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Thank you for consulting the Environment Agency on the above Strategic document that was sent out for consultation in May 2012. We appreciate the opportunity to contribute to your emerging Local Plan.

Having reviewed the Preferred Options and supporting documents we have the following comments to make.

Summary
We welcome that the importance of Climate Change adaptation and especially flood risk are recognised in the preferred options and will form a key focus for the emerging Local Plan.

We have made comments based around the following other issues for Warwick:

* Water Quality
* Water Resources
* Flood Risk
* Waste

These key issues are all key components in dealing fully with the impacts of Climate Change and we support the Local Plan ensuring all these environmental issues along with Green Infrastructure as a whole contribute to Climate Change Adaptation within the District.

We would like to offer our continuing support in the development of the Warwick District Local Plan as it moves towards publication of the next consultation document. We are happy to engage with you on the issue of policy focus and specific wording after this consultation process is complete as you consider the responses move the plan making process forward. We can also assist you in identifying cross boundary environmental issues which would need to be addressed to fulfil the requirements of the Duty to Cooperate.

Objectives
We support the over-arching objectives of the emerging Local Plan in sections:
* 4.11 Carbon emissions and use of natural resources and adapting to the impacts of Climate Change in regards to flooding. We would also encourage the consideration of impacts on water quality in assessing the impacts of climate change.

* 4.12 We support the Plans recognition for the planning of the appropriate infrastructure in the District to support the desired level of growth and environmental protection with regards to water provision and waste water treatments as well as waste and linking these to making the District more adaptive to Climate Change.

These particular objectives provide a strong platform for the protection and enhancement of the environment and Climate Change mitigation and should clearly link the environment to promoting sustainable economic growth in Warwick District.

Climate Change
The National Planning Framework states that the Planning System should contribute to protecting and enhancing our environment and help to mitigate and adapt to climate change. We support the work undertaken by the council on mitigation and adaptation to climate change and the commitment to a climate change policy (PO12) which seeks to reduce carbon dioxide emissions and promote renewable and low carbon energy production. We also support this policy's recognition of Climate Change Adaptation in seeking to require that development is designed to be resilient to and adapt to the future impacts of climate change.

Climate Change Adaptation Strategy
We support the councils view that a policy framework be set in place to ensure all new developments and buildings are designed to be resilient to and minimise the future impacts of climate change such as heat and water stress, increased subsidence, flooding and extreme weather events. We would suggest that the factors summarised in the Local Plan from the Climate Change Adaptation Strategy by linked clearly to the issues which would be impacted upon directly. This would include flood risk, efficient use of water resources, the impacts of the urban heat effect and the protection and enhancement of water quality and biodiversity through the provision of well planned Green Infrastructure.

We have broken down our comments to the separate topic areas of Flood Risk, Water Quality, Water Resources and Green Infrastructure (including Biodiversity) but all inseparable from the over-arching issue of Climate Change.

Flood Risk
It should be noted that Climate Change could increase rainfall and river flows with increasing intensity and scale and so there could be an increase in both pluvial and fluvial flooding. We currently factor in an increase of 20% on currently flood modelling to account for the predicted impacts of Climate Change.


It is important to flag up that under the issue of Gypsies and Travellers (Page.31) there is no mention of the location of sites and pitches with regard to flood risk. Safety is paramount for these members of society and they can be vulnerable to the effects of flooding so allocation of these sites should be located primarily in Flood Zone1.

As a point of clarification, on Page 97 Para 18.5. the 2nd point reads - "To ensure that new development does not increase surface water flooding". We would recommend that this point should be amended to say "To ensure new development does not increase flooding from pluvial (surface water, run off) and fluvial (river) sources", as both types of flooding pose a risk to the District and wider catchment.

Looking at flooding on a catchment basis, development and defence strategies in Warwick District could have impacts on the wider Avon and other catchments. These impacts could be felt into Stratford and Wychavon Districts so a strategic view of flooding must be encouraged. By taking a more catchment based approach to the issue of flood risk, relationships with neighbouring authorities both upstream and downstream of the District will be identified and taken into account, therefore again supporting the Duty to Cooperate requirement.

Page 98 Para 018. 1st line reads, "new development will take place on sites outside of flood risk zones as far as practicable". We suggest that in line with the NPPF it may be better to amend the sentence stating that "no development in Flood Zone 3 unless it is water compatible." as Flood Zones 1 and 2 are developable subject to satisfactory drainage provision.

With regards to Para 18.10 and the description the role of the SuDs Approval Boards (SABs). They are still emerging after some delays, but they will be active in due course when the Lead Local Authority take on this function.

The Development Sites.
The development sites all appear to have avoided major flood risk issues as there are minimum sections of flood plain identified within them.

There are areas susceptible to surface water flooding identified for the majority of the sites but these should be identified and assessed in any site specific Flood Risk Assessments and these should consider all forms of flooding. We do not see any show stoppers associated with this aspect but in order to ensure surface water and flood risk is managed effectively in the District we recommend that surface run off be addressed in Policy PO18. We therefore suggest that PO18 where it addresses SuDs schemes should also include the commitment to ensure all new development achieves Green Field rates of surface drainage.

Water Quality
We are pleased to note that the issue of Water Quality and the implementation of the Water Framework Directive (WFD) are addressed in the supporting text to Policy PO18. However, we would encourage these issues to be fully addressed in Policy PO18 and suggest a policy be taken forward which insures no development should be allowed without provision of the necessary infrastructure to ensure no deterioration of local water bodies and such development should seek opportunities to make a contribution to the WFD objectives contained in the relevant River Basin Management Plan. Currently, PO18 makes no reference to wastewater, sewerage capacity and sewage treatment capacity at local treatment works.

We also suggest that the council work with Severn Trent Ltd and ourselves to consider the information in the sub-regional Water Cycle Study (March 2010) is still the most up to date and relevant to support the emerging Local Plan. It could be assumed that such a review should draw the same conclusion as the March 2010 document in that overall Water Quality is generally poor quality in terms WFD classification due to high phosphate levels, invertebrate/fish failures etc and these failures are caused from sewage treatment works and diffuse pollution from urban and rural sources. The majority of waterbodies are of poor - moderate status with only 4 waterbodies currently at Good Ecological Status/Good Ecological Potential (if heavily modified), Finham Brook and Radford Brook are two, the others being canals.

Infrastructure Delivery Plan
The supporting IDP states:
"As part of this funding cycle STW are currently making improvements to Longbridge sewage works (Warwick) to improve its efficiency and add further capacity and it is anticipated that this will be completed by 2014. They also have an existing ,discharge consent‟ to increase the capacity of Finham sewage works by 15%."

This statement needs to be confirmed with regards to the Finham works as this also serves Coventry as well as parts of Warwick District. Coventry has its own growth and development which could also impact on any free discharge and treatment capacity at the works. Both the Longbridge and Finham works ultimately discharge into the River Avon which means we strongly recommended that the council consider the whole Avon Catchment with regards to waste water treatment and WFD and this would also help the Duty to Cooperate requirement with regards to water quality. Finham STW is still a concern being a large STW with a Phosphorous removal consent limit already so it may be required that we have to Consent below 1mg/l in order to achieve no deterioration to the waterbodies for WFD.

Water Resources
Water conservation is addressed in Policy PO18 and we endorse the efficient use of water, especially in new developments, but we recommend that the plan includes specific targets, i.e. which level of the Code for Sustainable Homes and BREEAM ratings to be achieved. Specific water use targets would strengthen the policy and give a clear steer to developers. At the moment the CSH levels are recommended in the Draft Infrastructure Delivery Plan only and we would like the council to consider bringing these into Policy.

It is noted that in the Draft Infrastructure Plan (and WCS) it recommends CSH level3/4 as a minimum and that the Council aspires to achieve CSH level 5/6. To achieve level 5/6 developers may need to use rainwater/greywater harvesting systems. Since the WCS was published the Agency has published 'Energy and Carbon Implications of rainwater harvesting and greywater recycling' (August 2010) (http://publications.environment-agency.gov.uk/PDF/SCHO0610BSMQ-E-E.pdf ) which highlighted the high carbon emission associated with the use of recycled/ rainwater for anything more than outdoor use. This may influence the CSH level 5/6 aspiration. Our position statements on rainwater harvesting can be found at: Rainwater Harvesting Position Statement

If all cost effective water efficiency measures have been considered, rainwater harvesting and greywater recycling systems can be a useful means of reducing demand for mains water. It may be possible to make additional water efficiency savings from retrofitting surrounding properties with water efficiency devices and working towards water neutrality.

Each domestic rainwater harvesting (for more than just garden use) or greywater reuse should be examined on a case by case basis as their effectiveness varies considerably depending on scale, location and design.

As a guide, rainwater harvesting systems may be appropriate where:
* all feasible water efficiency measures are already in place;
* the planned system is cost effective (including ongoing maintenance costs);
* the planned system will be competently maintained and monitored;
* energy use and carbon emissions are minimised;
* they offer a more sustainable solution to manage surface water run-off than could be provided by other SuDS approaches.

The most recent and comprehensive guidance on rainwater harvesting systems is from BSI - BS 8515. On greywater it is BS 8525. Some case studies are available from:

Harvesting rainwater for domestic uses: an information guide (Environment Agency)
Conserving water in buildings, Chapter7: using greywater and harvesting rainwater (Environment Agency)
Greywater: an information guide (Environment Agency)
UK Rainwater Harvesting Association website
BSI British Standards: BS8515 - Rainwater harvesting - Code of practice and BS8525 - Greywater systems - Part 1: Code of practice

Waste
Development of additional housing and employment land will have implications for managing the waste arising from the new developments, both in terms of construction phases and during occupation. It is important that County and District work together to ensure waste is managed in a coordinated way, and if additional waste management infrastructure is required, the timing of new developments is phased accordingly.

As waste will arise during construction, and from new homes and businesses. There is an opportunity to consider the design of communities and supporting services to minimise waste arisings and encourage and enable waste to be managed in accordance with the waste hierarchy - reduce, re-use, recycle, recover, with landfill as the last resort. We support the comments in the IDP in that the council will ensure that sufficient infrastructure is in place to meet future demand for waste collection services in residential and commercial uses through the provision of household and commercial waste and recycling bins. We would recommend that in the design and layout of new housing incorporate waste recycling and collection issues such as by providing sufficient space for the collection of various waste streams.

Waste management should be considered alongside other spatial planning concerns such as transport, housing, economic growth, natural resources and regeneration, recognising the positive contribution that waste management can make to the development of sustainable communities.

We hope you find the above comments informative. If you have any queries, please do not hesitate to contact us