MANAGING RISK BACKGROUND PAPER

Introduction...... 2 Legal and Policy Background ...... 2 Evidence Base...... 7 Managing Flood Risk Policy ...... 11 Policy Delivery Mechanisms...... 15 Alternative Policy Options...... 16

MANAGING FLOOD RISK BACKGROUND PAPER

Introduction 1. This paper sets out the policy background and evidence based studies that have been used to develop the policy on Managing Flood Risk.

Legal and Policy Background

Water Framework Directive, 2000/60/EC 2. The Directive requires all inland and coastal to reach ‘good chemical and ecological status’ for surface waters and ‘good status’ for groundwater in terms of quality and quantity by 2015. basin management plans are required to provide the context for the co-ordination of management for the river basin.

Assessment and Management of Flood Risks, Directive 2007/60/EC 3. The Directive requires assessment of all water courses and coast lines at risk from flooding. The purpose is to map the flood extent, the assets and humans at risk in these areas and to take adequate and coordinated measures to reduce this flood risk.

Flood and Water Management Act 2010 4. Relevant key features of the Act are: • To give the Environment Agency an overview of all flood and coastal risk management and unitary and county councils the lead in managing the risk of all local . • To introduce an improved risk based approach to reservoir safety. • To encourage the uptake of sustainable systems by removing the automatic right to connect to sewers and providing for unitary and county councils to adopt SUDS for new developments and redevelopments. • To provide for a Lead Local Flood Authority (LLFA), in this case County Council. The LLFA should bring together all relevant bodies – district councils, internal drainage boards, highways authorities, water companies and the Environment Agency to help manage local flood risk. Local flood risk includes surface run-off, groundwater and ordinary watercourses (including lakes and ). The LLFA, working with local partners, is to develop, maintain, apply and monitor a strategy for local flood risk management in its area.

5. Alongside the Act, the Flood Risk Regulations 2009 have been made to implement the Floods Directive in England and Wales. These regulations outline the roles and responsibilities of the various authorities consistent with the Flood and Water Management Act and provide for the delivery of the following outputs, as required by the Directive: • Preliminary Flood Risk Assessments (PFRAs), which will allow the identification of areas of potential significant risk. • Maps showing impact and extent of possible future significant flood events. • Flood risk management plans, identifying how significant flood risks are to be mitigated.

National Planning Policy Framework (DCLG, 2012) 6. The Government’s objectives in relation to climate change, flooding and water include: • minimising vulnerability and providing resilience to impacts arising from climate change • taking full account of flood risk and water supply and demand considerations.

7. The NPPF says that inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, make it safe without increasing flood risk elsewhere. Strategic Flood Risk Assessments and advice from the Environment Agency, lead local flood authorities and internal drainage boards should be used to develop policies to manage flood risk from all sources.

8. The NPPF says that Local Plans should apply a sequential, risk-based approach to the location of development to avoid flood risk to people and property where possible, and manage any residual risk, taking account of the impacts of climate change, by: • applying the Sequential Test • if necessary, applying the Exception Test • safeguarding land from development that is required for and future flood management • using opportunities offered by new development to reduce the causes and impacts of flooding; and • where climate change is expected to increase flood risk so that some existing development may not be sustainable in the long-term, seeking opportunities to facilitate the relocation of development, including housing, to more sustainable locations.

9. Further guidance is set out in a Technical Appendix to the NPPF.

River Basin Management Plans 10. River Basin Management Plans (RBMP) are plans for protecting and improving the water environment. Two are relevant in and , the Humber and Severn.

11. The Humber RBMP (Environment Agency, 2009) describes the river basin district, and the pressures that the water environment faces. It shows what this means for the current state of the water environment, and what actions will be taken to address the pressures. It sets out what improvements are possible by 2015 and how the actions will make a difference to the local environment – the catchments, the and coasts, and the groundwater.

12. Relevant actions include: • To promote the wide scale use of sustainable drainage schemes to reduce the risks of flooding and of impact on quality at times of high rainfall. • To promote water efficiency in new development through regional strategies and local development frameworks. Use a Water Cycle Study to identify policy advice on water efficiency measures. • To ensure that planning policies and spatial planning documents take into account the objectives of the Humber RBMP. • To take action to reduce the physical impacts of urban development in artificial or heavily modified waters, to help waters reach good ecological potential. • To implement surface water management plans, increasing resilience to surface water flooding and ensuring water quality is considered on a catchment basis. • To promote the use of sustainable drainage systems in new urban and rural development where appropriate, and retrofit in priority areas including highways where possible.

13. Spatial planning and design for urban development and infrastructure should aim to reduce surface water run off; protect and restore habitats; improve the quality of , coastal waters, and groundwater, and thus protect drinking water supplies and bathing areas. The release of toxic pollutants that harm the water environment also needs to be reduced.

14. The Severn RBMP (Environment Agency, 2009) is relevant to Bedworth and south of Borough towards Coventry. It raises the same issues as the Humber RBMP.

Catchment Flood Management Plans (CFMP) 15. A CFMP is a high level strategic plan for the Environment Agency to work with other decision makers within a river catchment to identify and agree long term policies for sustainable flood risk management. Two CFMPs cover the Borough: The River Trent and the River Severn.

16. The River Trent CFMP (Environment Agency, 2010) identifies the sub area of The Upper Soar and Upper Anker sub area, which is relevant to Nuneaton. For this sub area, Policy Option 4 is chosen. This Option refers to areas of low, moderate or high flood risk where flood risk is being managed effectively but where there is a need to take further actions to keep pace with climate change. This policy is selected because although the risk is currently managed appropriately, it is expected to rise significantly in the long term. In these circumstances, we need to do more in the future to reduce the expected increase in risks.

17. The River Severn CFMP (Environment Agency, 2009) covers the Telford, Black Country, Bromsgrove, Kidderminster and Coventry Cluster sub area. This is relevant to Bedworth. For this sub area, Policy Option 5 is chosen. This Option refers to areas of moderate to high flood risk where further action can be taken to reduce flood risk. This policy is about reducing the risk where the existing flood risk is too high. Action is needed in the short term to reduce this level of risk.

River Tame Flood Risk Management Strategy (Environment Agency, 2011) 18. The strategy outlines how the Environment Agency will reduce flood risk on the River Tame (of which the River Anker is a ) over the next 100 years (2009 – 2109) by: • continuing existing activities such as flood warnings, maintenance and advising businesses, landowners and the public on flood resilience; • improving the operation of existing flood storage areas; • improving river flows by reducing the number of pinch points and blockages which cause high river levels; • providing new flood defences and replacing some existing ones.

19. Whilst the strategy is referred to by the SFRA1, there are no specific aspects relevant to the Borough.

20. The SFRA 1 also refers to the River Tame Flood Risk Management Strategy (Environment Agency, 2011), River Trent Strategy and the River Severn Strategy. However, there are no specific implications for Nuneaton and Bedworth.

Shaping our Future - Sustainable Community Plan 2007-2021 for Nuneaton and Bedworth 21. Theme 4: Sustainable Borough aims to have a high quality environment with increased biodiversity and a sustainable approach to waste and energy. The Local Strategic Partnership will work together to tackle climate change.

Emerging Borough Plan 22. The following Strategic Objectives are relevant to the Managing Flood Risk Policy:

Objective 6 - To ensure that new development enhances and improves the quality and appearance of the existing urban area. In particular:

a) Important open spaces such as Riversley Park, Miners Welfare Park, Whittleford Park and community and local parks are protected and enhanced. Landscape character, historic, geological and natural features such as Arbury Historic Park and Garden, Stockingford Railway Cutting and Ensor’s Pool are protected and enhanced. b) Derelict, contaminated and untidy sites are brought back into beneficial use. c) Minimise the negative impact of development and make improvements where possible to air quality in Air Quality Management Areas. d) Maximise opportunities to use the River Anker, Wem Brook, the Coventry and Ashby Canal as attractive focal points for open space and new development where there is no negative impact on the green network or the water quality. e) Infill development positively responds to local character and does not result in town cramming. f) High quality and sustainable design and construction in line with design standards.

Objective 7 - To address climate change and encourage sustainability in all new development. In particular:

a) Avoid where possible sites that are at risk of flooding now or in the future. b) Utilising appropriate sustainable urban drainage systems for flood or surface water attenuation and using water sustainably. c) Protect and enhance the Borough’s ecological network, in particular priority habitats and species and minimising impacts on biodiversity. d) Maximise energy efficiency and the use of renewable energy, particularly those with greatest potential in the Borough. For example, combined heat and power district energy, biomass energy, ground source heat pumps, solar photovoltaics and solar thermal, along with any future renewable or low carbon technology that may become more suitable for the Borough during the plan period. e) Ensure development makes links to cycling and walking networks to encourage green travel.

23. The feedback received from the Issues and Options Core Strategy consultation (2009) is summarised below: • There are key characteristics relating to the location and quality of local watercourses and basic hydrology of the localities on flood risk missing from the Spatial Portrait. For example, the Environment Agency designated main rivers are: River Anker, Wem Brook, Nuneaton Flood Relief Channel, Sketchley Brook, Harrow Brook and Change Brook. Coventry Canal and Ashby-de-la- Zouch canal are also important green corridors. • The Nuneaton Flood Defence Scheme is maintained by the Environment Agency and is a significant flood defence infrastructure. • Flooding and drainage are missing from the list of Key Issues. This is a significant omission given climate change predictions. • Objective 7, which makes reference to avoiding development in the flood plain and ensuring sustainable drainage via the use of sustainable urban drainage techniques in construction, is welcomed. • Flood risk is a key consideration when deciding which land to build on. • Several areas are noted as places of concern in terms of recent flood events: Longshoot, St Nicolas Park, Skey Drive and the Bucks Hill Cemetery, Barpool , Avenue and Tomkinson Road, Brookvale Road, Winster Close and Howat Road, Weddington, Delamere Road, Shawe Avenue, Weddington Country Walk. • have the potential to play an important role in extending the Borough’s green infrastructure. These areas should be considered more positively rather than avoided. • Flood risk areas should be avoided in all cases. • An approach to development in flood zones in line with PPS25 – Development and Flood Risk is supported. Strategic Flood Risk Assessments should be used to advise on land allocated for development and essential infrastructure.

Evidence Base

UK Climate Projections 24. UKCIP is the leading organisation in climate change scenarios and is useful in forecasting what the likely weather patterns will be in the future. These climate/weather scenarios are broken down regionally. Overall, for the these suggest increases in temperatures for both winter and summer. Winters are expected to be wetter and summers drier than currently.

Strategic Flood Risk Assessment Level 1 (Halcrow, 2008) 25. The SFRA1 assesses and maps all forms of flood risk – groundwater, surface water, sewer and river sources, taking into account future climate change predictions - for Coventry, Solihull and Warwickshire. This information provides the basis for the Sequential Test to be applied to identify locations for future development in areas of least flood risk.

26. The SFRA1 summarises flood risk in Nuneaton and Bedworth including: • Main rivers and fluvial flood risk • Historical flooding • Flooding from surface water and artificial drainage sources • Flooding from impounded water bodies – and reservoirs • Flooding from groundwater • Climate change.

Main Rivers and Fluvial Flood Risk

Main River Flood Risk and Defences River Anker Enters the Borough from the east by Affects people, property, and Stretton and flows in a north-westerly infrastructure in Nuneaton. direction through Nuneaton and exits the Town benefits from Flood Relief Channel Borough north of Weddington. which protects more than 1000 properties from up to 1% AEP (1 in 100 year). Residential and commercial properties located in Flood Zone 2 through the town Main River Flood Risk and Defences centre. Small number of properties located in Flood Zone 2 by Weddington.

A number of properties are located in Pool Brook is a tributary of the River Flood Zone 2, although there are some Anker and joins the river through misalignments of the mapping. Nuneaton Town Centre. Parts of Queen Elizabeth Road adjacent to the balancing lake are vulnerable to flooding from Bar Pool and Whittleford Brooks and from flooding from surcharged sewers and overland flow from the Camp Hill Estate. Barpool Balancing is designed to accommodate flows from the Bar Pool Brook. A number of properties are located in Flood Zone 2 at an unnamed tributary of the Bar Pool Brook. Harrow Brook Enters the Borough from the north-east Some properties along The Longshoot by Dodwells Bridge Industrial Estate and are located in Flood Zone 2. flows in a predominantly southerly Properties also affected by overland flow. direction along the Nuneaton and Bedworth and Rugby boundary and flows Minor works to a ditch course joining the into the Anker. Harrow Brook since 1999. Flood protection – a bund and pumping station – installed. Wem Brook Enters the Borough as a non-Main River A number of properties are located in from the south east by Shilton and flows Flood Zone 2. predominantly in a north westerly direction. At SP 3662 9118 it becomes a designated Main River, flowing in a northerly direction before joining the left of the River Anker. Breach Brook Enters the Borough from the south west, A small number of properties are located forming the boundary between Nuneaton in Flood Zone 2 where the Breach Brook and Bedworth and North Warwickshire. meets the River Sowe by Exhall. Here it is considered a non-Main River. At SP 3334 8526 the watercourse becomes a designated Main River and Main River Flood Risk and Defences flows in an easterly direction before joining the right bank of the River Anker. River Sowe Becomes a designated Main River to the A number of properties are located within north of Bedworth Heath (where Flood Zone 2 as the watercourse flows previously it was part of Bedworth through the western edge of Bedworth. Sloughs Brook) and flows in an easterly direction before turning in a southerly direction and exits the Borough around Rowley’s Green. Change Brook Enters the Borough by St Nicolas and A number of properties are located within flows predominantly in a south westerly the Flood Zone maps in the downstream direction and joins the River Anker at extent as it joins the River Anker. Sandon Park Recreation Ground.

Historical Flooding 27. Major flooding occurred through Nuneaton in 1968. As a result, a flood relief channel was designed and constructed in the 1970’s to protect the town to a 1 in 80-year storm standard.

28. In December 1992, at the north of the Borough, sections of the River Anker flooded including areas of and some properties in Attleborough.

Flooding From Surface Water and Artificial Drainage Sources 29. Severn Trent Water maintains a register of properties/areas at risk of flooding from the public sewerage system. The DG5 Flood Register includes records of flooding from foul sewers, combined sewers and surface water sewers which are deemed to be public and therefore maintained by the Water Company. Information is the form of four digit postcode locations.

Table 1: Flooding From Artificial Sources as Recorded in Severn Trent DG5 Register

Post Code Area No Properties Affected CV10 0 13 CV10 9 1 CV11 4 1 CV11 6 3 CV12 0 8 CV12 8 3 CV12 9 11 CV2 1 1 CV6 4 4 CV7 8 4 CV7 9 4

30. Recent events include: • Elizabeth Road adjacent to the balancing lake is vulnerable to flooding from the Barpool and Whittleford Brooks and also due to flooding from surcharged sewers and overland flow from the Camp Hill Estate. Barpool Balancing Pond is designed to accommodate flows from the Barpool Brook. Flood events that occurred on the 21st July 2007 suggest that the sewer infrastructure that discharges into the lake is inadequate. • Land and properties were also flooded from surcharged sewers and overland flow in June 1999 around St Giles Road and Ash Green Lane, Exhall.

Flooding From Impounded Water Bodies 31. Coventry Canal and the Ashby-de-la-Zouch Canal are located in the Borough. British Waterways has no records of canal breaches. However, it is important that canals are included in any SFRA/FRA as they form a vital land drainage function. Canals occasionally overtop in places due to high inflows from natural catchments (i.e. where inflows are higher than the capacity of the structures) and they are also vulnerable where overtopping occurs from adjacent water courses.

32. Reservoirs with an impounded volume in excess of 25,000 cubic metres (measured above natural ground level) are governed by the Reservoirs Act and are listed on a register held by the Environment Agency. Due to high standards of inspection and maintenance required by legislation, normally flood risk from registered reservoirs is moderately low. One reservoir is held on the register at Seeswood Pool. There are no records of breach or overtopping.

Flooding from Groundwater 33. There are no known problems with flooding from groundwater within the Borough.

Climate Change 34. Climate change has been taken into account in this SFRA1 by preparing Flood Zone maps show how climate change might affect Flood Zones over a period of 50-100 years. The Report recognises that the larger flood flows resulting from climate change are more likely to impact wide, flat floodplains. In these areas, the Report recommends the use the climate change maps to carry out the Sequential Test, in order to ensure a long-term risk-based approach has been adopted in planning. A Strategic Flood Risk Assessment Level 2 (SFRA2) is being prepared to ensure that a sequential approach to flood risk is taken into account when selecting strategic sites for development.

Water Cycle Study (Halcrow Group Ltd, 2010) 35. The Water Cycle Study provides strategic evidence to determine if future growth and associated development will or will not have a detrimental impact on the environment and whether or not the necessary water infrastructure can be provided in a timely manner to support the required growth.

36. The Study includes a summary of the key findings and recommendations for Nuneaton and Bedworth Borough Council. These are: • There should be sufficient developable land outside of flood zones 2 and 3 within the Borough to accommodate the proposed development outside of high flood risk areas. • The Borough is predominantly underlain by clay-rich soils which are poorly- drained. As a result it is less likely that based SUDS will be appropriate to manage surface water runoff from development sites. • Potential capacity and issues consents at Nuneaton-Hartshill, Marston-Bedworth, Finham WWTWs will require further investigation. Bulkington WwTW does not have capacity or discharge consent issues for development up to 1500 additional dwellings.

SFRA Level 2 (JBA, 2013) 37. The Borough Council is required to undertake a Level 2 Strategic Flood Risk Assessment (SFRA2) in order to demonstrate that sufficient consideration has been given to flood risk at all stages of the planning process. The objective is to avoid inappropriate development in higher risk areas. The SFRA constitutes one of a number of planning tools that enables the Local Authorities to select and develop sustainable site allocations away from areas of greatest vulnerability of flooding in the Borough.

38. The main purpose of this SFRA2 is to assess potential allocations for strategic sites. At this stage it has contributed towards the selection of the preferred option strategic sites but not directly to the Managing Flood Risk policy. The SFRA 2 will inform further development of the Managing Flood Risk policy for the Submission Draft version of the Borough Plan.

Managing Flood Risk Policy 39. The policy takes account of the legal and policy background and local evidence. The reasons for the policy taking the form it does is set out below. As stated above, the policy will be revised to take account of the recommendations made by the SFRA2.

Sequential Approach 40. Overall, the SFRA1, SFRA2 and the Water Cycle Study indicate that flood risk from fluvial sources is low. There is enough developable land outside flood zones 2 and 3 to accommodate new development. However, in line with the NPPF, the sequential test should be used to locate new development in areas of least flood risk, giving highest priority to Flood Zone 1. Within sites, the Sequential Test should be used to inform site layout by locating the most vulnerable elements of a development in the lowest risk areas. For example, the use of low-lying ground in waterside areas for recreation, amenity and environmental purposes can provide an effective means of flood risk management as as providing connected green spaces with consequent social and environmental benefits.

41. In terms of design, there is a need to build resilience into a site’s design (e.g. flood resistant or resilient design, raised floor levels). Also, there is a need to ensure development is ‘safe’. For residential developments to be classed as ‘safe’, dry pedestrian egress out of the floodplain and emergency vehicular access should be possible.

Non Fluvial Flood Risk 42. The SFRA 1 and Water Cycle Study also recommends that other sources of flooding be considered and assessed through further strategic and site specific flood risk assessments. For Nuneaton and Bedworth these include: • Development adjacent to canals should be supported by a level 2 SFRA to ensure that residual risks of overtopping or breach are assessed. • There are a number of unmapped watercourses which pose some flood risk, and developers should include an assessment of the flood risk from these during FRAs. • Any development behind existing flood defences should be supported by a level 2 SFRA.

Surface Water Flooding 43. The SFRA 1 and Water Cycle Study indicates that for a number of locations, surface water flooding and field run-off have been identified as a problem. This is particularly the case at times of heavy and prolonged rainfall. Future development proposed in locations known to be at risk from surface water flooding is avoided. Appropriate surface water management policies should be developed to ensure that flood risk is not increased within the site or to locations downstream.

44. The SFRA 1 and Water Cycle Study suggest the following approaches to reduce run-off: • Reduce run- off rates and volumes. The Environment Agency requires Greenfield discharge rates with a minimum reduction of 20%. • Require Sustainable Urban Drainage Systems (SUDS) for all scales of development. At the household level there should be a presumption away from connecting property extensions or additional hard-standing area to the sewerage network. The additional runoff should be managed at source, where possible, or connected to a watercourse. Space should be set aside for SUDS and considered to inform the overall site layout. • Promote infiltration SUDS where possible. The Borough is largely underlain by clay soils (which are poorly drained). So, it is likely that infiltration approaches are less likely to be suitable to manage surface water. However, the potential for infiltration SUDS must be considered by developers for each development site. When infiltration is not possible, the presumption should be away from connections to the public sewer, where possible. Infiltration systems should be the preferred means of surface water disposal, provided ground conditions are appropriate. Above ground attenuation, such as balancing ponds, should be considered in preference to below ground attenuation, due to the water quality and biodiversity benefits they offer. • Do not connect surface water to the sewerage network. Brownfield development should seek to remove surface water connections to the public sewer; however in some dense urban areas it is recognised that this may be difficult to achieve, but should be considered an aspiration for all development. • Any large development proposals which come forward offer the opportunity to strategically plan the drainage provision across a site/s. Larger surface water drainage features (e.g. attenuation basins) are likely to result in operational and maintenance cost efficiencies. This will require early co- ordination by the Council as development applications come forward. • Promote environmental stewardship schemes to reduce water and soil runoff from agricultural land

45. There are a few locations where development would significantly increase flood risk elsewhere. For example, the Stretton Fields area by the Sketchley Brook, there is potential for increased flow into the Sketchley Brook from potential new development in the area. It is therefore recommended that SUDS are properly implemented here. The SRFA2 sets out specific requirements for the potential strategic site allocations.

Enhance and Restore the River Corridors 46. The SFRA 1 recommends the following in terms of enhancing and restoring river corridors: • Assess the condition of existing assets (e.g. bridges, culverts, river walls). Refurbishment and/or renewal of the asset should ensure that the design life is commensurate with the design life of the development. Developer contributions should be sought for this purpose. • Developers should look for opportunities to restore and enhance rivers through development to make space for water. Enhancement opportunities should be sought when renewing assets (e.g. de-culverting, the use of bio- engineered river walls, raising bridge soffits to take into account climate change). • Avoid further culverting and building over of culverts. Where practical, all new developments with culverts running through their site should seek to de-culvert rivers for flood risk management and conservation benefit. • Set development back from rivers. The Environment Agency requires an 8 metre wide undeveloped buffer strip for development by all watercourses including those where the Flood Zone does not exist.

Protect and Promote Areas for Future Flood Alleviation Schemes 47. The SFRA 1 recommends the following in terms of future flood alleviation schemes: • Protect Greenfield functional floodplain from future development (our greatest flood risk management asset) and reinstate areas of functional floodplain which have been developed (e.g. reduce building footprints or relocate to lower flood risk zones). • Develop appropriate flood risk management policies for the Brownfield functional floodplain, focusing on risk reduction. • Identify sites where developer contributions could be used to fund future flood risk management schemes or can reduce risk for surrounding areas. • Seek opportunities to make space for water to accommodate climate change.

Flood Awareness and Emergency Planning 48. The SFRA 1 recommends the following in terms of flood awareness and emergency planning: • The emergency planning process is improved using the outputs from the SFRA. • Residential and commercial occupiers within Flood Zone 3 are encouraged to signup to Flood Warnings Direct service operated by the Environment Agency. • Robust emergency (evacuation) plans are implemented for new developments greater than 1 hectare.

Water Resources 49. The Water Cycle Study identifies that there is a current and predicted supply- demand deficit within the study area. In addition, there are European level nature conservation interests at Lyppard Grange Ponds SAC, the Severn and River Wye SAC. A Habitats Regulation Assessment undertaken by Stratford-on- Avon District Council highlighted that in combination with development being proposed in the West Midlands and South West, its proposed Core Strategy could have significant affects on the integrity of these assets due to water abstraction.

50. For these reasons the Study states that planning policies be in place to ensure the efficient use of water in both new and existing housing stock. It recommends that all new development is built at Sustainable Code for Homes level 3/4 for water as a minimum and level 5/6 as an aspiration.

51. The Sustainable Design and Construction Policy includes this standard for water efficiency.

Waste Water Infrastructure 52. The Water Cycle Study recommends that when selecting sites through the Borough Plan consideration should be given to capacity constraints and proximity to wastewater infrastructure. Early discussions were held with Severn Trent Water to identify potential capacity constraints and capacity upgrades, most notably at Nuneaton-Hartshill, Bedworth WwTW and Finham WwTW.

53. Also, surface water should be kept out of the sewerage network, where possible. The removal of the automatic right to connect will help sewerage undertakers reduce surface water connections to the sewerage network. It is recognised that in some locations there will be no practicable alternative other than connecting surface water to the sewerage network, but it is the responsibility of the developer to demonstrate that all other possible drainage alternatives have been explored in the first instance.

54. Foul flows from new developments can be reduced through implementation of water efficiency measures and metering of all new development. This will reduce the new net burden on the wastewater network and at the WwTW.

55. The work on selection of sites has included discussions with the Environment Agency and Severn Trent Water to update information on infrastructure requirements.

Water Quality 56. New development must not cause deterioration of water quality or hinder the ability of a water body to meet the quality standards set by the Water Framework Directive. Locations where the WWTW discharges to watercourses with a higher dilutive capacity should be considered preferable.

57. WWTW are currently located at: Nuneaton-Hartshill, Marston-Bedworth, Bulkington and Finham. The Water Cycle Study has not identified any absolute barriers to development in the Borough. However, it does recognise some constraints to development that need to be addressed in terms of water quality.

58. The work on selection of sites has included discussions with the Environment Agency and Severn Trent Water to update information on infrastructure requirements.

59. Taking this information into account, the following policy is suggested:

Policy CLIM3 – Managing Flood Risk Policy

This policy will:

• Require site location, layout and design to reduce flood risk from all potential sources and take account of the impact of climate change on flood risk. • Require the use of sustainable urban drainage (SUDS) approaches suitable for the local soils and geology, to reduce surface water run-off from new development. • Promote environmental stewardship schemes to reduce water and soil run- off from agricultural land. • Require, where directly related to the development proposed, developers review and renew river and flood infrastructure. Where appropriate river restoration and enhancement and measures to reduce flood risk will be natural rather than engineering led schemes.

Policy Delivery Mechanisms

60. The following delivery mechanisms are relevant:

• Using the Sequential Approach to identify sites at least risk of flooding for development in the Borough Plan and other DPDs. • Developing new flood infrastructure, where relevant, to allow development to take place. • Delivery of projects set out in the Green Infrastructure Plan relating to flood alleviation. • Review the Strategic Flood Risk Assessment on at least a five-yearly basis. • Annual monitoring of the number of planning permissions granted contrary to advice of Environment Agency on either flood defence grounds or water quality. • Annual monitoring of the proportion of development in each Flood Zone and the number of developments incorporating SUDS. • Review the Emergency Planning Strategy.

Alternative Policy Options

Option Reason for Rejection Rely on the approach set out in the A locally framed policy is preferred. This NPPF option takes account of local circumstances within the framework of national planning policy. Include water resources and water Incorporating water resources issues into quality in this policy a policy on sustainable design and construction is preferred. A comprehensive policy on sustainable design and construction will bring a number or related issues together in a single policy. Water quality should be an issue considered when selecting development sites. It is also an issue that should be considered for other development sites that come forward in the existing urban area or as other windfall sites.