Support

Representation ID: 5077

Received: 02/01/2024

Respondent: Mary Cade

Flood risk due to any development will be affected by the management of any surrounding agricultural land, as well as geology, streams, springs etc Agricultural land that has vegetation cover all year round, including hedges and trees, and a high soil carbon content will be better at absorbing and retaining water/run off.
It is essential that discharge to watercourses and sewers is prevented. Grey water collection is ideal for buildings that have a community use eg schools, employment etc where much water is used for toilet flushing.

Comments noted. Whilst agreeing that management of land within the catchment will have an impact on flood risk of a particular development this could not be controlled through the planning application process and so falls outside the scope of the Local Plan. Management of the catchment is considered in the Flood Risk and River Basin Management Plans produced by the Environment Agency and referenced in the SFRA. he hierarchy for surface water discharge is set out in Policy CC14 with the accompanying text making it clear that surface water discharge to combined sewer systems should be on an exceptional basis only. The use of grey water is not always the most sustainable option due to the on-site treatment (for toilet flushing) and storage requirements, and may actually have a higher carbon footprint than the use of mains water. The inclusion of water butts in new residential development is set out in Local Plan Policy CC6.

Support

Representation ID: 5096

Received: 03/01/2024

Respondent: Natural England

Natural England welcomes this policy which includes promoting the use of sustainable drainage systems (SuDS). We agree that a multi-functional approach to SuDS should be encouraged and take opportunities to incorporate features that enhance and maintain biodiversity as part of a coherent green and blue infrastructure approach. GI reduces flood risk, improves water quality and natural filtration, helps maintain the natural water cycle and sustainable drainage at local and catchment scales, reducing pressures on the water environment and infrastructure, bringing amenity, biodiversity, economic and other benefits.

Support noted.

Support

Representation ID: 5124

Received: 03/01/2024

Respondent: National Highways

Policy CC14 of the local plan sets out the Council’s requirements for ensuring new development does not increase the risk of flooding. In doing so we note that the policy allows for discharging surface water to highway drains. It should be noted however, that with respect on the Strategic Road Network, this would not be permitted (with reference to DfT Circular 01/2022 paragraph 59).

Comments noted. Such consideration would be part of the surface water hierarchy process.

Object

Representation ID: 5474

Received: 05/01/2024

Respondent: Mr John Deag

The SUDS Manual is out of date and is not based on the latest understanding of the effects of climate change on rainfall. Developers should be required to adjust for this and should also show where water will flow to if a SUDS is overwhelmed.

Comments noted. Disagree. The SuDS Manual is referenced in the PPG as offering detailed industry guidance on sustainable drainage schemes and the text accompanying Policy CC14 states that developers ‘should ensure’ that good SuDS principles consistent with national standards ‘such as’ The SuDS Manual. The Environment Agency have also raised no objection to this part of the Local Plan. Some changes to the policy are suggested to reflect comments made by Anglian Water regarding impacts of climate change on flood risk.

Object

Representation ID: 5504

Received: 05/01/2024

Respondent: Mr Murdo Ross

The policy statements are laudable, but omit several important factors. Measures need to reflect the increased incidence and intensity of weather events. Existing down-stream infrastructure needs to be fully assessed on such updated criteria and frequency of cleaning reassessed. Govt policy with their approval of the Braunston Rd North development, confirms that they do not themselves adhere to such policies, with the accepted loss of mature pasture as soak-away and dismissal of the presence of springs.

Comments noted. Agree that effects of climate change on flood risk should be highlighted. Additional sentence in opening para regarding climate change and in relation to SuDS/IWM criteria in the policy (as recommended by Anglian Water). Unable to comment on the decision on the Braunston Road North scheme.

Object

Representation ID: 5576

Received: 05/01/2024

Respondent: Marian Markham

Flood risk policy must go further than just new developments. As seen on 20th October 2024 and 2nd January 2024, Rutland existing infrastructure is in adequate. The A606 flooded in several places. The A6003 flooded. These are main roads through the county and yes, the through traffic took to alternative small residential streets instead on these flood days.

I urge Rutland County Council to include Policy for "slowing the flow" of rainwater in the upper catchments. See https://www.wwt.org.uk/uploads/documents/2023-11-22/wwt-flood-protection-network-route-map-221123.pdf for examples. This can be undertaken in liasion with Severn Trent Water and Anglian Water AMP7 / AMP8 for River Restoration projects.

Comments noted. The flooding of highways is acknowledged in the SFRA (2023) and incidences of this are collated by the council. Whilst agreeing that management of land within the catchment will have an impact on flood risk of a particular development this could not be controlled through the planning application process and so falls outside the scope of the Local Plan. Management of the catchment is considered in the Flood Risk and River Basin Management Plans produced by the Environment Agency and referenced in the SFRA. The use of nature-based solutions to reduce flood risk is set out in Policy EN7 which recognises the importance of blue and green infrastructure provision (including SuDS) in connection with development to reduce overall flood risk.

Object

Representation ID: 5603

Received: 05/01/2024

Respondent: Julie Gray

I believe this policy needs to be much more robust to ensure that the extreme weather seen by climate change is acknowledged and areas at higher risk ( as seen this week) have much tighter controls in place to ensure that development does not further compound the problem. Its apparent that in many places the SUDS are overwhelmed, some of which has been compounded by development.

Comments noted. Agree that effects of climate change on flood risk should be highlighted. Additional sentence in opening para regarding climate change and in relation to SuDS/IWM criteria in the policy (as recommended by Anglian Water).

Support

Representation ID: 5659

Received: 05/01/2024

Respondent: Ketton Parish Council

Agent: Mary Cade

Whilst the risk of flooding is referenced in this and a number of policies, the Strategic Flood Risk Assessment (SFRA) appears to be out of date for the areas to the South East of the county along the Welland Valley, which includes Ketton . Given the increase in flooding in Ketton over recent years from the rivers Chater and Welland, and surface water and springs, this policy may not be sufficiently robust to avoid additional flood problems, considering the new housing developments here (up to 200 homes) over the period covered by the new LP.

Support noted. The overall objective of the SFRA is to identify any constraints on housing and employment growth planned for Rutland up to 2041 that may be imposed by flood risk and how these can be resolved i.e. by ensuring that flood risk taken into consideration. The updated SFRA 2023 uses the latest flood risk maps from the Environment Agency data source March 2023. It also includes an assessment of the implications of climate change on flood risk.

Support

Representation ID: 5765

Received: 06/01/2024

Respondent: Langham Parish Council

Support for policy, but infrastructure inadequate to prevent harm to local communities from flooding. Policy needs extension to encompass remedial action and cooperation with other Agencies to solve flooding problems in Langham .

Support noted. The flooding of highways is acknowledged in the SFRA (2023) and incidences of this are collated by the council. The SFRA document provides a strategic approach to the management of water and would be used in the drawing up for flood risk assessments accompanying planning applications. Policy CC1 seeks to ensure that new development does not place itself or others at increased risk of flooding, taking into account the effects of climate change.

Support

Representation ID: 5800

Received: 06/01/2024

Respondent: Mrs Sue Scarrott

seems sensible

Support noted.

Support

Representation ID: 5850

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

It should be recognised that water bodies can provide multiple ecosystem services for both retaining surface water runoff, biodiversity, and amenity.

It should also be recognised that flood control related to a proposal will also be affected by the management system for any farmland in the water catchment. Land management systems that provide a cover crop and build up soil carbon content, reduce and slow down water runoff.

Add that proposals should include confirmation from the water utility provider that the existing sewage system can take additional building development without releasing additional sewage into storm drains and rivers.

Support noted. The benefits of water bodies are set out under Policy EN7: Green and Blue Infrastructure. Whilst agreeing that management of land within the catchment will have an impact on flood risk of a particular development this could not be controlled through the planning application process and so falls outside the scope of the Local Plan. Management of the catchment is considered in the Flood Risk and River Basin Management Plans produced by the Environment Agency and referenced in the SFRA. The comments of the relevant Water Company would be sought when required on development proposals and they would advise on capacity issues.

Object

Representation ID: 5882

Received: 07/01/2024

Respondent: NGO East Mercia Rivers Trust

As flooding events in January 23 have shown, the drainage infrastructure is inadequate, the policy should include measures to address this. Man-made measures alone cannot stop flooding, river restoration is required to reconnect rivers to their floodplains & slow the flow. 8 metres from a watercourse is inadequate. No development should be allowed on floodplains or areas known to act as soak aways during high rainfall for residential areas. All developers should be required to undertake independent flood modelling to take account of the increasing frequency & intensity of rainfall as well as other proposed developments in the area.

Comments noted. Improvements to drainage infrastructure would be the responsibility of the relevant Water Company and, if appropriate, funding would be secured through the CIL/a Section 106 agreement as part of a planning permission. Management of land and rivers within the catchment will have an impact on flood risk of a particular development this could not be controlled through the planning application process and so falls outside the scope of the Local Plan. Management of the catchment is considered in the Flood Risk and River Basin Management Plans produced by the Environment Agency and referenced in the SFRA. CC14 (as amended) states that: ‘Through the application of the sequential and exception test, as well as the guidance set out in NPPF, development should be located in areas of the lowest flood risk;’. A Flood Risk Assessment submitted with as part of a planning application would consider existing and future predicted flood patterns and the text accompanying Policy CC14 will also be altered to acknowledge the impact of climate change on flood risk.

Support

Representation ID: 5954

Received: 07/01/2024

Respondent: Jane Ellis

RCC needs to directly engage with Parish and Town Councils when flood risk is assessed for large housing development sites (over 10 houses). The LPA does not appear to process the "local knowledge" required when it comes to flood risk assessment, as has been demonstrated by the approval of the Bellway site on Braunston Road South, which has resulted in apparent increased flood risk to neighbouring properties. The Braunston Road North approval is likely to result in further additional flood risk to existing properties

Support noted. Local views, including from Parish and Town Councils, are sought as part of the planning application consultation process. Other consultees such as the Environment Agency, the Internal Drainage Board and the relevant Water Company would consider the Flood Risk Assessment and advise the council accordingly. Unable to comment on the Braunston Road applications as part of the Local Plan process.

Support

Representation ID: 6302

Received: 08/01/2024

Respondent: Mr Chris Read

I'm lost for words.
Maybe mention this to the planning committee sometime.

Comments noted.

Object

Representation ID: 6755

Received: 05/01/2024

Respondent: Barrowden Parish Council

This Policy is ambiguous and needs to be made clearer. It can be read that the policy only applies to major developments which should not be the case.

The use of “where appropriate “ is far too loose and needs to have further clarity either in terms of size of development or size in relation to the plot or total hard surfaced area in relation to the plot size. The B & W Neighbourhood Plans in Policy BW7 has a simple statement which should be used in the Local Plan.

Comments noted. Agree to remove ‘major’ from first sentence in the policy. Disagree regarding use of ‘where appropriate’ as not all development proposals will be required to show that the list of criteria have been addressed. Detailed guidance on the requirements in relation to flood risk to accompany a planning application is set out in the NPPF/PPG. The wording of NP Policy BW7 follows that of the longer Local Plan Policy CC14 and the two policies would be used in the assessment of applicable planning applications.

Object

Representation ID: 6834

Received: 07/01/2024

Respondent: Julie Healey

It is important that in the local plan the floods are avoided by upkeep of the drains on the highways , they must be regularly checked.

Comments noted. Drainage clearance falls outside scope of the Local Plan. It would be carried out by RCC as Highway Authority.

Object

Representation ID: 7072

Received: 08/01/2024

Respondent: Mr Tony Godwin

Policy CC14 - Flood Risk
In view of the recent incidence of flooding in the County I’d propose that this policy should apply to all development – not just major ones. Thus the first sentence should have the word ‘major’ deleted - ‘To reduce the risk of flooding, all major development proposals….’ In Whitwell from living memory it is clear that incremental development even in a small village has had adverse effect on a natural drainage watercourse contributing to the recent flooding.

Comments noted. Agree to remove ‘major’ from first sentence in Policy CC14. This would mean that all development is screened against the flood risk guidance set out in the NPPF.

Object

Representation ID: 7230

Received: 07/01/2024

Respondent: Mr Harold Dermott

The Evidence Base information for this policy is out of date, it quite categorically does not represent the current state of Langham Brook. The 1990s were 30 years ago and Langham Brook has started exceeding its bank capacity again, almost certainly
due to climate change.

In early November 2023, Well Street in Langham was flooded, as was a property on Melton Road. The A606 was also flooded (and again in January 2024). This flooding was almost certainly caused by some significant blockages in the channel of Langham Brook within Langham.

Every time these blockages are raised, RCC undertakes to “remind riparian owners of their responsibilities”. The current ‘riparian owner process’ is demonstrably not working in Langham (and possibly elsewhere) because it appears that RCC has no authority to enforce riparian owners to do their duty. I therefore urge RCC to strengthen CC14 (or the most relevant policy) by reviewing the
‘riparian owner process’ in Rutland to make it workable for all waterways in the county

Comments noted. Policy CC14 covers flood risk from proposed development so it would be outside the scope of the policy, or any other policy in the Local Plan, to enforce riparian owners’ responsibilities when it comes to watercourses. This would be a matter for the council as Lead Local Flood Authority.

Object

Representation ID: 7285

Received: 08/01/2024

Respondent: Manor Oak Homes

Agent: Mr Andy Moffat

It is queried whether a Policy that repeats the requirements of the NPPF is required, and it is noted that the Policy also relates to major development whereas the NPPF applies to all development.

Comments noted. Agree NPPF applies to all development so word ‘major’ should be deleted. Whilst the policy does follow the requirements of the NPPF it aids developers in fleshing out what they should consider in terms of flood risk and mitigation. Similarly worded policies have been adopted recently in other Local Plans.

Support

Representation ID: 7347

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

This wording reflects Paragraph 173 of the NPPF (December 2023).

For both ‘Land south of Stamford Road’ (ref. H1.3) and ‘Land at Uppingham Road’, it is noted that a watercourse runs on the redline boundary between these two sites (i.e. on the southern boundary of ‘Land south of Stamford Road’ (ref. H1.3) and on the northern boundary of ‘Land at Uppingham Road’) and is situated within Flood Zones 2 and 3. The sites are however not located within a Flood Alert Area and the majority of the sites sit within Flood Zone 1 (which has a low probability of flood risk).

It is therefore considered that both sites can be sensitively designed for housing development, with appropriate sustainable drainage systems and green infrastructure located to adjacent the existing watercourse, to optimise development on the rest of the site.

Support noted. Comments not specifically related to content of Policy CC4 and accompanying text. Comments relating to two housing sites dealt with under the other relevant chapter of the Local Plan.

Object

Representation ID: 7497

Received: 08/01/2024

Respondent: Mrs Marlen Godwin

In Whitwell we had 7 homes effected. The natural water course was not taken into account when new homes were added to this small village and subsequently with the added disaster of roadside gutters/gullies not cleared, the heavy waterfall in December followed by more rain last week, caused a catastrophe. Perhaps the impact was greater as Whitwell is small and divided by the A606. But I do wish to thank Council for their customer service folks, and our Ward Councillor, not least MP Kearns for making time to talk to us.

First sentence of CC14 Flood risk says ‘All major development proposals’, this needs to red All development proposals. In the case of our village, minor ones impacted last week and could have been avoided.

Climate Change is here to stay and reducing speed, certainly on the A606 would mitigate this too.

Comments noted. Word ‘major’ to be deleted from first sentence in Policy CC14 and reference to be made to impact of climate change on flood risk in policy and accompanying text. Not applicable to comment on recent flooding event as part of the Local Plan process.

Support

Representation ID: 7616

Received: 08/01/2024

Respondent: Environment Agency

We would suggest the following sentence is added into criterion b of the policy:

b) that the development will be resilient to flood risk from all forms of flooding such that in the event of a flood the development could be quickly brought back into use without significant refurbishment. Through the application of the sequential and exception test, as well as the guidance set out in NPPF, development should be located in areas of the lowest flood risk.

Furthermore, we would welcome an additional criterion to encourage proposals to deliver nature-based solutions to mitigation flood risk, including enhancements to the green and blue infrastructure network, where possible.
We support the ‘Why is this policy needed? (Protecting the water environment section)’ section, which states the LPA will liaise with the EA, IDBs and Water Services providers when relevant proposals come in to discuss and prepare drainage solutions to cope with increased waste water and sewage effluent. However, we would recommend more detail regarding this is added into Policy INF1

Support noted. Agree to delete ‘major’ from first line of Policy CC14 so that it covers all development proposals being considered against the NPPF. Agree to add in ‘Through the application of the sequential and exception test, as well as the guidance set out in NPPF, development should be located in areas of the lowest flood risk;’ as new criteria after a).
The accompanying text makes reference to encouraging a multi-functional approach to SuDS that enhances biodiversity as part of a green and blue infrastructure approach.

Support

Representation ID: 7641

Received: 08/01/2024

Respondent: Severn Trent

Severn Trent is supportive of Policy CC14 in particular the reference to managing surface water flood risk.
We would like to recommend that the wording of Policy CC14 – Flood Risk is updated to include specific mention of ownership and ongoing maintenance of the completed SuDS schemes:
"All major developments shall ensure that Sustainable Drainage Systems (SuDS) for the management of surface water run-off are included, unless proved to be inappropriate. All schemes with the inclusion of SuDS should demonstrate they have considered all four areas of good SuDS design: quantity, quality, amenity and biodiversity. Completed SuDS schemes should be accompanied by a maintenance schedule detailing maintenance boundaries, responsible parties and arrangements to ensure the SuDS are managed in perpetuity."
Additions should also be made to the wording of the supporting text.

The suggested Drainage Hierarchy Policy is included as part of Policy CC14 as criteria f) and is explained in the supporting text. With regards to suggested SuDS policy, this is covered in Policy CC14 and the accompanying text. Agree to include additional sentence regarding long term management of SuDS: in second para on page 56 before last sentence add in: ‘Completed SuDS schemes should be accompanied by a maintenance schedule detailing maintenance boundaries, responsible parties and arrangements to ensure the SuDS are managed in perpetuity.’

Support

Representation ID: 7737

Received: 08/01/2024

Respondent: Anglian Water

Anglian Water supports the intention of Policy CC14 – Flood Risk. One addition should recognise the increased risk of flooding for existing communities due to Climate Change and the cumulative risks that land use change in an area can have on that risk in light of more extreme weather events including drought and storms. The policy should require developers to consider betterment to address the wider flood risks that the proposed development may affect. Text from another Councils emerging plan, perhaps anticipating changes in EA flood risk models in 2024 and NPPF policy, says, ‘Providing betterment over the existing situation in areas at risk of flooding and seeking to achieve integrated water management’. We recommend the current WCS and SFRA are updated in 2024/ 25 to be an Integrated Water Management Study including updated EA flood modelling including surface water flows and new climate change allowances.

Support noted. Agree to include reference to increased risk of flooding from climate change: Add in extra sentence at end of first para: ‘One of the most notable indications of climate change has been the increase in the frequency and severity of flooding. This policy is part of an integrated water management approach to water management in Rutland.'
Add in extra sentence to end of criteria e) ‘The design of the SuDS/Integrated Water Management should demonstrate how the effects of climate change has been considered.’

Object

Representation ID: 7848

Received: 08/01/2024

Respondent: Alicia Kearns

The lack of a full flooding strategy in the Local Plan is concerning. The recent serious flooding in October 2023 and this month (January 2024) have highlighted the need for improved mitigation measures. The recent flooding on the Bellway Development in Oakham represents a failure in the current planning criteria to adequately consider flooding risks. Stricter flooding assessments should be included in the Local Plan to avoid development on flood plains and improve mitigation measures across Rutland.

Comments noted. The overall objective of the SFRA is to identify any constraints on housing and employment growth planned for Rutland up to 2041 that may be imposed by flood risk and how these can be resolved, i.e. by ensuring that flood risk taken into consideration. It also includes an assessment of the implications of climate change on flood risk. The SFRA will be updated as the Local Plan progresses. Other flood documents are produced for Rutland, such as the Flood Risk and River Basin Management Plans produced by the Environment Agency. The effects of climate change must be taken into flood risk assessments and this requirement is set out in Policy CC14 (as changed).

Object

Representation ID: 7893

Received: 08/01/2024

Respondent: Ryhall Parish Council

RCC should now recognise that existing model for flood defence is now obsolete and need to consider more rigorous survey work. What was considered as one in a hundred-year events are now more like one in every 3 years as climate change takes hold.

Clogged ditches and gullies in Ryhall’s Back Lane and Belmesthorpe Lane/Shepherd’s Walk have been the cause of significant localized flooding and RCC needs to invest in preventative clearing these to ensure they function as required. Liaison with Anglia Water on a long-term issue in Foundry Road is illustrative of poor attention to this important preventative issue.

Comments noted. The impact of climate change on flood risk is recognised and set out in Policy CC14 and the accompanying text (as changed). Problems of local drainage issues fall outside the scope of the Local Plan and are a matter for the council as Highway/Lead Local Flood Authority.

Object

Representation ID: 8045

Received: 08/01/2024

Respondent: Ketton and Tinwell Joint Neighbourhood Plan Steering Group

While the risk of flooding is referenced in a number of policies, the Strategic Flood Risk Assessment (SFRA) appears to us to be out of date for the areas to the South East of the county along the Welland Valley. The draft 2023 assessment available on the RCC web site is based on a 2009 SFRA with updates carried out using a desktop assessment process.

Given the increase in flooding over recent years from the Chater, Welland, Surface Water and Underground Springs we do not believe that the Local Plan is robust enough in this respect to ensure additional flood problems with new developments over the period covered by the new Local Plan will be addressed.

The draft SFRA also includes a list of reported flooding events over the period Jan 2018 to June 2023. While there are a number of entries from Ketton, these do not cover the full impact of the flood events over the period. The RCC website does not include a reporting mechanism for flooding.

The overall objective of the SFRA is to identify any constraints on housing and employment growth planned for Rutland up to 2041 that may be imposed by flood risk and how these can be resolved i.e. by ensuring that flood risk taken into consideration. The updated SFRA 2023 uses the latest flood risk maps from the Environment Agency data source March 2023. It also includes an assessment of the implications of climate change on flood risk.