Issue and Options 2023

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It is noted that the Landform Analysis example (Figure 9) includes Flood Zones 2 and 3. These zones represent only part of the picture when it comes to understanding the constraints of flood risk on new development. Flood zones show the risk of flooding from rivers only. Flood risk from surface water is the biggest risk of all and our view is that it should be included in constraints mapping alongside flood risk from rivers. The NPPF Para 160 states “strategic policies should…manage flood risk from all sources”. Furthermore, including surface water in constraint mapping would align with the emerging Level 2 SFRA. Nationally consistent surface water flood mapping is available on the gov.uk website, similarly to the flood zones, here: https://check-long-term-flood-risk.service.gov.uk/map

For the purpose of structuring any future policies in the Plan, we strongly recommend that Issue C8 relating to SuDS is re-located to Issue C11 (Water Management) or Issue C12 (flood risk), with Issue C8 becoming solely related to drought. The reasons for this are: 1) The focus of Issue C8 is climate change adaptation/mitigation. SuDS certainly contributes to tackling this issue, but its purpose is much more strongly aligned with managing flood risk from surface water both from new developments and existing problem areas elsewhere, and therefore aligns better with Issue C11 and C12. 2) Current SDC policy CS.4 and WDC policy FW2 recognised the point above with SuDS policy sitting alongside and within the section on flood risk and water management. 3) Issue C8 is titled “Adapting to flood and drought events”, yet only references SuDS with respect of flooding, not flood risk more widely. Therefore Issue C8 only gives part of the picture. 4) By moving SuDS to Issue C11 (Water Management), it will go hand-in-hand with the proposed section on the Water Framework Directive, as SuDS can significantly improve water quality of runoff and help meet the environmental net gain requirements from new developments. 5) SuDS sits within NPPF chapter on “Planning and Flood Risk” and PPG chapter on “Flood Risk and Coastal Change”. It therefore feels more appropriate to locate SuDS within the flood risk and water management part of the plan. We also recommend that the scope of Issue C12 (flood risk) is widened. As currently worded, there is a lot of focus on river flood risk. It should be widened to include reference to other sources of flood risk, such as surface water, which can have a significant impact on new (and existing) development. This is in accordance with paragraph 156 of the NPPF. Furthermore there are a large number of smaller (but still significant) watercourses throughout Stratford and Warwick districts that contribute to flood risk issues. It is perhaps therefore a bit misleading to mention only the 31 main rivers.

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We strongly recommend that WDC policy FW2 is considered a strategic policy and addressed in Part 1 of the Plan. The reasons for this are: 1) The consultation has identified SuDS as a development-scale requirement, therefore not strategic. We believe this is misplaced. SuDS is a very broad term used to describe a series of measures to manage flood risk and provide wider environmental and social benefits. SuDS can be (and has been) used strategically to address existing flood risk issues e.g. in collaboration with water companies or via council-led capital schemes, over-provision of SuDS to reduce impact on sewer network. They can be used to slow the flow within a catchment for the benefit of areas downstream. They can contribute to wider Water Framework Directive requirements and Environmental Net Gain. These are some of the more common ways in which SuDS can deliver flood risk and wider environmental benefits at a strategic scale. SuDS are not just about delivery on a site-by-site basis. 2) Surface water flood risk is acknowledged to be the leading source of flood risk in England. The NPPF has strengthened its position on dealing with it, via SuDS, in recent versions. Furthermore government agreed earlier this year to implement Schedule 3 of the Flood & Water Management Act 2010 in England in 2024. This will bring a much greater importance and emphasis on the design and construction of well-designed above ground SuDS to both minor and major developments. This direction of travel mustn’t be ignored and we therefore consider it appropriate for the policy on SuDS to sit alongside or within the policy on flood risk. 3) By including SuDS in Part 1 of the plan, it would overcome a possible inconsistency in Table 20 of the consultation when it comes to applying existing policies into the new Plan, which currently states that SDC policy CS.4 (which includes surface water runoff and SuDS) is considered strategic but WDC policy FW2 is not.

Issue W1 refers to the importance of managing the impact of pollution from new development. It also specifically refers to water pollution which we welcome. For the purpose of structuring any future policies in the Plan, it may be appropriate to cross-reference the importance that SuDS can play in controlling and improving water pollution through the treatment of surface water runoff before discharging to the wider environment.

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Table 15 of Issue B5 (Environmental Net Gain) refers to the issues new development can have on water quality. For the purpose of structuring any future policies in the Plan, it may be appropriate within this table or the wider section to cross-reference the importance that SuDS can play in controlling and improving water pollution through the treatment of surface water runoff before discharging to the wider environment. There are likely to be opportunities related to Issue B6 (Wildbelt designations) to incorporate Natural Flood Management schemes to address known flood risks within a catchment, for the benefit of downstream communities. For the purpose of structuring any future policies in the Plan, it may be appropriate to reference this in the document or any subsequent policy.

Q-S1: As it is yet unknown what Local Nature Recovery Strategies are to cover and to what strategic detail, it is recommended that the sub-regional Green Infrastructure continues to be the main evidence base for local plans within the sub-region. This document records Green Infrastructure Assets(both Green and Blue) and how they interact with surrounding habitats. The document also identifies national ecological corridors and has the potential to identify more local corridors such as those in urban areas. As the strategy is governed by the Planning Authorities within Warwickshire Coventry and Solihull it can be adapted to pick up the results from this consultation and, if requested, integrated into the mapping and subsequent policy formation. Recommendations: • SWLP identifies Green Infrastructure Assets in line with the recently produced Natural England Green Infrastructure Toolkit • SWLP identifies ecological (blue and green) corridors through the WCS Green Infrastructure strategy • SWLP has a policy that supports the retention and enhancement of Green Infrastructure (in combination with other habitat, species and Environmental Net Gain policies) throughout its area. Q-S3.2: Option S3.2a: Prioritise brownfield development only when it corresponds with the identified growth strategy, or if it can be proven that the development is in a sustainable location or would increase the sustainability of the area. This approach allows for consideration of wider issues in relation to sustainability and we therefore support this. However, broader sustainability issues should include consideration of ecological value and protected species and habitats.

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Q-C9.1: Option C9.1a: Include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity In principle this is a welcome addition to policy, in order to enhance biodiversity opportunities. However, consideration should be given to avoiding conflict with mechanisms for biodiversity offset and natural capital.

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Q-B5: As a general view, in ecology advice we have delivered a net gain position where possible, in line with the NPPF changes in 2019. Stratford policy position is in line with this (Core Strategy 2016). Warwick DC policy position is also in line (NE3 Local Plan 2017), both stating no net loss, net gain where possible. Ecology planning advice support the position of 10% BNG to further develop this long-standing approach. Whilst the natural capital approach and biodiversity offset are closely linked, it is worth noting that the biodiversity offset process within planning advice is very well established (10 years); therefore a separate policy may be quicker and easier to adopt. This does not prevent integration of approaches. Q-B6: Ecology Planning advice strongly support the principle of wildlife corridors and buffers, in order to mitigate and adapt species and habitat movement as a result of climate change. Whilst we appreciate that Wildbelt is a new concept, it is broadly in line with this intention. We would encourage a district or borough, as part of the Local Plan process, to provide evidence supporting a percentage goal. Q-B7: Ecology Planning advice supports good quality signposting in policy documents; this makes policy position clearer for both applicants and consultees. It also provides consistency because it helps to avoid conflict in policy. Q-B8.1: N/A Q-B9: Ecology Planning advice would like to emphasise the importance of regionally important sites for nature conservation, such as Local Wildlife Sites and Local Geological Sites. We support alignment across the Plan area, with a similar approach for both Stratford and Warwick. Whilst we appreciate the need for flexibility, we would like to see locally-designated sites being adequately valued when balancing harm against benefit of development. Q-B10: The NPPF supports ‘wins’ across all three Economic, Social and Environmental themes. Therefore, the SWLP should look to formulate an Environmental Net Gain (ENG) policy to demonstrate an objective to be in conformity with the national framework. An ENG policy could incorporate Biodiversity Net Gain and Carbon Offsetting with the aims to enable nature_based solutions as ways to both mitigate and compensate developmental impacts as evidence to the adherence to the Mitigation Hierarchy. SDC and WDC continue to work with WCC EHEL to develop Natural Capital markets that will enable development to become environmentally sustainable should residual impacts be identified. It should be expected that conditions and obligations will be used to ensure ENG is achieved. CSWAPO has agreed that as Biodiversity Net Gain and other markets are developed, both locally and nationally, supplementary guidance will be produced through the Warwickshire Ecosystem Services Trading Protocol, an annex to the Warwickshire, Coventry and Solihull Green Infrastructure Strategy.

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Ecology Planning advice advocates protection of national and regional sites of importance for species and habitats. Regional sites include County sites such as Local Wildlife Sites. We also recommend protection and enhancement of linear habitats, such as river corridors, hedgerows etc.