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ID sylw: 107871

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Taylor Wimpey 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.
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.
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.
It is noted that the draft Policy relates to both regulated and unregulated energy. While Taylor Wimpey 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.
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.
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.
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.
We would recommend that it is noted that Form Factor are set out in the context of needing to balance design with performance.
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 multiple 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.
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 which aligns with the Governments 2025 FHS and FBS, and 2023 23 Written Ministerial Statement on setting requirements which exceed the requirements of the Building Regulations.