Net Zero Carbon Development Plan Document - Regulation 19
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Net Zero Carbon Development Plan Document - Regulation 19
1 The Local Context
Representation ID: 72177
Received: 08/06/2022
Respondent: Warwick District Labour Party
Set specific and more ambitious emission standards
Specify BREEAM where appropriate (and another standard or standards where not) and and by category at maximum energy credits.
WDC to be explicit in leading by example
1.1.2 Set specific and ambitious maximum carbon emission standards. Can we adopt specific carbon emission targets in kwhr/m2/yr (not just percentages) as is widely recommended? And make the energy efficiency first principle first and more strongly - the cheapest energy is the energy we do not use.
Where in the document do we specify BREEAM for all developments, domestic and non-domestic now that CC3 is being superseded? Or does BREEAM apply only to non-residential buildings - in which case what standard for residential is being specified?
Each BREEAM standard needs to be specifically set by category and date and at maximum energy credits NOT very good to eliminate any non carbon emission/energy loopholes being exploited.
1.1.3 WDC as building and landowner should already be leading more strongly by example, by applying the proposed DPD standards - or better - in all projects since the CEAP was adopted, not waiting for formal DPD adoption; for example in Kenilworth Leisure, Spencer Yard and any others from WDC or partners in the pipeline.
Comment
Net Zero Carbon Development Plan Document - Regulation 19
1.2 About Warwick District
Representation ID: 72178
Received: 08/06/2022
Respondent: Warwick District Labour Party
The role of the District in generating inward and outward flows of commuter traffic (principally to/from Coventry and Birmingham) should be highlighted. To minimise carbon emissions from current and future traffic flows the DPD should explicitly favour new development with minimum dwelling densities (NPPF paras 124/5) especially along public transport routes; and co-located as far as practical with planned employment locations (both within and outside the District), to encourage shorter journeys and greater use of active transport
The role of the District in generating inward and outward flows of commuter traffic (principally to/from Coventry and Birmingham) should be highlighted. To minimise carbon emissions from current and future traffic flows the DPD should explicitly favour new development with minimum dwelling densities (NPPF paras 124/5) especially along public transport routes; and co-located as far as practical with planned employment locations (both within and outside the District), to encourage shorter journeys and greater use of active transport
Comment
Net Zero Carbon Development Plan Document - Regulation 19
1.1 Warwick District Council's Climate Change Commitments
Representation ID: 72179
Received: 08/06/2022
Respondent: Warwick District Labour Party
More specific and ambitious energy targets
Clarify and maximise use of BREEAM standards where applicable and other measure(s) where not eg perhaps housing
WDC to lead by example
1.1.2 Set specific and ambitious maximum carbon emission standards. Can we adopt specific carbon emission targets in kwhr/m2/yr (not just percentages) as is widely recommended? And make the energy efficiency first principle first and more strongly - the cheapest energy is the energy we do not use.
Where in the document do we specify BREEAM for all developments, domestic and non-domestic now that CC3 is being superseded? Or does BREEAM apply only to non-residential buildings - in which case what standard for residential is being specified?
Each BREEAM standard needs to be specifically set by category and date and at maximum energy credits NOT very good to eliminate any non carbon emission/energy loopholes being exploited.
1.1.3 WDC as building and landowner should already be leading more strongly by example, by applying the proposed DPD standards - or better - in all projects since the CEAP was adopted, not waiting for formal DPD adoption; for example in Kenilworth Leisure, Spencer Yard and any others from WDC or partners in the pipeline.
Comment
Net Zero Carbon Development Plan Document - Regulation 19
1.2 About Warwick District
Representation ID: 72180
Received: 08/06/2022
Respondent: Warwick District Labour Party
Incorporate references to minimum dwelling densities and co-location.
Risk of being far from net zero objective if most new homes not and retrofitting is limited.
Include retrofitting standards and planned inspections by zero-engineers. Ambition as well as flexibility required here. Discourage demolition to minimise net additions of embedded carbon.
The role of the District in generating inward and outward flows of commuter traffic (principally to/from Coventry and Birmingham) should be highlighted. To minimise carbon emissions from current and future traffic flows the DPD should explicitly favour new development with minimum dwelling densities (NPPF paras 124/5) especially along public transport routes; and co-located as far as practical with planned employment locations (both within and outside the District), to encourage shorter journeys and greater use of active transport
How can this DPD ensure that new development does not add to the District's deficit if the many thousands of new homes envisaged will NOT be net zero and there will be significant retrofitting?
1.3.1 The objective should also cover standards not just for new buildings but for all retrofitting, refurbishment, conversion and extension projects on existing buildings; and planned sample inspections by trained zero-engineers to ensure objective emissions are being sustained.
It is recognised that these standards may need to be more practical and flexible for existing buildings but should be as explicit and ambitious as possible. They also need to reflect an associated objective to encourage refurbishment of old stock rather than demolition/newbuild in order to minimise net additions to embedded carbon. See comments under section 9 & 10 below
Comment
Net Zero Carbon Development Plan Document - Regulation 19
2 National Context
Representation ID: 72181
Received: 08/06/2022
Respondent: Warwick District Labour Party
Support the objective to bring forward Future Homes Standard policies in Warwick District. However could this be more ambitious? Have we considered the policies developed by Bath, Central Lincolnshire, Greater Cambridge for example?
Support the objective to bring forward Future Homes Standard policies in Warwick District. However could this be more ambitious? Have we considered the policies developed by Bath, Central Lincolnshire, Greater Cambridge for example?
Comment
Net Zero Carbon Development Plan Document - Regulation 19
3.1 National Planning Policy Framework (NPPF), July 2021
Representation ID: 72182
Received: 08/06/2022
Respondent: Warwick District Labour Party
Add reference to paras 124/5 (more efficient dwelling densities) and section 12 paras 126 to 136 (the importance of good design) to put the emphasis on sustainability in a fuller balanced planning context.
Add reference to paras 124/5 (more efficient dwelling densities) and section 12 paras 126 to 136 (the importance of good design) to put the emphasis on sustainability in a fuller balanced planning context.
Comment
Net Zero Carbon Development Plan Document - Regulation 19
3.2 Planning Practice Guidance updated in 2019
Representation ID: 72185
Received: 08/06/2022
Respondent: Warwick District Labour Party
See last comment. Will new guidance on density and design (Plan, DPD or SPD) be required to incorporate new carbon emission standards?
See last comment. Will new guidance on density and design (Plan, DPD or SPD) be required to incorporate new carbon emission standards?
Support
Net Zero Carbon Development Plan Document - Regulation 19
3.3 Warwick District Local Plan 2011-2029, adopted September 2017
Representation ID: 72186
Received: 08/06/2022
Respondent: Warwick District Labour Party
Useful background
Useful background
Support
Net Zero Carbon Development Plan Document - Regulation 19
3.4 Neighbourhood Development Plans (NDPs)
Representation ID: 72187
Received: 08/06/2022
Respondent: Warwick District Labour Party
Useful background
Useful background
Comment
Net Zero Carbon Development Plan Document - Regulation 19
4 Aims and Objectives
Representation ID: 72189
Received: 08/06/2022
Respondent: Warwick District Labour Party
Clarify policy on unregulated emissions
Extend policy to existing building conversions and developments
Toughen 'as early as possible' and commit all developments/refurbishments of WDC land/property from 2022 to net zero.
Clarify if gas is ruled out in 7.3. If not apply specific conditions to enable future low cost retrofitting
What does the policy aim to deliver in terms of unregulated energy emissions - is that also net zero? This needs to be made clear.
Not just newbuilds - see detailed Comment under 1.3.
Expand 'earlier where possible' to include a firm commitment to apply this net zero policy to all current and future developments/refurbishments of WDC property and land.
Is gas explicitly ruled out as implied by 7.3? If not, some hard conditions need to be stated and applied to avoid significant additional costs for future owners when fitting air source heat pumps:
· No combi boilers
· No microbore pipes
· Need to allow internal space for a hot water cylinder and heat store.
· The cylinder should be equipped with an immerser linked to the PV panels.