RLS2 - Housing design

Object

Representation ID: 71549

Received: 21/01/2020

Respondent: Mr Peter Southgate

As an architect based in and practising in Leamington Spa, I support the aims of this policy, especially the stated sustainability goals. However, the reference to CSH 4 should be reconsidered, given that the Code was withdrawn by Central Government in 2015. It has been replaced by the HQM regime. Energy performance standards for CSH 4 were incorporated into the UK Building Regulations (which now exceed CSH4) so it is pointless to add an extra hoop of compliance into a material planning consideration, especially as such a standard can no longer be meaningfully assessed.

Support

Representation ID: 71552

Received: 05/02/2020

Respondent: Mrs Sidney Syson

Government Policy and Building regulations are a changing landscape which makes Local Authority requirements a nightmare to impose, but I fully support the aims which should ensure that we encourage/impose as high a standard as possible for new buildings to combat climate change, fuel poverty, resource consumption and recycling.

Object

Representation ID: 71554

Received: 05/02/2020

Respondent: Mrs Sidney Syson

An additional comment: in view of the Government's announcement that no new petrol, diesel or hybrid cars are to be sold after 2035 I think a requirement for electric charging points should be added to the car parking requirements.

Support

Representation ID: 71619

Received: 17/02/2020

Respondent: Mr Richard Ward

I support the the encouragement of good housing design and the use of design guides. Also the role of the Conservation Area Forum helps this in particularly sensitive areas. (Although this this can be over-ruled by Inspectors, on appeal.)

It is notable that not all developers are motivated to pursue these aims.

Object

Representation ID: 71676

Received: 17/02/2020

Respondent: Spitfire Bespoke Homes Ltd

Agent: Pegasus Group

Spitfire’s representations to the Informal Consultation Draft consultation raised concerns about Policy RLS2, its relationship and necessity in the context of Local Plan Policy BE1, its lack of clarity regarding sustainable development standards. These concerns remain.
In the Regulation 16 draft NDP, Policy RLS2 has been amended to introduce more clarity on the expectations for housing development in some respects. The first three paragraphs of the policy now include: a requirement for all homes to be Lifetime Homes; an expectation that proposals should aim ‘where possible’ to achieve Level 4 of the Code for Sustainable Homes; and encouragement for the incorporation of higher environmental standards such as Passivhaus.
The fourth paragraph of Policy RLS2 also requires housing development to include design features that increase resilience to extreme weather events (including increased risk of river and surface water flooding) and for applicants to demonstrate the water efficiency of their proposals including ‘where practicable’ the incorporation of water efficiency and re-use measures in the design).
Whilst the requirements in the first three paragraphs of Policy RLS2 are less vague than in the previous draft of the policy, the requirements in the fourth paragraph remain imprecise in terms of the prevailing standards required for compliance. With respect to the requirements in all four of these paragraphs, Spitfire remain concerned that the NDP has not assessed the viability implications of encouraging compliance with a more rigorous set of standards and requirements than those required by the existing district wide criteria in Local Plan Policy BE1. Spitfire would also reiterate that there is no support for this approach within Local Plan Climate Change policies CC1 or CC3.
The policy is deemed not to meet the basic conditions, in that its requirements and expectations do not flow from national guidance, nor are they in general conformity with the Local Plan strategic policies. They therefore fail basic conditions a) and e).
With regard to the final paragraph of Policy RSL2, it is not considered appropriate for a NDP policy to state certain descriptions of development ‘will be refused’. The final paragraph also lacks clarity in its references to ‘poor design’ and ‘the relevant criteria’. Spitfire’s recommendation would be that the final paragraph ought to be omitted.

Object

Representation ID: 71679

Received: 17/02/2020

Respondent: Taylor Wimpey

Agent: Turley

Taylor Wimpey consider that policy RLS2 can be read as a duplication of key elements from policies SC0 and BE1 of the WDLP, as well as the Warwick District Council Residential Design Guide Supplementary Planning Document (2018).
Within the explanatory text to Policy RLS2, the RLSNP notes that “The Warwick Local Plan, through Policy BE1 Layout and Design, sets a framework for assessing the design of planning proposals. This includes all the key features and attributes of what is considered to be good design. Policy RLS2 does not need, or seek, to repeat these, but seeks to add further policy detail.” Notwithstanding Taylor Wimpey’s comments relating to the duplication of policies from the WDLP, where the RLSNP has included ‘further policy detail’ is around the requirement for proposals to achieve Level 4 of the Code for Sustainable Homes.
A Government Deregulation Bill in 2015 revoked the Code for Sustainable Homes from planning policy guidance, meaning that local planning authorities and qualifying bodies preparing neighbourhood plans should not set in their emerging local plans, neighbourhood plans, or supplementary planning documents, any additional local technical standards or requirements relating to the construction, internal layout or performance of new dwellings. This includes any policy requiring any level of the Code for Sustainable Homes to be achieved by new development.Therefore, as currently drafted Policy RLS2 is both a duplication of policies within the adopted WDLP and includes policy requirements which are not in accordance with national policy, thus not meeting basic conditions 8(2)(a) and 8(2)(e).