5 Overarching strategy – Achieving Net Zero Carbon Development
Object
Net Zero Carbon Development Plan Document - Regulation 19
Representation ID: 72183
Received: 27/04/2022
Respondent: Mr Steve Russell
Legally compliant? Not specified
Sound? Not specified
I do not agree with this policy and feel it will just add unnecessary cost to people that are already struggling.
I do not agree with this policy and feel it will just add unnecessary cost to people that are already struggling.
Comment
Net Zero Carbon Development Plan Document - Regulation 19
Representation ID: 72184
Received: 27/04/2022
Respondent: Graham Ball
The district's ultimate aim is to achieve net zero. The document is clear that for operational building emissions, a net zero target is the principal that developers should achieve, which is great. However, the document does not require developers to achieve net zero for the emissions of constructing developments, but the document also states that up to 50% of lifetime building emissions can come from the construction phase. Therefore, the policy will fail to deliver net zero.
There is no valid excuse for the policy to be so weak. Net zero for new buildings could be achieved far quicker, easier and cheaper by banning all new housing developments in the district. That would be a short term solution. In the long run, the biggest source of emissions is population growth.
The district's ultimate aim is to achieve net zero. The document is clear that for operational building emissions, a net zero target is the principal that developers should achieve, which is great. However, the document does not require developers to achieve net zero for the emissions of constructing developments, but the document also states that up to 50% of lifetime building emissions can come from the construction phase. Therefore, the policy will fail to deliver net zero.
There is no valid excuse for the policy to be so weak. Net zero for new buildings could be achieved far quicker, easier and cheaper by banning all new housing developments in the district. That would be a short term solution. In the long run, the biggest source of emissions is population growth.
Object
Net Zero Carbon Development Plan Document - Regulation 19
Representation ID: 72188
Received: 28/04/2022
Respondent: Steven Barnett
Legally compliant? Not specified
Sound? Not specified
Stop the carbon fraud.
Stop the carbon fraud.
Comment
Net Zero Carbon Development Plan Document - Regulation 19
Representation ID: 72192
Received: 02/05/2022
Respondent: Mr Andrew Pike
There are various references in the draft Plan to compliance with it being subject to that being ‘feasible’ in the light of the type of development and its design, and also to where it must be ‘viable’ for a design to comply. Surely, these ‘loopholes’ would give an opportunity for developers to get around full compliance? I suggest that developers should create designs that comply with the Plan, and if they do not their designs should be rejected, rather than them creating designs which do not comply, and then seeking to take advantage of the loose wording about feasibility or viability in the Plan.
While the draft Plan seems mainly about buildings, traffic issues are also of major concern in urban areas such as
Warwick and Leamington. I believe that there should be much wider use of traffic ’calming’ measures (eg. speed
bumps, chicanes etc) on urban roads (such as exist on Clemens Street in Leamington) in order to reduce speeds, and therefore carbon emissions, as well as improving safety generally. It also seems a nonsense that cars and diesel powered buses are still allowed to pass down the Parade in Leamington, through the heart of a pedestrian shopping area. I appreciate that, if the Parade was pedestrianised, traffic would still have to use other roads around the edges of the town, but that would at least avoid the concentrated pedestrian area around the Parade.
There are various references in the draft Plan to compliance with it being subject to that being ‘feasible’ in the light of the type of development and its design, and also to where it must be ‘viable’ for a design to comply. Surely, these ‘loopholes’ would give an opportunity for developers to get around full compliance? I suggest that developers should create designs that comply with the Plan, and if they do not their designs should be rejected, rather than them creating designs which do not comply, and then seeking to take advantage of the loose wording about feasibility or viability in the Plan.
While the draft Plan seems mainly about buildings, traffic issues are also of major concern in urban areas such as
Warwick and Leamington. I believe that there should be much wider use of traffic ’calming’ measures (eg. speed
bumps, chicanes etc) on urban roads (such as exist on Clemens Street in Leamington) in order to reduce speeds, and therefore carbon emissions, as well as improving safety generally. It also seems a nonsense that cars and diesel powered buses are still allowed to pass down the Parade in Leamington, through the heart of a pedestrian shopping area. I appreciate that, if the Parade was pedestrianised, traffic would still have to use other roads around the edges of the town, but that would at least avoid the concentrated pedestrian area around the Parade.
Comment
Net Zero Carbon Development Plan Document - Regulation 19
Representation ID: 72193
Received: 08/06/2022
Respondent: Warwick District Labour Party
Not just a strategy for newbuilds.
Set higher standards than anticipated 2025 national ones.
SAP and SBEM out of date and poor methodologies for calculating emissions eg performance gap not measured - see Jan 22 WDC policy review
We must have robust and specific tools here eg PHPP and with scope for LPA to update and toughen as methodologies improve.
Specify achieved energy standards test of all newbuilds at 9 years within 10 year guarantee period.
Why lim it standards to buildings over 1000sqm? What standards apply to smaller buildings?
Not just newbuild - see earlier comments
5.4 Can we legally set higher standards than the anticipated 2025 national one ? If so we should as national policy has often lagged behind the urgency required by the emergency.
5.7/5.8.5.9 SAP and SBEM may be out of date and relatively poor methodologies for calculating emissions - the draft DPD itself seems to imply the performance gap is not measured (5.9); and a Jan 22 WDC policy review states
Unfortunately, the calculation methods used in Building Regulations Part L (SAP and SBEM) are very poor predictors of the actual energy use of a building. SAP and SBEM are compliance tools, not really tools to predict energy and carbon performance (even though they purport to be). This is not only due to out-of-date carbon factors used for different energy sources, but the entire methodology.
Whatever robust tools we do select as accurate here should be specific eg PHPP which others have adopted, not left open for developers' decision with the phrase 'such as'.
The LPA must also be permitted to update the list of acceptable tools within this DPD as technology and experience indicate
Finally, should we require further testing of achieved energy standards at 9 years (before new House quality guarantee expires) to ensure any performance slippages over the short-term life of the buildings are rectified for the long-term.
5.11 Why are standards limited to new buildings of over 1000sqm. What standards will smaller buildings be expected to meet?
Comment
Net Zero Carbon Development Plan Document - Regulation 19
Representation ID: 72205
Received: 05/06/2022
Respondent: Individual
Please see attached.
Please see attached.
Comment
Net Zero Carbon Development Plan Document - Regulation 19
Representation ID: 72206
Received: 06/06/2022
Respondent: Emma Longworth
WCC’s policy to promote and support the transition to electric/hybrid vehicles in the County concentrates on the provision of public-access infrastructure. However, the Electric Vehicle Charging Infrastructure Strategy (ECVIS) also commits WCC, in coordination with other authorities and organisations, to “raise awareness of ... the options for and benefits of EV ownership.” I would argue that this means that WCC and its partners will take reasonable action to ensure that individual policies work together to remove barriers to the use of EVs. This means that fresh approaches must be taken so that private provision of charging points is not hindered by the policies of local government. This change in attitude will be necessary, for example, so that people living in terraced housing in streets where parking is at a premium can do their bit to clean up the atmosphere in their towns.
Please see attached.
Comment
Net Zero Carbon Development Plan Document - Regulation 19
Representation ID: 72207
Received: 07/06/2022
Respondent: Intelligent Alternatives Limited
Please see attached.
Please see attached.
Object
Net Zero Carbon Development Plan Document - Regulation 19
Representation ID: 72208
Received: 08/06/2022
Respondent: IM Land and IM Properties
Agent: Turley
Legally compliant? Not specified
Sound? Not specified
IM have reviewed the Net Zero DPD and have presented a number of concerns which without amendment, the draft DPD can only be considered unsound.
These concerns are:
• Unsound viability evidence base which does not meet the requirements of Paragraph 31 of the NPPF.
• Further detail is needed with respect to the offsetting fund proposed to ensure that any funds received by the council will be spent on effective and deliverable carbon offset projects; and
• The need to introduce transitional arrangements given that Policy NZC1 is introducing the full FHS two years before the Governments proposed timetable.
Please see attached.
Comment
Net Zero Carbon Development Plan Document - Regulation 19
Representation ID: 72211
Received: 08/06/2022
Respondent: Warwick District Green Party
Please see attached.
Please see attached.
Comment
Net Zero Carbon Development Plan Document - Regulation 19
Representation ID: 72215
Received: 08/06/2022
Respondent: IM Land
Agent: Barton Willmore
Please see attached.
Please see attached.
Comment
Net Zero Carbon Development Plan Document - Regulation 19
Representation ID: 72217
Received: 08/06/2022
Respondent: Persimmon Homes
Agent: Barton Willmore
Please see attached.
Please see attached.
Comment
Net Zero Carbon Development Plan Document - Regulation 19
Representation ID: 72218
Received: 08/06/2022
Respondent: Taylor Wimpey
Agent: Barton Willmore
Please see attached.
Please see attached.