The Sustainability Appraisal for the site is based on flawed and out of date data regarding flood risk, and in particular the flood risk posed to other properties. The Warwick DC SFRA used in the appraisal makes no mention of significant flooding that occurred in Kenilworth in 2012, or that Finham Brook is now part of an EA Flood Alert/Flood Warning zone. In particular there are houses situated downstream of the development that were flooded in 2012, that would be put at further risk due to run off from this development. The confusion in the Sustainability Appraisal continues in that Finham Brook is variously referred to as both a minor and main river (it is a main river). For more info on recent flooding, the Warwickshire County Council local flood risk management strategy published in Sep 2015 is a useful resource: https://askwarks.files.wordpress.com/2015/01/lfrms-and-appendices-2015-09-11.pdf
The PPG states:
Local planning authorities should use the Assessment to:
*determine the variations in risk from all sources of flooding across their areas, and also the risks to and from surrounding areas in the same flood catchment;
*inform the sustainability appraisal of the Local Plan, so that flood risk is fully taken into account when considering allocation options and in the preparation of plan policies, including policies for flood risk management to ensure that flood risk is not increased;
I do not see how the above can be fulfilled with an out of date SFRA.