Other

ID sylw: 102166

Derbyniwyd: 07/03/2025

Ymatebydd: IM Land 1 Limited

Asiant : Turley

IM Land recommend that the approach set out in the Warwick Net Zero DPD and supporting SPD is followed, which requires the consideration and reduction of upfront embodied carbon, without setting a specific target at this stage. The application of specific targets needs to be fully considered as part of the Plan evidence base and viability.

Yes

ID sylw: 102204

Derbyniwyd: 07/03/2025

Ymatebydd: BDW Trading Limited

Asiant : Knight Frank LLP

The policy focuses on reducing embodied carbon in new developments by encouraging the reuse of existing building materials and adopting circular economy principles. This approach aligns with the NPPF, in relation to mitigating climate change through sustainable construction practices.

However, it should be noted that the proposed 'Part Z' amendment, advocating for the inclusion of embodied carbon considerations in Building Regulations, whilst not yet enacted into law, may provide alternative measures. Therefore, the SWLP's policy on embodied carbon should be worded in a way to ensure consistency with emerging Building Regulations amendments to avoid unnecessarily exceeding these.

Other

ID sylw: 102314

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

We would recommend that the approach set out in the Warwick Net Zero DPD and supporting SPD is followed, this requires the consideration and reduction of upfront embodied carbon, without setting a specific target at this stage. The application of specific targets needs to be fully considered as part of the Plan evidence base and viability assessment.

No

ID sylw: 102344

Derbyniwyd: 07/03/2025

Ymatebydd: Richborough

Asiant : Marrons

The importance of lowering embodied carbon in building materials is understood, and this being encouraged by policy is noted. The quantitative targets within Policy Direction 24 refer however to the Low Energy Transformation Initiative (LETI) and the Royal British Institute of Architects (RIBA) rather than specific analysis for the Plan area. A local analysis of the ability of different types and scales of development to meet an embody carbon policy should be prepared and subsequently tested through viability.

Other

ID sylw: 102443

Derbyniwyd: 07/03/2025

Ymatebydd: Hill Residential

Asiant : Turley

Hill Residential supports the need to measure and reduce the embodied carbon of development. However, the requirements of this policy will require further consideration to ensure that they are feasible and viable. Hill Residential would recommend that the approach set out in the Warwick Net Zero DPD and supporting SPD is followed, this requires the consideration and reduction of upfront embodied carbon, without setting a specific target at this stage. The application of specific targets needs to be fully considered as part of the Plan evidence base and viability assessment.

Other

ID sylw: 102879

Derbyniwyd: 07/03/2025

Ymatebydd: Turley

Clarification on elements of the draft policy direction requested.

Yes

ID sylw: 102915

Derbyniwyd: 07/03/2025

Ymatebydd: Mr David Bailey

I agree.

No

ID sylw: 103044

Derbyniwyd: 07/03/2025

Ymatebydd: Bloor Homes

Asiant : Marrons

The importance of lowering embodied carbon in building materials is understood, and this being encouraged by policy is noted. The quantitative targets within Policy Direction 24 refer however to the Low Energy Transformation Initiative (LETI) and the Royal British Institute of Architects (RIBA) rather than specific analysis for the Plan area. A local analysis of the ability of different types and scales of development to meet an embody carbon policy should be prepared and subsequently tested through viability.

Other

ID sylw: 103404

Derbyniwyd: 07/03/2025

Ymatebydd: Richborough - Salford Road, Bidford-on-Avon

Asiant : Turley

Richborough support the SWLP’s ambitions to measure and reduce the embodied carbon of development within the SWLP area. However further evidence is essential to demonstrate that such requirements are viable.

It is noted that the Government intend to set future national targets for embodied carbon emissions through amendments to Building Regulations. This would circumvent the need for policy requirements.

The policies within WDC's existing Net Zero DPD and supporting SPD require the consideration and reduction of upfront embodied carbon, without setting a specific target at this stage. Richborough consider that this would be reasonable approach for the SWLP.

Other

ID sylw: 103406

Derbyniwyd: 07/03/2025

Ymatebydd: Richborough - Gaydon Road, Bishop's Itchington

Asiant : Turley

Richborough support the SWLP’s ambitions to measure and reduce the embodied carbon of development within the SWLP area. However further evidence is essential to demonstrate that such requirements are viable.

It is noted that the Government intend to set future national targets for embodied carbon emissions through amendments to Building Regulations. This would circumvent the need for policy requirements.

The policies within WDC's existing Net Zero DPD and supporting SPD require the consideration and reduction of upfront embodied carbon, without setting a specific target at this stage. Richborough consider that this would be reasonable approach for the SWLP.

Other

ID sylw: 103411

Derbyniwyd: 07/03/2025

Ymatebydd: Richborough - Lighthorne Road, Kineton

Asiant : Turley

Richborough support the SWLP’s ambitions to measure and reduce the embodied carbon of development within the SWLP area. However further evidence is essential to demonstrate that such requirements are viable.

It is noted that the Government intend to set future national targets for embodied carbon emissions through amendments to Building Regulations. This would circumvent the need for policy requirements.

The policies within WDC's existing Net Zero DPD and supporting SPD require the consideration and reduction of upfront embodied carbon, without setting a specific target at this stage. Richborough consider that this would be reasonable approach for the SWLP.

Other

ID sylw: 103412

Derbyniwyd: 07/03/2025

Ymatebydd: Richborough - Sycamore Close, Stockton

Asiant : Turley

Richborough support the SWLP’s ambitions to measure and reduce the embodied carbon of development within the SWLP area. However further evidence is essential to demonstrate that such requirements are viable.

It is noted that the Government intend to set future national targets for embodied carbon emissions through amendments to Building Regulations. This would circumvent the need for policy requirements.

The policies within WDC's existing Net Zero DPD and supporting SPD require the consideration and reduction of upfront embodied carbon, without setting a specific target at this stage. Richborough consider that this would be reasonable approach for the SWLP.

Other

ID sylw: 103415

Derbyniwyd: 07/03/2025

Ymatebydd: Richborough - Kineton Road, Wellesbourne

Asiant : Turley

Richborough support the SWLP’s ambitions to measure and reduce the embodied carbon of development within the SWLP area. However further evidence is essential to demonstrate that such requirements are viable.

It is noted that the Government intend to set future national targets for embodied carbon emissions through amendments to Building Regulations. This would circumvent the need for policy requirements.

The policies within WDC's existing Net Zero DPD and supporting SPD require the consideration and reduction of upfront embodied carbon, without setting a specific target at this stage. Richborough consider that this would be reasonable approach for the SWLP.

Other

ID sylw: 103417

Derbyniwyd: 07/03/2025

Ymatebydd: Richborough - Wellesbourne Road, Wellesbourne

Asiant : Turley

Richborough support the SWLP’s ambitions to measure and reduce the embodied carbon of development within the SWLP area. However further evidence is essential to demonstrate that such requirements are viable.

It is noted that the Government intend to set future national targets for embodied carbon emissions through amendments to Building Regulations. This would circumvent the need for policy requirements.

The policies within WDC's existing Net Zero DPD and supporting SPD require the consideration and reduction of upfront embodied carbon, without setting a specific target at this stage. Richborough consider that this would be reasonable approach for the SWLP.

Other

ID sylw: 103419

Derbyniwyd: 07/03/2025

Ymatebydd: Richborough - Plough Lane, Bishop's Itchington

Asiant : Turley

Richborough support the SWLP’s ambitions to measure and reduce the embodied carbon of development within the SWLP area. However further evidence is essential to demonstrate that such requirements are viable.

It is noted that the Government intend to set future national targets for embodied carbon emissions through amendments to Building Regulations. This would circumvent the need for policy requirements.

The policies within WDC's existing Net Zero DPD and supporting SPD require the consideration and reduction of upfront embodied carbon, without setting a specific target at this stage. Richborough consider that this would be reasonable approach for the SWLP.

Other

ID sylw: 103817

Derbyniwyd: 07/03/2025

Ymatebydd: Claire Jones

Too complicated to inderstand

Yes

ID sylw: 104081

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Stephen Norrie

The Councils are to be commended for the bold approach set out here, going beyond national standards, as well as the research that has gone into the position so far. I think this is a great policy. Well done!

Yes

ID sylw: 104409

Derbyniwyd: 07/03/2025

Ymatebydd: South Warwickshire Foundation trust

Yes, supportive of the efforts to reduce embodied carbon in the new developments. The policy’s emphasis on re-use, recycling, and flexible building design is aligned with NHS sustainability goals, as it helps reduce environmental impact over the long term.

Yes

ID sylw: 104696

Derbyniwyd: 07/03/2025

Ymatebydd: Miss Ann Colley

agree

Yes

ID sylw: 104736

Derbyniwyd: 07/03/2025

Ymatebydd: John Stott

Also an excellent policy.Demolition is nearly always the higher carbon route.

Other

ID sylw: 105115

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

St Philips support the SWA's goal of delivering high-quality, sustainable developments but believe policies need to be flexible and well-evidenced as per the NPPF. St Philips acknowledge the necessity to reduce embodied carbon; however, UK regulations primarily focus on operational energy use, lacking a national standard for embodied carbon assessments. St Philips am concerned that the SWAs are proposing policies that deviate from national requirements without adequate justification. Past proposals have been rejected for being inconsistent with national policy, highlighting the need for a robust evidence base to support any higher requirements.

Other

ID sylw: 106472

Derbyniwyd: 28/02/2025

Ymatebydd: McCarthy Stone and Churchill Living

Asiant : The Planning Bureau Ltd

We would like to remind the Council of the increased emphasis on Local Plan viability testing in Paragraph 58 of the NPPF and that the PPG states that “The role for viability assessment is primarily at the plan making stage. 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). The introduction of an embodied carbon policy must not be so inflexible that it deems sites unviable and any future policy needs to ensure this to make sure it is consistent with NPPF/PPG and can justified by the
Council. The viability of specialist older persons’ housing is more finely balanced than ‘general needs’ housing and we are strongly of the view that these housing typologies should be robustly assessed in the forthcoming Local Plan Viability Assessment. Additionally, new development will often be far more sustainable in many circumstances
including building fabric by use of modern methods of construction but also extending beyond that, such as sustainability through optimisation of use of a site and operational use of carbon. Existing foundations of buildings that have reached the end of their life cycle will seldom be practicable for new buildings and particularly so in the case of much needed specialised housing for older people.

Other

ID sylw: 106652

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

Whilst we are supportive of the Councils taking steps to reduce carbon emissions in new development, we question the focus placed solely on embodied carbon solely associated with buildings/ building materials. If embodied carbon is to be assessed, we believe that the overall impact of proposed a development should be considered at the planning stage e.g. the embodied carbon in any offsite supporting infrastructure that might be specifically required to make the development acceptable in planning terms such as new highways infrastructure. In such cases the embodied carbon impact would clearly be much greater than would be the case for a development which is well located to take advantage of existing infrastructure capacity and requires little of no supporting new infrastructure.

Other

ID sylw: 106898

Derbyniwyd: 06/03/2025

Ymatebydd: Historic England

Historic England welcomes a policy direction on embodied carbon and recommends the use of ‘Whole Life-Cycle Carbon Emissions Assessments’ as a means of reducing
embodied emissions. Reference should also be made to the importance of regular building maintenance, as the benefits of caring for and re-using historic buildings can lead to energy savings and a reduction in carbon emissions.

With regard to the re-use of existing buildings we consider that the plan should recognise sustainability over the long-term. Historic buildings represent a significant investment of expended energy and demolishing and replacing them requires a major reinvestment of embodied energy and other resources.

The local plan should therefore encourage and recognise the benefits of sympathetic restoration, retention, refurbishment and retrofitting of historic buildings.

Other

ID sylw: 106969

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

Bellway supports the need to measure and reduce the embodied carbon of development. However, the requirements of this policy will require further consideration to ensure that they are feasible and viable.
The proposed targets provided from LETI and RIBA provide a mixture of targets which relate to both the upfront embodied carbon of development (stages A1-A5), as well as the whole life carbon of development (Stages A1-D4), they do not provide a consistent set of targets or consideration.
At this stage the Plan’s evidence base provides no details on the consideration of embodied carbon, or potential costs of achieving the targets set out.
We would recommend that the approach set out in the Warwick Net Zero DPD5 and supporting SPD6 is followed, this requires the consideration and reduction of upfront embodied carbon, without setting a specific target at this stage. The application of specific targets needs to be fully considered as part of the Plan evidence base and viability assessment.

Other

ID sylw: 107272

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

In principle, the Cotswolds National Landscape (CNL) Board agrees with the approach laid out in Draft Policy Direction 24.
This approach aligns with the approach that is advocated in Policy CC1 (Climate Change - Mitigation) of the CNL Management Plan47 and in the Board’s Climate Change Strategy48.
However, in the context of the CNL (and the World Heritage Site) consideration will need to be given to how this can be achieved whilst also ensuring that new development reflects the local distinctiveness of the built environment (for example, the use of locally sourced Cotswold limestone and the use of vernacular architecture).

Other

ID sylw: 107745

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

Bellway supports the need to measure and reduce the embodied carbon of development. However, the requirements of this policy will require further consideration to ensure that they are feasible and viable.
The proposed targets provided from LETI and RIBA provide a mixture of targets which relate to both the upfront embodied carbon of development (stages A1-A5), as well as the whole life carbon of development (Stages A1-D4), they do not provide a consistent set of targets or consideration. We would also note that these targets are limited to a small number of potential building types and do not necessarily provide sufficient breadth of uses to be able to apply to all development. We would recommend that embodied carbon considerations focus on upfront embodied carbon as further downstream emissions cannot be controlled by the developer.
At this stage the Plan’s evidence base provides no details on the consideration of embodied carbon, or potential costs of achieving the targets set out.
We would recommend that the approach set out in the Warwick Net Zero DPD5 and supporting SPD6 is followed, this requires the consideration and reduction of upfront embodied carbon, without setting a specific target at this stage. The application of specific targets needs to be fully considered as part of the Plan evidence base and viability assessment.

Other

ID sylw: 107837

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

It is proposed to address embodied carbon in the Building Regulations within a new Part Z. The Government’s Building to Net Zero: Costing Carbon in Construction (May 2022) report recommends embodied carbon and whole-life carbon assessments for buildings are established in the Building Regulations. Local Authorities are only encouraged to include such a requirement within Local Plans – the fact that this is not advised to be mandatory confirms that allowing Building Regulations alone to cover this is sufficient. In any event, viability will be an important consideration. We support the acknowledgment that applicants can submit a justification where achieving embodies carbon targets is unviable.

Other

ID sylw: 107873

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Taylor Wimpey supports the need to measure and reduce the embodied carbon of development. However, the requirements of this policy will require further consideration to ensure that they are feasible and viable.
The proposed targets provided from LETI and RIBA provide a mixture of targets which relate to both the upfront embodied carbon of development (stages A1-A5), as well as the whole life carbon of development (Stages A1-D4), they do not provide a consistent set of targets or consideration. We would also note that these targets are limited to a small number of potential building types and do not necessarily provide sufficient breadth of uses to be able to apply to all development. We would recommend that embodied carbon considerations focus on upfront embodied carbon as further downstream emissions cannot be controlled by the developer.
At this stage the Plan’s evidence base provides no details on the consideration of embodied carbon, or potential costs of achieving the targets set out.
We would recommend that the approach set out in the Warwick Net Zero DPD {Net Zero Carbon DPD-Adopted May 2024 - Download - Warwick District Council.} and supporting SPD {Net Zero Carbon SPD-May 2024 - Download - Warwick District Council.} is followed, this requires the consideration and reduction of upfront embodied carbon, without setting a specific target at this stage. The application of specific targets needs to be fully considered as part of the Plan evidence base and viability assessment.

Other

ID sylw: 107909

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

Terra recognises the importance of reducing embodied carbon within the development
process. However, embodied carbon emissions are unregulated in the UK. Current policy and regulation focus solely on operational energy use, as distinct from embodied carbon.
There currently does not exist a nationally approved regulator or nationally recognised
standard, national planning policy or building regulation requirement to assess and report
embodied carbon emissions or whole life cycle carbon assessments – indeed the Future
Homes Standards - MHCLG Consultation on changes to Parts L and F of the Building
Regulations do not propose an embodied carbon target.
2.105 Whilst the SWAs are within its right to deviate from the Future Homes Standard and
Building Regulations, the NPPF is clear that the “preparation and review of all policies
should be underpinned by relevant and up-to-date evidence.” (Para 32).
2.106 In this context, whilst supportive in principle, Terra is concerned that the SWAs are seeking
to make provision for a policy that deviates from the national requirements without
providing sufficient justification.
2.107 Terra would also note that other Councils have proposed a similar requirement for
developments, which have not been accepted by Inspectors. In particular, in 2022 West
Oxfordshire District Council [WODC] submitted its Area Action Plan [AAP] for a Salt Cross
Garden Village – a case study recognised in the SWA’s ‘Climate Change Baseline Report
(2022) at paragraph 4.5.4. The AAP included Draft Policy 2 (Net Zero Carbon
Development), which required all new development to be net zero on-site through the use
of ultra-low energy fabric specification, low carbon technologies, on-site renewable energy
generation and embodied carbon reductions – Notably, Policy 2 required developments to
meet a < 500 kg CO2/m2 requirement.
2.108 However, the Inspector felt that the policy was inconsistent with national policy, as the
standards within it amounted to a significant uplift on Building Regulations – which
conflicted with then Secretary of State for Communities and Government – Eric Pickles MP
– Written Ministerial Statement [WMS] in March 2015, which stated that policies should
“not be used to set conditions on planning permissions with requirements above the
equivalent of the energy requirement of Level 4 of the Code for Sustainable Homes”. In
addition, the Inspector noted that the 2015 WMS “remains current national policy on this
matter” (IR124) – indeed, this position remains in the PPG (PPG ID: 6-012-20190315).
2.109 The Inspector also highlighted that whilst Section 1 of the Planning and Energy Act 2008
does allow for some policies to exceed energy requirements of building regulations if they
are deemed reasonable and consistent with national policies, in that instance, the
requirements were not reasonable (IR30). Furthermore, the Inspector highlighted that:
• There was a lack of evidence base to demonstrate the appropriateness of building
typologies and how key performance indicators were selected over alternatives;
• The standards within the plan were too rigid, and could not be realistically met by the
end user; and
• The standards of the policy were not flexible when having regard to the ever-changing
net zero building policy nor to “technological and market advancements and more
stringent nationally set standards, including within the Building Regulations” (IR137).
2.110 Consequently, the Inspector suggested a series of modifications to the policy – including
the deletion of the embodied carbon KPI – and suggested below amendment to the policy
wording:
“An energy statement will be required for all major development, which should
demonstrate the following:
…Embodied carbon – reducing the impact of construction by minimising the amount of
upfront embodied carbon emissions including appropriate embodied carbon targets. A
calculation of the expected upfront embodied carbon of buildings and full lifecycle
modelling”
2.111 Furthermore, regard should still be given to the then Minister of State for Housing’s – Lee
Rowley MP – Written Ministerial Statement [WMS] in December 2023. Whilst this was
challenged in the High Court by Rights Community Action, the case was dismissed,
meaning the WMS remains current government policy and a material consideration.
2.112 In light of the above, Terra would highlight that the Government’s intention is to achieve
zero carbon by 2025 through a step-by-step introduction of higher building regulations.
Whilst – in principle – the SWAs are within their rights to deviate from the Future Homes
Standard and Building Regulations where evidence justifies a higher requirement – NPPF
paragraph 32, PPG and the 2023 WMS – Terra note that sufficient evidence to support this
approach is required.