one of its sustainable development objectives SO01 – 

Housing Provision is considered to be in a severely unfavourable condition. The favourable 

condition assessment is transferred to its SEA Factor status. 

16.85 A considerable amount of materials used in the construction and maintenance of the built 

environment are non‐renewable. Equally, a considerable amount of the waste sinks into 

which current waste is stored is finite. These two problems will become more acute as time 

progresses through the plan period. 

16.86 Runnymede generates significant volumes of waste in the from of: Municipal Waste; 

Commercial and Industrial Waste; Construction and Demolition Waste; Hazardous Waste and 

Agriculture Waste. The majority of waste is dealt with in‐county, along with waste imported 

to the county from London and other parts of the South East. 

16.87 The European Waste Framework Directive (revised 2008) introduced the concept of the 

waste hierarchy (see: Figure 13), requiring first the prevent the generation of waste and to 

reduce its harmfulness. Waste materials should be reused, recycled or recovered, including 

use as a source of energy where it is not possible to prevent its generation. As a final resort, 

waste should be disposed of safely. 

Figure 13 ‐ EU Waste Hierarchy (2010) 

16.88 The Local Plan is not a waste plan and therefore could not reasonably have brought forward 

policies to deal with the totality of waste, but it could have brought forward policies to 

proactively reduce further the amount of waste that is generated and to increase the 

requirement for reuse of recycled or recovered materials in the maintenance or construction 


of urban developments and supporting infrastructure. The Local Plan does not have a specific 

policy for materials efficiency and waste. 

16.89 Urban development such as promoted by LP01, LP03, LP08, SP01, SP06 and SP08 are 

intended to result in development that both generates waste during construction and 

increases the requirements for waste handling facilities once in operation. This has been 

reflected in the Level 4 SEA were alternatives promoting increased development volume 

result in more adverse affects. This assessment consideration again was not replicated in the 

more strategic Level 3 SA appraisal. 

16.90 It has been determined that cumulative effects are not considered to be significant on this 

receptor. 


considered to be uncertain. 

ER08 – Built Environment 

16.92 The built environment receptor covers the effects on the quality and character of the built 

environment the maintenance and restoration of existing structures and the construction of 

new developments. 

16.93 In Runnymede 172 additional net dwellings were built in 2010/11. In 2009 133 affordable 

housing units were completed. In June 2011 there were 2,672 households on the housing 

register indicating a demand for housing within the borough is considerably greater than the 

supply. A considerable proportion (some 21,603) of its built environment incorporating 

existing commercial and residential properties are at risk of flooding. 


receptor is largely favourable. Similar to ER07, one of its sustainable development objectives 

SO01 – Housing Provision is considered to be in a severely unfavourable condition. The 

favourable condition assessment is transferred to its SEA Factor status. 

16.95 Runnymede’s population has increased annually and the positive trend in population growth 

is expected to continue 77 . Car ownership is also higher than the national average, at 1.5 cars 

per household 78 , and its road network is extensively used for private and business travel, as 

well as moving significant volumes of freight and exerts a considerable influence on the built 

form. The volume of traffic that makes use of the existing road network and that which 

passes through the borough, its towns, and villages is high. This volume of traffic can have 

adverse impacts on the condition of buildings and supporting infrastructure. The current 

condition of the built environment of a number of towns is considered to be of poor quality, 

therefore there is the opportunity to improve the condition of this receptor significantly. 

16.96 The population of Runnymede is growing; between 1991 and 2001 there was a growth rate of 

8.7%, mainly due to net inward migration rather than natural increase. At the time of the 

2001 Census there were around 32,000 households in the borough, accommodating a 

population of 78,033. The 2011 Census shows that the population has increased to 80,500 in 

32,700 households an increase of some 3.9% in households. By projecting the population 

growth rate between the three censuses 1991, 2001 and 2011 and assuming a similar rate of 

population increase over the projection period, the population will potentially rise to 86,000 

around 2026 (see: Figure 8 above). 

16.97 The Local Plan could have brought forward policies to ensure the production of a set of 

coherent Area Action Plans to guide the enhancement of the quality and offer of the towns as 

well as improve the integration of land use and infrastructure planning at both the strategic 

and the local levels. Policies could ensure that supporting infrastructure is brought forward 

simultaneously to enable and enhance the towns in terms of access for communities and the 

quality of the public realm and townscape. 

77 ONS Midyear Population Estimates 



16.98 The Local Plan contains a number of specific policies that address the built environment. It 

relies upon a group of policies that focus upon developing urban areas such as LP01, LP03, 

LP04, LP06 – LP08 the comprehensive redevelopment of the former DERA site. Policy SP05 

promotes the principle of ‘good design’ as advocated by the NPPF. 

16.99 As opposed to the majority of the other environmental receptors, urban development such as 

promoted by the Local Plan is considered to be beneficial to the Built Environment. This has 

been reflected in the Level 4 SEA were alternatives promoting increased development volume 

result in more beneficial affects. This assessment consideration was not replicated in the 

more strategic Level 3 SA appraisal. The Level 3 SA dampened the results across the majority 

of alternatives, accounting for the wider consideration of environmental and social issues 

within the Level 3 SA. 


receptor. 


considered to be mixed. 

ER09 – Historic Environment & Archaeology 

16.102 The historic environment can be defined as archaeological assets (both known and unknown) 

alongside sites, structures, and features of historic significance and value. Runnymede has a 

diverse historic heritage, in terms of buildings, archaeology and some landscapes and 

contains 307 statutory listed buildings, including 4 grade I listed properties; Runnymede Park, 

Tite Hill; Founders Building, Royal Holloway College, Egham Hill; Great Fosters, Stroude Road 

and Holloway Sanatorium, Strode Road. A further 19 buildings merit Grade II* listing. 

Runnymede also contains a number of areas of archaeological interest as well as 7 areas of 

conservation. 


receptor is overall favourable. The favourable condition assessment is transferred to its SEA 

Factor status. 

16.104 There is scope for urban regeneration to adversely affect the historic environment. These 

effects can be expressed in construction and operation through vibration on structural 

integrity and the continued cumulative impacts that the deposition of atmospheric pollution 

on the fabric of historic building assets. The historic landscape can be affected by the 

construction of new supporting infrastructure or changes to the volume of existing provision. 

16.105 The Local Plan could have brought forward policies that minimise the risks to the historic 

environment by proactively planning for its development and redevelopment. Risks to it that 

might arise from climate change and the construction and use of new development and 

supporting infrastructure on the historic environment and archaeology could have been 

assessed and proposed mitigation factored into proposals in advance. 

16.106 The Level 4 SEA identified Local Plan polices LP01, LP02, LP04, LP05, LP06, LP08 and SP09 and 

SP10 as having the potential to adversely affect Runnymede’s historic assets. Whilst the Local 

Plan proposes the protection of the historic character in centres such as in the Egham and 

Englefield Green Area (LP04) and Chertsey (LP06), it does not propose any wider protection of 

the historic environment either in terms of use. This assessment consideration was not 

replicated in the Level 3 SA appraisal. The Level 3 SA enhanced a number of the results 

across the majority of alternatives. 


receptor. 



ER10 – Landscape and Visual Amenity 

16.109 The landscape and visual amenity receptor covers the effects on the character and the 

integrity of the landscape (such as areas designated as warranting protection on the grounds 


of their natural beauty). Runnymede is typified as being a London urban fringe area 

constrained by Green Belt, alluvial flood plains and nature protection. 


receptor is overall favourable. The favourable condition assessment is transferred to its SEA 

Factor status. 

16.111 No landscapes in Runnymede are protected under the Area of Outstanding Natural Beauty 

but 78% of its land area is designated as metropolitan Green Belt. Pockets of high quality 

urban environments pepper an otherwise non‐distinct urban realm. Urban development and 

supporting infrastructure developments and schemes have the capacity to significantly affect 

the quantity of both the borough’s Green Belt and its urban environments. 

16.112 It is possibly optimistic to expect this Local Plan to bring forward policies to replace poor 

quality environments, enhance good quality environments, and strictly protect those limited 

environments that are deemed excellent. It might equally be optimistic to have expected it to 

brought forward policies that makes it possible to promote the development of places fit for 

the 21 st Century living, whilst managing the control of the risks such an ambition would 

present to the character and integrity of the limited amount of Runnymede’s good 

landscapes. 

16.113 The Local Plan contains no specific landscape and visual polices. The importance of retaining 

landscape and protecting visual amenity is loosely expressed in a number of policies on town 

centre development such as and tourism Policy SP06. The Local Plan contains a number of 

specific policies that have the potential to adversely affect the limited landscape and visual 

amenity quality that exist. These are the group of policies that focus upon developing urban 

areas such as LP01, LP02, LP04, LP05 and LP08 the comprehensive redevelopment of the 

former DERA site. Policy SP05 promotes the principle of ‘good design’ as advocated by the 

NPPF. 


receptor. 



ER01 – ER10 Overall Conclusion 

15.116 The Local Plan preparation, as part of the SAR, has involved an examination of the impact of 

the policy alternatives on the 10 environmental receptors. The 18 policy alternatives have 

given rise to a number of issues that have required different degrees of scrutiny at the 

various levels of assessment that form part of the SEA and SA process. These are set out in 

sections 5 to 14. 

15.117 The assembled data suggests that the 10 environmental receptors exhibit differing degrees 

of robustness and this reflects the complex relationship with the local area. Inevitably some 

of the receptors, such as ER01 (Natural Environment and Biodiversity), ER05 (Climate 

Change), and ER06 (Air quality) are particularly vulnerable to development changes in the 

local area. Consequently when considering the impact of the policy alternatives it was 

anticipated that any form of additional development would need to balance the impact on 

the environmental receptors and the need to accommodate the future needs of the local 

communities. 

15.118 The scrutiny that has taken place as part of the SEA and SA process and reported in this 

Sustainability Appraisal Report has provided the groundwork that will form an implicit part 

of the consideration of future proposals. A key part of this consideration will be the need to 

follow through with mitigation measures outlined in Appendix 2 to ensure that the impact 

on the environmental receptors is moderated. 

16.116 The report covers a spectrum of indicators that range from the negative to the positive. The 

overall view from the conclusions, when balancing the outcome of the SEA with the SA, is 

that the need to protect the receptors with the future needs of the local community results in 

a Plan with a neutral impact. 


16.117 Monitoring is considered an integral component of the SEA Directive and implementing SEA 

Regulations. To this end each section suggests a monitoring regime appropriate to the issues 

of concern to the environmental receptor. These will provide the framework basis to be 

employed as part of the Council’s monitoring regime for the SEA and Local Plan. 

16.118 Following the production and adoption of the Council’s Local Plan, a monitoring framework 

will be deployed to enable the Council to evaluate actual performance of the Plan in relation 

to the environment receptors against that which the SEA predicted, including any unforeseen 

adverse effects. 


SEA and SA Conclusion of the Local Plan Policies 


16.119 In terms of LP01 the three alternatives, all exhibit the same overall potential effect level in 

terms of SEA and a range from uncertain to mixed in terms of SA. 

16.120 Policy LP01 is chosen because it satisfies the overall strategy and does not have a significantly 

different impact to the other alternatives. It is considered that it will bring greater benefits in 

the round. There is particularly as it relates to the release of the former DERA site from the 

green belt for development. This links to the more detailed policy guidance that explores how 

the strategy is to be developed. 

16.121 Planning for future homes in Runnymede is a key function of this Strategy and a major 

component of the Sustainable Community Strategy (SCS). A range of housing is needed to 

meet the future needs of the population in the Borough; this includes homes for families and 

for first time buyers, and for the elderly, who are forming a growing proportion of the total 

population. There is a particularly strong need to provide affordable housing to meet the 

needs of those who cannot afford to buy or rent at market levels. Previous consultations on 

the Core Strategy have identified support for the location of new homes within urban areas, 

including in the town centres. 

16.122 It is important to note that the Borough housing allocations are not set at a maximum level, 

and where there is an identified local housing need, and other sustainability criteria can be 

met, national policy encourages the provision of increased numbers of dwellings. Provision 

has been made for windfall sites in the Plan and they are an integral part of supply and will 

need to taken into account as part of the Infrastructure Delivery Plan, the Community 

Infrastructure Levy and when recognising the requirements for the Thames Basin Special 

Protection Area (TBH SPA). 

16.123 In summary LP01 will result in focusing development within the existing urban areas with the 

exception of a new centre at DERA. 

16.124 The Local Plan team rejected two alternatives to Policy LP01, these were: 

 

 

LP01‐A1: To propose no additional growth but to respond to development schemes 

as they arise following the guidance in the NPPF to permit sustainable development. 

This ignores the SCS, excludes DERA for housing as it would remain in the green belt, 

but it would include the extant permission for commercial development. However, 

under the policy L02 further work is required to consider the consequences of 

choosing the housing options that require green belt releases; 

LP01‐A2: To focus solely on Addlestone for promoting significant development using 

the 2012 quantum’s of developments (that formed the early work on the SCS) and 

let other areas respond to development as option 2 [LP01‐A1]. This would exclude 

DERA for housing as it would remain in the green belt, but it would include the 

extant permission for commercial development. 

16.125 The implications of the policy and the alternatives on the receptors are uncertain. There is no 

consistently acceptable alternative in respect of the impact on the receptors and pathways. 

All alternatives have similar negative and positive. Accordingly there is no strong guidance 

from the impact on the receptors to assist with the selection of the preferred alternative. 







site. 

16.127 Having regard to the conclusion of both the SEA in Appendix 4 and the SA in Appendix 3, 

overall, all the policy approaches have a mixed beneficial impact. It is noted that the impact 


on the air quality is adverse (RSF 16), whilst it also has a negative impact on the desire to 

conserve and enhance the region’s bio‐diversity (RSF 19). 

16.128 The preferred approach overall does not result in a significantly different (either adverse or 

beneficial) impact to its alternatives and has therefore been chosen. 








site. 

16.130 Three core alternatives were considered. LP02‐ A1 145 units are identified representing an 

annual provision over 15 years of about 2000 units within the urban area. However, LP02 

and LP02‐A2 provides for 161 units p/a involving three additional sub‐divisions involving 

variously reserve site and green belt releases. LP02‐A3 (a)/(b) would also require either 

higher density development in the urban area or additional land to be released from the 

green belt to accommodate this scale of growth (550 units p/a). 

16.131 It is observed that LP03‐A3 (a)/(b) have a consistent trend towards a significant adverse 

impact and so these were excluded in the first iteration. In the next iteration it is noted that 

the remaining alternatives mostly have an uncertain/adverse impacts on the environmental 

receptor’s impact pathways. However, for LP02‐A2(c) was assessed to have an adverse 

impact on ER06 but it performed best on ER10. The Council concluded that all the remaining 

alternatives should remain in the second iteration as they had varying degrees on impact with 

no overall alternative emerging as clear choice. 

16.132 As the aggregate appraisal concluded no clear preferred alternative with LP02, LP02‐A1 and 

LP02‐A2, it was appropriate to consider the wider perspective of the SA. This became an 

important part of the appraisal as the Council wished to ensure that the development desired 

by the local community was recognised. However, the overall conclusion of the SA was 

positive for all alternatives. With the background of not excluding the LP02, LP02‐A1 and 

LP02‐A2 alternatives the following final appraisal was undertaken. 

16.133 From the data in the SHLAA, the housing allocation in the previous plans has never acted as a 

constraint on development and each application is considered within the policy guidelines. 

Accordingly, whilst a locally set housing requirement should be viewed as guidance, for the 

purposes of national guidance it is necessary to ensure an adequate land supply is available 

and this requires a formal housing figure to be established. 

16.134 The Coalition Government wants to boost housing delivery, therefore, LP02‐A1 which would 

reduce the annual housing target from 161 units to 145 units is not considered to be realistic 

or justified approach given this national guidance. Alternative 3 would set house building 

targets beyond those achieved in the Borough even in the boom times. This alternative was 

however eliminated through the SEA process. Alternative 2 emerged as the preferred 

alternative as being consistent with the evidence base in the South East Plan 

16.135 From the perspective of the SEA/SA there were 3 sub‐alternatives of LP02 A, A1 – A2 for 

consideration. There was no definitive view as to which sub‐alternative emerged as the 

preferred alternative. It would either require the release of the DERA size site from the green 

belt, the release of reserve sites or the release of urban edge SHLAA green belt sites. 

16.136 Planning for future homes in Runnymede is a key function of this Strategy and a major 

component of the Sustainable Community Strategy (SCS). A range of housing is needed to 

meet the future needs of the population in the Borough; this includes homes for families and 

for first time buyers, and for the elderly, who are forming a growing proportion of the total 

population. There is a particularly strong need to provide affordable housing to meet the 

needs of those who cannot afford to buy or rent at market levels. Previous consultations on 


the Core Strategy have identified support for the location of new homes within urban areas, 

including in the town centres. 

16.137 It is important to note that the Borough allocations are not set at a maximum level, and 

where there is an identified local housing need, and other sustainability criteria can be met, 

national policy encourages the provision of increased numbers of dwellings. No provision has 

been made for windfall sites in the Plan but they are an integral part of supply and will need 

to taken into account as part of the Infrastructure Delivery Plan, the Community 

Infrastructure Levy and when recognising the requirements for the Thames Basin Special 

Protection Area (TBHSPA). 

16.138 With regard to the conclusion of SA in Appendix 3, overall, all the policy approaches have a 






growth. 

16.139 The overall conclusion is that a single large sites would bring greater benefits by acting as a 

focus of infrastructure provision. The preferred alternative that best fits this requirement is 

LP02. This involves the release of the DERA site from the green belt. 

16.140 This approach aims to deliver on average 161 units per annum between the years 2011 and 

2026 based on extant permissions; windfall estimates and includes 1,500 units on DERA. The 

preferred approach overall in the SA consideration does not have a different impact to the 

alternatives 

16.141 The Local Plan team rejects five alternatives to Policy LP02, these were: 

 

 

 

LP02‐A1: Unplanned ‐ 145 p/a is based on extant permissions and windfall in urban 

area so no alternatives. Based on the NPPF approach; 

LP02‐A2: ‐ 161 p/a comprises 900 units with extant permission, and 1,500 units on 

identified (inc reserve sites) and windfall site sites. The sub‐alternative is based on 

how to accommodate the 1,500 units; 

o LP02‐A2(a): 1,500 units on green belt urban edge sites (Padd Farm, Wick Road, 

Virginia Water, and others in SHLAA); 

o LP02‐A2(b): 1,500 units on reserve sites and windfall sites; and, 

o LP02‐A2(c) 2400 units on DERA. 

LP02‐A3: Planned 550 units p/a; 

o LP02‐A3(a): A green belt solution based on DERA and all SHLAA green belt sites; 

and, 

o LP02‐A3(b): An urban area solution based on extant permissions, reserve sites 

and windfall sites. 

Location Policy 3 (LP03) – Development in Addlestone Urban Area 

16.142 There are a number of issues that are relevant to all the urban area policies. These have been 

captured in Box 3. 

Box 3 – Common Urban Area Development Issues 

 

 

 

During the Issues and Options stage, there was strong support for retaining, protecting, and enhancing 

the existing centres within the borough. This, along with the findings of the retail study, indicates that 

there is no need to pursue policies that promote out of town development. 

The retail study clearly demonstrates that the three main centres provide a day to day focus and that 

this should be enhanced, rather than seeking large scale retail development that would result in the 

towns changing to higher order centres in the retail hierarchy. 

This approach was supported by the SEP, which indicates that individuality is the key to the success of 

market plans, and so it is important to focus upon strengthening what each town has to offer. It is 

therefore not necessary to promote policies that would seek to create major retail expansion of our 

retail centres to elevate a centre in the retail hierarchy. 


16.143 The implications of the alternatives on the receptors are uncertain. There is no consistent 

negative impact to note although LP03‐A2 does have an adverse impact across 3 receptors. 

LP03 and LP03‐A1 have a general mixed impact on the ERIP’s. Accordingly there is no strong 

guidance from the impact on the receptors (ERIP) to assist with the selection of the preferred 

alternative. 

16.144 Having regard to the conclusion of SA in table 96, overall, all the policy approaches have a 

neutral impact. The impact on air quality is uncertain/adverse (RSF 16) for all alternatives, 




16.145 The Vision for Addlestone and the southern urban areas of the Borough in the Sustainable 

Community Strategy is that it will see the majority of new growth over the early period of this 

plan. The town centre will provide a range of facilities for the needs of its residents and 

businesses, as well as for the surrounding areas and will take opportunities for improvement 

and regeneration presented by vacant sites and underutilised sites along Station Road and 

adjoining area. Existing infrastructure will need to be enhanced and supported to 

accommodate this redevelopment. 

16.146 Planning for the future town centres in Runnymede is a key function of the overall Strategy 

and a major component of the Sustainable Community Strategy (SCS). A range of town centre 

uses is needed to meet the future needs of the population in the Borough. There is a 

particularly strong need to provide a diverse economic base to encourage reinvestment in the 

town centre. Previous consultations on the Core Strategy have identified support for 

investment in the town centre. 

16.147 The overall conclusion on the in the SEA/SA is that the alternatives do not have a significantly 

different impact to each other. For the reasons set out above, and to reflect the Sustainable 

Community Strategy, the preferred alternative is LP03. This approach promotes Addlestone 

as an area for ‘new town centre development’ that will largely replicate the form and 

function of the existing town centre. 

16.148 The Local Plan team rejects two alternatives to Policy LP03, these were: 

 

 

LP03‐A1: No additional growth proposed, but respond to development schemes as 

they arise in the context of the approach to be taken to sustainable development as 

set out in the NPPF; and, 

LP03‐A2: Significant development to be promoted in Addlestone (using the base 

information that formed the early work on the SCS). In other areas, development 

schemes would be responded to as Option 2. 

16.149 To summarise Policy LP03 promotes Addlestone as an area for ‘new town centre 

development’ that will largely replicate the form and function of the existing town centre. 

Location Policy 4 (LP04) – Development in Egham/Englefield Green Urban Area 


captured in Box 3 (see above). 


negative impact to note although LP04 does have a slightly more adverse impact across 3 

receptors (ER04,05 and 06). Accordingly there is no strong guidance from the impact on the 

receptors to assist with the selection of the preferred alternative 



receptors, but the impact of the alternatives is not different for planned or unplanned growth 

16.153 The Sustainable Community Strategy indicates that the town centre will provide a range of 

facilities for the needs of its residents and businesses, as well as for the surrounding areas 

and will take opportunities for improvement and regeneration. Existing infrastructure will 

need to be enhanced and supported to accommodate this redevelopment. 


16.154 The overall conclusion in the SEA/SA consideration is that the alternatives do not have a 

significantly different impact. However, the SCS seeks to regenerate the town centre’s in the 

Borough and LP04 –A is closer to this objective. LP04 –A makes specific reference to Royal 

Holloway UOL and it would generally act as a development control policy for the town centre 

in that any development coming forward will have to largely replicate the existing form and 

function of the existing town centre. This is the preferred approach. 

16.155 The Local Plan team rejected alternative Policy LP04–A1: 

 

LP04‐A1: No additional growth proposed, but responds to development schemes as 


set out in the NPPF. 

Location Policy 5 (LP05) – Royal Holloway UOL 

16.156 The objective of LP05 is to consider the expansion needs of the College on a sensitive Green 

Belt site whilst protecting the sites future academic use. 

16.157 Royal Holloway University of London brings educational, economic, and social benefits to the 

Borough, and one of the Council’s aspirations is therefore to retain RHUL in the Borough. 

However, in common with other higher education establishments, RHUL is under increased 

pressure to develop and grow. The University is committed to both enhancing its reputation 

and to maintaining its national position and Government Policy supports the University’s 

desire for the future growth of the college. The university is therefore developing a master 

plan to allow the University to grow and maintain its position, making provision for additional 

floor space for academic and research purposes, student residences and ancillary support 

purposes. 

16.158 The University wish to remain on the campus but indicate that it is too constrained to 

accommodate their growth aspirations. The Council has always wished to retain the campus 

within the Borough and to accommodate growth where consistent with policy. It is therefore 

necessary to consider how we can develop a policy to reasonably accommodate the 

aspirations of the university and retain the institution in the Borough, whilst affording a level 

of control over future development. At present the site is occupied by College buildings and 

gardens and has a mixture of college uses. The main College campus includes the Grade I 

listed Founder’s Building 

16.159 The green belt relaxation promoted by Policy LP05 and LP05‐A1 for RHUL is considered to 

result in an overall uncertain adverse affects on the environment. If implemented, these 

approaches would result in the promotion of development towards environmentally 

constrained locations and create uncertainty for the environmental receptors. 

16.160 Of the alternatives LP05 – A1 would provide the least effect on RHUL in terms of the effect on 

the environmental receptors. This approach maintains the Green Belt designation and would 

not allow the university to expand on the site, but doesn’t take in to account the reason 

behind the policy; the college need to expand to at the least maintain and preferably enhance 

its reputation and national position, an aspiration that is supported by the Government. As a 

local authority we recognise the educational, economic and social benefits the college brings 

to the Borough. However, the SEA consideration of the ERIP receptors solely consider the 

physical effect of the alternatives. This is only one dimension of the alternatives. ; The 

economic and social effects must also come in to play, and LP05‐A 1 would not allow any 

expansion of the college, and this may lead to it moving from the Borough, which would have 

a negative effect. LP05‐A2 on the other hand would allow the expansion, but without 

affording a level of control (through a previously agreed master plan) to protect the physical 

aspects of the expansion, to the detriment of this historic landscape, and particularly the 

Grade I Listed building. LP05 would allow expansion with more control than LP05‐A2. 

16.161 The Sustainable Community Strategy wishes to allow the expansion of the College to meet 

future needs. The overall strategy would be best served by the approach set out in LP05 ‐ A 

This approach provides Royal Holloway UOL with the potential to set out exceptional 

circumstances in order to address the strict Green Belt policy. 

16.162 The Local Plan team rejects the following two alternatives: 


LP05–A1 This approach maintains the green belt designation and not allow the site 

to expand 

LP05–A2 This approach removes the site from the green belt and allows the site to 

expand 

Location Policy 6 (LP06) – Development in Chertsey Urban Area 




negative impact to note although LP04 does have a slightly more adverse impact across 

receptors ER04. Accordingly there is no strong guidance from the impact on the receptors to 

assist with the selection of the preferred alternative 




growth. 

16.166 The Sustainable Community Strategy indicates that the town centre will provide a range of 

facilities for the needs of its residents and businesses, as well as for the surrounding areas 

and will take opportunities for improvement and regeneration. Existing infrastructure will 

need to be enhanced and supported to accommodate this redevelopment. Chertsey is 

considered as being an important historic centre in Runnymede. In addition, the Sustainable 

Community strategy seeks to retain the current mix of uses found in Chertsey and to protect 

its unique status in the borough by controlling new development so that it “…will assist in 

confirming the uniqueness of the town centre and establishing its position in the retail 

hierarchy as a place that meets local needs while providing opportunities for independent 

retailers…” The preferred approach is LP06 as it supports the overall strategy. 

16.167 The Local Plan team rejects one alternative to Policy LP06, which was: 

 




Location Policy 7 (LP07) – Development in Virginia Water Urban Area 




negative impact to note although LP04 does have a slightly more adverse impact on receptor 

ER04. Accordingly there is no strong guidance from the impact on the receptors to assist with 

the selection of the preferred alternative 


positive or neutral impact. The need to accommodate growth will have a consequence for all 


growth. 

16.171 The Sustainable Community Strategy indicates that the town and local centre will provide a 

range of facilities for the needs of its residents and businesses, as well as for the surrounding 

areas and will take opportunities for improvement and regeneration. Existing infrastructure 

will need to be enhanced and supported to accommodate this redevelopment. 

16.172 The approach in LP07 is to promote the continued maintenance of the urban area of Virginia 

Water as a high quality environment supported by the current mix of uses and to enhance its 

vibrancy and attraction through redevelopment opportunities. New development, including 

additional housing, will be in keeping with its surroundings. Opportunities for regeneration 

and redevelopment will be explored within the area adjoining Virginia Water Station to better 

meet local needs. 


16.173 The approach in LP07‐A1 is that no additional planned growth proposed is proposed but the 

Council will respond to development schemes as they arise. 

16.174 The overall impact in the SEA consideration shows that both have a similar impact. , 

However, LP07 is slightly more positive in the SA analysis. For the reasons set out above and 

to meet the requirements of the overall strategy the preferred approach is LP07. This 

proposes the continued protection of Virginia Water as a high quality environment supported 

by its current mix of uses found in the existing village centre that are being enhanced by a 

major development of a former car park. 

16.175 The Local Plan team rejects one alternative to Policy LP07, which was: 

 




Location Policy 8 (LP08) – The Former DERA Site Longcross 

16.176 The South East Plan allocated a new mixed use, including 2,500 new homes on the 116 

hectare former DERA site located in the Green Belt at Longcross. The site is divided by the M3 

motorway was and Policy LP08 seeks to provide for a similar mixed use development as per 

the South East Plan, but with a reduced provision of housing units. 

16.177 The site has a number of constraints, such as being located within the Green Belt as well as 

being located adjacent to the European protected sites of the Thames Basin Heaths SPA and 

Thursley Ash Pirbright and Chobham SAC. 







site. 

16.179 The policy alternatives for LP08 all exhibit the same overall potential effects across the range 

of assessments L2 – L5. In terms of SEA, policy LP08 is assessed as having the potential to 

result in an adverse effect whereas its three alternatives have been assessed as being of a 

lesser impact of uncertain. In terms of SA LP08 scores better than any of its alternatives. The 

Level 5 assessment did not differentiate significantly between any of the policies. 

16.180 LP08 is chosen because the Sustainable Community Strategy recognises the ability of the site 

to accommodate a new residential and commercial community during the Local Plan period 

but the site will need to be removed from the Green Belt to facilitate the anticipated 

development. The mixed use community will be supported by infrastructure to deal with the 

impacts on both the existing and new communities. This will include upgrading Longcross 

Station and the addition of an increased stopping service on the Reading to Waterloo line, 

retail, community, health, nursery, recycling facilities and public transport to serve the 

development. On and off site highway works will be required by the development and the 

provision of on and off site measures to mitigate the adverse impacts on the TBHSPA. The 

future development of the site will be set within the context of a Master Plan. This approach 

promotes removal of the DERA site from the Green Belt to allow its redevelopment for a 

mixed use development that includes up to 1,500 new homes and in the region of 79,000 m 2 

of onsite mixed employment uses. 

16.181 The Local Plan team reject the following alternatives; 

 

 

 

LP08 –A1 1500 dwellings to be developed on land at Great Grove Farm, Ottershaw 

LP08 –A2 1500 dwellings to be developed on at least two sites of a minimum size 

LP08 –A3 1500 dwellings to be developed on schemes as they arise in the context of 

the approach to be taken to sustainable development as set out in the NPPF. 


16.182 Alternative LP08 removes the DERA Site from the Green belt and similar to other location 

policies it sets out a number of development control outcomes the Council will look for in 

connection with new development in this area. 


16.183 With the exception of two policies (LP05 and LP08) the Council’s policy out in SP01 is to 

primarily locate new development within existing urban areas, thus maintaining the extent 

and existing boundaries of the current Green Belt. In the case of the two exceptions LP05 

proposes to relax the strictness of policy SP01 to permit development around the University 

site. LP08 removes the DERA site from the Green Belt. 

16.184 During the Issues and Options consultation 66% of respondents agreed or strongly agreed 

that future development should be in accessible urban locations rather than in the Green Belt 

and 60% agreed or strongly agreed that future development should be on previously 

developed sites of major developed sites. 


“The policy provides a local perspective on the guidance set out in 

the NPPF in terms of green belt protection. Section 9 of the NPPF 

(paragraphs 86 to 92) emphasises the need to avoid inappropriate 

development that will, by definition, be harmful to the green belt. 

The policy approach specifically reflects the position for major 

developed sites, site specific guidance and the context for meeting 

the possible needs of the gypsy and traveller community. Apart 

from the reference to major developed sites it brings together 

matters dealt with in separate policy guidance in the Local Plan. So 

whilst the policy does not seek to set a new approach it does set out 

clearly that there is a local character to green belt policy.” 

16.186 Having regard to the conclusion of both the SEA in Appendix 4 and the SA in Appendix 3, 

overall, all the policy approaches has a largely neutral effect. It is noted that the assessment 

team considered there to be potential impact of this policy on ER01, ER03 and ER07 impacts 

on the air quality appear to be the most relevant, as is adverse (RSF 16). Conversely, policy 

SP01 appears to result in a positive impact on the employment and social sustainable 

development objectives RSF 1, 9 and 13. 

16.187 To summarise, Policy SP01 promotes strict protection of the Green belt but with a general 

relaxation in terms of Royal Holloway UOL and the removal of the DERA site from the green 

belt. 


16.188 There continues to be a need for more affordable housing despite the provision that has been 

made over the last few years, including for young families who live and work in the Borough 

but who cannot afford to buy a home locally. 

16.189 There were 3 approaches that were examined. The first approach in SP02 recognises that 

with the current economic climate and the lack of funding for affordable housing, an 

appropriate starting point is to consider the implications of an aspirational target of 25% 

affordable housing provision on all qualifying sites. This would apply to sites providing 12 

dwellings or more (net), or a financial contribution from 10,000 sq m of commercial of net 

additional floor space or above. Any affordable housing provision below 25% would need to 

be fully justified by the applicant with an affordable housing viability report. This would be 

assessed on a case by case basis. For sites less than 12 units, a commuted payment is 

proposed per new unit (net). Should a developer challenge the proportion of affordable 

housing required, a full viability study will need to be submitted, and the developer will be 

required to fund an independent audit of the report. 

16.190 If this approach were adopted it would apply for at least two years at which time the policy 

approach will be reviewed to reflect any changes in the economic climate. The approach on 

affordable housing will be developed in supplementary guidance to support the core strategy. 


16.191 Alternative SP02 ‐ A1 does not seek to provide any affordable housing. This is a fairly radical 

approach for the Council to consider. Whilst this approach does not plan for affordable 

housing it may still come forward voluntary through individual schemes. However, the impact 

is to significantly prejudice the need to meet those who require affordable housing. 

16.192 Alternative SP02 ‐ A2 seeks to provide some 550 affordable houses each year. This will meet 

the identified annual needs for affordable housing. This will require a focus on many of the 

sites coming forward to provide exclusively affordable housing To meet full affordable 

housing need as identified in the Council’s SHMA would require implementation of a total 

housing supply that has been considered to be an unrealistic option for a number of reasons 

including the constraints on the land in the Borough from flooding, the proximity to the 

TBHSPA and also the Green Belt. Realistic affordable housing targets are more likely to be 

achieved by adopting a more realistic and deliverable approach which considers the 

economics of development. 

16.193 With regard to the SEA assessments it is noted that SP02 and SP02‐A1 have a neutral or 

positive impact. However, in respect of ER07 (use of materials) SP02 has an adverse e impact. 

With regard to SP02–A2 there is a greater impact on the receptors, with ER01 being adverse, 

and ER02 being significantly adversely affected. 

16.194 Having regard to the conclusion of SA in table 96, overall, the policy approaches SP02 and 





affect on RSF 16((reducing air pollution). The need to accommodate affordable housing will 



16.195 The Sustainable Community strategy wishes to promote affordable housing to create healthy 

and vibrant communities and in the way that it can help to help recruitment for local 

companies. The overall impact of the alternatives in the SEA/SA consideration does not differ 

significantly. However, SP02 is more in accordance with the overall strategy and reflects the 

aspirations of the Sustainable Community Strategy. The approach SP02 requires 25% 

affordable housing to be provided on qualifying sites (greater than 12 net additional 

dwellings) and provide financial contributions on all non‐qualifying developments 

16.196 The Local Plan team rejects two alternatives to Policy SP02, these are: 

 

 

SP02‐A1: No affordable housing; 

SP02‐A2: Meeting 500 units p/a. 

16.197 To summarise, Policy SP02 promotes a 25% affordable housing requirement, that will in plan 

terms be primarily met on the DERA site. 


16.198 Runnymede has the largest Gypsy and Traveller numbers in the North Surrey area according 

to the April 2007 North Surrey GTAA and also the highest proportion of Gypsies/Travellers in 

relation to the general population. Two caravans are equivalent to a pitch and the GTAA 

suggested that of the 49 additional Gypsy and Traveller pitches required in North Surrey, 20 

of these should be in Runnymede. 

16.199 In March 2012 the Government issued its National Planning Policy Framework (NPPF) along 

with its policy on Travellers. It is assumed that the Local Plan has taken account of compliance 

with this new policy framework in promoting a policy which safeguards existing sites with the 

location of additional provision as suggest in the GTAA being considered between 2016 and 

2026 in the form of a subsequent Sites DPD. 

16.200 Currently the Council applies an Interim Strategy, which was established in March 2010. This 

is based upon the Borough’s requirements deriving from the North Surrey Gypsy and 

Traveller Accommodation Assessment (GTAA) 2007. The strategy confirms that while no 

additional pitches are required to be provided up to 2016, an additional 23 pitches are 


equired by 2026. A Gypsy and Traveller Sites DPD will update the number of pitches and 

plots required, making use of a new local needs assessment, and also identify the locations 

for this provision. 

16.201 The approach in SP03 takes in to account the detailed assessment undertaken as part of the 

SEA indicating no significant difference between the alternatives. For the reasons set out 

above the preferred approach is SPO3 that seeks to meet the future needs of the gypsy 

community. 

16.202 The Local Plan team rejected one alternative to Policy SP03, which was: 

 

SP03‐A1: No additional provision; 

16.203 The overall conclusion of SEA as summarised in Appendix 4 is that the preferred policy of 

SP03 Gypsy, Travellers and Travelling Showpeople has a neutral effect. The same applies to 

the single alternative considered for this policy. 

16.204 The overall conclusion of SA as summarised in Appendix 3 is that the preferred policy has a 

mixed effect. 

16.205 To summarise, Policy SP03 promotes the safeguarding of existing sites. It suggests additional 

provision between the years 2016 – 2026 be considered in a future DPD. 


16.206 At the Issues and Options stage considerable support was received for the proposal that 

development should help fund infrastructure and services, for example the Council’s Yellow 

Bus Scheme (transport for school children), general bus services, and traffic management 

measures. 

16.207 During the evolution of the Local Plan, the Council considered the alternative to a policy on 

community infrastructure would be to rely on guidance as set out in Circular 05/05 and the 

use of the Community Infrastructure Levy (CIL) when it is introduced. It concluded that this 

would leave the provision of infrastructure to be dealt with on a case by case basis through 

the planning application process. The Council’s involvement in the Surrey collaboration 

project and its adoption of the “planning tariff” approach is supported by a policy LF10 in the 

SEP. This policy support s the small scale site tariff, and our proposed approach builds on 

this. 

16.208 It was considered important to address the provision of community facilities at the Local Plan 

level as it contributes towards maintaining the sustainability of locations and helps with 

community cohesion. However, given the fact that the Government has replaced Circular 

05/2005 with the NPPF coupled with the fact that the CIL Regulations 2010 are being 

implemented following the adoption of the Local Plan – it is questionable as to the 

effectiveness of this policy that largely replicates higher legislation in terms of CIL, s106 

Obligations (Planning Act) and Section 278 (Highways Act). 

16.209 The Local Plan promotes no alternatives to Policy SP04, going on to state that: 

“The policy provides a local perspective on the guidance set out in 

The NPPF says in paragraph 179 that it is important that planned 

infrastructure is delivered in a timely fashion. It is important for 

local planning authorities to understand the borough wide 

development costs at the time Local Plan are drawn up. For this 

reason infrastructure and development policies should be planned 

at the same time, in the Local Plan. In paragraph 175 it says that 

where practical, Community Infrastructure Levy (CIL) should be 

worked up and tested alongside the Local Plan. This is the proposed 

approach of the Local Plan. Policy SP04 seeks to set the context for 

the Infrastructure Delivery Plan (IDP) that underpins the CIL 

charging regime with the former being an integral part of the Local 

Plan process. It is recognised that the development policies in the 

Local Plan will identify the quantum of development and provide 

the guidance for assembling the IDP.” 


16.210 The overall conclusion of SEA as summarised in Appendix 4 is that Policy SP04 has a neutral 

effect. 

16.211 The overall conclusion of SA as summarised in Appendix 3 is that the Policy SP04 has a mixed 

effect. 

16.212 To summarise, Policy SP04 requires new development to contribute to the delivery of 

infrastructure identified in the IDP whilst promoting partnership working secure the same. 


16.213 At the Issues and Options stage there was considerable support (over 80% agreed or strongly 

agreed) with the premise that future development should enhance the built and natural 

environment with high quality design. 

16.214 The main alternative approach would have been to rely on the now outdated government 

guidance, regional policies, the Surrey Design Guide, or the production of supplementary 

documents regarding design issues. Having considered the importance of design locally and 

taking on board the advice of the Commission for Architecture and the Built Environment 

(CABE), the Council considered that it is important to have a policy in the Core Strategy that 

covers this issue, and this consideration has transferred to this Local Plan. 

16.215 However, the policy appears to be ‘all things to all men’, in that its main thrust is on the 

continued respect of the existing built, natural and historic environment with little scope for 

innovation that accompanies ‘exceptional quality design’ promoted by both the SCS and 

NPPF. 

16.216 The Local Plan promotes no alternatives to Policy SP05, and states that: 

“The NPPF establishes that design should contribute positively to 

making places better for people. It adds (paragraph 58) that Local 

Plans should develop robust and comprehensive policies that set 

out the quality of development that will be expected for the area. 

Policy SP05 sets out how the Council has provided an approach that 

reflects local circumstances and links into the Council’s Urban Area 

Appraisal 2009. The provision of an alternative policy approach is 

not considered appropriate.” 

16.217 The overall conclusion of SEA as summarised in Appendix 4 is that Policy SP05 has a mixed 

effect. 

16.218 The overall conclusion of SA as summarised in Appendix 3 is that the Policy SP05 has a 

beneficial effect. 

16.219 To summarise, Policy SP05 encourages the continued replication of the existing form and 

function of the built environment found in Runnymede. 


16.220 Tourism, recreation, and leisure are all issues of importance to Runnymede and create part of 

its individual character. In order to reflect this, it is considered important to have a policy 

covering this issue. 

16.221 Two policy approaches have been made available for consideration. SP06 supports the 

retention, improvement and provision of regional and local visitor attractions and facilities, 

and the promotion of local town centre focused facilities, whilst encouraging the promotion 

of heritage and waterways assets and protecting Green Belt (subject to other material 

considerations) as well as supporting the development of more hotel accommodation. 

16.222 SP06–A1 promotes the use of previously developed land within or adjacent to town and 

district centres or visitor attractions for new tourism, recreation and leisure opportunities to 

be accessible by public transport. The alternative also supports existing hotels and the 

improvement of the quality of existing visitor attractions where this can secure their 

continued viability without compromising the amenities of local residents or the Green Belt. 


16.223 The Council recognises the contribution the tourism industry has on the local economy. It will 

continue to support the development of existing attractions in order to realise their tourism 

potential, and to encourage projects which broaden the appreciation of the area’s natural 

environment and heritage. Runnymede is also an attractive and accessible location, and the 

historic fabric of the Borough is key to the tourist economy, particularly the sites of historic 

significance. It also has a rich supply of amenity and open space serving local communities. In 

addition to supporting the tourist economy, hotels and guesthouses are important in terms of 

providing direct employment and supporting other local firms that provide goods and 

services. 


effect, which was the same conclusion for the SP06–A1. 

16.225 The overall conclusion of SA as summarised in Appendix 3 is that SP06 has a neutral effect on 

the objectives, the alternative SP06–A1 has scored better as it is able to address the causes 

of climate change RSF17 

16.226 The Sustainable Community Strategy seeks to promote economic vibrancy. However, this 

needs to be balanced with the need to protect the (natural) environment. For the reasons set 

out above, in terms of the overall strategy, the preferred approach is set out in SP06. This 

seeks to support, promote, and encourage existing tourism, recreation, and leisure activities 

in the town centres and along the River Thames including the provision of more hotel 

accommodation. It caveats this support, premonition, and encouragement subject to other 

material considerations. The Local Plan team rejects the one alternative to Policy SP06–A1, 

which was: 

 

SP06‐A1: To support sustainable tourism, recreation and leisure in the area and to 

ensure that it remains a strong element of the Borough’s economy, the Council will: 

1. Support existing hotels and the improvement of the quality of existing visitor 

attractions where this can secure their continued viability without compromising the 

amenities of local residents or the objectives of the guidance in NPPF on green belt 

development; 

2. Promote all new built tourism, recreation and leisure development on previously 

developed land within or adjacent to town and district centres or visitor attractions; 

3. Require new tourism, recreation and leisure development to be accessible by public 

transport. 

16.227 To summarise Policy SP06 will (subject to other material considerations) provide 

encouragement for the continued use of heritage and waterways and the development of 

more hotel accommodation as contributors’ to the attractions of Runnymede. 

Strategic Policy 7 (SP07) – Thames Basin Heath Special Protection Area 

16.228 Natural England’s objection to housing development within 5km of this SPA has been a major 

constraint to development over the past few years and had the effect of halting development 

in local authority areas adjacent to it, including Runnymede. The SEP set out a comprehensive 

policy covering the main approach that needs to be taken with regard to the SPA. Similar to 

all other Councils, Runnymede put in place an interim supplementary planning guidance on 

its approach to development in the SPA. The Council uses this interim strategy when 

determining residential development proposals in the 5km SPA zone of influence 

(Supplementary Planning Guidance in 2008 (Revised 2009)). 

16.229 Policy SP07 effectively replicates the advice as set out in Local Plan 2001 Supplementary 

Planning Guidance in 2008 (Revised 2009) and the protection embedded within the Habitats 

Directive and Regulations. It identifies development at the DERA site as requiring a bespoke 

solution. 

16.230 The Local Plan promotes no alternatives to Policy SP07. 


effect. 


16.232 The overall conclusion of SA as summarised in Appendix 3 is that the Policy SP07 has a 

neutral effect. 

16.233 To summarise, Policy SP07 replicates advice approved by Natural England and currently being 

followed by the Council that permits the approval of residential development within 5 km of 

the TBH SPA. Development at DERA is singled out as ‘exceptional’, in that it requires a 

bespoke solution. 


16.234 Runnymede benefits from a strong local economy that has developed over the past 10 to 15 

years and spread over a number of major sites as well as within its urban centres. 

Safeguarding these existing sites is seen as key to protecting its existing economy. 

16.235 At the Issues and Options stage of consultation 55% of respondents strongly agreed or agreed 

with more intensive high value business development throughout Runnymede, particularly in 

town centres and major employment locations. 

16.236 Over 70% were in favour of improving the quality of business space by allowing mixed use 

redevelopment and changes of use to existing business premises. However, there was no 

particular support for allowing those vacant business premises not situated in town centres 

or business areas to be redeveloped for housing. These results suggest that there is support 

for new and improved business development throughout the borough. 

16.237 In terms of the SEA assessment, summarised in Appendix 4, the alternatives have an adverse 

impact on the use of materials ER07, the other receptors are uncertain to positive. 

16.238 Having regard to the conclusion of SA in Appendix 3 overall, the policy approaches generally 

have a neutral/positive impact. However, there is an adverse affect form the alternative 

SP08‐A1 on RSF 3 (reducing poverty) , RSF 6 (creating vibrant communities), RSF 9 and 11 

(stimulating the economy), and RSF 12 (developing a dynamic economy), RSF 13 (maintaining 

a skilled workforce), RSF 21 (improving transport), SP08‐A1 is less acceptable in the SA 

analysis 

16.239 The need to accommodate growth will have a consequence for all the receptors. However 

there is a need to accommodate growth to reflect the overall strategy and to acknowledge 

the Sustainable Community Strategy. For this and the reasons set out above SP08 is the 

preferred alternative. SP08 promotes the continued safeguarding of the existing employment 

and town centre sites including DERA. Travel plans encouraging including home working 

provision will be encouraged The policy seeks to safeguard its existing employment 

development by effectively resisting proposals that would result in their loss or reduction. 

16.240 The local Plan team reject the alternative SP08–A 1 which was: 

16.241 SP08–A1: In view of the scale of the provision to be made on the former DERA site a relaxed 

attitude will be taken towards the loss of employment land for the alternative uses. 

Appropriate development of employment sites will be expected to follow the principles of 

sustainable development. 

16.242 Accordingly there is no strong guidance from the impact on the receptors to assist with the 

selection of the preferred approach. 

16.243 To summarise, Policy SP08 promotes the continued safeguarding of the existing employment 

sites including DERA. Travel plans encouraging including home working provision will be 

supported. 


16.244 In the issues and options public consultation, over half of the respondents to transport 

related questions agreed residential development should make a financial contribution 

towards improving the Yellow Bus Scheme. Over half also agreed that all development should 

make a financial contribution towards improving existing (or providing new) bus services. 

16.245 Nearly half agreed that development should make a contribution towards improving paths, 

and cycle routes, and almost two thirds of the respondents agreed that large commercial 


developments, public buildings, and schools should have Travel Plans. Respondents also 

supported the suggestion that development should contribute towards improving the 

travelling facilities and services at railways stations. 

16.246 Specific comments also suggested that reducing car parking provision would only reduce 

travel demand by car if alternative arrangements such as car sharing were made. Points were 

also raised about the need to improve connectivity across the borough and with cross 

boundary areas. 

16.247 On the basis of its consultations, the Council considered it necessary to include a sustainable 

transport policy for Runnymede. An alternative would have been to prepare a sustainability 

principles policy. However, as transport is considered to be such a major issue for 

Runnymede, the approach was taken to set out the key elements or criterion required in 

order to work towards creating sustainable development. 

16.248 The purpose of the policy approach is therefore to improve accessibility by sustainable modes 

of transport to town centres, local centres, and facilities needed on an everyday basis to 

reduce reliance on the private car. 

16.249 The Local Plan promotes no alternatives to Policy SP09, but its text would suggest that it is 

based on locational coalescence of development promoted by Policy LP01. 

16.250 The overall conclusion of SEA as summarised in Appendix 4 is that Policy SP09 has a mixed 

effect. This policy was considered to result in significantly beneficial effects on ER05 Air 

Quality and ER06 Climate Change based on the potential effects a move from carbon based 

transport could bring. 


effect. In terms of its impact on RSF 6 Vibrant Communities, the assessment team saw a 

positive effect due in part to the outcome of focusing development in the urban centres. A 

similar positive effect was noted in terms of RSF 21 Transport Network Efficiency. 

16.252 To summarise, Policy SP09 effectively outlines a set of 8 ‘good to have’ criteria that will 

“…achieve sustainability…” that could apply to any location within the borough. 


16.253 Current data suggest that Runnymede has increased levels of commercial and residential 

properties at risk of flooding. In October 2011 there were 21,633 combined commercial and 

residential properties at risk of flooding. 

16.254 The policy recognises the severity of the flooding issue in Runnymede and the fact that it 

does not have within it any formal flood defences. In doing so it sets out the mechanism for 

determining planning applications within flood risk areas. This reiterates the guidance as set 

out in PPS25 which has been superseded by the NPPF Technical Guidance released in March 

2012. 

16.255 The Local Plan promotes no alternatives to policy SP10, going on to state that: 

“The NPPF has a technical guidance that provides the detailed 

guidance on flood risk. As this was published post the Local Plan 

policy approach being developed it is now considered that this will 

need to be revised to avoid duplication of the technical guidance 

but to retain the local aspects of flood management including the 

reference to the proposed flood relief channel. As this is a technical 

policy it is not considered appropriate to develop alternative policy 

approaches.” 


effect. This policy was considered to result in significantly beneficial effects on a number of 

IP/MfE in ER04 Water Resources and Management and adverse affects recorded against ER09 

Historic Environment and Archaeology due to the potential development displacement. 


effect. Similar to SP09, in terms of its impact on RSF 6 Vibrant Communities, the assessment 


team saw a positive effect due in part to the outcome of focusing development in the urban 

centres. A similar positive effect was noted in terms of RSF 15 and RSF 18 both objectives that 

relate to climate change adaption. 

16.258 To summarise, Policy SP10 largely refers to the implementation of the sequential and 

exception tests in PPS25 that has now been replaced by NPPF Technical Guidance. 

Overall Policy Conclusions 

16.259 The overall conclusion of SEA as summarised in Appendix 4 is that all accepted policies taken 

as whole will if implemented over the life of the Local Plan (2026) result in a neutral effect. 

Individually, Policies LP01, LP02, LP04, LP05, LP08 and SP05 all result in adverse affects on a 

number of environmental receptors. One Policy SP09 results in a positive effect. It is 

therefore considered that the Local Plan as it is currently drafted is relatively benign. 

16.260 The overall conclusion of SA as summarised in Appendix 3 is that is that all accepted policies 

taken as whole will if implemented over the life of the Local Plan (2026) ) result in a beneficial 

effect. This difference between the SEA and SA is to be expected in that the SA considers the 

wider social and economic objectives that are integral to a sustainability appraisal. Whilst is 

not considered to be acting adversely against sustainable development objectives, neither is 

it acting significantly positive in favour of sustainable development objectives in spite of its 

position within the development framework. It is therefore considered that the Local Plan as 

it is currently drafted is relatively benign. 



Section 17. 

Data Used 

Data, Data Uncertainty and Risks 

17.1 Since 2004, the Council has been collecting, analysing and presenting a comprehensive set of 

data comprehensively covering social, economic and environment issues the borough in the 

form of its State of Runnymede Reports 79 . Considerable amounts of data in the form of 

published documents, data and reports have been used in order to carryout and conclude the 

SEA and SA, (Appendix 11). Of particular note is the data used in terms of the HRA (Appendix 

8 and 9), data used to build the Constraints Map (Appendix 13) and the Air Quality 

Assessment (Appendix 14), including that used to support the Level 5 assessment of 

alternatives (Appendix 7). All sources used have been have been captured and are reported 

upon in Appendix 11. Sadly this inevitably is not an exhaustive list as the body of data and 

knowledge used is wider. 

Data Uncertainty 

17.2 The formulation of policies is rarely straightforward and their actual outcomes invariably 

include a number of levels of uncertainty. Equally, carrying out the SA and SEA assessment 

being carried out across such a wide range of environmental receptors and sustainability 

objectives. The following levels of uncertainty were taken into account during the assessment 

and appraisal process. They should therefore also be taken into account when reading the 

results presented in this SAR: 

 

 

 

Scientific uncertainties – variability in data and collection measures will always exist to 

a greater or lesser degree. 

Natural variability – there is often considerable natural variability in sustainability 

issues, for example the weather and people’s actions. 

Lack of precision – environmental, social and economic issues can be difficult to 

quantify or measure with a high degree of accuracy. 

 

Data Risks 

General uncertainty – follows from the lack of detail about the precise implementation 

that comes with a ‘broad‐brush’ approach taken in the Local Plan, and as required in a 

strategic assessment, it is difficult to make assessments to a high degree of detail. 

17.3 Inevitably relying on the uncertain or incomplete data in support of conclusions reached in 

this SAR has required additional research and professional judgement to assist in reducing the 

uncertainty, but it sadly cannot completely eliminate it. Where it has not been possible to 

resolve such uncertainty and where it was considered that risk to the environmental 

remained as was the case in terms of the HRA on policies LP01, LP02 and LP08, a 

precautionary approach has been taken. This approach has also been adopted in the scoring 

schema. 

79 



Section 18. 

Plan Uncertainty and Risks 

18.1 As with all planning there are inherent uncertainty and risks. The economic downturn has 

placed a particular level of uncertainty and risk on the plan making regime – are plans 

planning proactively for growth, or reactively for contraction. Changes to government policy 

such as that driven by the national guidance (NPPF), and others mean that plans such as the 

Council’s Local Plan will be produced in uncertainty; however, they must continue to be 

produced. 

18.2 Housing numbers are considered to be a key component of the Local Plan. Runnymede’s 

Local Plan places delivery of all its planned housing within the confines of a single policy ‐ 

LP08 DERA. As a result of its location and the nature of the policy, the Local Plan has been 

subjected to a HRA. It will only proceed to final submission following a conclusion of no likely 

significant effect in either the integrity of the Thames Basin Heaths SPA and Thursley, Ash, 

Pirbright and Chobham SAC. The Council’s HRA has considered three Local Plan policies – 

LP01, LP02 and LP08 and their ability alone or in combination with other plans or projects to 

adversely affect the integrity of two European site – Thames Basin Heaths SPA and Thursley, 

Ash, Pirbright and Chobham SAC. Based on the information available but against the advice of 

Natural England, the Council was able to ascertain that implementation of policies LP01, LP02 

and LP03 would not alone or in combination with other plans or projects adversely affect the 

integrity of either European site. 

18.3 The wider economic climate continues to remain flat, and as such could have profound 

effects on the deliverability of housing and infrastructure in the early part of the plan and 

could mean an early review in approach to the plan. The Local Plan sets out these plan risks 

and contingencies under each of the policy sections within the document. 



Section 19. 

Monitoring 

19.1 The SEA regulations require that significant environmental effects of the Local Plan be 

monitored. It is expected that this will be the same for the SA. The Council intends to 

continue to update and issue its State of Runnymede Report annually (See: Appendix 11). 

This monitoring regime will be aligned with the monitoring suggestions presented in the 

Tables at the end of each environmental receptor sections. 

19.2 Gaps in the environmental receptor baselines are expected to take some time to fill. To assist 

and effectively close the assessment loop, it is suggested that the Council use the SAR as a 

basis for screening certain types of developments in terms of EIA regulations 80 . The Council 

can then utilise the higher resolution data supplied in support of the screening and or the 

environmental statements to provide the SEA monitoring, this is considered a prudent and 

efficient use of the regulations. 

19.3 Monitoring measures devised will be based upon those described in each of the relevant 

sections. All monitoring measures will be considered against the environmental receptors and 

sustainability objectives and set against the following criteria: 

 

 

 

 

 

Clearly established attributes that need to be monitored; 

Clearly established performance indicator for the attribute; 

Ability to measure performance indicators; 

Readily available data; and, 

A clear responsibility for collecting the data. 

19.4 Only issues or factors identified as being significantly affected by implementation of the Local 

Plan will be monitored in detail by the Council. Issues and factors which either the SA or the 

SEA consider not significantly affected by the Plan will only be measured by indicators that 

exists within the State of Runnymede Report / Annual Monitoring Report. However, due to its 

coverage, the State of Runnymede Report including the use of the EIA regime it is considered 

that the ability to monitor ‘unforeseen effects’ as required by the SEA Directive is adequately 

covered. 

19.5 A problem might arise if the quality of data required for monitoring significant effects is not 

available to the Council through submitted EIA development ES’s or either the State of 

Runnymede Report / Annual Monitoring Report. Where the collection of this data proves to 

be financially or technically restrictive, the Council will adopt a risk based approach to take 

full account for any absence. 

19.6 It is also anticipated that the monitoring regime of the Local Plan specified by this SAR will 

evolve following adoption of the Local Plan. 

80 The Town and Country Planning (Environmental Impact Assessment) Regulations 2011 that implement the requirements of 

Directive 85/337/EEC (as amended). 



Section 20. 

Next Stages 

20.1 A key function of the SEA framework is to assess all likely significant effects pursuant to the 

requirements of the SEA Regulations during the development and production of the Local 

Plan. This SAR, its non‐technical summary and its supporting appendices, document the 

levels of assessment carried out by the Council during the production and development of 

the Local Plan and will be submitted for consultation alongside the Council’s Local Plan. 

20.2 Over the coming months following this consultation and leading up to the formal submission 

for examination to the Secretary of State of the Council’s Local Plan, the Council’s in‐house 

Impact Assessment team will continue to update and refine this SAR. This is intended to 

ensure that the final stage of SEA process is fully and effectively integrated into the 

development and production of Local Plan. Formally, the SEA is has progressed to 

presentation Stage C (see: Table 95 below). During Stage C, the SAR will be finalised to 

accompany the submitted Local Plan early in 2013. 

Table 95 – SEA Stages B and C 

Stage C: Preparing the Environmental Report 

C1: Finalising the SEA and ER Report including the a non‐technical summary (NTS) 


i Estimated traffic flows for 2006 – ADT of 12300 for A317 Eastworth Road 


February 08, 2013

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