Other

ID sylw: 106969

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

Bellway supports the need to measure and reduce the embodied carbon of development. However, the requirements of this policy will require further consideration to ensure that they are feasible and viable.
The proposed targets provided from LETI and RIBA provide a mixture of targets which relate to both the upfront embodied carbon of development (stages A1-A5), as well as the whole life carbon of development (Stages A1-D4), they do not provide a consistent set of targets or consideration.
At this stage the Plan’s evidence base provides no details on the consideration of embodied carbon, or potential costs of achieving the targets set out.
We would recommend that the approach set out in the Warwick Net Zero DPD5 and supporting SPD6 is followed, this requires the consideration and reduction of upfront embodied carbon, without setting a specific target at this stage. The application of specific targets needs to be fully considered as part of the Plan evidence base and viability assessment.

Yes

ID sylw: 106970

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

Bellway supports the consideration of climate change and resilience in the design of new development. The design
of new development is supported by various national guidance documents and requirements, including:
• Part O of the Building Regulations7 which sets out requirements for the assessment of overheating risk in
new homes.
• Environmental Agency climate change allowances8
in respect of flood risk assessment and surface water
management.
• The England Biodiversity Strategy and Natural England Climate Change Adaptation Manual
The application of any specific targets which go beyond the requirements of the Building Regulations or national
guidance needs to be fully considered as part of the Plan evidence base and viability assessment.

Other

ID sylw: 106971

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

Bellway supports the reduction of water demand through water efficiency measures. The requirements for enhanced water efficiency requirements beyond the requirements of the Building Regulations need to be appropriately evidenced.
Achieving a water use target of 100l/p/d for homes is considered achievable, as is the provider of rain harvesting
water butts. However, the provision of greywater recycling systems needs to adequately consider the technical feasibility and viability of this type of system.
Achieving 4 BREEAM credits for non-residential development is also likely to pose technical and viability issues.
Achieving 4 credits requires water demand to be reduce by 50% and would require the use of rainwater harvesting and greywater use.
While broadly supportive, it is recommended the Council give further consideration to the technical feasibility and costs of this Policy as part of the next stage of Plan preparation to ensure any proposals are feasible and viable.

No

ID sylw: 106972

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

The policy states that all developments should ensure there is adequate water supply to serve the development. As per guidance set out in the Water Services Infrastructure Guide, ‘water companies have a duty to satisfy the WSI needs of development through the provision of services and monitoring compliance with water supply regulations’. Therefore it is not the developers responsibility to provide adequate water capacity.
‘Where practicable’ should be added to the third bullet point to provide some flexibility where connections into existing infrastructure is required. “Avoid surface water connections into existing surface water and combined sewer networks, where practicable, and manage runoff through suitably designed SuDs schemes”.

No

ID sylw: 106973

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

This policy is prescriptive and does not allow much flexibility to site specific circumstances. ‘Where possible, practicable and viable’ should be added throughout.
The policy requires sites which include existing watercourses to appraise the risk of flooding, this may be through hydraulic modelling. The policy also notes that development layout should be sympathetic to any existing watercourse and overland surface water flow routes. The policy should align with national guidance which seeks for built development to avoid areas at risk of flooding, public open space within an area at risk of flooding should be supported (NPPF paragraph 175).

Other

ID sylw: 106974

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

Bellway is generally supportive of the principles set out in draft Policy Direction 25. However, the design principles set out are not justified unless they are to be considered on a site-by-site basis and incorporate flexibility to adapt to site specific circumstances. Design codes should not be overly prescriptive or restrictive where they are not
informed by detailed evidence and engagement with the Applicant team.
In addition the reference in the Policy Direction to ‘the principles of the 20-minute neighbourhood’ should be applied flexibly. At present the wording of the policy does not define what is considered to be ‘a reasonable walking distance of their homes’ or acknowledge potential implementation challenges.
It is noted that page 3 of the “Guide to existing housing densities in South Warwickshire” (January 2023), which forms part of the SWLP technical evidence, defines a 20-minute neighbourhood as “every-day services to be accessible within a 10-minute walk or cycle each way”. This is an unrealistic aim for larger strategic residential developments located adjacent to larger settlements, as well as developments within smaller settlements, where
infrastructure constraints and service provision limitations make such proximity difficult to achieve.
Accordingly any design measures must be justified with evidence (as required by paragraph 36 of the NPPF) and worded to allow for site-by-site consideration of requirements, rather than apply a blanket approach to new development.

Other

ID sylw: 106975

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

Table 8 states that the production of site-specific design codes will be led by the SWLP team. The production of site-specific design codes should be done with collaboration between SWLP and sites’ landowners / developers / promoters to ensure effective engagement and the site’s deliverability.

No

ID sylw: 106976

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

The Policy Direction requires major development to be supported by a Health Impact Assessment. It is considered that the plan should set a threshold for what the policy considers to be ‘major’ to ensure that the policy and requirements are clear (NPPF paragraph 16d). Without a clear threshold, assessments could become inconsistent and create uncertainty. Therefore it is important that the Policy Direction provides the necessary clarity to ensure the requirement is justified (as required by paragraph 36 of the NPPF).
Policy Direction 30 states that: “developments with significant negative impact on health and wellbeing will not be supported unless mitigated or compensated for through planning obligations”. This is a broad statement and does not define what is considered a constitute a negative impact on health. It should accordingly be made clear that any mitigation / compensation should be site specific, and would need to comply with the tests set out in Regulation 122(2) of the Community Infrastructure Levy Regulations 2010 (as amended).

Other

ID sylw: 106977

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We are generally supportive of draft Policy Direction 31. Bishop’s Tachbrook is part of proposed Strategic Growth Location SG10 which has been identified for growth and the settlement is also located in Priority Area 3, therefore is considered a sustainable and accessible location suitable for accommodating growth.
The second part of the Policy proposes to require developments to demonstrate that they will incorporate or contribute towards the provision of cycle lanes, pedestrian paths and public transport and public transport links should be integrated into the development. The policy should specifically note that not all development will be of a scale to enable public transport links through the site. Additionally, only developments subject to a S106 Agreement would be able to contribute to off-site sustainable access improvements and any requests for upgrades will be required to demonstrate that they are complaint with Section 122 of the Community Infrastructure Levy Regulations 2010.

No

ID sylw: 106978

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

Bellway object to draft Policy Direction 32, providing that it does not seek to go beyond the Building Regulations.
As the Council is seeking to go beyond these requirements in emerging policy, then suitable evidence is required to be provided to ensure it is justified in line with paragraph 36 of the NPPF.
Turley, Sustainability and ESG, have undertaken a review of Policy Direction 32 and state that in addition to setting out a strategy for EV charging infrastructure within Council buildings and public realm the Policy notes the need for robust policies for EV structure in new development.
Bellway supports the installation of EV infrastructure and notes that Part S of the Building Regulations11 sets out requirements for EV charging in new development, with an EV charger required for every house with dedicated parking, as well as non-residential development requirements.
The policy notes the greatest challenge is installing EV charging infrastructure in existing areas, in particular this will include urban areas with terrace housing, where the lack of charging infrastructure and low cost charging is a barrier to uptake of EVs.
Turley have agreed in their review that any provision beyond the Building Regulations will need to be justified, evidenced and considered as part of a viability assessment.