runnymede sustainability appraisal of … sustainability appraisal of the issues and options ramboll...

Intended for

Runnymede Borough Council

Date

July, 2016

Project Number

UK15-23260

RUNNYMEDE SUSTAINABILITY APPRAISAL OF THE ISSUES AND OPTIONS

RUNNYMEDE SUSTAINABILITY APPRAISAL OF THE ISSUES AND OPTIONS

Ramboll 92, Avenue d'Auderghem 1040 Bruxelles T +32 02 737 96 80 F +32 02 737 9699 www.ramboll-management.be

Project No. UK1523260 Issue No. 01 Date 11/07/2016 Made by Emma Green / Emma Jones Checked by Bram Miller Approved by Bram Miller Made by:

Checked/Approved by:

This report has been prepared by Ramboll Environ with all reasonable skill, care and diligence, and taking account of the Services and the Terms agreed between Ramboll Environ and the Client. This report is confidential to the Client, and Ramboll Environ accepts no responsibility whatsoever to third parties to whom this report, or any part thereof, is made known, unless formally agreed by Ramboll Environ beforehand. Any such party relies upon the report at their own risk. Ramboll Environ disclaims any responsibility to the Client and others in respect of any matters outside the agreed scope of the Services.

SUSTAINABILITY APPRAISAL OF THE ISSUES AND OPTIONS Runnymede

Version Control Log Revision Date Made by Checked by Approved by Description

A 15/06/2016 EG/EJ BM BM Draft report

B 01/07/16 EG/EJ BM BM Draft report sent to client (UnQA’d

draft)

1 11/07/16 EG/EJ BM BM Report to client


CONTENTS

1. KEY MESSAGES 1 1.1 What is this report? 1 1.2 What has been assessed? 1 1.3 What were the results? 1 2. INTRODUCTION 3 2.1 Background 3 2.2 This report 3 2.3 Habitat Regulations Assessment 3 2.4 Stages of the SA 3 2.5 ‘Runnymede 2035’ Local Plan 4 2.6 How to comment on the report 4 2.7 Next steps in the process 4 3. METHODOLOGY OF THE ISSUES AND OPTIONS

ASSESSMENT PROCESS 5 3.1 Introduction 5 3.2 Selecting / identifying reasonable alternatives 5 3.3 Assessing reasonable alternatives 5 4. ASSESSMENT RESULTS 9 4.1 Introduction 9 4.2 Spatial strategy 12 4.3 Thorpe village boundary options 19 4.4 Housing options 26 4.5 Economy and retail options 28 4.6 The built environment 31 4.7 The natural environment 34 4.8 Recreation, green space and leisure 36 4.9 Heritage 38 4.10 Transport and infrastructure 39 4.11 Flooding 41 ANNEXES AND APPENDICES

ANNEX 1 SCREENING OF THE ALTERNATIVE ISSUES AND OPTIONS SEPARATE APPENDICES: APPENDIX 1: SELECTION OF REASONABLE ALTERNATIVES APPENDIX 2: SITE ASSESSMENTS


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SUSTAINABILITY APPRAISAL OF THE ISSUES AND OPTIONS

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1. KEY MESSAGES

1.1 What is this report?

• The Runnymede Local Plan is being subject to a Sustainability Appraisal (SA) to assess its effects on important sustainability issues within the Borough.

• This report sets out an assessment of the Runnymede Issues, Options and Preferred Approaches document (July 2016). The results of this assessment will be used by the Council when drafting the next stages of the Local Plan.

1.2 What has been assessed?

• As part of the SA process reasonable alternatives need to be defined and assessed. This includes defining and assessing reasonable alternative sites for development and reasonable alternative approaches to the spatial strategy and other planning issues.

• There is no generally accepted definition of what constitutes reasonable and it is up to the Council to decide what is reasonable.

• All of the sites that are deemed reasonable by the Council have been assessed. Appendix 1 sets out which sites are considered reasonable and why.

• The Council has also developed a number of alternatives approaches to planning issues (spatial strategy; housing; economy and retail; built environment; natural environment; recreation, green space and leisure; heritage; transport and infrastructure; and flooding). The reasoning behind the choice of reasonable alternatives for these issues is also set out in Appendix 1;

• The approach to the assessment of the alternative approaches has been set out in sections 3.1 to 3.9 in this report. Not all approaches have been assessed or assessed against the full range of sustainability topics. This is because they will have effects on only some of the sustainability issues or because alternatives have not been suggested (and the purpose of this stage of the assessment is to help the council decide between alternatives).

1.3 What were the results?

• The results of the assessments are shown in assessment tables which show how each site / alternative approach performs in relation to different sustainability objectives.

• Significant negative effects are shown in red and significant positive effects are shown in green.

• A significant negative effect does not mean that a particular site / approach should not be taken forward by the Council and a significant positive effect does not mean that the site / approach should automatically be taken forward.

• The results of the site assessments are shown in Appendix 2 and a summary is included in section 4.1. Generally, the preferred sites performed comparatively well (compared to the alternative sites suggested). In particular the preferred sites performed comparatively well in relation to Green Belt issues as the preferred sites are either Residual Land Parcels (where development has been shown to be more acceptable to Green Belt purposes); or are within settlement limits and are designated as housing reserve sites in the Runnymede Local Plan 2001 (as saved) and as such would be considered suitable for residential development. In some cases the preferred sites will have potentially negative or uncertain effects on the SA objectives and these are outlined in Appendix 2.

• The results of the assessment of the alternative approaches is shown in Section 4. Generally, the Council’s preferred approaches have performed comparatively well. However, in some


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cases the preferred approaches will have potentially negative or uncertain effects on the SA objectives and these are outlined in Section 4.

• The Council can use the results of the assessment to choose planning approaches and a portfolio of sites that performs the most positively, and can use the knowledge gained to ensure that mitigation measures are put in place to reduce any negative impacts identified.

• For more detail on the performance of a particular site / approach please see Appendix 2 (for site assessments) and Section 4 (for the assessment of potential approaches).


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2. INTRODUCTION

2.1 Background

The preparation of the Runnymede 2035 Local Plan is being subject to an integrated sustainabil-ity appraisal (SA) and strategic environmental assessment (SEA) in line with the requirements of Statutory Instrument 2004 No. 1633: The Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA Regulations). In English planning practice this combined assessment is referred to as a Sustainability Appraisal (SA). The SA is being carried out by Ramboll Environ using a team of consultants experienced in strategic appraisal of local authority spatial planning documents. The purpose of the SA is to promote sustainable development by integrating sustain-ability considerations into the plan making process at all relevant stages including when consider-ing alternative approaches to developing the plan (the issues and options stage).

2.2 This report

This document presents the findings of the SA of the Runnymede 2035 Local Plan, Issues, Op-tions and Preferred Approaches document (July, 2016). The information in this report will be used by the Council when drafting the next stages of the Local Plan.

This report does not constitute an environmental report (in the English planning system called a SA report) under the SEA regulations. At the issues and options stage it is good practice to pro-duce fairly brief reports which can then be developed into the formal (regulation compliant) SA report at a draft plan stage. Please also note that further assessment of alternatives is also likely to be carried out as part of the assessment of the draft plan.

2.3 Habitat Regulations Assessment

Please note that this report does not constitute a Habitat Regulations Assessment (HRA) screen-ing report. A HRA screening report has been produced1 and has concluded that there will be no adverse effects to Thursley, Ash, Pirbright & Chobham SAC, Windsor Forest and Great Park SPA and the South West London Waterbodies SPA/Ramsar (one unit Thorpe Gravel Pits 1 and sup-porting habitats).IN relation to the Thames Basin Heaths SPA and SANG provision it is considered that there would be no risk of an adverse effect on the Thames Basin Heaths SPA since the policy developed under Preferred Approach NE2 would require the Council to either meet the SANGS provision from alternative strategic SANGS, meet the shortfall by releasing development sites that can provide their own SANGS, or revise its overall housing allocation to reflect that for which SANGS could definitely be provided. Therefore it can be concluded that there will be no adverse effects to Thames Basin Heaths SPA.

2.4 Stages of the SA

There are a number of stages to SA and these are shown below:

Completed stages: An SA scoping report was produced in September 2014. From all of the infor-mation collected, an SA framework, or set of sustainability objectives, was developed, against which the various components of the plans will be appraised. This SA framework has been amended taking into account the views of consultees;

• This stage: The production of an issues and options assessment briefing paper (this report) which outlines the results of the SA of the ‘Runnymede 2035’ Local Plan (formal Regulation 18 consultation);

• Future stages: The appraisal of the draft plan (likely to be later in 2016) and amendments to the SA to take into account the results of consultation (likely to be early 2017).

1 Appropriate Assessment Report Pursuant to Regulation 102 (1) of the Habitats Regulations 2010 (Habitats Regulations) on the Likely Significant Effects of Runnymede Borough Council’s Local Plan 2035 Issues, Options and Preferred Approaches Document. June 2016 HRA Screening and Appropriate Assessment Report


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2.5 ‘Runnymede 2035’ Local Plan

The Borough Council’s current Local Plan – The Runnymede Local Plan (Second Alteration) was adopted in 2001. The Council is now required to produce a new Local Plan by early 2017, which will plan for and manage development up to 2035.

It is being prepared to help further guide planning decisions in the area and once adopted, will contain all policies (both strategic policies and more detailed Development Management level po-lices), and all land use allocations necessary to guide development in the Borough up to 2035. On adoption, it is intended that the plan will replace the remaining saved policies of the 2001 Runnymede Borough Local Plan.

The Issues and Options consultation is the early part of the Local Plan making process and sets out the issues that are facing Runnymede over the next 20 years, the potential options for deal-ing with those issues and based on those considerations, what the Council thinks the preferred strategy should be in each case. The consultation fulfils the requirements of Regulation 18 of the Local Planning Regulations 2012.

2.6 How to comment on the report

This report is being published for consultation and we would welcome comments on the method-ology used and results of the assessment.

This statutory consultation is open until Wednesday 17th August. We are unable to accept anony-mous representations and representations must be made in writing. We would like you to send us your views electronically if possible. You can complete the questionnaire on our website or down-load a copy of the questionnaire to complete and email back to us at [email protected]. If you cannot do this, please request and return a printed copy of the questionnaire to us. Please clearly mark any additional sheets with your name and ensure that you confirm which part of the document you are referring to. Please send your completed questionnaire to: The Policy and Strategy team, Runnymede Borough Council, Civic Centre, Station Road, Addlestone, KT15 2AH.’

2.7 Next steps in the process

The next step in the preparation of the Local Plan for Runnymede Borough will be the preparation of a draft plan. This is currently scheduled to be produced later in 2016. At this point in the pro-cess the formal SA report will be produced and will be consulted on with the public and other stakeholders at the same time as the draft plan.

mailto:[email protected]

mailto:[email protected]


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3. METHODOLOGY OF THE ISSUES AND OPTIONS ASSESS-MENT PROCESS

3.1 Introduction

This stage involves appraisal of the issues and options against the SA framework, taking into ac-count the evidence base. The SEA Regulations make it clear that reasonable alternatives to a plan should be identified and assessed. In addition to this, the SA report should include an out-line of the reasons for “selecting the alternatives dealt with” (SCHEDULE 2, Regulation 12(3)).

3.2 Selecting / identifying reasonable alternatives

The SEA Regulations require that the SA report identifies the reasons for selecting the alterna-tives tested in light of the others available (SEA Regulations Schedule 2 (8)). In SA practice this is usually understood as having two meanings:

1. Discuss why it was ‘reasonable’ to select the alternatives that were developed to be tested; and

2. Discuss why the preferred approach was selected in light of the SA of alternatives.

There is no generally accepted definition of what constitutes reasonable and it is up to the Coun-cil to decide what sites and strategy approaches are reasonable. In the interests of putting in place a clear audit trail for the SA, Appendix 1 outlines in detail why reasonable alternatives were selected by the Council (both for sites and the strategic approaches considered).

3.3 Assessing reasonable alternatives

3.3.1 What has been assessed?

Both site allocations and strategic issues / alternative approaches have been assessed. All the sites that have been defined as reasonable (as highlighted above and discussed in Appendix 1) have been assessed.

However, the information presented by the Council in the Issues, Options and Preferred Ap-proaches consultation document is more than just potential development sites. It is a mix of op-tions, potential approaches and sites. Sites can be assessed against the SA framework with a higher level of certainty compared with the more generic potential approaches. It is not possible or useful to assess the effects of potential approaches against every element of the SA frame-work, either because they will have effects on only some of the sustainability objectives or be-cause alternatives have not been suggested (and the purpose of this stage of the assessment is to help the council determine between alternatives). It is important that the SA process is fo-cused on where it can make a positive difference and add value to the decision making process (which at this stage is focused on choosing between alternatives). Therefore each potential ap-proach has been assessed slightly differently and some of them have not been assessed. How-ever, please note that all policies developed as part of the Draft Plan will be assessed as part of the next stage of the SA. To determine whether the approaches are likely to have an effect on the SA objectives (and therefore whether an assessment is needed), a screening table has been used. This is shown in Annex A of this report. Please also see Section 4 which sets out the way that each approach has been assessed.

3.3.2 How is sustainability defined?

The scoping stage of the SA (as referred to in Section 1.3) resulted in the production of a SA framework which will be used to test the sustainability of the plan. This is shown in Table 2.1. The SA framework sets out those factors that are considered to be important in defining and test-ing sustainability for this plan. Some amendments were made to the SA framework following consultation in 2014 and these changes have been shown in grey highlighting.


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Please note that the SA makes an assessment against the future baseline (or a without the plan scenario). In such a scenario development is still likely to take place but without the benefit of Local Plan policies guiding it in a more sustainable direction. In addition, the SA objectives are geared towards helping the Council steer development away from sensitive areas and promote development that is more sustainable. This means that promoting development will not neces-sarily score negatively. For example for a site that avoids designated ecological sites it is per-fectly possible for this site / strategy to score positively with regard to SA objective 1 (biodiver-sity).

Table 3.1: Proposed SA framework


Proposed SA Objectives Proposed decision-aiding criteria

SA Objective 1: To conserve and enhance biodiversity, habitats and species

Will it avoid potential impacts of development on designated sites? Will it avoid net loss of and achieve enhancement of ecological resources and services? Will it avoid habitat fragmentation? Will it lead to development which incorporates biodiversity into the design e.g. linking green corridors, incorporation of habitats etc helping to reduce the future effects of climate change on biodiversity?

SA Objective 2: to protect and improve the health and well-be-ing of the population and reduce inequalities in health

Will it help to address pockets of deprivation and child poverty? Will it improve access to healthcare? Will it provide for the needs of an ageing population? Will it facilitate active lifestyles? Support local sustainable food production, including the provision of allotments and community gardening?

SA Objective 3: to protect soil and minerals resources

Will it ensure that mineral resources are not sterilised? Will it avoid environmental effects from mineral abstraction on sensitive receptors? Will it achieve efficiency in land use and avoid the development of greenfield land over the redevelopment of previously developed land and buildings? Will it minimise waste arisings and facilitate recycling?

SA Objective 4: to improve water quality and efficiency

Will it ensure developments are water efficient especially taking into account future climate change scenarios? Will it maximise beneficial re-use of contaminated land? Will it help to improve ground and surface water quality and meet the objective of achieving good status under the Water Framework Directive?

SA Objective 5: to increase resili-ence to climate change, including flood risk

Will it ensure that people, property and businesses are protected from flooding and guide development to the area of least flood risk? Will development incorporate SUDS? Will it lead to developments which are designed to be resilient to hotter, drier summers and warmer, wetter winters including more resilience to flooding?


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SA Objective 6: to reduce air and noise pollution

Will it ensure that development minimises exposure to poor air quality and noise pollution? Will it avoid contributing to congestion? Will it facilitate the incorporation of electric vehicle charging points into new developments or ensuring they can be retrofitted?

SA Objective 7: reduce green-house gas emissions

Will it ensure that new developments are designed to achieve high levels of energy efficiency? Will it prioritise access to good public transport and safe walking and cycling facilities infrastructure (including segregated cycle lanes), over facilities for private cars? Will it increase renewable energy generation? Will it achieve development that demonstrates sustainable design and construction including efficient use of materials?

SA Objective 8: to sustain eco-nomic growth and competitive-ness across the Borough

Will it support a dynamic and diverse economy including a dynamic rural economy? Will it stimulate economic growth in deprived areas? Will it support all businesses and business sectors and low environmental impact business sectors in particular? Will it contribute to the provision of opportunities for employment and improvements in educational attainment and skills development?

SA Objective 9: to ensure the provision of high quality, sus-tainable constructed and afforda-ble homes and necessary com-munity infrastructure.

Will it provide viable and deliverable good quality and affordable housing to meet identified needs? Will it ensure the delivery of necessary community infrastructure and access to a full range of community services?

SA Objective 10: to protect and enhance the Borough’s historic assets

Will it ensure that development avoids adverse effects on heritage assets, archaeology and Conservation Areas? Will it ensure that development is well-designed and is well- related to the surrounding townscape?

SA Objective 11: to protect and enhance open space and the landscape character of the Bor-ough

Will it protect and enhance landscape character? Will it ensure the quality of and provision of suitable open space, where need is identified?

3.3.3 How does the SA define significance

As part of the SA it is necessary to outline likely significant effects. To do this in as clear and transparent way as possible, a set of significance criteria has been defined for the assessment and every impact has been scored accordingly. The significance criteria that have been used are set out in Table 2.2.


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Table 3.2: Significance criteria

Table 3.2: Significance criteria

Score Description Symbol

Significant positive impact The option strongly supports the achievement of the SA Objective and has a major positive effect with relation to characteristics of the effect and the sensitivity of the receptors

++

Minor positive impact The option generally supports the achievement of the SA Objective and has a minor positive effect with relation to characteristics of the effect and the sensitivity of the receptors

+

Neutral The option does not have an effect on the achievement of the SA Objective

0

Minor negative impact The option conflicts with the achievement of the SA Objective and has a negative effect with relation to characteristics of the effect and the sensitivity of the receptors

-

Significant negative impact The option conflicts with the SA Objective and has a negative effect with relation to characteristics of the effect and the sensitivity of the receptors. In addition the future baseline indicates a worsening trend in the absence of intervention

- -

Uncertain It is unclear whether there is the potential for a negative or positive effect on the SA Objective

?

3.3.4 Cumulative effects

To comply with the SEA regulations it is necessary to identify any likely significant cumulative ef-fects of the plan. A detailed cumulative effects assessment will be carried out at the draft plan stage and reported as part of the formal SA report.

3.3.5 Difficulties encountered in the assessment

The main difficulty encountered in the assessment was the lack of detail apparent in the potential approaches (please note that at this stage in the planning process it is entirely expected that the alternative approaches do not contain detailed expression) which leads to a fairly broad brush as-sessment of this element of the issues and options assessment. This was dealt with by focusing the assessment on providing a general indication of the relative performance of the potential ap-proaches.


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4. ASSESSMENT RESULTS

4.1 Introduction

The results of the site assessments are shown in Appendix 2. The results have been presented in assessment tables, which enables readers to clearly see performance against the SA objectives.

The key constraints within the District are Green Belt, flooding and biodiversity (with regard to the effect of Natura 2000 sites and other issues). With regard to Green Belt issues the preferred sites are either Residual Land Parcels (where development has been shown to be more accepta-ble to Green Belt purposes); or are within settlement limits and are designated as housing re-serve sites in the Runnymede Local Plan 2001 (as saved) and as such would be considered suita-ble for residential development. Other alternative sites have performed less well as they are within the Green Belt and the sites are not considered to be (or totally to be) previously devel-oped land. This would mean that development would be unacceptable to Green Belt purposes and would require a review of the Green Belt boundary to allow development to go ahead.

With regard to flooding, large areas of the Borough are subject to flood risk. However, all of the sites generally performed well with the majority in flood zone 1. The preferred sites also gener-ally performed well, with the majority of the sites being in flood zone 1. Three of the preferred sites (60, 255 and 256) are partly within flood zones 2 and 3. With sites 255 and 256 this is fairly minor areas of land. Larger parts of Site 60 is partially in zones 2, 3a and 3b. Flood zone 3b is an absolute constraint so this section would be left undeveloped and any development within zone 2 would need to pass the sequential test and if in zone 3a both the sequential and exception tests.

With regard to the impact on Natura 2000 sites one of the key issues is the effect on the Thames Basin Heaths Special Protection Area (TBHSPA). Many of the sites assessed (including the major-ity of the preferred sites) are within the 5km buffer zone of the TBHSPA meaning that Suitable Accessible Natural Greenspace (SANGs) would need to be provided if development were to go ahead.

SA relies on expert judgement, which is guided by knowledge of the likely effects of the plan, the baseline data available and responses and information provided by consultees and other stake-holders. A ‘precautionary approach’ is taken with the worst case scenario being reported in the case of any doubt about potential effects, and mitigation is suggested if there is any doubt as to the effect of the plan.

The assessment of the potential approaches is reported in this section of the report. The assess-ment results are set out in assessment tables showing the performance of the approaches against the relevant SA objectives. Please note that the Council’s preferred approach is high-lighted in grey in the tables. Due to the high level nature of the assessment at this stage mitiga-tion measures and enhancement measures have not been explicitly included in the tables. How-ever, some recommendations are given throughout the assessment of issues that need to be considered as policies are drafted.

The Council’s preferred approaches perform comparatively well (compared with the alternative approaches posed). However, there are some uncertain / negative effects recorded in relation to some of the preferred approaches as listed below:

• Spatial strategy approach SS3 (deliver development in urban areas and on previously developed sites in the Green Belt. Return Thorpe to settlement and release some of the Resultant Land Parcels). There are uncertainties attached to all of the spatial strategy approaches because of their high level nature. SS3 has an uncertain / minor negative effect against SA objective 1 (biodiversity), objective 3 (soil and minerals) and objective 11 (landscape character). It has an uncertain effect against objective 4 (water), objective 9 (provision of homes) and objective 10 (historic assets). Minor negative effects have been recorded against objective 5 (climate and flood risk) and objective 8 (economic growth). A


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mixed effect of uncertain/ minor positive has been recorded against SA objective 6 (air and noise) and objective 7 (greenhouse gas emissions) and a minor positive effect has been recorded against objective 2 (health and well-being). However, the preferred strategy performs well in comparison with the other strategies and it is felt that the preferred strategy is the most positive as it will focus as much development as can be sustainably managed in the Borough through a focus on development in urban areas, previously developed sites in the Green Belt and RLPs. Unsurprisingly the main tension is between the provision of homes and protecting the landscape character and Green Belt of the Borough with strategies that provide for a higher percentage of the OAN (SS5 - 7) scoring well against objective 9 (provision of homes) and poorly against objective 11 (landscape character). Strategies that provide for a lower percentage of OAN (SS1 – SS4) score less well against objective 9 (provision of homes) but potentially slightly better with regard to objective 11 (landscape character) (although it needs to be recognised that this unmet need will have to be met in neighbouring authorities which have similar constraints to development). Once it is clearer where any unmet need is likely to be located further work should be undertaken to understand its sustainability implications working in conjunction with neighbouring authorities.

• TH1-TH6 (Thorpe Boundary Options) have the potential to cause some negative effects if the changes in the village boundary led to development. However, the inclusion of an area as part of a boundary option does not mean that it has been allocated for development and an assumption cannot be made that development will occur on these areas in the foreseeable future;

• H2/01 (Minimum density policy, with bespoke densities in certain areas, i.e. ‘commuter hubs’ in line with developing Government policy) and BE1/01 (Include an overarching policy approach to enhancing Runnymede’s townscape and public realm including density guides) could lead to an uncertain effect on townscape character. The approach could lead to development which is of a higher density than the surrounding area, therefore, risking negative effects on this aspect of townscape. The Local Plan will need to ensure that high quality design is a key part of policy, taking into account aspects of the Runnymede Urban Character Appraisal;

• H4/03 (Meet the need for specialist accommodation in full – look at existing sites and make up the shortfall within the Resultant Land Parcels (at the expense of general housing)) will be positive with regard to meeting the needs of specialist populations but uncertain with regard to the effect on general affordability. There is a risk that this is done at the expense of general affordable housing and the correct balance will need to be struck as the approach is developed;

• F3/01 (To allow applicants an automatic pass of the sequential test for applications in flood zones 2 and 3a where sites are otherwise shown to be available, suitable (in Runnymede this would be sites put forward for development in the Urban Area or on previously developed land in the Green Belt) and achievable for development) could increase the risk of more people and businesses being affected by flooding. However, the Council has stated that it will remain committed to ensuring that sites proposed would continue to be safe in a flood event. Until further details are known this has been listed as a minor negative effect.

• F3/01 (see above) would help the Council meet the need for significantly increased housing supply and provision of more employment land. However, an uncertain effect has also been noted against SA objective 8 (sustain economic growth) as the cost to businesses of flooding is uncertain.

• There is not enough evidence to show what the effects of F4/02 (Do not issue article 4 directions to remove permitted development rights for minor extensions) would be, therefore


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an uncertain effect has been given. Further research is needed to ascertain the cumulative impact of minor developments on the flood risk.


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4.2 Spatial strategy


All of the alternative approaches have been assessed against the SA framework, albeit to a high level of detail. This is because at the spatial strategy level there is (as would be expected at this early stage in strategy development) little detail presented on potential locations of development (especially for options SS5, SS6 and SS7 – where additional Green Belt land may be released in currently unknown locations). The proposed vision and objectives of the plan have also been assessed and are included in the table below. Please see Appendix 1 for an explanation of the content of each alternative.

4.2.2 The results of the assessment

Table 4.1: Assessment of the spatial strategy approaches

Assessment of the spatial strategy approaches SA objective Impact of the approaches Commentary and comparison of options (including if appropri-

ate nature and spatial extent of potential impacts, probability, duration, frequency and reversibility)

V/O2 SS1 SS2 SS3 SS4 SS5 SS6 SS7


+ ?/- ?/- ?/- ?/- ?/- ?/- ?/- The vision and objectives score positively. The amount of land required within the Borough would increase from options SS1 to SS6, with the least amount of land within the Borough required for Option SS1 (but higher amounts of land required outside of the Borough – see below). All the options would focus development on urban areas and previously developed sites (meaning less risk to ecologically sensitive sites in the Borough). Options SS3 and SS4 would also utilise some of the Resultant Land Parcels (RLPs) which have some ecological sensitivities and options SS5, SS6 and SS7 would utilise the RLPs and increasing amounts of additional Green Belt land (in unknown locations). However, it must be recognised that any unmet housing need would have to be sought in neighbouring authority areas following Duty to Co-operate discussions and there is a risk that agreement to take unmet needs will not be met. If some of the Borough’s needs are accommodated in neighbouring authorities, this could potentially cause ecological

2 This refers to the proposed vision and objectives of the Local Plan


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issues wherever development takes place (and all neighbouring authorities are similarly constrained). However, the potential locations of this development are an unknown. All of the approaches would require the provision of additional Suitable Alternative Natural Greenspace (SANGS) solutions. Some of the options (Option SS2, SS3, SS5, SS6 and SS7) would return Thorpe to settlement but this is only likely to result in a small number (less than 5 per annum) new houses so this is not seen as a significant issue (please also see the assessment of the Thorpe Boundary options). In conclusion, the effects of all of the approaches have some level of uncertainty attached to them but with the potential to score negatively. However, it is felt that the preferred strategy is the most positive as it will focus as much development as can be sustainably managed in the Borough through a focus on development in urban areas, previously developed sites in the Green Belt and RLPs.

SA Objective 2: To protect and improve the health and well-be-ing of the population and reduce inequalities in health

+ - - + + +/- +/- +/- The vision and objectives score positively. The higher the level of objectively assessed need (OAN) that can be met within the Borough the more positive the strategy will be for access to services as people will be able to access the services they need in a more sustainable way and the higher the level of development the more viable services will be within the Borough. Please see the assessment against SA9 for a more detailed discussion on OAN. However, the higher the level of development within the Borough the more green space is likely to be developed on with potential secondary effects on people’s health and well-being. On balance it is felt that the preferred approach is the most positive as it can meet up to 82% of the OAN but will not result in additional development on Green Belt land (additional to the RLPs).


+ ?/- ?/- ?/- ?/- ?/- ?/- ?/- As with SA objective 1, the amount of land within the Borough to be affected will increase with the options with greenfield land take increasing. Options SS3- SS7 would utilise some of the RLPs but these generally do not coincide with mineral safeguarding areas. Options SS5, SS6 and SS7 would also utilise increasing amounts of additional Green Belt land (in unknown locations) which would increase the amount of greenfield land take and could also


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potentially conflict with mineral development. Please also see assessment against SA objective 1 in relation to development outside of the Borough and the fact that all of council areas around Runnymede are similarly constrained. Whether development minimises waste arisings and facilitates recycling (a SA sub objective of objective 3) is dependent on how development is implemented so this is unclear at this stage. In conclusion, the effects of all of the approaches have some level of uncertainty attached to them but with the potential to score negatively. However, it is felt that the preferred strategy is the most positive as it will focus as much development as can be sustainably managed in the Borough through a focus on development in urban areas, previously developed sites in the Green Belt and RLPs.

SA Objective 4: to improve water quality and efficiency?

+ ? ? ? ? ? ? ? The vision and objectives score positively. This is dependent on how development is implemented, therefore the effects are uncertain at this stage. However, it should be recognised that effects on issues such as water use within the Borough will increase as the housing numbers increase. However, it must be recognised that any unmet housing need would have to be sought in neighbouring authority areas following Duty to Co-operate discussions and there is a risk that agreement to take unmet needs will not be met. If some of the Borough’s needs are accommodated in neighbouring authorities, water use will increase in line with the quantum of development. Policies within the Local Plan on sustainable construction are likely to mitigate these effects but this will be assessed and reported in the formal SA report.

SA Objective 5: to increase resili-ence to climate change, including flood risk

+ - - - - - - - The vision and objectives score positively. Whether development incorporates SUDS and are more resilient to climate change (SA sub objectives of objective 5) is dependent on how development is implemented so this is unclear at this stage. With regard to directing development towards areas with the least flood risk, all of the approaches would pose a risk that properties are subject to flood risk as the large parts of the Borough’s urban areas (especially Chertsey and Egham) are subject to high risks of flooding. There is also a likelihood that SS5, SS6 and SS7 (which would


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increase levels of development in the Green Belt in unknown locations) would result in development in areas at risk from flooding. However, adjacent authorities are also subject to similar levels of flood risk (this area of the country is the largest area of undefended floodplain in England) so in SS1 and SS2 which meet very low levels of the OAN there would also be a risk. In conclusion, the effects of all of the approaches have some level of uncertainty attached to them but it is felt that the preferred strategy is the most positive as it will focus as much development as can be sustainably managed in the Borough through a focus on development in urban areas, previously developed sites in the Green Belt and RLPs (and in generally low risk flood areas).


+ +/? +/? +/? +/? +/? +/? +/? The vision and objectives score positively. All of the strategy approaches will be positive in that they will focus development in the urban areas and / or in the RLPs, most of which lie adjacent to the existing urban areas and mainly those which sit higher in the centres hierarchy (or in the case of Longcross can be made to be self-sustaining). This will be positive in relation to facilitating more sustainable forms of transport and reducing the need to travel which will have secondary positive effects in relation to air and noise pollution. There is a possibility that SS5, SS6 and SS7 (which would increase levels of development in the Green Belt in unknown locations) could increase the need to travel. However, options which would seek higher levels of OAN outside the Borough are also likely to be located in areas which would do the same. Development in the urban areas and RLPs could also be subject to air and noise pollution and this would affect all the potential approaches. In conclusion, the effects of all of the approaches have some level of uncertainty attached to them but it is felt that the preferred strategy is the most positive as it will focus as much development as can be sustainably managed in the Borough through a focus on development in urban areas, previously developed sites in the Green Belt and RLPs.


+ +/? +/? +/? +/? +/? +/? +/? The vision and objectives score positively.


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Whether development achieves high levels of energy efficiency, increases renewable energy generation and demonstrates sustainable design and construction principles (SA sub objectives of objective 7) is dependent on how development is implemented so this is unclear at this stage. With regard to access to more sustainable forms of transport (and therefore, secondary effects on greenhouse gas emissions) please see the assessment against SA objective 6.


+ - - - - - - - The vision and objectives score positively. SS1 would lead to a deficit of up to 41,000sqm industrial floorspace, specifically for storage and distribution uses. SS2 - a deficit of 42,000sqm; SS3 and SS4 – a deficit of 87,000sqm; SS5 - a deficit of up to 106,000sqm; SS6 - 121,000sqm; and SS7 - 250,000sqm. There may be opportunities to deliver mixed use developments at some of the RLPs which could incorporate an element of storage & distribution if suitable and viable for this use, but it is likely that Runnymede will not be able to meet its employment needs under any of the scenario’s. The ability of Runnymede to deliver its employments needs will be dependent on neighbouring authorities in the FEA and there is a risk that agreement to take unmet employment needs will not be reached. All of the options are therefore negative in this regard.

SA Objective 9: to ensure the provision of high quality, sustain-able constructed and affordable homes and necessary community infrastructure.

+ ? ? ? ? ? ++ ++ The vision and objectives score positively. Whether development achieves the delivery of necessary infrastructure and access to services (an SA sub objective of objective 9) is dependent on how development is implemented so this is unclear at this stage. With regard to meeting identified need for housing, the following figures are relevant. SS1 – level of unmet need would be between 286 to 385 dwellings per year; SS2 - 283 to 383 dwellings per year; SS3 – 83 to 233 dwellings per year; SS4 – 86 to 235 dwellings per year; SS5 – 0 to 69 dwellings per year; SS6 and SS7 would enable Runnymede to fully meet the OAN within the Borough. Any unmet housing need would have to be sought in neighbouring authority


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areas following Duty to Cooperate discussions and there is a risk that agreement to take unmet needs will not be reached. All of the options (apart from SS6 and SS&) are therefore uncertain in this regard.


+ ? ? ? ? ? ? ? The vision and objectives score positively. There is a risk that all of the strategy approaches could have negative effects on townscape and historic assets as they will focus development in the urban areas (with risks that development would affect conservation areas and listed buildings) and in the RLPs (some of which will affect listed buildings and Areas of High Archaeological Potential). However, the effect will be dependent on how development is implemented and this is uncertain at the current time.


+ 0 0 -/? -/? - - - - - - The vision and objectives score positively. All of the options would result in development in the Green Belt and this is inevitable given the nature of the Green Belt in Runnymede and the demand for housing. SS3 and SS4 would focus development in urban areas, previously developed sites in the Green Belt and RLPs. The Council’s Strategic Review of the Green Belt (2014) found that RLPs either do not meet or only weakly meet Green Belt purposes as set out in the NPPF. Therefore, development on these sites and the previously developed sites in the Green Belt (dependent on how it is implemented) should be more acceptable than other sites within the Green Belt. However, in recognition that this still represents development in open countryside (and there is likely to be effects on Green Belt and landscape) these approaches have been scored as minor negative. The assessment against SA objective 1 is also relevant here – any unmet need that needs to be accommodated in neighbouring authorities is also likely to be constrained by Green Belt but the effect of this is uncertain. Once it is clearer where any unmet need is likely to be located further work should be undertaken to understand its sustainability implications working in conjunction with neighbouring authorities. SS5, SS6 and SS7 would also release increasing amounts of Green Belt land in uncertain locations. Development on these additional parcels of land


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will not be acceptable to Green Belt purposes (according to the Strategic Review of the Green Belt (2014)) and will have a significant negative effect on the SA objective. SS1 and SS2 would still release land in the Green Belt but this would be on previously developed sites and involve small changes to the boundary so the effect is likely to be neutral.


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4.3 Thorpe village boundary options


The alternative approaches have been assessed against a small number of the SA objectives only. The generic approaches to the options are unlikely to affect the other SA objectives so these have been screened out of the assessment. Please see Appendix 1 for an explanation of the content of each alternative. This assessment takes a particularly precautionary approach in that it considers constraints and opportunities within the area of Thorpe and assesses what the impacts of defining a boundary between the village and the Green Belt could potentially be if it led to development. However, please note that an option to include an area to be within the village boundary does not mean that it has been allocated for development and an assumption cannot be made that development will occur on these areas in the foreseeable future. The spatial strategy included several options to exclude the village of Thorpe from the Green Belt, which if taken forward, would see Thorpe treated as part of the urban area for planning purposes. This means that the village will cease to be part of the Green Belt and will be considered as urban area mean-ing that development would be more acceptable. This assessment considers the effects for a number of options where a detailed village boundary could be defined, whereas the effect of excluding the village from the Green Belt has been assessed in the spatial strategy options. Please also note that before a site is allocated for development or planning permission is granted, an assessment will be made of the likely environmental effects and appropriate mitigation put in place.

4.3.2 The results of the assessment

Table 4.2: Assessment of the Thorpe Village Boundary approaches – TH1 – 32 and 47 Western Avenue

Assessment of the Thorpe Village Boundary approaches – TH1 – 32 and 47 Western Avenue SA objective Impact of the ap-

proaches Commentary and comparison of options (including if appropriate nature and spatial extent of potential impacts, probability, duration, frequency and reversibility)

TH1/01 TH1/02 SA Objective 1: To conserve and enhance bi-odiversity, habitats and species

+ + Neither of the alternative approaches would affect designated sites or areas of valued habitat. Therefore the approaches have been scored as minor positive.


+ + Neither of the alternative approaches would affect mineral resources nor bring the boundary of the village closer to mineral abstraction. Therefore the approaches have been scored as minor positive.

SA Objective 5: to increase resilience to cli-mate change, including flood risk

+ + Both approaches are within flood zone 1 and therefore both approaches have been scored as minor positive.

SA Objective 6: to reduce air and noise pollu-tion

- - This area of Thorpe is in close proximity to the M25 / Thorpe Bypass (a source of air and noise pollution and the M25 corridor in this area is a designated AQMA) but both approaches are a similar distance from the M25 / Thorpe Bypass. Both approaches have been scored as minor negative.


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+ + The village of Thorpe does not have any ancient monuments or areas of archaeological interest and the alternative approaches do not conflict with the Thorpe Conservation Area. Both options would avoid adverse effects on heritage assets so would score positively.

SA Objective 11: to protect and enhance open space and the landscape character of the Borough

- - 0 With regard to the Green Belt, all of Thorpe is currently within the Green Belt (including these sites). The Council is trying to establish where boundaries should go if Thorpe was excluded from the Green Belt. TH1/01 is considered to have an unacceptable impact on the structure and the function of the Green Belt if included in the village boundary. TH1/02 is considered preferable in that it retains the current boundary and makes it more defensible. TH1/01 is also greenfield land which could have a negative impact on landscape character. TH1/02 would bring the boundary to the existing property boundaries so would have a neutral effect on landscape character. Both approaches would have a neutral effect on the provision of open space


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Table 4.3: Assessment of the Thorpe Village Boundary approaches – TH2 – TASIS site North

Assessment of the Thorpe Village Boundary approaches – TH2 – TASIS site North SA objective Impact of the ap-



- - Both approaches are subject to a Tree Preservation Order (TPO 64: Thorpe House, Coldharbour lane, Thorpe) but would not affect designated sites or other areas of valued habitat. Therefore the approaches have been scored as minor negative.




+ + Both approaches are within flood zone 1 and therefore both approaches have been scored as minor positive.


0 0 Both sites are relatively distant from significant sources of air and noise pollution.


- - The village of Thorpe does not have any ancient monuments or areas of archaeological interest. However, the Eastern side of Thorpe village is designated as a conservation area and this would affect both TH02/01 and TH2/02. In addition, small parts of both approaches are covered by policies BE15 (High Archaeological Potential) and BE16 (Preservation and Recording of Archaeological Remains) in the extant Local Plan. Both approaches have been scored as minor negative.


- - With regard to the Green Belt, all of Thorpe is currently within the Green Belt (including these sites). The Council is trying to establish where boundaries should go if Thorpe was excluded from the Green Belt. It is considered that TH2/02 would form a more defensible boundary to the Green Belt in this area. Both options could have a negative effect on landscape character as the current use of the area is for tennis courts and playing fields.


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Table 4.4: Assessment of the Thorpe Village Boundary approaches – TH3 – Coltscroft/Croft Farm/Elmside, West End Farm, Car Park at Memorial Fields and Land south of Westward Ho, Rosemary Lane

Assessment of the Thorpe Village Boundary approaches – TH3 – Coltscroft/Croft Farm/Elmside, West End Farm, Car Park at Memorial Fields and Land south of Westward Ho, Rosemary Lane SA objective Impact of the ap-



- - Both approaches are within 5km of the TBHSPA buffer zone so if development were to be proposed within this area a SANG solution would need to be proposed. Neither boundary would directly affect designated sites or areas of valued habitat.




- - Both approaches are within flood zone 2 so both would have a minor negative impact.


- - - Both approaches are in close proximity to the M25 / Thorpe Bypass. However, TH3/02 would bring the village boundary up against the M25 AQMA so would have a significant negative impact.


+ + The village of Thorpe does not have any ancient monuments or areas of archaeological interest and the alternative approaches do not conflict with the Thorpe Conservation Area. Both options would avoid adverse effects on heritage assets so would score positively.


-/0 -/0 With regard to the Green Belt, all of Thorpe is currently within the Green Belt (including these sites). The Council is trying to establish where boundaries should go if Thorpe was excluded from the Green Belt. It is considered that TH2/02 would form a more defensible boundary to the Green Belt in this area.

Option TH3/01 would have a neutral effect on landscape as it is adjacent to the M25 / Thorpe Bypass and largely follows the existing extent of Policy GB2 which includes existing residen-tial properties in Thorpe and would not therefore be considered greenfield. TH3/02 would also have a neutral effect as it currently includes an area of land which is partially developed by one dwelling at Coltscroft and a builder’s yard.


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Table 4.5: Assessment of the Thorpe Village Boundary approaches – TH4 - Thorpe Farm and 1 & 2 Manor Farm Cottages, Coldharbour Lane

Assessment of the Thorpe Village Boundary approaches – TH4 - Thorpe Farm and 1 & 2 Manor Farm Cottages, Coldharbour Lane SA objective Impact of the ap-



+ + Neither of the alternative approaches would affect designated sites or areas of valued habi-tat. Therefore the approaches have been scored as minor positive.


0 - TH4/02 would bring the village boundary closer to an active mineral site and mineral safe-guarding area. However, the mineral site is currently being restored, so this effect will be in the short term only and neutral in the long term.


+ - - TH4/01 is within flood zone 1 but the majority of TH4/02 is within flood zone 3a.


0 -/0 Both sites are relatively distant from most significant sources of air and noise pollution. However, TH4/02 would bring the village closer to an active mineral site. However, the min-eral site is currently being restored, so this effect will be in the short term only and neutral in the long term.


- - The village of Thorpe does not have any ancient monuments or areas of archaeological inter-est. However, the Eastern side of Thorpe village is designated as a conservation area and this would affect both TH02/01 and TH2/02. In addition, small parts of both approaches are covered by policies BE15 (High Archaeological Potential) and BE16 (Preservation and Record-ing of Archaeological Remains) in the extant Local Plan. Both approaches have been scored as minor negative.


- 0 With regard to the Green Belt, all of Thorpe is currently within the Green Belt (including these sites). The Council is trying to establish where boundaries should go if Thorpe was excluded from the Green Belt. It is considered that TH2/02 would form a more defensible boundary to the Green Belt in this area.

Both approaches would have a neutral effect on landscape character as the site is previously developed. Both approaches would have a neutral effect on the provision of open space.


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Table 4.6: Assessment of the Thorpe Village Boundary approaches – TH5 - TASIS Site South

Assessment of the Thorpe Village Boundary approaches – TH5 - TASIS Site South SA objective Impact of the ap-



+ - TH5 /02 brings the village boundary into close proximity to St Anne’s SSSI / South West Lon-don Waterbodies SPA. TH5/01 would not affect designated sites or areas of valued habitat




+ - - TH5/01 is within flood zone 1. TH5/02 has large areas within flood zones 2 and 3a.




- - The village of Thorpe does not have any ancient monuments or areas of archaeological inter-est. However, the Eastern side of Thorpe village is designated as a conservation area and this would affect both TH02/01 and TH2/02. In addition, small parts of both approaches are covered by policies BE15 (High Archaeological Potential) and BE16 (Preservation and Record-ing of Archaeological Remains) in the extant Local Plan. Both approaches have been scored as minor negative.


- 0 With regard to the Green Belt, all of Thorpe is currently within the Green Belt (including these sites). The Council is trying to establish where boundaries should go if Thorpe was excluded from the Green Belt. It is considered that TH2/02 would form a more defensible boundary to the Green Belt in this area.

Both approaches would have a neutral effect on landscape character as the site is previously developed. Both approaches would have a neutral effect on the provision of open space.


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Table 4.7: Assessment of the Thorpe Village Boundary approaches – TH6 - Woodcock Hall Farm, Green Road

Assessment of the Thorpe Village Boundary approaches – TH6 - Woodcock Hall Farm, Green Road SA objective Impact of the ap-



- - Both approaches are within 5km of the TBHSPA buffer zone so if development were to be proposed within this area a SANG solution would need to be proposed. Neither boundary would directly affect designated sites or areas of valued habitat.




- - - - Both approaches are within flood zone 3a




+ + The village of Thorpe does not have any ancient monuments or areas of archaeological inter-est and the alternative approaches do not conflict with the Thorpe Conservation Area. Both options would avoid adverse effects on heritage assets so would score positively.


- 0/- With regard to the Green Belt, all of Thorpe is currently within the Green Belt (including these sites). The Council is trying to establish where boundaries should go if Thorpe was excluded from the Green Belt. It is considered that TH2/02 would form a more defensible boundary to the Green Belt in this area.

Both approaches could have a negative effect on landscape character as the site is currently in agricultural use. Both approaches would have a neutral effect on the provision of open space.


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4.4 Housing options


The approach to the assessment of the alternative approaches is set out below:

• H1, H2, H3 and H4 – The approaches have been assessed against a small number of the SA objectives only. The generic approaches to the options are unlikely to affect the other SA objectives so these have been screened out of the assessment. In addition, any site specific issues which would require mitigation have been addressed in the assessment of the sites (see Appendix 2).

• H5 – Any sites that are proposed for allocation for this Local Plan have been assessed as a site allocation (see Appendix 2 of this report) so are not assessed here.

Please see Appendix 1 for an explanation of the content of each alternative.

4.4.2 Results of the assessment

Table 4.8: Assessment of the housing approaches

Assessment of the housing approaches SA objective Impact of the approaches Commentary and comparison of options (including if appropriate nature and

spatial extent of potential impacts, probability, duration, frequency and revers-ibility)

H1/01 H1/02 H1/03

SA Objective 9: to ensure the provision of high quality, sus-tainable constructed and afford-able homes and necessary com-munity infrastructure

+ + - - H1/03 would score negatively as the market is unlikely to provide the mix of homes needed and this is evidenced by the fact that there is currently an inappropriate mix of dwellings in the area. Approaches H1/01 and H1/02 would both perform positively as they will help to provide a more balanced mix of homes. H1/02 would be slightly more positive as it will be based on further evidence on the appropriate mix for Runnymede. It will be important to assess the delivery mechanisms of this approach once the draft plan is developed.

SA objective Impact of the approaches Commentary and comparison of options H2/01 H2/02

SA Objective 9: to ensure the provision of high quality, sus-

+ - - H2/01 is likely to increase the delivery of housing so will be positive. It should also in-crease the delivery of smaller housing which will change the housing mix favourably.


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tainable constructed and afford-able homes and necessary com-munity infrastructure

H2/02, by failing to specify density criteria is likely to contribute to a failure to deliver housing needs so will perform poorly.

SA Objective 10: To protect and enhance the Borough’s historic assets

? + H2/01 could lead to development which is of a higher density than the surrounding area, therefore, risking negative effects on this aspect of townscape. The Local Plan will need to ensure that high quality design is a key part of policy, taking into account aspects of the Runnymede Urban Character Appraisal. H2/02 will help to protect the existing char-acter of areas (in terms of the density of development) so will be positive.

SA objective Impact of the approaches Commentary and comparison of options H3/01


++ Runnymede has a substantial problem in relation to housing affordability so any action to increase affordable housing is likely to have a significantly positive effect. The option of not taking action would not be considered reasonable because of the scale of the is-sue and Government policy so has not been assessed. The option of increasing market housing to such an extent as to provide for full affordable housing is not considered rea-sonable as the amount of development needed to do this is not achievable in Runny-mede. Therefore, this option has also not been assessed.

SA objective Impact of the approaches Commentary and comparison of options H4/01 H4/02 H4/03 H4/04


- - - +/? +/? Relying on market forces (as set out in H4/01) is unlikely to provide for specialist ac-commodation needs and this is evidenced by the fact that there is currently unmet need. A criteria based policy (as set out in H4/02) is also likely to be ineffective in delivering the unmet need.

The approaches which aim to meet the need in full (H4/03 and H4/04) are likely to be positive with regard to meeting the needs of specialist populations. However, there is a risk that this is done at the expense of general affordable housing and the correct bal-ance will need to be struck as the approach is developed.


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4.5 Economy and retail options



• E1, E2, E3, E6, E7 and E8 – The approaches have been assessed against a small number of the SA objectives only. The generic approaches to the options are unlikely to affect any of the other SA objectives so these have been screened out of the assessment. Please note that E1 includes designation of Strategic Employ-ment Sites. However, at this time there is little detail available on what this designation would mean on the ground for these sites (which are extant Industrial Estates). Therefore, after discussion with the Council the decision has been taken to assess these designations at the Draft Plan assessment stage.

• E4, E5 – No alternative options have been proposed for these approaches. An assessment of the Local Plan policies will be made as part of the assessment of the Draft Plan.

• R1, R2 and R3 The potential approaches have not been assessed as part of this stage of the SA as they are considered unlikely to have different sustainability effects on the ground.

• R4, R5, R7 – The approaches have been assessed against a small number of the SA objectives only. The generic approaches to the options are unlikely to affect the other SA objectives so these have been screened out of the assessment. In addition, any site specific issues which would require mitigation have been ad-dressed in the assessment of the sites (see Appendix 2);

• R6 No alternative options have been proposed for this approach. An assessment of the Local Plan policies will be made as part of the assessment of the Draft Plan. This option includes town centre allocations. However, at this time there is little detail available on what these allocations would include. Therefore, after discus-sion with the Council the decision has been taken to assess these allocations at the Draft Plan assessment stage.

• Ru1 - No alternative options have been proposed for these approaches. An assessment of the Local Plan policies will be made as part of the assessment of the Draft Plan.



Table 4.9: Assessment of the economy approaches

Assessment of the economy approaches SA objective Impact of the approaches Commentary and comparison of options

E1/013 E1/02 E1/03

3 Please note that this table assesses the concept of the Strategic Employment Site. It does not represent a site specific assessment as these sites have not been designated for new development.


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+ + - - E1/01 and E1/02 would both help to sustain economic growth by protecting those stra-tegic employment sites that are considered most strategically important. E1/03 could have significant negative effects on the SA objective as letting the market dictate is not likely to be successful – there have been very limited levels of development in recent years. E1/01 is considered to be slightly more positive as it will help to provide ancil-lary uses which can make development even more attractive and will also help to en-courage environmental improvements.

SA objective Impact of the approaches Commentary and comparison of options E2/01 E2/02 E2/03


+ + - - E2/01 and E1/02 would both help to sustain economic growth by facilitating additional provision / intensification of use subject to detailed sustainability considerations. E2/03 would not help to sustain growth and competitiveness and would have a nega-tive effect.



+ - - + E3/01 and E3/03 would both help to sustain economic growth by facilitating additional provision of smaller office space. E3/02 (letting market forces dictate) would not help to sustain growth and competitiveness and would have a negative effect and this is ev-idenced by the fact that there is a need for this type of smaller office space.

SA objective Impact of the approaches Commentary and comparison of options E6/01 E6/02


+ - - E6/01 is likely to be positive in that it will help add local detail to the policy in the NPPF and help support incubation of high tech clusters of creative, knowledge driven or high technology industries. Relying on the NPPF would not help to sustain economic growth and prosperity as local detail would be key in identifying clusters and making such a policy work.



+ - - - - E7/01 would perform the most strongly as it would build on the most up to date evi-dence which points to the fact that some employment space may be suitable for con-version to other uses. E7/02 and E7/03 would not help to sustain economic growth


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and prosperity as it would be based on out of date evidence or let market forces dic-tate provision.

SA objective Impact of the approaches Commentary and comparison of options E8/01 E8/02


+ 0 E8/01 will be positive in helping to provide opportunities for improvements in educa-tional attainment which will have a secondary effect on economic growth and competi-tiveness. E8/02 would not necessarily have a negative effect as there are policies within the NPPF but it would be considered a missed opportunity.

Table 4.10: Assessment of the retail and tourism approaches

Assessment of the retail and tourism approaches SA objective Impact of the approaches Commentary and comparison of options

R4/01 R4/02 SA Objective 8: to sustain eco-nomic growth and competitive-ness across the Borough

+ + Both of the policy approaches could have potential positive impacts in controlling uses in town and local centres. However, R4/02 will provide a more bespoke solution for lo-cal centres (based on work to be carried out). It is not necessarily appropriate to pro-mote the same uses in local centres as in town centres and more work is needed to de-termine the appropriate uses.

SA objective Impact of the approaches Commentary and comparison of options R5/01 R5/02


+ + Both of the policy approaches could be positive. However, R5/02 would be more posi-tive as it is based on evidence that suggests that a lower sequential approach for de-velopment of major projects is more appropriate.

SA objective Impact of the approaches Commentary and comparison of options R7/01 R7/02 R7/03 R7/04


+ 0 0 0 R7/01 is considered to be the most positive approach in ensuring facilities are provided that meet people’s local needs whilst still safeguarding local centres. The other options would help safeguard local centres but would be less effective in meeting people’s needs (especially sections of the population that are less mobile – such as the elderly) as they would not allow small scale retail provision outside of centres.


+ - - -


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tainable constructed and afford-able homes and necessary com-munity infrastructure.

SA objective Impact of the approaches Commentary and comparison of options To1/01 To1/02 To1/03


+ + 0 To1/02 and To1/03 will both be positive in encouraging provision of hotels in the Bor-ough. To1/01 would not necessarily have a negative effect as there are policies within the NPPF but it would be considered a missed opportunity.

4.6 The built environment



• BE1 - BE3 and BE5 - BE8 - The approaches have been assessed against a small number of the SA objectives only. The generic approaches to the options are unlikely to affect the other SA objectives so these have been screened out of the assessment. In addition, any site specific issues which would require mitigation have been addressed in the assessment of the sites (see Appendix 2);

• BE4 – It is felt that because BE4/01 does not set out what a general policy on the environment could contain, it’s not possible to make a meaningful assessment at this stage. An assessment of the Local Plan policies will be made as part of the assessment of the Draft Plan.



Table 4.11: Assessment of the built environment approaches

Assessment of the built environment approaches SA objective Impact of the approaches Commentary and comparison of options

BE1/01 BE1/02 BE1/03 BE1/04 SA Objective 9: to ensure the provision of high quality, sus-

+ - - - BE1/01 is the only approach that would help to deliver the higher development needs that are required in the Borough. The other approaches would not contribute to this delivery.


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? + + + All of the options could be positive in some way in making sure that development is well designed and contributes positively to townscape. However, there are some risks with BE1/01 as it could lead to development which is of a higher density than the sur-rounding area, therefore, risking negative effects on this aspect of townscape. The policy will need to ensure that high quality design is a key part of the policy, taking into account aspects of the Runnymede Urban Character Appraisal.

SA objective Impact of the approaches Commentary and comparison of options BE2/01 BE2/02 BE2/03 BE2/04

SA Objective 4: to improve wa-ter quality and efficiency?

SA Objective 5: to increase re-silience to climate change, in-cluding flood risk



+ 0 0 0 All of the approaches would help contribute to well-designed developments. However, only BE2/01 will contribute towards ensuring that development contributes positively to current sustainability standards and targets. Therefore BE2/01 will have a positive impact on the sustainability objectives and the other approaches would have a neutral effect as they are based on outdated policies or would not include reference to sustain-ability standards that should be met.




+ + + + All of the approaches would help contribute to making developments more sustainable and contribute towards carbon reduction targets. However, BE3/01 will be the most positive as it will promote different ways that developers can use (subject to viability) to help meet targets.


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+ + + + All of the approaches seek to protect the Green Belt from inappropriate development and will therefore have a positive effect on the SA objective. BE5/01 would perform the most positively as it will remove a mechanistic method of deciding what is and isn’t significant development and instead will enable decisions to be taken, taking into ac-count local factors. The policy will need to be developed to ensure that the different sensitivities in the different areas of the Green Belt are taken into account.

SA objective Impact of the approaches Commentary and comparison of options BE6/01 BE6/02


+ + Both the approaches seek to protect the Green Belt from inappropriate development and will therefore have a positive effect on the SA objective. BE6/01 would perform the most positively as it will enable decisions to be taken, taking into account local fac-tors. The policy will need to be developed to ensure that the different sensitivities in the different areas of the Green Belt are taken into account.



+ + ? + All the approaches (apart from BE7/03) seek to protect the Green Belt from inappropri-ate development (by ensuring redevelopment will have no greater impact on the Green Belt) and will therefore have a positive effect on the SA objective. BE7/03 would not be in accordance with the NPPF.

SA objective Impact of the approaches Commentary and comparison of options BE8/01 BE8/02 BE8/03


+ + + All the approaches seek to protect the Green Belt from inappropriate development and will therefore have a positive effect on the SA objective. BE6/01 would perform the most positively as it will give the most clarity as to what is acceptable.


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4.7 The natural environment



• NE1, NE3 - The approaches have been assessed against a small number of the SA objectives only. The generic approaches to the options are unlikely to affect the other SA objectives so these have been screened out of the assessment. In addition, any site specific issues which would require mitigation have been addressed in the assessment of the sites (see Appendix 2).

• NE2 – There is no alternative to funding and protecting Suitable Alternative Natural Greenspace (SANGs) and Strategic Access Management and Monitoring (SAMM). The alternative approaches put forward would both ensure such protection but are slightly different ways of administrating such protection. Therefore, it is not felt that they would lead to significantly different effects on the ground.



Table 4.52: Assessment of the natural environment approaches

Assessment of the natural environment approaches SA objective Impact of the approaches Commentary and comparison of options

NE1/01 NE1/02 NE1/03 NE1/04 NE1/05 SA Objective 1 (biodi-versity), 2 (health and well-being), 3 (soil and minerals), 4 (wa-ter quality and effi-ciency), 5 (climate change resilience), 6 (air and noise pollu-tion), 7 (greenhouse gas emissions), 10 (historic assets) and 11 (open space and landscape character)

+ - - + - - ++ NE1/02 and NE1/04 will have a negative impact. Their failure to designate Local Green Space and/or Biodiversity Opportunity Areas will mean that the Local Plan fails to provide enhancements for biodiversity, open space and landscape. This will have secondary effects on issues such as soil, water quality, and health and climate resili-ence due to the wider environmental and health benefits that spaces such as Local Green Spaces and Biodiversity Opportunity Areas provide.

NE1/01 and NE1/03 would score positively but would be a missed opportunity with regard to increasing ecological resilience within the Borough as NE1/01 would only designate Local Green Spaces and NE1/03 would only designate Biodiversity Oppor-tunity Areas.

NE1/05 would score significantly positive as it would provide policy support for both Local Green Spaces and Biodiversity Opportunity Areas.

SA objective Impact of the approaches Commentary and comparison of options


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NE3/01 NE3/02 NE3/03 NE3/04 SA Objective 1 (biodi-versity), 2 (health and well-being), 3 (soil and minerals), 4 (wa-ter quality and effi-ciency), 5 (climate change resilience), 6 (air and noise pollu-tion), 7 (greenhouse gas emissions), 10 (historic assets) and 11 (open space and landscape character)

++ ++ + + All of the approaches would seek to protect and enhance valued landscapes and will therefore be positive against all of the SA objectives listed to the left. However, NE3/01 and NE3/02 are felt to be the most positive as it will enable decisions to be taken, taking into account local factors and the evidence that has been collected with regard to local landscape character.


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4.8 Recreation, green space and leisure



• RGL1, RGL2, RGL4, RGL6 - The approaches have been assessed against a small number of the SA objectives only. The generic approaches to the options are unlikely to affect the other SA objectives so these have been screened out of the assessment. In addition, any site specific issues which would require mitigation have been addressed in the assessment of the sites (see Appendix 2).

• RGL3 – Because of the situation with regard to burial land in the Borough, it is not felt that the options would have significantly different sustainability effects

• RGL5 - No alternative options have been proposed for this approach. An assessment of the Local Plan policies will be made as part of the assessment of the Draft Plan.

• Please see Appendix 1 for an explanation of the content of each alternative.


Table 4.63: Assessment of the recreation, green space and leisure approaches

Assessment of the recreation, green space and leisure approaches SA objective Impact of the approaches Commentary and comparison of options

RGL1/01 RGL1/02 RGL1/03 SA Objective 2: to protect and im-prove the health and well-being of the population and reduce inequal-ities in health

SA Objective 9: to ensure the pro-vision of high quality, sustainable constructed and affordable homes and necessary community infra-structure

- - - - ++ RGL1/01 and RGL1/02 will fail to provide the types of open spaces that are deficient in Runnymede, facilitate active lifestyles (and local food production as the Borough is defi-cient in allotments) and therefore fail to improve the health and well-being of the popula-tion. RGL1/03 will introduce a requirement for certain provisions of open space to be pro-vided with development and therefore will be positive.

SA objective Impact of the approaches Commentary and comparison of options RGL2/01 RGL2/02


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SA Objective 2: to protect and im-prove the health and well-being of the population and reduce inequal-ities in health

SA Objective 11: to protect and enhance open space and the land-scape character of the Borough

- + RGL2/01 will fail to improve the quality of natural and semi natural space and will there-fore have a negative effect on SA objective 1. This is likely to have secondary negative effects on people’s well being. RGL2/02 will be positive in helping to improve these spaces and will have positive impacts on biodiversity and well-being. Mechanisms to achieve the policy will need to be developed later on in the planning process

SA objective Impact of the approaches Commentary and comparison of options RGL4/01 RGL4/02


SA Objective 11: to protect and enhance open space and the land-scape character of the Borough

+ + Both of the approaches would help to preserve open spaces in the Borough, thus having positive effects on health and well-being and landscape.

SA objective Impact of the approaches Commentary and comparison of options RGL6/01 RGL6/02 RGL6/03


SA Objective 9: to ensure the pro-vision of high quality, sustainable constructed and affordable homes and necessary community infra-structure

0 + + RGL6/02 and RGL6/03 would both have positive impacts on the SA objectives through the support for future provision of health and fitness clubs and a bowling complex. RGL6/01 is unlikely to give the policy approach needed to ensure that facilities are improved. Be-cause developments are already underway in Addlestone Town Centre and Egham Leisure Centre it is not felt that providing site allocations (RGL6/03) would be any more positive in meeting the SA objectives than RGL6/02 – introducing a Local Plan policy but not allo-cating sites.


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4.9 Heritage



• H1 – H9 - The approaches have been assessed against SA objective 10 only. The generic approaches to the options are unlikely to affect the other SA objectives so these have been screened out of the assessment. In addition, any site specific issues which would require mitigation have been addressed in the assessment of the sites (see Appendix 2). Please note that the alternative approaches for H1 to H9 are effectively the same, as follows. Therefore, these have been assessed as one issue:

• H1-H9/01- One high level strategic policy relating to all heritage assets

• H1-H9/02- A small suite of policies to include a high level strategic policy plus policies encompassing aspects of heritage not covered in sufficient detail in National legislation

• H1-H9/03- Retain the content of the current local plan saved policies

• H1-H9/04- No local policy, rely on National legislation and guidance


Table 4.74: Assessment of the heritage approaches

Assessment of the heritage approaches SA objective Impact of the approaches Commentary and comparison of options

H1-H9 /01

H1-H9 /02

H1-H9 /03

H1-H9 /04


+ ++ 0 0 H1-H9 / 01 and H1-H9 / 02 will both be positive in protecting the heritage of the Bor-ough, although H1-H9 / 02 will be the most positive as it will include a high level policy and then a small suite of policies which deal with local issues. This will be more effec-tive in protecting the assets of the Borough. H1-H9 /03 and H1-H9 /04 will be a missed opportunity as the current Local plan policies are out of date (H1-H9/03) and national legislation and guidance (H1-H9 /04) would not provide the right local focus.


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4.10 Transport and infrastructure



• T1, T2, I1 and I2 - The approaches have been assessed against a small number of the SA objectives only. The generic approaches to the options are unlikely to affect the other SA objectives so these have been screened out of the assessment. In addition, any site specific issues which would require mitigation have been addressed in the assessment of the sites (see Appendix 2).



Table 4.85: Assessment of the transport approaches

Assessment of the transport approaches SA objective Impact of the approaches Commentary and comparison of options

T1/01 T1/02 T1/03 T1/04 SA Objective 6: to reduce air and noise pollution

++ + - - - T1/01 would be significantly positive as it would fully address the transport issues identified in the Borough including the need to co-ordinate the approach to the transport implication of expansion at Heathrow. This would help to reduce congestion (a SA sub objective of objective 6). T1/02 would still be positive but would not include reference to a Heathrow expansion. Although a decision on a third runway has not been made (and even if a decision is made to build a third runway at the airport, this is unlikely to happen in the Local Plan period), the implications could be significant. The Heathrow Strategic Planning Group Terms of Reference were adopted in December 2015 and the Local Plan needs to reflect this. T1/03 would fail to address the current transport issues in the Borough as the current Local Plan policies are out of date. T1/04 (not including a policy) would have a significant negative impact as it would fail to support a reduction in the need to travel and address congestion and hotpots and corridors in the Borough

SA objective Impact of the approaches Commentary and comparison of options T2/01 T2/02 T2/03


++ - - T2/01 would be significantly positive as it would fully address issues around Travel Plans, Transport Assessments highway safety, parking etc and this would help to re-


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duce congestion (a SA sub objective of objective 6). T2/02 and T2/03 would fail to ad-dress the current transport issues in the Borough as the current Local Plan policies are out of date and the NPPF would not ass the local detail that could make the policy ef-fective.

Table 4.96: Assessment of the infrastructure approaches

Assessment of the infrastructure approaches SA objective Impact of the approaches Commentary and comparison of options

I1/01 I1/02 I1/03 I1/04 SA Objective 9: to ensure the provision of high quality, sus-tainable constructed and afford-able homes and necessary com-munity infrastructure

++ + + - - Future development and changes to the population dynamics of the Borough are likely to put pressure on infrastructure facilities / services. I1/01 will be significantly positive as it will ensure that infrastructure will be retained and new infrastructure will be de-veloped at a pace with the development it serves. I1/02 and I1/03 will still be positive but they are not as comprehensive in their scope as I1/01 so will miss the opportunity to retain infrastructure and coincide infrastructure with development. I1/04 will be sig-nificantly negative as it would fail to ensure that much needed infrastructure is devel-oped / maintained in the Borough

SA objective Impact of the approaches Commentary and comparison of options I2/01 I2/02


++ ? I2/01 will ensure that development planned on allocated sites has the necessary infra-structure to mitigate any negative sustainability effects and make the development as sustainable as possible. This would also test the viability of the site and ensure that any site that is allocated is deliverable. I2/02 introduces an unacceptable level of un-certainty into the planning of allocated sites and makes the sustainability and viability of each site very difficult to assess.


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4.11 Flooding



• F1, F3, F4, F5 - The approaches have been assessed against SA objective 5 only. The generic approaches to the options are unlikely to affect the other SA objectives so these have been screened out of the assessment. In addition, any site specific issues which would require mitigation have been addressed in the assessment of the sites (see Appendix 2).

• F2, F6 and F7 – No alternative options have been proposed for these approaches. An assessment of the Local Plan policies will be made as part of the assessment of the Draft Plan.



Table 4.107: Assessment of the flooding approaches

Assessment of the flooding approaches SA objective Impact of the approaches Commentary and comparison of options

F1/A01 F1/A02 F1/B01 F1/B02 SA Objective 5: to increase resilience to climate change, including flood risk

+ ? + - F1/A01 and F1/A02 would both help to alleviate the effects of flooding but F1/A02 would not necessarily reduce flooding and is not likely to be as effective as a strategy that supports the River Thames scheme. The area covered by the River Thames scheme is the largest area of undefended floodplain in England. F1/A02 is uncertain because the exact nature of the “other measures” is unclear. The River Thames scheme has been subject to a SEA and this highlights the significant effects of the pro-posed scheme. F1/B01 would be a more comprehensive solution to solving flooding issues than relying on flood alleviation schemes. In addition flood alleviation schemes are a long term so-lution and may leave properties vulnerable in the meantime. F1/B02 would not intro-duce flood resistance measures so is likely to perform negatively.

SA objective Impact of the approaches Commentary and comparison of options F1/C01 F1/C02


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Assessment of the flooding approaches SA Objective 5: to increase resilience to climate change, including flood risk

+ + F1/C01 would be a more comprehensive solution to solving flooding issues than relying on Environment Agency initiatives (F1/C02) but both help to reduce the effects of flooding.

SA objective Impact of the approaches Commentary and comparison of options F3/01 F3/02 F3/03

SA Objective 5: to increase resilience to climate change, including flood risk

- - + F3/01 gives applicants an automatic pass of the sequential test for certain types of de-velopment and would lead to more development in flood zones 2 and 3a. This could increase the risk of more people and businesses affected by flooding. However, the Council has stated that it will remain committed to ensuring that sites proposed would continue to be safe in a flood event. Until further details are known this has been listed as a negative effect. F3/02 would lead to more development in flood zones 2 and would be subject to the same uncertainties listed above. F3/03 would be more positive as it would apply the sequential test rigorously.

SA Objective 8: to sustain economic growth and com-petitiveness across the Bor-ough

++/? +/? - F3/01 and F3/02 would help the Council meet the need for significantly increased housing supply and provision of more employment land by relaxing the sequential test. An uncertain effect has also been noted as the cost to businesses of flooding is uncer-tain. F3/01 would release more land for development so would be more positive. F3/03 would mean that the Council would fail to provide enough employment land

SA Objective 9: to ensure the provision of high quality, sustainable constructed and affordable homes and neces-sary community infrastruc-ture.

++ + - F3/01 and F3/02 would help the Council meet the need for significantly increased housing supply and provision of more employment land by relaxing the sequential test. F3/01 would release more land for development so would be more positive. F3/03 would mean that the Council would fail to meet the need for significantly increased housing supply

SA objective Impact of the approaches Commentary and comparison of options F4/01 F4/02

SA Objective 5: to increase resilience to climate change, including flood risk

? ? There is not enough evidence to show what the effects of F4/01 and F4/02 would be. Further research is needed to ascertain the cumulative impact of minor developments on the flood risk.

SA objective Impact of the approaches Commentary and comparison of options F5/01 F5/02


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Assessment of the flooding approaches SA Objective 5: to increase resilience to climate change, including flood risk

+ - F5/01 would be positive in ensuring that basement developments do not have an unac-ceptable effect on groundwater flows thus reducing the incidence of groundwater flood-ing. F5/02 would not ensure this same safeguard so is likely to have a negative effect.


ANNEX 1 SCREENING OF THE ALTERNATIVE ISSUES AND OPTIONS


The information presented by the Council in the Issues, Options and Preferred Approaches consultation document is more than just potential development sites. It is a mix of options, potential approaches and sites. It is not possible or useful to assess the effects of these potential approaches against every element of the SA frame-work, either because they will have effects on only some of the sustainability topics or because alternatives have not been suggested (and the purpose of this stage of the assessment is to help the council determine between alternatives). Therefore each potential approach has been assessed slightly differently (against different SA objectives) and some of them have not been assessed. However, please note that all policies developed as part of the Draft Plan will be assessed as part of the next stage of the SA. To determine whether the approaches are likely to have an effect on the SA objectives (and therefore whether an assessment is needed), a screening table has been used. This is shown below:

SA1 SA2 SA3 SA4 SA5 SA6 SA7 SA8 SA9 SA10 SA11 Vision & objectives

Y Y Y Y Y Y Y Y Y Y Y

Spatial strategy approaches SS1 – SS7 Y Y Y Y Y Y Y Y Y Y Y Thorpe Village Boundary Options TH1 – TH6

Y Y Y Y Y Y

Housing options H1 Y H2 Y Y H3 Y H4 Y H5 This approach has not been assessed. Any sites proposed as a site allocation (or as a reasonable alternative site allocation) have been assessed sepa-

rately Economy and retail approaches E1 Y E2 Y E3 Y E4 No alternative options have been proposed for these approaches. An assessment of the Local Plan policies will be made as part of the assessment of

the Draft Plan E5 E6 Y E7 Y E8 Y


SA1 SA2 SA3 SA4 SA5 SA6 SA7 SA8 SA9 SA10 SA11 R1 The potential approaches have not been assessed as part of this stage of the SA as they are considered unlikely to have different sustainability effects

on the ground. R2 R3 R4 Y R5 Y R6 No alternative options have been proposed for these approaches. An assessment of the Local Plan policies will be made as part of the assessment of

the Draft Plan R7 Y Ru1 No alternative options have been proposed for these approaches. An assessment of the Local Plan policies will be made as part of the assessment of

the Draft Plan TO1 Y Built environment approaches BE1 Y Y BE2 Y Y Y Y BE3 Y Y BE4 Because BE4/01 does not set out what a general policy on the environment could contain, it’s not possible to make a meaningful assessment at this

stage. An assessment of the Local Plan policies will be made as part of the assessment of the Draft Plan. BE5 Y BE6 Y BE7 Y BE8 Y Natural environment approaches NE1 Y Y Y Y Y Y Y Y Y NE2 There is no alternative to funding and protecting Suitable Alternative Natural Greenspace (SANGs) and Strategic Access Management and Monitoring

(SAMM). The alternative approaches put forward would both ensure such protection but are slightly different ways of administrating such protection. Therefore, it is not felt that they would lead to significantly different effects on the ground.

NE3 Y Y Y Y Y Y Y Y Y Recreation, green space and leisure approaches RGL1 Y Y RGL2 Y Y Y RGL3 Because of the situation with regard to burial land in the Borough, it is not felt that the options would have significantly different sustainability effects


SA1 SA2 SA3 SA4 SA5 SA6 SA7 SA8 SA9 SA10 SA11 RGL4 Y Y RGL5 No alternative options have been proposed for this approach. An assessment of the Local Plan policies will be made as part of the assessment of the

Draft Plan. RGL6 Y Y Heritage approaches H1 – H9 Y Transport and infrastructure approaches T1 Y T2 Y I1 Y I2 Y Flooding approaches F1 Y F2 No alternative options have been proposed for these approaches. An assessment of the Local Plan policies will be made as part of the assessment of

the Draft Plan F3 Y Y Y F4 Y F5 Y F6 No alternative options have been proposed for these approaches. An assessment of the Local Plan policies will be made as part of the assessment of

the Draft Plan F7 No alternative options have been proposed for these approaches. An assessment of the Local Plan policies will be made as part of the assessment of

the Draft Plan

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