Royal Leamington Spa Neighbourhood Development Plan

Climate Emergency.

I can find no reference to the Climate Emergency Motion and action plan that has been developed by Warwick District Council.


5.1 Housing Development.

Housing Design

Paragraph 5.1.9 states quote …….”There is also a need to ensure that new housing achieves the highest possible standards in terms of environmental performance, thereby reducing impact on the environment and climate change”

The highest possible standard would be to build to net zero carbon and Policy RLS2 certainly will not deliver this. Setting a net zero carbon standard such as Passivhaus Plus or equivalent would certainly fit with the second commitment of the WDC Climate Emergency strategy namely quote:


2.Facilitating decarbonisation by local businesses, other organisations and residents so that total carbon emissions within Warwick District are as close to zero as possible by 2030.

Retrofitting to net zero carbon is a lot more expensive than setting out with that standard at the start.

The Committee on Climate Change have calculated that the extra cost of building to a 15kWh/m2/yr standard (e.g Passivhaus standard or equivalent.) as opposed to the current building regs level would be around £4,800 per dwelling, while the cost of retrofitting to this standard would be £26,300. So taking into account the WDC Climate Emergency strategy why would the Neighbourhood Plan not mandate a 15kWh/m2/yr standard to fit with the Climate Emergency ambition?


The statement within Policy RSL2 – quote “Applicants are encouraged to go beyond prevailing sustainable development standards particularly with regard to environmental performance of buildings……….” is probably worthless and developers will just say that they are ‘policy compliant with the Local Plan and build to the out-dated 2013 building regulations.

I use as evidence of this Kenilworth Neighbourhood Plan Policy KP15 which has similar wording.

Policy KP15 Environmental Standards of New Buildings

Development proposals are encouraged to adopt higher environmental standards of building design and energy performance such as the Passivhaus or similar approach.

5.69 This policy seeks to encourage applicants to incorporate the highest
environmental standards of building design and performance. The public sector has an important role to play in demonstrating the practicalities and long term benefits of adopting high environmental building standards.

To date in every planning application submitted to the WDC Planning Committee developers have completely ignored this policy.

Could I suggest that the LSNP uses words similar to those included in WDC Local Plan Policy CC3 when highlighting decentralised heating networks. I would suggest replacing the words “Applicants and encouraged to go beyond ……” by “The Council will expect the applicants to consider going beyond……….”

I would further suggest adding the following paragraphs:

Development within the scope of the policy will be required for higher environmental standards to incorporate the assessment into the Sustainable Building Statement submitted with the planning application.

Promoting higher environmental standards forms an important part of central government’s decarbonisation strategy and in addition the Council’s Climate Emergency strategy.

Policy RLS2 goes on to state developers should aim to achieve Level 4 of the Code for Sustainable Homes. I have two comments to say about this:

1. The Code for Sustainable Homes was abolished by the Conservative administration in 2015.
2. The Code for Sustainable Homes is (or rather was) approximately a 20% improvement above the current building regulations. Why would you ask for a 20% improvement when the current consultation on building regulations was recommending the option for a 31% improvement?

Fabric First

It is important to include a Policy that developers must adopt a Fabric First approach to the design of new buildings


Performance Gap.

It is vitally important to have a policy that addresses the ‘performance gap’.

Within the UK, buildings are required to comply with a design standard set by building regulations currently the out dated 2013 regulations. In mainland Europe and elsewhere internationally, buildings are required to comply with a performance-in-use standard. The so called ‘performance gap’ is the difference in performance between the design intent and what is actually achieved post construction, and this ‘performance gap’ is of critical importance to the user………and the planet!

As evidence of the importance of mitigating the performance gap I would refer to an intensive study into new domestic and non-domestic buildings carried out under the Technology Strategy Board/Innovate UK’s Building Performance programme which revealed a typical performance gap of between 2.5 and 4 times for energy use. A secondary school that was reviewed recently by a colleague from the Passivhaus Trust found that the building was using 5 times more energy than was predicted.
I would recommend that a policy be added to the Leamington Neighbourhood Plan along the lines as has been develop by Milton Keynes Council.

The Developer must implement a recognised quality regime that ensures the ’as built’ performance (energy use, carbon emissions, indoor air quality, and overheating risk) matches the calculated design performance of dwellings. The Developer must put in place a recognised monitoring regime to allow the assessment of energy use, indoor air quality, and overheating risk for 10% of the proposed dwellings for the first five years of their occupancy, and ensure that the information recovered is provided to the applicable occupiers and the planning authority.

Sustainable Urban Drainage Systems (SUDS)

No development scheme should take place without a detailed SUDS strategy. This will help with many items of resilience, for example improving flood prevention.

Development Plan Documents. (DPD)

I can see no reference to the DPD currently being developed by Warwick District Council.