Q-C12: Please add any comments you wish to make about water management or flood risk in South Warwickshire

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.

What provision has been made for waste water infrastructure or is it to be dumped in rivers?

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 – C12. 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.

Issue C11: Water management: Natural England expects the Plan to consider the strategic impacts on water quality and resources as outlined in paragraph 170 of the NPPF. We would also expect the plan to address flood risk management in line with the paragraphs 155-165 of the NPPF. The Local Plan should be based on an up to date evidence base on the water environment and as such the relevant River Basin Management Plans should inform the development proposed in the Local Plan. These Plans (River basin management plans: updated 2022 - GOV.UK (www.gov.uk)) [https://www.gov.uk/guidance/river-basin-management-plans-updated-2022] implement the EU Water Framework Directive and outline the main issues for the water environment and the actions needed to tackle them. Local Planning Authorities must in exercising their functions, have regard to these plans. The Local Plan should contain policies which protect habitats from water related impacts and where appropriate seek enhancement. Priority for enhancements should be focussed on European sites, SSSIs and local sites which contribute to a wider ecological network. Plans should positively contribute to reducing flood risk by working with natural processes and where possible use Green Infrastructure policies and the provision of SUDs to achieve this. Issue C12: Flood risk: The Plan should positively contribute to reducing flood risk by working with natural processes and where possible use Green Infrastructure policies and the provision of SUDs to achieve this.

Flood risk: 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 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 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?

Flood risk: 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 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 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?

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 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?

Flood risk: 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 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?

Issue C11: Water Management QC11b. The quality of water is important and this issue is often dealt with in Part 1 of a local plan. We consider option b to be the most appropriate option which would prioritises water quality as a strategic issue, and develop a new policy based upon up-to-date evidence. This should be tested through evidence and consulted on as the Plan progresses. Issue C12: Flood Risk We are content with the approach proposed to flood risk which is consistent with the requirements of the NPPF in both national and local terms. The Strategic Flood Risk assessment undertaken for Part 1 together with the Water Cycle Study which will follow will inform emerging future policy which should take account of updates to the PPG in August 2022 following the government’s review of policy for development in areas of flood risk and bring it in line with recent changes to the NPPF.

Propensity to Flooding: Henley-in-Arden is famously susceptible to flooding, and certainly more so than other sites and locations proposed in the plan. The SFRA highlights that Henley is one of the most sensitive areas in the Stratford District to the fluvial impacts of climate change. The town rests at the base of a hilly catchment area providing an obvious outlet for when the River Alne floods, as it did most notably in memory in 2007. Additional development would increase the impact of that flooding and place greater demands on the surrounding environment in the event of flooding. No Potential to Future Proof the Infrastructure: There is no obvious solution to the problem of future-proofing any development proposed in Henley-in-Arden. Ageing water and sewerage infrastructure means that there is little chance of expansion or the development of the infrastructure of the future, particularly electric charging points for cars and the support of renewables.

Issue C11: Water Management QC11b. The quality of water is important and this issue is often dealt with in Part 1 of a local plan. We consider option b to be the most appropriate option which would prioritises water quality as a strategic issue, and develop a new policy based upon up-to-date evidence. This should be tested through evidence and consulted on as the Plan progresses. Issue C12: Flood Risk We are content with the approach proposed to flood risk which is consistent with the requirements of the NPPF in both national and local terms. The Strategic Flood Risk assessment undertaken for Part 1 together with the Water Cycle Study which will follow will inform emerging future policy which should take account of updates to the PPG in August 2022 following the government’s review of policy for development in areas of flood risk and bring it in line with recent changes to the NPPF.

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 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?

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 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?

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 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 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?

A policy that encourages the retrofit of climate change measures (as per Option C5b) would be preferable to a policy that requires net zero carbon requirements for all building proposals that require planning permission. Option C5a could result in restrictive and expensive implications for development proposals for the conversion or change of use of existing buildings. Any forthcoming policy should permit a range of options that encourage applicants to avoid, minimise or mitigate the cause of climate change based upon the precise needs and feasibility of the project.

The incorporation of policy measures on ‘adapting to higher temperatures’ should reflect national policy or building regulation requirements. Policy measures should allow for project and site specific considerations, and there is a need to ensure that any measures/requirements are viable and deliverable. Aligning local requirements with national requirements will mean that the industry is able to suitably adapt to new requirements and future policies are not so onerous as to discourage investment within South Warwickshire. General measures such as the provision of green infrastructure can be delivered through other policies in the emerging plan.

Flood risk: 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 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?

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 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?

5.15 As Issue C12 highlights, flood risk is considered a strategic planning matter and will therefore be addressed within Part 1 of the Plan. At present, there is not sufficient evidence to understand what sort or level of work is required.

There’s some good stuff on climate resilience and zero carbon but nothing controversial. This does however include flooding and water management issues (where there is a recognition of surface water flooding risk). There is however nothing here or elsewhere on waste water management issues which we should I think point out.

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 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?

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 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?

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 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?

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 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?

Issue - C12: Flooding is another issue that does not recognise boundaries so we are keen to ensure that as our plans develop we all take a consistent and constructive approach to the issue. Duty to cooperate response: Flooding is another issue that requires a co-ordinated approach across administrative boundaries. This is being achieved through preparation of a SFRA and Water Cycle Study for Coventry and Warwickshire. Again, this topic would seem suitable for a DOCG at sub-regional level.

Issue C11: Water Management QC11b. The quality of water is important and this issue is often dealt with in Part 1 of a local plan. We consider option b to be the most appropriate option which would prioritises water quality as a strategic issue, and develop a new policy based upon up-to-date evidence. This should be tested through evidence and consulted on as the Plan progresses. Issue C12: Flood Risk We are content with the approach proposed to flood risk which is consistent with the requirements of the NPPF in both national and local terms. The Strategic Flood Risk assessment undertaken for Part 1 together with the Water Cycle Study which will follow will inform emerging future policy which should take account of updates to the PPG in August 2022 following the government’s review of policy for development in areas of flood risk and bring it in line with recent changes to the NPPF.

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 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?

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 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?

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 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