Q-C3.1: Do you think we should develop a carbon offsetting approach to new developments where it is demonstrated that it is not possible to achieve net carbon zero requirements on site?
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Carbon Sequestration: Carbon offsetting policies will be very important, especially to ensure that they are not abused by developers. There is no definition of offsetting in the glossary and this must be addressed.
No answer given
2.65. The integration of renewable energy and carbon sequestration within new developments could both be feasible options in helping to achieve net zero carbon development but, as stated elsewhere in this Statement, anything above standard requirements will need to be carefully considered in the context of other policy requirements to ensure that any approach adopted by the Councils is justified, viable and deliverable. 2.66. In the Respondent’s view, significantly more information needs to be provided before developers can provide any sort of meaningful comments on the suggested approach to renewable energy generation or carbon sequestration in South Warwickshire. The Respondent therefore reserves their right to make further comments once more information is made available in this regard. Q-
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Issue C1: Solar and wind power: Consideration should be given to communities benefiting in terms of a reduction to their cost of electricity for the time that the development is in place, as should giving the public the opportunity to buy shares in any wind farm and get a return in electricity cost reduction. The rooves of schools, warehouses, public buildings should be equipped with solar panels, and there should be a policy that all new buildings are equipped with appropriate levels of solar panels. Issue C3: Carbon Sequestration: Carbon offsetting policies will be very important, especially to ensure that they are not abused by developers. There is no definition of offsetting in the glossary and this must be addressed.
No answer given
Issue C1: Solar and wind power: Consideration should be given to communities benefiting in terms of a reduction to their cost of electricity for the time that the development is in place, as should giving the public the opportunity to buy shares in any wind farm and get a return in electricity cost reduction. The rooves of schools, warehouses, public buildings should be equipped with solar panels, and there should be a policy that all new buildings are equipped with appropriate levels of solar panels. Issue C3: Carbon Sequestration: Carbon offsetting policies will be very important, especially to ensure that they are not abused by developers. There is no definition of offsetting in the glossary and this must be addressed.
No answer given
Issue C1: Solar and wind power: Consideration should be given to communities benefiting in terms of a reduction to their cost of electricity for the time that the development is in place, as should giving the public the opportunity to buy shares in any wind farm and get a return in electricity cost reduction. The rooves of schools, warehouses, public buildings should be equipped with solar panels, and there should be a policy that all new buildings are equipped with appropriate levels of solar panels. Issue C3: Carbon Sequestration: Carbon offsetting policies will be very important, especially to ensure that they are not abused by developers. There is no definition of offsetting in the glossary and this must be addressed.
No answer given
QC1.1: Renewable energy generation 3.8 The University supports Option C1.1b to have a policy supporting renewable energy generation schemes in principle subject to criteria on the suitability of the location. The University already has plans for renewable energy generation on campus including long term ambitions in relation to the ecopark and would welcome a supportive policy and criteria to be met.
No answer given
Issue C1: Solar and wind power: Consideration should be given to communities benefiting in terms of a reduction to their cost of electricity for the time that the development is in place, as should giving the public the opportunity to buy shares in any wind farm and get a return in electricity cost reduction. The rooves of schools, warehouses, public buildings should be equipped with solar panels, and there should be a policy that all new buildings are equipped with appropriate levels of solar panels Issue C3: Carbon Sequestration: Carbon offsetting policies will be very important, especially to ensure that they are not abused by developers. There is no definition of offsetting in the glossary and this must be addressed.
No answer given
Q-C1.1. Please select the option which is most appropriate for South Warwickshire Option C1.1c. We consider that it is appropriate to identify land that is considered suitable for wind or solar energy generation schemes. However, we are not convinced that it is necessary, or appropriate, to ‘allocate’ such land. It would be sufficient for the option to be: . Identify land that is considered suitable for wind or solar energy generation schemes. An allocation normally relates to a specific site (rather than area) where a specific type and scale of development is considered to be both suitable and deliverable (i.e., likely to be available, developed and built open within the plan period). In many cases, such sites will have been put forward by a developed in a ‘call for sites’. If allocated sites are not deliverable then the development plan would not be ‘effective’ and, by extension, would not be ‘sound’. There is nothing in national planning policy or guidance to say that areas that are identified as being suitable for wind or solar energy have to be deliverable, in the context outlined above. In other words, it doesn’t have to be likely that the land would be available, or that the development would be delivered, within the plan period. Nor would it be appropriate to limit the identification of suitable areas to those locations that would be deliverable, in this context. Suitable areas, in the context of paragraph 155 and footnote 54 of the National Planning Policy Framework (NPPF), could potentially cover substantial areas of land. As such, they could potentially be larger than the area that might be required for individual wind or solar energy development proposals. Allocating suitable areas would potentially give the impression that the whole of the suitable area would, or should, be developed, which may not be appropriate. Instead of allocating land, it may be more appropriate to treat suitable areas as ‘areas of search’ – spatial areas that are identified as being potentially suitable for wind and solar energy subject to more detailed assessment at the project stage. We do not think that it would be appropriate to not identify suitable areas as this would, in effect, rule out wind energy proposals. However, again, this does not mean that the suitable areas have to be allocated. Q-C2. Please select the option which is most appropriate for South Warwickshire It would be better to have a requirements for decentralised energy systems for development over a relevant size thresholds than a more generic policy encouraging the consideration of such systems. We acknowledge that, for Option C2a to be effective, it may be necessary to concentrate planned growth into a smaller number of larger developments. However, development of this scale would not be appropriate in the Cotswolds National Landscape and is not likely to be appropriate within the immediate setting of the National Landscape. Q-C3.1. Do you think we should develop a carbon offsetting approach to new developments where it is demonstrated that it is not possible to achieve net carbon zero requirements on site? Yes. Within the Cotswolds National Landscape and its setting, such offsetting schemes should be delivered in a way that is compatible with - and, ideally, positively contributes to – the natural beauty of the National Landscape.
No answer given
Issue C1: Solar and wind power: Consideration should be given to communities benefiting in terms of a reduction to their cost of electricity for the time that the development is in place, as should giving the public the opportunity to buy shares in any wind farm and get a return in electricity cost reduction. The rooves of schools, warehouses, public buildings should be equipped with solar panels, and there should be a policy that all new buildings are equipped with appropriate levels of solar panels.
No answer given
Consideration should be given to communities benefiting in terms of a reduction to their cost of electricity for the time that the development is in place, as should giving the public the opportunity to buy shares in any wind farm and get a return in electricity cost reduction. The rooves of schools, warehouses, public buildings should be equipped with solar panels, and there should be a policy that all new buildings are equipped with appropriate levels of solar panels. Carbon offsetting policies will be very important, especially to ensure that they are not abused by developers. There is no definition of offsetting in the glossary and this must be addressed.
No answer given
Consideration should be given to communities benefiting in terms of a reduction to their cost of electricity for the time that the development is in place, as should giving the public the opportunity to buy shares in any wind farm and get a return in electricity cost reduction. The rooves of schools, warehouses, public buildings should be equipped with solar panels, and there should be a policy that all new buildings are equipped with appropriate levels of solar panels. Carbon offsetting policies will be very important, especially to ensure that they are not abused by developers. There is no definition of offsetting in the glossary and this must be addressed.
No answer given
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Q-C1.1: Please select the option which is most appropriate for South Warwickshire Option C1.1c: None of these Policy should ensure roof space is allocated for renewable energy production. Large warehouses have huge unused roof spaces for example which, with government led policy, could be utilised for green energy. This would mean space which could be allocated to agriculture/green belt/housing can be used for such rather than large solar/wind farms. Where land/space is in demand we need to utilise our roof and air space more effectively. Q C3.1 Do you think we should develop a carbon offsetting approach to new developments where it is demonstrated that it is not possible to achieve net carbon zero requirements on site? Don’t Know – Entirely depends on the nature of the offsetting scheme. Is this just green washing such as planting trees in the wrong site which will then not be looked after and not flourish or is this an offsetting scheme which actually makes a true beneficial impact?
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Energy Resources & Zero Carbon Emissions Our thought on this section are that it’s been written by someone who does not have a full understanding of their topic. There is no mention of hydrogen as a source of power – either it’s various forms of generation or use. Nor is there any very positive treatment of solar energy. Your analysis indicates that the use of solar panels on domestic or commercial buildings appears to be very low. Why is this when solar technology is currently increasing the efficiency of the panels at a high rate. Solar panels should form a major source of carbon free power going forward with micro hubs distributing the electricity around neighbourhoods and then buying from, or feeding surpluses, into the grid should be given the highest priority.
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Q-C1.1: Please select the option which is most appropriate for South Warwickshire Option C1.1c: None of these Policy should ensure roof space is allocated for renewable energy production. Large warehouses have huge unused roof spaces for example which, with government led policy, could be utilised for green energy. This would mean space which could be allocated to agriculture/green belt/housing can be used for such rather than large solar/wind farms. Where land/space is in demand we need to utilise our roof and air space more effectively. Q C3.1 Do you think we should develop a carbon offsetting approach to new developments where it is demonstrated that it is not possible to achieve net carbon zero requirements on site? Don’t Know – Entirely depends on the nature of the offsetting scheme. Is this just green washing such as planting trees in the wrong site which will then not be looked after and not flourish or is this an offsetting scheme which actually makes a true beneficial impact?
No answer given
Issue C2: Decentralised energy systems Q-C2: Please select the option which is most appropriate for South Warwickshire We would support Option C2b, which suggests having a policy encouraging the consideration of decentralised energy systems. Our client’s land lies adjacent to a solar farm and if allocated, we would explore the potential for connection to this facility to provide energy to any new settlement.
No answer given
Issue C3: Carbon Sequestration: Carbon Offsetting schemes: In principle yes – but we would need to see more details and strategies for its use before committing. Renewable / low carbon energy: The plan should identify suitable areas for different forms of renewable / low carbon energy. As a part of this, the plan should take account of the capacity of the natural environment to accommodate energy infrastructure. These should avoid designated landscapes and sites. Development management policies should address biodiversity and landscape impacts, including cumulative landscape and visual impacts.
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Q-C1.1: Option QC 1a because issues of connection to the grid can then be properly thought through. Q-C3.1: The Paper does not explain whether or how the planning system can require sequestration
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Issue C3 Carbon Sequestration Q-C3.1 A carbon off-setting approach to new developments could be supported in principle, if it was demonstrated that it is not possible to achieve net carbon zero requirements on a particular site. Further information is required on this subject and presumably this will be included in subsequent consultations.
No answer given
Q-C3.1 A carbon off-setting approach to new developments could be supported in principle, if it was demonstrated that it is not possible to achieve net carbon zero requirements on a particular site. Further information is required on this subject and presumably this will be included in subsequent consultations.
Q-C3.1: Do you think we should develop a carbon offsetting approach to new developments where it is demonstrated that it is not possible to achieve net carbon zero requirements on site? It is important that new planning policy requirements are soundly based and include flexibility to enable them to respond to the specific circumstances faced by individual sites / developments in terms of development type, physical characteristics and local market economics. A carbon offsetting approach would provide an opportunity for developments to mitigate their impact against any evidenced policy requiring zero carbon development where the requirements cannot be met on site. However any approach relating to carbon offsetting would need to be supported by a mechanism setting out how this would be applied in practice, identification of receptor sites / schemes for the funds paid and a demonstration through the local plan viability work that this would not adversely impact on the viability and deliverability of development (as recognised by NPPF paragraph 34).
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Q-C2: Please select the option which is most appropriate for South Warwickshire At this stage Bellway supports option C2c: None of these. Option C2a proposes to require decentralised energy systems on developments of 2,500 dwellings or more or 10ha+ of employment land which Bellway cannot support without evidence to justify that this is deliverable on these sites. Any policy requirement, should only ‘encourage’ this provision and agreed on a site by site basis. Larger strategic sites normally have significant infrastructure costs, particularly where they are new settlements, so this requirement will need to be factored into the site’s viability and delivery timescales. Q-C3.1: Do you think we should develop a carbon offsetting approach to new developments where it is demonstrated that it is not possible to achieve net carbon zero requirements on site? No – introducing this policy without national guidance is likely to lead to delays in the delivery of dwellings. There is also no local evidence to support this requirement and it will need to be tested through ‘needs’ evidence and the viability assessment for the plan. New homes are not required to be zero carbon until 2050 and policy should not be going further than the Future Homes Standard.
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Q-C2 – Please select the energy system approach which you believe to be the most appropriate for South Warwickshire. It is our view that the SWLP should have a policy to encourage the consideration of decentralised energy systems, however, there should not be a threshold above which such systems are expected. Decentralised energy systems can be costly and not always practical. There is currently a lack of evidence to demonstrate that the 2,500 threshold suggested for the use of decentralised energy systems is achievable and will not adversely affect viability. Instead, the SWLP should include a policy advising that the provision of decentralised energy systems would be considered a significant benefit in the planning balance during the course of determining planning applications.
No answer given
Issue C3: Carbon Sequestration Q-C3.1: Do you think we should develop a carbon offsetting approach to new developments where it is demonstrated that it is not possible to achieve net carbon zero requirements on site? 5.1 A carbon offsetting approach should be introduced as part of the new Local Plan to allow for flexibility in instances where it is not feasible to achieve net carbon zero requirements on a site, whether that be due to site constraints, viability or practicality of being able to develop the site. However, it is important to ensure sufficient viability testing has been carried out to support the Policy.
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if it is not Net Zero should not be granted planning permission
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Q-C2 – Please select the energy system approach which you believe to be the most appropriate for South Warwickshire. It is our view that the SWLP should have a policy to encourage the consideration of decentralised energy systems, however, there should not be a threshold above which such systems are expected. Decentralised energy systems can be costly and not always practical. There is currently a lack of evidence to demonstrate that the 2,500 threshold suggested for the use of decentralised energy systems is achievable and will not adversely affect viability. Instead, the SWLP should include a policy advising that the provision of decentralised energy systems would be considered a significant benefit in the planning balance during the course of determining planning applications.
No answer given
Q-C3.1: Do you think we should develop a carbon offsetting approach to new developments where it is demonstrated that it is not possible to achieve net carbon zero requirements on site? 2.61. Don’t know. As recognised in the Consultation Document, some developments may not be able to completely neutralise their carbon emissions on site and in these cases a carbon off-setting approach would seem reasonable. However, it will be imperative that the SWLP provides an appropriate mechanism for carbon offsetting. The Consultation Document suggests that in addition to natural solutions such as tree planting that a fund could be created through the pooling of financial contributions from developers which will enable the existing housing stock to be retrofitted with measures to help reduce carbon emissions. However, it is not clear how such a scheme would operate in practice (i.e., how will financial contributions be calculated and who would be responsible for administrating, delivering and monitoring such a scheme?) or if it would meet the tests of Regulation 122 of the CIL Regulations 2010 (as amended). Without more information it is therefore very difficult to comment. Accordingly, the Respondent reserves their right to comment once more information is made available in this regard. Q-C3.3: Please add any comments you wish to make about renewable energy generation or carbon sequestration in South Warwickshire 2.62. The integration of renewable energy and carbon sequestration within new developments could both be feasible options in helping to achieve net zero carbon development but, as stated elsewhere in this Statement, anything above standard requirements will need to be carefully considered in the context of other policy requirements to ensure that any approach adopted by the Councils is justified, viable and deliverable. 2.63. In the Respondent’s view, significantly more information needs to be provided before developers can provide any sort of meaningful comments on the suggested approach to renewable energy generation or carbon sequestration in South Warwickshire. The Respondent therefore reserves their right to make further comments once more information is made available in this regard.