Publication (Regulation 19)

Ends on 8th September 2026 (48 days remaining)

6 Achieving a Net Zero and Climate Resilient South Warwickshire Comment

6.1 Achieving Climate Resilient and Net Zero

Policies within this section contribute to achieving the following Strategic Objectives:

SO1. Providing infrastructure in the right place at the right time

SO5. Contributing towards Net Zero Carbon targets

6.1.1 The Local Plan has a legal duty and decisive role in tackling climate change across South Warwickshire though helping to shape places that support the transition to net zero carbon, reduce greenhouse gas emissions, and adapt to the impacts of climate change, thereby improving resilience.

Policy NZ.1 (Non-Strategic Policy) Comment

Operational Net Zero in New Residential Buildings 

Where viable new-build residential development of 1 or more homes shall make the fullest possible contribution towards mitigating climate change (reducing carbon emissions) by meeting all of the following steps.

  1. The new-build residential development shall be designed to achieve net zero, or where possible net negative, operational energy use, through meeting all of the following energy performance requirements:
    1. ≤ 20 kWh/m2/year space heat demand.
    2. ≤ 35 kWh/m2/year total energy use intensity (EUI). On developments of multiple buildings, it will be acceptable for this to be met as a site-wide average, provided that no individual home exceeds 60kWh/m2/year.)
    3. Onsite renewable electricity generation capacity kWp equal to (ground floor area x 60% / 4.5).
      1. Or, if the kWp target is unfeasible, then provide renewable electricity generation kWh equal to the home’s annual total energy use.
      2. It is acceptable for the renewable target to be met on a site-wide basis, including in mixed-use (see policy NZ.2 for non-residential).
    4. The development shall not be connected to the gas grid. Buildings shall not use fossil fuel other than safety-critical backup power systems.
  2. To minimise the energy performance gap between design and use:
    1. Compliance with the above targets at application stage shall be demonstrated using an accurate energy prediction method.
    2. On completion: Major schemes should update the calculations to reflect the building’s actual construction. Minor schemes should reconfirm the specifications to which they have been built.
    3. Major applications (as defined in the NPPF) should implement an assured performance method throughout design and construction.
  3. If the renewable electricity provision falls short of a net zero energy balance (1.a.iii.1), the developer will offset the shortfall via a contribution to enable delivery of the equivalent renewable generation capacity elsewhere locally. This shall be priced and ring-fenced for that purpose. Offsetting is only an acceptable route where an onsite net zero energy balance is unfeasible.
  4. The developer is encouraged to demonstrate exploration of energy storage or energy sharing systems, to allow more of the onsite generation to be used on site. Where such features are incorporated, this will be recognised as a benefit with material weight.
Policy Justification

6.1.2 All of this policy’s energy performance targets (EUI, space heat demand and renewable energy) have been demonstrated feasible in the South Warwickshire context via the accurate energy modelling evidence report of typical building types in this local plan area. That report identifies the construction specifications that would meet these performance targets in each building type, and the quantified cost uplift for those specifications compared to today’s basic building standards. That report will be made available within the local plan evidence library. The identified cost uplifts for this policy are being fed into the plan viability assessment, which will also be made available in the local plan evidence library.

  1. Regarding the renewable electricity provision target:
  • Where it is proposed to meet the target on a site-wide basis in mixed-use, the total target should be calculated by applying the residential and non-residential (see policy NZ.2) targets in proportion to their respective area.
  • There is a preference for building-mounted PV, or PV mounted over other uses such as car parking, so as to make efficient use of land as per NPPF 2024 paragraphs 129-130c. The other reason PV is preferred (and assumed in the evidence modelling) is that PV today has the best balance of low visual impact, low maintenance, and generating a useful amount of electricity while being widely suitable for integration with other uses such as residential. However, any other renewable energy generation technology can contribute towards this target where suitable for the setting and effective.
  • It will not be acceptable for the renewable energy target to be met primarily through standalone generation that has no connection to the proposed buildings or other on-site energy uses. Standalone equipment whose purpose will be primarily a commercial power station that sells REGO[11]-certified electricity to the grid will not count towards this renewable energy goal (for example a commercial solar or wind farm that happens to be alongside a new residential development). However, it is acceptable, and encouraged, for the on-site renewable energy at a residential development to supply any unused energy to the grid on a standard feed-in tariff at times when onsite generation exceeds onsite demand, provided that REGO certificates are not also sold.
  • The Council notes that the kWp target in point 1.a.iii.1 will in some cases result in annual renewable energy generation that would be more than the building’s own annual energy demand. This makes the building ‘net negative energy’ in that it will export more to the grid than it annually takes from the grid. This is for the sake of maximising climate mitigation It is considered reasonable as it has been proven feasible in the energy and cost modelling evidence, and will go some way towards either helping to decarbonise the electricity grid, or towards paying back some of the development’s embodied carbon, which will not be zero (for an explanation of embodied carbon and associated targets, see Policy NZ.4). However, this excess renewable energy is still only a very small contribution towards mitigating the total impact of the development. For example, the excess amount of renewable energy sent to the grid across a period of 30 years from 2026 would only represent a grid carbon saving of between 4-12% of a house’s up-front embodied carbon[12].
  • Applicants should follow MCS guidance in calculating[13] their predicted renewable energy generation.

6.1.4 Regarding the energy performance gap:

  • This is a common phenomenon where new buildings typically perform significantly worse than predicted (using more energy) expectation for major schemes to follow an assured performance method. Up to the point of completion of a building, the main causes are poor prediction methods, errors or changes in construction compared to designs, and poor equipment installation.
    • Acceptably accurate energy performance prediction methods currently include Passivhaus Planning Package (PHPP). For non-residential uses, CIBSE TM54 is[14] another suitable method. Other suitably accurate methods may arise in the plan period. If the developer proposes any alternative method, the Council(s) may consider these on a case-by-case basis depending on track record evidence of the accuracy of that method at predicting actual energy performance. Building regulations compliance methods SAP[15] and SBEM[16] are not acceptably accurate for this purpose. The Council(s) are aware that SAP is being replaced by a new national method, HEM[17], when government updates the building regulations to the Future Homes Standard sometime between 2025 and 2027. It is not yet known whether HEM will be sufficiently accurate for compliance with the local plan policy, but evidence on this may be considered as it emerges.
    • An ‘assured performance’ method is a series of steps from design through to building handover, aimed to avoid these pitfalls that otherwise tend to cause the energy performance gap. Several such methods have been formalised in the industry, including the Assured Performance Process by National Energy Foundation & Good Homes Alliance; Passivhaus certification process, and BSRIA Soft Landings. Other acceptable methods may be available or may arise in the plan period.
    • The offsetting price shall start at £2.03/kWh, and may be updated in future to keep pace with cost changes. This reflects the current estimated cost of solar PV installation, plus a margin to allow administration of the offset fund by the Council(s). It is expected to be paid into the relevant Council’s offset fund, but the Council(s) will consider alternative schemes where the developer may propose a direct contribution to a suitable renewable energy installation in the area, subject to that scheme meeting the same criteria of additionality that the Council would use to select projects that its own offset fund would support. These criteria will include that the project will not sell REGO certificates and is located in the local plan area (or less preferably the wider region).

Policy NZ.2 (Non-Strategic Policy) Comment

Operational Net Zero in New Non-residential Buildings

Where viable new-build non-residential development of 100m2 or more shall make the fullest possible contribution towards mitigating climate change (reducing carbon emissions) by meeting all of the following steps.

  1. The new-building shall be designed to achieve net zero operational energy use, by meeting all of the following energy performance targets:
    1. ≤ 15 kWh/m2/year space heat demand in schools and light industrial.
    2. Total energy use intensity (EUI) targets as follows:
      1. ≤52 kWh/m2/year in primary schools
      2. ≤35 kWh/m2/year in unrefrigerated light industrial. If unfeasible due to the specific proposed use, then follow ‘Other’ (1.a.ii.3, below).
      3. Other: Disclose total EUI in kWh/m2/year, of which the regulated-only energy uses should be ≤30 kWh/m2/year. Show what efforts have been made towards the relevant targets in the UK Net Zero Carbon Buildings Standard.
      4. It will be acceptable for EUI targets to be met as a site-wide average.
    3. Onsite renewable electricity annual generation kWh equal to the building’s annual total energy use.
      1. It is acceptable for the renewable target to be met on a site-wide basis, including in mixed-use (see policy NZ.1 for residential).
    4. Buildings shall not use fossil fuel unless in safety-critical backup power.
  2. To minimise the energy performance gap between design and use:
    1. Compliance with the above targets at application stage shall be demonstrated using an accurate energy prediction method.
    2. On completion: Major schemes should update the calculations to reflect the building’s actual construction. Minor schemes should reconfirm the specifications to which they have been built.
    3. Major applications (≥1000m2 floorspace) should implement an assured performance method throughout design and construction.
  3. If the renewable electricity provision falls short of a net zero energy balance (1.a.iii.1), the developer will offset the shortfall via a contribution to enable delivery of the equivalent renewable generation capacity elsewhere locally. This shall be priced and ring-fenced for that purpose. Offsetting is only an acceptable route where an onsite net zero energy balance is unfeasible.
  4. The developer is encouraged to explore energy storage or sharing systems, to allow more of the onsite generation to be used on site. Where these are incorporated, this will be recognised as a benefit with material weight.
Policy Justification

6.1.5 This policy’s energy performance targets for total EUI, space heat demand and renewable energy have been demonstrated feasible in the South Warwickshire context via the accurate energy modelling evidence report of typical building types of these specific uses in this local plan area. The primary school EUI target of 52kWh/m2/year aligns with the Department for Education requirements for new schools in England. The fallback target for regulated energy use is selected on the basis of published recent third-party energy modelling evidence which covered additional building types beyond those covered in the SWLP modelling.

6.1.6 The energy modelling evidence report (cited above) identifies the construction specifications that would meet these performance targets in each building type, and the quantified cost uplift for those specifications compared to today’s basic building standards. It will be made available in the local plan evidence library. The identified cost uplifts for this policy are being fed into the plan viability assessment, which will also be part of the local plan evidence library.

6.1.7 Regarding the renewable electricity provision target:

  • Where it is proposed to meet the target on a site-wide basis in mixed-use, the total target should be calculated by applying the residential and non-residential targets in proportion to their respective area (see policy NZ.1 for the applicable residential target).
  • There is a preference for building-mounted PV, or PV mounted over other uses such as car parking, so as to make efficient use of land as per NPPF 2024 paragraphs 129-130c. The other reason PV is preferred (and assumed in the evidence modelling) is that PV today has the best balance of low visual impact, low maintenance, and generating a useful amount of electricity while being widely suitable for integration with urban areas. However, any other renewable energy generation technology can contribute towards this target where suitable for the setting and effective.
  • It will not be acceptable for the renewable energy target to be met primarily through standalone generation that has no connection to the proposed buildings or other on-site energy uses. Standalone equipment whose purpose will be primarily a commercial power station that sells REGO[18]-certified electricity to the grid will not count towards this renewable energy goal (for example a commercial solar or wind farm development that happens to be alongside an otherwise unrelated development of new buildings). However, it is acceptable, and encouraged, for the on-site renewable energy at a new building to supply any unused energy to the grid on a standard feed-in tariff at times when onsite generation exceeds onsite demand, provided that REGO certificates are not also sold.
  • Applicants should follow MCS guidance in calculating[19] their predicted renewable energy generation.

6.1.8 Regarding the energy performance gap:

  • See equivalent supporting text on Policy NZ.1 for explanation of this phenomenon.
  • Acceptably accurate energy performance prediction methods for non-residential uses currently include Passivhaus Planning Package (PHPP) and CIBSE TM54. Applicants should be aware that CIBSE TM54 is a nationally endorsed energy use prediction method in that it is named in Building Regulations Part L 2021 as an acceptable means to fulfil Part L’s mandatory ‘energy forecasting’ requirement. Other suitably accurate methods may arise in the plan period. If the developer proposes any alternative method, the Council(s) may consider these on a case-by-case basis depending on track record evidence of the accuracy of that method at predicting actual energy performance. Building regulations compliance methods (e.g. SBEM in non-residential) are not acceptably accurate for this purpose. It is not yet known whether future updates to SBEM will be sufficiently accurate for compliance with the local plan policy. Evidence on this may be considered as it emerges.
  • An ‘assured performance’ method is a series of steps from design through to building handover, aimed to avoid these pitfalls that otherwise tend to cause the energy performance gap. Several methods have been formalised in the industry, including the Passivhaus certification process, BSRIA Soft Landings, and NABERS UK Design For Performance (the latter available for offices only at the time of drafting this local plan, but may be expanded to other uses in the plan period). Other acceptable methods may be available or may arise in the plan period.

6.1.9 The offsetting price shall start at £2.03kWh, and may be updated in future to keep pace with cost changes. This reflects the current estimated cost of solar PV installation, plus a margin to allow administration of the offset fund by the Council(s). It is expected to be paid into the relevant Council’s offset fund, but the Council(s) will consider alternative schemes where the developer may propose a direct contribution to a suitable renewable energy installation in the area, subject to that scheme meeting the same criteria of additionality that the Council would use to select projects that its own offset fund would support. These criteria will include that the project will not sell REGO certificates, and is located in the local plan area (or less preferably the wider region).

Policy NZ.3 (Non-Strategic Policy) Comment

Embodied Carbon 

All development proposals should strive to reduce embodied carbon as far as possible. Towards this aim, the following expectations should be met:

  1. Where it is proposed to demolish a building of 100m2 or more, this should be justified e.g. in relation to feasibility, suitability for the proposed use, or unacceptably poor energy efficiency.
  2. Major new-build proposals (10+ homes or 1000m2 floor space) should identify the steps taken to reduce the building or overall development’s impact on embodied carbon e.g. regarding its design and building materials to minimise embodied carbon.
  3. Proposals for large scale new-build developments (a minimum of 100 dwellings or a minimum of 5000m2 of non-residential floor space) must submit a calculation, following the RICS Whole Life Carbon methodology, which should demonstrate that the following targets have been met:

‘Upfront’ embodied carbon emissions (RICS modules A1-A5)

  • Houses: 600kgCO2 e/m2 floor space (gross internal area).
  • Flats/apartments: 500kgCO2 e/ m2 floor space (gross internal area)
  • Non-Residential: 600kgCO2 e/ m2 floor space (gross internal area).
Policy Justification

6.1.10 Embodied carbon is the carbon emissions associated with the construction, maintenance and end-of-life of a building. Embodied carbon represents about 25-75% of the total carbon emissions that are caused across a building’s whole lifetime (with the remainder represented by the carbon emissions from energy use in the building).

6.1.11 Up-front embodied carbon is all the emissions that occur up to the point of completing the building, such as due to raw material extraction, manufacturing of construction products, transporting those products to site and the process of construction itself.

6.1.12 Materials like cement, steel and bricks are associated with high embodied carbon emissions (especially up-front embodied carbon) due to their energy-intensive manufacturing. By contrast, recycled materials and bio-based materials like timber and hemp have much lower embodied carbon. Developers of any size of project are encouraged to educate themselves on this topic and are able to give narrative on choices made to make such swaps in their chosen materials. Buildings’ structural design can also help to minimise the necessary total amount of material and therefore embodied carbon.

6.1.13 The RICS Whole Life Carbon Assessment methodology, which follows the relevant British/European Standard (BS15978), is the industry’s accepted method for accounting for embodied carbon. It defines a series of ‘modules’ from A to C. Modules A1 to A5 are the ‘upfront’ embodied carbon. An embodied carbon assessor follows this method while utilising one of several available online databases of embodied carbon emissions of various construction products and methods. These offer embodied carbon information for many specific products and for generic types of typical construction materials/techniques. At the time of drafting this plan, the RICS method is the only acceptable one. However, should alternative methods arise over the plan’s lifetime, these may be considered on their merits.

6.1.14 The Local Planning Authority recognises that an embodied carbon assessment itself can be a significant investment in time and professional fees. This is why the policy only requires that assessment in super-major developments (here defined as 100+ homes or 5,000m2 floor space), because the burden of the assessment itself is much smaller in proportion to the overall project size. Additionally, developments of 100+ homes tend to be made up of repetitions of a small number of home types by volume developers – so that not every individual home needs its own assessment, but a single assessment can cover all homes of the same type. Many leading volume housebuilders have already begun investigating the embodied carbon of their homes[20] as part of their wider corporate sustainability efforts such as science-based carbon targets or mandatory carbon reporting and therefore are well prepared to conduct such an assessment, compared to smaller developers. Large non-residential developers are similarly likely to be more familiar with embodied carbon for similar reasons, and because embodied carbon improvements can help earn a BREEAM rating, which is a very widely sought-after certification in the non-residential property market.

6.1.15 The policy only sets targets for up-front embodied carbon, not whole-life carbon. This is because the other parts of whole-life carbon are in the future and the calculation of these emissions is based on less reliable assumptions than the up-front portion. Again, these are only applied to super-major developments in light of their increased ability to take on the reporting burden.

6.1.16 The expectation on smaller developers is merely to educate themselves with regards to the embodied carbon impact of their and material choices, and provide narrative as to the choices they have made in light of this. This expectation still only applies to ‘major’ development and therefore will not put any burden on very small developers and householder applications.

6.1.17 The Local Planning Authority l is aware that new buildings will need additional insulation and equipment in order to meet the separate operational energy targets expressed in policies NZ.1 and NZ.2, and that this therefore could raise the upfront embodied carbon compared to a new build that just meets today’s building regulations. Therefore, the upfront embodied carbon targets expressed in this policy reflect the figures that would be achieved by new buildings that already meet the net zero energy performance standard, as demonstrated in recent published third-party embodied carbon modelling evidence which used the RICS method and covered several types of residential and non-residential building.

6.1.18 Existing buildings represent a significant ‘investment’ in historic embodied carbon. If demolished, that ‘investment’ is wasted and more embodied carbon will be emitted to replace that floorspace. Therefore, policy point 1 is designed to encourage the reuse of existing buildings as far as feasible, instead of defaulting to demolition and replacement.

Policy NZ.4 (Non-Strategic Policy) Comment

Energy Performance Improvements in Existing Buildings 

In light of the urgent need for improvement to existing buildings’ energy and carbon performance in order to meet local climate commitments and national legislated carbon goals, the following expectations are set where permission is needed for proposals for conversions, extensions and change of use of existing buildings.

  1. Proposals for works to existing buildings should demonstrate that opportunities to improve energy efficiency and operational carbon emissions have been considered in design decision-making. The level of detail expected will be proportional to the scale of the proposal.
  2. . The level of detail expected will be proportional to the scale of the proposal.
  3. Development proposals relating to existing buildings that would result in significant improvement to the carbon and/or energy performance of the building will be supported, with weight afforded in their favour in proportion to the carbon reduction benefit they bring. To demonstrate this:
    1. Major proposals relating to existing buildings (10+ dwellings or 1,000+m2 floor space) should use the applicable Building Regulations calculation method (SAP, HEM, or SBEM) to report on:
      1. Dwellings: % improvements on the Dwelling Emission Rate (DER), Dwelling Primary Energy Rate (DPER), and Dwelling Fabric Energy Efficiency (DFEE).
      2. Non-residential buildings: % improvements on Building Emission Rate (BER) and Building Primary Energy Rate (BPER).
    2. Improvements to Energy Use Intensity (EUI) and space heat demand, using an accurate energy use prediction methodology, will also be an optional relevant disclosure that is encouraged in applications.
    3. Where the proposal commits to achieving either EnerPHit certification, or the applicable retrofit targets expressed in the UK Net Zero Carbon Buildings Standard for the relevant year of completing the works, this will be recognised as an outstanding effort towards climate change mitigation, and material weight will be afforded in favour. If the planning decision hinges on this benefit, a condition will be applied accordingly.
    4. will be afforded in favour. If the planning decision hinges on this benefit, a condition will be applied accordingly.
    5. Major proposals relating to existing residential buildings are encouraged to follow the latest PAS2035 guidance. Where this is demonstrated, this will be recognised as a benefit of the scheme.
  4. Major proposals relating to existing buildings (threshold as above), where planning permission is required for changes that relate to the heating system, should demonstrate that the feasibility of low- or zero-carbon heating systems have been explored prior to any replacement of existing gas or other fossil fuel heating systems.
Policy Justification

6.1.19 Please note that SAP, SBEM and HEM refer to the Building Regulations Part L compliance calculation methodologies. Any energy assessor will be familiar with these terms, but for ease:

  • SAP stands for Standard Assessment Procedure. This is the calculation currently used for demonstrating compliance with Building Regulations Part L for dwellings.
  • SBEM stands for Simplified Buildings Energy Model. This is the calculation currently used for demonstrating compliance with Building Regulations Part L for buildings other than dwellings.
  • HEM stands for Home Energy Model. This is a new national calculation that national Government has announced will eventually replace SAP for demonstration of compliance with Building Regulations Part L Future Homes Standard, after an approximately two-year transition period when both SAP and HEM will be in use for Building Regulations compliance after the Future Homes Standard comes into force.
  • Regulations compliance after the Future Homes Standard comes into force.

6.1.20 As noted in the supporting climate evidence base, there is an urgent need for existing buildings to undergo a rapid uptake of energy efficiency improvements and rollout of low carbon heating to replace gas and other fossil fuel heating. However, the local plan cannot force existing building owners to make these changes and can only exert influence to encourage these changes where a change to an existing building requires permission.

6.1.21 Many energy retrofit works to existing buildings do not require planning permission. Where permission is needed, there is often a perception of high barriers and uncertainty about the relative weight that will be placed on the benefits of the proposed climate change mitigation compared to other impacts. This policy therefore seeks to expressly clarify for applicants and officers that such benefits should be quantified (using specific metrics) and given weight in the decision, in proportion to those benefits. The policy is designed to help reveal the significance of those benefits by requesting specific metrics against which performance improvement can or should be reported and referencing specific industry best practice benchmarks or processes that signify outstanding effort in this regard.

Policy NZ.5 (Non-Strategic Policy) Comment

Climate Resilient Design 

To protect occupants from the impacts of climate change, especially in a context of increasing energy efficiency in buildings, applications for new-build major development (10+ homes or 1000m2 floor space) should meet the following expectations.

  1. Demonstrate that overheating risk measures have been selected in accordance with the cooling hierarchy, where the earlier steps should be pursued before resorting to the later steps:
    1. Minimise internal heat generation through energy-efficient design and specification
    2. Minimise the amount of heat entering the building in summer, using:
      1. Building orientation
      2. Shading
      3. Albedo (reflective or light-coloured external materials)
      4. Fenestration and insulation.
    3. Manage heat within the building through exposed-internal thermal mass and high ceilings.
    4. Passive ventilation.
    5. Mechanical ventilation.
    6. Active cooling measures as a last resort.
  2. Detailed overheating assessment is encouraged, comprising the following methodologies by CIBSE[21]:
    1. CIBSE TM52 for non-residential development
    2. CIBSE TM59 for residential development.
    3. Within this, applicants are encouraged to use future weather files (CIBSE Design Summer Year’ [DSY] for 2050 or 2080) as opposed to a DSY based on previous decades’ weather. Where the building passes the applicable overheating assessment using these future weather files, this will be recognised as a significant benefit in climate adaptation.
Policy Justification

6.1.22 Climate change is anticipated to increase average annual temperatures, the occurrence and intensityof extreme weather events including heatwaves, wildfires, flooding, drought and storms. Ensuring that new development and changes to existing buildings respond to these changes is therefore a crucial element in responding to the climate emergency and will create more resilient communities, ecosystems and the economy for the future.

6.1.23 Climate resilient design is an approach to development that considers current and future climate conditions to optimise building performance and energy efficiency, as well as reducing the impact of development on the natural environment. The core principles of climate resilient design include adapting to higher temperatures through passive and natural cooling measures, reducing water consumption, managing flood risk and mitigating biodiversity loss.

6.1.24 This policy sets out the climate resilient design requirements for new development and changes to existing buildings.

6.1.25 While the Council is aware that there are national building regulations relating to overheating risk mitigation (Part O), that regulation allows two possible routes to compliance: A basic/simplified route, and an enhanced/dynamic route. The regulation allows most developments to follow the basic/simplified route, which may not be suitable to deal with future years’ increased overheating risk in the changing climate, and also does not reflect the potential effects of the enhanced energy efficiency targets set by this local plan’s separate policies NZ.1 and NZ.2. Additionally, Part O only covers residential developments and therefore fails to protect people from overheating risks in their place of work, study or leisure outside the home.

6.1.26 Because the space heat demand target set by policies NZ.1 and NZ.2 is tighter than the standard that would be achieved by current Building Regulations, these buildings will be more effective at holding on to heat that gets inside them, unless careful design choices are made to avoid excess unwanted heat and to manage and remove this where it occurs. Without careful application of the cooling hierarchy (which prioritises passive means first), developers might otherwise resort to seemingly simpler technological solutions such as air conditioning which can have heavy energy use and may undo some of the carbon savings that the local plan is aiming to achieve.

6.1.27 Therefore, the basic route to compliance with Building Regulations on overheating is not considered sufficient. Instead, applicants are asked to utilise the industry’s best practice overheating risk mitigation assessment method, CIBSE TM52 or TM59 (for non-residential and residential respectively).

6.1.28 Applicants should note that CIBSE TM59 aligns with the enhanced/dynamic route to compliance with national Building Regulations Part O.

6.1.29 The policy therefore does not contradict nor duplicate Part O, but specifies the Council’s preferred route to compliance within Part O, and extends this to non-residential buildings too so that South Warwickshire’s new build employment and learning spaces will be equally ready for the increased frequency and intensity of heatwaves that the UK is already experiencing and will continue to experience more often in coming decades.

Policy NZ.6 (Non-Strategic Policy) Comment

Carbon Sinks and Sequestration 

Development must protect, enhance, and support the long-term storage and sequestration of carbon in natural and semi-natural habitats.

  1. All development will be required to:
    1. apply the mitigation hierarchy to avoid harm to carbon sinks wherever possible; and
    2. protect and retain existing carbon-rich habitats and features, including soils, peatlands, woodlands, hedgerows, wetlands, grasslands, waterbodies, and other areas identified as significant carbon stores.
  2. All development is expected to:
    1. deliver measurable carbon storage or sequestration gain, prioritising on-site measures that enhance the carbon function of habitats and deliver wider environmental co-benefits, in accordance with the LNRS, and Policy DS.1 Environmental Mitigation and Compensation; and
    2. secure the long-term management of retained and enhanced carbon sinks, proportionate to the development and carbon outcomes proposed.
  3. Where measurable carbon storage or sequestration gain cannot reasonably be achieved on-site, this must be clearly justified through proportionate evidence. Off-site provision should support LNRS priorities and wider ecological and climate resilience objectives and may be delivered through recognised schemes including those set out in the Warwickshire, Coventry and Solihull Green Infrastructure Strategy (Annex A – Ecosystem Services Trading Protocol), as updated.
  4. Carbon sequestration measures must not substitute for the avoidance or mitigation of harm to carbon-rich or irreplaceable habitats, soils or peatlands.
Policy Justification

6.1.30 Natural carbon sinks play a critical role in mitigating climate change while supporting biodiversity, water regulation and other ecosystem services. Protecting and enhancing these assets contributes to climate resilience and delivers multiple environmental benefits. The 2024 technical evidence 'Assessment of Carbon Sequestration and Habitat baseline opportunities' provides baseline mapping to identify existing carbon sinks and areas with the potential for carbon sequestration opportunities. It recommends establishing a presumption against the loss of Climate Change Resilience Assets (defined as existing features within the environment that contribute to climate change mitigation and adaptation), and for Nature-based Solutions to be provided to mitigate any loss.

6.1.31 The NPPF at its core requires sustainable development and emphasises the need to mitigate and adapt to the effects of climate change. Para 136 of the NPPF recognises the role of natural assets such as trees in achieving this, and the importance of some undeveloped land for carbon storage is highlighted in para 125b. The above policy emphasises the importance of retaining carbon rich habitats to support these ambitions.

Policy NZ.7 (Non-Strategic Policy) Comment

Decentralised Energy Systems ~ Major Development 

This policy applies to all major development proposals including residential, commercial, industrial, institutional, leisure and mixed use.

Where viable development will be expected to support the transition to a low-carbon and resilient decentralised energy network in accordance with national policy, including the NPPF, and relevant national energy policy. Development must contribute to achieving net zero, improving energy security, and support low carbon energy infrastructure that enables the decarbonisation of heat and power.

A. Energy Hierarchy

Major development must demonstrate application of the following energy hierarchy where feasible and viable:

  • Reduced energy demand.
  • Maximising energy efficiency.
  • Incorporating decentralised, renewable or low carbon energy systems.
  • Use any remaining fossil fuels as efficiently as possible (only where unavoidable).

B. Feasibility and Viability Assessment

Major development must submit a Decentralised Energy Feasibility and Viability Assessment that:

  • Evaluates connection to existing and planned heat networks.
  • Assesses the potential for on site or shared renewable generation.
  • Considers shared ground loop heat pumps, ambient loop systems, microgrids and energy storage.
  • Identifies opportunities for demand side response and flexibility.
  • Assesses the whole life carbon and embodied carbon implications of different energy options.
  • Demonstrates that higher performing low carbon options have been selected.
  • Identifies any abnormal site constraints and explains how these have been addressed.
  • For non-residential development to assess opportunities to act as anchor loads for heat networks.

C. Thermal Masterplanning

Major development must undertake thermal masterplanning proportionate to the scale, nature and complexity of the proposal, including:

  • Mapping of heat demand and waste heat sources.
  • Identification of opportunities for heat network zones or clusters.
  • Safeguarding on-site routes and connection points necessary for future decentralised energy infrastructure.
  • Compatibility with low temperature heating systems.
  • Phasing and future connection potential.
  • Coordination with adjacent sites to maximise shared infrastructure opportunities.
  • For commercial/industrial schemes assessment of waste heat recovery potential.

D. Heat Network Zones

Where a site lies within or adjacent to a designated heat network zone, development must:

  • Assess the potential for connection to an existing heat network;
  • Be designed to enable future connection where connection is not currently feasible or viable;
  • Incorporate low temperature distribution systems compatible with future network supply;
  • Safeguard sufficient on-site space and connection routes to facilitate future heat network connection where required; and
  • Avoid installing systems that would preclude future connections.

E. Order of preference for Heating and Cooling Systems

To support decarbonisation and net zero objectives, major development must follow this order of preference:

  • Connection to an existing or planned heat network using low carbon heat sources
  • On site communal low carbon heat systems such as shared ground loop heat pumps or ambient loop systems
  • Individual low carbon systems such as air source and ground source heat pumps
  • Other systems only where options above are demonstrated to be unfeasible to unviable
  • Cooling systems must prioritise passive design, followed by low carbon mechanical systems. For non-residential development, cooling demand must be minimised through passive design and thermal zoning.

F. Future Proofing

Major development must incorporate infrastructure that enables future decentralised energy solutions including:

  • Low-temperature heating systems
  • Roof structures capable of supporting solar PV/thermal
  • Space for plant, pipework and future energy centre connections
  • Safeguarding of heat network corridors
  • Ducting for future electrical upgrades
  • Smart controls and metering to support flexibility of services
  • Design that avoids locking into high carbon systems
  • Provision for future battery storage or thermal storage
  • Structural capacity for future renewable installations
  • Passive design measures to reduce heating and cooling demand
  • For non-residential buildings, space for future waste-heat capture or reuse

G. Local Energy Resilience, Grid Capacity and Storage

Major development must demonstrate how it contributes to local energy resilience including:

  • Integration of electrical and/or thermal energy storage
  • Measures to reduce peak demand
  • Provision for on-site balancing and flexibility
  • Design measures that reduce risk of outages, including diversity of supply and redundancy in critical systems
  • Early engagement with the Distribution Network Operator (DNO) to identify grid constraints
  • Measures to avoid exacerbating local capacity constraints, including load shifting, smart controls and on-site generation.
  • Safeguarding space for future grid reinforcement where required
  • Consideration of microgrid or islanding capability where appropriate.
  • For major commercial/industrial schemes, assessment of high-load equipment and mitigation of grid impacts.

H. Delivery, Phasing and Long Terms Management

Major development proposals incorporating communal or decentralised energy infrastructure must submit a Decentralised Energy Delivery and Management Plan that confirms:

  • Delivery and phasing of decentralised energy infrastructure;
  • Connection agreements where relevant;
  • Long term maintenance and management arrangements;
  • Monitoring of energy performance and carbon outcomes;
  • Safeguarding of future connection points and corridors where relevant; and

Arrangements for shared ownership and governance of communal systems where applicable.

Policy Justification

6.1.32 The policy justification for this policy is covered under Policy NZ.8.

Policy NZ.8 (Non-Strategic Policy) Comment

Decentralised Energy Systems ~ Minor Development 

This policy applies to all minor development proposals including residential, commercial, industrial, institutional, leisure and mixed use. Where viable, development should comply with the following measures.

A. Decentralised Energy Measures

Minor development should incorporate, where feasible and proportionate to the scale of development, decentralised energy measures including:

  • Rooftop solar PV or solar thermal
  • Individual heat pumps
  • Shared communal heat pumps for small clusters
  • Battery storage
  • Smart controls and demand side response capability
  • Low-temperature heating systems in new dwellings
  • Design that enables future connection to heat networks, where located within or near heat network zones
  • Consideration of embodied carbon in material and system choices
  • Passive design measures to reduce heating and cooling demand

Where minor development is within a heat network zone, it must be designed to enable future connection unless demonstrated to be unfeasible or unviable.

B. Safeguarding and Co-location

Development should support the efficient integration of decentralised energy systems within sites and across adjacent developments where feasible and viable. Proposal for co-location of decentralised energy infrastructure will be supported where they do not result in unacceptable impacts on amenity, environmental quality, landscape, or infrastructure capacity.

C. Design, Amenity and Environmental Consideration

Decentralised energy infrastructure must be sensitively designed to minimise impacts on:

  • Landscape and townscape
  • Heritage assets
  • Noise and vibration
  • Air quality
  • Biodiversity
  • Flood risk
  • Residential amenity
Policy Justification

6.1.33 Policies NZ.7 and NZ.8 support the NPPF requirement for local plans to secure radical reductions in greenhouse gas emissions, supports renewable and low carbon energy and identified opportunities for decentralised energy networks.

6.1.34 Applying the policy to all major development, including commercial, industrial and institutional schemes is essential because:

  • Non-residential buildings often have high and consistent heat loads making them ideal anchor loads for heat networks
  • Commercial and industrial development can generate waste heat that can be captured and reused
  • Large non-residential schemes can place significant pressure on local electricity networks requiring coordinated grid planning
  • Embodied carbon in non-residential buildings is often substantial and must be considered in whole life carbon assessments.

6.1.35 Decentralised energy systems – including heat networks, communal heat pumps, microgrids and energy storage, play a crucial role in achieving net zero, improving energy resilience and reducing peak demand. Thermal masterplanning ensures that opportunities for heat networks and waste heat recovery are identified early and safeguarded.

6.1.36 The feasibility and viability requirement ensures that decentralised energy solutions are deliverable and proportionate while preventing over reliance on fossil fuel systems that would undermine long-term decarbonisation. The order of preference for heating and cooling systems ensures consistency with the Councils net zero policies and avoids lock in high carbon infrastructure.

6.1.37 Future proofing measures ensure that development can adapt to future technological and regulatory changes, including the transition to low temperature heat networks and increased electrification of heat and transport.

6.1.38 Local energy resilience is increasingly important due to grid constraints and the need to manage peak demand. Requiring storage, flexibility and coordination with DNOs helps prevent capacity shortfalls and reduces risk of outages. Safeguarding land for heat networks and grid reinforcement avoids the future sterilisation of land and ensures long term deliverability.

6.1.39 Embodied carbon is a significant component of whole life carbon emissions. Requiring consideration of embodied carbon ensures that decentralised energy infrastructure delivers genuine carbon benefits and avoids unintended consequences.

6.1.40 Minor development also has a role to play in decentralisation, and the policy provides clear expectations while maintaining proportionality.

6.1.41 The policy is positively prepared. It provides flexibility through feasibility and viability testing while ensuring development contributes meaningfully to the transition to a low-carbon decentralised energy system.

[11] Renewable Energy Guarantee of Origin. These are the certificates that energy suppliers purchase for their customers in order to offer their customers ‘renewable’ tariffs. If renewable energy generation equipment at a development towards policy NZC1’s target were also to sell REGO certificates to wholesale energy purchasers, then the carbon savings would be double-counted (once towards this policy, and then again by the customers purchasing the green tariffs that are based on those REGOs).

[12] Each kWh of renewable energy sent to the grid is here assumed to negate an equal amount of grid energy carbon per kWh. Embodied carbon emissions were estimated based on an average of per-m2 floorspace figures given in third-party published evidence in Oxfordshire and Essex, multiplied by the floor space amounts in South Warwickshire energy modelling evidence. Excess energy generation figures were derived from South Warwickshire energy modelling evidence (total generation minus total energy use, in kWh). The final figure is without accounting for deterioration in the generation ability of the solar panels over the 30 years, but also without assuming any reduction in the home’s energy use that could occur via increased efficiency of replacement appliances in that timescale, thus assuming that these two effects would balance each other out. Grid carbon intensity is assumed to reflect HM Government DESNZ ‘Green Book’ future grid carbon projections (specifically: grid average, consumption-based, domestic, from 2026 onwards).

[13] MCS is the Microgeneration Certification Scheme. https://mcscertified.com/

[14] Chartered Institute of Building Services Engineers, Technical Memorandum 54.

[15] SAP = Standard Assessment Procedure. The calculation currently used for demonstrating compliance with Building Regulations Part L for dwellings.

[16] SBEM = Simplified Buildings Energy Model. The calculation currently used for demonstrating compliance with Building Regulations Part L for buildings other than dwellings.

[17] Home Energy Model. A new calculation that will eventually replace SAP for demonstration of compliance with Building Regulations, described above.

[18] Renewable Energy Guarantee of Origin. These are the certificates that energy suppliers purchase for their customers in order to offer their customers ‘renewable’ tariffs. If renewable energy generation equipment at a development towards policy NZC1’s target were also to sell REGO certificates to wholesale energy purchasers, then the carbon savings would be double-counted (once towards this policy, and then again by the customers purchasing the green tariffs that are based on those REGOs).

[19] MCS is the Microgeneration Certification Scheme. https://mcscertified.com/

[20] For example:

[21] Chartered Institute of Building Service Engineers

For instructions on how to use the system and make comments, please see our help guide.
back to top