Other

ID sylw: 107743

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land-Land to the west of Southam Road, Long Itchington

Asiant : Savills

Bellway supports the need to utilise low carbon heating for new development. However, further consideration needs to be given to the feasibility and suitability of including requirements for decentralised energy systems to provide heating and cooling.
Currently the majority of district heating schemes make use of gas fired Combined Heat and Power (CHP) systems to generate electricity and heat. However, the continued decarbonisation of the electricity network means that this option will emit more carbon than compared to an individual gas boiler.
Future Heat Networks will need to incorporate low carbon technologies, for example Air Source Heat Pumps, or make use of low carbon waste heat from other sources.
Further to the technical constraints noted above the Council’s evidence base supporting this particular policy does not adequately consider the implications of the FHS and FBS on the likely heating requirements and heat density of new development. Nor does it consider the cost and viability of this type of system at this stage.
It is recommended the Council give further consideration to the technical feasibility of heat networks and costs as part of the next stage of Plan preparation to ensure any proposals are feasible and viable.

Other

ID sylw: 107832

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

Paragraph 165(c) of the NPPF states plans should identify opportunities for development to draw its energy supply from decentralised energy supply systems. This is what the draft policy seeks to achieve. It does not make this obligatory and simply encourages use and development of such systems, with regard given to viability considerations. This is supported, as it means the policy will not risk undermining the effectiveness and deliverability of the plan where it is not possible for a scheme to comply with this.

The draft policy states developments will be required to demonstrate a ‘thermal master planning approach’ to maximise energy efficiency opportunities. Clarity should be provided on what this means for developers, along with clear justification for including this within the policy.

The draft policy will require an Energy Statement to be submitted as part of a planning application. It is acknowledged there is support for this requirement within the evidence base, with the Climate Evidence on Renewables and Decentralised Energy Opportunities (May 2024) report recommending this. The building performance standards which Energy Statements will need to demonstrate are met should not exceed the requirements of the national Building Regulations.

Other

ID sylw: 107865

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Taylor Wimpey supports the need to utilise low carbon heating for new development. However, further consideration needs to be given to the feasibility and suitability of including requirements for decentralised energy systems to provide heating and cooling.
Currently, the majority of district heating schemes make use of gas fired Combined Heat and Power (CHP) systems to generate electricity and heat. However, the continued decarbonisation of the electricity network means that this option will emit more carbon than compared to an individual gas boiler.
Future Heat Networks will need to incorporate low carbon technologies, for example Air Source Heat Pumps, or make use of low carbon waste heat from other sources. This type of system does not benefit from the electricity generation in a CHP system which has implications for the financial viability of alternative sources.
Further to the technical constraints noted above, the Council’s evidence base supporting this particular policy does not adequately consider the implications of the FHS and FBS on the likely heating requirements and heat density of new development. Nor does it consider the cost and viability of this type of system at this stage. When considering cost, consideration should be given to the implications of delivering heat networks and tying residents into long term heating contracts with no options on choice of network supplier.
It is recommended the Council give further consideration to the technical feasibility of heat networks and costs as part of the next stage of Plan preparation to ensure any proposals are feasible and viable.

Other

ID sylw: 107951

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

Paragraph 165(c) of the NPPF states plans should identify opportunities for development to draw its energy supply from decentralised energy supply systems. This is what the draft policy seeks to achieve. It does not make this obligatory and simply encourages use and development of such systems, with regard given to viability considerations. This is supported, as it means the policy will not risk undermining the effectiveness and deliverability of the plan where it is not possible for a scheme to comply with this.

The draft policy states developments will be required to demonstrate a ‘thermal master planning approach’ to maximise energy efficiency opportunities. Clarity should be provided on what this means for developers, along with clear justification for including this within the policy.

The draft policy will require an Energy Statement to be submitted as part of a planning application. It is acknowledged there is support for this requirement within the evidence base, with the Climate Evidence on Renewables and Decentralised Energy Opportunities report recommending this. The building performance standards which Energy Statements will need to demonstrate are met should not exceed the requirements of the national Building Regulations.

Other

ID sylw: 108072

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

Paragraph 165(c) of the NPPF states plans should identify opportunities for development to draw its energy supply from decentralised energy supply systems. This is what the draft policy seeks to achieve. It does not make this obligatory and simply encourages use and development of such systems, with regard given to viability considerations. This is supported, as it means the policy will not risk undermining the effectiveness and deliverability of the plan where it is not possible for a scheme to comply with this.

The draft policy states developments will be required to demonstrate a ‘thermal master planning approach’ to maximise energy efficiency opportunities. Clarity should be provided on what this means for developers, along with clear justification for including this within the policy.

The draft policy will require an Energy Statement to be submitted as part of a planning application. It is acknowledged there is support for this requirement within the evidence base, with the Climate Evidence on Renewables and Decentralised Energy Opportunities (May 2024) report recommending this. The building performance standards which Energy Statements will need to demonstrate are met should not exceed the requirements of the national Building Regulations.

Other

ID sylw: 108216

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

The fact that the policy does not make this obligatory and is simply encouraging of the use and development of such systems, with regard given to viability considerations, is supported, as it means that the policy will not risk undermining the effectiveness and deliverability of the plan, where it is not possible for a scheme to comply with this.

The draft policy states that developments will be required to demonstrate a ‘thermal master planning approach’ to maximise energy efficiency opportunities. Clarity should be provided as to what this means for developers, and there should be a clear justification for including this within the policy.

The building performance standards which Energy Statements will need to demonstrate are met should not exceed the requirements of the national Building Regulations.

Other

ID sylw: 108329

Derbyniwyd: 07/03/2025

Ymatebydd: George Martin

Commercial is mentioned in the first sentence and then forgotten. Commercial and industrial sites are often the biggest and most immediate opportunity for decentralised solutions.

UK industrial electricity prices are 4-5 times those of the US (pre-Trump) and 50% higher than Germany. If we want to retain industries and jobs like car manufacturing in Warwickshire, or Aga, etc, then making decentralised renewable energy generation (and energy efficiency) easy is fundamental!

b) should allow for the possibility of going beyond the development site.

Affordability is likely to be a function of the business model. It is easy for a property developer to argue a scheme is unaffordable when a specialist ESCO or similar would have no problem. Attitude to risk (and ability to manage this) is a key factor – but in my limited experience easy for planning consultants and developers to exploit to get the answer they want.

Need to check whether this is in scope of the UK Planning System, but for non-domestic sites, on average 80% of the energy demand is not for buildings per se – it will be for industrial processes. These should be included within scope of any reviews as these are where the major benefits and potential sources of waste heat come from (for use in local heat networks for example).

The section on decentralised energy systems is good but it might make sense to reorder the sections to put support for this before section 7.1 to put it in context.

No

ID sylw: 108462

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

The Bird Group would question the requirement in Draft Policy-F that all “major development” in South Warwickshire will be required to demonstrate a thermal master planning approach to maximise energy efficiency opportunities.
No information is provided in the draft policy, or supporting justification, as to what constitutes “major development” in this context, in fact the justification merely refers to “new developments”. If “major development” represents residential developments of 10 or more dwellings, the Bird Group consider the requirement to be unnecessarily burdensome for many developments.
The policy should also acknowledge that there might occasions where an existing system might be available but does not have enough capacity to accommodate the energy needs of planned new development. Furthermore, if the draft policy is to be taken forward into the Pre-Submission SWLP, to avoid any unnecessary ambiguity the policy should, as per the supporting justification, make clear that that detailed energy statements will be required, to include potential for connection to decentralised energy systems.

Other

ID sylw: 108575

Derbyniwyd: 07/03/2025

Ymatebydd: Corbally Group (Harbury) Ltd

Asiant : Pegasus Group

The fact that the policy does not make this obligatory and is simply encouraging of the use and development of such systems, with regard given to viability considerations, is supported, as it means that the policy will not risk undermining the effectiveness and deliverability of the plan, where it is not possible for a scheme to comply with this.

The draft policy states that developments will be required to demonstrate a ‘thermal master planning approach’ to maximise energy efficiency opportunities. Clarity should be provided as to what this means for developers, and there should be a clear justification for including this within the policy.

The building performance standards which Energy Statements will need to demonstrate are met should not exceed the requirements of the national Building Regulations.

Yes

ID sylw: 108622

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Draft Policy F – Decentralised Energy Systems
6.1.
NPPF §165(c) states that plans should identify opportunities for development to draw its energy supply from decentralised energy supply systems, and this is what the draft policy seeks to achieve. The fact that it does not make this obligatory and is simply encouraging of the use and development of such systems, with regard given to viability considerations, is supported, as it means that the policy will not risk undermining the effectiveness and deliverability of the plan, where it is not possible for a scheme to comply with this.
6.2.
The draft policy states that developments will be required to demonstrate a ‘thermal master planning approach’ to maximise energy efficiency opportunities. Clarity should be provided as to what this means for developers, and there should be a clear justification for including this within the policy.
6.3.
The draft policy will require an Energy Statement to be submitted as part of a planning application. It is acknowledged that there is support for this requirement within the evidence base, with the Climate Evidence on Renewables and Decentralised Energy Opportunities (May 2024) report recommending this. The building performance standards which Energy Statements will need to demonstrate are met should not exceed the requirements of the national Building Regulations.

Other

ID sylw: 108826

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land-Land east of Stratford-on-Avon

Asiant : Savills

Bellway supports the need to utilise low carbon heating for new development. However, further consideration needs to be given to the feasibility and suitability of including requirements for decentralised energy systems to provide heating and cooling.
The 2025 Future Homes Standard (FHS) and Future Buildings Standard (FBS) Consultation { https://www.gov.uk/government/consultations/the-future-homes-and-buildings-standards-2023-consultation/the-future-homes-and-buildings-standards-2023-consultation} set out requirements which will significantly reduce the energy demand of new homes and buildings, this will reduce the thermal demand of new development.
Currently the majority of district heating schemes make use of gas fired Combined Heat and Power (CHP) systems to generate electricity and heat. However, the continued decarbonisation of the electricity network means that this option will emit more carbon than compared to an individual gas boiler.
Future Heat Networks will need to incorporate low carbon technologies, for example Air Source Heat Pumps, or make use of low carbon waste heat from other sources. This type of system does not benefit from the electricity generation in a CHP system which has implications for the financial viability of alternative sources.
Development coming forward after the introduction of the FHS and FBS will only be able to connect to heat networks where the energy demand of the new buildings is matched by equivalent low carbon heat, i.e. delivered through the use of a heat pump.
There may be discrete opportunities for heat networks where there are opportunities around an existing low carbon heat course, or sufficient density, for example large scale blocks of flats. This is noted in the FHS consultation, which states, ‘New low carbon communal and district heat networks will likely be the preferred way of providing heating and hot water to blocks of flats under the Future Homes Standard’. However the consultation anticipates the use of heat pumps in homes and buildings to provide heating and hot water, the policy is therefore unlikely to suit new low density development.
Further to the technical constraints noted above the Council’s evidence base supporting this particular policy does not adequately consider the implications of the FHS and FBS on the likely heating requirements and heat density of new development. Nor does it consider the cost and viability of this type of system at this stage. When considering cost consideration should be given to the implications of delivering heat networks and tying residents into long term heating contracts with no options on choice of network supplier. It is noted that while work is ongoing to regulate heat networks, heat networks are currently not regulated by Ofgem and pricing is not restricted which may impact residents energy costs.
In this context it is considered unlikely that the reduced energy demand of new development is unlikely to provide sufficient heat demand for a low carbon heat network to be feasible or viable for low destiny development. It is recommended the Council give further consideration to the technical feasibility of heat networks and costs as part of the next stage of Plan preparation to ensure any proposals are feasible and viable.