Q-C6.1: Please select the option which is most appropriate for South Warwickshire
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Issue C4: New Buildings: Warwick District Council should set a higher local standard beyond the building regulations requirements to achieve net zero carbon in all new developments. Issue C5: Existing Buildings: The council should include a policy that requires net zero carbon requirements for all building proposals that require planning permission, including conversions, changes of use, and householder residential applications.
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We also agree with Option C4.1b: Set a higher local standard beyond the building regulations requirements to achieve net zero carbon in all new developments. Our clients’ aspirations for residential development within South Warwickshire is for net zero carbon homes, to be able to actively contribute to the wider environmental agenda. Whilst we also agree that this may impact on the provision of affordable housing in terms of the viability of sites and the additional costs associated with creating net carbon, but a balance has to be struck. Whilst phased approach will provide additional time for developers, starting the requirements from say 2030 in line with the South Warwickshire Climate Action Plan. However a Net Zero policy should start from the start of the SWLP plan period, in order for the plan to then manage the provision of this across the period, otherwise it will not be able to meet the strategic objective of having a “resilient and Net Zero Carbon South Warwickshire Contributing towards Net Zero Carbon targets Ensuring that new development does not cause a net increase in carbon emissions, that new developments are resilient to a changing climate, and that every opportunity is taken to reduce existing carbon emissions and mitigate against climate harms”. Innovation in zero carbon technologies as well as building fabrics could also seek to help design better buildings which are would also meet the other strategic vision of a “A well-designed and beautiful South Warwickshire - Focusing on the design of new development to create great places, spaces and buildings that are of a high quality and cater for the needs of all users and which respect the setting of our many settlements” Smaller development can begin the introduction of more eco-friendly design in a rural setting, which can then potentially have a knock-on effect and help promote entire small-scale settlements and villages to seek to collectively be more carbon neutral (subject to any restrictive designations). Undertaking these types of wholescale behavioural changes through small scale gentle development can be more appealing to smaller settlements. In terms of what scale of development this should apply to, we agree with Option C4.2b: Development over a certain size as opposed to all development, including residential extensions. What threshold this should be set against should be linked to the threshold for the provision of affordable housing so that this can be taken into account as part of the viability work.
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Issue C4: New Buildings: Warwick District Council should set a higher local standard beyond the building regulations requirements to achieve net zero carbon in all new developments. Issue C5: Existing Buildings: The council should include a policy that requires net zero carbon requirements for all building proposals that require planning permission, including conversions, changes of use, and householder residential applications.
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The importance of climate change is such that in July 2019 Warwick and Stratford-on-Avon District Councils declared a climate emergency, and consequently produced a joint Climate Change Action Programme. The climate emergency requires both Councils to become netzero carbon as organisations by 2025, but more importantly seeks to reduce the total emissions in the District as a whole by at least 55% with a view to becoming a net zero District. We agree with the Council’s assertion that the Local Plan has a role to play in reducing the carbon footprint of the district and an overarching support towards achieving net-zero carbon development across the sub region. This will need to form a strong consideration through the choice of the growth options, with development directed towards areas where existing sustainable infrastructure is located. It is imperative that in order for the Local Plan to achieve this, that the Council delivers objectives around good growth which addresses carbon emissions, but does via planning policies that are fully tested for their potential viability implications.
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Warwick District Council should set a higher local standard beyond the building regulations requirements to achieve net zero carbon in all new developments. The council should include a policy that requires net zero carbon requirements for all building proposals that require planning permission, including conversions, changes of use, and householder residential applications.
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Warwick District Council should set a higher local standard beyond the building regulations requirements to achieve net zero carbon in all new developments.
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All new hoiusing to be built in the district needs to be zero carbon (Bath and North East Somerset have just adopted this policy). This will preclude most sporadic development in the countryside not essential to local needs. Stratford District has a bad record of allowing large free standing hoiuses to be developed in open countryside. Small cottages are often bought by developers and converted to huge houses. This is not environmentally sustainable.
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Issue C4: New buildings Net Zero Carbon policies are seeing increasing take up across new Local Plans and are likely to become common policy requirements in the future. Many authorities are following the London Plan approach to Net Zero Carbon which requires offsite contributions for Net Zero where it cannot be reached onsite. Often it is difficult to meet Net Zero carbon on residential sites with as roof spaces are not sufficient for the amount of PV required, even with a fabric first approach taken into account. Therefore, any emerging policy needs to consider an offsetting fund where it cannot be reached on site. Option C4.1c is the most appropriate approach for the Council to take on this issue with regard to the Greenhill Street Site. This will enable the development industry to adapt to the higher standards over time, and should give time for the costs of meeting the standard to come down. It is imperative that the Council’s consider these layered climate change policies against the delivery of affordable housing in this country, which is already constrained by viability, particularly with brownfield locations. Therefore, a phased approach enables developers time to adjust and supports the delivery of vital affordable housing to the District. Issue C6: Whole Life-Cycle carbon assessments Similar to the preceding issue, Orbit is supportive of detailed climate change policies overall but seeks flexibility and phasing of their introduction to retain the viability and deliverability of sites. A Whole LifeCycle Carbon Assessment considers a building’s carbon impact on the environment and are most usefully undertaken once a building has been constructed but prior to occupation. It should therefore be questioned whether requiring them at planning stage will result in submission of high-level reports which are not sufficiently detailed or accurate. The viability of such a policy would need to be tested during the plan making stage. The Councils therefore need to thoroughly consider at what point in the planning process is the most suitable for Whole Life-Cycle carbon assessments to be required to ensure that they get the most out of the process without placing unnecessary burden on developers at too early a stage in the development process.
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Q-C4.1: Please select all options which are appropriate for South Warwickshire Option C4.1a: Do not have a policy and allow new developments to comply with the national regulation requirements, which may change over time If a net The Building Regulations Part L 2021 Target for Fabric Efficiency would be applicable to all proposed dwellings and sets the Government’s standards for energy efficient. The Council does not need to set local efficiency standards to achieve the shared net zero goal. zero carbon policy is to be employed by the Council it must be fully evidenced and justified, and included in viability considerations. Q-C6.1: Please select the option which is most appropriate for South Warwickshire Whilst the value of Whole Life-Cycle Carbon assessments is recognised and there is no in principle objection to the need for some forms of post construction, pre-occupation assessment, if a policy is to be pursued on this matter there are a number of key considerations: • Once sold, the purchasers and mortgagees will own properties. Any policy would need to be carefully worded such that it would not require the sharing of energy use, air quality and overheating risk data with a third party, where the developer no longs the dwelling as this could raise GPDR issues. Enforcement of such a policy for future owners and occupiers could also fail the test of conditions on any subsequent planning permission. • The purpose of such information would also need to be clearly set out. It will not be possible to post factum make alterations to the constructed buildings, so what would be the benefit or purpose of such a significant amount of data collation? If the purpose is to inform and advise as to future construction methods, then this could be equally achieved by an informed and targeted research exercise by organisations such as the BRE in advising Governments and through amendments to Building Regulations.
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Q-C4.1: The Pare does not explain how setting higher standards in this area could mean fewer affordable homes or fewer community facilities – so how can we make a balanced choice. There should be a national policy. Q-C5: Option C5c. This surely a matter for national policy and we are not at all convinced that you have the resources or expertise to produce a proportionate policy
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Q-C4.1 We consider that there is no requirement to have a specific policy covering the energy efficiency standards of new development. This would be a duplication of Building Regulations which are being updated regularly to reflect the national desire to reduce carbon dioxide emissions from previous standards. The frequency of changes to Building Regulations will probably mean that plans adopted to align with current standards will soon be out of date.
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I am surprised at some of the questions being asked in this chapter. A good example is C4.1 - it seems obvious to me that a project at the scale of a Local Plan should be aiming for net zero in all new developments (Option C4.1b) and it seems ridiculous to me that anything else is even potentially being considered. Enabling people to argue for a lowering of standards is just storing up bigger problems for later. The climate crisis is the biggest issue facing our world and we are going to have to make significant changes to the way we make and build things. The Local Plan is a perfect opportunity to set out how things can be done properly. For example all new dwellings should be built to the highest standards of energy efficiency and be installed with renewable energy sources such as heat pumps and solar panels. Developers may say that this will make schemes unviable but profit margins cannot be a consideration here - we are talking about houses that will stand for decades or longer so the aims and expectations should be as ambitious as possible. There are examples of innovative, attractive and environmentally friendly housing schemes being built all over the UK but particularly in urban areas and lessons should be learnt from these
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80% reduction by 2040 and 100% reduction by 2050.
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Issue C5: Existing Buildings We welcome the acknowledgement of Historic England’s advice on the re-use of existing buildings and the links to our relevant webpage. In terms of Option C5b, whilst Historic England supports measures to tackle climate change, retrofitting of renewable technologies on historic buildings can be more challenging and we would recommend reference to our latest advice on this subject: https://historicengland.org.uk/advice/technical-advice/retrofit-and-energy-efficiencyin-historic-buildings Issue C6: Whole Life-Cycle Carbon Emission Assessments Historic England 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.
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Q-C4.1: Please select all options which are appropriate for South Warwickshire In the absence of evidence being presented by the Council, Crest Nicholson supports option C4.1a. Building Regulation standards are able to change to address and accommodate best practice and the latest technology and standards being brought forward by the development industry on a comparable, national, basis. Local Plan policy is not as agile in responding to such innovation and as such is not an appropriate way to control building standards. Crest Nicholson requests that the South Warwickshire LPAs clarify the evidence they propose to rely upon to justify any proposed additional standards. In the absence of a robust evidence based justification there is still an opportunity for policy wording to encourage developers to exceed the requirements set out within Building Regulations to seek for individual sites and developers to deliver net zero carbon in advance of this becoming enshrined in the Building Regulations, where this is possible. Crest Nicholson is the first UK housebuilder to have its net-zero target validated by the Science Based Targets initiative (SBTi), reflecting its commitment to reducing greenhouse gas (GHG) emissions across its value chain and reaching net-zero GHG emissions by 2045. Crest Nicholson is already making progress in reducing GHG emissions, driving the efficient use of plant and equipment on site, trialling lower carbon technologies including hybrid generators and an electric telehandler, using alternative low carbon fuels and increasing the procurement of renewable electricity. To reduce emissions relating to other organisations in it supply chain, Crest Nicholson continuously reviews the design, technologies and materials used within its homes. It is also a member of the Future Homes Hub’s Embodied and Whole Life Carbon Workgroup, which is developing guidance, tools and an implementation plan to support an industry-wide reduction in whole life carbon. Such measures will be introduced at the Crest Nicholson site to the south of Westwood Heath Road, to minimise the GHG impacts of the proposed development. There are opportunities for other house builders and developers to follow suit without rigid requirements and timescales being set within Local Plan documents. Q-C4.2: What scale of development should the requirements apply to? An approach aligned to Building Regulations will apply to all development. Approaches which seek to introduce a standard which is in excess of the Building Regulation requirements will need to be appropriately justified, including through the use of a viability appraisal. Q-C6.1: Please select the option which is most appropriate for South Warwickshire The preferred option relating to carbon emissions should be informed by reference to a robust evidence base. Neither the National Planning Policy Framework nor the Planning Practice Guidance require embodied carbon emissions to be measured. The proposed policy approach does not provide any detail in relation to: the application of the embodied carbon assessment; what baseline the assessment will be measured against; and how the outcome of the assessment would be enforced. There are currently considered to be data collection issues impacting on the ability to undertake a proper Whole Life Carbon Assessment. Principally, many manufacturers are still lacking the creation and verification of data for Environmental Product Declarations. Any requirements which are over and above national policy need to be clearly evidenced, including through impacts on viability.
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South Warwickshire is stating a commitment to Net Zero, therefore a prerequisite should be that all new housing stock has to meet “passive standard” construction. This will include affordable housing (subsidised by the constructor). Britain has a record of building houses of poor insulation standards and hence high heating costs, which in turn has a negative effect the environment. By insisting on passive houses, the heating costs will be minimal, environmental effects will be minimised and it will massively increase South Warwickshire’s goal of meeting net zero.
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Issue C4: New Buildings 5.1 We do not consider that there is any justification for seeking achievement of standards on carbon uses which exceed building regulations. 5.2 The Government have set out a clear roadmap to low carbon homes that will alongside the decarbonisation of the national grid ensure that the Government can meet its commitments to net zero by 2050. 5.3 Government recognises that the improvements in energy efficiency of new homes should be a transition which ensures that new homes continue to come forward to meet housing needs whilst still be sufficiently challenging to significantly reduce the carbon emissions of new homes from 2025. 5.4 There is no requirement or justification for additional standards to be placed on development through local plans.
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Bellway considers that the SWLP should not set their own targets, national guidance should lead on dates and thresholds.
Q-C6.1: Please select the option which is most appropriate for South Warwickshire (Whole Life-Cycle Carbon Emission Assessments) Bellway supports Option C6.1c: None of these. The preferred option relating to carbon emissions should be informed by reference to a robust evidence base. Neither the NPPF nor the PPG require embodied carbon emissions to be measured. The proposed policy approach does not provide any detail in relation to: the application of the embodied carbon assessment; what baseline the assessment will be measured against; and how the outcome of the assessment would be enforced. There are currently considered to be data collection issues impacting on the ability to undertake a proper Whole Life Carbon Assessment. Principally, many manufacturers are still lacking the creation and verification of data for Environmental Product Declarations. Any requirements which are over and above national policy need to be clearly evidenced, including through impacts on viability.
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In response to Q-C6.3, it is important that carbon reduction policies in the Part 1 SWLP avoid onerous requirements, well beyond which is normally expected, feasible and readily demonstrable in the current development industry and which the Local Planning Authority (LPA) has the expertise to review. Any requirements should be reflective of national policy requirements and therefore Bourne Leisure considers that the preferred approach should be Option C6.1c, so not to discourage investment in the area. If Whole Life-Cycle Carbon Emissions Assessments are introduced through the Part 1 SWLP, the policy requirement for such a document should include different targets for different scales and types of development. Whilst there will be a need for it to be simple to understand, and it should address circumstances such as applications being determined that cross the threshold dates, this approach would allow the policy to properly respond to different sectors, types and nature of developments. It would also give the development industry an opportunity to be prepared for any new requirements. Further to this, any new policies should recognise the challenge of meeting any such requirements for conversions, changes of use and the extensions of buildings.
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Q-C4.1 – Please select the building regulations requirement option that is appropriate for South Warwickshire Option C4.1a is the most appropriate, the SWLP should not include a policy setting higher standards on renewable energy that the building regulations. The SWLP is being prepared to cover the period up to 2050. During the course of the plan period building regulations are likely to change. It is appreciated that it is highly likely that there will be at least one Local Plan review within the next 5 to 10 years, however, by the time a replacement Local Plan is in place updated building regulations could have been produced resulting in an out of date policy in the plan. In addition, any additional standards would need to be fully factored into any viability assessment work produced by the Council’s support of preparation of the SWLP. The additional costs associated with the increased building relation standards could have significant viability issues, potentially making some brownfield sites undeliverable, or causing viability issues that reduce the quantum of affordable housing provided. Whilst we fully support the concept of delivering energy efficient buildings and working towards net zero carbon buildings, the implications of making this mandatory in the plan need to be fully understood in the context of viability.
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Issue C6: Whole Life-Cycle carbon emission assessments Q-C6.1: Please select the option which is most appropriate for South Warwickshire Option C6.1a – Include a Policy that requires new developments to have a whole lifecycle emissions assessment, with a target for 100% reduction in embodied emissions compared to a business as usual approach to construction? Option C6.1b – Include a Policy that has different whole lifecycle reduction targets for different scales and types of developments and for different time periods. Option C6.1c – None of these. 5.4 Catesby Estates acknowledges that it is important to consider the emissions resulting from materials, construction activities and the use of a building over its lifetime. However, the Councils have not presented any evidence to justify the options presented at this stage. Therefore, at present, without viability evidence and a baseline for emissions data, it is not possible, or justified to introduce Option C6.1a as a Policy. 5.5 Option C6.1a could have a detrimental impact upon the viability of developments, and would potentially impact upon delivery of sites coming forward. A Policy requiring new developments to have a target for 100% reduction in embodied emissions could undermine the other objectivges of the plan including delivery of much needed housing. 5.6 We would emphaise the need for the policy to be supported by robust viability work. Q-C6.2: If a phased approach is used, what dates and thresholds should be used? 5.7 The dates and thresholds should be realistic and justified but underpinned by evidence undertaken by the Councils. The approach should correspond with Part L of the Building Regulations to ensure consistency throughout. It is important to also accord with the NPPF, which sets out within Paragraph 152 that the planning system should support the transition to a low carbon future in a changing climate, thus any proposed planning policy should be transitional, but also prepared positively, ensuring aspiration but deliverability, as per paragraph 16 of the NPPF.
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We consider that both the planning approval and buildings regulations processes for South Warwickshire should set the highest possible standards for carbon reductions for all new build properties. Standards for extensions and conversions should encourage reto-fitting and carbon reduction measures.
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2.68. If the decision is made to proceed with a policy that seeks reductions in embodied emissions, then a phased approach should be adopted. However, it is difficult to advise where this threshold should be set without more information being provided regarding the potential implications of such a policy. The Councils should therefore look to test the various options and present this work as part of a preferred strategy which can be commented on in due course.
Q-C4.1: Please select all options which are appropriate for South Warwickshire Option C4.1a: Do not have a policy and allow new development to comply with the national building regulation requirements, which may change over time. 2.64. The Respondent considers it superfluous to include a policy requiring new development to comply with national building regulation requirements given that developers will need to comply with Building Regulations in any event. 2.65. While the Councils aspirations to raise the standard of design and achieve net zero carbon is understood, and to some extent supported, achieving this will come at a significant cost to development which, given the time frames involved, is unlikely to be easily absorbed and therefore has the potential to put at risk the delivery of sites and, in turn, the timely delivery of market and affordable homes. 2.66. Considering these concerns, Option 4.1a is considered to be most appropriate. If, however, the Councils are minded to set a higher local standard, then it is advised that realistic transitional arrangements are allowed for to enable the development industry time to respond. In the Respondent’s view, the timeframe indicated in Option C4.1c is the minimum that should be adopted. In imposing standards caution also needs to be shown to ensure that redundant technology is not prescribed and that developers can make an appropriate choice of systems at the time houses are being delivered. In addition, the Plan will have to be supported by evidence demonstrating that the viability both technical and financial has been taken into account. Q-C6.1: Please select the option which is most appropriate for South Warwickshire Option C6.1c: None of these 2.67. While the Councils’ aspiration to raise standards and seek greater reductions in embodied emissions is appreciated, the Respondent has significant concerns regarding the additional cost to the development industry, which cannot be easily absorbed.
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Issue C4: New Buildings: Warwick District Council should set a higher local standard beyond the building regulations requirements to achieve net zero carbon in all new developments. Issue C5: Existing Buildings: The council should include a policy that requires net zero carbon requirements for all building proposals that require planning permission, including conversions, changes of use, and householder residential applications. If any houses are built, every one of them should be fully insulated, and made as near to zero heating as possible.
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Q-C4.1 - Please select all options which are appropriate for South Warwickshire: 1) Option C4.1a: Do not have a policy and allow new development to comply with the national building regulation requirements, which may change over time. 2) Option C4.1b: Set a higher local standard beyond the building regulations requirements to achieve net zero carbon in all new developments. 3) Option C4.1c: Have a phased approach to net zero carbon, setting a future date by which all new development will need to achieve net zero standards. In the intervening period new development will need to meet building regulation standards. Option C4.1a is preferred as it would be onerous to set a standard higher than the building regulations requirement. A policy could encourage a local standard beyond building regulations but should not mean that an application should be refused because it does not meet regulations over and above the national standard. In time, the building regulations will evolve to allow a phased approach to reaching Net Zero. A separate approach would hinder plan delivery due to developers having to have a different design, building process and materials to the regulations, slowing the pace of delivery and reducing viability. Davidsons are committed to energy efficiency in our homes and currently build to a high standard than buildings regulations require.
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Issue C4: New Buildings: Warwick District Council should set a higher local standard beyond the building regulations requirements to achieve net zero carbon in all new developments. Issue C5: Existing Buildings: The council should include a policy that requires net zero carbon requirements for all building proposals that require planning permission, including conversions, changes of use, and householder residential applications.