Ni roddwyd ateb

One big step forward that I considered that we had made in this country in recent decades was the way that rivers had been restored to a clean, healthy condition. However in recent years we seem to have taken some substantial steps backwards. From what I can gather it is because water companies (who make plenty of profit anyway) want to further increase this by doing the absolute bare minimum (and even less if they can) to safeguard the rivers. From what I have heard, this is completely preventable and it is totally unacceptable for this to happen in current times.

Given that garden watering using clean tap water is one of the avoidable problems in drought should there not be some provision for underground water capture and storage of excess (flood) water as well as reduction in flood risk and SuDs

As well as managing the impact of floods, developments should also seek to reduce their likelihood. For example prohibiting run off from drives and roofs into the sewerage system.

Flood risk is critical in many areas of South Warwickshire and this should be incoportated into the main Strategy documents.

The suggested development at Weston under Wetherley is on 2 farms which have floodplains. This is concerning for flooding further down the river but also the water run off if developed would potentially worsen the flooding of the bridge and pub that already occurs.

What about a more ecological approach. Managed wetlands perhaps? Beavers would be amazing but that’s probably very unlikely ☹️

The Policy Summary is based on siting development on areas of least risk as defined by Flood Zones 1-3. Flood zones 1-3 represent flood fluvial flood risk only ( river and brook floodplain as defined by EA mapping) Both the NPPF and your SFRA require development policy to consider all sources of flood risk not just fluvial flood risk. The Policy Summary should reflect this and policy should additionally state "That development in areas of low flood risk from all sources is the preferred option". Rationale: In UK more existing housing is affected by surface water flooding than fluvial flooding, and groundwater flooding is an increasing problem as developments have been permitted in areas at risk of these sources of flooding.

IMPORTANT WE HAVE GOOD FLOOD RISK CONTROLS AND DEFENCES

On behalf of Cubbington Parish Council Cubbington has historically been prone to flooding to the south west of the village and extensive flood alleviation work was undertaken at the Pingle Brook. Any development of land within this catchment, particularly in the green belt between Thwaites and Offchurch should not take place and is questionably unsustainable with significant obstacles to overcome. https://www.mcphillips.co.uk/projects/cubbington-flood-risk-management-warwickshire/ In addition, existing surface water flooding risks in the Kenilworth Road / Balmoral Way vicinity will be intensified with any development in the fields behind the Rugby Road or opposite Kenilworth Road. https://flood-warning-information.service.gov.uk/long-term-flood-risk/postcode https://flood-warning-information.service.gov.uk/long-term-flood-risk

Ni roddwyd ateb

Managing flood risk is vitality important to Alcester. There is currently a 1 in 75yr risk to approx 165 homes and businesses - this needs mitigating measures NOW - further development before these measures will exacerbate the issue.

The Policy Summary is based on siting development on areas of least risk as defined by Flood Zones 1-3. Flood zones 1-3 represent flood fluvial flood risk only ( river and brook floodplain as defined by EA mapping) Both the NPPF and your SFRA require development policy to consider all sources of flood risk not just fluvial flood risk. The Policy Summary should reflect this and policy should additionally state "That development in areas of low flood risk from all sources is the preferred option" Rationale: In UK more existing housing is affected by surface water flooding than fluvial flooding, and groundwater flooding is an increasing problem as developments have been permitted in areas at risk of these sources of flooding. The narrative to this consultation says that Level 2 SFRA will follow for individual development sites when identified. However to be truly Strategic there should be an analysis of the cumulative affects of development on flood risks from all sources. For example the broad flat floor of the Avon Valley, in the vicinity of Wellesbourne, is attracting major development proposals at the Warwickshire University Wellesbourne site and adjacent Wellesbourne Airfield, plus large housing developments attached to Wellesbourne built up area. These developments will all be built on the underlying geology which is an Aquifer, a permanent shallow water body that provides the base water flow to the River Avon. You cannot see it but it is there about 1-2 metres underground. A recent HYDROGEOLOGICAL AND HYDROLOGICAL ASSESSMENT FOR A PROPOSED SAND AND GRAVEL QUARRY AT WASPERTON, WARWICKSHIRE is part of a WCC planning application ( WDC/22CM008), this evidences how groundwater behaves in this aquifer. The overall groundwater flow direction is from the high ground to the East and South East towards the River Avon, indicating that groundwater and the river are in hydraulic continuity. The report also indicates impacts of disturbing the Aquifer and analysis that is required and mitigations. A plausible impact of this cumulative development on the Aquifer is that Groundwater levels will rise in other areas of the aquifer and cause groundwater flooding of existing properties as well as the new developments. A strategic plan is required to ensure impacts are identified and mitigation actions proposed.

IMPORTANT WE PLAN FOR ANY FUTURE FLOOD RISK CAUSED BT CLIMATE CHANGE

Managing flood risk vitally important to Alcester. Up to 165 homes and businesses could be affected by flooding. Need investment and protection NOW. This is currently preventing development coming forward.

Flood risk management must be introduced as a matter of urgency

Any development in Flood sensitive zones should not be permitted.

Sites which include areas which function as flood plains, for instance at Weston under Wetherley/Hunningham should not be considered for development as they will worsen the situation and increase flood risk. Greenbelt land contributes significantly to surface water drainage and should be protected.

Establish and agree targets for 'betterment' beyond current flood neutrality plus 40% for climate change. This can be achieved by early (pre-planning) engagement with the relevant developer site by site so they can build in sufficient water/hold back facility to meet the agreed target for the site. We would consider that 30% betterment to be an achievable and realistic target. Such an approach also avoids the need to set limits on hard standing areas as a proportion of the site as the soil permeability of different locations will affect run off. In Shipston for example the Western slope is heavy clay and even as undeveloped fields has hardly any capacity to soak water away, hence run off is extreme in spate conditions thus larger storage/holding areas are necessary.

I am concerned that new developments on or close to flood plains increases the risk of contributing to higher floods water further downstream. An example, is the need to maintain flood plains higher up the River Leam providing protection for Leamington Spa and other built areas further downstream. Proposals to develop large areas adjacent to Hunningham would increase this risk of flood and increase development and carbon costs at the expense of an existing natural flood plain. If the proposal goes ahead will the County and/or developer be willing to compensate home and business owners affected by such future flooding?

For the purpose of structuring any future policies in the Plan, we strongly recommend that Issue C8 relating to SuDS is re-located to Issue C11 (Water Management) or Issue C12 (flood risk), with Issue C8 becoming solely related to drought. The reasons for this are: 1) The focus of Issue C8 is climate change adaptation/mitigation. SuDS certainly contributes to tackling this issue, but its purpose is much more strongly aligned with managing flood risk from surface water both from new developments and existing problem areas elsewhere, and therefore aligns better with Issue C11 and C12. 2) Current SDC policy CS.4 and WDC policy FW2 recognised the point above with SuDS policy sitting alongside and within the section on flood risk and water management. 3) Issue C8 is titled “Adapting to flood and drought events”, yet only references SuDS with respect of flooding, not flood risk more widely. Therefore Issue C8 only gives part of the picture. 4) By moving SuDS to Issue C11 (Water Management), it will go hand-in-hand with the proposed section on the Water Framework Directive, as SuDS can significantly improve water quality of runoff and help meet the environmental net gain requirements from new developments. 5) SuDS sits within NPPF chapter on “Planning and Flood Risk” and PPG chapter on “Flood Risk and Coastal Change”. It therefore feels more appropriate to locate SuDS within the flood risk and water management part of the plan. We also recommend that the scope of Issue C12 (flood risk) is widened. As currently worded, there is a lot of focus on river flood risk. It should be widened to include reference to other sources of flood risk, such as surface water, which can have a significant impact on new (and existing) development. This is in accordance with paragraph 156 of the NPPF. Furthermore there are a large number of smaller (but still significant) watercourses throughout Stratford and Warwick districts that contribute to flood risk issues. It is perhaps therefore a bit misleading to mention only the 31 main rivers.

Any water company managing foul sewer systems should be included as a statutory consultee on all planning applications as the impact that developments have on this vital infrastructure should be considered at the outline planning stage.

No further comments.

As well as managing the impact of floods, developments should also seek to reduce their likelihood. For example prohibiting run off from drives and roofs into the sewerage system.

no development near or on flood plains

In major new development such as Meon Vale the sewers remain in the ownership of the developer for many years before adoption. There have been faults with the sewers which have led to blockages and leaks which are clearly damaging to the environment. There must be a better, swifter process for the adoption of infrastructure. It should not all be left until the whole development is complete. Meon Vale has been under construction for 9 years now and it is likely to be another 3 - 5 years before it is complete and sewers are adopted.

Severn Trent should be a statutory consultee on planning applications. The management of foul waste needs to be considered from outset.

Areas proposed around weston under wetherley and Hunningham already flood when we have large anounts of rainfall. By introducing more housing through removing woods/trees/grasslands, this problem will only get worse. The river bursts frequently around here so my concern is that this would only become frequent, resulting more flood damaged houses and busninesses.

Exclude development in Flood Plain land which should be retained for Public open space or productive agriculture

A sensible approach needs to be made. It seems large developments get away with building on flood plains but 1 new house doesn't.