Other

ID sylw: 106474

Derbyniwyd: 28/02/2025

Ymatebydd: McCarthy Stone and Churchill Living

Asiant : The Planning Bureau Ltd

Water efficiency requirements should remain in line with Government targets and the Building Regulations. Were the Council to seek higher standards than the Building
Regulations from new development from the point of the Local Plan’s adoption this would need to be evidenced. We would also remind the Council to include the uplift in build costs for delivering adaptation to flood and drought events that goes beyond the Building Regulations 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

Yes

ID sylw: 106653

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

We recognise that water resources are under significant pressure and that this is likely to be accentuated as a result of climate change over Local Plan period. The implications of having to meet the BREEAM "excellent" standard for water consumption should though factored into the Viability Assessment produced with the Pre-Submission SWLP.

Other

ID sylw: 106971

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land-Land off Mallory Road, Bishop's Tachbrook

Asiant : Savills

Bellway supports the reduction of water demand through water efficiency measures. The requirements for enhanced water efficiency requirements beyond the requirements of the Building Regulations need to be appropriately evidenced.
Achieving a water use target of 100l/p/d for homes is considered achievable, as is the provider of rain harvesting water butts. However, the provision of greywater recycling systems needs to adequately consider the technical feasibility and viability of this type of system.
Achieving 4 BREEAM credits for non-residential development is also likely to pose technical and viability issues.
Achieving 4 credits requires water demand to be reduce by 50% and would require the use of rainwater harvesting and greywater use.
While broadly supportive, it is recommended the Council give further consideration to the technical feasibility and costs of this Policy as part of the next stage of Plan preparation to ensure any proposals are feasible and viable.

No

ID sylw: 107527

Derbyniwyd: 07/03/2025

Ymatebydd: Davidsons Homes

Asiant : Cerda Planning Ltd

Achieving a water efficiency standard of 100 litres per person per day is extremely difficult. Building Regulations state that the average water consumption for a dwelling should not exceed 125 litres per person per day. Some Authorities reduce this further to 110 litres however 100 litres just isn’t achievable in a practical sense.

Other

ID sylw: 107791

Derbyniwyd: 07/03/2025

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

Asiant : Savills

Bellway supports the reduction of water demand through water efficiency measures. The requirements for enhanced water efficiency requirements beyond the requirements of the Building Regulations need to be appropriately evidenced.
Achieving a water use target of 100l/p/d for homes is considered achievable, as is the provider of rain harvesting water butts. However, the provision of greywater recycling systems needs to adequately consider the technical feasibility and viability of this type of system. This is only likely to be suitable for larger, commercial development and will not be suitable for residential development due to constraints over space required for storage, treatment requirements and cost.
Achieving 4 BREEAM credits for non-residential development is also likely to pose technical and viability issues.
Achieving 4 credits requires water demand to be reduce by 50% and would require the use of rainwater harvesting and greywater use.
While very large development may have the scale to overcome the technical issues noted above, smaller development will likely have similar issues around the need for greywater use, i.e. space, treatment and cost.
While broadly supportive, it is recommended the Council give further consideration to the technical feasibility and costs of this Policy as part of the next stage of Plan preparation to ensure any proposals are feasible and viable.

No

ID sylw: 107839

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

The proposed water efficiency standard of 100 litres per person per day notably exceeds that in the Building Regulations (125 litres per day, with the option for authorities to reduce it to 110 litres per day). It is acknowledged that the evidence base, namely the Coventry and Warwickshire Sub-Regional Water Cycle Study (August 2024), recommends a planning policy to require a water efficiency target of 100 litres per day to be achieved using a fittings- based approach, due to evidence of pressures on the environment, and on public water supply. Thus, such a policy, though unnecessary given that this is addressed in the Building Regulations, could be justified.

Yes

ID sylw: 107875

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Taylor Wimpey supports the reduction of water demand through water efficiency measures. The requirements for enhanced water efficiency requirements beyond the requirements of Building Regulations need to be appropriately evidenced.
Achieving a water use target of 100l/p/d for homes is considered achievable, as is the requirement to provide rain harvesting water butts. However, the provision of greywater recycling systems needs to adequately consider the technical feasibility and viability of this type of system. This is only likely to be suitable for larger, commercial development and will not be suitable for residential development due to constraints over space required for storage, treatment requirements and cost.
While very large development may have the scale to overcome the technical issues noted above, smaller development will likely have similar issues around the need for greywater use, i.e. space, treatment and cost.
While broadly supportive, it is recommended the Council give further consideration to the technical feasibility and costs of this Policy as part of the next stage of Plan preparation to ensure any proposals are feasible and viable.

Other

ID sylw: 107955

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

The proposed water efficiency standard of 100 litres per person per day notably exceeds that in the Building Regulations (125 litres per day, with the option for authorities to reduce it to 110 litres per day). It is acknowledged that the evidence base, namely the Coventry and Warwickshire Sub-Regional Water Cycle Study (August 2024), recommends a planning policy to require a water efficiency target of 100 litres per day to be achieved using a fittings- based approach, due to evidence of pressures on the environment, and on public water supply. Thus, such a policy, though unnecessary given that this is addressed in the Building Regulations, could be justified.

Other

ID sylw: 108076

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

The proposed water efficiency standard of 100 litres per person per day notably exceeds that in the Building Regulations (125 litres per day, with the option for authorities to reduce it to 110 litres per day). It is acknowledged that the evidence base, namely the Coventry and Warwickshire Sub-Regional Water Cycle Study (August 2024), recommends a planning policy to require a water efficiency target of 100 litres per day to be achieved using a fittings- based approach, due to evidence of pressures on the environment, and on public water supply. Thus, such a policy, though unnecessary given that this is addressed in the Building Regulations, could be justified.

Yes

ID sylw: 108182

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We broadly support the provisions of policy H.

Yes

ID sylw: 108220

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

The proposed water efficiency standard of 100 litres per person per day notably exceeds that in the Building Regulations (125 litres per day, with the option for authorities to reduce it to 110 litres per day). It is acknowledged that the evidence base, namely the Coventry and Warwickshire Sub-Regional Water Cycle Study (August 2024), recommends a planning policy to require a water efficiency target of 100 litres per day to be achieved using a fittings- based approach, due to evidence of pressures on the environment, and on public water supply. Thus, such a policy, though unnecessary given that this is addressed in the Building Regulations, could be justified.

Other

ID sylw: 108579

Derbyniwyd: 07/03/2025

Ymatebydd: Corbally Group (Harbury) Ltd

Asiant : Pegasus Group

The proposed water efficiency standard of 100 litres per person per day notably exceeds that in the Building Regulations (125 litres per day, with the option for authorities to reduce it to 110 litres per day). It is acknowledged that the evidence base, namely the Coventry and Warwickshire Sub-Regional Water Cycle Study (August 2024), recommends a planning policy to require a water efficiency target of 100 litres per day to be achieved using a fittings- based approach, due to evidence of pressures on the environment, and on public water supply. Thus, such a policy, though unnecessary given that this is addressed in the Building Regulations, could be justified.

Other

ID sylw: 108626

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Draft Policy H – Water Efficiency
6.13.
The proposed water efficiency standard of 100 litres per person per day notably exceeds that in the Building Regulations (125 litres per day, with the option for authorities to reduce it to 110 litres per day). It is acknowledged that the evidence base, namely the Coventry and Warwickshire Sub-Regional Water Cycle Study (August 2024), recommends a planning policy to require a water efficiency target of 100 litres per day to be achieved using a fittings-based approach, due to evidence of pressures on the environment, and on public water supply. If considered necessary, the policy should additionally be subject to viability testing as part of the Local Plan review.

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.

No

ID sylw: 108812

Derbyniwyd: 07/03/2025

Ymatebydd: Barratt David Wilson Homes (Mercia)

Asiant : Savills

Barratt David Wilson Homes Mercia considers that the SWLP should not be including a Policy which requires achievement of a water efficiency standard of 100 litres per person per day without the appropriate justification. This justification is required by the NPPF {National Planning Policy Framework (December 2024) Paragraph 36}.and currently does not exist.
As acknowledged within the supporting text for Draft Policy H, a water efficiency standard of 125 litres per person per day is set in Building Regulations and that there is an option for LPAs to require a tighter standard of 110 litres per person per day where there is a clear local need. Reference is made to the Water Cycle Study {Coventry and Warwickshire Sub-regional Water Cycle Study – Stage 1. Final report. August 2024}. recommending consideration of an even tighter standard of 100 litres per person per day. However, what the evidence base currently does not do is consider the implications of this proposal, which relates to the fittings installed in new dwellings, on the viability of new development. This assessment therefore still needs to take place.

Other

ID sylw: 108830

Derbyniwyd: 07/03/2025

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

Asiant : Savills

Bellway supports the reduction of water demand through water efficiency measures. The requirements for enhanced water efficiency requirements beyond the requirements of the Building Regulations need to be appropriately evidenced.
Achieving a water use target of 100l/p/d for homes is considered achievable, as is the provider of rain harvesting water butts. However, the provision of greywater recycling systems needs to adequately consider the technical feasibility and viability of this type of system. This is only likely to be suitable for larger, commercial development and will not be suitable for residential development due to constraints over space required for storage, treatment requirements and cost.
Achieving 4 BREEAM credits for non-residential development is also likely to pose technical and viability issues.
Achieving 4 credits requires water demand to be reduce by 50% and would require the use of rainwater harvesting and greywater use.
While very large development may have the scale to overcome the technical issues noted above, smaller development will likely have similar issues around the need for greywater use, i.e. space, treatment and cost.
While broadly supportive, it is recommended the Council give further consideration to the technical feasibility and costs of this Policy as part of the next stage of Plan preparation to ensure any proposals are feasible and viable.