Other

ID sylw: 108078

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

This is a comprehensive policy which is generally consistent with national guidance on flood risk in the NPPF and PPG. Notably, the sequential and the exception tests for flooding, referred to in Paragraphs 173 – 178 of the NPPF, are omitted from the policy, although these are briefly discussed in the supporting justification. It is recommended that reference to both tests should be made within the policy itself; this will need to acknowledge, as per Paragraph 175 of the NPPF, that the sequential test is not necessary in situations where a site-specific flood risk assessment demonstrates that no built development within the site boundary, including access or escape routes, land raising or other potentially vulnerable elements would be located on an area that would be at risk of flooding from any source. Paragraph 176 adds that applications for some minor development and changes of use should also not be subject to the sequential test. In line with Paragraph 180 of the NPPF, planning applications for sites allocated in the South Warwickshire Plan, applicants would not need to apply the sequential test again.

Yes

ID sylw: 108183

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We broadly support the provisions of Policy J and the objective of reducing flood risk.
However, we consider that the provisions of the policy are not consistent with the NPPF, specifically regarding the sequential approach to locating development.
The NPPF continues to apply the sequential test to locate development outside flood zones 2 and 3, including in relation to pluvial flooding, and this includes all parts of a development site. Policy J refers to applying an ‘internal’ sequential test, by first accepting a development site which is in flood zones 2 or 3 and then designing out vulnerable parts of a development to locate this in lower flood zone areas – which could include locating vulnerable uses in flood zone 2. This is not the approach required by the NPPF (or PPG in respect of undertaking sequential tests). The policy should be amended to make clear that all development sites should apply the sequential test at site selection stage rather than layout design stage.
This approach should be applied to both plan making and development management.

Other

ID sylw: 108222

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

This is a comprehensive policy which is generally consistent with national guidance on flood risk in the NPPF and PPG. Notably, the sequential and the exception tests for flooding, referred to in Paragraphs 173 – 178 of the NPPF, are omitted from the policy, although these are briefly discussed in the supporting justification. It is recommended that reference to both tests should be made within the policy itself; this will need to acknowledge, as per Paragraph 175 of the NPPF, that the sequential test is not necessary in situations where a site-specific flood risk assessment demonstrates that no built development within the site boundary, including access or escape routes, land raising or other potentially vulnerable elements would be located on an area that would be at risk of flooding from any source. Paragraph 176 adds that applications for some minor development and changes of use should also not be subject to the sequential test. In line with Paragraph 180 of the NPPF, planning applications for sites allocated in the South Warwickshire Plan, applicants would not need to apply the sequential test again.

Other

ID sylw: 108284

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

Draft Policy J largely reiterates the guidance contained in the NPPF and PPG on Flood Risk and the Sequential Test. It is unnecessary to repeat national policy in the SWLP. The SWLP should simply direct the reader to the NPPF and PPG.

Other

ID sylw: 108415

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

Asiant : Cerda Planning Ltd

We broadly support the provisions of Policy J and the objective of reducing flood risk.

However, we consider that the provisions of the policy are not consistent with the NPPF, specifically regarding the sequential approach to locating development.

The policy should be amended to make clear that all development sites should apply the sequential test at site selection stage rather than layout design stage. This approach should be applied to both plan making and development management.

Other

ID sylw: 108446

Derbyniwyd: 06/03/2025

Ymatebydd: Mr R Wilding

Asiant : Cerda Planning Ltd

We broadly support the provisions of Policy J and the objective of reducing flood risk.

However, we consider that the provisions of the policy are not consistent with the NPPF, specifically regarding the sequential approach to locating development.

The policy should be amended to make clear that all development sites should apply the sequential test at site selection stage rather than layout design stage. This approach should be applied to both plan making and development management.

Other

ID sylw: 108581

Derbyniwyd: 07/03/2025

Ymatebydd: Corbally Group (Harbury) Ltd

Asiant : Pegasus Group

This is a comprehensive policy which is generally consistent with national guidance on flood risk in the NPPF and PPG. Notably, the sequential and the exception tests for flooding, referred to in Paragraphs 173 – 178 of the NPPF, are omitted from the policy, although these are briefly discussed in the supporting justification. It is recommended that reference to both tests should be made within the policy itself; this will need to acknowledge, as per Paragraph 175 of the NPPF, that the sequential test is not necessary in situations where a site-specific flood risk assessment demonstrates that no built development within the site boundary, including access or escape routes, land raising or other potentially vulnerable elements would be located on an area that would be at risk of flooding from any source. Paragraph 176 adds that applications for some minor development and changes of use should also not be subject to the sequential test. In line with Paragraph 180 of the NPPF, planning applications for sites allocated in the South Warwickshire Plan, applicants would not need to apply the sequential test again.

No

ID sylw: 108628

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Draft Policy J – Reducing Flood Risk
6.15.
This policy simply replicates that of NPPF and PPG and is not necessary.

Yes

ID sylw: 108741

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We support Draft Policy J and agree that new development should be prioritised in areas at lowest risk of flooding.
We note that Strategic Growth Option SG08 (West of Warwick Group) scores relatively poorly in relation to flood risk in the HELAA Part B assessment. SLR has produced a Preliminary Flood Risk Assessment and Surface Water Drainage Strategy (Appendix 3) in support of these representations. This document considers how land at Budbrooke Lodge Farm, which forms part of SG08, could be developed in a way which ensures that development is located outside areas at risk of flooding in line with the aspirations of Draft Policy J.
With regards to surface water flood risk, SLR state at section 5.2 of their report that much of the existing surface water flood risk is likely to be caused by overland flows which pool in the topographically lower areas of the site. It is considered that appropriate management of surface water via SuDS systems can appropriately manage surface water flows across the site.
Overall, it is considered that flood risk does not pose a significant constraint to residential development at land at Budbrooke Lodge Farm. Any areas of the site which are at risk of flooding will not contain built development and can instead be utilised to provide high quality public open space for new and existing residents.