Preferred Option: Achieving Sustainable Buildings

These requirements do not go nearly far enough. It is far more cost effective to make new buildings as close to carbon neutral as possible, than to "retrofit" technologies.

These proposals are a polite nod in the direction of sustainability.

PO12 describes the need to adopt 'a policy of requiring a 20% reduction in carbon emissions in all significant developments' and 'requiring that new development is designed to adapt to the future impacts of climate change'.
Due to the lack of facilities in, poor public transport to, and lack of cycle access to Norton Lindsey, the building of more houses in the village would result in a significant increase in car journeys to and from the village. This would increase carbon emissions and have a negative future impact on climate change.
Thus, Norton Lindsey does not meet the requirements of PO12.

A 25% reduction by 2027 would be welcomed (12.13). However, To achieve an overall 25% reduction by 2027, new developments (with all the opportunities of new build), will need to contribute more than a 20% reduction.

Any new developments should be made to be as carbon neutral as possible and should include the maximun energy savings acheivable. This should include consideration of energy supply and generation, proper casemnts for windows and insulation levels

We consider that PO12: Climate Change should be updated to accord with the provisions of the NPPF. At para 95 the Government advises in the Framework that when setting any local requirement for a building's sustainability, local authorities should do so in a way that is "... consistent with the Government's zero carbon buildings policy and adopt nationally prescribed standards.". The proposed preferred option - which includes the requirement for a 20% carbon reduction via renewable and low carbon technologies - is not seen as consistent with the Government's zero carbon buildings policy or nationally prescribed standards.

It is at the national level, via on-going revisions to Part L of Building Regulations, that the Government is implementing its zero carbon buildings policy. These revisions to Building Regulations necessitate higher standards of energy performance in dwellings and the use of on-site renewable and low carbon energy. Future changes are expected to include a mechanism for off-site carbon reduction measures called 'allowable solutions'. Building Regulations are therefore the primary driver for the use of renewable and low carbon energy and so we recommend removing the 20% carbon reduction target proposed for the Local Plan.

Warwick Local Plan - Preferred Options Consultation
Response on behalf of Taylor Wimpey's Land Interests in Barford
We act on behalf of Taylor Wimpey plc, who have a land interest in Barford. A copy of the site plan is appended to these representations. Below we set out a response to a number of draft policies contained in the Preferred Options document (May 2012).
PO3: Broad Location of Growth
Taylor Wimpey support the Council's Preferred Option as set out in draft Policy PO3 which includes the distribution of some housing growth across the District, including land within and/or on the edge of some villages. Furthermore support is given to the proposal for a hierarchy of growth in those villages with a broad range of services and public transport to the towns.
Taylor Wimpey have land interests in Barford, and consider that this could deliver upto 60 new homes in a location that is considered to be sustainable for this scale of development.
We consider that the Council's proposed approach to housing delivery, as set out in draft Policy PO3, accords with the requirements set out in paragraph 47 of the NPPF which encourages Local Planning Authorities to significantly boost the supply of housing through a number of means. The support for providing new homes through extensions to existing villages is also encouraged by the NPPF (paragraph 52).
PO4: Distribution of Sites for Housing
Taylor Wimpey supports the proposal for Category 1 villages, including Barford, to provide 100 dwellings. However, we consider, specifically in respect of Barford, that where sites, in addition to Taylor Wimpey's site at Land off Wellesbourne Road, are identified as being suitable and deliverable for residential development, within and/or on the edge of the village, then Barford may be able to accommodate growth in excess of 100 dwellings. On this basis, we suggest that a dwelling range should be provided which indicates the minimum and maximum number of units the Council considers to be broadly acceptable on sites which are deliverable and developable in Barford. Whilst we understand that the 100 dwelling figure is not a maximum, it would be helpful for development management purposes to establish a figure that was considered to be the upper limit. Furthermore, if some of the Category 1 and 2 villages are unable to meet the broad targets set then other villages may need to make up the shortfall. It is suggested that an assessment of likely housing capacity in each village is required to understand what the housing capacity parameter should be.
1 August 2012
TW Warwick PO Response Letter July 2012.docx
Development Policy Manager
Warwick District Council
Riverside House
Milverton Hill
Leamington Spa
CV32 5HZ
a
Page 2
PO6: Mixed Communities & a Wide Choice of Homes
A - General Market Housing
Taylor Wimpey broadly supports the requirement for housing developments to provide a mix of house sizes and types to meet the needs identified in the SHMA. However, not all sites will be in a location or be of a size to always fully reflect the SHMA requirements in full. Therefore, it is proposed that the words "seek to" are inserted in between the words "will ensure".
PO12 : Climate Change
Taylor Wimpey notes the Council's intention to adopt a requirement that "seeks a 20% reduction in carbon emissions from development to include a contribution from renewable and low carbon technologies". Whilst the policy implies that the carbon reduction is not restricted to these technologies, Taylor Wimpey request that the policy is amended to include reference to the following:
"Where development viability supports a 20% reduction in carbon emissions, contributions to this may include reductions through supply chain and construction methods, as well as contributions from renewable and low carbon technologies".
As part of the CIL viability work, it is requested that any costs associated with a 20% reduction in carbon emissions is taken into account with all other design requirements and planning obligations such as affordable housing.
PO12 : Transport
Preferred Option: Parking
Taylor Wimpey support the proposal to review Vehicle Parking Standards supplementary planning document (2007) and specifically the intention to ensure car parking is provided within new residential developments that allows for convenient and safe parking. Taylor Wimpey would welcome the opportunity to respond to any future supplementary planning document that is prepared.
We look forward to receiving confirmation of receipt of these representations.

On behalf of Barwood Strategic Land LLP and the landowners we write in support of their
respective interests at land 'south of Gallows Hill/ west of Europa Way, Warwick'. This site is
identified in the Local Plan Preferred Options as a location for growth delivering 1,600 dwellings
in phases 2 and 3 of the plan period along with employment land, open space and community
facilities.
Land interests within the proposed allocation are also held by William Davies and Hallam Land;
it is intended that all developers and landowners will work together to secure a comprehensive
masterplanning approach to the development of this site.
We respond to the respective policy areas and chapters below:
1. Part 1: Setting the Scene and Summary
- In setting the strategy, it should be made clear the time period that the plan is proposed
to cover. For example, at 1.2, there is reference to the next 15 years and only later in
the document is confirmed that that the plan period covers 2011 to 2029.
- It is noted that paragraph 4.2 makes reference to the fact that the District could grow by
as much as 15% over the next 15 years (from a current population of 138,800) - this
represents an increase of some 20,820 residents. We highlight that the 2008 based
household projections shows growth from 62,938 households in 2011 to 77,955
households in 2029. This represents an increase of 15,557 households. The 2006
based projections showed 17,110 households over the same period. The 2010 based
population projections show very similar population growth to the 2008 based projections
and although the latter remain the most up to date, it is expected that the 2010 based
CLG household projections will be very similar.
- Paragraph 4.10 should be revised to make reference to the need to ensure that Local
Plan meets the full, objectively assessed needs for market and affordable housing as
required by the NPPF.
2. Delivering Growth - Housing / PO1: Preferred Level of Growth
- The preferred level of housing growth is proposed to be 600 dwellings per annum
(totalling 10,800 dwellings) over the plan period, which when deducting commitments,
small SHLAA sites and windfalls results in a need to identify and allocate land for 6,986
dwellings. The Council have disregarded Option 2 (employment led growth and 700
dwellings per annum) seemingly solely on the basis that there is a lack of certainty that a
sufficient number of homes on strategic sites could be delivered within the plan period.
Using the Council's own calculations, delivering 700 dwellings per annum would result in
the need for an additional 1,800 dwellings to be found on allocated sites. Part of the
justification relates to the perceived lead in times for the delivery of the larger sites;
however the Council's own phasing programme is a self-fulfilling prophecy in this regard.
Phasing the larger allocations in Phases 2 and 3 (i.e. post 2019) could result in a
significant number of dwellings coming to the market at the same time and making it
difficult to therefore deliver an additional 1,800 dwellings in full within the plan period.
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We would suggest that the Council allows the market and the development industry to
regulate itself in respect of the phasing and the timing of the delivery of development.
To allow the larger allocations to make a start earlier in the plan period will ensure
steady delivery of housing over the life of the plan. It is not in a developer's own interest
to saturate the market however steady delivery on a number of sites over a number of
years will promote healthy competition and ensure sufficient time to allow such sites to
be built out in full. Furthermore, in doing this, there would exist the opportunity to
allocate land for the 'missing' 1,800 dwellings which would make a bigger step towards
meeting the Council's housing need.
- In addition, we highlight that the NPPF makes reference to development which is
sustainable going ahead without delay. It follows that in order for a site to have secured
an allocation in what will be an adopted Local Plan, that site must be sustainable and
therefore in accordance with the NPPF, there is no need for that site to be held back by
an arbitrary phasing policy.
- The Localism Act enshrines a Duty to Cooperate on Local Authorities when preparing
plans. In the event that Warwick District does not meet its own housing need in full, we
see no evidence of adjoining LPA's being prepared to take on and meet that need. The
District is bounded by the following LPA's:
- Stratford District: Latest draft Core Strategy did not propose to accommodate sufficient
growth to meet its own needs. No proposals to meet unmet need from Warwick District.
- Coventry: Latest draft Local Plan does not propose to accommodate sufficient growth to
meet its own needs. No proposals to meet unmet need from Warwick District.
- Rugby Borough: Adopted Core Strategy does not include any proposals to accommodate
unmet need from Warwick District.
- It is not therefore clear the way in which the Duty to Cooperate has been carried forward
or the way in which the District's housing need will be met in full, particularly given that
the household increase is projected to be closer to 15,557 households rather than the
10,800 households currently being planned for.
- Further justification for using lower housing targets is provided in paragraph 5.22 where
it is stated that using Option 2 would meet the projected change in employment between
2011 and 2031 as identified in the West Midlands Integrated Policy Model. However the
Council consider this to now be optimistic as it was carried out in 2010 and forecast an
increase in employment growth from 2011. We highlight however that throughout the
NPPF there is reference to the need to 'plan positively' and the need to stimulate and
secure economic growth. It would appear that the Council are revising their growth for
the period to 2029 (i.e. the long term) because short term growth has failed to
materialise. This cannot be said to be planning positively or assisting in securing
economic growth.
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3. PO3: Location of Growth
- The components of growth are reviewed below:
- Committed Housing Sites (1,224 dwellings): whilst clearly committed sites, we question
whether it is appropriate to include all of these sites and not include any allowance for
non-implementation. A 10% non-implementation rate is the industry 'norm' which we
consider should be applied here, thus reducing the commitments to 1,102 dwellings.
- Small Urban SHLAA sites (290): We seek clarification as to where these sites fall within
Table 7.2 of the Draft Local Plan (DLP).
- Other Windfall Housing Sites (2,300): Paragraph 7.25 of the DLP confirms that the
Council consider there to be a limited supply of land within the existing built up areas of
the towns. Windfalls can be included if the Council can demonstrate that such sites have
consistently become available in the local area and will continue to form a reliable source
of supply having regard to the SHLAA. The Council's SHLAA methodology confirms that
a minimum site size of 5 dwellings was used and that Officer's did not rely solely on sites
which supplied to them by developers or landowners but also conducted their own
research including reviewing areas currently in non residential use and looking at small
scale developments such as change of use of existing buildings. It would therefore
appear that the Council have had every opportunity to identify suitable residential sites
and include them in the SHLAA. With the removal of rear garden land from the definition
of previously developed land, we consider that the scope for new windfall development is
much reduced and that windfalls will no longer continue to make up a significant element
of future supply. Furthermore, under the banner of the NPPF and the requirement to
plan positively, windfalls should be seen as a 'bonus' rather than forming approximately
20% of the overall supply.
Land South of Gallows Hill
- The distribution of housing growth across the District is supported with particular
reference to Land South of Gallows Hill. It is noted that within the Council's Landscape
Character Assessment (February 2009), it is concluded that the study area is not suitable
and the rural character should be safeguarded from development. It is however clear
that this study has considered landscape character in isolation and this study should be
considered 'in the round' as is only one part of the evidence base underpinning the Local
Plan. The NPPF is clear that economic growth is a priority and that economic, social and
environmental factors have to be balanced against each other.
- The developers of this site will be commissioning technical and environmental work to
underpin the draft allocations; this will include detailed landscape and visual work to
demonstrate ways in which the site can be developed without adverse landscape impact.
- Whilst the developers will be working together to ensure a comprehensive approach to
the delivery of the site, we consider it important to recognise that within this should exist
the flexibility to ensure that each developer can bring parts of the site forward at their
own pace within an overall masterplanned approach. The delivery of large sites is often
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hampered by requirements to submit a single planning application which can cause
significant delays and is often to the detriment of the site itself.
4. PO5: Affordable Housing
- Whilst we do not object to the provision of affordable housing in principle, we do not see
any up to date evidence of the way in which the appropriateness of the target as been
assessed in terms of the financial viability of development in accordance with paragraphs
173 and 174 of the NPPF. Paragraph 7.43 of the DLP makes reference to a November
2011 document and an Addendum dated May 2012. The May 2012 document does not
feature in the Evidence Base on the Council's web-site and therefore we reserve the
right to make further representations in this respect upon publication of this document.
5. PO6: Mixed Communities and a Wide Choice of Housing
- We consider that sufficient flexibility should be included within any policy to ensure that
account is taken of up to date market demand in addition to the SHMA's. The latter can
become obsolete very quickly and clearly, if developers feel there is no demand for a
particular type of property then they will not build it, which can result in stalled sites and
lower rates of housing delivery.
- Lifetime Homes: there is no national policy which requires the provision of Lifetime
Homes and we see no justification which supports 25% provision.
- Homes for Older People: whilst the provision of extra care housing is supported, these
have very site specific criteria with operators having specific requirements in respect of
site location and suitability. A site which is suitable for market housing may not be
suitable for extra care housing and it is important to ensure that this policy is not applied
so rigidly so as to sterilise areas of land or stall sites.
6. PO8: Economy
- It is noted that the Council propose to consider allocating a 'proportion' of the site south
of Gallows Hill for employment. The provision of mixed use development is supported
although clearly further clarification is required on the definition of 'a proportion'.
7. PO10: Built Environment
- The Council's Garden Towns, Suburbs and Villages prospectus is supported.
8. PO12: Climate Change
- We have reviewed the Council's evidence base and do not see any case for the
introduction of a 20% climate change policy. We are also disappointed to see a
continued emphasis on renewable energy provision within new developments (when the
Council themselves acknowledge the disadvantages with some renewable technologies)
as opposed to the emphasis being placed on energy efficiency. If the overall aim is seek
a reduction in carbon emissions, we fail to see why this should be achieved through
renewable energy rather than energy efficiency measures.
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9. PO18: Flooding and Water
- Whilst the policy as a whole is supported it is noted that much of this replicates national
guidance and is therefore superfluous. Furthermore, the requirement that all new
developments include SUDS is unfeasible. There are some instances where SUDS
schemes are not feasible or viable and this should be recognised within the policy.
10. Draft Infrastructure Planning
- Whilst the provision of a draft Infrastructure Plan is supported to assist in providing
certainty to developers when bringing forward new sites, particularly in respect of the
larger strategic sites. We consider that further refinement of this plan may be needed.
For example, within Warwick and Leamington Spa, 6 new primary schools are currently
being considered at the same time as capacity in a number of existing schools is also
identified. It is noted that the NPPF advocates a CIL charging schedule being prepared
in tandem with a Local Plan if possible and we consider this may be appropriate in this
case to assist in determining the total cost of items identified in the Draft Infrastructure
Plan. This is of particular importance when reviewing the Strategic Transport
Assessment Overview Report which identifies a requirement of up to circa £5,000 per
property for transport infrastructure without taking into account any other infrastructure
requirements or planning obligations.