Issue and Options 2023

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This point should include reference to the blue infrastructure as well as the green. ‘Protecting what already exists and maximising opportunities for enhancement including improvements to the blue/green networks through tree planting, biodiversity initiatives and protection of the watercourse corridors.

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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.

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