TR3 Transport Improvements

* The DLP generates significant traffic movements through Bishops Tachbrook parish most acutely along the B4087 Oakley Wood Road & into Tachbrook Road.
* The predicted increase in peak time traffic along B4087 Oakley Wood Road is 75% which is the highest in the district. This figure does not include the impact of SDC's Gaydon/Lighthorne development. It is not clear from STA4 that the duty to cooperate has been exercised.
* The village of Bishop's Tachbrook, with ca 720 homes, is already subject to considerable through traffic at peak times. The STA has not measured traffic movements on Mallory Road. The effect of having these 2 main road running through the village is that the community is physically split into 3 sections. There are no measures to address this, nor to deal with the increase that will arise from having so many more cars in this area.
* There is a well-documented speeding problem through the village on the B4087 Oakley Wood Road and Mallory Road. Pedestrians, including school children, wishing to cross Oakley Wood Road and Mallory Road are at huge risk at peak times.
* None of the 27 measures contained in DLP STA 4 will directly mitigate the negative impacts of the huge increase in traffic movements on the people of Bishops Tachbrook, parish specifically:
1. Health and wellbeing with respect to congestion, road safety / speeding, air pollution, noise pollution and vibration, particularly along Oakley Wood Road.
2. Community cohesion - the increased isolation of the Savages Close / East side area from the village due to the huge increase in traffic along Oakley Wood Road effectively cutting them off. Likewise the separation between north and south sides of Mallory Road. The Safer Route to School has not been completed.
3. Degradation of the historic environment along the Oakley Wood Road conservation area and vibration damage to listed buildings.
* The DLP proposes 4,750 houses to be built in this southern part of the District. It is our key point in this submission that there may be no combination of mitigation measures that can address the challenge of such a large housing development in such a constrained area. The STAs fail to provide clear evidence that the traffic measures will be effective. An example of the challenge is that despite Europa Way being upgraded to dual carriageway, Oakley wood Road which runs parallel only a mile to the east is expected to experience a traffic increase of 75%. This increase will inevitably feed through to Tachbrook Road and so into south Leamington urban area ending at the constricting railway bridge. The STAs do not include any mitigation measures to deal with this.

Cycleways, a local group promoting cycling in Leamington, Warwick and Kenilworth, considers the Local Plan Section TR3, in particular the Infrastructure Delivery Plan, as inconsistent with national policy. The relevant national policies are the National Planning Policy Framework 2012 and the government's White Paper on Transport (Creating Growth, Cutting Carbon, Making Sustainable Transport Happen, HMG 2011). Whereas the general objectives of the Local Plan are in line with the objectives of the national policies, the IDP dos not deliver these objectives.

The main focus of the IDP is on increasing road capacity, and provides much detail on how the road junction capacity in urban areas can be increased to benefit motor vehicles. An example can also be seen in the planned development of Europa Way to a dual carriageway. The resulting higher car traffic volume will inherently be a barrier for people switching to other modes of transport, particular cycling, and the IDP provides little or no detail of how the needs of cyclists or pedestrians will be met. This is in contrast to the NPPF which asks to "give priority to pedestrian and cycle movements" and "create safe and secure layouts which minimise conflicts between traffic and cyclists or pedestrians" (NPPF para. 4.35).
Likewise, one of the objectives of the White Paper is to encourage people to make "more sustainable travel choices...........genuinely sustainable transport modes.........socially sustainable" (para. 9, p. 8), in particular for shorter journeys which make up two thirds of all travel (para. 4, p. 7).

Excellent idea

It is also impossible to state, to comply with the statutory tests of soundness outlined at paragraph 182 of NPPF, that the Plan meets objectively assessed infrastructure requirements arising from the strategy, consistent with the principles of sustainable development. Therefore the Plan is unsound on this basis.
In fact, despite the work undertaken through WSTA to date, the potential of, and impacts of, sustainable transport measures, has still not been undertaken. This is made clear by the recommendations of WSTA Phases 3 and 4. Stagecoach Midlands notes, too, that WCC 's specialist consultants conclude at page 7 of WSTA phase 4, that "it is critical that sustainable transport improvements form part of the mitigation package for housing and employment growth proposals...". The Company also note that the phase 4 report finds at section 1.6 on p 6. that "in areas where the most severe increases (in delay) occur appear to be in regions where there is potential to further optimise the proposed mitigations to overcome the issues." In other words, the reasonable alternatives, merely to accommodate the plan strategy, have not yet been defined fully, nor optimised or tested sufficiently robustly to allow a reasonable examination to conclude that the Plan represents the most appropriate strategy when considered against reasonable alternatives, based on proportionate evidence. The Plan is therefore unsound for this reason.
Without having a suitable evidential base, nor a rigorously defined transport strategy to prevent unmitigated impacts becoming severe, it is no surprise that the IDP does not comprise a suite of schemes that holistically and demonstrably achieve the mitigations required, and are equally evidentially supported as being deliverable. The Plan makes absolutely no provision for bus priority schemes needed to address the clear serious deterioration in peak traffic conditions that WSTA makes clear will arise. Not is there any evidence on the siting and operation of Park and Ride facilities, such that their effectiveness and viability can be evaluated. Indeed the failure even to allocate a site for a Park and Ride to the south of Leamington and Warwick, on the basis of its optimum impact and commercial viability is evidence that this element of the Plan strategy is little more than a concept, rather than a commitment to deliver an effective mitigation intervention.
Stagecoach notes that, despite representations to WCC and WDC over many years, the scope for a Park and Ride north of Leamington, where provision of the required bus capacity already exists taking advantage of the existing "Unibus" corridor, and along which demand would be expressed contra-flow to the student peak, has not even been considered.

Without measures to mitigate transport-related development impacts being tested for cost and effectiveness, and then defined in the Plan and the IDP, Stagecoach is quite clear that there can be no effective means of the LPA of Highways Authorities securing the required developer funding, compliant with CIL Regulation 122, to effect their delivery. Thus the Plan cannot be considered either positively planned or effective, and thus must be considered unsound.

The Highways Agency welcomes the opportunity to comment on the Publication Draft Local Plan and broadly supports the overall spatial strategy, which focuses future development on the most sustainable and accessible locations.
The Highways Agency broadly supports the strategic transport objectives set out at Para 5.31 of the Publication Draft Local Plan, particularly the need to carry out improvements to major congestion hotspots and to fostering a more sustainable transport pattern.
The Highways Agency has worked with Warwickshire County Council to assess the transport implications for the wider Warwick and Leamington Area and for the M40 Corridor resulting from the growth proposals set out in the emerging Local Plan. This work has identified a number of transport interventions and priorities that would be required to accommodate the Local Plan proposals including improvements to the SRN at A46 Thickthorn and Stanks Roundabouts. Whilst the Grey's Mallory Roundabout is not on the SRN, the proposed improvement will assist traffic flow to and from the M40 J14.
These schemes have been identified in the draft Infrastructure Delivery Plan including indicative costs and this is welcomed by the Highways Agency. It is also clear from Policy TR3 that contributions will be sought from all development that will lead to an increase in traffic on the road network in accordance with the Infrastructure Delivery Plan.
Draft Policy TR2 requires all large scale development proposals with significant traffic generation to be supported by a Transport Assessment and a Travel Plan where necessary. At Para 5.49 the supporting text to Policy TR2 states that a Travel Plan will be required for all non-residential developments. This approach does not accord with Government policy set out in the NPPF and Circular 02/2013, which also require the submission of a Travel Plan to support residential developments where there is expected to be a material traffic impact on the SRN.
The Highways Agency therefore considers that Policy TR2 should clearly state that Travel Plans will be required for both residential and non-residential development which will result in significant traffic movements on the SRN.
Draft Policy TR3 states that contributions towards transport improvements will be sought from all development that will lead to an increase in traffic on the road network in accordance with the Infrastructure Delivery Plan (IDP). The draft IDP (April 2014) identifies a number of highway infrastructure schemes relating to the SRN including the A46 Thickthorn Roundabout, Kenilworth; A46/A425/A4177 Birmingham Road 'Stanks Island' and Grey's Mallory Roundabout. The Highways Agency agrees with the priorities and phasing identified in the Draft IDP for these improvements, though we note that the funding source has yet to be confirmed.
However, in respect of the proposal for the introduction of "Smart Motorways" on the M40 between J14 and J15, there is less certainty that this will be required within the Plan period or any guarantee that the Highways Agency will be in a position to fund it.
At the time Warwickshire County Council was preparing the STA(4) to inform the Local Plan the Highways Agency specifically requested the County Council to remove the term "Smart Motorway" on the M40 from the document and replace it with a more generalised term of "Traffic Management", which could include a range of initiatives to manage traffic in a safe and efficient manner.
Whilst STA(4) no longer refers to "Smart Motorways" the IDP still does. Therefore the Highways Agency requests that the term "Smart Motorway" in respect to the M40 in the Draft IDP, which forms Appendix 4 to the Draft Local Plan, be replaced with the term "Traffic Management".
The Highways Agency is looking forward to working with the District Council and Warwickshire County Council to facilitate development in Warwick District supported by the timely delivery of required infrastructure improvements.

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Local Plan Strategy and Objectives:
Welcome LP strategy and supporting objectives, and commitment to deliver framework provided by the objectives to deliver sustainable development giving full consideration to the natural environment.
Development Strategy:
DS3 Supporting Sustainable Communities
Recommend two amendments to chapter 2.8
Within point .a) physical infrastructure the text should be amended to include
'Flood defence structures' within the examples given.
We would recommend that point c) of this policy is expanded to highlight the multiple benefits that green infrastructure can deliver, in your policy the provided examples include parks, open space and playing pitches.
Does not accurately identify range of ecosystem services that green infrastructure provides, including surface water management and improving water quality, through Sustainable Drainage Systems (SuDS), habitat and green routes for biodiversity movement, to support nature conservation/expansion of habitat. Assists with reducing the urban heat island by providing thermal cooling as an adaptation of climate change in addition to providing health and social benefits. It should be considered as integral to all new developments rather than as separate entity such as formal green space for recreational uses.
c) Recommend bullet point be amended to include the following text:
„Ecosystem services including Sustainable Drainage Systems (SuDS), expansion of habitat and as an adaptation to climate change „is added to the end of the sentence.
DS4 Spatial Strategy
Support this policy and welcome the prioritisation of brownfield redevelopment first approach advocated by this policy, however:
Recommend that point f) be amended to include the following text
'or other highly sensitive features in the natural environment (included designated sites for nature conservation) will be avoided'
Recommend insertion of the following statements:
„h) sensitive groundwater resources (i.e. source protection zones) supporting public water supply boreholes are protected'.
i) ensure that development is not at risk of flooding, does not increase flood risk elsewhere and will reduce flood risk overall.‟ DS7 Meeting the Housing Requirement
In chapter 2.23 we note that this approach provides the opportunity to investigate and remediate any contaminated land. Development proposals should be supported by Preliminary Risk Assessment (i.e. Desk study, conceptual model and initial assessment of risk on controlled waters receptors). DS10, DS11& DS15: The EA supports council‟s preference for allocating PD sites. Development proposal should be supported by Preliminary Risk Assessment (i.e. Desk study, conceptual model and initial assessment of risk on controlled waters receptors).
Development proposals should take into consideration the EA's groundwater protection policy (GP3) to ensure that groundwater resources are not impacted as a result of development.
EC2 Farm Diversification
Recognise importance of farming to the rural economy, and need to support diversification into non agricultural activities. However farm diversification can involve range of activities from recreational to energy production that may have negative impact upon the environment. Therefore recommend insertion of the following statements into the policy:
'd) Farmland is important for nature conservation and biodiversity. Enhancements to maintain ecological resilient networks through the countryside should be incorporated to proposals. e) Connectivity of riparian corridors are maintained and protected with buffer margins and tree planting
f) There will be a presumption against development that could lead to the degradation of the Water framework Directive (WFD) status of the waterbody should not be permitted'.
CT6 Camping and Caravan Sites
EA recognises importance of these sites for holiday use is important to local economy, but this needs to be balanced with the requirements of European Directives and the NPPF.
In line with existing practice guidance for the NPPF we note that Camping and Caravan parks are classified as „highly vulnerable‟ and that planning permission must not be granted for sites located within flood zone 3, and that the exception test must be granted for sites within flood zone 2.
We recommend that a precautionary approach be taken and we recommend the insertion of the following policy wording:
'There is a presumption against locating camping and caravan sites within the flood plan because of their vulnerability within a flood event'
The Environment Agency is concerned about the potential impacts that new camping / caravan sites may have on meeting the requirements of the Water Framework Directive, specifically in relation to the provision of foul waste infrastructure.
During the year there may be significant peaks in use of toileting precautionary approach taken and recommend insertion of the following policy wording:
'There should be a presumption against development of new camping and caravan sites that can not demonstrate adequate provision for the management and discharge foul / waste water'.
Refer you to letter sent to your Authority in relation to the preferred options consultation - Sites for Gypsies and Travellers ref UY/2007/101229/SL-04/PO1 - LO1 dated 09 May 2014. where there us more detailed information about potential allocations, and provides supporting evidence for policy recommendations.
CT7 Warwick Castle and Warwick Racecourse/St Mary‟s Lands
Acknowledge need to allow new development within this area that is sensitive to heritage assets; recommend that the following policy wording is added to the policy:
f) Identify how the proposals will contribute to EU Water Framework Directive and the Severn River Basin Management plan which requires the restoration and enhancements of water bodies to prevent deterioration and promote recovery of waterbodies.
We have the following information about the watercourse status as determined under WFD objectives.
GB109054043800 (Gog Brook from Source to confl with R Avon) is failing WFD with Moderate status (2009)
GB109054044402 R Avon (Wark) conf R Leam to Tramway Br, Stratford is failing WFD with Moderate status (2009)
To meet the requirements of the WFD objectives these waterbodies must reach good ecological status, all new development within this area must contribute to meeting this objective.
MS2 Note that the major sites include Stoneleigh Park and Stoneleigh Deer Park. The watercourse in this area is failing to meet good status as defined by the WFD, specifically waterbody GB109054043840 R Avon (Warks) - conf R Sowe to conf R Leam is failing WFD with Poor status (2009).
It is imperative that any new development contributes positively to improving quality of this watercourse.
Recommend that the following policy wording is added to the policy:
'Identify how the proposals will contribute to EU Water Framework Directive and the Severn River Basin Management plan which requires the restoration and enhancements of water bodies to prevent deterioration and promote recovery of waterbodies'.
Policy H1 Directing New Housing
In line with recommendations within Halcrow Water Cycle Study 2010, which recommends that:
„Floodplains should be safeguarded from future development and local authorities must apply the Sequential Test to ensure all new development is directed towards Flood Zone 1 in the first instance.
Opportunities should be taken to reinstate areas of functional floodplain which have been previously developed and Flood Zones 2 and 3 should be left as open space‟
Recommend addition of the following points within the policy wording:
vi) the development is not at risk of flooding and will not increase the risk of flooding elsewhere.
vii) All development proposals should be discussed with STW at the earliest possible opportunity, to understand the constraints for development and potential upgrades required to ensure the provision of adequate foul/ waste water infrastructure.'
Policy H5 Specialist Housing for Older People Residential care home are classified as "more vulnerable" in accordance with Table 2 of NPPF and are therefore considered appropriate in Flood Zones 1, 2 and 3a (Exception test required).
However, as the occupants are less mobile they are particularly vulnerable in a flood event, making evacuation more difficult. With this in mind, we recommend that you consider adding criteria:
'd) the proposed site is located in Flood Zone1.'

Policy H6 Houses in Multiple Occupancy, and Student Accommodation
Correctly identified that household waste management is often an issue at HMO‟s and Policy H6 e) requires that adequate provision is made for storage of refuse containers in new HMO‟s and that storage areas do not impact on the amenity of the local area.
While we would support this policy it is also important to ensure that not only is the space provided adequate but it is also appropriate to the functioning of the HMO.
For example there should be appropriate storage space internally at the point of arising as well as externally in order to minimise number of trips required to outside storage areas. The distance that occupants need to travel to access waste storage areas should also be considered as carrying waste beyond a certain distance may cause inconvenience and result in reduced participation in collection arrangements.
Distance between waste storage areas and waste collection points should also be considered. Routing and access for waste collection vehicles will also be important. In addition clear signage should be provided to identify what waste streams can go into each waste receptacle, this will be especially important for transient populations who may not be familiar with the authorities waste collection arrangements.
H8 New Gypsy and Traveller Sites
In line with existing practice guidance for the NPPF we note that Gypsy and Traveller sites are considered to be „highly vulnerable‟ and that planning permission must not be granted for sites located within flood zone 3, and that the exception test must be granted for sites within flood zone 2.
Recommend a precautionary approach and recommend the insertion of the following policy wording:
f) 'There is a presumption against locating camping and caravan sites within the flood plan because of their vulnerability within a flood event
g) The site will not impact on important designated sites for nature conservation.
h) Riparian Corridors are protected.
i)There should be a presumption against development of new traveller and gypsy sites that can not demonstrate adequate provision for the management and discharge foul / waste water'
SC0 Sustainable Communities
Would like to include the following points into this policy as they are significant indictors of sustainable development, furthermore without their inclusion into the text below the proposed policy may be judged as not meeting the requirements of the NPPF, or European legislation.
Suggest that point j) is re-worded as follows:
„reduce flood risk on the site and to the wider community through the layout and form of the development, and surface water is managed effectively on site through the incorporation of green infrastructure including Sustainable Urban Drainage systems into all new development's.
Recommend insertion of text below into the policy:
'h) Development proposals should have regard to and support the actions and
objectives of the Severn River Basin Management Plans (RBMPs) and also have regard to the River Severn Catchment Flood Management Plans (CFMPs).
i) Protect principal aquifers and the source protection zones associated with pubic supply boreholes within the northern part of the district, there will be a presumption against development within a groundwater SPZ1 which would physically disturb an aquifer.'
BE1 Built Environment
Note policy seems to provide an overarching approach to ensure that built development is both recommend:
following wording is added to the end of bullet point i)
' incorporating sustainable water managment features including, wetlands, ponds and swales, green roofs and street rain gardens.'
Recommend insertion of following points within the policy:
'q) Safeguard ecological features incorporating them into design and creating more resilient ecological networks, as an integral part of the scheme.
r) Development proposals must demonstrate that the strategic network of environmental infrastructure will be protected, enhanced and expanded at every opportunity. s) Ensure that there is an appropriate easement between all waterbodies/ watercourses to allow access and maintenance (for Main River this will be a minimum of 8 metres).
t) In line with objectives of the Water Framework Directive (WFD), development proposals must not adversely affect water quality of waterbodies in the District and wherever possible take measures to improve it.'
Recommend you consult your Lead Local flood Authority in relation to their requirements for easements for developments in close proximity to ordinary watercourses.
Development near to waterbodies should include access to them, and watercourses should reflect a natural state. Every opportunity should be taken where development lies adjacent to the river corridor, their tributaries or floodplain to benefit the river by reinstating a natural, sinuous river channel and restoring the functional floodplain within areas where it has been previously lost.
Welcome bullet point n) which requires sufficient provision for sustainable waste management within new developments.
TR3 Transport Improvements
Recommend policy amended to reflect the need to retrofit SuDS to existing transport routes, and to all new transport routes.
One of the significant contributions to pollution within some watercourses may be attributed directly to discharges of surface water from road network. This can contribute recovery of a watercourse and its ability to reach good ecological status as required by the Water Framework Directive.
Recommend policy is reworded to state:
'Contributions should include provision for public transport, footpaths, cycleways, towpaths and sustainable drainage systems, both internal and external to development areas'.
CC2 Planning for Renewable Energy and Low Carbon Generation Hydropower proposals (point g) must be supported by an assessment demonstrating that this method of energy generation will not compromise the objectives of the River Severn Basin Management Plan. New hydroelectric developments will also be subject to Flood Defence Consent from the relevant Flood Risk Management Authority.
Recommend insertion of following text:
h) Development proposals should have regard to and support the actions and objectives of the River Severn River Basin Management Plan (RBMPs)
i) Hydroelectric developments will also be subject to Flood Defence Consent from the relevant Flood Risk Management Authority'
FW1 Development in Areas at Risk of Flooding
Suggest that title of this policy is changed as it implies that development in areas of risk of flooding is appropriate , which is contrary to NPPF in which the aim of the Sequential Tests is to steer new development to areas with the lowest probability of flooding. We recommend that an alternative policy title such as „Reducing Flood Risk‟ is used instead. Where there are no reasonable available sites in Flood Zone 1, the Sequential Test should be applied; taking into account the flood risk vulnerability of land use and consider reasonably available sites in Flood Zone 2, applying the Exception Test if required. Only where there are no reasonable available sites in Flood Zones 1 and 2 should the suitability of sites in Flood Zone 3 be considered, taking into account the flood risk vulnerability of land uses and applying the Exception Test if required. As soon as the need for the Exception test is established, a level 2 SFRA should be undertaken by a suitable qualified technical expert or engineer. We have the following comments on the criteria outlined for this policy in relation to each bullet point within the policy. a) The SFRA level 1 Flood Zone maps are based on our Flood Map (fluvial risk) and the Areas Susceptible to Surface Water Flooding, now known as the Updated Flood Map for Surface Water (surface water risk). Unless there are plans to continually update the SFRA mapping, we suggest that our online Flood Map (now known as "Flood Map for Planning") available on the .GOV.UK website is referred to as this is updated on a quarterly basis and should provide the most up to date information.
b) this is essentially the Sequential test, and we would consider this criteria is re-worded to:
'the Sequential test is applied on the site so that the most vulnerable development is located in areas of lowest flood risk'.
c ) We recommend that the term "flood defence" in this criterion is replaced with the following wording
'development is appropriately flood resistance and resilience'
Because the term flood defence suggests formal flood walls etc which will prevent flooding in all circumstances, however even development behind flood defence structures can experience flooding through breach or overtopping. It is far more practicable to direct new development to flood zone 1 rather than in an area benefiting from existing flood defences. This should not be used to justify development in inappropriate locations.
e) Request clarification as to how the term "regular flooding" defined, we feel that this should either be removed from the policy, or the wording changed to indicate a likely return period, paying due regard to the NPPF which has a presumption against all development within the functional floodplain unless it can be described as water compatible.
g) Suggest this is re-worded to the following text:
'the development must be 'safe' over its lifetime, taking into account the effects of climate change. Safe pedestrian and emergency vehicle access routes above the 1:100 year plus climate change flood level must be available. Evacuation plans must be prepared for all new developments in flood risk areas'. Suggest that the paragraph "land that is required for current and future flood management will be safeguarded from development" is added as a continuation of the points (i) rather than a separate paragraph. We recommend that the paragraph "Where development is supported as an exception to this policy..." is removed, as there shouldn‟t be any exceptions to this policy and all criteria must be complied with. This wording is repeated in paragraph 5.130 and should be removed.
This is contrary to the National Planning Policy Framework, and the Environment Agency must object in principal to inappropriate development within the floodplain.
We would object to this section policy at a formal review of this plan, and it‟s inclusion could render the policy as unsound. We recommend the addition of the following criteria to Policy FW1 as supported by the level 1 SFRA: 'j) the functional floodplain is protected from all built development.
k) space should specifically be set aside for Sustainable Drainage System (SuDS) and used to inform the overall site layout.
l) development proposals must provide a minimum 8m wide development buffer strip from watercourses (culverted or otherwise).
m) every opportunity should be taken to de-culvert and re-naturalisation of watercourses. Culverting of existing open watercourses will not be permitted.
n) opportunities should be sought to reduce the overall level of flood risk in the area and beyond through the layout and form of the development, and the appropriate application of SuDS.
o)for residential development, finished floor levels are set a minimum of 600mm above the 1% (1 in 100 year) plus climate change flood level.
p) developers will be required to contribute towards the cost of planned flood risk management schemes that will benefit the site.
q) opportunities should be sought to make space for water within the development to accommodate climate change.
r) Development proposals will demonstrate that will not cause deterioration of the waterbodies WFD status and contribute to meeting good status.
s) Carry out a WFD Assessment to demonstrate how the waterbody will not deteriorate in status and will be enhanced
t) No detrimental impact on priority habitat or designated sites of nature conservation.' With regard to the FRA requirements, we suggest that point (a) is re-worded as
'within Flood Zone 2 or 3 or proposals of 1 hectare or greater in Flood zone 1, as defined on the Environment Agency's Flood Map for Planning'.
The mapping in Warwick District Council‟s SFRA level 1 is based on our Flood Map. The SFRA report states that it is a "living" document and should be reviewed on a regular basis. Our Flood Map for Planning is updated on a quarterly basis to incorporate improved river models etc and this should be reflected in the SFRA document.
However, if there are no plans to update the SFRA maps on a quarterly basis in line with our Flood Map updates, then we recommend that our Flood Map is considered the best available information or until such time as a level 2 SFRA is produced. Recommend that bullet points are used in this section so as to avoid confusion with the numbering system used in the criteria part of the policy. Paragraph 5.131 Our "Flood Map for Planning" replaced the indicative flood zone maps and should be referred to in this paragraph. FW2 Sustainable Urban Drainage We recommend that the title of this policy is re-worded to 'Sustainable Drainage' as the sustainable drainage applies to both greenfield and brownfield sites.
In the first paragraph "Sustainable Urban Drainage Systems (SUDS)" should be replaced with „Sustainable Drainage Systems (SuDS)‟ as they are now known.
The retrofitting of SuDS onto existing drainage systems should be a requirement for developments where it is not possible to install an entirely new system. Recommend that the following text is added to point c):
'ecological networks and informal recreation'
Suggest that the middle paragraph of this policy is re-worded as follows to make it clearer on the surface water hierarchy and that surface water discharge should be limited to greenfield runoff rate for all points of discharge:
„Surface water runoff should be managed as close to its source as possible in line with the following drainage hierarchy: i. Discharge into the ground (infiltration) unless it is demonstrated by infiltration tests and groundwater levels that infiltration is not possible. ii. Discharge to a surface water body. iii. Discharge to a surface water sewer, highway drain or another drainage system. iv. Discharge to a combined sewer. Above ground storage, such as balancing ponds, should be considered in preference to below ground attenuation, due to the water quality and biodiversity benefits they offer. For all sites, surface water discharge rate should be limited to the site-specific greenfield runoff rate for all return periods up to the 1% (1 in 100 year) plus climate change event' We recommend that the paragraph which includes the text "In exceptional circumstances, where a sustainable drainage system....c) contributions will be made to off-site SuDS schemes" is removed.
This wording provides an unnecessary get out clause and could result in the delivery of unsustainable development, sustainable drainage systems take many different forms and there is no reason why a SuDS solution cannot be designed for every site.
We welcome the policy requirement for developers undertake groundwater risk assessment to ensure that groundwater quality is protected a result of development proposals. Subsequently any proposal involving infiltration SuDS schemes should be accompanied by contaminated land investigations to endure that site condition is appropriate.
For sites that are identified as significantly contaminated EA would require input into any SuDS schemes proposed for new development to determine the most appropriate schemes. This would be to safeguard groundwater quality.

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