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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Issue C4: New Buildings 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of changes to Building Regulations will probably mean that plans adopted to align with current standards will soon be out of date. Issue C6: Whole Life-Cycle carbon emissions assessments Q-C6.1c – none of these. The requirement for such an assessment would be unduly onerous on the developers and we would argue that Building Regulations and the need to comply with them, will adequately safeguard emissions to agreed levels (set nationally by the Government).
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Q-C4.1: Please select all options which are appropriate for South Warwickshire We are generally supportive of Option C4.1c – a phased approach to net zero carbon - setting a future date by which all new development will need to achieve net zero standards. L&Q Estates are committed to responding to the climate crisis and are actively looking to deliver housing to standards above those set out in current building regulations in response to this challenge. Indeed, their most recent Corporate Strategy includes a commitment to setting an L&Q design standard in response to the emerging Future Homes Standard, as well as more broad investment in modern methods of construction. However, it is important to note that renewable and low carbon energy dwellings may not always be practicable or viable in new developments. Therefore, we are supportive of Option C4.1c insofar as this option allows time for the cost of achieving these standards to come down, and may mean that more affordable housing and community benefits can be secured from development.
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Q-C4.1: Please select all options which are appropriate for South Warwickshire 49. Any such proposed policy would be a duplication of control and is unnecessary.
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Q-C4.1: Please select all options which are appropriate for South Warwickshire 5.1. If a net zero carbon policy is to be employed by the Council it must be fully evidenced and justified, and included in viability considerations. 5.2. 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 efficiency. The Council does not need to set local efficiency standards to achieve the shared net zero goal. Q-C6.1: Please select the option which is most appropriate for South Warwickshire 5.3. Whilst the value of Whole Life-Cycle Carbon assessments is recognized 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, properties will be owned by the purchaser and mortgagees. 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 longer owns 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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ISSUE C4: NEW BUILDINGS Q-C4.1: Please select all options which are appropriate for South Warwickshire 2.44 Ellis Machinery would not support any of the above. Any such proposed policy would be a duplication of control and is unnecessary.
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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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Q-C4.1: Please select all options which are appropriate for South Warwickshire 5.1. If a net zero carbon policy is to be employed by the Council it must be fully evidenced and justified, and included in viability considerations. 5.2. 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 efficiency. The Council does not need to set local efficiency standards to achieve the shared net zero goal. Q-C6.1: Please select the option which is most appropriate for South Warwickshire 5.3. Whilst the value of Whole Life-Cycle Carbon assessments is recognized 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, properties will be owned by the purchaser and mortgagees. 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 longer owns 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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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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Q CA 4.2 What scale of development should the requirements apply to? Claverdon does not have expertise to respond to this point. QC5 Please select all options which are appropriate for South Warwickshire Claverdon does not have expertise to respond to this point QC6.2.1 If a phased approach is used, what dates and thresholds should be used? Claverdon does not have expertise to respond to this. QC6.2.2 Please add any comments you wish to make about Net Zero Carbon buildings in South Warwickshire Claverdon does not have expertise to respond to this.
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Q-C4.1: The SWLP is being prepared to cover the period up to 2050. During the course of the plan period building regulations will 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 implemented and could result in an out of date policy in the SWLP.
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Q-C4.1: we need to be brave and make it our USP. Why delay, eventually it will be governmet policy so lets get ahead Q-C4.2: Yes. The alternative could lead to a surge of extensions and rebuilds as a way of bi-passing the system Q-C5: C5a + C5b a mixture of the two. need to set boundaries
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2.20 Climate Change Mitigation and New Buildings (C4.1 and C4.2) 2.20.1 WPDG supports a phased approach to net zero carbon for new buildings, setting a future date by which all new development will need to achieve net zero standards. This could be 2030 in line with the ambitions of the South Warwickshire Climate Action Plan. In the intervening period new development will need to meet building regulation standards. 2.20.2 Question C4.2 asks what scale of development the requirement should apply to. It is suggested that this is applied to major developments as defined in Annex 2 of the NPPF (subject to viability testing).
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Q-6.1 45. Achieving 100% reduction in embodied emissions for new developments is not an easy proposition for any developer or authority to establish. As is noted in the Issues and Options document, a number of the factors are outside the direct control of the developer, occupier and authority (e.g. decarbonisation of the national grid). As is also noted, there are significant cost considerations if this approach is adopted which will impact upon viability. The sorts of concerns do need to be taken into account if a viable and deliverable Local Plan is to be prepared. 46. If 100% reduction in embodied emissions is sought then there is a need for the wider technologies with the construction sector to fully adjust and it would be appropriate for a phased approach to be adopted if this type of policy is to be carried forward.
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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 5.1. If a net zero carbon policy is to be employed by the Council it must be fully evidenced and justified, and included in viability considerations. 5.2. 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. 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 5.3. 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, properties will be owned by the purchased and mortgagees. 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 longer owns 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 is still 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 46. Net zero carbon and construction standards for new homes should accord with national policy and regulations rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling. Q-6.1 47. Achieving 100% reduction in embodied emissions for new developments is not an easy proposition for any developer or authority to establish. As is noted in the Issues and Options document, a number of the factors are outside the direct control of the developer, occupier and authority (e.g. decarbonisation of the national grid). As is also noted, there are significant cost considerations if this approach is adopted which will impact upon viability. The sorts of concerns do need to be taken into account if a viable and deliverable Local Plan is to be prepared. 48. If 100% reduction in embodied emissions is sought then there is a need for the wider technologies with the construction sector to fully adjust and it would be appropriate for a phased approach to be adopted if this type of policy is to be carried forward.
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Q-C4.1 46. Net zero carbon and construction standards for new homes should accord with national policy and regulations rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling. Q-6.1 47. Achieving 100% reduction in embodied emissions for new developments is not an easy proposition for any developer or authority to establish. As is noted in the Issues and Options document, a number of the factors are outside the direct control of the developer, occupier and authority (e.g. decarbonisation of the national grid). As is also noted, there are significant cost considerations if this approach is adopted which will impact upon viability. The sorts of concerns do need to be taken into account if a viable and deliverable Local Plan is to be prepared. 48. If 100% reduction in embodied emissions is sought then there is a need for the wider technologies with the construction sector to fully adjust and it would be appropriate for a phased approach to be adopted if this type of policy is to be carried forward.
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Q-C4.1 43. Net zero carbon and construction standards for new homes should accord with national policy and regulations rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling. Q-6.1 44. Achieving 100% reduction in embodied emissions for new developments is not an easy proposition for any developer or authority to establish. As is noted in the Issues and Options document, a number of the factors are outside the direct control of the developer, occupier and authority (e.g. decarbonisation of the national grid). As is also noted, there are significant cost considerations if this approach is adopted which will impact upon viability. The sorts of concerns do need to be taken into account if a viable and deliverable Local Plan is to be prepared. 45. If 100% reduction in embodied emissions is sought then there is a need for the wider technologies with the construction sector to fully adjust and it would be appropriate for a phased approach to be adopted if this type of policy is to be carried forward.
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Q-C4.1 44. Net zero carbon and construction standards for new homes should accord with national policy and regulations rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling. Q-6.1 45. Achieving 100% reduction in embodied emissions for new developments is not an easy proposition for any developer or authority to establish. As is noted in the Issues and Options document, a number of the factors are outside the direct control of the developer, occupier and authority (e.g. decarbonisation of the national grid). As is also noted, there are significant cost considerations if this approach is adopted which will impact upon viability. The sorts of concerns do need to be taken into account if a viable and deliverable Local Plan is to be prepared. 46. If 100% reduction in embodied emissions is sought then there is a need for the wider technologies with the construction sector to fully adjust and it would be appropriate for a phased approach to be adopted if this type of policy is to be carried forward.
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MAOL recognises that its operations impact upon the environment and is committed to regular monitoring, auditing and reviewing activities with a view to identifying opportunities for sustainable environmental improvement, in line with strategic business goals. Our client also recognises that the planning system has a crucial role to play in delivering effective action on climate change and supports the Council’s commitment to reducing carbon outputs as a positive response to the Climate Emergency Action Plan. Our client does not comment on the technical requirement around achieving net zero but is keen to ensure that any policies are flexible enough to deal with different/changing circumstances and so that development specific and site specific/context issues can be fully considered. For example, any development within the grounds of Warwick Castle would need to consider the varied challenges of managing an historic site. Also, there may be technical and financial viability issues associated with net zero, particularly if applied to proposals for the conversion or change of use of existing buildings. As a general point, the Issues and Options consultation includes a lot of technical details around climate change. Our client agrees that the SWLP Part 1 should consider how the climate emergency will be met and that climate change should be at the heart of decision making. However, the SWLP Part 1 should avoid being overloaded with detailed requirements which will either come in Part 2 or can be satisfactorily addressed through National Policy/Building Regulations. Rather, consideration should be given to the inclusion of a strategic policy which requires appropriate mitigation for climate impacts to be embedded in all development proposals and explains in broad terms how the SWLP will support the Councils’ ambitions toward a reduction in carbon emissions to net zero.
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Issue C4.1 a-c and C5 a-c : New and Existing Buildings . The Chamber does not favour developing a policy framework that requires measures that go ahead and beyond of new Building Regulations. This would be particularly the case for new commercial buildings and offices. Currently, due to dramatic increases in building costs, especially for buildings that require large quantities of steel such as warehouse, offices and factory buildings there are significant viability issues associated with the ability to add new stock to parts of the sub regions commercial stock . Land values and rental levels in many parts of the region mean that much new development is very marginal and finely balanced. Imposing new plan based requirements could completely remove the possibility of new development in some sectors and for some types of space .This would severely handicap and hamper the growth of the local economy . The same factors would be at work with the existing building stock should net zero requirements be imposed in the plan area ahead of national requirements .It also follows that any changes should be introduced on a phased basis and spread over a relatively long period of time.
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Waste Waste policy is found within the Warwickshire Waste Core Strategy Local Plan, adopted in July 2013. Notwithstanding this, the South Warwickshire Local Plan has an important role to play in reducing waste and moving waste up the ‘waste hierarchy’ (prevention; preparing for reuse; recycling; other recovery; disposal). WCC supports the use of whole life-cycle emissions assessments and embodied emissions reduction targets, as this could help to reduce waste. However, we consider that more evidence is required to inform the particular policy options considered under issue C6.
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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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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.
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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. 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.