Issue and Options 2023

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Option I3b: Each District Council to produce its own Levy Currently, the two district councils have their own separate CIL schedules. St Joseph recommends each District Council should continue with this strategy, as the two geographical areas have different priorities in terms of regeneration, commercial space etc. to allow for reduced or increased CIL rates.

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Option S3.2a: Subject to the Urban Capacity Study, where we assume a brownfield register will be included to assess all brownfield sites, St Joseph support the inclusion of a policy prioritising brownfield development, if proven to be located within a sustainable area. This approach is in line with the National Planning Policy Framework (NPPF), where it encourages the re-development of brownfield land. Consideration should be given to Paragraph 119 where Local Planning Authorities (LPAs) should set a clear strategy through strategic policies to make as much use as possible of brownfield land.

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Q-H3 Option H3a: Do not seek to include minimum space standards in a policy in the SWLP. A number of LPAs across England have adopted the Nationally Described Space Standards (NDSS), specifically falling within large cities such as London and Birmingham where they have a significant amount of apartments. It is not considered strategically important to include this requirement within Part 1 of the Local Plan, however, each Council may find it beneficial to consider the inclusion of NDSS within their Part 2 plans.

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Option C4.1c: Have a phased approach to net zero carbon, setting a future date by which all new development will need to achieve net zero standards. In the intervening period new development will need to meet building regulation standards. To encourage all developments to deliver a net zero carbon development there should be an allowance for flexibility and support from the council in each individual planning consent, to incentivise developers to use sustainable development methods and materials to ensure that there is a level playing field for developers. As well as this, there should be a document that clearly sets out sustainable development methods and materials that are allowed under permitted development. Some Councils have implemented a ‘Net Zero Carbon Toolkit’ to set out why we need to deliver net zero carbon home and how we can achieve this in line with relevant legislation. We suggest the above suggestions are uniformly implemented. It is suggested that as well as the Council looking at the implementation of Net Zero Carbon developments on a site-by-site basis, it is recommended that the council should avoid onerous planning obligations such as CIL and S106 obligations when looking into how to encourage and implement net zero carbon developments to ultimately increase the viability of projects. Improvements or requirements will have implications on the viability across the majority of schemes.

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Option C9.1a: Include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity Paragraph 179 of the NPPF outlines that planning policies and decisions should protect and enhance biodiversity. The Council’s approach to biodiversity net gain should align with the Governments proposals as set out in the Environment Bill. The Government believe that a 10% net biodiversity gain is acceptable. As part of Berkeley’s 2030 vision a 10% net biodiversity gain is a requirement across all of our sites. St Joseph are achieving this, with an average net biodiversity gain of 56% across the company, with Swan’s Landing is set to achieve 94% across the site. Berkeley Group have a strong focus across all of their development across England, including Swan’s Landing in Stratford-upon-Avon, to deliver sites that deliver new habitats. Swan’s Landing seeks to provide bird and bat boxes contained within houses and apartment buildings, as well as hedgehog highways within every garden. Green infrastructure is also provided throughout the scheme, including SUDs basin. It should be noted that in plan making, viability is key to housing delivery, and the costs associated with biodiversity gain may be significant. The viability of producing a positive net biodiversity gain of 10% across all sites should be assessed by the Council on an individual basis to not limit or prevent housing delivery. We believe that a 10% gain is achievable for most developers and that it should be pushed for major developments, to fulfil the guidance set out within the NPPF, and accord with the Government’s Environment Bill.

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As noted within the I&O consultation, Stratford District Council already require a similar assessment, (Development Requirements SPD Part V on Climate Change Adaptation and Mitigation) as a validation requirement for all planning applications. Additional guidance to support this checklist would be useful for applicants/developers to assist with completing the checklist.