Q-C12: Please add any comments you wish to make about water management or flood risk in South Warwickshire

Henley often floods so careful consideration needs to be given to building more homes on a flood plain. Residents would need expert advice on if more homes could make flooding worse for existing homes, particularly the antiquated sewage systems which us and our neighbours are frequently experiencing issues with.

Must not build in areas at risk of flood and development must not exacerbate surface run off. Appropriate infrastructure needed to ensure water quality maintained. Houses should have water collection/filter provision for anything use other than drinking water. Rivers and their tributaries must be protected.

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?

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 or 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?

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?

Q-C11: The Plan should be ambitious in its thinking. As a minimum we should look for Option C11a but ideally, we should aim for C11b. Q-C12: Assessments will be made of potential sites at the next round of consultation.

Do not build on flood meadows. Control paved areas in new developments; proactive interventions to improve quality of local streams and rivers. Control use of chemicals and fertilisers on council land. Assess whether existing drainage and sewer systems can cope with a new development, without discharge into streams and rivers; ensure developers pay for required improvements to drainage and sewer systems. Involve Severn Trent in development flood and drainage assessments.

Must not build in areas at risk of flood and development must not exacerbate surface run off. Appropriate infrastructure needed to ensure water quality maintained. Houses should have water collection/filter provision for anything use other than drinking water. Rivers and their tributaries must be protected.

Issue C8: Adapting to flood and drought events Option C8a Include a policy that goes beyond existing building regulations, requiring new development and changes to existing buildings to incorporate measures to adapt to flood and drought events. This policy should include details restricting development alongside watercourses and their associated floodplains to mitigate against the effects of climate change on the frequency and magnitude of flood events. Where possible floodplain capacity should be increased, and new development located outside of flood zone 3 with managed retreat where possible of existing development. Issue C11: Water Management Option C11b Include policy along similar lines to the existing policies, where supported by up-to-date evidence. Policies to encourage improvements in line with the water framework directive rather than maintain the current status should be included. Issue C12: Flood Risk Policies should include drives to increase flood plain capacity through managed retreat of existing developments where possible. These should also state that future development should be located outside of flood zones 2 and 3 and existing development already within existing flood zones should not increase in their vulnerability to flooding. A policy to restrict the use of voids and stilts should be included as a form of flood plain compensation or flood risk mitigation. These should only be acceptable in a redevelopment of an existing site if all other solutions have been exhausted. In line with national planning policy finished floor levels for new developments should be set 600mm above the 1% AEP plus relevant climate change event providing resilience for the lifetime of the developments. Where modelled fluvial flood levels have not been produced / provided by the Environment Agency for a site, the applicant or their consultants will need to undertake suitable hydraulic calculations or modelling to determine the 1 in 30 year flood level and extent (defined as the functional floodplain in the updated PPG) across the site.Development should maintain at least an 8 metre easement between all built development and the top of the bank of watercourses and the toe of flood defences to allow for maintenance and inspection requirements. The Environment Agency strongly encourages greater buffers (20m) to be incorporated into policies to allow for access for larger maintenance works, to minimise future impact on flood flow routes, and to account of the natural movement of watercourses during a developments lifetime. In addition, as the frequency and severity of flooding is set to increase due to the impacts of climate change, this brings increased maintenance requirements of watercourses and flood defences. Any land which is required, or likely to be required, for a current or future Flood Risk Management Scheme should be safeguarded from future development as stated in paragraph 157 of the NPPF. Third party external funding towards flood risk management schemes should be sought from development to support the catchment wide approach to reducing flood risk which is projected to increase as a result of climate change.The Environment Agency and other Risk Management Authorities are constantly working on developing new schemes to limit the effects of flood risk and climate change, and therefore the above list should not be considered exhaustive. The Environment Agency also strongly encourages developer lead schemes to manage the effects of climate change and flood risk. Warwickshire County Council, as Lead Local Flood Authority, should be consulted regarding surface water issues and suitable measures to deal with surface water arising from development proposals required to minimise the impact to and from new development. In addition, given recent flooding events, we would strongly advise that policies should be included within the Local Plan to ensure all developments achieve better than Greenfield runoff rates for both Greenfield development and brownfield sites. The Environment Agency is happy to continue to provide comment on flood risk policy as it is developed. Water Quality Q-C11: Please select the option which is most appropriate for South Warwickshire Option C11b: Include policy along similar lines to the existing policies, where supported by up-to date evidence Local sewage treatment works would likely need upgrading or supplementing to support the level of growth currently identified and over the time period of the plan. We recommend this be factored into the Water Cycle Study and continued close engagement with STW and ourselves. The WFD status of the receiving watercourses should also be taken into account when considering the vulnerability of the water environment at that location, with those waterbodies under greatest stress posing the biggest constraint to additional large scale growth in the catchment. Drought and non-drought events can put customer water supply at risk, these challenges combined with increased levels of development in the area should be considered as part of the whole in the assessment of whether a sustainable supply of water is available to support the plan.

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?

Must not build in areas at risk of flood and development must not exacerbate surface run off. Appropriate infrastructure needed to ensure water quality maintained. Houses should have water collection/filter provision for anything use other than drinking water. Rivers and their tributaries must be protected.

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?

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?

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?

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?

We are concerned that new developments on or close to flood plains increase the risk of flooding further downstream. Maintain Maintenance of the floodplains of the River Leam will provide protection for Leamington Spa and other built areas further downstream. Proposals to develop large areas adjacent to Hunningham would increase this risk of flooding and require remediation elsewhere with increased carbon costs at the expense of an existing natural flood plain. If the proposal goes ahead, will the developer be willing to compensate home and business owners affected by such future flooding due to removal of this natural flood plain?

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?

Q-C12: Flood risk: 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?

Q-C12: Flood risk: 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?

Q-C12: Flood risk: 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?

Issue C11: Water Management Q-C11: please select the option which is most appropriate for South Warwickshire Option C11a has the potential to be the most appropriate policy, however this is subject to its specific wording. At present, the existing policies concerning water management state the term ‘good’, however there is no definition of ‘good’ and the term remains subjective, therefore unclear and has potential to be unachievable. 5.17 As Issue C12 highlights, flood risk is considered a strategic planning matter and will therefore be addressed within Part 1 of the Plan. At present, there is not sufficient evidence to properly judge what sort or level of Policy is required. Until the additional evidence is undertaken, it is not appropriate to comment on water management or flood risk. However, The Church Commissioners reiterates that as per validation requirements, all major applications require a Flood Risk Assessment to assess a site, and mitigate against any potential problems. 5.18 Furthermore, the wording within Issue C12 infers that the Part 2 work will be based upon the strategy, however the work undertaken should inform the strategy, therefore all work undertaken should underpin any proposed policy. 5.19 In addition, whilst the Level 1 Strategic Flood Risk Assessment states that it can be used to inform the Local Plan on the location of future development and the preparation of sustainable policies, there is not sufficient evidence to fully decipher this, and this report should only be considered as a factor towards the wider review of sites suitable for development. As per Paragraph 0073 (Reference ID: 7-007-20220825), Diagram 1 outlines that following the completion of a Level 1 Strategic Flood Risk Assessment, the authority then identify where development can be located in areas with a low risk of flooding and assess alterative development options using the Sustainability Appraisal, considering flood risk and other planning objectives. Following this exercise, the Council can then apply the Sequential Test to identify appropriate allocation sites and development, which can then require a Level 2 Strategic Flood Risk Assessment. As a result, a greater amount of work and evidence is required to inform the Local Plan, as the Council have not yet reviewed the availability of sites, to identify those in areas of low risk flooding and those not. 5.20 In addition, the SFRA summarises that there are urban areas of Stratford upon Avon and Warwick that are at risk of fluvial and surface water flooding. As a result, the Councils need to take this into account when reviewing their available urban sites. This may require greater areas of Green Belt land to be released, if urban areas are at greater susceptibility to flooding. 5.21 At present, two reports have been produced to cover Stratford and Warwick separately. In the future, it would be more useful and appropriate to look at South Warwickshire as an entity, with supporting joint evidence. In addition, Appendix D within both reports identifies Flood Alert and Flood Warning Areas, and it would be more appropriate to have accompanying maps of these areas to identify clearly those locations. At present, it is unclear.

Q-C12: Flood risk: I am concerned that new developments on or close to flood plains increases the risk of contributing to higher floodwater levels further downstream. It is essential to maintain flood plains higher up the River Leam in order to provide protection for housing and businesses downstream including Leamington Spa. Proposals to develop large areas adjacent to the Leam near Weston and Hunningham would increase the risk of flooding as a result of replacing land that can absorb rainwater with paved areas that cannot and through the loss an existing natural flood plain. Where such development is permitted the developer must pay for flood prevention measures at the location in question and also downstream to at least, and ideally more than, offset the impact of the development on flood levels.

Q-C12: Flood risk: 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?

Q-C12: Flood risk: 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?

Q-C12: Flood risk: 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?

Q-C12: Flood risk: 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?

Q-C12: Flood risk: 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?

Q-C12: Flood risk: 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?

Q-C12: Flood risk: 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?

Q-C12: Flood risk: 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?