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 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?

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 floodplain. If the proposal goes ahead will the County and/or developer be willing to compensate home and business owners affected by such future flooding?

1). My concerns are around flooding, in particular one of the sites proposed after the call for sites is the 93 hectares of land in Weston-under-Wetherley. This site is close to a high risk area of flooding and would be likely to increase the risk of flooding, because of the likely number of houses possibly built. 2). HS2 seems to have already had an influenced the River Leam to Hunningham and Eathorpe and further upstream, which the EA are looking into, put this to an increase in housing along this area it would seem to me to be rather risky.

We must mitigate against future flood risks, protecting our communities vulnerable to pluvial and fluvial flooding. • Attention should be paid to water efficiency and recycling, including integrating grey water recycling and low carbon rainwater harvesting in new developments. • The councils should work with the Local Flood Authority to implement Rural Sustainable Drainage systems projects across the district. • All footways and drives in new developments should be permeable. • Work with landowners/EA/local flood groups and other stakeholders to provide natural flood defences, slowing the river flow upstream • The Councils must support the call for bathing water status for our rivers, enhancing the quality of our District’s surface water and groundwater.

QC 10.1 Please select all options which are appropriate for South Warwickshire Claverdon does not have expertise to respond to this. QC12.2 Please add any comments you wish to make about water management or flood risk in South Warwickshire Development on the flood plains of the numerous watercourses in the SWLP area should not be permitted and surface water run off controlled by attenuation measures to avoid surge flooding and contamination of the watercourses. Minimum use of impervious materials to be used in development locations to aid natural absorption.

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 ander 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?

2.23 Water Quality (C11) 2.23.1 It is suggested that existing policies in relation to water quality can be carried forward. This could be kept under review as the evidence base for the Local Plan evolves. 2.24 Flood risk 2.24.1 The plan should adopt a sequential approach in line with paragraph 161 of the NPPF: “All plans should apply a sequential, risk-based approach to the location of development – taking into account all sources of flood risk and the current and future impacts of climate change – so as to avoid, where possible, flood risk to people and property.” 2.24.2 This approach should be reflected in the search for sites and identification of preferred sites.

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?

Q-C11: The JPC does not consider this is material for the part 1 plan Q-C12: Development on the flood plains of the numerous watercourses in the SWLP area should not be permitted and surface water run off controlled by attenuation measures to avoid surge flooding and contamination of the watercourses. Minimum use of impervious materials to be used in development locations to aid natural absorption.

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?

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.

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.

ssue 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.

Q-C11: Option C11b: Include policy along similar lines to the existing policies, where supported by up-to-date evidence This would be a sensible approach.

Q-C12: 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?

Q-C12: 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 C12 - flooding is becoming more of an issue, and there should be policies built in to further mitigate flood risk for existing sites.

Issue C8 Adapting to flood and drought events. SUDS. This paragraph is fine but does not go far enough. The Plan should include a policy that for existing domestic and non-domestic buildings such that SUDS MUST apply where a driveway or hardstanding is being added or replaced. In continental Europe, Green Roofs are used extensively to help control storm water flooding. This is because a Green Roof will go some some way to attenuate the flow of storm water. Reducing water consumption. The consumption of 100 litres per person per day is reasonable however we believe a lesser figure is used in some other countries. The document should consider that there may be the need before 2050 to account for the carbon footprint of water used in the manufacture of construction materials and during the construction process. 7.4 Flooding and water management. Issue C11: Water Management We support Option C11b, to retain and improve the existing policies. The two currently adopted policies refer to the maintenance of ‘good’ status of water bodies, however a ‘high’ status should be aimed for if possible. Water quality offsetting should be avoided if possible but if it is essential it will require careful monitoring. Issue C12: Flood risk. Clearly the two councils currently have different policies on development in flood zones. We suggest that the policy should be the same across the Plan area and that there will be a presumption against development in flood zones 2 and 3. It should be noted that the Government has recently put the NPPF out to consultation which includes policies on this issue, so the section will need to be reviewed again later.

QC11. Please select the option which is most appropriate for South Warwickshire: The JPC does not consider this is material for the part 1 plan QC12.2 Please add any comments you wish to make about water management or flood risk in South Warwickshire: Development on the flood plains of the numerous watercourses in the SWLP area should not be permitted and surface water run off controlled by attenuation measures to avoid surge flooding and contamination of the watercourses. Minimum use of impervious materials to be used in development locations to aid natural absorption.

Issue C8: Adapting to flood events and drought 70. As set out in the NPPF (para 31), all policies should be underpinned by relevant and up to date evidence, which should be adequate, proportionate and focussed tightly on supporting and justifying the policies concerned. Therefore, a policy requirement for the optional water efficiency standard must be justified by credible and robust evidence. 71. If the Council wishes to adopt the optional standard for water efficiency of 110 litres per person per day, then the Council should justify doing so by applying the criteria set out in the PPG (ID: 56-014-20150327). PPG states that where there is a ‘clear local need, Local Planning Authorities (LPA) can set out Local Plan Policies requiring new dwellings to meet tighter Building Regulations optional requirement of 110 litres per person per day’. PPG (ID: 56-015-20150327) also states the ‘it will be for a LPA to establish a clear need based on existing sources of evidence, consultations with the local water and sewerage company, the Environment Agency and catchment partnerships and consideration of the impact on viability and housing supply of such a requirement’. The Housing Standards Review was explicit that reduced water consumption was solely applicable to water stressed areas. 72. Building Regulations require all new dwellings to achieve a mandatory level of water efficiency of 125 litres per day per person, which is a higher standard than that achieved by much of the existing housing stock. This mandatory standard represents an effective demand management measure. The Optional Technical Housing Standard is 110 litres per day per person. Issue C11: Water Management 73. Development should only be asked to mitigate its own impact. It would be unreasonable and fail the CIL tests for developers too be expected to pay to address existing sewerage leaks in South Warwickshire.

C11: Water Management The two currently adopted policies that are highlighted in the table refer to the maintenance of ‘good’ status of water bodies. Is ‘good’ status the highest-level status in existence? If not, the highest status MUST be included. Water quality offsetting! Yet another example of Offsetting that will require careful policy interventions. Issue C12: Flood risk. It should be noted that the Government has recently put the NPPF out to consultation. This section can only be revied when Part 2 of the SWLP is published.

Q-C12: 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?

Q-C12: 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?

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.

Q-C12: Flood Risk:the site proposed is near to an area that regularly floods. Part of the site itself is also subject to periodic flooding. As a general principle, flood plains or those areas that have a direct impact on them, should not be developed. Houses built on such sites usually have long term damp, mould and health issues.