We certainly support the intentions that this policy is aiming to achieve, and are pleased to see reference to both green and blue infrastructure provision being sought. However, we do not feel this policy goes far enough to ensure it has a positive effect on biodiversity. A numerical commitment to biodiversity net gain is required in order to be in line with upcoming Environment Bill. We would support a 10% target for biodiversity net gain and the use of Natural Englands Biodiversity Metric 2.0 as a way of measuring and accounting for losses and gains. This is available through the following link:
http://nepubprod.appspot.com/publication/5850908674228224

The policy could seek a requirement for all development or development over a certain size to include a detailed assessment of existing natural capital and the scope to provide net gain through design.

A significant contribution to achieving net-gain and improving connectivity between areas is to seek the inclusion of an 8 – 10m undeveloped wildlife corridor alongside watercourses. These are important local assets which can provide strong and resilient ecosystems, green and blue infrastructure links, water quality and human health through pleasant amenity space. Article 10 of the Habitats Directive stresses the importance of natural networks of linked habitat corridors to allow the movement of species between suitable habitats, and promote the expansion of biodiversity. River corridors are particularly effective in this way and the network of river corridors may help wildlife adapt to climate change by providing a migration corridor. This approach would ensure development provides enhancements which prevent deterioration of the ecological status of waterbodies.

The justification for this policy discusses the commitment to improving waterbody status to good no later than 2027 which we support and welcome. There are currently no waterbodies with the Spelthorne Borough that are at good status and the specific methodology for improving the status of the water bodies is not discussed in depth, nor are the issues currently causing lower classifications. Furthermore, the Water Framework Directive (WFD) water bodies which exist within the boundary have not been highlighted in the plan, with the exception of the reservoirs and the River Thames. We would like the plan to be more specific about the relevant WFD rivers and lakes so the objectives for improvement can be more detailed and tailored to each waterbody. This will also help support developers to meet your policy objectives.

With that in mind, this policy could go much further in identifying what measures will be supported in which areas. We have enclosed the relevant WFD bodies for the area, with a summary of the issues affecting quality. These are the most recent (2016) classifications, and the reasons explaining the elements below ‘Good’ status can be found on the Catchment Data Explorer.

The sustainability appraisal indicators for Biodiversity are shown to be positive from short to long term. However, the preferred approach within the sustainability appraisal states that you are seeking to go beyond statutory requirements to include a policy which has a local context and we do not feel the current policy wording is in line with this approach. Incorporating the measures we have advised will assist you in achieving this positive benefit.

Waterbody	ID	Overall	Ecological	Chemical	Elements below ‘Good’ status
Rivers
Surrey Ash	GB106039023480	Moderate	Moderate	Good	Physio-chemical elements – phosphate (moderate)
Colne (Confluence with Chess to River Thames)	GB106039023090	Moderate	Moderate	Good	Physio-chemical elements – phosphate (poor)
King George VI Reservoir water transfer	GB806100096	Moderate	Moderate	Good	Mitigation Measures Assessment – moderate or less
Thames (Egham to Teddington)	GB106039023232	Poor	Poor	Good	Biological quality elements - Macrophytes and Phytobenthos Combined (poor). Physio-chemical elements – phosphate (poor), temperature (moderate)
Lakes
Wraysbury Reservoir	GB30642417	Moderate	Moderate	Good	Physio-chemical elements – phosphorus (bad)
King George VI Reservoir	GB30642488	Moderate	Moderate	Good	Biological quality elements – phytoplankton (moderate). Physio-chemical elements – phosphorus (bad)
Staines Reservoir North	GB30642490	Moderate	Moderate	Good	Physio-chemical elements – phosphorus (bad)
Staines Reservoir South	GB30642525	Moderate	Moderate	Good	Biological quality elements – phytoplankton (moderate). Physio-chemical elements – phosphorus (bad)
Queen Mary Reservoir	GB30642639	Poor	Poor	Good	Biological quality elements - Macrophytes and Phytobenthos Combined (poor), phytoplankton (moderate). Physio-chemical elements – phosphorus (poor)