Please see attached

Re:" a) Considering the potential to utilise large scale renewable or low carbon energy sources such as heat networks or local large-scale renewable energy generation sources, preferably through a direct connect." As before 'considering' is not strong enough - there needs to be more muscle, more bite, to this.

Re: offsets - these need looking at carefully so that they are *real* and not 'greenwashing'. The offset industry is full of loopholes - they must not be allowed.

This is an emergency. Zero carbon cannot be achieved using low carbon sources. Low is not zero - and how low do you mean? This looks like a get-out option which should be removed.
Carbon offsetting is also problematic and too easily used as a get-out. "Burn now - offset later" should not be an option. Any offsetting for the building construction must be within the time frame of the building construction. Any offsetting required from the use of the building must be equivalent and run at the same time as the carbon usage.
The wording suggests WDC is not seriously committed to this. "Should", "expected" and "considered" do not mean the same as "must", "required" and "delivered". There should be no wiggle room and the policy should be explcit in defining what is required.

'Offsetting should be delivered within or as close as possible to the development' - this is absolutely vital. But this policy should go further and say 'no further than 1 mile from the development' so that developers cannot plant trees in far away districts which are of no benefit to the local people whose green fields, trees and hedgerows are being built on. In Bishop's Tachbrook AC Lloyd offset biodiversity losses by securing land in Alcester, in a different district. This cannot be allowed to happen under this policy.

This is both vital and sensible.

The policy states new development should achieve net zero carbon emissions through reducing energy demand, incorporating zero or low carbon energy sources, and offsetting residual operational emissions to net zero.
While Policy NZC1 states development should be net zero, it does not clearly present the definition of net zero, nor what is meant by being, ‘net zero carbon at the point of determination of planning permission’ as referenced in Policy NZC2(D).
To meet the overarching policy requirement the following sub-policies are proposed:
• Policy NZC2(A) requires development to achieve a 75% carbon reduction above Part L 2013, this relates to the regulated emissions of new development only.
• Policy NZC2(B) sets out a requirement for development to consider zero and low carbon sources of energy. It is noted that the supporting text for this policy states this clause requires an Energy Statement to be prepared setting out how the residual energy demand of development should be met, however this is not what the Policy as it currently stands requires.
• Policy NZC2(C)) sets out the use of ‘net zero ready’ technology in the event fossil fuels are used onsite.
• Policy NZC2(D) states that where development cannot demonstrate that it is net zero carbon at the point of determination of a planning permission, is required to address residual carbon emissions via payment to the Council’s fund or approved alternative.
These policy requirements do not clearly define net zero, or how these policies require development to reduce emissions before offsetting. While we note that net zero is the likely intent of the policies it is not currently clear what definition of net zero the Council is using, nor does the policies definitively set out what the onsite building level requirement is.
Given the issues of viability in Section 1 we believe that this Policy is amended to align with the requirements and timings of the Future Homes Standard (FHS) and national guidance which is aiming to deliver Net Zero Ready housing over time.