Q-C12: Please add any comments you wish to make about water management or flood risk in South Warwickshire
no flood plain development
No comment, but ensure the importance of flood risk assesment remains within a planning matter.
Implementation of Schedule 3 of the Flood and Water Management Act 2010 should be incorporated into this local plan. It sets out a framework for the rollout of drainage systems, a sustainable drainage system approving body, and national standards on design, construction, operation and maintenance. It also makes the right to connect surface water runoff to public sewers conditional upon a drainage system being approved before any construction work can start.
in the proposal for development around weston under wetherley I note that the area proposed is on steep gradient and abuts to current flood zone - the run off any proposed development there would need a huge SuDS which would surly negate any benefits to development in this area
Current site area in Weston under Wetherley /Hunningham area abuts flood zone 3. Current guidance on management of surface water run off from development of agricultural land to housing/ mixed use development suggests a framework ( including SuDs)but is not able to account for the unknown future changes in water management required due to climate change. It is highly likely that development will increase future flood risk along the Leam river and significantly affect the ecology of the watercourse.
I am concerned that new developments on or close to flood plains increases the risk of contributing to higher floods water further downstream. An example, is the need to maintain flood plains higher up the River Leam providing protection for Leamington Spa and other built areas further downstream. Proposals to develop large areas adjacent to Hunningham would increase this risk of flood and/or increase development and carbon costs at the expense of an existing natural flood plain. If the proposal goes ahead will the County and/or developer be willing to compensate home and business owners affected by such future flooding? To expand further and illustrate my point in this regard, has the Council taken into account the type of work done by Shipston Area Flood Action Group (SAFAG), through their Slow the Flow project, webpage: https://safag.org/learn/slow-the-flow/ ? It strikes me that any development on and adjoining flood plains not only increases the risk of higher floods but is also completely the opposite of projects such as SAFAG’s Slow the Flow! SAFAG have shown that their project works, we don’t need to make the flooding situation worse, before we realise that it would be better to avoid such a risk. We could simply take on board what SAFAG have learnt and achieved and avoid developments that are on and adjoining flood plains, and thereby avoid the increased flooding problem. Flooding of Shipston was severe, and flooding in Leamington has been severe in the past, we do not want to make it worse.
Stop building on flood plains like the development near Emscote Road in Warwick and the new school off Harbury Lane which is on the Tach Brook floodplain. Absolutely ridiculous planning acceptance that that sort of building is OK.
I am concerned that new developments on or close to flood plains increase the risk of flooding further downstream. Maintain Maintenance of the floodplains of the River Leam will provide protection for Leamington Spa and other built areas further downstream. Proposals to develop large areas adjacent to Hunningham would increase this risk of flooding and require remediation elsewhere with increased carbon costs at the expense of an existing natural flood plain. If the proposal goes ahead, will the developer be willing to compensate home and business owners affected by such future flooding due to removal of this natural flood plain?
Must not build in areas at risk of flood and development must not exacerbate surface run off. Appropriate infrastructure needed to ensure water quality maintained. Houses should have water collection/filter provision for anything use other than drinking water. Rivers and their tributaries must be protected.
Implementation of Schedule 3 of the Flood and Water Management Act 2010 should be incorporated into this local plan. It sets out a framework for the rollout of drainage systems, a sustainable drainage system approving body, and national standards on design, construction, operation and maintenance. It also makes the right to connect surface water runoff to public sewers conditional upon a drainage system being approved before any construction work can start.
In my view current policies on flood risk are weak, and too many developments have been approved in flood plains or areas of known flood risk. I'd like to see improved controls in the completed SWDP.
(1) Water Management: the public are increasingly angry about water management (and specifically sewage discharge). This situation has in part arisen because of decades of under-funding of the relevant infrastructure. Therefore, although SWLP does not directly have water management responsibilities, it is very important that the new Local Plan deals with the issue of waste water infrastructure so that (i) new developments do not compound problems; (ii) housebuilding is carried out to the highest environmental standards in this regard; (iii) infrastructure is considered, planned and built before house building commences and the design and development of this is a joint activity between local authorities, water companies and developers. (2) Flood Risk: housebuilding should not be permitted on flood plains or areas prone to flooding unless the property is designed with appropriate mitigating features and does not compound flooding problems (eg with regard to water run-off).
Issue C4: New Buildings Option C4.1a is our preferred approach. Achieving net zero should be ‘stepped’ in line with Government targets and the proposed changes to the building regulations. This is more desirable as there is considerable momentum from Government in preparing enhanced sustainability standards as it is clear the energy efficiency requirements for domestic and non-domestic buildings will increase sharply in the coming years. Aligning the Council’s requirement for net zero development with those of Government would therefore be pragmatic and more achievable. Were the Council to seek net zero or ask for higher standards than the building regulations from new development from the point of the Local Plan’s adoption then we would remind the Council to include the uplift in build costs for delivering net zero within any forthcoming Local Plan viability assessment and that the PPG states that “Viability assessment should not compromise sustainable development but should be used to ensure that policies are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of the plan” (Paragraph: 002 Reference ID: 10-002-20190509). Therefore, in order for the future plan to be found sound the following should be implemented: • Any future policy should be stepped in line with emerging government targets and requirements and • Ensure the policy is properly assessed within the forthcoming viability assessment Q-C4.2: What scale of development should the requirements apply to? If the proposed policy is stepped in line with the building regulations, the new policy should apply to all new developments. Issue C7: Adapting to higher temperatures The option looks to include a policy that requires new developments to incorporate measures to adapt to higher temperatures such as the use of cool materials and using green infrastructure to create cooling. It is recommended that option C7c is taken forward ‘None of these’. This is because this area is now covered via Part O of the Building Regulations and the plan should not seek to amend or go beyond the building regulations. The Council also need to be mindful of how part O (Overheating) of the building regulations is balanced alongside daylight and sunlight requirements. Issue C8: Adapting to flood and drought events Drainage and water efficiency requirements should remain in line with Government targets and the Building Regulations. Were the Council to seek higher standards than the Building Regulations from new development from the point of the Local Plan’s adoption this would need to be evidenced. We would also remind the Council to include the uplift in build costs for delivering adaptation to flood and drought events that goes beyond the Building Regulations within any forthcoming Local Plan viability assessment and that the PPG states that “Viability assessment should not compromise sustainable development but should be used to ensure that policies are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of the plan” (Paragraph: 002 Reference ID: 10-002-20190509).
Because of lack of investment, the climate change we have been experiencing over the last few years has had a detrimental effect on both water supply and drainage. Pipes have moved, so there is a signicant increase in leaks. Old clay pipes used in drainage have deteriorated and ditches not cleared have caused an increase in localised flooding.
No comment
All flood plains and water ways to be identified and no building whatsoever can be built upon them.
Need to also give careful consideration to surface water flooding risks as these are of as much importance as flooding risk from waterways. This also needs to be considered when building on field that currently absorb water and reduces risk of flooding
Please consider rain water capture and storage as part of all new developments, both residential and commercial. This will help for both droughts and floods.
In areas where we already know that flooding occurs - I do not think we should use these areas for housing or building development - we should leave these 'natural areas' as they are - flood plains - in the fields between Weston under wetherley and Hunningham there are areas which flood - we should encourage the bio diversity in these areas and use these areas for green /blue corridors.
Much of the area within Lapworth Parish is subject to flooding and recently 1:100 year floods are occuring frequently as a result of climate change eg the Old Warwick Road was closed due to flooding for several days in early 2023. Ageing and limited infrastructure and lack of regular maintainence contributes toward regular flooding.
Avoid building on land subject to flood risk. Such land should be prioritised for promoting biodiversity and green/blue corridors.
Encourage water storage, run-off attenuation, and sustainable drainage.
There should be a presumption against development on land liable to flooding. The SFRA highlights that Henley is one of the most sensitive areas in SDC to the fluvial impacts of climate change.There is a contradiction between the HSA and development plans for Henley. The assessment outlines the need for carefully considered development and not that Henley should absorb significant urban expansion as suggested in the Plan
There is a large area in this region [to the North of Long Itchington] which has very poor drainage and relies on the Sponge effect of the agricultural ground to prevent overloading the ditch which is the only drainage source. This ditch has very little fall between the A423 and River Itchen to permit a high flow rate. When some houses were built to the east of the A423 they have already had floods because the ditch is incapable of taking the flow.
QC10.1a: Should plan include a policy requiring new development and changes to existing buildings to undertake a Climate Change Risk Assessment. Yes WWT supports the use of Climate change assessments, but the Council needs a clearer plan for actually delivering and monitoring in line with the climate change priories of COP27, the Governments Climate change strategy and in line with the declared Climate Change Emergencies in both Council areas. Therefore we need local policies halting the deterioration of water bodies being lost from Water Framework in line and with the Governments 25 year Environment Plan, Climate Change Act (2019) and Environment Act (2021). The Councils should also include a SUDs policy, as these can be strategic in nature.
Must not build in areas at risk of flood and development must not exacerbate surface run off. Appropriate infrastructure needed to ensure water quality maintained. Houses should have water collection/filter provision for anything use other than drinking water. Rivers and their tributaries must be protected.
Q-C11 Lapworth parish Council consider that SDC policy CS4 provides a good base modified to include waterbodies in the WDC area.
I am concerned that new developments on or close to flood plains increases the risk of contributing to higher floodwater levels further downstream. It is essential to maintain flood plains higher up the River Leam in order to provide protection for housing and businesses downstream including Leamington Spa. Proposals to develop large areas adjacent to the Leam near Weston and Hunningham would increase the risk of flooding as a result of replacing land that can absorb rainwater with paved areas that cannot and through the loss an existing natural flood plain. Where such development is permitted the developer must pay for flood prevention measures at the location in question and also downstream to at least, and ideally more than, offset the impact of the development on flood levels.
Q. 34 Yes. The Local Plan should exclude sites that have a history of drainage issues, or are likely if developed to cause drainage problems on neighbouring land. An example of an area to be avoided for this reason is land north of Beehive Hill, Kenilworth, which has been offered for development by its owners.
Q-C11. Please select the option which is most appropriate for South Warwickshire Option C11b. As indicated in the Issues and Options consultation document, there have been recent issues with sewage leaks in some locations across South Warwickshire. This is a common problem across many parts of the country. One of the causes of sewage pollutions is that some sewage treatment works are already at, or beyond, capacity. As such, new development can further exacerbate this issue. One option for addressing this issue would be for the Local Plan to impose ‘Grampian conditions’29 whereby the new housing should not be occupied until there is sufficient capacity in the sewage treatment infrastructure to deal with the sewage waste arising from the development (and from other anticipated development in the locality). In the context of the Cotswolds National Landscape, it is important to note that one of the ‘special qualities’ of the National landscape is the ‘river valleys…with high quality water’.30 29 https://www.planningofficers.org.uk/uploads/news/UseOfGrampianConditions.pdf 30 The special qualities of the Cotswolds National Landscape are listed in Chapter 2 of the Cotswolds AONB Management Plan 2018-2023