Revised Development Strategy

WARWICK DISTRICT COUNCIL LOCAL PLAN

REVISED DEVELOPMENT STRATEGY - JUNE 2013

Thank you for referring the above consultation which was received via email on 17 June 2013.

We note from paragraph 1.4 of the proposals that this document does not intend to fully address all the issues to be addressed by the Local Plan, but to provide opportunity to comment on the revised development locations bought forward as a result of an expanding evidence base and the outcome of last year's public consultation. In light of this, the Environment Agency is focussing its comments on the development locations identified within this plan. We trust that these comments shall be read alongside our advice on policy development included within our previous response of 03 August 2012 in response to your Preferred Options consultation. We do however have some additional comments to make regarding the implementation of the Water Framework Directive which we have included at the end.

Sites South of Warwick and Whitnash
The southern boundary of this site is defined by the Tach Brook and its associated floodplain. The Sequential Approach to flood risk management outlined within the NPPF and Tables 1, 2 and 3 of the supporting Technical Guide should be applied to ensure that new development is directed towards the areas of lowest risk, and only proposed in areas of floodplain if it is absolutely necessary. Map 3 shows the proposed extent of Country Park at this location, which completely encompasses the area shown to flood. We support this approach to land use allocation as it ensures vulnerable development is steered away from this area of risk, and that an unobstructed river corridor is maintained for flood risk and habitat benefit.

The Tach Brook flood extent was produced using our National Generalised Modelling therefore whilst the modelling process did provide some information on depth / level of water to provide an indicative floodplain, they are not suitable for use in the detailed allocation of sites or to an inform a planning permission. Providing that the Local Plan confirms the extent of development will not encroach into this floodplain (including the medium risk Flood Zone 2 as well as Flood Zone 3) then this should not pose a problem at this stage, however we do recommend that when this site is taken forward accurate modelling of this watercourse should be undertaken to confirm the extent of risk and inform detailed proposals relating to the design and layout of the county park. This may form part of a Level 2 Strategic Flood Risk Assessment (SFRA).

The corridor of the Tach Brook forms part of the River Avon Local Wildlife Site. Para 5.1.10 and 5.1.20 outline the proposals for habitat and recreation. Any development should look to preserve enhance the river corridor. This waterbody (the Tach Brook from Source to confluence of River Avon) is currently defined within the Severn River Basin Management Plan (RBMP) as being of Poor Ecological Status under the Water Framework Directive (WFD). As such a key objective in planning this area should be to create and enhance its water-based biodiversity and potential for biodiversity in line with the local objectives included within the Severn RBMP. In light of this, the blue infrastructure of the rivers and brooks in the area and their associated riparian habitat should be integral in any green infrastructure planning.

The proposal to include a country park on the southern side of the development is welcome and will hopefully provide an area for rainwater infiltration and a buffer to surface water run off. However, we recommend that in order to provide maximum environmental benefits for the Tach Brook, the park should be extended to cover the whole southern perimeter of the development so that the full length of the Tach Brook is afforded the best possible protection from pollution and potential for improvement. If a formal extension of the country park would not be possible to the east of Europa Way then as a minimum we would require an undeveloped buffer zone along the river bank which should be informed by site-specific modelling. This would be additional to and not replace the SUDS schemes which should be employed across the entire strategic development plan.

In addition to the main Tach Brook there is a small tributary located at Grid Reference 430081 263267 which is connected to the main channel with modelled Flood Zone 2 and has no modelled floodplain further upstream of Europa Way. We recommend that an 8m continuous easement is maintained from the unmodelled channel and that the area defined as Flood Zone 2 is to be undeveloped. You may wish to assess this area in more detail as part of a Level 2 SFRA.

The other watercourse that affects this development area is the Myton Brook which flows in a northerly direction from Europa Way past Brook Farm, Cottage Farm and Saumur Way. This watercourse does not appear to be considered within the proposals (although it is noted within the SA). The Myton Brook has been modelled in detail, however the model extent only covers the length of the watercourse classified as Main River, and as such, the flood risk that this watercourse poses to the proposed area of development is unknown. Furthermore, the Myton Brook includes approximately 170 metres of culverted channel which poses a barrier to ecological migration and potentially increases flood risk. The condition of this culvert is unknown. Whilst the contributing area to the watercourse is likely to be small, and therefore flood flows also likely to be small, we recommend that the risk from the watercourse in this area is quantified through a Level 2 SFRA. No development should take place within an 8m easement of the culvert, and opportunities to remove the culvert and restore it to a natural channel within a green corridor should be explored in line with WFD and flood risk objectives.

We are aware that there are existing surface water flooding problems in the area, as flagged up by concerned local residents in The Malins and Myton Crescent. We question whether a Surface Water Management Plan would be of use to support these broad allocations, as there may be other areas which have similar concerns. Recommendation Sev 11/8 of the Severn Catchment Flood Management Plan recommends as an action that investigations are undertaken into areas most prone to flooding and that an assessment should be undertaken of the allowable discharge rates from new developments.

In our response of 11 November 2010 to your draft Water Topic Paper we gave the following advice:

A number of areas within the district suffer from surface water flooding, and as such, the WCS makes a number of recommendations regarding surface water drainage. The Environment Agency's current requirements with regards to surface run-off limitation is that previously undeveloped sites have their surface drainage attenuated to the greenfield run-off rate (i.e. the same as before), whereas brownfield sites should as a minimum reduce their surface runoff by 20% in order to provide a betterment and allow for the impacts of climate change.

In areas which already have surface flooding problems or are at the top of sensitive river catchments, we are increasingly looking for all development sites (including brownfield) to attenuate to greenfield rates in order to provide sufficient betterment to local communities, moving towards reducing or even eliminating existing flooding problems. This could be something that is appropriate for the characteristics of your district; however, this will require more water to be held back on development sites and could deter some developers due to cost implications. This needs to be carefully weighed up, as failure to act now may worsen the overall effects of flooding in Warwick in the future, increasing the overall economic and social price of flood risk long-term.

In light of this we would encourage you to consider undertaking a Surface Water Management Plan (SWMP) to investigate these issues more fully, and to inform your LDF allocations and policies, allowing well-informed decisions to be made which provide he greatest benefit to the district's circumstances. Guidance on this can be found at http://www.defra.gov.uk/environment/flooding/manage/surfacewater/plans.htm.

Michael Green of Warwickshire's Lead Local Flood Authority would be best place to advise on this issue and make any appropriate recommendations.

Whitnash and South of Sydenham
The eastern boundary of the site is within Flood Zone 2 and Flood Zone 3 of the Whitnash Brook. The Sequential Approach to flood risk management outlined within the NPPF and Tables 1, 2 and 3 of the supporting Technical Guide should be applied to ensure that new development is directed towards the areas of lowest risk, and only proposed in areas of floodplain if it is absolutely necessary. Map 4 shows a Local Wildlife Site buffer along the line of the watercourse and including its indicative floodplain. We support this approach to protecting the watercourse and the surrounding Local Nature Reserve as it ensures vulnerable development is steered away from this area of risk and that an unobstructed river corridor is maintained for flood risk and habitat benefit.

The Whitnash Brook flood extent was produced using our National Generalised Modelling therefore whilst the modelling process did provide some information on depth / level of water to provide an indicative floodplain, they are not suitable for use in the detailed allocation of sites or to an inform a planning permission. Providing that the Local Plan confirms the extent of development will not encroach into this floodplain (including the medium risk Flood Zone 2 as well as Flood Zone 3) then this should not pose a problem at this stage. It is noted from paragraph 5.2.15 that this buffer zone will be used for enhancing the ecological value of the area and providing recreational space along the southern section. Dependant on the nature of works proposed within this buffer zone for recreational space then accurate modelling of this watercourse could be undertaken to confirm the extent of inundation from the Whitnash Brook and to accommodate this within any proposals. This may form part of a Level 2 SFRA.

Any works in this location should look to preserve and enhance the river corridor. This WFD waterbody (Radford Brook from source to confluence of River Leam) is currently classed as Good Ecological Status therefore our focus (and that of the plan) should be to retain the high quality environment and not allow any deterioration. In light of this we would welcome a significant buffer between any new development and the nature reserve. Regardless of the presence or absence of water voles, the larger the buffer the better to prevent disturbance to the watercourse, allow for the effects of out of bank flows and to and reduce the risk of polluted runoff entering the brook.

Red House Farm, Leamington
The site is entirely located within low risk Flood Zone 1 and is situated 750-800 metres away from the River Leam. We therefore have no fluvial flood risk concerns for this site, but we do welcome the proposals within para 5.3.17 to create improved access to the associated wetland habitat creation project.

Thickthorn, Kenilworth
The site is entirely located within Flood Zone 1 and is situated 1200 metres away from the nearest watercourse, the River Leam. We have no fluvial flood risk concerns for this site.

Sustainability Appraisal
We have reviewed the supporting Final Interim Sustainability Report submitted in support of these proposals and consider that the impacts of development in these locations are fairly represented. Appendix 1 section 9 To Create Good Quality Air, Water and Soils, the question "Will it prevent deterioration of water quality as measured by the Water Framework Directive?" should be included, with the associated indicator being "Water Framework Directive measures of water quality in local rivers".

Evidence Base
We draw your attention to the recommendations in Section 11 of your new updated Level 1 SFRA undertaken by Mouchel in April 2013, and advise that these are cross-referenced with your draft policies last consulted upon in August 2012 (prior to this publication) to ensure they are as locally specific and up to date as possible.

Your Halcrow Water Cycle Study of 2010 makes the following recommendations regarding some of these sites. We advise that Severn Trent Water Ltd comment on these change in development areas and advise as to any considerations that need to be allowed for in terms of foul infrastructure availability and timing.

Downstream of the Land at South Sydenham and East of Whitnash, Land at Red House Farm Campion Hill and Land North of Milverton there are significant network capacity constraints. Capacity improvements to alleviate this flooding problem are currently being appraised as part of Severn Trent's sewer flooding investment programme. Further hydraulic analysis will be required to assess the impact of this development on sewer capacity. The phasing of development should consider the delivery of this infrastructure.

Since the previous consultation on the Local Plan the Environment Agency has done a significant amount of work in relation to WFD in this area and its implementation through the Humber and the Severn RBMP. Please see the attached table which details the waterbodies within your district boundaries, their current status, reasons for failure, predicted status for 2015 and targets status for 2027. We are currently identifying specific actions for each waterbody which are needed to be undertaken by various bodies to bring the waterbodies up to the required status. We welcome the acknowledgement of WFD in support of Policy PO18, however feel that implementation of this should be supported by an inclusion within the body of a policy itself. We do not as yet have detailed actions supported by evidence, therefore are not yet in a position to provide detailed WFD policy recommendations for your plan. In light of this advise that an overarching policy is put in place, possibly within Policy PO18.

Prior to the revocation of the WMRSS, the Phase Two Revision Panel report (Sept 2009) contained a recommendation to amend the current policy QE.9 (Water Environment) to "have regard to the actions and objectives of the Severn and Humber River Basin Management Plans. " We consider that a similar commitment would be appropriate for your Local Plan policies as it allows for a wide range of considerations to be implemented through the planning system, including deculverting, bankside improvement works, buffer zones, habitat improvements, surface water runoff control, foul drainage considerations both for main and on-main systems, flood risk management and water resources management.

The Environment Agency has been working with Sustainability West Midlands to provide some guidance to LPAs as to how you can contribute towards WFD success through your different council functions, and to provide specific advice for strategic plan making and development control decisions. These are available on the following links:

Summary Note:
https://publications.environment-agency.gov.uk/skeleton/publications/ViewPublication.aspx?id=e4cef733-e366-4969-a57c-3b5fbbc722b6

Full Document:
https://publications.environment-agency.gov.uk/skeleton/publications/ViewPublication.aspx?id=4e8c5eee-9804-4571-b911-70dc8b9af063

If you have any queries about the above comments please let us know on the details below. We are happy to meet to discuss or to comment on draft wording prior to the publication of your Submission draft.

WARWICK DISTRICT COUNCIL LOCAL PLAN

REVISED DEVELOPMENT STRATEGY - JUNE 2013

Thank you for referring the above consultation which was received via email on 17 June 2013.

We note from paragraph 1.4 of the proposals that this document does not intend to fully address all the issues to be addressed by the Local Plan, but to provide opportunity to comment on the revised development locations bought forward as a result of an expanding evidence base and the outcome of last year's public consultation. In light of this, the Environment Agency is focussing its comments on the development locations identified within this plan. We trust that these comments shall be read alongside our advice on policy development included within our previous response of 03 August 2012 in response to your Preferred Options consultation. We do however have some additional comments to make regarding the implementation of the Water Framework Directive which we have included at the end.

Sites South of Warwick and Whitnash
The southern boundary of this site is defined by the Tach Brook and its associated floodplain. The Sequential Approach to flood risk management outlined within the NPPF and Tables 1, 2 and 3 of the supporting Technical Guide should be applied to ensure that new development is directed towards the areas of lowest risk, and only proposed in areas of floodplain if it is absolutely necessary. Map 3 shows the proposed extent of Country Park at this location, which completely encompasses the area shown to flood. We support this approach to land use allocation as it ensures vulnerable development is steered away from this area of risk, and that an unobstructed river corridor is maintained for flood risk and habitat benefit.

The Tach Brook flood extent was produced using our National Generalised Modelling therefore whilst the modelling process did provide some information on depth / level of water to provide an indicative floodplain, they are not suitable for use in the detailed allocation of sites or to an inform a planning permission. Providing that the Local Plan confirms the extent of development will not encroach into this floodplain (including the medium risk Flood Zone 2 as well as Flood Zone 3) then this should not pose a problem at this stage, however we do recommend that when this site is taken forward accurate modelling of this watercourse should be undertaken to confirm the extent of risk and inform detailed proposals relating to the design and layout of the county park. This may form part of a Level 2 Strategic Flood Risk Assessment (SFRA).

The corridor of the Tach Brook forms part of the River Avon Local Wildlife Site. Para 5.1.10 and 5.1.20 outline the proposals for habitat and recreation. Any development should look to preserve enhance the river corridor. This waterbody (the Tach Brook from Source to confluence of River Avon) is currently defined within the Severn River Basin Management Plan (RBMP) as being of Poor Ecological Status under the Water Framework Directive (WFD). As such a key objective in planning this area should be to create and enhance its water-based biodiversity and potential for biodiversity in line with the local objectives included within the Severn RBMP. In light of this, the blue infrastructure of the rivers and brooks in the area and their associated riparian habitat should be integral in any green infrastructure planning.

The proposal to include a country park on the southern side of the development is welcome and will hopefully provide an area for rainwater infiltration and a buffer to surface water run off. However, we recommend that in order to provide maximum environmental benefits for the Tach Brook, the park should be extended to cover the whole southern perimeter of the development so that the full length of the Tach Brook is afforded the best possible protection from pollution and potential for improvement. If a formal extension of the country park would not be possible to the east of Europa Way then as a minimum we would require an undeveloped buffer zone along the river bank which should be informed by site-specific modelling. This would be additional to and not replace the SUDS schemes which should be employed across the entire strategic development plan.

In addition to the main Tach Brook there is a small tributary located at Grid Reference 430081 263267 which is connected to the main channel with modelled Flood Zone 2 and has no modelled floodplain further upstream of Europa Way. We recommend that an 8m continuous easement is maintained from the unmodelled channel and that the area defined as Flood Zone 2 is to be undeveloped. You may wish to assess this area in more detail as part of a Level 2 SFRA.

The other watercourse that affects this development area is the Myton Brook which flows in a northerly direction from Europa Way past Brook Farm, Cottage Farm and Saumur Way. This watercourse does not appear to be considered within the proposals (although it is noted within the SA). The Myton Brook has been modelled in detail, however the model extent only covers the length of the watercourse classified as Main River, and as such, the flood risk that this watercourse poses to the proposed area of development is unknown. Furthermore, the Myton Brook includes approximately 170 metres of culverted channel which poses a barrier to ecological migration and potentially increases flood risk. The condition of this culvert is unknown. Whilst the contributing area to the watercourse is likely to be small, and therefore flood flows also likely to be small, we recommend that the risk from the watercourse in this area is quantified through a Level 2 SFRA. No development should take place within an 8m easement of the culvert, and opportunities to remove the culvert and restore it to a natural channel within a green corridor should be explored in line with WFD and flood risk objectives.

We are aware that there are existing surface water flooding problems in the area, as flagged up by concerned local residents in The Malins and Myton Crescent. We question whether a Surface Water Management Plan would be of use to support these broad allocations, as there may be other areas which have similar concerns. Recommendation Sev 11/8 of the Severn Catchment Flood Management Plan recommends as an action that investigations are undertaken into areas most prone to flooding and that an assessment should be undertaken of the allowable discharge rates from new developments.

In our response of 11 November 2010 to your draft Water Topic Paper we gave the following advice:

A number of areas within the district suffer from surface water flooding, and as such, the WCS makes a number of recommendations regarding surface water drainage. The Environment Agency's current requirements with regards to surface run-off limitation is that previously undeveloped sites have their surface drainage attenuated to the greenfield run-off rate (i.e. the same as before), whereas brownfield sites should as a minimum reduce their surface runoff by 20% in order to provide a betterment and allow for the impacts of climate change.

In areas which already have surface flooding problems or are at the top of sensitive river catchments, we are increasingly looking for all development sites (including brownfield) to attenuate to greenfield rates in order to provide sufficient betterment to local communities, moving towards reducing or even eliminating existing flooding problems. This could be something that is appropriate for the characteristics of your district; however, this will require more water to be held back on development sites and could deter some developers due to cost implications. This needs to be carefully weighed up, as failure to act now may worsen the overall effects of flooding in Warwick in the future, increasing the overall economic and social price of flood risk long-term.

In light of this we would encourage you to consider undertaking a Surface Water Management Plan (SWMP) to investigate these issues more fully, and to inform your LDF allocations and policies, allowing well-informed decisions to be made which provide he greatest benefit to the district's circumstances. Guidance on this can be found at http://www.defra.gov.uk/environment/flooding/manage/surfacewater/plans.htm.

Michael Green of Warwickshire's Lead Local Flood Authority would be best place to advise on this issue and make any appropriate recommendations.

Whitnash and South of Sydenham
The eastern boundary of the site is within Flood Zone 2 and Flood Zone 3 of the Whitnash Brook. The Sequential Approach to flood risk management outlined within the NPPF and Tables 1, 2 and 3 of the supporting Technical Guide should be applied to ensure that new development is directed towards the areas of lowest risk, and only proposed in areas of floodplain if it is absolutely necessary. Map 4 shows a Local Wildlife Site buffer along the line of the watercourse and including its indicative floodplain. We support this approach to protecting the watercourse and the surrounding Local Nature Reserve as it ensures vulnerable development is steered away from this area of risk and that an unobstructed river corridor is maintained for flood risk and habitat benefit.

The Whitnash Brook flood extent was produced using our National Generalised Modelling therefore whilst the modelling process did provide some information on depth / level of water to provide an indicative floodplain, they are not suitable for use in the detailed allocation of sites or to an inform a planning permission. Providing that the Local Plan confirms the extent of development will not encroach into this floodplain (including the medium risk Flood Zone 2 as well as Flood Zone 3) then this should not pose a problem at this stage. It is noted from paragraph 5.2.15 that this buffer zone will be used for enhancing the ecological value of the area and providing recreational space along the southern section. Dependant on the nature of works proposed within this buffer zone for recreational space then accurate modelling of this watercourse could be undertaken to confirm the extent of inundation from the Whitnash Brook and to accommodate this within any proposals. This may form part of a Level 2 SFRA.

Any works in this location should look to preserve and enhance the river corridor. This WFD waterbody (Radford Brook from source to confluence of River Leam) is currently classed as Good Ecological Status therefore our focus (and that of the plan) should be to retain the high quality environment and not allow any deterioration. In light of this we would welcome a significant buffer between any new development and the nature reserve. Regardless of the presence or absence of water voles, the larger the buffer the better to prevent disturbance to the watercourse, allow for the effects of out of bank flows and to and reduce the risk of polluted runoff entering the brook.

Red House Farm, Leamington
The site is entirely located within low risk Flood Zone 1 and is situated 750-800 metres away from the River Leam. We therefore have no fluvial flood risk concerns for this site, but we do welcome the proposals within para 5.3.17 to create improved access to the associated wetland habitat creation project.

Thickthorn, Kenilworth
The site is entirely located within Flood Zone 1 and is situated 1200 metres away from the nearest watercourse, the River Leam. We have no fluvial flood risk concerns for this site.

Sustainability Appraisal
We have reviewed the supporting Final Interim Sustainability Report submitted in support of these proposals and consider that the impacts of development in these locations are fairly represented. Appendix 1 section 9 To Create Good Quality Air, Water and Soils, the question "Will it prevent deterioration of water quality as measured by the Water Framework Directive?" should be included, with the associated indicator being "Water Framework Directive measures of water quality in local rivers".

Evidence Base
We draw your attention to the recommendations in Section 11 of your new updated Level 1 SFRA undertaken by Mouchel in April 2013, and advise that these are cross-referenced with your draft policies last consulted upon in August 2012 (prior to this publication) to ensure they are as locally specific and up to date as possible.

Your Halcrow Water Cycle Study of 2010 makes the following recommendations regarding some of these sites. We advise that Severn Trent Water Ltd comment on these change in development areas and advise as to any considerations that need to be allowed for in terms of foul infrastructure availability and timing.

Downstream of the Land at South Sydenham and East of Whitnash, Land at Red House Farm Campion Hill and Land North of Milverton there are significant network capacity constraints. Capacity improvements to alleviate this flooding problem are currently being appraised as part of Severn Trent's sewer flooding investment programme. Further hydraulic analysis will be required to assess the impact of this development on sewer capacity. The phasing of development should consider the delivery of this infrastructure.

Since the previous consultation on the Local Plan the Environment Agency has done a significant amount of work in relation to WFD in this area and its implementation through the Humber and the Severn RBMP. Please see the attached table which details the waterbodies within your district boundaries, their current status, reasons for failure, predicted status for 2015 and targets status for 2027. We are currently identifying specific actions for each waterbody which are needed to be undertaken by various bodies to bring the waterbodies up to the required status. We welcome the acknowledgement of WFD in support of Policy PO18, however feel that implementation of this should be supported by an inclusion within the body of a policy itself. We do not as yet have detailed actions supported by evidence, therefore are not yet in a position to provide detailed WFD policy recommendations for your plan. In light of this advise that an overarching policy is put in place, possibly within Policy PO18.

Prior to the revocation of the WMRSS, the Phase Two Revision Panel report (Sept 2009) contained a recommendation to amend the current policy QE.9 (Water Environment) to "have regard to the actions and objectives of the Severn and Humber River Basin Management Plans. " We consider that a similar commitment would be appropriate for your Local Plan policies as it allows for a wide range of considerations to be implemented through the planning system, including deculverting, bankside improvement works, buffer zones, habitat improvements, surface water runoff control, foul drainage considerations both for main and on-main systems, flood risk management and water resources management.

The Environment Agency has been working with Sustainability West Midlands to provide some guidance to LPAs as to how you can contribute towards WFD success through your different council functions, and to provide specific advice for strategic plan making and development control decisions. These are available on the following links:

Summary Note:
https://publications.environment-agency.gov.uk/skeleton/publications/ViewPublication.aspx?id=e4cef733-e366-4969-a57c-3b5fbbc722b6

Full Document:
https://publications.environment-agency.gov.uk/skeleton/publications/ViewPublication.aspx?id=4e8c5eee-9804-4571-b911-70dc8b9af063

If you have any queries about the above comments please let us know on the details below. We are happy to meet to discuss or to comment on draft wording prior to the publication of your Submission draft.

WARWICK DISTRICT COUNCIL LOCAL PLAN

REVISED DEVELOPMENT STRATEGY - JUNE 2013

Thank you for referring the above consultation which was received via email on 17 June 2013.

We note from paragraph 1.4 of the proposals that this document does not intend to fully address all the issues to be addressed by the Local Plan, but to provide opportunity to comment on the revised development locations bought forward as a result of an expanding evidence base and the outcome of last year's public consultation. In light of this, the Environment Agency is focussing its comments on the development locations identified within this plan. We trust that these comments shall be read alongside our advice on policy development included within our previous response of 03 August 2012 in response to your Preferred Options consultation. We do however have some additional comments to make regarding the implementation of the Water Framework Directive which we have included at the end.

Sites South of Warwick and Whitnash
The southern boundary of this site is defined by the Tach Brook and its associated floodplain. The Sequential Approach to flood risk management outlined within the NPPF and Tables 1, 2 and 3 of the supporting Technical Guide should be applied to ensure that new development is directed towards the areas of lowest risk, and only proposed in areas of floodplain if it is absolutely necessary. Map 3 shows the proposed extent of Country Park at this location, which completely encompasses the area shown to flood. We support this approach to land use allocation as it ensures vulnerable development is steered away from this area of risk, and that an unobstructed river corridor is maintained for flood risk and habitat benefit.

The Tach Brook flood extent was produced using our National Generalised Modelling therefore whilst the modelling process did provide some information on depth / level of water to provide an indicative floodplain, they are not suitable for use in the detailed allocation of sites or to an inform a planning permission. Providing that the Local Plan confirms the extent of development will not encroach into this floodplain (including the medium risk Flood Zone 2 as well as Flood Zone 3) then this should not pose a problem at this stage, however we do recommend that when this site is taken forward accurate modelling of this watercourse should be undertaken to confirm the extent of risk and inform detailed proposals relating to the design and layout of the county park. This may form part of a Level 2 Strategic Flood Risk Assessment (SFRA).

The corridor of the Tach Brook forms part of the River Avon Local Wildlife Site. Para 5.1.10 and 5.1.20 outline the proposals for habitat and recreation. Any development should look to preserve enhance the river corridor. This waterbody (the Tach Brook from Source to confluence of River Avon) is currently defined within the Severn River Basin Management Plan (RBMP) as being of Poor Ecological Status under the Water Framework Directive (WFD). As such a key objective in planning this area should be to create and enhance its water-based biodiversity and potential for biodiversity in line with the local objectives included within the Severn RBMP. In light of this, the blue infrastructure of the rivers and brooks in the area and their associated riparian habitat should be integral in any green infrastructure planning.

The proposal to include a country park on the southern side of the development is welcome and will hopefully provide an area for rainwater infiltration and a buffer to surface water run off. However, we recommend that in order to provide maximum environmental benefits for the Tach Brook, the park should be extended to cover the whole southern perimeter of the development so that the full length of the Tach Brook is afforded the best possible protection from pollution and potential for improvement. If a formal extension of the country park would not be possible to the east of Europa Way then as a minimum we would require an undeveloped buffer zone along the river bank which should be informed by site-specific modelling. This would be additional to and not replace the SUDS schemes which should be employed across the entire strategic development plan.

In addition to the main Tach Brook there is a small tributary located at Grid Reference 430081 263267 which is connected to the main channel with modelled Flood Zone 2 and has no modelled floodplain further upstream of Europa Way. We recommend that an 8m continuous easement is maintained from the unmodelled channel and that the area defined as Flood Zone 2 is to be undeveloped. You may wish to assess this area in more detail as part of a Level 2 SFRA.

The other watercourse that affects this development area is the Myton Brook which flows in a northerly direction from Europa Way past Brook Farm, Cottage Farm and Saumur Way. This watercourse does not appear to be considered within the proposals (although it is noted within the SA). The Myton Brook has been modelled in detail, however the model extent only covers the length of the watercourse classified as Main River, and as such, the flood risk that this watercourse poses to the proposed area of development is unknown. Furthermore, the Myton Brook includes approximately 170 metres of culverted channel which poses a barrier to ecological migration and potentially increases flood risk. The condition of this culvert is unknown. Whilst the contributing area to the watercourse is likely to be small, and therefore flood flows also likely to be small, we recommend that the risk from the watercourse in this area is quantified through a Level 2 SFRA. No development should take place within an 8m easement of the culvert, and opportunities to remove the culvert and restore it to a natural channel within a green corridor should be explored in line with WFD and flood risk objectives.

We are aware that there are existing surface water flooding problems in the area, as flagged up by concerned local residents in The Malins and Myton Crescent. We question whether a Surface Water Management Plan would be of use to support these broad allocations, as there may be other areas which have similar concerns. Recommendation Sev 11/8 of the Severn Catchment Flood Management Plan recommends as an action that investigations are undertaken into areas most prone to flooding and that an assessment should be undertaken of the allowable discharge rates from new developments.

In our response of 11 November 2010 to your draft Water Topic Paper we gave the following advice:

A number of areas within the district suffer from surface water flooding, and as such, the WCS makes a number of recommendations regarding surface water drainage. The Environment Agency's current requirements with regards to surface run-off limitation is that previously undeveloped sites have their surface drainage attenuated to the greenfield run-off rate (i.e. the same as before), whereas brownfield sites should as a minimum reduce their surface runoff by 20% in order to provide a betterment and allow for the impacts of climate change.

In areas which already have surface flooding problems or are at the top of sensitive river catchments, we are increasingly looking for all development sites (including brownfield) to attenuate to greenfield rates in order to provide sufficient betterment to local communities, moving towards reducing or even eliminating existing flooding problems. This could be something that is appropriate for the characteristics of your district; however, this will require more water to be held back on development sites and could deter some developers due to cost implications. This needs to be carefully weighed up, as failure to act now may worsen the overall effects of flooding in Warwick in the future, increasing the overall economic and social price of flood risk long-term.

In light of this we would encourage you to consider undertaking a Surface Water Management Plan (SWMP) to investigate these issues more fully, and to inform your LDF allocations and policies, allowing well-informed decisions to be made which provide he greatest benefit to the district's circumstances. Guidance on this can be found at http://www.defra.gov.uk/environment/flooding/manage/surfacewater/plans.htm.

Michael Green of Warwickshire's Lead Local Flood Authority would be best place to advise on this issue and make any appropriate recommendations.

Whitnash and South of Sydenham
The eastern boundary of the site is within Flood Zone 2 and Flood Zone 3 of the Whitnash Brook. The Sequential Approach to flood risk management outlined within the NPPF and Tables 1, 2 and 3 of the supporting Technical Guide should be applied to ensure that new development is directed towards the areas of lowest risk, and only proposed in areas of floodplain if it is absolutely necessary. Map 4 shows a Local Wildlife Site buffer along the line of the watercourse and including its indicative floodplain. We support this approach to protecting the watercourse and the surrounding Local Nature Reserve as it ensures vulnerable development is steered away from this area of risk and that an unobstructed river corridor is maintained for flood risk and habitat benefit.

The Whitnash Brook flood extent was produced using our National Generalised Modelling therefore whilst the modelling process did provide some information on depth / level of water to provide an indicative floodplain, they are not suitable for use in the detailed allocation of sites or to an inform a planning permission. Providing that the Local Plan confirms the extent of development will not encroach into this floodplain (including the medium risk Flood Zone 2 as well as Flood Zone 3) then this should not pose a problem at this stage. It is noted from paragraph 5.2.15 that this buffer zone will be used for enhancing the ecological value of the area and providing recreational space along the southern section. Dependant on the nature of works proposed within this buffer zone for recreational space then accurate modelling of this watercourse could be undertaken to confirm the extent of inundation from the Whitnash Brook and to accommodate this within any proposals. This may form part of a Level 2 SFRA.

Any works in this location should look to preserve and enhance the river corridor. This WFD waterbody (Radford Brook from source to confluence of River Leam) is currently classed as Good Ecological Status therefore our focus (and that of the plan) should be to retain the high quality environment and not allow any deterioration. In light of this we would welcome a significant buffer between any new development and the nature reserve. Regardless of the presence or absence of water voles, the larger the buffer the better to prevent disturbance to the watercourse, allow for the effects of out of bank flows and to and reduce the risk of polluted runoff entering the brook.

Red House Farm, Leamington
The site is entirely located within low risk Flood Zone 1 and is situated 750-800 metres away from the River Leam. We therefore have no fluvial flood risk concerns for this site, but we do welcome the proposals within para 5.3.17 to create improved access to the associated wetland habitat creation project.

Thickthorn, Kenilworth
The site is entirely located within Flood Zone 1 and is situated 1200 metres away from the nearest watercourse, the River Leam. We have no fluvial flood risk concerns for this site.

Sustainability Appraisal
We have reviewed the supporting Final Interim Sustainability Report submitted in support of these proposals and consider that the impacts of development in these locations are fairly represented. Appendix 1 section 9 To Create Good Quality Air, Water and Soils, the question "Will it prevent deterioration of water quality as measured by the Water Framework Directive?" should be included, with the associated indicator being "Water Framework Directive measures of water quality in local rivers".

Evidence Base
We draw your attention to the recommendations in Section 11 of your new updated Level 1 SFRA undertaken by Mouchel in April 2013, and advise that these are cross-referenced with your draft policies last consulted upon in August 2012 (prior to this publication) to ensure they are as locally specific and up to date as possible.

Your Halcrow Water Cycle Study of 2010 makes the following recommendations regarding some of these sites. We advise that Severn Trent Water Ltd comment on these change in development areas and advise as to any considerations that need to be allowed for in terms of foul infrastructure availability and timing.

Downstream of the Land at South Sydenham and East of Whitnash, Land at Red House Farm Campion Hill and Land North of Milverton there are significant network capacity constraints. Capacity improvements to alleviate this flooding problem are currently being appraised as part of Severn Trent's sewer flooding investment programme. Further hydraulic analysis will be required to assess the impact of this development on sewer capacity. The phasing of development should consider the delivery of this infrastructure.

Since the previous consultation on the Local Plan the Environment Agency has done a significant amount of work in relation to WFD in this area and its implementation through the Humber and the Severn RBMP. Please see the attached table which details the waterbodies within your district boundaries, their current status, reasons for failure, predicted status for 2015 and targets status for 2027. We are currently identifying specific actions for each waterbody which are needed to be undertaken by various bodies to bring the waterbodies up to the required status. We welcome the acknowledgement of WFD in support of Policy PO18, however feel that implementation of this should be supported by an inclusion within the body of a policy itself. We do not as yet have detailed actions supported by evidence, therefore are not yet in a position to provide detailed WFD policy recommendations for your plan. In light of this advise that an overarching policy is put in place, possibly within Policy PO18.

Prior to the revocation of the WMRSS, the Phase Two Revision Panel report (Sept 2009) contained a recommendation to amend the current policy QE.9 (Water Environment) to "have regard to the actions and objectives of the Severn and Humber River Basin Management Plans. " We consider that a similar commitment would be appropriate for your Local Plan policies as it allows for a wide range of considerations to be implemented through the planning system, including deculverting, bankside improvement works, buffer zones, habitat improvements, surface water runoff control, foul drainage considerations both for main and on-main systems, flood risk management and water resources management.

The Environment Agency has been working with Sustainability West Midlands to provide some guidance to LPAs as to how you can contribute towards WFD success through your different council functions, and to provide specific advice for strategic plan making and development control decisions. These are available on the following links:

Summary Note:
https://publications.environment-agency.gov.uk/skeleton/publications/ViewPublication.aspx?id=e4cef733-e366-4969-a57c-3b5fbbc722b6

Full Document:
https://publications.environment-agency.gov.uk/skeleton/publications/ViewPublication.aspx?id=4e8c5eee-9804-4571-b911-70dc8b9af063

If you have any queries about the above comments please let us know on the details below. We are happy to meet to discuss or to comment on draft wording prior to the publication of your Submission draft.

WARWICK DISTRICT COUNCIL LOCAL PLAN

REVISED DEVELOPMENT STRATEGY - JUNE 2013

Thank you for referring the above consultation which was received via email on 17 June 2013.

We note from paragraph 1.4 of the proposals that this document does not intend to fully address all the issues to be addressed by the Local Plan, but to provide opportunity to comment on the revised development locations bought forward as a result of an expanding evidence base and the outcome of last year's public consultation. In light of this, the Environment Agency is focussing its comments on the development locations identified within this plan. We trust that these comments shall be read alongside our advice on policy development included within our previous response of 03 August 2012 in response to your Preferred Options consultation. We do however have some additional comments to make regarding the implementation of the Water Framework Directive which we have included at the end.

Sites South of Warwick and Whitnash
The southern boundary of this site is defined by the Tach Brook and its associated floodplain. The Sequential Approach to flood risk management outlined within the NPPF and Tables 1, 2 and 3 of the supporting Technical Guide should be applied to ensure that new development is directed towards the areas of lowest risk, and only proposed in areas of floodplain if it is absolutely necessary. Map 3 shows the proposed extent of Country Park at this location, which completely encompasses the area shown to flood. We support this approach to land use allocation as it ensures vulnerable development is steered away from this area of risk, and that an unobstructed river corridor is maintained for flood risk and habitat benefit.

The Tach Brook flood extent was produced using our National Generalised Modelling therefore whilst the modelling process did provide some information on depth / level of water to provide an indicative floodplain, they are not suitable for use in the detailed allocation of sites or to an inform a planning permission. Providing that the Local Plan confirms the extent of development will not encroach into this floodplain (including the medium risk Flood Zone 2 as well as Flood Zone 3) then this should not pose a problem at this stage, however we do recommend that when this site is taken forward accurate modelling of this watercourse should be undertaken to confirm the extent of risk and inform detailed proposals relating to the design and layout of the county park. This may form part of a Level 2 Strategic Flood Risk Assessment (SFRA).

The corridor of the Tach Brook forms part of the River Avon Local Wildlife Site. Para 5.1.10 and 5.1.20 outline the proposals for habitat and recreation. Any development should look to preserve enhance the river corridor. This waterbody (the Tach Brook from Source to confluence of River Avon) is currently defined within the Severn River Basin Management Plan (RBMP) as being of Poor Ecological Status under the Water Framework Directive (WFD). As such a key objective in planning this area should be to create and enhance its water-based biodiversity and potential for biodiversity in line with the local objectives included within the Severn RBMP. In light of this, the blue infrastructure of the rivers and brooks in the area and their associated riparian habitat should be integral in any green infrastructure planning.

The proposal to include a country park on the southern side of the development is welcome and will hopefully provide an area for rainwater infiltration and a buffer to surface water run off. However, we recommend that in order to provide maximum environmental benefits for the Tach Brook, the park should be extended to cover the whole southern perimeter of the development so that the full length of the Tach Brook is afforded the best possible protection from pollution and potential for improvement. If a formal extension of the country park would not be possible to the east of Europa Way then as a minimum we would require an undeveloped buffer zone along the river bank which should be informed by site-specific modelling. This would be additional to and not replace the SUDS schemes which should be employed across the entire strategic development plan.

In addition to the main Tach Brook there is a small tributary located at Grid Reference 430081 263267 which is connected to the main channel with modelled Flood Zone 2 and has no modelled floodplain further upstream of Europa Way. We recommend that an 8m continuous easement is maintained from the unmodelled channel and that the area defined as Flood Zone 2 is to be undeveloped. You may wish to assess this area in more detail as part of a Level 2 SFRA.

The other watercourse that affects this development area is the Myton Brook which flows in a northerly direction from Europa Way past Brook Farm, Cottage Farm and Saumur Way. This watercourse does not appear to be considered within the proposals (although it is noted within the SA). The Myton Brook has been modelled in detail, however the model extent only covers the length of the watercourse classified as Main River, and as such, the flood risk that this watercourse poses to the proposed area of development is unknown. Furthermore, the Myton Brook includes approximately 170 metres of culverted channel which poses a barrier to ecological migration and potentially increases flood risk. The condition of this culvert is unknown. Whilst the contributing area to the watercourse is likely to be small, and therefore flood flows also likely to be small, we recommend that the risk from the watercourse in this area is quantified through a Level 2 SFRA. No development should take place within an 8m easement of the culvert, and opportunities to remove the culvert and restore it to a natural channel within a green corridor should be explored in line with WFD and flood risk objectives.

We are aware that there are existing surface water flooding problems in the area, as flagged up by concerned local residents in The Malins and Myton Crescent. We question whether a Surface Water Management Plan would be of use to support these broad allocations, as there may be other areas which have similar concerns. Recommendation Sev 11/8 of the Severn Catchment Flood Management Plan recommends as an action that investigations are undertaken into areas most prone to flooding and that an assessment should be undertaken of the allowable discharge rates from new developments.

In our response of 11 November 2010 to your draft Water Topic Paper we gave the following advice:

A number of areas within the district suffer from surface water flooding, and as such, the WCS makes a number of recommendations regarding surface water drainage. The Environment Agency's current requirements with regards to surface run-off limitation is that previously undeveloped sites have their surface drainage attenuated to the greenfield run-off rate (i.e. the same as before), whereas brownfield sites should as a minimum reduce their surface runoff by 20% in order to provide a betterment and allow for the impacts of climate change.

In areas which already have surface flooding problems or are at the top of sensitive river catchments, we are increasingly looking for all development sites (including brownfield) to attenuate to greenfield rates in order to provide sufficient betterment to local communities, moving towards reducing or even eliminating existing flooding problems. This could be something that is appropriate for the characteristics of your district; however, this will require more water to be held back on development sites and could deter some developers due to cost implications. This needs to be carefully weighed up, as failure to act now may worsen the overall effects of flooding in Warwick in the future, increasing the overall economic and social price of flood risk long-term.

In light of this we would encourage you to consider undertaking a Surface Water Management Plan (SWMP) to investigate these issues more fully, and to inform your LDF allocations and policies, allowing well-informed decisions to be made which provide he greatest benefit to the district's circumstances. Guidance on this can be found at http://www.defra.gov.uk/environment/flooding/manage/surfacewater/plans.htm.

Michael Green of Warwickshire's Lead Local Flood Authority would be best place to advise on this issue and make any appropriate recommendations.

Whitnash and South of Sydenham
The eastern boundary of the site is within Flood Zone 2 and Flood Zone 3 of the Whitnash Brook. The Sequential Approach to flood risk management outlined within the NPPF and Tables 1, 2 and 3 of the supporting Technical Guide should be applied to ensure that new development is directed towards the areas of lowest risk, and only proposed in areas of floodplain if it is absolutely necessary. Map 4 shows a Local Wildlife Site buffer along the line of the watercourse and including its indicative floodplain. We support this approach to protecting the watercourse and the surrounding Local Nature Reserve as it ensures vulnerable development is steered away from this area of risk and that an unobstructed river corridor is maintained for flood risk and habitat benefit.

The Whitnash Brook flood extent was produced using our National Generalised Modelling therefore whilst the modelling process did provide some information on depth / level of water to provide an indicative floodplain, they are not suitable for use in the detailed allocation of sites or to an inform a planning permission. Providing that the Local Plan confirms the extent of development will not encroach into this floodplain (including the medium risk Flood Zone 2 as well as Flood Zone 3) then this should not pose a problem at this stage. It is noted from paragraph 5.2.15 that this buffer zone will be used for enhancing the ecological value of the area and providing recreational space along the southern section. Dependant on the nature of works proposed within this buffer zone for recreational space then accurate modelling of this watercourse could be undertaken to confirm the extent of inundation from the Whitnash Brook and to accommodate this within any proposals. This may form part of a Level 2 SFRA.

Any works in this location should look to preserve and enhance the river corridor. This WFD waterbody (Radford Brook from source to confluence of River Leam) is currently classed as Good Ecological Status therefore our focus (and that of the plan) should be to retain the high quality environment and not allow any deterioration. In light of this we would welcome a significant buffer between any new development and the nature reserve. Regardless of the presence or absence of water voles, the larger the buffer the better to prevent disturbance to the watercourse, allow for the effects of out of bank flows and to and reduce the risk of polluted runoff entering the brook.

Red House Farm, Leamington
The site is entirely located within low risk Flood Zone 1 and is situated 750-800 metres away from the River Leam. We therefore have no fluvial flood risk concerns for this site, but we do welcome the proposals within para 5.3.17 to create improved access to the associated wetland habitat creation project.

Thickthorn, Kenilworth
The site is entirely located within Flood Zone 1 and is situated 1200 metres away from the nearest watercourse, the River Leam. We have no fluvial flood risk concerns for this site.

Sustainability Appraisal
We have reviewed the supporting Final Interim Sustainability Report submitted in support of these proposals and consider that the impacts of development in these locations are fairly represented. Appendix 1 section 9 To Create Good Quality Air, Water and Soils, the question "Will it prevent deterioration of water quality as measured by the Water Framework Directive?" should be included, with the associated indicator being "Water Framework Directive measures of water quality in local rivers".

Evidence Base
We draw your attention to the recommendations in Section 11 of your new updated Level 1 SFRA undertaken by Mouchel in April 2013, and advise that these are cross-referenced with your draft policies last consulted upon in August 2012 (prior to this publication) to ensure they are as locally specific and up to date as possible.

Your Halcrow Water Cycle Study of 2010 makes the following recommendations regarding some of these sites. We advise that Severn Trent Water Ltd comment on these change in development areas and advise as to any considerations that need to be allowed for in terms of foul infrastructure availability and timing.

Downstream of the Land at South Sydenham and East of Whitnash, Land at Red House Farm Campion Hill and Land North of Milverton there are significant network capacity constraints. Capacity improvements to alleviate this flooding problem are currently being appraised as part of Severn Trent's sewer flooding investment programme. Further hydraulic analysis will be required to assess the impact of this development on sewer capacity. The phasing of development should consider the delivery of this infrastructure.

Since the previous consultation on the Local Plan the Environment Agency has done a significant amount of work in relation to WFD in this area and its implementation through the Humber and the Severn RBMP. Please see the attached table which details the waterbodies within your district boundaries, their current status, reasons for failure, predicted status for 2015 and targets status for 2027. We are currently identifying specific actions for each waterbody which are needed to be undertaken by various bodies to bring the waterbodies up to the required status. We welcome the acknowledgement of WFD in support of Policy PO18, however feel that implementation of this should be supported by an inclusion within the body of a policy itself. We do not as yet have detailed actions supported by evidence, therefore are not yet in a position to provide detailed WFD policy recommendations for your plan. In light of this advise that an overarching policy is put in place, possibly within Policy PO18.

Prior to the revocation of the WMRSS, the Phase Two Revision Panel report (Sept 2009) contained a recommendation to amend the current policy QE.9 (Water Environment) to "have regard to the actions and objectives of the Severn and Humber River Basin Management Plans. " We consider that a similar commitment would be appropriate for your Local Plan policies as it allows for a wide range of considerations to be implemented through the planning system, including deculverting, bankside improvement works, buffer zones, habitat improvements, surface water runoff control, foul drainage considerations both for main and on-main systems, flood risk management and water resources management.

The Environment Agency has been working with Sustainability West Midlands to provide some guidance to LPAs as to how you can contribute towards WFD success through your different council functions, and to provide specific advice for strategic plan making and development control decisions. These are available on the following links:

Summary Note:
https://publications.environment-agency.gov.uk/skeleton/publications/ViewPublication.aspx?id=e4cef733-e366-4969-a57c-3b5fbbc722b6

Full Document:
https://publications.environment-agency.gov.uk/skeleton/publications/ViewPublication.aspx?id=4e8c5eee-9804-4571-b911-70dc8b9af063

If you have any queries about the above comments please let us know on the details below. We are happy to meet to discuss or to comment on draft wording prior to the publication of your Submission draft.

WARWICK DISTRICT COUNCIL LOCAL PLAN

REVISED DEVELOPMENT STRATEGY - JUNE 2013

Thank you for referring the above consultation which was received via email on 17 June 2013.

We note from paragraph 1.4 of the proposals that this document does not intend to fully address all the issues to be addressed by the Local Plan, but to provide opportunity to comment on the revised development locations bought forward as a result of an expanding evidence base and the outcome of last year's public consultation. In light of this, the Environment Agency is focussing its comments on the development locations identified within this plan. We trust that these comments shall be read alongside our advice on policy development included within our previous response of 03 August 2012 in response to your Preferred Options consultation. We do however have some additional comments to make regarding the implementation of the Water Framework Directive which we have included at the end.

Sites South of Warwick and Whitnash
The southern boundary of this site is defined by the Tach Brook and its associated floodplain. The Sequential Approach to flood risk management outlined within the NPPF and Tables 1, 2 and 3 of the supporting Technical Guide should be applied to ensure that new development is directed towards the areas of lowest risk, and only proposed in areas of floodplain if it is absolutely necessary. Map 3 shows the proposed extent of Country Park at this location, which completely encompasses the area shown to flood. We support this approach to land use allocation as it ensures vulnerable development is steered away from this area of risk, and that an unobstructed river corridor is maintained for flood risk and habitat benefit.

The Tach Brook flood extent was produced using our National Generalised Modelling therefore whilst the modelling process did provide some information on depth / level of water to provide an indicative floodplain, they are not suitable for use in the detailed allocation of sites or to an inform a planning permission. Providing that the Local Plan confirms the extent of development will not encroach into this floodplain (including the medium risk Flood Zone 2 as well as Flood Zone 3) then this should not pose a problem at this stage, however we do recommend that when this site is taken forward accurate modelling of this watercourse should be undertaken to confirm the extent of risk and inform detailed proposals relating to the design and layout of the county park. This may form part of a Level 2 Strategic Flood Risk Assessment (SFRA).

The corridor of the Tach Brook forms part of the River Avon Local Wildlife Site. Para 5.1.10 and 5.1.20 outline the proposals for habitat and recreation. Any development should look to preserve enhance the river corridor. This waterbody (the Tach Brook from Source to confluence of River Avon) is currently defined within the Severn River Basin Management Plan (RBMP) as being of Poor Ecological Status under the Water Framework Directive (WFD). As such a key objective in planning this area should be to create and enhance its water-based biodiversity and potential for biodiversity in line with the local objectives included within the Severn RBMP. In light of this, the blue infrastructure of the rivers and brooks in the area and their associated riparian habitat should be integral in any green infrastructure planning.

The proposal to include a country park on the southern side of the development is welcome and will hopefully provide an area for rainwater infiltration and a buffer to surface water run off. However, we recommend that in order to provide maximum environmental benefits for the Tach Brook, the park should be extended to cover the whole southern perimeter of the development so that the full length of the Tach Brook is afforded the best possible protection from pollution and potential for improvement. If a formal extension of the country park would not be possible to the east of Europa Way then as a minimum we would require an undeveloped buffer zone along the river bank which should be informed by site-specific modelling. This would be additional to and not replace the SUDS schemes which should be employed across the entire strategic development plan.

In addition to the main Tach Brook there is a small tributary located at Grid Reference 430081 263267 which is connected to the main channel with modelled Flood Zone 2 and has no modelled floodplain further upstream of Europa Way. We recommend that an 8m continuous easement is maintained from the unmodelled channel and that the area defined as Flood Zone 2 is to be undeveloped. You may wish to assess this area in more detail as part of a Level 2 SFRA.

The other watercourse that affects this development area is the Myton Brook which flows in a northerly direction from Europa Way past Brook Farm, Cottage Farm and Saumur Way. This watercourse does not appear to be considered within the proposals (although it is noted within the SA). The Myton Brook has been modelled in detail, however the model extent only covers the length of the watercourse classified as Main River, and as such, the flood risk that this watercourse poses to the proposed area of development is unknown. Furthermore, the Myton Brook includes approximately 170 metres of culverted channel which poses a barrier to ecological migration and potentially increases flood risk. The condition of this culvert is unknown. Whilst the contributing area to the watercourse is likely to be small, and therefore flood flows also likely to be small, we recommend that the risk from the watercourse in this area is quantified through a Level 2 SFRA. No development should take place within an 8m easement of the culvert, and opportunities to remove the culvert and restore it to a natural channel within a green corridor should be explored in line with WFD and flood risk objectives.

We are aware that there are existing surface water flooding problems in the area, as flagged up by concerned local residents in The Malins and Myton Crescent. We question whether a Surface Water Management Plan would be of use to support these broad allocations, as there may be other areas which have similar concerns. Recommendation Sev 11/8 of the Severn Catchment Flood Management Plan recommends as an action that investigations are undertaken into areas most prone to flooding and that an assessment should be undertaken of the allowable discharge rates from new developments.

In our response of 11 November 2010 to your draft Water Topic Paper we gave the following advice:

A number of areas within the district suffer from surface water flooding, and as such, the WCS makes a number of recommendations regarding surface water drainage. The Environment Agency's current requirements with regards to surface run-off limitation is that previously undeveloped sites have their surface drainage attenuated to the greenfield run-off rate (i.e. the same as before), whereas brownfield sites should as a minimum reduce their surface runoff by 20% in order to provide a betterment and allow for the impacts of climate change.

In areas which already have surface flooding problems or are at the top of sensitive river catchments, we are increasingly looking for all development sites (including brownfield) to attenuate to greenfield rates in order to provide sufficient betterment to local communities, moving towards reducing or even eliminating existing flooding problems. This could be something that is appropriate for the characteristics of your district; however, this will require more water to be held back on development sites and could deter some developers due to cost implications. This needs to be carefully weighed up, as failure to act now may worsen the overall effects of flooding in Warwick in the future, increasing the overall economic and social price of flood risk long-term.

In light of this we would encourage you to consider undertaking a Surface Water Management Plan (SWMP) to investigate these issues more fully, and to inform your LDF allocations and policies, allowing well-informed decisions to be made which provide he greatest benefit to the district's circumstances. Guidance on this can be found at http://www.defra.gov.uk/environment/flooding/manage/surfacewater/plans.htm.

Michael Green of Warwickshire's Lead Local Flood Authority would be best place to advise on this issue and make any appropriate recommendations.

Whitnash and South of Sydenham
The eastern boundary of the site is within Flood Zone 2 and Flood Zone 3 of the Whitnash Brook. The Sequential Approach to flood risk management outlined within the NPPF and Tables 1, 2 and 3 of the supporting Technical Guide should be applied to ensure that new development is directed towards the areas of lowest risk, and only proposed in areas of floodplain if it is absolutely necessary. Map 4 shows a Local Wildlife Site buffer along the line of the watercourse and including its indicative floodplain. We support this approach to protecting the watercourse and the surrounding Local Nature Reserve as it ensures vulnerable development is steered away from this area of risk and that an unobstructed river corridor is maintained for flood risk and habitat benefit.

The Whitnash Brook flood extent was produced using our National Generalised Modelling therefore whilst the modelling process did provide some information on depth / level of water to provide an indicative floodplain, they are not suitable for use in the detailed allocation of sites or to an inform a planning permission. Providing that the Local Plan confirms the extent of development will not encroach into this floodplain (including the medium risk Flood Zone 2 as well as Flood Zone 3) then this should not pose a problem at this stage. It is noted from paragraph 5.2.15 that this buffer zone will be used for enhancing the ecological value of the area and providing recreational space along the southern section. Dependant on the nature of works proposed within this buffer zone for recreational space then accurate modelling of this watercourse could be undertaken to confirm the extent of inundation from the Whitnash Brook and to accommodate this within any proposals. This may form part of a Level 2 SFRA.

Any works in this location should look to preserve and enhance the river corridor. This WFD waterbody (Radford Brook from source to confluence of River Leam) is currently classed as Good Ecological Status therefore our focus (and that of the plan) should be to retain the high quality environment and not allow any deterioration. In light of this we would welcome a significant buffer between any new development and the nature reserve. Regardless of the presence or absence of water voles, the larger the buffer the better to prevent disturbance to the watercourse, allow for the effects of out of bank flows and to and reduce the risk of polluted runoff entering the brook.

Red House Farm, Leamington
The site is entirely located within low risk Flood Zone 1 and is situated 750-800 metres away from the River Leam. We therefore have no fluvial flood risk concerns for this site, but we do welcome the proposals within para 5.3.17 to create improved access to the associated wetland habitat creation project.

Thickthorn, Kenilworth
The site is entirely located within Flood Zone 1 and is situated 1200 metres away from the nearest watercourse, the River Leam. We have no fluvial flood risk concerns for this site.

Sustainability Appraisal
We have reviewed the supporting Final Interim Sustainability Report submitted in support of these proposals and consider that the impacts of development in these locations are fairly represented. Appendix 1 section 9 To Create Good Quality Air, Water and Soils, the question "Will it prevent deterioration of water quality as measured by the Water Framework Directive?" should be included, with the associated indicator being "Water Framework Directive measures of water quality in local rivers".

Evidence Base
We draw your attention to the recommendations in Section 11 of your new updated Level 1 SFRA undertaken by Mouchel in April 2013, and advise that these are cross-referenced with your draft policies last consulted upon in August 2012 (prior to this publication) to ensure they are as locally specific and up to date as possible.

Your Halcrow Water Cycle Study of 2010 makes the following recommendations regarding some of these sites. We advise that Severn Trent Water Ltd comment on these change in development areas and advise as to any considerations that need to be allowed for in terms of foul infrastructure availability and timing.

Downstream of the Land at South Sydenham and East of Whitnash, Land at Red House Farm Campion Hill and Land North of Milverton there are significant network capacity constraints. Capacity improvements to alleviate this flooding problem are currently being appraised as part of Severn Trent's sewer flooding investment programme. Further hydraulic analysis will be required to assess the impact of this development on sewer capacity. The phasing of development should consider the delivery of this infrastructure.

Since the previous consultation on the Local Plan the Environment Agency has done a significant amount of work in relation to WFD in this area and its implementation through the Humber and the Severn RBMP. Please see the attached table which details the waterbodies within your district boundaries, their current status, reasons for failure, predicted status for 2015 and targets status for 2027. We are currently identifying specific actions for each waterbody which are needed to be undertaken by various bodies to bring the waterbodies up to the required status. We welcome the acknowledgement of WFD in support of Policy PO18, however feel that implementation of this should be supported by an inclusion within the body of a policy itself. We do not as yet have detailed actions supported by evidence, therefore are not yet in a position to provide detailed WFD policy recommendations for your plan. In light of this advise that an overarching policy is put in place, possibly within Policy PO18.

Prior to the revocation of the WMRSS, the Phase Two Revision Panel report (Sept 2009) contained a recommendation to amend the current policy QE.9 (Water Environment) to "have regard to the actions and objectives of the Severn and Humber River Basin Management Plans. " We consider that a similar commitment would be appropriate for your Local Plan policies as it allows for a wide range of considerations to be implemented through the planning system, including deculverting, bankside improvement works, buffer zones, habitat improvements, surface water runoff control, foul drainage considerations both for main and on-main systems, flood risk management and water resources management.

The Environment Agency has been working with Sustainability West Midlands to provide some guidance to LPAs as to how you can contribute towards WFD success through your different council functions, and to provide specific advice for strategic plan making and development control decisions. These are available on the following links:

Summary Note:
https://publications.environment-agency.gov.uk/skeleton/publications/ViewPublication.aspx?id=e4cef733-e366-4969-a57c-3b5fbbc722b6

Full Document:
https://publications.environment-agency.gov.uk/skeleton/publications/ViewPublication.aspx?id=4e8c5eee-9804-4571-b911-70dc8b9af063

If you have any queries about the above comments please let us know on the details below. We are happy to meet to discuss or to comment on draft wording prior to the publication of your Submission draft.