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

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?

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?

QC 10.1 The Parish Council does not have expertise to respond to these options. QC11 The Parish Council does not consider this is material for the part 1 Plan QC12 The Parish Council considers development on the flood plains of the numerous watercourses in the South Warwickshire Local Plan 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 C11 - Water Management 5.19.1 St. Modwen support any emphasis placed on water efficiency measures in new development proposals. The East of Southam vision document acknowledges the water stressed nature of the local water resource catchment and includes proposals for any water re-use and efficiency measures that might be adopted as part of the proposed development. Issue C12 – Flood Risk 5.20.1 St. Modwen support the policy position taken to protect land subject to flooding from inappropriate development. The East of Southam vision document gives consideration of surface and fluvial flood risk in masterplan design. The findings of the SFRA Level 1 report conclude that there is nothing of material significance that will present a constraint to the development of land East of Southam. The proposals actively incorporate the integration of an ecological enhanced green and blue infrastructure network.

In the development of the SWLP strategy water resource management, sustainable surface water management, fluvial flood risk and water quality should all be core elements to determining location and size of new development. The location of new development has the potential to impact the number of properties at risk of multiple sources of flooding, including sewer flooding in the network. Policies on SuDs are recommended, and site selection should consider availability to follow the drainage hierarchy and avoid connection of surface water into the foul/combined sewer network. Water quality is an important consideration when determining the location of new development. If the water environment does not have available capacity for increased treated effluent from wastewater treatments works that are set to take new development, then this should be a core consideration in the appropriateness of allocating a development site. Many of our wastewater treatment works discharging into the river Avon and it’s tributaries are at the technically achievable limit with regards to meeting their permit requirements. Unless existing surface water and infiltration flows from a catchment can be significantly reduced, new technology arises that allows us to treat phosphorous more effectively or the Environment Agency allow a deterioration through relaxing permit requirements it is likely to be very difficult to accommodate the planned growth strategies across South Warwickshire.

For your information we have set out some general guidelines and relevant policy wording that may be useful to you in the development of your plan. Wastewater Strategy We have a duty to provide capacity for new development in the sewerage network and at our Wastewater Treatment Works (WwTW) and to ensure that we protect the environment. On a company level we are producing a Drainage and Wastewater Management Plan covering the next 25 years, which assesses the future pressures on our catchments including the impacts of climate change, new development growth and impermeable area creep. This plan will support future investment in our wastewater infrastructure and encourages collaborative working with other Risk Management Authorities to best manage current and future risks. Where site allocations are available, we can provide a high-level assessment of the impact on the existing network. Where issues are identified, we will look to undertake hydraulic sewer modelling to better understand the risk and where there is sufficient confidence that a development will be built, we will look to undertake an improvement scheme to provide capacity. Surface Water Management of surface water is an important feature of new development as the increased coverage of impermeable area on a site can increase the rainwater flowing off the site. The introduction of these flows to the public sewerage system can increase the risk of flooding for existing residents. It is therefore vital that surface water flows are managed sustainably, avoiding connections into the foul or combined sewerage system and where possible directed back into the natural water systems. We recommend that the following policy wording is included in your plan to ensure that surface water discharges are connected in accordance with the drainage hierarchy: Drainage Hierarchy Policy New developments shall demonstrate that all surface water discharges have been carried out in accordance with the principles laid out within the drainage hierarchy, whereby a discharge to the public sewerage system is avoided where possible. Supporting Text: Planning Practice Guidance Paragraph 80 (Reference ID: 7-080-20150323) states: “Generally the aim should be to discharge surface water run off as high up the following hierarchy of drainage options as reasonably practicable: 1. into the ground (infiltration); 2. to a surface water body; 3. to a surface water sewer, highway drain, or another drainage system; 4. to a combined sewer.” Sustainable Drainage Systems (SuDS) Sustainable Drainage Systems (SuDS) represent the most effective way of managing surface water flows whilst being adaptable to the impact of climate change and providing wider benefits around water quality, biodiversity, and amenity. We therefore recommend that the following policy wording is included within your plan regarding SuDS: Sustainable Drainage Systems (SuDS) Policy All major developments shall ensure that Sustainable Drainage Systems (SuDS) for the management of surface water run-off are included, unless proved to be inappropriate. All schemes with the inclusion of SuDS should demonstrate they have considered all four areas of good SuDS design: quantity, quality, amenity and biodiversity. Completed SuDS schemes should be accompanied by a maintenance schedule detailing maintenance boundaries, responsible parties and arrangements to ensure the SuDS are managed in perpetuity. Supporting Text: Sustainable Drainage Systems (SuDS) should be designed in accordance with current industry best practice, The SuDS Manual, CIRIA (C753), to ensure that the systems deliver both the surface water quantity and the wider benefits, without significantly increasing costs. Good SuDS design can be key for creating a strong sense of place and pride in the community for where they live, work and visit, making the surface water management features as much a part of the development as the buildings and roads.

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.

Q-C11: Option C11a has the potential to be the most appropriate policy, however this is subject to its specific wording. At present, the existing policies concerning water management state the term ‘good’, however there is no definition of ‘good’ and the term remain s subjective, therefore unclear and has potential to be unachievable. Q-C12: Please add any comments you wish to make about water management or flood risk in South Warwickshire 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 properly judge what sort or level of Policy is required. Until the additional evidence is undertaken, it is not appropriate to comment on water management or flood risk. However, Caddick Land reiterates that as per validation requirements, all major applications require a Flood Risk Assessment to assess a site, and mitigate against any potential problems. 5.19 Furthermore, the wording within Issue C12 infers that the Part 2 work will be based upon the strategy, however the work undertaken should inform the strategy, therefore all work undertaken should underpin any proposed policy. 5.20 In addition, whilst the Level 1 Strategic Flood Risk Assessment states that it can be used to inform the Local Plan on the location of future development and the preparation of sustainable policies, there is not sufficient evidence to fully decipher this, and this report should only be considered as a factor towards the wider review of sites suitable for development. As per Paragraph 0077 (Reference ID: 7-007-20220825), Diagram 1 outlines that following the completion of a Level 1 Strategic Flood Risk Assessment, the authority then identify where development can be located in areas with a low risk of flooding and assess alterative development options using the Sustainability Appraisal, considering flood risk and other planning objectives. Following this exercise, the Council can then apply the Sequential Test to identify appropriate allocation sites and development, which can then require a Level 2 Strategic Flood Risk Assessment. As a result, a greater amount of work and evidence is required to inform the Local Plan, as the Council have not yet reviewed the availability of sites, to identify those in areas of low risk flooding and those no t. 5.21 In addition, the SFRA summarises that there are urban areas of Stratford upon Avon and Warwick that are at risk of fluvial and surface water flooding. As a result, the Councils need to take this into account when reviewing their available urban sites. This may require greater areas of Green Belt land to be released, if urban areas are at greater susceptibility to flooding. At present, two reports have been produced to cover Stratford and Warwick separately. In the future, it would be more useful and appropriate to look at South Warwickshire as an entity, with supporting joint evidence. In addition, Appendix D within both reports identifies Flood Alert and Flood Warning Areas, and it would be more appropriate to have accompanying maps of these areas to identify clearly those locations. At present, it is unclear.

Q-C11: Please select the option which is most appropriate for South Warwickshire NWBC Response – Preference towards option C11b. This allows a review and update of current policy approach to be undertaken and address any increased climate change implications. No further comments.

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?

As stated in the previous Knight Frank response (ref. 2102), Climate Change and the integration of SuDS within developments should be considered in line with national policy and guidance. PPG para 055 ref. ID 7-055-20220825 states that SuDS provide benefits for water quantity and quality, biodiversity and amenity, with multifunctional SuDS delivering a wider range of additional biodiversity and environmental net gains.