Issue and Options 2023

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As set out in response to the Scoping and Call for Sites consultation, L&Q Estates supports Stratford-on-Avon and Warwick District Councils in the continued preparation of a Joint Local Plan. Working together provides the Councils with the opportunity to comprehensively develop the vision, strategic objectives, development requirements, spatial development strategy and policies that will shape detailed development proposals, taking into account changes to the national planning legislation, revisions to the NPPF and National Planning Practice Guidance (NPPG) that have occurred since the adoption of the Development Plans, adopted in 2016 (Stratford) and 2017 (Warwick) respectively. Any joint Local Plan must embrace similarities between the authorities and the opportunities created (such as the provision of strategic infrastructure) whilst also recognising differences. For example, the two administrative areas at present have differing settlement hierarchies where Stratford on Avon has a more rural population than Warwick and those difference must be taken into account in the strategic nature of spatial policies that are prepared. Notwithstanding, the Joint Plan itself provides the opportunity to set a spatial hierarchy and identification of land for development which ensures the existing character of the area as a whole is preserved and enhanced. National Requirements for Plan-Making Paragraph 33 of the NPPF requires local planning authorities to keep policies in their Local Plans up to date by undertaking a review at least once every five years. The joint Local Plan will ensure that an up-to-date Local Plan for ‘South Warwickshire’ will be in place to support growth and meet future development needs. L&Q Estates supports the Councils’ proactive approach to progressing a joint Local Plan to ensure that an up-to-date policy framework exists for the ‘South Warwickshire’ area, to guide growth to2050 and to ensure that development is genuinely plan-led. Vision and Strategic Objectives The Plan’s Vision seeks to “meet South Warwickshire’s sustainable development needs to 2050” and “provide homes and jobs, boost and diversify the local economy, and provide appropriate infrastructure, in suitable locations, at the right time.” These representations are broadly supportive of the vision as presented as it accords with para 7 of the NPPF which states that the purpose of the planning system is “to contribute to the achievement of sustainable development.” The five overarching principles which then set out the basis on which policies will be formed and thus how the Vision will be delivered do not match the Vision as drafted. For example, the delivery of homes and jobs does not appear in any of the over-arching principles accompanying the Vision. Whilst the detail of the Issues and Options consultation document goes onto talk about the delivery of growth an over-arching principle to underpin the Vision should be developed, from which detailed policies will flow. Such a principle would also tie in to the Strategic Objectives which follow, which do set out a number of objectives to deliver South Warwickshire’s development needs. The Vision places significant emphasis on responding to the ‘climate emergency’. Although this principle in general is supported and it aligns with the Government’s aspirations for achieving net zero carbon emissions it is also important that this does not dominate the Vision and Strategic Objectives of the Plan to the detriment of delivering a balanced, sustainable strategy which achieves the delivery of development to meet identified needs. The Vision also makes reference to ‘beauty’ stating that this will create spaces where people want to be, which respect and reflect the existing beauty and heritage of the area. This aspiration is supported in principle and it is acknowledged that national policy is pursuing ‘beauty’ in planning however there is a concern that as a concept this is not well defined and will need to be supported by more detailed design which reflect on what beauty might mean in practice.

The Issues and Options document is supported by a sustainability Appraisal (‘the SA’), prepared by Lepus Consulting. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Issues and Options consultation document, where the SA outputs will help the Authorities to identify sustainable development options and prepare a plan which is “economically, environmentally and socially sustainable.” NPPF paragraph 32 identifies that local plans should be informed throughout their preparation by a SA which meets the relevant legal requirements and which should demonstrate how the Plan has addressed relevant economic, social and environmental objectives. To support the Issue and Options consultation has considered different locational reasonable alternatives. These include the 5 no. growth options proposed, 7 no. new settlement locations (for development of no less than 6,000 homes), 32 no. Broad Locations for development around the Main settlements (to up to 2,000 homes), and 22 no. Small Settlement Locations for development of between 50-500 homes. The SA then used the SA Framework to evaluate how the different reasonable alternatives perform against sustainability objectives. The Sustainability Objectives are: • Climate Change – Reduce the SWLP1 authorities’ contribution towards the causes of climate change • Flood Risk – Plan for anticipated levels of climate change • Biodiversity and Geodiversity – Protect, enhance and manage biodiversity and geodiversity • Landscape – Protect, enhance and manage the quality and character of landscapes and townscapes • Cultural Heritage – Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance • Environmental Pollution – Mitigate adverse impacts from existing air, water, soil and noise pollution and avoid generating further pollution • Natural Resources – Protect and conserve natural resources including soil, water and minerals • Waste – Reduce waste generation and disposal and support sustainable management of waste • Housing - Provide affordable, high quality and environmentally sound housing for all • Human health – Safeguard and improve community health, safety and wellbeing • Accessibility – Improve accessibility, increase the proportion of travel by sustainable modes and reduce the need to travel • Education – Increase access to education and improve attainment to develop and maintain a skilled workforce • Economy – Ensure sufficient employment land and premises are available to develop and support diverse, innovative and sustainable growth The significance of effects is assessed in accordance with Table 2.1 in the SA [see attached document]. The principle and broad approach of the SA is supported but the alternatives it considers are quite limited in scope and do not include for any site or location which does not fall within one of the locations set out. L&Q Estates’ land interests on land at Station Road, Long Marston is such a location yet it is available and is considered a suitable, deliverable site which would deliver sustainable development. The Site (Map ref. 146) does not fall specifically within any of the Broad Locations or SSL’s identified. Whilst further comments are made below in relation to Q-S5.2 on the site’s suitability for development in order to assess all reasonable alternatives the L&Q Estates land on Station Road, Long Marston need to be assessed within the SA and taken on board in the formation of the spatial growth strategy as a reasonable alternative. If this is not done then the SA will not have considered all reasonable alternatives.

Q-I2: Please select the option which is most appropriate for South Warwickshire: A: Set out infrastructure requirements for all scales, types and location of development B: Focus on strategic infrastructure relating specifically to the growth strategy It will be necessary for the South Warwickshire Local Plan to consider infrastructure requirements across the plan area, both strategic and non-strategic. It is suggested that the adoption of a consistent approach to infrastructure across the plan area would be beneficial, would provide certainty for those involved in the planning process and would simplify the viability study of the Local Plan which is now a national requirement. It is recognised that elements of the growth strategy may require specific strategic infrastructure in order to ensure deliverability and the Plan will need to clearly identify these requirements, along with the delivery mechanisms to secure this. For non-strategic infrastructure, a less detailed approach is likely to be sufficient which considers different areas and types/scales of development. However, it will be necessary for both to inform the plan-making process going forward. Q-I3: Please select the option which is most appropriate for South Warwickshire: A: Establish a South Warwickshire CIL (or emerging Infrastructure Levy) to support the delivery of the Plan B: Each District to produce its own Levy It is acknowledged that both Districts currently have CIL and that the charging schedules have been developed independently. It is also noted that the Plan acknowledges that it is possible to charge different rates of CIL in different zones within a single levy. If it is the Council’s intention to review CIL then it would be logical to review this jointly alongside the Local Plan process. This allows for infrastructure costs to be properly understood and suitable delivery mechanisms identified, including potentially CIL or developer obligations. This should inform the viability study of the Plan to ensure that obligations do not undermine delivery of the Plan. Q-I5: Please add any comments you wish to make about infrastructure, viability and deliverability The NPPF para 34 requires Local Plans to set out the contributions expected from development including affordable housing requirements, plus other infrastructure such as education, health, transport, flood and water management, green and digital infrastructure. The NPPF states that such contributions should not undermine the deliverability of the Plan. In developing policies that will set out development contributions expected from developments detail viability work must support the Local Plan process. Such viability work should be based on a detailed, site specific evidence base that will ensure planning applications which comply with development plan policies will be viable, without the need for further viability work to be undertaken at the application stage. As intimated at NPPF para 58.

Q-S3.2: Please select the option which is most appropriate for South Warwickshire: 2A: Prioritise brownfield development only when it corresponds with the identified growth strategy, or if it can be provide that the development is in a sustainable location or would increase the sustainability of the area. 2B: Prioritise development on brownfield land, incorporating existing buildings into development proposals wherever possible, irrespective of its location. 2C: None of these. It is acknowledged that national policy encourages the reuse and redevelopment of brownfield land. However, as identified by Option 2A, it is important that brownfield development should reflect the identified growth strategy in order to ensure that sustainable development is achieved. It should be noted that the Urban Capacity Study (October 2022) established that it is unlikely to be possible to meet current development needs without significant greenfield development. Whilst the reuse of suitable brownfield land, in line with the growth strategy and/or in sustainable locations should be encouraged by planning policy, it will not avoid the need for greenfield development as part of the South Warwickshire Local Plan. QS5.2 – Do you think new settlements should be part of the overall strategy? The Joint Local Plan could consider potential new settlement locations as part of a broad strategy of growth across the Plan area. A new settlement can deliver significant infrastructure in support of its development, to the benefit of future occupiers and can deliver a significant amount of growth to meet identified need. Option E1 provides for a new settlement in an area broadly to the north of the existing Long Marston Airfield and Meon Vale developments, which have come online through previous and the currently adopted Development Plan strategy, as referred to above. L&Q Estates land interests could be an extension to these developments, as highlighted, which would in effect create a new settlement at approximately the scale the Council are considering. Development on the land could deliver additional development in this area that would assist in the delivery of such key infrastructure on land that sits between the two developments, and which could provide comprehensive development to link the two areas, which could all be defined by a new settlement boundary. Development of the land would therefore fit within this category when considered as described, or be a further extension to the settlements already created. Moreover, this area needs to be considered within the SA where it currently does not fall within any of the reasonable alternatives identified and this must be rectified as the Plan progresses. For the purposes of these representations an assessment of the Site against the SA objectives is set out below: SA Objective 1 Climate Change: The site would deliver 1,000-1,500 dwellings in a sustainable location, close to existing development, services and facilities, and public transport links. The Site would support the delivery of 20-minute neighbourhoods to reduce travel to meet everyday needs with regard to the development surrounding. SA Objective 2 Flood Risk: The site comprises areas of Flood Zone 1, 2 and 3 but development will be placed outside of the current Zone 2 and 3 flood extents. There are limited opportunities to utilise soakaways based on technical work undertaken to support the delivery of the site and the surface water drainage strategy will utilise swales, filter drains, porous surfaces and detention basis as well as the principle of Building with Nature to maximise the opportunities for improvements to Zone 2 and 3 areas to maximise flood risk prevention. SA Objective 3 Biodiversity, Flora, Fauna and Geodiversity: An Ecological Site appraisal has recorded key habitat types and considered the ecological sensitivities of the Site. The site is not within 10km or 2mm of internationally or national designated sites (respectively) and whilst it is in the Impact Risk Zone of the Welford Field Site of Special Scientific Interest (SSSI) and also Racecourse Meadow SSSI the distance between the site and each SSSI means development of the site would not be anticipated to these. A landscape and green infrastructure strategy could provide an increase in the biodiversity values of the Site, in line with the mandate of the Environment Bill and the Masterplan has embodied such principles. SA Objective 4 Landscape: The site is not subject to any national or local landscape designation, it is not within the Green Belt or a Special Landscape Area and there are no TPOs on site. Whilst there is some intervisibility with Meon Hill within the Cotswold Area of Outstanding Natural Beauty (AONB) the Masterplan has been devised to mitigate potential impacts and would be seen in the context of the surrounding Meon Vale and LMAGV developments. SA Objective 5 Cultural Heritage: The site is not in a conservation area nor does it contain listed buildings. There are listed buildings to the west in Long Marston Village and to the South East, but these would not prejudice the overall deliverability of the Site for development. SA Objective 6 Pollution: It should be noted that mitigation is achievable for air quality impacts, including for example additional tree planting, installation of electric vehicle charging points and increased use of public transport through sustainably located development, such as at this Site. Objective 7 Natural Resources: The site is shown on Natural England mapping as Grade 4 agricultural land which is identified as poor quality. Objective 8 Waste: A development of 1,000-1,500 houses would generate a level of household waste however this can be managed with provision of suitable recycling facilities for all households. Objective 9 Housing Provision: The Site would deliver housing in a sustainable location. This would include affordable housing. Objective 10 Health: The site is accessible by modes of transport other than the private car which provide sustainable access to health services and facilities. There would be open space on site in the form of a country park and links to public footpaths and cycleways as set out above. Objective 11 Accessibility and 12 Education: The site is accessible by all forms of transport and development of the site would support and enhance bus services. There are also various local services and facilities in the immediate surrounds as referred to above and a primary school and local centre would be provided on the site. Objective 13 Economy: The site is well located to benefit from existing economic and employment opportunities associated with Meon Vale to the south and LMAGV to the north. Q-S9: Please select the option which is most appropriate for South Warwickshire Option S9a: Save all existing settlement boundaries where these are already defined within the Core Strategy, Local Plan, emerging SAP or an NDP. Option S9b: Within this Part 1 Plan, review which settlements have boundaries defined and which do not, as well as the extent of any such boundaries. It is considered that a combination of both options may be appropriate for the Joint Local Plan. Where the Plan seeks to allocate land for development for strategic sites as set out at paragraph 1.4 of the Issues and Options document, then reviewing settlement boundaries should be undertaken as part of the proposed site allocation. Beyond this, to be found sound, the Plan must be prepared: Positively, in a way that is aspirational, but deliverable, and it should set out a framework for addressing housing needs and other economic, social and environmental priorities (NPPF paragraphs 15 and 16). To shape the spatial strategy for the Plan and ensure all reasonable alternatives are considered, a review of existing settlement boundaries will be required to identify sufficient land, in sustainable location to meet the development needs of the Plan. For example, land at Station Road Long Marston plus the existing development to the north and south could be defined by a settlement boundary which relates to their strategic function in delivering growth and development as an overall entity.

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Q-S4.1: Do you think that growth of some of our existing settlements should be part of the overall strategy? Warwick focuses development around its four main urban areas, whilst Stratford’s identified Local Service Villages accommodate a proportion of development as well as its main towns. In order to develop the most sustainable pattern of development, growth at existing settlements should be in the most sustainable locations. In the case of L&Q Estates land interests this should include the consideration of the land as an additional development that would sit alongside the existing Long Marston Airfield Garden Village to the north, and Meon Vale to the south and which would create a new settlement. The former Long Marston Airfield site is a garden village and will bring forward approximately 3,500 homes plus employment opportunities, a village centre, two primary schools and a secondary school. Meon Vale has planning permission for approximately 1,000 houses, retained employment space, a leisure hub and a primary school. The original village of Long Marston is to the west, separated by fields. The land identified at Appendix A the subject of these representations could deliver a distinguishable, high quality and landscape led development providing 1,000 – 1,500 new homes, a country park, a primary school and a local centre/community uses. It is ideally placed to link to both the Long Marston Airfield Garden Village (LMAGV) to the north and Meon Vale to the south, and to assist in the provision of significant infrastructure including the South Western Relief Road and the reopening of Honeybourne railway station, should that come forward (see Appendix B, Vision Document page 20). The Airfield and Meon Vale are both referred to as 'villages' although they are not currently formally part of the Spatial Strategy in the adopted Development Plan. The land off Station Road provides the opportunity to define a development boundary around the L&Q Estates land, Meon Vale and the LMAGV, creating a sustainable settlement in this location. As a location, the L&Q Estates land interests should be considered further, as a specific reasonable alternative within the SA and relevant evidence base documentation to consider its suitability for development and with a view to identifying the area within which it sits as a new settlement. Q-S4.2: The Site does not fall within or adjacent to any of the settlements that have been considered in the Settlement Design Analysis published with the Issues and Options consultation. However, based on the Council's consideration of Settlement Analysis the site would score highly. It can be accessible by all forms of transport and provide vehicular access off Campden Road and Station Road as well as being integrated into a network of pedestrian and cycling routes within and beyond the site, connecting to the existing Public Rights of Way and National Cycle Routes including the Stratford Greenway. It is not in a Special Landscape Area and as shown in the Vision Document, can be designed to take account of the areas within the Site at risk of flooding, providing development outside of these areas. Further, it can be linked to the LMAGV and Meon Vale developments to the north and south respectively and when taking into account the facilities proposed on the Site it can be within 800m of the facilities the Council have considered in the Settlement Analysis including retail, jobs, places to meet, open space and education. This is set out on Page 34 of the Vision Document.

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QH1-1: The HEDNA is proposing that we move away from an approach where future household needs are based on the 2014-based household projections towards a trendbased approach. Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of housing need across South Warwickshire Paragraph 11 of the NPPF requires that strategic policies should as a minimum provide for the objectively assessed need for housing as well as any needs that cannot be met in neighbouring areas. Paragraph 60 sets out the Government’s objective of “significantly boosting” the supply of homes and paragraph 61 provides additional guidance identifying that strategic policies should be informed by the minimum local housing need identified by the standard method as well as any unmet needs from neighbouring areas. The Planning Practice Guidance (PPG) (para 2a-002) again confirms that the standard method provides only the minimum number of homes expected to be delivered but it does allow authorities to diverge from the Standard Method where this can be justified by exceptional circumstances: where such an alternative reflects current and future demographic trends including migration and market signals. The HEDNA supporting the Issues and Options Consultation has assessed matters of housing need and requirements in great detail across the Coventry and Warwickshire Hosing Market Area in which ‘South Warwickshire’ is located. In coming to the recommendations on proposed housing need (dwellings per annum) across the Housing Market Area the report appears to have followed the relevant Government guidance in demonstrating exceptional circumstances supporting a trend-based approach to housing need for the Joint Plan area. The modelling of new demographic projects which take account of Census data releases and specific matters relating to the population in Coventry in particular, as part of the housing market area, but also including an assessment of Age Structures across the Housing Market Area (HMA), migration and demographic interactions is supported in principle. The trend based figures, which equate to an overall housing need across the Joint Plan area of 1,679 dwellings per annum is supported in principle. The HEDNA also identifies that Warwick has the highest levels of migration of population from Coventry, and that Stratford-on-Avon forms part of the Greater Birmingham Housing Market Area and the authorities should respectively consider planning for unmet need from Coventry and the Greater Birmingham HMA respectively. Whilst the number of homes which may be required in Coventry is likely to reduce based on the overall need being lower in the HEDNA than the 2014 sub-regional based household projections, the unmet need in the Greater Birmingham and Black Country HMA in particular is well evidenced. The GBBCHMA Housing Need and Housing Land Supply Position Statement (July 2020) identifies the housing shortfall of the GBBCHMA as 67,160 dwellings. The now revoked Draft Black Country Plan 2018-2039 showed a shortfall of circa 28,000 homes in the Black Country alone. Birmingham City Council have recently suggested a potential shortfall of over 78,000 dwellings. Further, the ‘Mind the Gap’ Barton Willmore Paper dated March 2021 and ‘Falling Short – Taking Stock of Unmet Needs across GB&BCHMA’ paper by Turley in August 2021, both commissioned by HBF Members concluded that the significant unmet needs in the GBBCHMA exist now, and will continue to exist in the future. The Black Country shortfall identified is considered to remain relevant to the Plan-making process and the recent letter from the Inspectors examining the Shropshire Local Plan confirms that the scale of need and unmet need remains relevant to Plan-making. Para 14 of that letter (see Appendix C) concluded that "Despite this new plan making context, there is no reason before us to find that the identified unmet needs in the Black Country area will disappear." It is important that these shortfall figures do not take into consideration the 35% uplift applied to Birmingham introduced in December 2020 as the adopted Birmingham Development Plan. The Black Country housing shortfall also does not consider the 35% uplift applied to Wolverhampton City Council in May 2021. Such considerations should also feed into the proposed housing targets that are set in the South Warwickshire Plan going forward and this could increase the requirement even further. NPPF REF

There is an acute recognition in the Issues and Options consultation documents of an affordability problem across South Warwickshire Plan area, where those on low incomes and young people struggle to access the housing market. Warwick District Council’s latest ‘Authority Monitoring Report’ (AMR) (for the period 2020-2021) indicates that against an annual requirement of 280 affordable dwellings since the beginning of the currently adopted Plan period in 2011 (within its own area), the Council have delivered 841 affordable dwellings (out of a total requirement for 2,800), 30% of the target. Stratford-on-Avon’s latest AMR for the period 2021-2022 (published December 2022) identifies that in the current Core Strategy plan period of 2011-2031, 3,204 affordable dwellings have been provided out of a total 10,019 dwellings (net) built. This equates to 37% of all dwellings and is just above the Plan’s affordable housing policy requirement of 35% of all dwellings to be affordable. Notwithstanding Stratford-on-Avon’s marginal reported over delivery, the HEDNA considered the affordability issue across the District further. It identifies at Table 8.45 that the estimated annual need for affordable housing (rented and affordable home ownership) across Stratford-on-Avon and Warwick is 1,386 dwellings per annum. Whilst it is recognised that these are ‘net’ figures and not ‘newly arising need’, PPG paragraph 2a-024 makes provision to encourage local authorities to consider increasing planned housing numbers where this can help to meet the identified affordable need: “The total affordable housing need can then be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, given the probably percentage of affordable housing to be delivered by market housing led developments. An increase in the total housing figures included in the strategic plan may need to be considered where it could help deliver the required number of affordable homes.” The Issues and Options consultation recognises that the area has an acute affordability problem, and it is suggested that to address this, the Plan could consider providing housing above the ‘minimum’ need, to boost supply, and in turn deliver additional affordable housing.

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Q-H3: Please select all options which are appropriate for South Warwickshire Option H3a: Do not seek to include minimum space standards in a policy in the SWLP. Option H3b: Apply Nationally Described Space Standards to developments across South Warwickshire based on locally derived evidence. If the Council are to include a policy requiring new developments to deliver dwellings which comply with Nationally Described Space Standards (NDSS), it must be fully justified. Such a requirement must not make development unviable and must set out such evidence in a proportionate manner to justify its inclusion, as set out in Footnote 49 of the NPPF which states that “Policies may also make use of the nationally described space standard, where the need for an internal space standard can be justified.” Further, the Planning Practice Guidance section on Housing: Optional Technical Standards (paragraph 020) states that: “Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas: • need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. • viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. • timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.” If the use of NDSS is subsequently justified and pursued through a policy, that policy should be sufficiently flexible to recognise that well-designed house types, which fall slightly below will be acceptable, particularly on sites where the majority of the dwellings comply. The policy should also make provision for additional flexibility in relation to affordable housing as many registered providers have their own requirements. Option H3c: Include a requirement to meet optional Building Regulations M4(2)/M4(3) as standard. These are focussed upon ensuring appropriate accessibility standards. It is unnecessary for the inclusion of an M4(2) and or M4(3) policy. The Building Regulations 2010 'Access to and use of buildings' Approved document Part M already provides specific requirements for M4(2) dwellings in relation to Accessible and Adaptable Homes and M4(3) M4 (3)(2)(a) dwellings in relation to Wheelchair Adaptable Homes housing. As such, it is therefore not necessary for this to repeated in any policy, also because developers are already aware they need to deliver to this standard. Q-H5: Please select all options which are appropriate for South Warwickshire As set out in the Planning Practice Guidance (Paragraph: 016 Reference ID: 57-016- 20210208), The Self-build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016) sets out the legal definition of self-build and custom housebuilding, and also sets out the requirement for each relevant authority to keep a register and publicise the register. Furthermore, Self-build or custom build will help diversify the housing market, as per PPG paragraph 16a Reference ID: 57-016a-20210208. Whilst there is no in-principle objection to the concept of self-build/custom housing, any specific policy requiring the delivery of such plots must be carefully considered, fully justified and flexible. Stratford-Upon-Avon District’s Self Build & Custom Housebuilding Register had 278 people on it as of 31st March 2022. Warwick’s Register had 95 people on it in 2019, but that is the latest published position. Table 13.1 of the HEDNA identifies that serviced plot demand for self-build dwellings is 63 plots per annum which is 4% of the purported 1,679 dwelling/annum housing requirement set out in the Issues and options consultation. I&O. The HEDNA evidence and Self-Build Register for both authorities should form part of the evidence base that informs any emerging policies that deal the delivery of selfbuild/custom plots on applications for residential development. If the Plan is going to require a % of self-build plots this must only be limited based on the current evidence available. Further, if there is a policy requiring self/custom build on major sites then it is nevertheless submitted that it should include a mechanism to allow for such plots to come forward for market housing if demand is subsequently found to be absent. For example, if serviced plots for self-build and custom housebuilding have been made available and marketed for a set period of time and have not sold, plots can be used for delivery of general market housing.

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Q-C4.1: Please select all options which are appropriate for South Warwickshire Option C4.1a: Do not have a policy and allow new developments to comply with the national regulation requirements, which may change over time If a net The Building Regulations Part L 2021 Target for Fabric Efficiency would be applicable to all proposed dwellings and sets the Government’s standards for energy efficient. The Council does not need to set local efficiency standards to achieve the shared net zero goal. zero carbon policy is to be employed by the Council it must be fully evidenced and justified, and included in viability considerations. Q-C6.1: Please select the option which is most appropriate for South Warwickshire Whilst the value of Whole Life-Cycle Carbon assessments is recognised and there is no in principle objection to the need for some forms of post construction, pre-occupation assessment, if a policy is to be pursued on this matter there are a number of key considerations: • Once sold, the purchasers and mortgagees will own properties. Any policy would need to be carefully worded such that it would not require the sharing of energy use, air quality and overheating risk data with a third party, where the developer no longs the dwelling as this could raise GPDR issues. Enforcement of such a policy for future owners and occupiers could also fail the test of conditions on any subsequent planning permission. • The purpose of such information would also need to be clearly set out. It will not be possible to post factum make alterations to the constructed buildings, so what would be the benefit or purpose of such a significant amount of data collation? If the purpose is to inform and advise as to future construction methods, then this could be equally achieved by an informed and targeted research exercise by organisations such as the BRE in advising Governments and through amendments to Building Regulations.