Other

ID sylw: 103388

Derbyniwyd: 07/03/2025

Ymatebydd: Richborough - Wellesbourne Road, Wellesbourne

Asiant : Turley

Draft Policy Direction 22 as currently drafted goes against national Government guidance and further work is required to demonstrate that such an approach is viable.

The SWLP should consider the policies within the existing Warwick District Council’s Net Zero Development Plan Document, which requires development to achieve Net Zero Carbon in operation and aligned with the Governments’ The 2025 Future Homes Standard (FHS) and Future Buildings Standard (FBS) Consultation (2023) along with the 2023 Written Ministerial Statement, which includes information on setting requirements which exceed the requirements of Building Regulations.

Other

ID sylw: 103392

Derbyniwyd: 07/03/2025

Ymatebydd: Richborough - Plough Lane, Bishop's Itchington

Asiant : Turley

Draft Policy Direction 22 as currently drafted goes against national Government guidance and further work is required to demonstrate that such an approach is viable.

The SWLP should consider the policies within the existing Warwick District Council’s Net Zero Development Plan Document, which requires development to achieve Net Zero Carbon in operation and aligned with the Governments’ The 2025 Future Homes Standard (FHS) and Future Buildings Standard (FBS) Consultation (2023) along with the 2023 Written Ministerial Statement, which includes information on setting requirements which exceed the requirements of Building Regulations.

Yes

ID sylw: 103672

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Philip Wall

Must reduce carbon footprint of ALL new development

Yes

ID sylw: 103760

Derbyniwyd: 07/03/2025

Ymatebydd: Mrs Deborah Carter

Reduce CO2 output and future energy requirements for the region

No

ID sylw: 103772

Derbyniwyd: 07/03/2025

Ymatebydd: Jack Casey

It is our position that the Building Regulations is the appropriate mechanism for delivering carbon reduction emissions. This standard approach provides certainty to housebuilders as efficiencies in supply chains will encourage delivery. These locally set standards complicate matters and could frustrate development.

Yes

ID sylw: 103812

Derbyniwyd: 07/03/2025

Ymatebydd: Claire Jones

We need to focus on green and sustainable homes, but also need to think about the developments. They need to have lots of trees and nature friendly planting

Yes

ID sylw: 104067

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Stephen Norrie

This is a good policy, showing a lot of work, and deserves praise. I am worried that the approach to airtightness and ventilation could encourage damp houses.

Yes

ID sylw: 104252

Derbyniwyd: 07/03/2025

Ymatebydd: Ms Rachel Pope

These are sensible requirements and criteria which, importantly, go beyond current building regulations in order to achieve Net Zero. If, at the time that any future planning permissions are granted, national policy has not caught up, it will be important to find ways to ensure that the requirements are enforced and that developers are not allowed to circumvent them.

Yes

ID sylw: 104406

Derbyniwyd: 07/03/2025

Ymatebydd: South Warwickshire Foundation trust

Yes, the approach is broadly supported. However, please see below key considerations:

• The NHS Trust strongly supports measures that align with the NHS's own Net Zero and sustainability goals, particularly those that reduce long-term operational energy costs and enhance resilience.
• The emphasis on both operational and embodied carbon reductions is welcome.
• The commitment to the Future Homes Standard (FHS) and Future Buildings Standard (FBS) is supported, provided that the approach remains flexible and evidence-based.
• Mechanical ventilation should only be installed when passive ventilation is not suitable.

Yes

ID sylw: 104455

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Neal Appleton

Agree, but fossil-free fuel does not mean only heat pumps. Policy should allow for fossil-free systems that are not entirely reliant on electricity. This diversifies fuel reliance, making our communities collectively more resilient. In the event of the kind of weather that disrupts power supplies, resilient heating systems will be key.

Yes

ID sylw: 104684

Derbyniwyd: 07/03/2025

Ymatebydd: Miss Ann Colley

agree with all aspects

Yes

ID sylw: 104721

Derbyniwyd: 07/03/2025

Ymatebydd: John Stott

A good set of requirements that should achieve what has been essential for many years.

Yes

ID sylw: 104756

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Ian Dunning

Yes except remove the clauses that let small developers get out of it.

Yes

ID sylw: 104937

Derbyniwyd: 07/03/2025

Ymatebydd: Ms Susan Ingleby

Yes. I support all of this except carbon offsets which are proving to be rather dubious.

Yes

ID sylw: 104953

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Kenneth Chitty

Whilst in agreement with the requirementIt would be worth looking at the Goldsmith Street development designed by Mikhail Riches in Norwich for the local council. comprising 105 high density dwellings the residents report that even on the coldest days they seldom need to put heating on. Clearly whatever was done actually works and should be used as a working model within the SWLP and mandated on developers.

Other

ID sylw: 105105

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

Whilst St Philps strongly supports the SWAs moving towards Net Zero Carbon development, as set out in detail in St Philps’ response to Draft Policy Direction- 24 (Embodied carbon), if the SWAs wish to deviate from the Future Homes Standard and Building Regulations, sufficient evidence will need to be prepared to justify this – in accordance with NPPF paragraph 32, the PPG and the 2023 WMS.

In addition, the NPPF is clear that planning policies should have regard to the economic viability of sites (Para 72) and should not undermine the deliverability of the Local Plan (Para 35). To this end, the SWLP will need to be supported by A Viability Assessment that cumulatively tests the impact of policy and infrastructure requirements on the viability of sites allocated in the SWLP. This should include any Net Zero Carbon requirements.

No

ID sylw: 105272

Derbyniwyd: 03/03/2025

Ymatebydd: Lockley Homes

Asiant : Goldfinch Town Planning Services (West Midlands)

Highly onerous Climate Change Net Zero policies are being taken forward within the emerging SWLP which will place a financially damaging burden on new housing development proposals, at a time when the construction industry is operating within a climate of stubbornly high interest rates, high inflationary pressures, during a severe economic recession, and at a time when the industry is facing a huge spike in the financial costs of building materials, and significant increases in skilled construction labour costs.

Other

ID sylw: 106201

Derbyniwyd: 07/03/2025

Ymatebydd: Acres Land & Planning

The Government will introduce Future Homes Standards in due course and this will determine the blueprint for developers and builders to follow. The Draft Policy Direction 22 appears to go well beyond this in setting different and tougher standards without any clear justification – although the criteria listed in the policy are helpful in general terms. Has any liaison taken place with builders’ representatives on this topic?

Other

ID sylw: 106211

Derbyniwyd: 07/03/2025

Ymatebydd: Cala Homes (Cotswolds)

Asiant : Lichfields (London)

Cala supports the overall direction of this draft policy direction and commits to providing high quality, sustainable and energy-efficient developments. However, there may be some sites where meeting zero-carbon will be unviable. It is unclear whether the last sentence of this draft policy direction relates to Part A (residential buildings) and Part B (non-residential buildings) or just to Part B. This needs to be clarified. NPPF Paragraph 72 states that policies should have regard to economic viability and Paragraph 35 states that contributions should not undermine deliverability of the Local Plan. The impact of Net Zero Carbon requirements on deliverability should therefore be tested as part of viability assessments of the SWLP.

Other

ID sylw: 106392

Derbyniwyd: 06/03/2025

Ymatebydd: Rachael Newsome

Make solar panels be attached to all the acres of factory rooftops.

Other

ID sylw: 106471

Derbyniwyd: 28/02/2025

Ymatebydd: McCarthy Stone and Churchill Living

Asiant : The Planning Bureau Ltd

Were the Council to seek net zero or ask for higher standards than the building regulations from new development from the point of the Local Plan’s adoption then we would remind the Council to include the uplift in build costs for delivering net zero within any forthcoming
Local Plan viability assessment and that the PPG states that “Viability assessment should not compromise sustainable development but should be used to ensure that policies are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of
the plan” (Paragraph: 002 Reference ID: 10-002-20190509). Therefore, in order for the future plan to be found sound the following should be implemented:
• Any future policy should be stepped in line with emerging government targets and requirements and
• Ensure the policy is properly assessed within the forthcoming viability assessment

No

ID sylw: 106651

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

Whilst we would agree with the Councils that there is a need to act to reduce carbon emissions, we disagree that this needs to be undertaken through the local plan given that there is already a national approach being taken forward to achieve the same goal, the Future Homes Standard (FHS). 8 Currently if the Councils choose to go beyond current or future standards the following stated requirements must be subject to viability testing as part of the Pre-Submission SWLP: • The requirement under Part A that residential buildings must be designed and built to be Net Zero Carbon in operation and that they must generate renewable energy on-site to at least match annual energy use; and • The requirement under Criterion 2 for heat pumps to be the primary heating system for houses unless in areas with low-carbon district heating networks. • Under Criterion 4, it is suggested that battery storage may be required for future residential development schemes. This should be viability tested and the implications for battery storage investigated in terms of space requirements and maintenance.Regarding the requirement under Criterion 4 for roof orientation that maximises PV generation options where possible. We consider it is important that the Councils first establish what impact this could potentially have on scheme density, and how this requirement if applied would align with the SWLP’s design policies. Similarly, Criterion relates to compact building forms and will have direct implications for scheme layouts. This requirement also needs to be considered alongside the SWLP’s design policies.

Other

ID sylw: 106820

Derbyniwyd: 27/02/2025

Ymatebydd: Pauline Prestt

Please ensure that the new homes built are net zero with solar panels and possibly district heating schemes not gas boilers.

Other

ID sylw: 106968

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

Bellway supports the transition to delivering Net Zero development, however has concerns over elements of the policy as currently drafted which go against national Government guidance, have design implications which have not been thought through, and will have viability issues not yet considered.
The WMS states, ‘the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations. Any planning policies that propose local energy efficiency standards for buildings that go beyond current or planned buildings regulation should be rejected at examination if they do not have a well-reasoned and robustly costed rationale.’ In this context it is considered that as proposed Policy contradicts the Government’s WMS and as such the space heating, total energy use and energy performance requirements should be removed or reconsidered to align with the 2023 Future Homes and Buildings Standard Consultation and WMS which describes Net Zero Ready development.
It is recommended that the Policy only considers requirements which relate to regulated emissions only in line with the principles set out in the 2023 WMS and the recent examination and modifications to the Bristol Local Plan Review.
We support the provision of Solar PV to provide onsite energy generation, however, this expectation is not likely to be feasible across a development with a mix of housing including flats, bungalows and homes.
It is recommended that the Plan considers the approach and Policies set out in the Warwick District Council Net Zero DPD which requires development to achieve Net Zero Carbon in operation. This provides a route to achieving Net Zero this which aligns with the Governments 2025 FHS and FBS, and 2023 Written Ministerial Statement on setting requirements which exceed the requirements of the Building Regulations.

Other

ID sylw: 107017

Derbyniwyd: 07/03/2025

Ymatebydd: Cherwell District Council

DTC RESPONSE:

We note the section seeking to address climate change and to move towards achieving net zero
carbon within South Warwickshire. We note the priority for the creation of a green and clean
environment and for the an emphasis towards wellbeing and your approach to meeting your
climate change objectives.

Yes

ID sylw: 107078

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Yes, the Cotswolds National Landscape (CNL) Board agrees with the approach laid out in Draft Policy Direction 22.
This approach aligns with the approach that is advocated in Policy CC1 (Climate Change - Mitigation) of the CNL Management Plan43 and in the Board’s Climate Change Strategy44.

Other

ID sylw: 107330

Derbyniwyd: 07/03/2025

Ymatebydd: Stratford-on-Avon District Social Inclusion Partnership

We agree with this section of the document, however if this leads to house price inflation, measures should be taken to ensure that owner occupation does not go beyond the reach of local households and where affordability is a significant issue and justifiable, alternative forms of low cost affordable home ownership models must be considered.

No

ID sylw: 107519

Derbyniwyd: 07/03/2025

Ymatebydd: Davidsons Homes

Asiant : Cerda Planning Ltd

We wish to place a holding objection in relation to this policy direction, absent of having a full understanding as to how realistic this policy direction is and whether it should be scaled back to align with the current Building Regulations. Whilst the policy could support proposals that meet the net zero carbon standard and additional planning weight may be given to such proposals by the decision maker, to require all new buildings to meet this standard at this time could be undeliverable. Our concern is that the products do not exist given that Building Regulations do not require this higher target as standard. We would wish to work with the Councils in developing this element of the SWLP further.

Other

ID sylw: 107668

Derbyniwyd: 07/03/2025

Ymatebydd: Cala Homes (Cotswolds)

Asiant : Lichfields (London)

Cala supports the overall direction of the Draft Policy Direction 22 to reduce carbon footprint and the general measures to achieve this such as air tightness and ventilation, renewables, compact building form, cool and green roofs etc. Cala commits to providing high quality, sustainable and energy-efficient developments.
However, due the financial and practical constraints to achieve net zero carbon on some sites, there may be cases where meeting zero carbon in new development is unviable. This needs to be balanced against the policy aspirations. It is noted that the last sentence of the draft policy direction states, “It should be noted that where full compliance is not feasible or viable the applicant needs to submit robust evidence along with the energy statement setting out clearly the reasons for non-compliance.” It is not fully clear however whether this relates to Part A (residential buildings) and Part B (non-residential buildings) or just to Part B. This needs to be clarified.
The NPPF, para 72, is clear that planning policies should have regard to the economic viability of sites and that policies which seek contributions from development should not undermine the deliverability of the Local Plan (Para 35). To this extent, Cala considers that as part of any viability assessment that is undertaken by South Warwickshire to support the SWLP, this must include the impact of Net Zero Carbon requirements on deliverability of sites and the ability to meet the policies set within the Local Plan.

Other

ID sylw: 107744

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

Bellway supports the transition to delivering Net Zero development, however has concerns over elements of the policy as currently drafted which go against national Government guidance, have design implications which have not been thought through, and will have viability issues not yet considered. Below a number of key issues have been identified and are considered.
As part of the Bristol Local Plan Review examination the Examiner has reviewed Bristol’s Net Zero policies which set out similar energy performance targets, and as part of the main modifications has removed these requirements3 . In place of the energy performance targets the modifications include a requirement for development to achieve a 100% reduction in regulated carbon emissions only. This reason for the change is noted as the 2023 WMS set out above.
In this context it is considered that as proposed Policy contradicts the Government’s WMS and as such the space heating, total energy use and energy performance requirements should be removed or reconsidered to align with the 2023 Future Homes and Buildings Standard Consultation and WMS which describes Net Zero Ready development.
While we support the delivery of low carbon development it is considered any targets should be restricted to regulated energy only.
With regards to air tightness the FHS consultation notes that as part of the consultation consideration was given to, ‘better walls, floors, roofs, triple glazing and improved thermal bridging. However, the only cost effective and practical improvement we found could be made to the standard was an improvement in airtightness. This improvement in airtightness is matched with the change to a decentralised mechanical extract ventilation system’.
We support the provision of Solar PV to provide onsite energy generation, however, this expectation is not likely to be feasible across a development with a mix of housing including flats, bungalows and homes. Delivering 3kWp – 4kWp per dwelling will require c.24-32m2 of roof space, which for smaller units will not be achievable. Furthermore, where there may be sufficient roof space available it is likely that this requirement would have unintended design implications, reducing the potential for design including roof lights, dormer windows, split roofs etc which are often considered a requirement to create a well-designed development.
It is noted that the form factor targets set out here are recommendations only, we would recommend that it is noted that these are set out in the context of needing to balance design with performance.
It is recommended that the Plan considers the approach and Policies set out in the Warwick District Council Net Zero DPD which requires development to achieve Net Zero Carbon in operation. This provides a route to achieving Net Zero this which aligns with the Governments 2025 FHS and FBS, and 2023 Written Ministerial Statement on setting requirements which exceed the requirements of the Building Regulations.