Yes

Representation ID: 103303

Received: 07/03/2025

Respondent: Elizabeth Simpson Yates

We have a fantastic volunteer group on flood protection but it is not acceptable for developers to so heavily plan based on the existence of such groups. We need stronger governance on flood protection.

Yes

Representation ID: 103305

Received: 07/03/2025

Respondent: Mrs Jenny Stevens

Need to be in areas of low flood risk and prevent issues with run off

Other

Representation ID: 103449

Received: 07/03/2025

Respondent: Richborough - Salford Road, Bidford-on-Avon

Agent: Turley

Richborough have no overall concerns with the policy but note that a number of Planning Practice Guidance updates are due in relation to Flood Risk and any future policy wording should reflect this whilst also allowing flexibility for future policy changes.

Other

Representation ID: 103451

Received: 07/03/2025

Respondent: Richborough - Gaydon Road, Bishop's Itchington

Agent: Turley

Richborough have no overall concerns with the policy but note that a number of Planning Practice Guidance updates are due in relation to Flood Risk and any future policy wording should reflect this whilst also allowing flexibility for future policy changes.

Other

Representation ID: 103453

Received: 07/03/2025

Respondent: Richborough - Lighthorne Road, Kineton

Agent: Turley

Richborough have no overall concerns with the policy but note that a number of Planning Practice Guidance updates are due in relation to Flood Risk and any future policy wording should reflect this whilst also allowing flexibility for future policy changes.

Other

Representation ID: 103455

Received: 07/03/2025

Respondent: Richborough - Sycamore Close, Stockton

Agent: Turley

Richborough have no overall concerns with the policy but note that a number of Planning Practice Guidance updates are due in relation to Flood Risk and any future policy wording should reflect this whilst also allowing flexibility for future policy changes.

Other

Representation ID: 103457

Received: 07/03/2025

Respondent: Richborough - Kineton Road, Wellesbourne

Agent: Turley

Richborough have no overall concerns with the policy but note that a number of Planning Practice Guidance updates are due in relation to Flood Risk and any future policy wording should reflect this whilst also allowing flexibility for future policy changes.

Other

Representation ID: 103458

Received: 07/03/2025

Respondent: Richborough - Wellesbourne Road, Wellesbourne

Agent: Turley

Richborough have no overall concerns with the policy but note that a number of Planning Practice Guidance updates are due in relation to Flood Risk and any future policy wording should reflect this whilst also allowing flexibility for future policy changes.

Other

Representation ID: 103459

Received: 07/03/2025

Respondent: Richborough - Plough Lane, Bishop's Itchington

Agent: Turley

Richborough have no overall concerns with the policy but note that a number of Planning Practice Guidance updates are due in relation to Flood Risk and any future policy wording should reflect this whilst also allowing flexibility for future policy changes.

No

Representation ID: 103823

Received: 07/03/2025

Respondent: Claire Jones

We shouldn’t build on flood plains

Yes

Representation ID: 103909

Received: 07/03/2025

Respondent: Mr Amarjit Gill

New building should only occur in areas of low flood risk, which means protecting our green belt which acts as a buffer to protect our towns.

Yes

Representation ID: 104122

Received: 07/03/2025

Respondent: Mr Stephen Norrie

This policy seems good. However, does it conflict with specific development sites selected in Chapter 4, which include areas of flood plain within the designated areas?

Other

Representation ID: 104331

Received: 07/03/2025

Respondent: Ms Rachel Pope

Given the increase in flooding incidents over recent years it would seem foolhardy to allow any development in any areas except those at the lowest risk of flooding. It should also be acknowledged how wrong forecasting / event probability is proving to be at the moment and therefore the most extreme scenarios should be considered.

Yes

Representation ID: 104417

Received: 07/03/2025

Respondent: South Warwickshire Foundation trust

Yes, broadly support the proposed policy on Reducing Flood Risk, as flooding has direct and indirect impacts on public health, healthcare infrastructure, and emergency service access. However, to protect residents and ensure NHS resilience, the policy should explicitly require health impact assessments for flood-prone developments and guaranteed emergency access routes in flood-risk areas.

Yes

Representation ID: 104488

Received: 07/03/2025

Respondent: Mr Neal Appleton

Strategies for returning land to flood management use should also be considered.

Other

Representation ID: 104730

Received: 07/03/2025

Respondent: Miss Ann Colley

Flood risk is a major concern with the additional hardstanding proposed to be introduced. Not just at the development, but also downstream ie Tewkesbury, Worcester. The experience flooding currently!

Yes

Representation ID: 104972

Received: 07/03/2025

Respondent: Ms Susan Ingleby

Yes.

Yes

Representation ID: 104977

Received: 07/03/2025

Respondent: H Crook

No building on flood plains to prevent down-river flooding.

No development including caravan parks and static van parks. Above stratford there are 3 large static van parks, which are on stratford's flood plain. Even though the vans have flotation devices so they won't be damaged. The whole area is covered in tarmac , roads, and storage sheds next to each static. Hence complete loss of flood plain all along the river above stratford upon avon. ( see 3 large caravan/static van sites (Avon estates), and an enormous entertainment complex. This needs to be prevented in other areas flood plains.

Other

Representation ID: 105585

Received: 26/02/2025

Respondent: Mrs Sian Kellaway

Flooding in all of these locations is increasing year on year.

Yes

Representation ID: 105775

Received: 07/03/2025

Respondent: Wates Developments Ltd

Agent: Savills

Wates Developments support Draft Policy J, emphasising that new developments should prioritise areas with low flood risk. Although Strategic Growth Option SG15 (North of Wellesbourne Group) has a poor flood risk score, most of it is not flood-affected. Coppington Farm is outside Flood Zones 2 and 3, and developments there would comply with Draft Policy K and national standards. Jubb's Flood Risk, Drainage and Water Supply Review suggests adjusting SG15's planning boundary to exclude Flood Zones 2 and 3, ensuring compliance with national policy. We request that these flood-prone areas are excluded from any allocation made.

Yes

Representation ID: 106519

Received: 06/03/2025

Respondent: Wychbury Developments

Agent: Cerda Planning Ltd

Policy J – Reducing flood risk
We broadly support the provisions of Policy J and the objective of reducing flood risk.
However, we consider that the provisions of the policy are not consistent with the NPPF, specifically
regarding the sequential approach to locating development.
The NPPF continues to apply the sequential test to locate development outside flood zones 2 and 3,
including in relation to pluvial flooding, and this includes all parts of a development site. Policy J refers to
applying an ‘internal’ sequential test, by first accepting a development site which is in flood zones 2 or 3
and then designing out vulnerable parts of a development to locate this in lower flood zone areas – which
could include locating vulnerable uses in flood zone 2. This is not the approach required by the NPPF (or
PPG in respect of undertaking sequential tests). The policy should be amended to make clear that all
development sites should apply the sequential test at site selection stage rather than layout design stage.

This approach should be applied to both plan making and development management

Yes

Representation ID: 106655

Received: 07/03/2025

Respondent: Warwickshire Property and Development Group

Agent: Framptons

Yes, as the approach is consistent with the NPPF and PPG on Flood Risk and the Sequential Test.

No

Representation ID: 106834

Received: 06/03/2025

Respondent: Anthony Munton

The section in the SWLP on flooding is not very convincing. We live in times where rainfall is increasing; more importantly it is less frequent and, in consequence, comes in very heavy bursts.
Allowing planning permission where there is a risk in the life of the property cannot be allowed – whether to make the government numbers or property developer’s gains!
SUDS is a great concept but not likely to be effective in open fields and shallow flood plains, such as round here. In addition, all such mitigation works must be placed upon the developers, even if this raises the cost of housing - not upon on society as a whole (viz local and central government) or the council taxpayer. It should be paid by those who make the profit!

Other

Representation ID: 107333

Received: 07/03/2025

Respondent: Stratford-on-Avon District Social Inclusion Partnership

We note that no references exist in the plan to mobile/park home site applications but would encourage consideration of the implications of developing further sites within the district as the units themselves have very poor thermal comfort and residential units often require considerable grant funded retrofit works to make them perform well in terms of energy usage. Additionally, these site are often located near rivers that can flood and unless mitigating features are installed, residents can be at increased risk of homelessness as a result of flooding.

Other

Representation ID: 107359

Received: 06/03/2025

Respondent: National Trust

Reducing flood risk – The National Trust has experienced extensive instances of flooding at Charlecote Park since late 2023 and as a flood plain site located within Flood Zone 3, this is anticipated in situations of extreme weather conditions and climate change. Concern is raised however with regards to Charlecote Park’s location at the confluence of the River Avon and the River Dene and the impact that increased surface run off upstream development sites in the vicinity of Charlecote Park could have upon the capacity of the existing watercourses.
We are supportive that the South Warwickshire Plan acknowledges that the anticipated implications of climate change will only increase the area's vulnerability to such events and it is important therefore to appraise, manage and reduce the risk of flooding, directing development away from areas at risk of flooding wherever possible and to encourage developments to work with and to harmonise with the natural environment and surroundings.
We are supportive of the proposed policy J in respect of seeking to ensure that development does not place itself or others at increased risk of flooding, making sure that new development takes full account of flood risk, both current risk and future forecast risk, applying both the sequential test to flood risk and the surface water hierarchy for addressing issues of surface water management

Yes

Representation ID: 107528

Received: 07/03/2025

Respondent: Davidsons Homes

Agent: Cerda Planning Ltd

We broadly support the provisions of Policy J and the objective of reducing flood risk.
However, we consider that the provisions of the policy are not consistent with the NPPF, specifically regarding the sequential approach to locating development.

Other

Representation ID: 107610

Received: 07/03/2025

Respondent: National Highways

In relation to flood risk, any application near to the SRN would be needed to submit a
flood risk assessment and drainage strategy to be reviewed and agreed prior to
planning permission being granted.

Other

Representation ID: 107840

Received: 05/03/2025

Respondent: Catesby Estates Ltd

Agent: Pegasus Group

This is a comprehensive policy which is generally consistent with national guidance on flood risk in the NPPF and PPG. Notably, the sequential and the exception tests for flooding, referred to in Paragraphs 173 – 178 of the NPPF, are omitted from the policy, although these are briefly discussed in the supporting justification. It is recommended that reference to both tests should be made within the policy itself; this will need to acknowledge, as per Paragraph 175 of the NPPF, that the sequential test is not necessary in situations where a site-specific flood risk assessment demonstrates that no built development within the site boundary, including access or escape routes, land raising or other potentially vulnerable elements would be located on an area that would be at risk of flooding from any source. Paragraph 176 adds that applications for some minor development and changes of use should also not be subject to the sequential test. In line with Paragraph 180 of the NPPF, planning applications for sites allocated in the South Warwickshire Plan, applicants would not need to apply the sequential test again.

Other

Representation ID: 107876

Received: 07/03/2025

Respondent: Taylor Wimpey Strategic Land

Agent: Turley

Taylor Wimpey largely has no concerns with the policy. However, reference to new development being required to “seek opportunities for river restoration and enhancement, e.g. de-culverting, removing structures and reinstating a natural, sinuous river channel” should be clarified, particularly in respect of the detail required to demonstrate that this has been explored by a proposed development. In addition, given the potential cost associated with these activities, reference should be made in the policy that this will be subject to viability.

Other

Representation ID: 107958

Received: 07/03/2025

Respondent: Rainier Developments Ltd

Agent: Pegasus Group

This is a comprehensive policy which is generally consistent with national guidance on flood risk in the NPPF and PPG. Notably, the sequential and the exception tests for flooding, referred to in Paragraphs 173 – 178 of the NPPF, are omitted from the policy, although these are briefly discussed in the supporting justification. It is recommended that reference to both tests should be made within the policy itself; this will need to acknowledge, as per Paragraph 175 of the NPPF, that the sequential test is not necessary in situations where a site-specific flood risk assessment demonstrates that no built development within the site boundary, including access or escape routes, land raising or other potentially vulnerable elements would be located on an area that would be at risk of flooding from any source. Paragraph 176 adds that applications for some minor development and changes of use should also not be subject to the sequential test. In line with Paragraph 180 of the NPPF, applicants would not need to apply the sequential test again for planning applications for sites allocated in the South Warwickshire Plan.