Spelthorne Local Plan - Preferred Options Consultation: Policies and Site Allocations

Spelthorne Local Plan Preferred Options: policies


Policy E1: Green Belt

  1. The Green Belt boundary is defined on the Policies Map (forthcoming). In order to uphold the fundamental aims of the Green Belt to prevent urban sprawl and to keep land within its designation permanently open, inappropriate development will not be approved unless very special circumstances can be demonstrated. Very special circumstances will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm is clearly outweighed by other considerations.

Replacement and extension of buildings in the Green Belt

  1. The Council will permit the replacement of a building in the Green Belt provided the new building:
  1. would be in the same use,
  2. is not materially larger than the one it replaces,
  3. is sited on or close to the position of the existing building, unless an alternative position would benefit the openness of the Green Belt, and
  4. does not have a materially greater impact on the openness of the Green Belt.
  1. The Council will permit the extension and alteration to a building in the Green Belt provided the addition:
  1. is not disproportionate to the size of the original building, and
  2. does not have a materially greater impact on the openness of the Green Belt.

Sustainability Appraisal Indicators

Reasoned Justification

The Metropolitan Green Belt plays a key role in Spelthorne to protect its character by preventing the immediate outward sprawl of London, to ensure settlements do not merge into each other, encouraging development of previously developed land and safeguarding the countryside from encroachment. In developing this Local Plan, a two-stage review of the Green Belt was undertaken to assess the extent to which land in the Borough fulfils these purposes. As a result, some land was considered not to perform these functions to the extent that warranted retaining the Green Belt designation and the decision was made to amend the boundary to remove areas that did not perform well and should be developed for other uses instead. The current area of Green Belt following removal of those sites is shown on the Policies Map (forthcoming).

The original building will be determined based on its size as existing on 1 July 1948 or first built if later than this date. This is to enable the effect of cumulative development to be taken into account when a building has been extended previously. The cumulative impact of a series of small extensions can be just as great as a single large addition. The size of the plot is not relevant when considering whether a replacement building is materially larger or an extension results in disproportionate additions. Guidance is provided on percentage increases that will be considered 'material' in the case of replacement buildings and 'disproportionate' for extensions to assist applicants on the likelihood of permission being granted.

This Policy applies to dwellings within the former Plotland Areas. Other policies that protect the character of the riverside will be relevant to these dwellings even though the former Plotlands designation no longer applies. The removal of the designation is a key change to this Local Plan. It was considered that the application of policies on Plotland Areas was inconsistent across the local authorities that have or had the designation, as some applied it in addition to Green Belt policy and some applied it instead of Green Belt policy. Spelthorne previously applied the policy in addition to Green Belt policy and set out design based criteria to protect the distinctive character of the river and is not strictly relevant to Green Belt, which can be covered instead by design policies for riverside development.

Proposals within the Green Belt will also be expected to comply with all other Local Plan policies, particularly those that cover design, amenity, landscape, biodiversity and flooding.

Monitoring Indicators



Data Source

Permissions granted for inappropriate development in the Green Belt without very special circumstances


Planning applications and appeals

Key Evidence

  • Green Belt Assessment Stage 1, 2017
  • Green Belt Assessment Stage 2, 2019

Sustainability Appraisal Alternative Options

Alternative Option 1: Rely on national policy for strategic and small scale development within the Green Belt.

Reject alternative. This option would result in there not being a specific local policy approach. This option would however help to safeguard the Green Belt and results in minor positive impacts.

Alternative Option 2: Have a policy which sets out the Council's approach to the extension, alteration and/or replacement of buildings in the Green Belt including size restrictions. Include specific size restrictions to aid the assessment of proposals that are 'materially larger'.

Reject alternative. This approach will allow the Council to safeguard the Green Belt but will not give consideration to proposals on a case by case basis and may not fully take account of the merits of individual cases.

Alternative Option 3: Have a policy which sets out the Council's approach to the extension, alteration and/or replacement of buildings in the Green Belt. Give support to proposals within the Green Belt provided they do not have a materially greater impact on the openness of the Green Belt. Do not include size or permitted development restrictions and give consideration to proposals on a case by case basis.

Preferred approach. This policy will enable decisions to be made by taking account of the individual merits of proposals. This option removes the prescriptive and mechanistic approach to deciding what would be 'materially larger' and allows some flexibility.

This approach is considered to be consistent with the national policy.

Core Strategy 2009 policies to be replaced

  • Policy EN2: Replacement and Extension of Dwellings in the Green Belt including Plotland Areas

Policy E2: Flooding

  1. The Strategic Flood Risk Assessments (SFRA 1 and 2) will be used to inform the location of future development within the Borough.
  2. New development will be guided to areas of lowest flood risk from all sources of flooding through the application of the sequential test. The exception test will continue to be applied where national planning policy advises that this is necessary. Where individual sites contain different flood zones, the layout of the site will also be expected to minimise flood risk.
  3. All development proposals are required to demonstrate that land drainage will be adequate and that they will not result in an increase in surface water run-off. The Council will expect incorporating SuDs (Sustainable Drainage Systems) to manage surface water drainage, unless it can be demonstrated that they are not appropriate. Where SuDs are provided, arrangements must be put in place for their management and maintenance over their full lifetime.
  4. Development in Flood Zones 2 and 3a13 will be permitted provided that:
  1. the vulnerability of the proposed use is appropriate for the level of flood risk on the site;
  2. the proposal passes the sequential and exception test (where required) as outlined in the NPPF and Government guidance;
  3. a site-specific flood risk assessment demonstrates that the development, including the access and egress, will be safe for its lifetime (taking into account climate change) without increasing flooding elsewhere, and will (where possible) reduce flood risk overall;
  4. the scheme incorporates flood protection, flood resilience and resistance measures appropriate to the character and biodiversity of the area and the specific requirements of the site;
  5. applications include appropriate flood warning and evacuation plans and have been approved, and
  6. site drainage systems are appropriately designed, taking account of storm events and flood risk of up to 1 in 100 year event with an appropriate allowance for climate change.
  1. Applications must be supported by Flood Risk Assessments where appropriate that demonstrate the development will be safe, not increase flood risk elsewhere, and maximise opportunities to reduce flood risk.
  2. Within the 1 in 20 year (5% AEP) extent, existing infrastructure or solid buildings that resist water ingress are not included within the definition of Flood Zone 3b Functional Floodplain and the associated planning requirements do not apply. Small scale or re-development of these buildings may be considered, subject to the following:
  1. Re-development must not increase the footprint of the buildings that are resistant to water ingress, and where appropriate should reduce the footprint;
  2. Change of use to a higher vulnerability classification is not permitted;
  3. Increase in the number and/or vulnerability of occupants of the site is not permitted;
  4. Where possible, development vulnerability should be reduced;
  5. Raising finished floor levels;
  6. Reducing surface water runoff rates and volumes from the site;
  7. Increasing floodplain storage capacity and creating space for flooding to occur by restoring functional floodplain;
  8. Reducing impedance to floodwater flow and restoring flood flow paths;
  9. Incorporating flood resilient and/or resistance measures;
  10. Ensuring development remains safe for users in time of flood (this may refer to the timely evacuation of properties prior to the onset of flooding in accordance with an individual Flood Warning and Evacuation Plan for the site);
  11. Basements, basement extensions, conversions of basements to a higher vulnerability classification or self-contained units are not permitted.
  1. With the exception of the provision of essential infrastructure, 'undeveloped' Flood Zone 3b will be safeguarded for flood management purposes.

River Thames Scheme

  1. The Council supports proposals for strategic flood relief measures (including any associated enabling works), including the proposed flood channel through the Borough as part of the wider River Thames Scheme. The proposed route of the channel and the land adjacent to it, as shown on the Policies Map (forthcoming) will be safeguarded for this purpose14.

[13] As identified on the latest Environment Agency flood risk maps and the Council’s latest Strategic Flood Risk Assessment
[14] As set out in para 157 (b) of the NPPF.

Sustainability Appraisal Indicators


Flood Zones in Spelthorne are based on definitions contained within National Planning Practice Guidance and the Council's Strategic Flood Risk Assessment (Level 1):

  • Flood resistance: Flood-resistant construction can prevent entry of water or minimise the amount that may enter a building where there is short duration flooding outside with water depths of 0.6 metres or less. This form of construction should be used with caution and accompanied by resilience measures, as effective flood exclusion may depend on occupiers ensuring some elements, such as barriers to doorways, are put in place and maintained in a good state.
  • Flood resilience: Flood-resilient buildings are designed and constructed to reduce the impact of flood water entering the building so that no permanent damage is caused, structural integrity is maintained and drying and cleaning is easier and the building can be re-occupied more quickly.

Planning Practice Guidance states that flood resistance and resilience measures should not be used to justify development in inappropriate locations.

Flood Zones

Flood Zone


Zone 1 Low Probability

Land having a less than 1 in 1,000 annual probability of river or sea flooding.

(Shown as 'clear' on the Flood Map - all land outside Zones 2 and 3)

Zone 2 Medium Probability

Land having between a 1 in 100 and 1 in 1,000 annual probability of river flooding; or land having between a 1 in 200 and 1 in 1,000 annual probability of sea flooding.

Zone 3a High Probability

Land having a 1 in 100 or greater annual probability of river flooding; or land having a 1 in 200 or greater annual probability of sea flooding.

Zone 3b The Functional Floodplain

This zone comprises land where water has to flow or be stored in times of flood. Local planning authorities should identify in their Strategic Flood Risk Assessments areas of functional floodplain and its boundaries accordingly, in agreement with the Environment Agency.

Note: The Flood Zones shown on the Environment Agency's Flood Map for Planning (Rivers and Sea) available on the Environment Agency's web site, do not take account of the possible impacts of climate change and consequent changes in the future probability of flooding. Reference should therefore also be made to the Strategic Flood Risk Assessment when considering location and potential future flood risks to developments and land uses.

Flood Zone 3b Functional Floodplain

The definition of Flood Zone 3b Functional Floodplain for Spelthorne Borough Council includes all buildings which have not been designed to exclude floodwater and do not resist water ingress, such as garages and warehouses, as well as roads, other linear features and other areas for car parking or recreational use which may provide important flow routes and flood storage functionality.

Reasoned Justification

In Spelthorne there are areas within the 1 in 20 (5%) or greater flood extent that are already developed and are prevented from flooding by the presence of existing infrastructure or solid buildings. Whilst these areas may be subject to frequent flooding, it may not be practical to refuse all future development. As such, and in accordance with the PPG, in some instances the Council will consider existing building footprints, where they can be demonstrated to exclude floodwater, not to be defined as Flood Zone 3b Functional Floodplain.

The approach the Council will take to development within the 1 in 20 year (5%) flood outline recognises the importance of pragmatic planning solutions that will not unnecessarily 'blight' areas of existing development, the importance of the undeveloped land surrounding them and the potential opportunities to reinstate areas which can operate as functional floodplain through redevelopment to provide space for floodwater and reduce risk to new and existing development.

The consideration of whether a building resists water ingress will be considered on a case-by-case basis as part of the planning application process, having regard to the presence of existing buildings on the site and the existing routing of floodwater through the site during times of flooding.

Monitoring Indicators



Data Source

Number of planning decisions, including appeals, granting permission not in accordance with Policy E2

No planning permissions that are not in accordance with Policy E2

In house monitoring

Key Evidence

  • Draft Strategic Flood Risk Assessment (Spelthorne Borough Council, 2018)
  • Local Flood Risk Management Strategy (Surrey County Council, 2014)
  • Spelthorne Water Cycle Study (Spelthorne Borough Council, 2019)

Sustainability Appraisal Alternative Options

Alternative Option 1: Do not have a specific policy on flooding in the Local Plan. Instead rely on national planning policy and guidance; on flood alleviation schemes such as the River Thames Scheme; and rely on developers entering discussion with the Environment Agency at the application stage.

Reject alternative. Due to the uncertainty created by relying on discussions between developers and the Environment Agency, the approach is considered to have unknown impacts. This approach does not allow for flood risk to be planned for holistically in Spelthorne.

Alternative Option 2: Have a local policy, reflecting the context of Spelthorne and influenced by the Strategic Flood Risk Assessment.

Preferred option. This approach would significantly reduce the risk of flooding and take account of the local context for Spelthorne.

 Core Strategy 2009 policies to be replaced

  • Policy LO1: Flooding

Policy E3: Environmental Protection

Air quality

  1. The Council will seek to improve and protect the Borough's air quality by ensuring all development15 proposals prevent further deterioration of existing poor air quality and are 'air quality neutral' as far as reasonably practicable. For development proposals that could potentially cause or exacerbate air pollution, the Council will expect that mitigation and compensation measures are incorporated to ensure that all major developments are sustainable from an air quality perspective. Where on site measures alone are not possible or are insufficient to reduce the impact on air quality, applicants should consider the scope for offsetting the impact by contributing to funding of other initiatives that improve air quality. An applicant will be required to submit an air quality assessment for development proposals where the proposed development falls within an Air Quality Management Area and/or where the Council considers that air quality is likely to be compromised. Planning permission will not be granted for proposals where adverse effects on air quality are of a significant scale, either individually or in combination with other proposals and/or the effects cannot be appropriately and effectively mitigated.

Water Quality

  1. The Council will ensure new development located near ground and surface water has the appropriate measures in place to mitigate any adverse impact on water quality and water features. Planning permission will not be granted to new developments which do not demonstrate the incorporation of water efficiency measures such as water recycling and collection features. Wherever practical, Sustainable Drainage Systems (SuDS) should be incorporated to minimise the discharge of surface water to the sewer system.


  1. The Council will look to protect and improve local noise conditions as far as reasonably practicable. The Council will ensure that development proposals that may generate unacceptable noise, or be unacceptably impacted by noise sources, incorporate appropriate attenuation measures to minimise the effects on new and existing residents. The adverse impacts of noise are to be reduced to acceptable levels through good design, layout and orientation of sites and buildings, and adequate noise insulation. The Council will require an acoustic report to accompany an application for development proposals that may be sensitive to noise sources, or might cause unacceptable noise for residents, businesses or the environment.


  1. The Council will require developments that may result in light pollution to incorporate appropriate lighting and other energy efficiency measures to provide the right lighting levels necessary. Planning permission will not be granted for light generating development proposals that may have an adverse impact on residential developments, amenity, wildlife and biodiversity.

Land Contamination

  1. The Council will ensure that development proposals affecting contaminated land demonstrate the suitability of the proposed use in relation to the condition of the site and take into account the receptor's sensitivity to pollutants. In all cases, the Council will require that an appropriate site investigation and treatment of contamination is undertaken prior to the development. Through the incorporation of mitigation measures and/or support for decontamination and soil remediation initiatives, land contamination will be minimised or even avoided.

[15] All development is applicable where development is proposed in an Air Quality Management Area, generates significant levels of pollution, increases traffic volumes or congestion, is for non-residential uses of 1000 sqm or greater, is for 10 or more dwellings and/or involves change of use of a development sensitive to poor air quality.

Sustainability Appraisal Indicators

Reasoned Justification

Air Quality

Air quality is an important environmental issue for Spelthorne. The Council's Air Quality Action Plan designates the whole Borough as an Air Quality Management Area (AQMA). This reflects that the whole Borough is in particular need to improve air quality therefore the Council will ensure that any new development in the Borough is consistent with the local air quality action plan.

Road traffic has been identified as the biggest single contributor to poor air quality in Spelthorne and results in other adverse environmental and health effects. Transport modelling and highways data suggest that the main road corridors are the worst affected areas. Some areas in the Borough with poor air quality below EU standards for nitrogen dioxide remain notably alongside the A308 at Sunbury Cross and the A30 at the Crooked Billet roundabout. The level of particulates (known as PM10s) is also a concern adjoining the M25 and Heathrow Airport.

The Council has a statutory duty to work towards the Government and European Union's air quality standards. Though the Council has little or no influence over traffic, there is scope to reduce reliance on cars and trips that have origins or destinations within the Borough to ensure that air quality impacts are kept to a minimum. The Council, with other stakeholders, will develop and implement a strategy to decrease the reliance on cars, promote sustainable modes of transport and reduce congestion and environmental impacts. The Council will ensure that there are mechanisms such as additional air quality monitoring stations in the Borough to capture current levels and to assist in managing air quality improvements. The Council will require an 'air quality assessment' to be undertaken where the development proposed is in an Air Quality Management Area, generates significant levels of pollution, increases traffic volumes or congestion, is for non-residential uses of 1000 sqm or greater, is for 10 or more dwellings and/or involves change of use of a development sensitive to poor air quality.

Individual developments are often shown to have a very small air quality impact. The cumulative impact of many individual schemes, deemed insignificant in themselves, can contribute to a 'creeping baseline'. Therefore, good practice to reduce emissions and exposure should be incorporated into all developments at the outset, at a scale commensurate with the emissions. Consideration of air quality neutrality should focus on both NOx and PM10 emissions, the energy sources used within buildings and emissions from the vehicles associated with the use of the development. Mitigation measures to reduce emissions may be applied on or off-site.

In many cases, the impact of the development being assessed will have a cumulative effect with other planned developments, which may or may not have planning permission. Where these developments have been granted planning permission and are therefore 'committed' developments, their impacts should be assessed cumulatively with those of the application site. The contribution of these committed developments should be accounted for in the 'future baseline', provided that their contributions can be quantified. It is difficult to include other planning applications yet to be determined, as the outcome is not certain - the number and type of traffic movements may not be quantifiable and the site layout and end users may be unknown. Circumstances with scenario assessment for proposed development without planning permission will be rare.

In some circumstances, there will be an existing permission for development on the site that has not yet been exercised. In the planning system, the estimated emissions from the existing permission could be considered as part of the future baseline and thus a revised application for the site would give rise to an incremental change in emissions from that associated with the extant permission. The Council's approach, in line with best practice guidance, is that impacts be assessed for the new permission sought against the current baseline for the site, disregarding the extant permission; this will reflect the 'real world' increase experienced by receptors.

Water Quality

The Borough's surface and ground water resources are extremely important for a range of uses and consumers including domestic, commercial, industrial and agricultural. The water industry is a major user of land in the Borough with four large reservoirs: the Queen Mary, Wraysbury, King George VI, Staines North and Staines, and treatment works at Ashford.

Due to the Borough's proximity to the River Thames, a significant area is at risk from flooding, with Staines and Shepperton being the worst affected areas. The Borough's ground water is particularly susceptible to pollution from contaminated run-off, storm sewerage and misconnections of sewerage to surface water drains. As such, there is the need for practical measures to be taken to protect, restore and enhance the quality of the Borough water resources and its water features without compromising sustainable development.

Therefore, the Council in conjunction with the Environment Agency will seek to resist any development proposal that threatens water quality but will support initiatives that result in improving water quality and the capacity of surface water to support wildlife. As stipulated in the European Water Framework Directive, the Council will also ensure that the Borough's waterbodies achieve good ecological status and protection for drinking water sources and protected sites such as Sites of Specific Scientific Interest.

The possibility of adverse impacts on water quality, and the impact of any possible discharge of effluent or leachates which may pose a threat to surface or underground water resources, directly or indirectly through surrounding soils, depends on the nature and scale of the development proposed as well as the local topography, the size and sensitivity of the water body. Therefore risks to water quality will need to be considered on a case by case basis rather than through application of a generic distance buffer.


Some parts of the Borough suffer from high levels of noise, particularly due to Heathrow Airport and road traffic. There are also high noise levels close to the motorways, trunk roads and other major roads such as the A308. Where noise sensitive development, including housing and schools, are proposed in these areas sound attenuation measures will be required to ensure an acceptable environment is created for residents of the development. Planning permission will be refused where the impact of noise cannot be minimised to an acceptable level. Applicants should seek advice from the Council's Environmental Health team to ensure that the need for assessments and the appropriate level of detail is established at an early stage. The extent of aircraft noise from Heathrow is indicated by noise contours which are shown on the Policies Map.

Noise sensitive uses proposed in areas that are exposed to noise from existing or planned industrial or commercial sources, will only be permitted where future users will not be exposed to an unacceptable noise impact that would result in creation of a statutory nuisance. Noise generating development will be permitted where it can be demonstrated that any nearby noise sensitive uses (as existing or with planning permission), will not be exposed to noise impact that will adversely affect the amenity of users of surrounding noise sensitive premises. In urban areas the density of industrial plant and air handling units (including kitchen extracts, air-condition units and refrigeration plant) has a cumulative effect of increasing the overall background noise level. To prevent this level continually increasing to the detriment of the local residential amenity in those locations there will be an expectation that all new noise sources would be expected to operate at a Rating Level (BS4142) of 10dB below the background noise level measured as an LA90.

Noise pollution from Heathrow Airport is of particular concern to the Council as the airport is close to major built up areas which means a large number of people in the Borough suffer noise disturbance from aircraft using the airport. Approximately, 300,000 people are affected by aircraft noise from Heathrow as defined by the 57Leq noise contour. In residential areas close to the airport, only one-for-one replacement of existing housing will be allowed within the 66Leq noise contour. The worst affected areas are in the north of the Borough in Stanwell and Stanwell Moor.

The phasing out of noisier aircraft has led to some reduction in noise disturbance but the potential gains have not been fully realised because of a continuing upward trend in the total number of aircraft movements. Night flights are also a potential source of great disturbance to communities. The Council will continue to support controls on night flying that achieve a progressive improvement in the night noise climate, including a limit on the total number of night flights. The Council also supports the retention of noise preferential routes, aimed at ensuring flights are concentrated over more sparsely populated areas, and the maintenance of controls that limit ground noise at the airport.

Light pollution

This policy seeks to minimise the adverse impact from light pollution on the environment. It promotes the use of measures to minimise the adverse impact of lighting on surrounding areas. Applicants developing proposals for lighting will be required to assess the impact of the lighting scheme and demonstrate there are no unacceptable adverse impacts.

Land contamination

This policy seeks to ensure land which is likely to be affected by contamination is minimised.

Less stringent pollution control and less careful site management in the past has led to a substantial legacy of sites contaminated by former uses. In particular, large areas of the Borough have been worked for minerals and the land subsequently filled. Although much of this activity has been on land within the Green Belt, many old sites are now occupied by, or are close to housing and commercial developments. These pits were filled long before any controls existed on waste disposal and, together with former industrial sites, now present a range of unknown contamination issues which need to be addressed. Contaminants may also be present on land where there are no specific records of contaminating uses, such as in made ground where unsuitable fill has been used.

A fundamental principle of sustainable development is that the condition of land, its use and its development should be protected from potential hazards. Failing to deal adequately with contamination could cause harm to human health, property and the wider environment. Where development is proposed, the developer is responsible for ensuring that development is safe and suitable for use for the purpose for which it is intended. A potential developer will need to satisfy the Council that unacceptable risk from contamination will be successfully addressed through remediation without undue environmental impact during and following the development. The developer is also responsible for ensuring submission of adequate site investigation information and comprehensive risk assessment, prepared by a competent person (with a recognised relevant qualification and demonstrable experience in contaminated land).

Failure to provide sufficient information, according with best practice guidance, may result in permission being refused and/or is likely to result in delays in clearance of planning conditions and unnecessary cost implications. Prior to implementation of remediation, a remediation method statement will be required to be agreed with the Council. Following any remediation, evidence must be included in a validation report on how remediation works have been carried out and verified to demonstrate that the remediation has been successful.

As a minimum, after carrying out the development and commencement of its use, the land should not be capable of being determined as contaminated land under Part IIA of the EPA 1990.

Monitoring Indicators



Data source

Number of monitored sites exceeding the annual air quality objective for nitrogen dioxide (40ug/m)3

Reduce nitrogen dioxide levels to below (40ug/m)3

at monitored sites

The Borough Council, Surrey County Council, Highways Agency

Net additional dwellings permitted within 66 Leq noise contour

No new dwellings should be permitted within the 66Leq noise contour

The Borough Council

Key evidence

        • Air Quality Action Plan 2005
        • Air Quality Annual Status Report 2019
        • Contaminated Land Inspection Strategy 2017

Sustainability Appraisal Alternative Options

Alternative Option 1: Rely on existing national policy, legislation and the Council's Planning Application Validation list. Conform to statutory pollution levels.

Reject approach. This does not cover the full range of receptors and further detail is required by the NPPF. By dealing with applications on a case by case basis the impacts on health and pollution are uncertain.

Alternative Option 2: Include a policy which has regard for the local context, setting out the general approach to environmental protection. Seek to minimise pollution and go beyond statutory pollution levels.

Preferred approach. This will ensure that development takes account of its local environment and impacts on or to a range of receptors.

Core Strategy Policies to be replaced

        • Policy EN3 (Air Quality)
        • Policy EN11 (Development and Noise)
        • Policy EN12 (Noise from Heathrow)
        • Policy EN13 (Light Pollution)
        • Policy EN15 (Development affecting Contaminated Land)

Policy E4: Green and Blue Infrastructure


  1. The Council will encourage development proposals which restore, maintain and enhance habitat connectivity and will seek opportunities for habitat creation particularly within Biodiversity Opportunity Areas. Development proposals will be expected to contribute to biodiversity through clearly demonstrating improvements when submitting a planning application as part of securing biodiversity net-gain.

Green Infrastructure

  1. The Council will require development to contribute to the delivery and maintenance of a high quality green infrastructure network by requiring proposals to provide and make enhancements to on-site assets. If a robust and evidenced case can be made that on-site provision is neither feasible nor viable, a financial contribution towards provision and enhancement may be sought in exceptional circumstances.

Blue Infrastructure

  1. The Council will protect and enhance the ecological, landscape and recreational value of watercourses and reservoirs. Development proposals which will have an adverse impact on the functions and setting of a watercourse and its corridors will not be permitted. Development proposals must demonstrate how they will support the provision and enhancement of blue infrastructure, in accordance with the Water Framework Directive.

Sustainability Appraisal Indicators

*It should be noted that this scoring relates solely to Green and Blue Infrastructure. A more detailed Sustainability Appraisal for the topic, including Biodiversity, is present in the Sustainability Appraisal document.


Biodiversity Opportunity Areas (BOAs) are identified as the most important areas for biodiversity in the Borough. BOAs represent the basis for an ecological network where improved habitat management as well as efforts to restore and create habitats will be most effective in enhancing connectivity to benefit species recovery.

Green Infrastructure is a network of multi-functional green space in both urban and rural settings, which is capable of delivering a wide range of environmental and biodiversity benefits for communities.

Blue Infrastructure is the network of watercourses and other bodies of water which provide ecological, landscape and recreational value to the Borough. This also includes the banks and corridors immediately along the watercourse which can provide significant biodiversity benefits.

Reasoned justification

Paragraph 170 of the NPPF states that planning policies and decisions should contribute to and enhance the natural and local environment through protecting and enhancing valued landscapes and sites of biodiversity. Paragraph 174 of the Framework sets out that local plan policies should identify, map and safeguard components of local wildlife-rich habitats and wider ecological networks. Spelthorne has a number of international, national and locally designated biodiversity sites which justify protection.

Biodiversity net-gain is an approach which aims to leave the natural environment in a measurably better state than beforehand. This approach has been included as part of the Government's Draft Environmental (Principles and Governance) Bill 2018. Biodiversity net gain will be sought on sites where existing green assets can be improved or enhanced or where these are lost, such as on greenfield sites, proposed development will provide significant replacements.

BOAs are key areas where priority habitat can be created, improved or restored and there are two significant areas identified in Spelthorne where opportunities for restoration and creation of habitats exist:

  • Staines Moor to Shortwood Common (TV03)
  • Shepperton to Thorpe16 (TV04)

As such, this justifies the inclusion of a policy to seek to achieve these objectives where possible.

The Water Framework Directive17 requires rivers and water-bodies in the UK to achieve good ecological status by 2027. This includes resisting the establishment and spread of non-native invasive species which can have a significant detrimental impact on native species.

Many of the water-bodies in the Borough support recreational uses which are required to be carried out within tight environmental restrictions and are regulated. Recreational uses are supported provided that they respect the ecological and landscape values of the water-bodies and the associated corridor.

[16] https://surreynaturepartnership.files.wordpress.com/2014/11/biodiversity-opportunity-areas_surrey-nature-partnership_20151.pdf

[17] http://ec.europa.eu/environment/water/water-framework/index_en.html

Monitoring Indicators



Data Source

Gains in biodiversity provided by development

All developments to provide biodiversity gains

Planning applications and appeals

Condition of European and National sites

Continual improvement in condition

Natural England surveys

Condition of local sites

Continual improvement in condition

SNCI surveys

Progress towards Water Framework Directive objectives

Achieve 'good ecological status' at earliest opportunity and by 2027 at the latest

Data provided by Environment Agency

Key Evidence

          • Biodiversity Opportunity Areas: the basis for realising Surrey's ecological network (Surrey Nature Partnership, 2015)
          • Spelthorne Biodiversity Action Plan
          • Water Framework Directive (2000)
          • Draft Environment (Principles and Governance) Bill 2018
          • Biodiversity net gain: updating planning requirements (Department for Environment, Food and Rural Affairs)

Sustainability Appraisal Alternative Options

Alternative Option 1: Do not have a specific policy on green and blue infrastructure but include the provision of green infrastructure in a design policy.

Reject approach. This approach would provide opportunities for green infrastructure but may give less weight to its importance as it would form part of a more generic policy.

Alternative Option 2: Have a policy that ensures development provides or contributes to the provision or enhancement of green and blue infrastructure.

Preferred approach. The NPPF stipulates that Local Plans and planning policy should set out a strategic approach for the creation, protection, enhancement and management of networks of biodiversity and Green Infrastructure.

*It should be noted that this scoring relates solely to Green and Blue Infrastructure. A more detailed Sustainability Appraisal for the topic, including Biodiversity, is present in the Sustainability Appraisal document.

Core Strategy 2009 policies to be replaced

          • EN7 - Tree Protection
          • EN8 - Protecting and Improving the Landscape and Biodiversity

Policy E5: Open Space

Existing Open Space

  1. The Council will seek to protect, maintain and where possible, enhance existing open spaces in the Borough and encourage quality and accessibility improvements.
  2. Open Space (including all open spaces within urban areas and all land and water that provides opportunities for sport and recreation and playing fields) will be protected from development in accordance with the NPPF.

Provision of new open space

  1. Proposals for new residential development will be expected to make provision for open space having regard to the standards as set out in the most up-to-date Open Space Assessment. Reference should be made to the local accessibility standards highlighted in the most up-to-date Assessment at the time of the submission of a planning application.
  2. Proposals for open space should be firstly directed to areas where there are deficiencies of such space as identified within the most up-to-date Open Space Assessment and Playing Pitch Strategy.

Local Green Space

  1. The Council will give protection to spaces designated as Local Green Space and development will only be permitted where very special circumstances can be demonstrated which outweigh the harm.

Sustainability Appraisal Indicators


Open Space is defined as all types of spaces, including areas of water such as rivers, lakes and reservoirs, which provide areas for sport and recreation and can act as amenity value. The Open Space Assessment provides a qualitative and quantitative audit of publicly accessible open space in the Borough. This assessment (or any successor document) should be used as the starting point when considering open space requirements for new developments.

The Playing Pitch Strategy will provide a robust and up-to-date assessment of the need for playing pitches in Spelthorne as well as identifying opportunities for new provision.

Reasoned Justification

Open Space is important due to the positive contribution it makes to the character of settlements and health and social well-being. Open Space forms the basis of the Borough's green infrastructure network supporting residents and other users. Therefore, it is considered that cumulatively, these spaces form valued assets of strategic importance which should be protected as a priority. Open spaces within urban areas provide relief from the urban environment for residents. Urban open spaces also provide breaks in the built environment. Policy E5 identifies all open space within urban areas as open space for the purposes of this policy and the protection afforded to these.

The NPPF in paragraph 96 states that access to a network of high quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities. Planning policies should be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities and opportunities for new provision.

Given the importance of these spaces, there is justifiable reason for the inclusion of a policy which seeks to protect existing provision as a minimum and ensure provision of spaces in which there are identified deficiencies over the plan period.

The NPPF allows for the designation of land as Local Green Space (LGS) through the preparation of the Local Plan. The designation is suitable for spaces of particular local significance or have community value. By designating as LGS the spaces will be protected from development in a manner which is consistent with Green Belt policy. Open spaces which do not meet the requirements of the LGS designation will be protected through the NPPF as stated in Policy E5.

Monitoring Indicators



Data Source

Quantity of open space

No loss of open space, identified deficiencies met by end of plan period

Planning applications and appeals

Open Space Assessment and Playing Pitch Strategy

Key Evidence

    • Open Space Assessment (Spelthorne BC, 2019)
    • Playing Pitch Strategy (2019)
    • Local Green Space Assessment methodology (October 2019)

Sustainability Appraisal Alternative Options

Alternative Option 1: Do not include a policy in the Local Plan. Rely on the NPPF to guide open space provision and protection.

Reject approach. This approach limits control over open space provision. This option fails to take account of local evidence on open space.

Alternative Option 2: Introduce a policy mechanism to ensure provision of open space across the Borough is supplied in the future.

Preferred approach. This will take account of recent evidence on open space in the Borough. Trends are already being monitored and kept under review.

Core Strategy 2009 policies to be replaced

          • Policy CO3: Provision of Open Space for New Development
          • Policy EN4: Provision of Open Space and Sport and Recreation Facilities