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2.22 Climate change mitigation (10.1 and 10.2) 2.22.1 The requirement for proposals to include a climate change checklist for major developments (as defined in the NPPF) is supported (C.10.b). 2.22.2 Question C10.2 asks for any additional comments in relation to Climate Change Risk Assessments. It is suggested that the Council’s should prepare the checklist and associated guidance and ensure that it is proportionate to the development that is proposed.

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Q-C10.1 49. The inclusion of a climate change risk assessment based upon a clear and relevant checklist for some larger planning applications is appropriate but not for all schemes. A threshold of 50 dwellings is proposed.

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Q-C10.1 51. The inclusion of a climate change risk assessment based upon a clear and relevant checklist for some larger planning applications is appropriate but not for all schemes. A threshold of 50 dwellings is proposed.

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51. The inclusion of a climate change risk assessment based upon a clear and relevant checklist for some larger planning applications is appropriate but not for all schemes. A threshold of 50 dwellings is proposed.

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Q-C10.1 48. The inclusion of a climate change risk assessment based upon a clear and relevant checklist for some larger planning applications is appropriate but not for all schemes. A threshold of 50 dwellings is proposed.

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Q-C10.1 49. The inclusion of a climate change risk assessment based upon a clear and relevant checklist for some larger planning applications is appropriate but not for all schemes. A threshold of 50 dwellings is proposed.

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The Vision Document (enclosed at Appendix 1) includes a draft Sustainability Strategy which contains measures that could be delivered at Hatton New Community to ensure it is delivered as a zero-carbon settlement with exceptional levels of environmental sustainability. Hill Residential is leading the house building industry with the adoption of low and zero carbon building models and the scale of growth at Hatton will afford Hill Residential the flexibility to improve on their own very high standards. The 2025 Future Home Standard (FHS) will require every new home in England to produce 75% to 80% less carbon emissions (it ‘will also be a ‘zero carbon ready’ standard, switching off fossil fuels and becoming zero carbon as the grid decarbonises) than those currently being built. A stepping-stone to that target came into place, with homes built from June 2022 required to deliver 31% less carbon emissions than necessary under previous regulations. In advance of these policy and regulatory changes Hill Residential, along with partners, in 2020 adopted and trialled a range of certified Passivhaus, and Active Homes project research and development schemes. Each example is achieving the 75% to 80% reductions, in low through to high density homes and apartments. During 2022, Hill Residential developed solar form design guides and Passivhaus Playbooks. In 2023 they will further develop this knowledge into Residential Pattern Books to enable them to create the appropriate low carbon pathways, to achieve 2025- 2030 transition strategies. Currently, all Hill Residential’s homes are designed to optimise water usage of 105 litres per person per day (lpppd) and they have also delivered homes in Cambridge that achieve 100lpppd. In parallel Hill Residential are developing a better understanding of whole life carbon and circular economy strategies which will inform the homes they build at Hatton. Hill Residential are future-proofing new schemes and homes through climate change, adaptation, and resilience strategies. This includes public realm sustainable urban drainage systems (SuDs), subterranean engineered solutions and green (brown) roofs to mitigate surface water flooding risks - in response to the predicted transitional and physical climate change risks. Hill Residential are also committed to deploying varying forms of Modern Methods of Construction (MMC) as the progress towards the introduction of the FHS from 2025 and their voluntary net zero pathway commitments as set out within the Vision Document (Appendix 1).

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Q-C10.2. Further information/ evidence testing and further consultation is required in relation to the need for new development to undertake a Climate Change Risk Assessment. At present, based on the information available it could be viewed as duplication of other proposed policies (such as adapting to higher temperatures, carbon emission etc).

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Q-C10.1: Should be aligned with the national approach.

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Issue C10: Climate change Risk Assessments. Whilst the contents of the single paragraph seem sensible, will this process be fit for purpose in 2050?. We support Option C10.1a. It is important that a climate change risk assessment is required by planning for all new developments.

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Q-C10.1 50. The inclusion of a climate change risk assessment based upon a clear and relevant checklist for some larger planning applications is appropriate but not for all schemes. A threshold of 50 dwellings is proposed.

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Issue C10: Climate change Risk Assessments. Whilst the contents of the single paragraph seem sensible, will this process be fit for purpose in 2050? It is important that a climate change risk assessment is required by planning for all new developments. A barrier here is the fact that the climate emergency is NOT considered to be a material planning issue. Can this be mandated in the SWLP?

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Should be aligned with the national approach.

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Q-C9.1: Please select the option which is most appropriate for South Warwickshire 5.4. Rainier are supportive of the need to address net losses to biodiversity through the provision of enhancement to deliver an overall net gain. The Environment Act will require all development to provide at least a 10% Biodiversity Net Gain (BNG) increase and there would be no objection to this being carried through into a local policy. Indeed, it would reflect one of the core principles of the NPPF to conserve and enhance the natural environment. 5.5. Any such policy though, should be drafted to provide as much flexibility as possible. The test is whether the 10% BNG is delivered, not the method by which it is delivered. It is important that the way in which ‘net gains’ are calculated is given careful consideration and a pragmatic view should be taken in terms the delivery of biodiversity enhancements where there are clear landscape and habitat improvements, rather than being wholly reliant on the output of a rigid calculator, in particular where this could impede viability and thus the delivery of much needed housing. It should also allow for contributions to be made towards off-site mitigation with suitable receptor sites or projects identified through the Local Plan process to secure the deliverability of development.

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Issue C10 – Climate Change Risk Assessments Climate Change Risk Assessments (or Checklists) should not be required for all new build development and changes to existing buildings (option C10.1c). Such a requirement is likely to be unduly onerous and disproportionate in many cases, particularly where planning applications are submitted for minor developments or works to existing buildings.

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Q-C10.1: The Plan should be ambitious in its thinking. As a minimum we should look for Option C10a but ideally, we should aim for C10b.

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Q-C10.1: Should be aligned with the national approach.

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Q-C10.1: Should be aligned with the national approach.

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Q-C10.1: Option C10.1c should be followed, whereby none of the above options are suitable. The Church Commissioners is supportive of measures to tackle climate change, but clarity should be provided as to what is actually required through a Climate Change Risk Assessment. It is not clear at present and therefore a evidenced decision is not possible on the most appropriate option to address climate change, based on the information and wording available. As a result, the Councils should conduct further research to inform their evidence base, prior to deciding whether a Policy is required and to what extent.

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Issue C10 – Climate Change Risk Assessments 5.26.1 St. Modwen supports a policy requirement for proposals for new development and changes to existing buildings to provide a climate change checklist setting out the appropriate range of adaptation and mitigation measures to be incorporated. We believe a checklist setting out the appropriate range of adaptation and mitigation measures to be incorporated would be a more appropriate policy solution and allow applicants the flexibility to approach net zero carbon ambitions and their response to climate change in a way that responds to their application.

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As noted within the I&O consultation, Stratford District Council already require a similar assessment, (Development Requirements SPD Part V on Climate Change Adaptation and Mitigation) as a validation requirement for all planning applications. Additional guidance to support this checklist would be useful for applicants/developers to assist with completing the checklist.

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Q-C10.1: Option C10.1c should be followed, whereby none of the above options are suitable. Caddick Land is supportive of measures to tackle climate change, but clarity should be provided as to what is actually required through a Climate Change Risk Assessment. It is not clear at present and therefore a evidenced decision is not possible on the most appropriate option to address climate change, based on the information and wording available. As a result, the Councils should conduct further research to inform their evidence base, prior to deciding whether a Policy is required and to what extent.

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Q-C10.1: The SWLP should not be imposing additional requirements over and above national guidance.