BASE HEADER

No

ID sylw: 108739

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We object to Draft Policy H as currently worded. Planning Practice Guidance (Paragraph: 014 Reference ID: 56-014-20150327 and Paragraph: 015 Reference ID: 56-015-20150327) states that where there is a clear local need, Local Plan policies can “require new dwellings to meet the tighter Building Regulations optional requirement of 110 litres/person/day”. LPAs are required to establish a clear need
based on:
• “existing sources of evidence.
• consultations with the local water and sewerage company, the Environment Agency and catchment partnerships.
• consideration of the impact on viability and housing supply of such a requirement.”
We recognise that the Water Cycle Study (2024) produced to support the plan recommends that a water efficiency standard of 100 litres/person/day should be required in the SWLP. However, there is no basis for implementing such a strict requirement, which goes beyond the optional technical standard of 110 litres.
The Written Ministerial Statement issued on 13 December 2023 (Statement UIN HCWS123, 13 December 2023)
states that “the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations”. The statement goes on to state that any planning policies which propose standards in excess of current or planned building regulations must ensure that development remains viable and that the impact on housing deliverability and affordability is considered. Aat this stage in the plan-making process, the evidence base for the SWLP does not include evidence to demonstrate the viability of the 100 litres/person/day requirement. In the absence of this information to justify the policy requirements, we object to the policy as currently worded due to a lack of compliance with national planning policy as set out in the PPG.