Cubbington Neighbourhood Development Plan - Regulation 16 Submission

Comment

Representation ID: 87761

Received: 09/12/2024

Respondent: Warwickshire County Council

CNDP Objective 1 – To protect and
enhance green spaces - We support the protection of open spaces and river corridors – this could be developed to mention the benefits of open
space as flood risk management to retain water. Above ground SuDS could be utilised in open spaces.

Policy CNDP3 –Sustainable Design and Construction Point O - The policy states that all new developments uses existing watercourses and ditches, surface, sustainable drainage
systems (SUDS) to hold rainwater in storms. SuDS should be planted with native vegetation to support wildlife. All paving
should be semi-permeable to allow run-off to drain away.
If a site is over 1ha or for 10 or more dwellings, it is classed as a major planning application, therefore in line with the
National Planning Policy Framework, a site specific Flood Risk Assessment and Surface Water Drainage Strategy must be
submitted to the Lead Local Flood Authority for review.
You could add to your objective a specific point about new developments needing to consider their flood risk and
sustainable drainage systems when building on Greenfield and brownfield sites, as supported by the Sustainable drainage
systems chapter in the Planning Practise Guidance (PPG). A link has been detailed below:
https://www.gov.uk/guidance/flood-risk-and-coastal-change#sustainable-drainage-system
You could include an additional point that encourages new developments to open up any existing culverts on a site
providing more open space/green infrastructure for greater amenity and biodiversity; and the creation of new culverts
should be kept to a minimum. New culverts will need consent from the LLFA and should be kept to the minimum length

Policy CNDP3 –Sustainable Design and Construction
Point R - The document mentions new developments having appropriate car parking. Whilst wording has been amended and now
states surfaces should be permeable, further consideration may be given to the LLFA’s previous comments. Depending on
the size and type of drainage, there is an opportunity to introduce SuDS and adequate treatment for flows, to ensure that discharge/run off flows leaving the car park site do not degrade the quality of accepting water bodies, providing greater amenity.

Comment

Representation ID: 87762

Received: 09/12/2024

Respondent: Warwickshire County Council

Appendix 5 - We note that this policy lacks specific reference to surface water flood risk and development drainage apart from
Appendix 5. We strongly recommend consideration of the below points:
You could develop this point to include the SuDS hierarchy. The hierarchy is a list of preferred drainage options that the
LLFA refer to when reviewing planning applications. The preferred options are (in order of preference): infiltration (water
into the ground), discharging into an existing water body and discharging into a surface water sewer. Connecting to a
combined sewer system is not suitable and not favourable.
In this section it would be good to mention that all above ground attenuation features should be designed to be
multifunctional and consider the four pillars of SuDS which are water quality, water quantity, amenity and biodiversity.
A comment could be included to say all developments will be expected to include sustainable drainage systems and that
new developments need to consider their flood risk when building on Greenfield and brownfield sites, as supported by
the Sustainable drainage systems chapter in the Planning Practise Guidance (PPG). A link has been detailed below:
https://www.gov.uk/guidance/flood-risk-and-coastal-change#sustainable-drainage-systems
You have included references to the NPPF and Core Strategy Policies. WCC FRM have their own Local Guidance for
Developers which may be worth including in the reference documents. A link has been detailed below:
https://api.warwickshire.gov.uk/documents/WCCC-1039-95

Comment

Representation ID: 87763

Received: 09/12/2024

Respondent: Warwickshire County Council

QV S3.1 - You could add to your objective a specific point about new developments needing to consider their flood risk and sustainable drainage systems when building on Greenfield and brownfield sites