Other

Representation ID: 102188

Received: 07/03/2025

Respondent: IM Land 1 Limited

Agent: Turley

72. The policy sets out that SuDs should be above ground, given the opportunities to provide biodiversity and water quality enhancements. However, this may not always be the most appropriate drainage option. Accordingly, the policy wording should be updated to note that SuDs will be considered on a site-by-site basis in accordance with the SuDs hierarchy, with a preference for above ground interventions.

Yes

Representation ID: 102270

Received: 07/03/2025

Respondent: BDW Trading Limited

Agent: Knight Frank LLP

The policy requires all developments incorporate SuDS to manage surface water runoff effectively, aligning with the National Planning Policy Framework (NPPF) 2024, which requires major developments to include sustainable drainage systems unless there is clear evidence that this would be inappropriate.

This is supported and Cophams Hill will integrate multifunctional SuDS not only to manage surface water runoff but also enhance biodiversity, improve water quality, and provide recreational spaces. This approach ensures that the development contributes positively to the local environment and community, aligning with sustainable development principles.

Other

Representation ID: 102343

Received: 07/03/2025

Respondent: Taylor Wimpey Strategic Land

Agent: Turley

The policy sets out that SUDs should be above ground, given the opportunities to provide biodiversity and water quality enhancements. However, this may not always be the most appropriate drainage option and as such, should be considered on a site-by-site basis, potentially with a preference for above ground intervention.

No

Representation ID: 102351

Received: 07/03/2025

Respondent: Richborough

Agent: Marrons

Planning Practice Guidance quotes the NPPF as stating that SuDS should be used in development unless this would be inappropriate for the site. It is considered that this exception should be included in any policy requiring SuDS in the SWLP, as Draft Policy K does not currently allow for the exception, therefore meaning that the current policy is ‘unsound’.

No

Representation ID: 102398

Received: 07/03/2025

Respondent: Mrs Jenny Bevan

In accordance with the NPPF, SuDS ponds should not be included in the calculation of accessible green space, as they do not constitute usable green space. Additionally, it is recommended that these ponds be located away from children's play areas, which isn't the case at the Myton Green play area or area off Longcroft

Other

Representation ID: 102437

Received: 07/03/2025

Respondent: Hill Residential

Agent: Turley

Hill Residential agree with this policy, subject to comments.

In accordance with Draft Policy I, flood risk and drainage deliverables should include water quality assessments in line with methods outlined in the CIRIA SuDs Manual, such as the simple index approach.

Yes

Representation ID: 102940

Received: 07/03/2025

Respondent: Mr David Bailey

I agree.

No

Representation ID: 103060

Received: 07/03/2025

Respondent: Bloor Homes

Agent: Marrons

Planning Practice Guidance quotes the NPPF as stating that SuDS should be used in development unless this would be inappropriate for the site. It is considered that this exception should be included in any policy requiring SuDS in the SWLP, as Draft Policy K does not currently allow for the exception, therefore meaning that the current policy is ‘unsound’.

Yes

Representation ID: 103152

Received: 07/03/2025

Respondent: Severn Trent Water

Severn Trent Water are supportive of the Sustainable Urban Drainage Systems Policy.

Yes

Representation ID: 103312

Received: 07/03/2025

Respondent: Elizabeth Simpson Yates

Agree to the use of smaller, dispersed SuDS.

Yes

Representation ID: 104125

Received: 07/03/2025

Respondent: Mr Stephen Norrie

SuDS are an important climate adaptation measure, so this is a good policy.

Yes

Representation ID: 104419

Received: 07/03/2025

Respondent: South Warwickshire Foundation trust

Broadly support the policy and approach to multi-functional SuDS in residential developments, recognizing their role in flood mitigation, biodiversity enhancement, and improving public health. However, the policy should emphasize ensuring public health considerations are integrated into SuDS designs, with particular focus on water quality and preventing contamination. As well as this, a monitoring and maintenance plan should be included with particular focus on their health and environmental functions, ensuring they remain effective and beneficial for residents' well-being throughout the development's lifespan.

Yes

Representation ID: 104737

Received: 07/03/2025

Respondent: Miss Ann Colley

agree

No

Representation ID: 104776

Received: 07/03/2025

Respondent: Mr Dan Brock

I object to the Climate Resilient and Net Zero Carbon section due to contradictions between large-scale development and environmental goals. The proposed 54,500 new homes risk increasing carbon emissions, overwhelming infrastructure, and encroaching on greenbelt land, undermining climate resilience. There is insufficient clarity on how net-zero targets will be realistically achieved alongside major construction. Additionally, the plan lacks evidence of thorough community consultation, raising concerns about whether local views on sustainability have been properly considered. Without addressing these contradictions, the plan risks failing to deliver meaningful climate action.

Yes

Representation ID: 104979

Received: 07/03/2025

Respondent: Ms Susan Ingleby

Yes

Yes

Representation ID: 105776

Received: 07/03/2025

Respondent: Wates Developments Ltd

Agent: Savills

Wates Development support Draft Policy K, agreeing that development should not increase flood risk. We acknowledge the importance of implementing high-quality SuDS features for surface water management. Although Strategic Growth Option SG15 scores poorly for flood risk, Coppington Farm is not affected and all development should be outside flood risk areas, adhering to Draft Policy K. We request the exclusion of Flood Zones 2 and 3 from any allocation if SG15 is selected. Jubb has produced a review (Appendix 3) which confirms that infiltration may be unsuitable due to underlying strata, prompting a drainage strategy which prioritises attenuation solutions.

No

Representation ID: 106476

Received: 28/02/2025

Respondent: McCarthy Stone and Churchill Living

Agent: The Planning Bureau Ltd

Drainage requirements should remain in line with Government targets and the Building Regulations. Were the Council to seek higher standards than the Building Regulations from new development from the point of the Local Plan’s adoption this would need to be
evidenced. We would also remind the Council to include the uplift in build costs for delivering adaptation to flood and drought events that goes beyond the Building Regulations within any forthcoming Local Plan viability assessment and that the PPG states that “Viability assessment should not compromise sustainable development but should be used to ensure that policies
are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of the plan” (Paragraph: 002 Reference ID: 10-002-20190509).
Therefore, in order for the future plan to be found sound the following should be implemented:
• Any future policy should be stepped in line with emerging government targets and requirements and
• Ensure the policy is properly assessed within the forthcoming viability assessment

Yes

Representation ID: 106656

Received: 07/03/2025

Respondent: Warwickshire Property and Development Group

Agent: Framptons

Yes, we generally agree with the approach laid out in Draft Policy- K which concerns the design and delivery of multi-functional Sustainable Drainage Systems (SuDS). The policy should though acknowledge that while it is preferable for SuDS features to be provided above-ground, and for adequate space to be provided throughout the development for these features, this might not always be possible due to existing site constraints

No

Representation ID: 106973

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land off Mallory Road, Bishop's Tachbrook

Agent: Savills

This policy is prescriptive and does not allow much flexibility to site specific circumstances. ‘Where possible, practicable and viable’ should be added throughout.
The policy requires sites which include existing watercourses to appraise the risk of flooding, this may be through hydraulic modelling. The policy also notes that development layout should be sympathetic to any existing watercourse and overland surface water flow routes. The policy should align with national guidance which seeks for built development to avoid areas at risk of flooding, public open space within an area at risk of flooding should be supported (NPPF paragraph 175).

No

Representation ID: 107749

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land to the west of Southam Road, Long Itchington

Agent: Savills

This policy is prescriptive and does not allow much flexibility to site specific circumstances. ‘Where possible, practicable and viable’ should be added throughout.
The policy requires sites which include existing watercourses to appraise the risk of flooding, this may be through hydraulic modelling. The policy also notes that development layout should be sympathetic to any existing watercourse and overland surface water flow routes. The policy should align with national guidance which seeks for built development to avoid areas at risk of flooding, public open space within an area at risk of flooding should be supported (NPPF paragraph 175).

Other

Representation ID: 107842

Received: 05/03/2025

Respondent: Catesby Estates Ltd

Agent: Pegasus Group

This policy is broadly supported, although the Councils are reminded that whilst Paragraph 181 of the NPPF encourages the incorporation of sustainable drainage systems, it also recognises that this is unnecessary where there is clear evidence that this would be inappropriate. As such, the policy must make clear that there may be instances in which exceptions can be made, with SUDS not delivered providing that there is a clear justification for this, in line with the NPPF.

Furthermore, the policy should be amended to allow for more flexibility, for example, below- ground SUDS features may be suitable in some instances, and there may be sites and schemes where it is not possible to achieve a site-wide dispersal of SUDS, as currently stipulated in the draft policy. It is noted that the NPPF provides no such requirements for SUDS.

No justification from the Council has been provided for this policy. This may have been omitted in error, but it is imperative for the emerging policy to be fully justified to be found sound. It is considered that the policy can be adequately justified, subject to the amendments recommended above.

Other

Representation ID: 107877

Received: 07/03/2025

Respondent: Taylor Wimpey Strategic Land

Agent: Turley

The policy sets out that SUDs should be above ground, given the opportunities to provide biodiversity and water quality enhancements. However, this may not always be the most appropriate drainage option and as such, should be considered on a site-by-site basis, potentially with a preference for above ground intervention.

Other

Representation ID: 107959

Received: 07/03/2025

Respondent: Rainier Developments Ltd

Agent: Pegasus Group

This policy is broadly supported, although the Councils are reminded that whilst Paragraph 181 of the NPPF encourages the incorporation of sustainable drainage systems, it also recognises that this is unnecessary where there is clear evidence that this would be inappropriate. As such, the policy must make clear that there may be instances in which exceptions can be made, with SUDS not delivered providing that there is a clear justification for this, in line with the NPPF.

Furthermore, the policy should be amended to allow for more flexibility, for example, below- ground SUDS features may be suitable in some instances, and there may be sites and schemes where it is not possible to achieve a site-wide dispersal of SUDS, as currently stipulated in the draft policy. It is noted that the NPPF provides no such requirements for SUDS.

No justification from the Council has been provided for this policy. This may have been omitted in error, but it is imperative for the emerging policy to be fully justified to be found sound. It is considered that the policy can be adequately justified, subject to the amendments recommended above.

Other

Representation ID: 108080

Received: 07/03/2025

Respondent: Seven Homes

Agent: Pegasus Group

This policy is broadly supported, although the Councils are reminded that whilst Paragraph 181 of the NPPF encourages the incorporation of sustainable drainage systems, it also recognises that this is unnecessary where there is clear evidence that this would be inappropriate. As such, the policy must make clear that there may be instances in which exceptions can be made, with SUDS not delivered providing that there is a clear justification for this, in line with the NPPF.

Furthermore, the policy should be amended to allow for more flexibility, for example, below- ground SUDS features may be suitable in some instances, and there may be sites and schemes where it is not possible to achieve a site-wide dispersal of SUDS, as currently stipulated in the draft policy. It is noted that the NPPF provides no such requirements for SUDS.

No justification from the Council has been provided for this policy. This may have been omitted in error, but it is imperative for the emerging policy to be fully justified to be found sound. It is considered that the policy can be adequately justified, subject to the amendments recommended above.

Yes

Representation ID: 108223

Received: 07/03/2025

Respondent: Persimmon Homes (South Midlands)

Agent: Pegasus Group

This policy is broadly supported, although the Councils are reminded that whilst Paragraph 181 of the NPPF encourages the incorporation of sustainable drainage systems, it also recognises that this is unnecessary where there is clear evidence that this would be inappropriate. As such, the policy must make clear that there may be instances in which exceptions can be made, with SUDS not delivered providing that there is a clear justification for this, in line with the NPPF.

Furthermore, the policy should be amended to allow for more flexibility, for example, below- ground SUDS features may be suitable in some instances, and there may be sites and schemes where it is not possible to achieve a site-wide dispersal of SUDS, as currently stipulated in the draft policy. It is noted that the NPPF provides no such requirements for SUDS.

No justification from the Council has been provided for this policy. This may have been omitted in error, but it is imperative for the emerging policy to be fully justified to be found sound. It is considered that the policy can be adequately justified, subject to the amendments recommended above.

No

Representation ID: 108322

Received: 07/03/2025

Respondent: George Martin

On the basis that the SWLP is to 2050 Officers should review the Environmental Audit Committee's January 2025 evidence session "With climate change making flooding events more likely are flood resilience efforts fit for purpose"

It seems on reading this section that it only deals with new developments. There should be a section dealing with retrofitting existing driveways mandating SuDS.

Yes

Representation ID: 108582

Received: 07/03/2025

Respondent: Corbally Group (Harbury) Ltd

Agent: Pegasus Group

This policy is broadly supported, although the Councils are reminded that whilst Paragraph 181 of the NPPF encourages the incorporation of sustainable drainage systems, it also recognises that this is unnecessary where there is clear evidence that this would be inappropriate. As such, the policy must make clear that there may be instances in which exceptions can be made, with SUDS not delivered providing that there is a clear justification for this, in line with the NPPF.

Furthermore, the policy should be amended to allow for more flexibility, for example, below- ground SUDS features may be suitable in some instances, and there may be sites and schemes where it is not possible to achieve a site-wide dispersal of SUDS, as currently stipulated in the draft policy. It is noted that the NPPF provides no such requirements for SUDS.

No justification from the Council has been provided for this policy. This may have been omitted in error, but it is imperative for the emerging policy to be fully justified to be found sound. It is considered that the policy can be adequately justified, subject to the amendments recommended above.

Notwithstanding this, the supporting Vision Document and Development Framework Plan for this Site has demonstrated the ability to incorporate SuDs features through the proposed allocation as part of a carefully considered drainage strategy for the Site, whilst also offering additional recreational and biodiversity enhancement benefits for the Site and the immediately surrounding area.

Yes

Representation ID: 108629

Received: 07/03/2025

Respondent: Kiely Bros Holdings Ltd

Agent: Pegasus Group

Draft Policy K – Multi-Functional Sustainable Drainage Systems
6.16.
This policy is broadly supported, although the Councils are reminded that whilst NPPF §181 encourages the incorporation of sustainable drainage systems, it also recognises that this is unnecessary where there is clear evidence that this would be inappropriate. As such, the policy must make clear that there may be instances in which exceptions can be made, with SUDS not delivered providing, that there is a clear justification for this.
6.17.
Furthermore, the policy should be amended to allow for more flexibility, for example, below-ground SUDS features may be suitable in some instances, and there may be sites and schemes where it is not possible to achieve a site-wide dispersal of SUDS, as currently stipulated in the draft policy. It is noted that the NPPF provides no such requirements for SUDS.
6.18.
No justification from the Council has been provided for this policy. This may have been omitted in error, but it is imperative for the emerging policy to be fully justified to be found sound. It is considered that the policy can be adequately justified, subject to the amendments recommended above.

Yes

Representation ID: 108742

Received: 19/03/2025

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: Savills

We support Draft Policy K in principle and agree that development should not be permitted where there is an increase in flood risk to the site or surrounding area. We agree that high quality SuDS features should be implemented proportionately to manage surface water runoff. SLR has produced a
Preliminary Flood Risk Assessment and Surface Water Drainage Strategy (Appendix 3) in support of these representations. This document considers how land at Budbrooke Lodge Farm, which forms part of Strategic Growth Option SG08, can provide a surface water drainage solution which ensures SuDS features are used to manage surface water run-off.
A concept plan and vision document have also been produced by Node (Appendix 1). These documents incorporate the recommendations of SLR’s work to ensure that suitable and appropriate SuDS features are incorporated into the site masterplan to ensure the appropriate management of surface water across the proposed development. As the SWLP preparation process continues, further technical work can be undertaken to further demonstrate the suitability of the site and proposed SuDS features.

No

Representation ID: 108832

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

This policy is prescriptive and does not allow much flexibility to site specific circumstances. ‘Where possible, practicable and viable’ should be added throughout.
The policy requires sites which include existing watercourses to appraise the risk of flooding, this may be through hydraulic modelling. The policy also notes that development layout should be sympathetic to any existing watercourse and overland surface water flow routes. The policy should align with national guidance which seeks for built development to avoid areas at risk of flooding, public open space within an area at risk of flooding should be supported (NPPF paragraph 175).