The incorporation of policy measures on ‘adapting to higher temperatures’ should reflect national policy or building regulation requirements. Policy measures should allow for project and site specific considerations, and there is a need to ensure that any measures/requirements are viable and deliverable. Aligning local requirements with national requirements will mean that the industry is able to suitably adapt to new requirements and future policies are not so onerous as to discourage investment within South Warwickshire. General measures such as the provision of green infrastructure can be delivered through other policies in the emerging plan.

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It is important that any policy measures relating to biodiversity do not dictate site specific biodiversity enhancement requirements (e.g. larger developments to have less than 50% of the wider site consisting of hard surfaces), as applicants and developers will need to comply with wider national legislative biodiversity requirements that are coming forward through the Environment Act. The policy must allow the applicant and its design team to evolve its own strategy for mitigation and biodiversity net gain based upon the character of the site; the nature of the development; the existing green infrastructure; the needs of any local biodiversity strategies; and wider technical considerations such as the integration of the surface water drainage system. Therefore, Bourne Leisure considers that Option C9.1b is the appropriate approach for the SWLP. Stratford-on-Avon and Warwick District Councils might consider preparing separate guidance outside the Statutory Development Plan, which provides ideas/suggestions on biodiversity enhancement options for applicants as an alternative to a policy requirement.

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As per Option C10.1c, Climate Change Risk Assessments (or Checklists) should not be required for all new build development and changes to existing buildings. Such a requirement would be unduly onerous and disproportionate in many cases, particularly where planning applications are submitted for minor developments or works to existing buildings. Often relevant information is already provided across the lengthy suite of application documents submitted for major applications. The need to prepare a checklist or further assessment is likely to create duplication. If a Risk Assessment is taken forward, it is vital that the LPA has sufficient expertise to review these assessments rather than putting additional burden upon applicants unnecessarily. Checklists, that are not a mandatory submission document, may be a helpful prompt for applicants to consider as part of the design process and would not result in the duplication of efforts or require the need for applicants to instruct additional parties to prepare application material

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Bourne Leisure considers that Option T2a should be pursued as it seeks a hierarchical approach to prioritising transport infrastructure. This is vital for businesses in rural areas, as such an approach Pg 5/6 26338513v4 recognises the challenges within rural areas regarding accessibility to different sustainable transport methods. The hierarchical approach will also help to support existing rural businesses that inevitably rely more heavily on private vehicles and will continue to need to invest as part of wider objectives in the plan

Yes

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