Preferred Options 2025

Other

Representation ID: 108822

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

We generally support draft Policy Direction 5, however contributions requested need to be acceptable in planning terms, directly related to the development and fairly and reasonably related in scale and kind to the development in accordance with paragraph 58 of the NPPF. We note from the SWLP that a Viability Appraisal will be produced to support the Regulation 19 plan. This should ensure the policy requirements being proposed will not impact on the delivery of development sites. The Viability Appraisal should be informed by a full and detailed review of all financial contributions which may be sought for development at the application stage.

Other

Representation ID: 108823

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

We support the provision of broad density requirements being proposed and areas suitable for higher density development being indicatively identified. However, the NPPF (paragraph 129) is clear that there are a number of factors which should be considered when assessing whether a scheme makes the most efficient use of land. When it comes to the implementation of minimum density standards, a range should be used to reflect accessibility and potential of different areas (NPPF paragraph 130). Fundamentally, densities should be determined on a site by site basis.
In regards to the production of Design Codes, it is important that these are produced in conjunction with the Sites’ landowners/ promoters / developers to ensure they are deliverable

No

Representation ID: 108824

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

We object to the requirements set out in Draft Policy A which introduced the requirement for all new residential dwellings to comply with Nationally Described Space Standards. The PPG (Paragraph: 003 Reference ID: 56-003-20150327) states ‘that Local Authorities should consider the impact of using these standards as part of their Local Plan viability assessment.’ We understand from the Preferred Options plan (page 62) that further viability testing will be undertaken, however this has not yet been done and therefore at this stage, the requirement is not evidenced.
Additionally, the requirement for all 1 and 2 bed affordable homes to support double/twin occupancy is not justified as the HEDNA does not provide clear justification for the need for this additional bedroom requirement nor has any evidence been produced to assess the impact of this requirement on viability and the efficient use of land. The PPG also states that where local authorities set additional requirements they will need to gather evidence to determine whether there is a need for additional standards in their area, and justify setting appropriate policies in their Local Plans (Paragraph: 002 Reference ID: 56-002-20160519). This proposed policy requirement is therefore not considered to be in accordance with NPPF paragraph 36(b).
We note that the 2022 HEDNA recommends at paragraph 14.74 that all dwellings are constructed to M4(2) standard and 10% are constructed to M4(3) standard, with the potential to require a higher percentage for affordable housing. However, there is no justification within the SWLP evidence base for 25% of affordable dwellings to meet the M4(3) standard and so we consider this element of the policy to be unjustified. The PPG also states that LPAs should take into account the overall impact on viability of M4(2)/(3). This will need to be a key consideration in the Viability Appraisal that the Councils intend to prepare to support the Regulation 19 SWLP. This requirement should also be considered against national policy to make efficient use of land. Plots which are compliant with M4(2) and M4(3) standards are larger and will result in a lower density of development being achieved.

Yes

Representation ID: 108825

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

Turley, Sustainability and ESG, have undertaken a review of Strategic Objective 6 and state that Bellway supports the need to deliver development which aligns with the UK’s Net Zero trajectory, and ensures development is designed to mitigate and adapt to the effects of climate change, incorporating climate resilient design.
We support the ambition set out in the requirements outlined within this objective, noting that there are likely to be challenges with elements of these which are reflected in responses to the draft Policies.

Other

Representation ID: 108826

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

Bellway supports the need to utilise low carbon heating for new development. However, further consideration needs to be given to the feasibility and suitability of including requirements for decentralised energy systems to provide heating and cooling.
The 2025 Future Homes Standard (FHS) and Future Buildings Standard (FBS) Consultation { https://www.gov.uk/government/consultations/the-future-homes-and-buildings-standards-2023-consultation/the-future-homes-and-buildings-standards-2023-consultation} set out requirements which will significantly reduce the energy demand of new homes and buildings, this will reduce the thermal demand of new development.
Currently the majority of district heating schemes make use of gas fired Combined Heat and Power (CHP) systems to generate electricity and heat. However, the continued decarbonisation of the electricity network means that this option will emit more carbon than compared to an individual gas boiler.
Future Heat Networks will need to incorporate low carbon technologies, for example Air Source Heat Pumps, or make use of low carbon waste heat from other sources. This type of system does not benefit from the electricity generation in a CHP system which has implications for the financial viability of alternative sources.
Development coming forward after the introduction of the FHS and FBS will only be able to connect to heat networks where the energy demand of the new buildings is matched by equivalent low carbon heat, i.e. delivered through the use of a heat pump.
There may be discrete opportunities for heat networks where there are opportunities around an existing low carbon heat course, or sufficient density, for example large scale blocks of flats. This is noted in the FHS consultation, which states, ‘New low carbon communal and district heat networks will likely be the preferred way of providing heating and hot water to blocks of flats under the Future Homes Standard’. However the consultation anticipates the use of heat pumps in homes and buildings to provide heating and hot water, the policy is therefore unlikely to suit new low density development.
Further to the technical constraints noted above the Council’s evidence base supporting this particular policy does not adequately consider the implications of the FHS and FBS on the likely heating requirements and heat density of new development. Nor does it consider the cost and viability of this type of system at this stage. When considering cost consideration should be given to the implications of delivering heat networks and tying residents into long term heating contracts with no options on choice of network supplier. It is noted that while work is ongoing to regulate heat networks, heat networks are currently not regulated by Ofgem and pricing is not restricted which may impact residents energy costs.
In this context it is considered unlikely that the reduced energy demand of new development is unlikely to provide sufficient heat demand for a low carbon heat network to be feasible or viable for low destiny development. It is recommended the Council give further consideration to the technical feasibility of heat networks and costs as part of the next stage of Plan preparation to ensure any proposals are feasible and viable.

Other

Representation ID: 108827

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

Bellway supports the transition to delivering Net Zero development, however has concerns over elements of the policy as currently drafted which go against national Government guidance, have design implications which have not been thought through, and will have viability issues not yet considered. Below a number of key issues have been identified and are considered.
Written Ministerial Statement (WMS) – December 13th - Local Energy Efficiency Standards Update – In December 2023 the Government released a WMS { Written statements - Written questions, answers and statements - UK Parliament} which sets out clarity on the development and application of local energy efficiency standards in the context of advancing national policy. The WMS notes that the introduction of Part L 2021 supersedes the 2015 WMS which set guidance for Local Authorities to not set energy efficiency standards beyond Code for Sustainable Homes Level 4. The WMS goes onto note that the 2025 Future Homes Standard (FHS) will mean, ‘that homes built to that standard will be net zero ready and should need no significant work to ensure that they have zero carbon emissions as the grid continue to decarbonise. Compared to varied local standards, these nationally applied standards provide much-needed clarity and consistency for businesses, large and small, to invest and prepare to build net-zero ready homes’.
The WMS states, ‘the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations. The proliferation of multiple, local standards by local authority area can add further costs to building new homes by adding complexity and undermining economies of scale. Any planning policies that propose local energy efficiency standards for buildings that go beyond current or planned buildings regulation should be rejected at examination if they do not have a well-reasoned and robustly costed rationale.’
As part of the Bristol Local Plan Review examination the Examiner has reviewed Bristol’s Net Zero policies which set out similar energy performance targets, and as part of the main modifications has removed these requirements { Local plan examination library: examination documents}. In place of the energy performance targets the modifications include a requirement for development to achieve a 100% reduction in regulated carbon emissions only. This reason for the change is noted as the 2023 WMS set out above.
In this context it is considered that as proposed Policy contradicts the Government’s WMS and as such the space heating, total energy use and energy performance requirements should be removed or reconsidered to align with the 2023 Future Homes and Buildings Standard Consultation and WMS which describes Net Zero Ready development.
Regulated and unregulated energy - It is noted that the draft Policy relates to both regulated and unregulated energy. While we support the delivery of low carbon development it is considered any targets should be restricted to regulated energy only. Developers only have the ability to influence the regulated energy demand through design and specification of materials and systems and renewable energy technologies. However, the unregulated energy consumption, (often referred to as ‘plug in load’) of development is ultimately the function of the residents or occupiers use of the building, which cannot be influenced by the developer and therefore setting a targets for energy, energy generation and energy offsetting which include unregulated energy is not appropriate.
For example, post 2025 one of the greatest demands for unregulated energy in new homes will be to charge an electric vehicle. It unreasonable to assume that a developer should effectively meet the cost of mitigating energy and carbon from charging an electric vehicle. Similarly non-residential building uses, including commercial uses can include significant process loads, e.g. refrigeration, it is again unreasonable to assume that a developer should effectively meet the cost of mitigating energy and carbon from these uses. The responsibility of unregulated energy use and emissions therefore should sit with the building residents and occupiers.
The Governments Future Homes and Buildings Standard Consultation states in reference to setting energy intensity targets, ‘We consider that metrics which include unregulated loads are not a suitable because designers and housebuilders have little or no control over these end uses of energy.’
In addition as noted above the examination of the Bristol Local Plan has revised Policy NZC2 to relate to regulated emissions only.
In this context it is recommended that the Policy only considers requirements which relate to regulated emissions only in line with the principles set out in the 2023 WMS and the recent examination and modifications to the Bristol
Local Plan Review.
Air tightness and ventilation – The Policy states new developments are expected to achieve higher airtightness beyond the FHS, as well as consider mechanical ventilation with heat recovery.
With regards to air tightness the FHS consultation notes that as part of the consultation consideration was given to, ‘better walls, floors, roofs, triple glazing and improved thermal bridging. However, the only cost effective and practical improvement we found could be made to the standard was an improvement in airtightness. This improvement in airtightness is matched with the change to a decentralised mechanical extract ventilation system’.
The FHS aims to strike a balance of cost effective improvements, noting further improvements to fabric are not a cost effective intervention to reduce carbon emissions.
Further reductions in air tightness would necessitate the use of mechanical ventilation which has a cost implication for development beyond current and proposed future Building Regulations. Any requirements for improved air tightness and use of mechanical ventilation would need to be appropriate evidenced and considered as part of the viability assessment.
Renewable Energy Generation – The Policy sets out an expectation for residential development to include Solar PV capacity of 3kWp – 4kWp, optimising roof orientation and pitch for Solar PV where possible.
We support the provision of Solar PV to provide onsite energy generation, however, this expectation is not likely to be feasible across a development with a mix of housing including flats, bungalows and homes. Delivering 3kWp –4kWp per dwelling will require c.24-32m2 of roof space, which for smaller units will not be achievable. Furthermore, where there may be sufficient roof space available it is likely that this requirement would have unintended design implications, reducing the potential for design including roof lights, dormer windows, split roofs etc which are often considered a requirement to create a well-designed development.
In addition the technical constraints to delivery requirements for onsite energy generation need to be considered in line with the 2023 WMS noted above. Setting an energy based requirement does not align with the requirements of the WMS. Any onsite generation requirements need to be considered as part of an overarching approach to reducing carbon emissions.
Form Factor – While delivering efficient building form and the form factor of development can help reduce energy demand and therefore carbon emissions, this also needs to be considered in conjunction with the design of buildings and wider development. As with the energy generation requirements placing limits on building form may lead to unintended design implications, minimising opportunities for design which may be reflective of the local character of opportunities presented by development.

It is noted that the targets set out here are recommendations only, we would recommend that it is noted that these are set out in the context of needing to balance design with performance.
Cool and Green roofs – The draft Policy also requires residential development to include the consideration of green roofs and walls. We would note that while green roofs and walls can have multi benefits, reducing the surface run off whilst having a positive impact on biodiversity, they have a significant implication in terms of design and cost and are not suitable for residential development where residents are responsible for their ongoing maintenance. Green roofs and walls are likely to be applicable to non-residential development only and we would recommend this is removed from this Part A of this Policy.
Recommendation – It is recommended that the Plan considers the approach and Policies set out in the Warwick District Council Net Zero DPD which requires development to achieve Net Zero Carbon in operation. This provides a route to achieving Net Zero this which aligns with the Governments 2025 FHS and FBS, and 2023 Written Ministerial Statement on setting requirements which exceed the requirements of the Building Regulations.

Other

Representation ID: 108828

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

Bellway supports the need to measure and reduce the embodied carbon of development. However, the requirements of this policy will require further consideration to ensure that they are feasible and viable. The proposed targets provided from LETI and RIBA provide a mixture of targets which relate to both the upfront embodied carbon of development (stages A1-A5), as well as the whole life carbon of development (Stages A1-D4), they do not provide a consistent set of targets or consideration. We would also note that these targets are limited to a small number of potential building types and do not necessarily provide sufficient breadth of uses to be able to apply to all development. We would recommend that embodied carbon considerations focus on upfront embodied carbon as further downstream emissions cannot be controlled by the developer.
The LETI embodied carbon targets noted are delivered from the LETI 2020 Design Guide 2030 targets. While the Plan is at an early stage these targets go well beyond best practice and consideration needs to be given as to whether these are feasible and viable.
At this stage the Plan’s evidence base provides no details on the consideration of embodied carbon, or potential costs of achieving the targets set out. Recent evidence prepared to support the South Oxfordshire District Council Local Plan indicates a potential cost of c.£11k to c.£24k per plot beyond Part L 2021 to achieve the LETI targets {ITV04 Joint Local Plan Viability Report (Publication Version)}.This Policy therefore potentially carries a significant cost which will need to be considered as part of next stages of Plan development.
We would note that while embodied carbon is not currently considered by the Building Regulations, the FHS and FBS December 2023 consultation the Government stated, ‘The government intends to consult on our approach to measuring and reducing embodied carbon in new buildings in due course’. It is likely that the Government will set future national targets for embodied carbon through amendments to the Building Regulations. In the context of the Government’s December 2023 consultation we would anticipate that a future set of national embodied carbon targets would supersede local requirements.
We would recommend that the approach set out in the Warwick Net Zero DPD { Net Zero Carbon DPD-Adopted May 2024 - Download - Warwick District Council} and supporting SPD {6 Net Zero Carbon SPD-May 2024 - Download - Warwick District Council} .is followed, this requires the consideration and reduction of upfront embodied carbon, without setting a specific target at this stage. The application of specific targets needs to be fully considered as part of the Plan evidence base and viability assessment.

Other

Representation ID: 108829

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

Bellway supports the consideration of climate change and resilience in the design of new development. The design of new development is supported by various national guidance documents and requirements, including:
• Part O of the Building Regulations { https://www.gov.uk/government/publications/overheating-approved-document-o} which sets out requirements for the assessment of overheating risk in new homes.
• Environmental Agency climate change allowances {https://www.gov.uk/guidance/flood-risk-assessments-climate-change-allowances} in respect of flood risk assessment and surface water management.
• The England Biodiversity Strategy { https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/69446/pb13583-biodiversity-strategy-2020-111111.pdf} and Natural England Climate Change Adaptation Manual {https://publications.naturalengland.org.uk/publication/5679197848862720}.
As part of new design we give consideration to preventing overheating through application of the colling hierarchy as noted, focussing on passive design measures in the first instance. This can include design, orientation and tree planting.
The application of any specific targets which go beyond the requirements of the Building Regulations or national guidance needs to be fully considered as part of the Plan evidence base and viability assessment.

Other

Representation ID: 108830

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

Bellway supports the reduction of water demand through water efficiency measures. The requirements for enhanced water efficiency requirements beyond the requirements of the Building Regulations need to be appropriately evidenced.
Achieving a water use target of 100l/p/d for homes is considered achievable, as is the provider of rain harvesting water butts. However, the provision of greywater recycling systems needs to adequately consider the technical feasibility and viability of this type of system. This is only likely to be suitable for larger, commercial development and will not be suitable for residential development due to constraints over space required for storage, treatment requirements and cost.
Achieving 4 BREEAM credits for non-residential development is also likely to pose technical and viability issues.
Achieving 4 credits requires water demand to be reduce by 50% and would require the use of rainwater harvesting and greywater use.
While very large development may have the scale to overcome the technical issues noted above, smaller development will likely have similar issues around the need for greywater use, i.e. space, treatment and cost.
While broadly supportive, it is recommended the Council give further consideration to the technical feasibility and costs of this Policy as part of the next stage of Plan preparation to ensure any proposals are feasible and viable.

No

Representation ID: 108831

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

The policy states that all developments should ensure there is adequate water supply to serve the development. As per guidance set out in the Water Services Infrastructure Guide, ‘water companies have a duty to satisfy the WSI needs of development through the provision of services and monitoring compliance with water supply regulations’. Therefore it is not the developers responsibility to provide adequate water capacity. ‘Where practicable’ should be added to the third bullet point to provide some flexibility where connections into existing infrastructure is required. “Avoid surface water connections into existing surface water and combined sewer networks, where practicable, and manage runoff through suitably designed SuDs schemes”.