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

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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. Page | 204 Runnymede BC FINAL Sustainability Appraisal Report – Feb 2013
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. Page | 205 Runnymede BC FINAL Sustainability Appraisal Report – Feb 2013
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2013 DRAFT Sustainability Appraisal
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Draft Sustainability Appraisal Repo
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CONTENTS List of Tables ...........
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SECTION 8. [ER04] WATER RESOURCES A
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Local Plan Policy Context Conclusio
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Table 59 - ER04 - Water Resource an
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Commenting on this SAR Report Pleas
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Glossary of terms TERM Baseline Dat
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Section 1. Section 1 Introduction t
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Section 16 Conclusions 1.17 This se
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Section 2. Legal and Statutory Requ
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effects on the environment of certa
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Box 1 ‐ Elements of an Environmen
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Table 2 - Assessment Chapter Compon
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Date Key stage in SA/SEA Effect on
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Section 3. Introduction Framework a
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3.16 Monitoring reports will be aug
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Figure 4 - Compatibility between SA
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Table 6 - Meeting the requirements
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Environmental Receptor ER03 Land an
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the SEA. Each policy and its altern
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Table 10 - Additive and interactive
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3.43 In terms of environment, asses
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Section 4. Assessment of RBC’s Lo
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LP Objective Strategic Policy Objec
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No. Policy LP04 Development in Egha
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Location Policy 2 (LP02) - Housing
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4.41 The approach in Policy LP04 ac
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4.56 Policy LP08 seeks to provide
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4.73 To summarise, Policy SP03 prom
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4.90 However, the policy appears to
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Policy and Alternatives Considered
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Section 5. Introduction [ER01] Natu
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Protecting and enhancing valued lan
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Sites of International Importance a
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SSSI Area (ha) Reason for designati
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Evolution of Baseline in Absence of
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scenario) will have a similar impac
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5.63 LP07 overall in the SA conside
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Policy SP08 - Employment Developmen
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Cumulative Effects Assessment 5.100
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Section 6. Introduction [ER02] Welf
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European Nitrates Directive (1991)
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Figure 8 ‐ Projected Population i
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for community gain. Across the rang
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alternative to leave the site in th
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the policy requires all development
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6.96 With regard to WHWB5 (opportun
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Section 7. Introduction [ER03] Land
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County 7.12 Surrey Waste Plan (2008
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Evolution of Baseline condition in
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through the appropriate re‐use of
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Policy SP07: Thames Basin Heaths Sp
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Table 52 - Suggested Monitoring of
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Section 8. Introduction [ER04] Wate
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Local 8.11 Strategic Flood Risk Ass
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Figure 11 - Source Protection Zone
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8.32 An increase in population with
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the final development schemes. Ther
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encourages proposals that enhance t
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Cumulative Effects Assessment 8.87
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Section 9. Introduction [ER05] Air
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9.11 The Air Quality Strategy for E
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to 23 μg/m 3 in 2011 55 . It is as
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9.45 LP02 overall in the SA conside
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9.67 The overall conclusion of the
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Policy SP08: Employment Development
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and from ER06 Climate change. Syner
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The dispersion software used to mod
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not been approved yet and can be re
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Table 66 - Suggested Monitoring of
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Section 11. Introduction [ER06] Cli
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11.8 The Directive requires buildin
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Local to reduce distance travelled
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11.36 By the 2050s, it has been pro
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is a reflection of the scale of dev
Page 153 and 154: the receptors, but the impact of th
Page 155 and 156: 11.83 SP06 has a neutral effect on
Page 157 and 158: No. Policy Impact 66 Location Polic
Page 159 and 160: Suggested Monitoring Regime Table 7
Page 161 and 162: Section 12. Introduction [ER07] Mat
Page 163 and 164: 12.14 With regard to waste manageme
Page 165 and 166: (MEW2). However, the impact is unce
Page 167 and 168: Policy SP06: Tourism, Recreation an
Page 169 and 170: Cumulative Effects Assessment 12.67
Page 171 and 172: Section 13. Introduction [ER08] Bui
Page 173 and 174: Runnymede Urban Area Character Appr
Page 175 and 176: 13.29 Having regard to the conclusi
Page 177 and 178: 13.52 Having regard to the conclusi
Page 179 and 180: Table 83 - Summary of Local Plan Po
Page 181 and 182: Section 14. Introduction [ER09] His
Page 183 and 184: Table 87 - ER09 Summary Key Environ
Page 185 and 186: whilst it also has a negative impac
Page 187 and 188: 14.53 LP07 overall in the SA consid
Page 189 and 190: 14.74 SP06 has an adverse effect on
Page 193 and 194: Section 15. Introduction [ER10] Lan
Page 195 and 196: 15.11 Soil Strategy for England (20
Page 197 and 198: whilst it also has a negative impac
Page 199 and 200: Policy SP01: Green Belt Areas 15.44
Page 203: Section 16. Introduction Conclusion
Page 207 and 208: covers the capacity to create oppor
Page 209 and 210: Provision of sustainable homes for
Page 211 and 212: 16.70 Policy LP03 and its two alter
Page 213 and 214: of urban developments and supportin
Page 215 and 216: of their natural beauty). Runnymede
Page 217 and 218: SEA and SA Conclusion of the Local
Page 219 and 220: the Core Strategy have identified s
Page 221 and 222: 16.154 The overall conclusion in th
Page 223 and 224: 16.173 The approach in LP07‐A1 is
Page 225 and 226: 16.191 Alternative SP02 ‐ A1 does
Page 227 and 228: 16.210 The overall conclusion of SE
Page 229 and 230: 16.232 The overall conclusion of SA
Page 231 and 232: team saw a positive effect due in p
Page 233 and 234: Section 17. Data Used Data, Data Un
Page 235 and 236: Section 18. Plan Uncertainty and Ri
Page 237 and 238: Section 19. Monitoring 19.1 The SEA
Page 239 and 240: Section 20. Next Stages 20.1 A key
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