Yes

ID sylw: 104407

Derbyniwyd: 07/03/2025

Ymatebydd: South Warwickshire Foundation trust

Yes, the broad approach is agreed on with the note that non-residential buildings should either remain operational during the retrofit or services moved to an alternative and suitable location.

Yes

ID sylw: 104694

Derbyniwyd: 07/03/2025

Ymatebydd: Miss Ann Colley

agree

Yes

ID sylw: 104729

Derbyniwyd: 07/03/2025

Ymatebydd: John Stott

Again a much needed statement about existing buildings

Yes

ID sylw: 104942

Derbyniwyd: 07/03/2025

Ymatebydd: Ms Susan Ingleby

Yes

Yes

ID sylw: 106897

Derbyniwyd: 06/03/2025

Ymatebydd: Historic England

We welcome the reference to historic buildings in this policy direction and accompanying text. Historic England has a wealth of published guidance in relation to the historic environment and energy and carbon efficiency. In particular we refer you to the following:

our recently published Historic England Advice Note 18 (July 2024) ‘Adapting Historic Buildings for Energy and Carbon Efficiency’:

https://historicengland.org.uk/images-books/publications/adapting-historic-buildingsenergy-carbon-efficiency-advice-note-18/

and we would also recommend reference to:

https://historicengland.org.uk/advice/technical-advice/retrofit-and-energy-efficiencyin-historic-buildings/

Yes

ID sylw: 107079

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 23. This approach aligns with the approach that is advocated in Policy CC1 (Climate Change - Mitigation) of the CNL Management Plan45 and in the Board’s Climate Change Strategy46.

Other

ID sylw: 107331

Derbyniwyd: 07/03/2025

Ymatebydd: Stratford-on-Avon District Social Inclusion Partnership

Broadly in agreement with Draft Policy Direction 23 but consider that there is room for outlining additional steps that could be considered to fully enable improvements to energy efficiency and the sensitive retrofitting of energy efficiency measures.

Planning issues related to the installation of energy efficiency measures in conservation areas and requiring listed building consent presents significant hurdles both for ‘able to pay’ residents, and for government grant retrofit programmes delivered by the Local Authorities. Residents may desire to reduce their energy consumption but are unsure which measures to prioritise and may be put off by confusion around permitted development guidelines
and the time and expense required to obtain permissions.

Options for supporting residents in sensitively retrofitting energy efficiency measures and the appropriate use of micro-renewables include:

• Providing more information for residents online to clearly explain permitted development within conservation areas and permissions required for conservation areas and listed building in the form of web pages/fact sheets (example attached)

• Prioritising applications relating to retrofitting energy efficiency measures or clean heat measures

• Providing a dedicated planning officer to provide advice to residents who are thinking of retrofitting energy efficiency measures or clean heat measures

• Offering a free, paid, or sliding-scale cost pre-application advice service for listed buildings, buildings of solid wall or traditional construction, and buildings within conservation areas relating to the installation of energy efficiency or clean heat measures (example attached)

• Offering free, paid, or sliding-scale cost ‘fast-track’ application processing for listed buildings, buildings of solid wall or traditional construction, and buildings within conservation areas relating to the installation of energy efficiency or clean heat measures.

Other

ID sylw: 107357

Derbyniwyd: 06/03/2025

Ymatebydd: National Trust

The places that the National Trust care for in the South Warwickshire Local Plan area are very historic and heating and cooling systems have often been retrofitted in the intervening years between the National Trust taking on the property from the historic owner. There are often proposals to remediate this retrofitting with the intention to introduce low or zero carbon measures to generate or use energy. We would therefore recommend that any consideration of low or zero carbon development in historic environments is assessed appropriately, in the context of the high constraints present. This approach would also apply in respect of reducing energy consumption in existing historic buildings.

No

ID sylw: 108324

Derbyniwyd: 07/03/2025

Ymatebydd: George Martin

As with other net zero policies for buildings in the consultation, it is not specific enough and has no teeth. 

I am pleased to see reference to LETI and Passivhaus, but the policy misses the AECB CarbonLite Retrofit Standard which is better for traditional buildings and also takes into account many more retrofit risks.  The STBA Guidance Wheel provides the opportunity to research the interactions between different options of retrofit. 

As an alternative to AECB CarbonLite Standard or Passivhaus (EnerPHit) then PAS 2035 (for domestic buildings) & Trustmark should be required as it has consumer protection and QA embedded in it.  

The various emerging documents and standards from the National Retrofit Hub should also be included.

For non domestic buildings, PAS 2038 should be used but need to check if this has consumer protection. For commercial Properties the BBP Low carbon Retrofit tool.

The policy needs to set out clearly when each standard should be required. If left to the applicant it will just not happen.

The policy appears to rely heavily on EPCs for domestic buildings.  By comparison with DECs (for non-domestic buildings) EPCs are generally considered as unfit for purpose.  The authors of this policy should look at the following two references:

• Letter from Lord Deben chair, Committee on Climate Change to Lee Rowley MP parliamentary Under Secretary of State dated 2nd February 2023 - Reform of domestic EPC rating metrics to support of Net Zero
• National Retrofit Hub response to the ‘Reforms to the Energy Performance of Buildings regime’ consultation 2024-2025 - February 2025.

It is agreed by the committee on Climate Change that the current EPC is unfit for purpose. Work is underway to change this. EPC C is not going to deliver net zero. The authors should check what other targets are proposed between 2030 and 2050.

As the South Warwickshire Joint Climate Action Programme (October 2021) Is 4 years old it should be reviewed.

The STBA approach is important for listed buildings and properties in Conservation Areas.

Yes

ID sylw: 108393

Derbyniwyd: 07/03/2025

Ymatebydd: Alscot Estate

Asiant : Jonathan Thompson Land & Consultancy Limited

The Estate fully support Draft Policy Directions 22, 23 and 24