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

Showing forms 181 to 194 of 194
Form ID: 85189
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: 85244
Respondent: David Wilson Homes
Agent: Harris Lamb

It is not necessary for a SWLP to include a policy requiring new developments to incorporate measures to increase biodiversity. In November of this year it will be a statutory requirement for all development proposals to demonstrate 10% biodiversity net gain. As this is set out in the Act it does not need to be repeated in policy.

File: Map
Form ID: 85279
Respondent: David Wilson Homes
Agent: Harris Lamb

Q-C9.1 – Please select a biodiversity option which is most appropriate for South Warwickshire Option C9.1b: Do not include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity It is not necessary for a SWLP to include a policy requiring new developments to incorporate measures to increase biodiversity. In November of this year it will be a statutory requirement for all development proposals to demonstrate 10% biodiversity net gain. As this is set out in the Act it does not need to be repeated in policy.

Form ID: 85329
Respondent: David Wilson Homes
Agent: Harris Lamb

Q-C9.1 – Please select a biodiversity option which is most appropriate for South Warwickshire Option C9.1b: Do not include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity It is not necessary for a SWLP to include a policy requiring new developments to incorporate measures to increase biodiversity. In November of this year it will be a statutory requirement for all development proposals to demonstrate 10% biodiversity net gain. As this is set out in the Act it does not need to be repeated in policy.

Form ID: 85387
Respondent: Church Commissioners for England (‘The Church Commissioners’)
Agent: Barton Willmore (now Stantec)

Q-C7: Please select the option which is most appropriate for South Warwickshire The Church Commissioners submits that the Councils should not include a requirement for development to accommodate measures to adapt to higher temperatures (Option C7c). Instead, this issue should be left to Building Regulations. Issue C8: Adapting to Flood and Drought Events Q-C8: Please select the option which is most appropriate for South Warwickshire Option C8b should be followed, where a policy is not included that goes beyond Building Regulations. 5.13 At present, Stratford’s Core Strategy has Policy relating to SUDs, stating that all development proposals to control and discharge 100% of runoff into SUDs, which is consistent with Policy FW2 of Warwick’s Local Plan. Whilst Stratford doesn’t currently have a policy requirement with regards water consumption, there is reference to minimising water consumption, and Warwick’s Local Plan stipulates specific requirements for water efficiency standards of 110 litres per person, per day for residential developments. Furthermore, whilst the above presents a number of Options, wording identified within Issue C8 states that consideration could be given to decreasing the requirement to 100 litres or lower per person, per day which isn’t included within the Options. 5.14 As the two local authorities have current policies in relation to SUDs provision, and Warwick has water efficiency requirements, it would be appropriate and consistent to pursue this within the South Warwickshire Local Plan. However, any specific water efficiency requirements should be tested via evidence and viability assessments completed, to ensure the Policy is realistic, achievable and deliverable.

Form ID: 85517
Respondent: Rowington Parish Council

QC7 The Parish Council does not have the expertise to enable it to respond.

Form ID: 85555
Respondent: St. Modwen
Agent: Copperfield Land and Planning Land Limited

4 Issue C7 – Adapting to High Temperatures 5.24.1 St. Modwen support a policy that requires new developments to respond to the impacts of higher temperatures. Many local authorities already require developments to provide carbon/energy assessments that would typically include a review of assessments outlined in the cooling hierarchy. Therefore, we think it would be appropriate for the Plan to include a policy that requires new developments and changes to existing buildings to incorporate measures to adapt to higher temperatures. Issue C9 – Mitigating Biodiversity Loss 5.25.1 St. Modwen support a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity. We would comment that a fixed target with no flexibility could significantly limit opportunities for some plots, therefore it may be worth having some flexibility within the target to allow for offset measures or a proportionate response.

Form ID: 85568
Respondent: Warwickshire County Council

Q-C9.1: Option C9.1a: Include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity In principle this is a welcome addition to policy, in order to enhance biodiversity opportunities. However, consideration should be given to avoiding conflict with mechanisms for biodiversity offset and natural capital.

Form ID: 85587
Respondent: Severn Trent

Severn Trent is supportive of climate responsive development design which supports ambitious water efficiency targets and flood resilience. It is important that all new developments are designed in accordance with the drainage hierarchy, and where possible existing dwellings are encouraged to minimise any existing surface water connections to the foul/combined sewer network. We are supportive of the inclusion of existing dwellings in policy wording, as betterment of existing surface water connections and water consumption could free capacity in the existing network from flows from new development. This could reduce the need for carbon intensive and costly improvements to the sewer network and wastewater treatment works.

Form ID: 85655
Respondent: Taylor Wimpey
Agent: Turley

Question C9.1: Option C9.1a is the most appropriate option for South Warwickshire and is in accordance with paragraphs 177d and 182b of the NPPF which seek to secure biodiversity net gain via plan-making. 3.54 However, any planning policy requiring new development to incorporate measures to increase biodiversity should be flexible and adhere to the PPG [Paragraph 022 Reference ID: 8-022-20190721] which states, “biodiversity net gain can be achieved onsite, off-site or through a combination of on-site and off-site measures”. 3.55 It is recommended WDC and SOADC work with Warwickshire County Council (WCC) to identify ‘habitat banks’ i.e. areas of enhanced or created habitats which generate biodiversity credits. This will support strategic sites that are unable to deliver net gain wholly on site.

Form ID: 85686
Respondent: St Joseph Homes Limited

Option C9.1a: Include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity Paragraph 179 of the NPPF outlines that planning policies and decisions should protect and enhance biodiversity. The Council’s approach to biodiversity net gain should align with the Governments proposals as set out in the Environment Bill. The Government believe that a 10% net biodiversity gain is acceptable. As part of Berkeley’s 2030 vision a 10% net biodiversity gain is a requirement across all of our sites. St Joseph are achieving this, with an average net biodiversity gain of 56% across the company, with Swan’s Landing is set to achieve 94% across the site. Berkeley Group have a strong focus across all of their development across England, including Swan’s Landing in Stratford-upon-Avon, to deliver sites that deliver new habitats. Swan’s Landing seeks to provide bird and bat boxes contained within houses and apartment buildings, as well as hedgehog highways within every garden. Green infrastructure is also provided throughout the scheme, including SUDs basin. It should be noted that in plan making, viability is key to housing delivery, and the costs associated with biodiversity gain may be significant. The viability of producing a positive net biodiversity gain of 10% across all sites should be assessed by the Council on an individual basis to not limit or prevent housing delivery. We believe that a 10% gain is achievable for most developers and that it should be pushed for major developments, to fulfil the guidance set out within the NPPF, and accord with the Government’s Environment Bill.

Form ID: 85704
Respondent: Caddick Land
Agent: Barton Willmore (now Stantec)

Q-C7: 1 Caddick Land submits that the Councils should not include a requirement for development to accommodate measures to adapt to higher temperatures (Option C7c). Instead, this issue should be left to Building Regulations. Q-C8: Option C8b should be followed, where a policy is not included that goes beyond Building Regulations. 5.13 At present, Stratford’s Core Strategy has Policy relating to SUDs, stating that all development proposals to control and discharge 100% of runoff into SUDs, which is consistent with Policy FW2 of Warwick’s Local Plan. Whilst Stratford doesn’t currently have a policy requirement with regards water consumption, there is reference to minimising water consumption, and Warwick’s Local Plan stipulates specific requirements for water efficiency standards of 110 litres per person, per day for residential developments. Furthermore, whilst the above presents a number of Options, wording identified within Issue C8 states that consideration could be given to decreasing the requirement to 100 litres or lower per person, per day which isn’t included within the Options. 5.14 As the two local authorities have current policies in relation to SUDs provision, and Warwick has water efficiency requirements, it would be appropriate and consistent to pursue this within the South Warwickshire Local Plan. However, any specific water efficiency requirements should be tested via evidence and viability assessments completed, to ensure the Policy is realistic, achievable and deliverable. Q-C9.1: The Environmental Act 2021 sets out a requirement for developments to achieve a Biodiversity Net Gain of 10%. Consequently, there is no need for a separate policy to incorporate measures to increase biodiversity, as all developments will be subject to this statutory requirement, as of November 2023. Therefore, Caddick Land believes that Option C9.1b is the most appropriate Option. However, if the Council want to introduce a separate policy that requires a greater figure than this, they must demonstrate evidence to show this is needed and that it has been viability tested. This will ensure the policy is clearly written and is deliverable, achieving sustainable development, opposed to creating a barrier to development. Furthermore, the Council should consider and include mitigation options within their policy, making reference to off-site delivery if there is no other feasible or viable option on site, and allowing developers to pay a financial offsetting payment.

Form ID: 85769
Respondent: North Warwickshire Borough Council

Q-C7: Please select the option which is most appropriate for South Warwickshire NWBC Response – Improved building regulations (national) would be a better more proactive approach to addressing the issue and viability may be an issue. Improved insulation may also be a method of addressing the issue and the Plan can ‘encourage’ improvements to design, but to include requirements within Policy will require evidence/justification for an approach specific to South Warwickshire Plan area, until National Building Regs are revised. No further comments. Q-C9.1: Please select the option which is most appropriate for South Warwickshire NWBC Response – Preference towards option C9.1a, but there may be site/development circumstances where it is difficult to have less than 50% of the wider site to consist of paved/hard surfaced areas, particularly in urban or pdl situations. No further comments.

Form ID: 85848
Respondent: Barratt David Wilson Homes (Mercia)
Agent: Knight Frank LLP

Q-C7: The preferred option should be determined with reference to a robust evidence base, including in relation to the viability. More evidence is required. Q-C9.1: Option C9.1b is appropriate as new legislation will deal with this matter. Q-C9.2: As reflected in the previous Knight Frank response (ref. 2102), there is a clear emphasis on climate change adaptation and mitigation set out in the Planning Act 2008 and further commitments set out in the Net Zero Strategy: Build Back Greener (October 2021), which should be reflected in the council’s planning policies without duplicating existing requirements or introducing additional or onerous measures that adversely affect the viability of development proposals. The councils should also consider Part L Buildings Regulations when developing policies, to ensure that developments are not overburdened with additional measures that go beyond the requirements of national policy, regulations and guidance. Any policies relating to climate responsive design should be based upon a proportionate evidence base to be found ‘sound’, including an assessment of their impacts upon viability for individual sites and on a whole-plan basis to ensure other policies are not adversely affected.