Q-C9.1: Please select the option which is most appropriate for South Warwickshire

Showing forms 151 to 180 of 194
Form ID: 83406
Respondent: L&Q Estates
Agent: Mr Will Whitelock

Issue C7: Adapting to higher temperatures It is considered that a requirement to future-proof new development to adapt to the effects of higher and more extreme temperature change could be incorporated as part of design guides/codes for strategic development sites or locations. As shown on the Vision Document for Land South of Allimore Lane, Alcester, the orientation of buildings and streets to reduce excessive solar gain and to catch breezescould be considered as part of the scheme design. The use of green infrastructure, greenspace and bluespace can be integrated within the masterplan and landscape framework, in order to minimise the urban heat island effect, provide shading and places of refuge and promote evaporative cooling. L&Q Estates intend to engage with the local community and other stakeholders through public consultation events to help influence the design of the Land South of Allimore Lane, Alcester development during the preparation of the outline planning application, following the adoption of the South Warwickshire Local Plan. A site-specific design code will be developed for the Site in accordance with NPPF Paragraph 129. Q-C9.1: Please select the option which is most appropriate for South Warwickshire NPPF Paragraph 32 advises that local plans should address relevant environmental objectives, including opportunities for net gains. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered). Further, Paragraph 174 advises that planning policies and decisions should contribute to and enhance the natural and local environment by minimising impacts on and providing net gains for biodiversity, including establishing coherent ecological network that are more resilient to current and future pressures. L&Q Estates are supportive of Option C9.1a: Include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity. The Site will seek to deliver a minimum 10% in biodiversity net gain, alongside other on-site habitat provision and enhancement, through the retention of woodland habitats, enhancement of the setting of Spittle Brook, strengthening of hedgerow along the site frontages, and the creation of wildflower meadows around SuDS features which are tolerant to wetter conditions. Low-lying areas of the site would allow for the creation of wetland habitats to enhance the setting of the development and to provide net gains in biodiversity. In addition, the large arable field to the south of the Site provides a wide range of opportunities for good quality habitat creation.

Form ID: 83471
Respondent: Bellway Homes (West Midlands)
Agent: Cerda Planning

Issue C7: Adapting to higher Temperatures C7b: We do not believe that a policy requiring new developments to incorporate measures to adapt to higher temperatures are necessary, particularly within Part 1 of the Plan. We consider that such measures are most likely to occur through the market in time, if required. If it were to become part of a policy requirement, we would expect that viability would be taken into account. Such measures should be carefully considered to ensure that they do not stifle the provision of much needed dwellings across the District. Issue C8: Adapting to flood and drought events Option C8b: We consider that there is no requirement to have a specific policy to incorporate measures to adapt to flood and drought events. This would be a duplication of Building Regulations which are being updated regularly to manage flood risk and water consumption. 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 C9: Mitigating Biodiversity Loss Q-C91a. The Environment Act 2021 requires all planning permissions in England to deliver at least 10% biodiversity net gain (date yet to be confirmed) but expected to be November 2023. The NPPF already encourages BNG and most developers accept that their proposals will need to take account of it. Most new local plans are including specific policies dealing with biodiversity loss and gain. Any policy should be consistent with national policy and subject to thorough evidence testing and consulted upon as the Plan progresses, in particular if the target is for greater than 10% BNG.

Form ID: 83593
Respondent: Sharba Homes
Agent: Barton Willmore

Q-C8: Please select the option which is most appropriate for South Warwickshire Option C.8b – Do not include a policy that goes beyond existing building regulations, requiring new development and changes to existing buildings to incorporate measures to adapt to flood and drought events. Building regulations requirements are updated and enforced separately from planning policies and may change a number of times during the anticipated plan period, often with transitional arrangements where necessary. This ensures the development industry is able to take account and adapt to these requirements.

Form ID: 83623
Respondent: Sharba Homes
Agent: Barton Willmore

Q-C8: Please select the option which is most appropriate for South Warwickshire Option C.8b – Do not include a policy that goes beyond existing building regulations, requiring new development and changes to existing buildings to incorporate measures to adapt to flood and drought events. Building regulations requirements are updated and enforced separately from planning policies and may change a number of times during the anticipated plan period, often with transitional arrangements where necessary. This ensures the development industry is able to take account and adapt to these requirements. Q-C9.1: Please select the option which is most appropriate for South Warwickshire None of these. The Environmental Act requires a development to achieve 10% net gain and we consider that it reasonable and appropriate for policies in the SWLP to reflect this legal requirement.

Form ID: 83669
Respondent: Adam Corney
Agent: The Tyler Parkes Partnership Ltd

Q-C9.1: Should be aligned with the national approach

Form ID: 83791
Respondent: Stephen Bolton

7.3 Climate responsive development design The two opening paragraphs set the scene quite well and are seriously ambitious. What is clear is that the 4 existing policies from Stratford and Warwick that follow will not deliver the aspirations of what needs to be done NOW. The comments on BREEAM that are made earlier in this submission apply. BREEAM is good to have and will help deliver a better Climate response – however BREEAM Good and Very Good are inadequate and BREEAM MUST be included in the design to achieve the highest category available at the time of the final publication of the SWLP. To emphasise an earlier point - all current BREEAM categories will not deliver true net zero carbon. Issue C7: Adapting to higher temperatures Table 14 – The cooling Hierarchy. The four points require modification and updating. There is no mention of MVHR (mechanical ventilation with heat recovery). This is ESSENTIAL for true net zero carbon buildings and on all buildings new or existing where the air tightness is less than 3 cubic metres per square metre of internal surface area of the building m3 at 50Pa. The notation is 3m3/(h·m2)@50Pa. The reason for this is in relation to the health and wellbeing of the occupants. A definition for `MVHR should be added to the Glossary. The section needs to add specific details about the size and orientation of windows. Windows should also be triple glazed. Specific comments referring to the numbered items in the table on page 131: 1 The sentence here is wrong - ‘Such ventilation should be able to preserve air tightness in cold weather” Closing ventilation will adversely affect the indoor air quality. For example, in Scotland all new housing must have CO2 monitors in bedrooms. This should also apply to schools. 2 This should be MVHR 3 Again this should be MVHR 4 All building ventilation to have MVHR. The mistake that has been made in developing this table is that the assumption is that the airtightness will be 3 or more. The 2021 regulations have air tightness at <8m3/(h·m2)@50Pa – for true net zero carbon it needs to be at about 0.6 which is the requirement for Passivhaus certification. The paragraphs on the use of cool materials and green infrastructure are correct. Green roofs also help with flood control through attenuation of rain water (see later comment).

Form ID: 83804
Respondent: Mr Guy Hornsby

No answer given

Form ID: 83995
Respondent: Braemar Midlands Ltd
Agent: Richborough Estates

Q-C8 48. Standards concerning flooding and sustainable drainage 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-C9.1 49. Braemar is supportive of new development including appropriate green and blue infrastructure which provides for sustainable drainage and biodiversity opportunities, alongside creating a scheme where people want to live. However, any biodiversity standards for housing schemes should accord with national policy 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.

Form ID: 84000
Respondent: Individual

Issue C7: Adapting to higher temperatures Table 14 – The cooling Hierarchy. The four points require modification and updating. There is no mention of MVHR (mechanical ventilation with heat recovery). This is ESSENTIAL for true net zero carbon buildings and on all buildings new or existing where the air tightness is less than 3 cubic metres per square metre of internal surface area of the building m3. At 50Pa The notation is 3m 3/(h·m 2)@50Pa The reason for this is in relation to the health and wellbeing of the occupants. A definition for `MVHR should be added to the Glossary. Need to add specific comments on the size and orientation of windows. Windows should also be triple glazed. Specific comments referring to the numbered items in the table on page 131. 1. The sentence here is wrong - ‘Such ventilation should be cable to preserve air tightness in cold weather” Closing ventilation will adversely affect the indoor air quality. For example, in Scotland all new housing must have CO2 monitors in bedrooms. This should also apply to schools. 2. This should be MVHR 3. Again, this should be MVHR 4. All building ventilation to have MVHR. The mistake that has been made in developing this table is that the assumption is that the airtightness will be 3 or more. The 2021 regulations have air tightness at <8m 3/(h·m 2)@50Pa – for true net zero carbon it needs to be at about 0.6 which is the requirement for Passivhaus certification. The paragraphs on the use of cool materials and green infrastructure are correct. Green roofs also help with flood control through attenuation of rainwater see later comment. Issue C8 Adapting to flood and drought events. SUDS. This paragraph is fine but does not go far enough. There needs to be a policy that for existing domestic and non-domestic buildings such that SUDS MUST apply where a driveway or hardstanding is being added or replaced. Green Roofs. In continental Europe Green Roofs are used to help control storm water flooding. This is because a Green Roof will go some someway to attenuate the flow of storm water. Will there be the need before 2050 to account for the carbon footprint of water used in the manufacture of construction materials………and during the construction process? A point to consider. Reducing water consumption. Reducing to 100 litres per person per day sounds OK – However need to look at what is best practice internationally.

Form ID: 84124
Respondent: Holly Farm Business Park Ltd
Agent: The Tyler Parkes Partnership Ltd

Q-C7: Please select the option which is most appropriate for South Warwickshire Should be aligned with the national approach. Q-C8: Please select the option which is most appropriate for South Warwickshire Should be aligned with the national approach. Q-C9.1: Please select the option which is most appropriate for South Warwickshire Should be aligned with the national approach.

Form ID: 84204
Respondent: Gemma & Nick Davies

Climate responsive development is obviously needed to safeguard our housing stock for future but more importantly efforts to reduce climate change are more important. We should not just focus on adapting.

Form ID: 84274
Respondent: Federated Hermes Property Unit Trust (“Hermes”)
Agent: Lichfields (London)

Issue C8: Adapting to flood and drought events Hermes’ preference is that the Local Plan should not include a policy that goes beyond existing building regulations requiring new development and changes to existing buildings to incorporate measures to adapt to flood and drought events (option C8b). Any policy should reflect national standards/minimum requirements, which would ensure that there is a consistent approach applied.

Form ID: 84322
Respondent: Rainier Developments Limited
Agent: Pegasus Group

5.4. Rainier are supportive of the need to address net losses to biodiversity through the provision of enhancement to deliver an overall net gain. The Environment Act will require all development to provide at least a 10% Biodiversity Net Gain (BNG) increase and there would be no objection to this being carried through into a local policy. Indeed, it would reflect one of the core principles of the NPPF to conserve and enhance the natural environment. 5.5. Any such policy though, should be drafted to provide as much flexibility as possible. The test is whether the 10% BNG is delivered, not the method by which it is delivered. It is important that the way in which ‘net gains’ are calculated is given careful consideration and a pragmatic view should be taken in terms the delivery of biodiversity enhancements where there are clear landscape and habitat improvements, rather than being wholly reliant on the output of a rigid calculator, in particular where this could impede viability and thus the delivery of much needed housing. It should also allow for contributions to be made towards off-site mitigation with suitable receptor sites or projects identified through the Local Plan process to secure the deliverability of development.

Form ID: 84336
Respondent: Liberal Democrat Group (Stratford District councillors)

Energy efficiency, renewables, resources and Infrastructure Although national building regulations do not currently require new homes to be zero carbon, councils are permitted to set their own local planning requirements that do demand zero carbon [1]. Noting the overarching principles intended, this standard would be appropriate for inclusion in the plan. Provision of energy, water, sewage, roads and transport is challenging in this area. A mix of renewable energy types, particularly those that are community inspired schemes and community beneficial should be supported. However we additionally comment that lower wind speeds from the NOABL[2] wind speed database and other mapping sources mitigate against large scale wind turbines in central England. This does not preclude farm scale individual masts serving local demand. Wind turbines in towns have been shown to be ineffective[3] .

Form ID: 84369
Respondent: Warwickshire County Council [Learning and Achievement]

Q-C7: The Plan should be ambitious in its thinking; hence we should look for Option C7a. Q-C8: The Plan should be ambitious in its thinking; hence we should look for Option C8a.

Form ID: 84446
Respondent: Mr Jonathan Burrows

Ensure developers adhere to original agreements; don't give in to their excuses not to; prevent developers doing unnecessary green space covering, or tree cover or spinney clearances.

Form ID: 84516
Respondent: Mactaggart & Mickel
Agent: McLoughlin Planning

Q-C8: The Respondent is generally supportive of the management and use of water within new developments and already seeks to incorporate SUDS in its schemes where it is feasible to do so. Furthermore, the Respondent has no in principle objection to the implementation of measures to reduce water consumption, however, they would not currently support a policy which goes beyond existing Building Regulations. Q-C9.1: The Respondent is generally supportive of incorporating measures to increase biodiversity within new developments and notes that the need to provide 10% Biodiversity Net Gain (BNG) is soon to become mandatory under the Environment Act 2021. In light of which the need for an additional policy is unclear. The introduction of any policy that has the potential to affect the viability and delivery of sites needs to be cautiously considered, with overly prescriptive requirements (such as limitations on the amount of hard landscaping that can be used within sites etc.) avoided. In the Respondent’s view, suggestions regarding how a development might go about achieving biodiversity increases on site should be set out in supporting text and not directly in policy wording to reflect best practice rather than a strict policy requirement. While the delivery of on-site BNG may be preferred, the ability to deliver off-site BNG should not be ruled out, since there will be sites where BNG on site is not achievable. In this regard it is imperative that the SWLP provides an appropriate mechanism for offsetting when it is simply impractical to provide the level of net gain by any calculator being adopted by Natural England. For the avoidance of doubt, the Respondent would have significant objections if the level of BNG required in South Warwickshire were to extend beyond the 10% required in line with the provisions of the Environment Act 2021.

File: Vision
Form ID: 84551
Respondent: Lockley Homes
Agent: Goldfinch Town Planning Services (West Midlands)

Q-C7: Lockley Homes would select Question C7c. Whilst we support the principles behind the emerging policy approach and the need to incorporate climate change mitigation features within new buildings, incorporating these types of features can significantly increase the financial build costs for new build residential schemes, at a time when the house building construction industry is already experiencing an unprecedented rapid increase in both materials and labour costs. We would advise that a pre-cautionary policy approach is therefore taken by the LPA’s in relation to this issue, to help the emerging Plan to respond effictively to paragraphs 31 and 82 (indent d) of the Revised NPPF (2021). These issues already considered in our wider SWLP Representations Statement (March 2023). Lockley Homes is promoting a proposed new housing development site through the Council’s emerging SWLP Review which is coming forward within a sustainably-located infill site, within an area of under-utilised land, which forms very low quality fully restricted public access green space. The Sustainability credentials of this site are already discussed in detail within this wider SWLP Representations Statement (March 2023). The site in question is located within the Village of Broom settlement within the western part of the Stratford-on-Avon District, immediately bordering a vast, open prairie style, severely ecologically damaged and heavily eroded rural landscape. Which has suffered from many years of successive intensive farming practices, which has resulted in the widespread removal of hedgerow networks over a number of years on a huge ‘landscape-scale’ across considerable areas of South Warwickshire open lowland countryside. It has also resulted in the blanket removal of mature veteran and ancient deciduous trees across considerable expanses of countryside, due to the extensive hedgerow clearance works described above. The severe shortage of existing tree cover due to blanket tree removal within large expanses of the farmland landscape to the north of the Lockley Homes proposal site is supported by robust and defendable up-to-date photographic evidence in Photograph 2 (Appendix B of this Representations Statement). Lockley Homes is proposing to introduce new tree planting measures using suitable native tree species (see Appendix C of this Representations Statement) which would help to promote increased shade cover and promote natural cooling within the Village of Broom settlement. As well as provide habitats to support biodiversity. New tree planting is critical to help rural areas adapt to higher summer temperatures. Particularly those rural countryside locations which have suffered from the intensive farming practices described further above. Given the very limited existing tree cover present within adjoining open countryside for reasons explained above, there is a considerable opportunity for a new future high-quality residential scheme coming forward for this site to introduce significant new tree planting measures within rear residential garden spaces and within on-site landscaping screening buffer strips, using suitable native tree species to help support biodiversity. This would help introduce increased cooling measures through new tree planting (tree canopy shade cover, and natural cooling through evapotranspiration), as well as deliver net gains for biodiversity within a severely ecologically damaged rural landscape. The inclusion of this site as a new housing site allocation on the main Policies Map of the Council’s emerging SWLP Review would therefore be supported by Biodiversity Net Gain (BNG) focused guidance as set out in paragraphs 8 (indent c), 120 (indent a), 174 (indent d), 179 (indent b) and 180 (indent d) of the Revised NPPF (2021). The proposals would also be supported by climate change focused guidance set out within paragraphs 153 and 154 of the Revised NPPF (2021). Paragraph 153 of the Revised NPPF (2021) is clear that: “… Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for … biodiversity and landscapes, and the risk of overheating from rising temperatures…” Given the above issues, the benefits of supporting new housing developments proposals coming forward within intensively farmed landscapes which are proposing to include new greening/ tree planting measures, should be given increased prominence within the SWLP proposed policy approach. These types of new housing development proposals should be strongly supported within the emerging SWLP Review (2023), given that they can play a crucial role in helping rural areas adapt to higher summer temperatures for the reasons explained above. Q-C9.2: Lockley Homes is a developer of very high-quality new luxury homes, and as a developer we take our environmental responsibility very seriously, and where opportunities exist, we are keen to support biodiversity where possible within our new-build residential development schemes. Lockley Homes considers that it is possible to provide compensatory measures to help provide new wildlife habitat features/ habitat enhancements to help deliver net gains for biodiversity, within high quality new build residential schemes. Consistent with guidance in paragraphs 8 (indent c), 120 (indent a), 174 (indent d), 179 (indent b) and 180 (indent d) of the Revised NPPF (2021). Lockley Homes maintains its view that this is particularly possible and relevant when progressing new build housing development schemes coming forward on low-quality green space sites. Such as under-utilised, low-quality former horse grazing paddock land, and for site locations coming forward within areas of severely ecologically damaged open countryside. Which have suffered from considerable and constant ecological damage, as a direct result of years of uncontrolled mechanized industrial-scale intensive farming practices. Which has resulted in the widescale removal of features from the rural landscape, which would have previously provided important and highly beneficial wildlife habitats. For example, such as farmland wildlife ponds and other wetland habitat features, extensive hedgerow networks previously crossing large-expanses of farmland, removal of veteran and ancient trees within hedgerow networks due to widespread hedgerow destruction. Loss of wild flower hedgerow field margins, small woodland copses, wildflower meadows, etc. These issues are considered in further detail within Appendix C of this Representations Statement (2023). Ecologically damaged areas of sterile monoculture intensive farmland, within open countryside locations, such as ecologically damaged pasture fields and arable farmland, in particular, provide an excellent example, and significant opportunity where beneficial wildlife habitats can be delivered. To help re-introduce threatened wildlife habitat features, that have already been lost at an alarming rate from the British lowland countryside - due to years of damaging intensive farming practices as discussed above. In our view, this can help to deliver significant nature conservation enhancements and compensatory measures, to help support Biodiversity Net Gain (BNG). By providing habitats to support populations of severely declining and threatened wildlife species - consistent with approach expected by paragraphs 8 (indent c), 120 (indent a), 174 (indent d), 179 (indent b) and 180 (indent d) of the Revised NPPF (2021). In our view, the focus should be on replacing those threatened wildlife habitat features that have suffered particular high levels of extensive decline, and are considered to be particularly endangered, and vulnerable within the British lowland countryside - due to intensive farming practices. Most notably, this involves the replacement and re-introduction of Priority Wildlife Habitats within the countryside (priority habitats are classed as particularly vulnerable and scarce). A good example of a priority wildlife habitat type that has experienced significant rapid decline within South Warwickshire and the wider British lowland countryside, is farmland wildlife ponds. Therefore, the introduction of small wildlife garden ponds within new housing development site layouts, provides an excellent, robust and defendable example of a type of ecologically important, and significantly declining priority wildlife habitat feature, that can be easily replicated and incorporated into new residential site layouts. Within rear residential garden spaces and as part of small Sustainable Urban Drainage (SUDS) wetland ponds delivered in on-site natural green space landscaping buffer strips. Including these features has a particularly strong level of planning policy support when assessed against guidance in paragraph 179 (indent b) of the Revised NPPF (2021). Which confirms that plans should “…promote the conservation, restoration and enhancement of priority habitats…” Farmland wildlife ponds are now a priority habitat type given their increasing rarity and widespread decline within the British lowland countryside. Lockley Homes are promoting a sustainably located potential new housing development site through the emerging SWLP (2023). The site in question is located within the northern edge of the Village of Broom settlement boundary, immediately north of Mill Lane. The site is located within the civil parish of Bidford-on-Avon, within the western part of the Stratford-on-Avon District. The site in question is located on very low-quality green space (former paddock land), which has suffered from years of horse over-grazing, which has resulted in very poor and damaging grassland habitat management. The site subsequently has no nature conservation interest. On its northern site boundary, the proposal site immediately borders an area of ‘severely depleted and heavily ecologically damaged’ open countryside, which has suffered from years of uncontrolled intensive farming practices. Which has resulted in the extensive loss of a wide range of wildlife habitat features from the adjacent rural farmland landscape. Including the removal of miles of hedgerow networks due to the expansion of arable farmland and pasture fields, loss of mature veteran trees from hedgerow networks due to widespread hedgerow destruction on a vast scale, loss of hedgerow field margins. The draining of farmland wildlife ponds and other wetland habitat features. Blanket tree removal across large expanses of countryside, etc. The above issues are supported by robust, up-to-date and defendable photographic evidence in Photograph 2 within Appendix B of this Representations Statement document (2023). Particularly evident is the blanket removal of mature trees and hedgerow networks. Given the above issues, and for the reasons explained above and in more detail within Appendix B of this Representations Statement, Lockley Homes considers that Issue C9: (Mitigating Biodiversity loss) should increasingly recognise the important role that high quality new residential development proposals can play in helping to support the policy objectives of Issue C9. Lockley Homes maintains its view that it has a sustainably located site suitable for new housing development located within an existing village settlement boundary. Given the very strong, clear and compelling sustainability credentials of the site as already evidenced in our Representations, we consider that this site (within the Village of Broom settlement boundary) should be prioritised for future development and included without delay as a new housing site allocation on the main Policies Map of the Council’s emerging South Warwickshire Local Plan (SWLP). Allocating this site for new housing development would help to meet the policy objectives of Issue C9: ‘Mitigating Biodiversity Loss’ for the reasons explained above and within Appendix B of this Representations Statement (2023).

Form ID: 84592
Respondent: Lou and Scott Henney

Climate responsive development is obviously needed to safeguard our housing stock for future but more importantly efforts to reduce climate change are more important. We should not just focus on adapting.

Form ID: 84626
Respondent: Rainier Developments Limited
Agent: Pegasus Group

Q-C9.1: Please select the option which is most appropriate for South Warwickshire 5.4. Rainier are supportive of the need to address net losses to biodiversity through the provision of enhancement to deliver an overall net gain. The Environment Act will require all development to provide at least a 10% Biodiversity Net Gain (BNG) increase and there would be no objection to this being carried through into a local policy. Indeed, it would reflect one of the core principles of the NPPF to conserve and enhance the natural environment. 5.5. Any such policy though, should be drafted to provide as much flexibility as possible. The test is whether the 10% BNG is delivered, not the method by which it is delivered. It is important that the way in which ‘net gains’ are calculated is given careful consideration and a pragmatic view should be taken in terms the delivery of biodiversity enhancements where there are clear landscape and habitat improvements, rather than being wholly reliant on the output of a rigid calculator, in particular where this could impede viability and thus the delivery of much needed housing. It should also allow for contributions to be made towards off-site mitigation with suitable receptor sites or projects identified through the Local Plan process to secure the deliverability of development.

Form ID: 84669
Respondent: L&Q Estates
Agent: Mr Will Whitelock

Q-C9.1: Please select the option which is most appropriate for South Warwickshire NPPF Paragraph 32 advises that local plans should address relevant environmental objectives, including opportunities for net gains. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered). Further, Paragraph 174 advises that planning policies and decisions should contribute to and enhance the natural and local environment by minimising impacts on and providing net gains for biodiversity, including establishing coherent ecological network that are more resilient to current and future pressures. L&Q Estates are supportive of Option C9.1a: Include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity. The Site will seek to deliver a minimum 10% in biodiversity net gain, alongside other on-site habitat provision and enhancement, through the retention and enhancement of existing hedgerow within the site and supplementary planting to diversify the species mix,creation of natural areas surrounding the edge of the site to include wildflower meadow, scrub, tree and copse planting, in addition to the inclusion of sustainable drainage features comprising attenuation ponds, rain gardens and swales that are designed for ecological benefit.

Form ID: 84743
Respondent: Rainier Developments Limited
Agent: Pegasus Group

Q-C9.1: Please select the option which is most appropriate for South Warwickshire 5.4. Rainier are supportive of the need to address net losses to biodiversity through the provision of enhancement to deliver an overall net gain. The Environment Act will require all development to provide at least a 10% Biodiversity Net Gain (BNG) increase and there would be no objection to this being carried through into a local policy. Indeed, it would reflect one of the core principles of the NPPF to conserve and enhance the natural environment. 5.5. Any such policy though, should be drafted to provide as much flexibility as possible. The test is whether the 10% BNG is delivered, not the method by which it is delivered. It is important that the way in which ‘net gains’ are calculated is given careful consideration and a pragmatic view should be taken in terms the delivery of biodiversity enhancements where there are clear landscape and habitat improvements, rather than being wholly reliant on the output of a rigid calculator, in particular where this could impede viability and thus the delivery of much needed housing. It should also allow for contributions to be made towards off-site mitigation with suitable receptor sites or projects identified through the Local Plan process to secure the deliverability of development.

Form ID: 84763
Respondent: Rainier Developments Limited
Agent: Pegasus Group

Q-C9.1: Please select the option which is most appropriate for South Warwickshire 5.4. Rainier are supportive of the need to address net losses to biodiversity through the provision of enhancement to deliver an overall net gain. The Environment Act will require all development to provide at least a 10% Biodiversity Net Gain (BNG) increase and there would be no objection to this being carried through into a local policy. Indeed, it would reflect one of the core principles of the NPPF to conserve and enhance the natural environment. 5.5. Any such policy though, should be drafted to provide as much flexibility as possible. The test is whether the 10% BNG is delivered, not the method by which it is delivered. It is important that the way in which ‘net gains’ are calculated is given careful consideration and a pragmatic view should be taken in terms the delivery of biodiversity enhancements where there are clear landscape and habitat improvements, rather than being wholly reliant on the output of a rigid calculator, in particular where this could impede viability and thus the delivery of much needed housing. It should also allow for contributions to be made towards off-site mitigation with suitable receptor sites or projects identified through the Local Plan process to secure the deliverability of development.

Form ID: 84845
Respondent: Rainier Developments Limited
Agent: Pegasus Group

Q-C9.1: Please select the option which is most appropriate for South Warwickshire 5.4. Rainier are supportive of the need to address net losses to biodiversity through the provision of enhancement to deliver an overall net gain. The Environment Act will require all development to provide at least a 10% Biodiversity Net Gain (BNG) increase and there would be no objection to this being carried through into a local policy. Indeed, it would reflect one of the core principles of the NPPF to conserve and enhance the natural environment. 5.5. Any such policy though, should be drafted to provide as much flexibility as possible. The test is whether the 10% BNG is delivered, not the method by which it is delivered. It is important that the way in which ‘net gains’ are calculated is given careful consideration and a pragmatic view should be taken in terms the delivery of biodiversity enhancements where there are clear landscape and habitat improvements, rather than being wholly reliant on the output of a rigid calculator, in particular where this could impede viability and thus the delivery of much needed housing. It should also allow for contributions to be made towards off-site mitigation with suitable receptor sites or projects identified through the Local Plan process to secure the deliverability of development.

Form ID: 84866
Respondent: Rainier Developments Limited
Agent: Pegasus Group

Q-C9.1: Please select the option which is most appropriate for South Warwickshire 5.4. Rainier are supportive of the need to address net losses to biodiversity through the provision of enhancement to deliver an overall net gain. The Environment Act will require all development to provide at least a 10% Biodiversity Net Gain (BNG) increase and there would be no objection to this being carried through into a local policy. Indeed, it would reflect one of the core principles of the NPPF to conserve and enhance the natural environment. 5.5. Any such policy though, should be drafted to provide as much flexibility as possible. The test is whether the 10% BNG is delivered, not the method by which it is delivered. It is important that the way in which ‘net gains’ are calculated is given careful consideration and a pragmatic view should be taken in terms the delivery of biodiversity enhancements where there are clear landscape and habitat improvements, rather than being wholly reliant on the output of a rigid calculator, in particular where this could impede viability and thus the delivery of much needed housing. It should also allow for contributions to be made towards off-site mitigation with suitable receptor sites or projects identified through the Local Plan process to secure the deliverability of development.

Form ID: 84891
Respondent: Corbally Group (Harbury) Ltd
Agent: Pegasus Group

Q-C9.1: Corbally Group are supportive of the need to address net losses to biodiversity through the provision of enhancement to deliver an overall net gain. The Environment Act will require all development to provide at least a 10% Biodiversity Net Gain (BNG) increase and there would be no objection to this being carried through into a local policy. Indeed, it would reflect one of the core principles of the NPPF to conserve and enhance the natural environment. 5.5. Any such policy though, should be drafted to provide as much flexibility as possible. The test is whether the 10% BNG is delivered, not the method by which it is delivered. It is important that the way in which ‘net gains’ are calculated is given careful consideration and a pragmatic view should be taken in terms the delivery of biodiversity enhancements where there are clear landscape and habitat improvements, rather than being wholly reliant on the output of a rigid calculator, in particular where this could impede viability and thus the delivery of much needed housing. It should also allow for contributions to be made towards off-site mitigation with suitable receptor sites or projects identified through the Local Plan process to secure the deliverability of development.

Form ID: 84913
Respondent: Lone Star Land Ltd
Agent: Pegasus Group

Q-C9.1: Please select the option which is most appropriate for South Warwickshire Lone Star Land Ltd. are supportive of the need to address net losses to biodiversity through the provision of enhancement to deliver an overall net gain. The Environment Act will require all development to provide at least a 10% Biodiversity Net Gain (BNG) increase and there would be no objection to this being carried through into a local policy. Indeed, it would reflect one of the core principles of the NPPF to conserve and enhance the natural environment. Any such policy though, should be drafted to provide as much flexibility as possible. The test is whether the 10% BNG is delivered, not the method by which it is delivered. It is important that the way in which ‘net gains’ are calculated is given careful consideration and a pragmatic view should be taken in terms of the delivery of biodiversity enhancements. It is considered from a biodiversity net gain perspective, development proposals within a new settlement provides greater opportunities for BNG on site. Furthermore, BNG within a development of a strategic scale would be able to ensure the vitality of habitats and/or landscapes.

Form ID: 84975
Respondent: Summers Holdings Ltd
Agent: The Tyler Parkes Partnership Ltd

Q-C7: Should be aligned with the national approach. Q-C8: Should be aligned with the national approach. Q-C9.1: Should be aligned with the national approach.

Form ID: 85007
Respondent: Dr Nicola Sawle

Climate responsive development is obviously needed to safeguard our housing stock for future but more importantly efforts to reduce climate change are more important. We should not just focus on adapting.

Form ID: 85073
Respondent: Mr Nigel Holdsworth
Agent: The Tyler Parkes Partnership Ltd

Q-C7: Should be aligned with the national approach. Q-C8: Should be aligned with the national approach. Q-C9.1: Should be aligned with the national approach.