No

ID sylw: 107830

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

The justification for this policy is weak. No evidence is provided that the size of new homes is diminishing and only two appeal decisions have been considered. The Homes England Capital Funding Guide does not require NDSS compliance. 85% of NDSS is generally accepted as the benchmark for grant-led affordable homes. Robust justification, viability testing, and evidence will be required to justify this policy. If pursued, the policy should be flexible enough to allow well-designed house types slightly below NDSS, particularly on sites where most dwellings comply. There should be provision for additional flexibility for affordable housing as many registered providers have their own requirements.

The draft policy also states homes should be provided to M4(2) and M4(3) standards. This must be based on evidence to be justified as per Footnote 51 of the NPPF. The HEDNA recommends that all should meet M4(2) standards and 10% M4(3) but the HEDNA is now out of data so a refreshed study would need to look at this issue. Catesby Estates believe this policy is unnecessary as the Building Regulations Part M provides specific requirements for M4(2), M4(3) standards and these do not need to be repeated in development plan policy.

Other

ID sylw: 107831

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

Self Build & Custom Housebuilding Register had 345 people on it as of 31st March 2024. Warwick’s Register had 95 people on it as of 2019, which is the latest published position. Table 13.1 of the HEDNA identifies that serviced plot demand for self-build dwellings is 63 plots per annum. Evidence exists to suggest a need for custom and self-build plots, and we therefore support in principle a policy relating to delivery of such plots, although the evidence needs to be refreshed.

The policy should be amended to provide flexibility rather than a 5% of developable area on schemes over 99 dwellings. There will also be separate self-build allocations and windfall sites. Areas should not be sterilised and prevented from delivering other forms of housing to contribute towards meeting a different need which may be more appropriate and with more demand in the area. There could be reference to a trigger for releasing self-build plots on sites where there is no demand for them.

Other

ID sylw: 107832

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

Paragraph 165(c) of the NPPF states plans should identify opportunities for development to draw its energy supply from decentralised energy supply systems. This is what the draft policy seeks to achieve. It does not make this obligatory and simply encourages use and development of such systems, with regard given to viability considerations. This is supported, as it means the policy will not risk undermining the effectiveness and deliverability of the plan where it is not possible for a scheme to comply with this.

The draft policy states developments will be required to demonstrate a ‘thermal master planning approach’ to maximise energy efficiency opportunities. Clarity should be provided on what this means for developers, along with clear justification for including this within the policy.

The draft policy will require an Energy Statement to be submitted as part of a planning application. It is acknowledged there is support for this requirement within the evidence base, with the Climate Evidence on Renewables and Decentralised Energy Opportunities (May 2024) report recommending this. The building performance standards which Energy Statements will need to demonstrate are met should not exceed the requirements of the national Building Regulations.

No

ID sylw: 107835

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

This policy stipulates new buildings should be designed and built to be net zero. This exceeds requirements in the Building Regulations. The Government’s response to the Future Homes Standard consultation in 2023 stated policy shouldn't be prescriptive on methodology and technology. Until there is an upgrade to the grid, developers only need to demonstrate dwellings are zero carbon enabled.

The Government don't expect plan-makers to set standards that go beyond current or planned Building Regulations. Existing standards don't have to be duplicated in planning policies. The Councils don't have a well-reasoned and robustly-costed rationale and haven't undertaken viability assessments. This policy is therefore unsound. Onerous energy efficiency requirements can severely undermine development viability. This should have been acknowledged in the SA.

The industry is moving towards zero-carbon ready housing as standard. Transitional arrangements must be in place to ensure this can be done smoothly. The plan must avoid onerous requirements which may jeopardise short-term delivery. Note that achievement of net zero is unlikely to be feasible for all developments, particularly urban brownfield developments. Policy should be flexible/deferential to changes in national standards.

The stepped change to zero carbon under the programmed future Building Regulation changes gives developers certainty and allows the industry to develop solutions collaboratively. Following this standard allows the industry to benefit from cost efficiencies and certainty associated with delivery of mass-produced proprietary products, which will better address viability and delivery of development to meet the Council’s planned housing trajectory.

The supporting text indicates relying on Building Regulations alone will be insufficient to achieve net zero by 2050. However, Building Regulations are under continuous review and the Government are aware of the need to meet net zero. Building regulations will continue to evolve when appropriate.

Other

ID sylw: 107837

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

It is proposed to address embodied carbon in the Building Regulations within a new Part Z. The Government’s Building to Net Zero: Costing Carbon in Construction (May 2022) report recommends embodied carbon and whole-life carbon assessments for buildings are established in the Building Regulations. Local Authorities are only encouraged to include such a requirement within Local Plans – the fact that this is not advised to be mandatory confirms that allowing Building Regulations alone to cover this is sufficient. In any event, viability will be an important consideration. We support the acknowledgment that applicants can submit a justification where achieving embodies carbon targets is unviable.

No

ID sylw: 107838

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

Again, these matters are already covered by the Building Regulations, and as such do not need to be addressed in a policy which goes beyond these. The Building Regulations will apply, and developers will need to adhere to these, securing climate resilient design with or without a development plan policy on this.

It is noted that the policy seeks to introduce a climate change checklist for South Warwickshire, which will need to be completed and submitted as part of planning applications. Further details should be provided on what this checklist covers, whether in the policy or within the supporting text. In addition, there should be a clear justification for referencing this within the policy, and the requirements which will need to be met. The checklist must not place onerous requirements on developers which exceed the requirements of the Building Regulations.

No

ID sylw: 107839

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

The proposed water efficiency standard of 100 litres per person per day notably exceeds that in the Building Regulations (125 litres per day, with the option for authorities to reduce it to 110 litres per day). It is acknowledged that the evidence base, namely the Coventry and Warwickshire Sub-Regional Water Cycle Study (August 2024), recommends a planning policy to require a water efficiency target of 100 litres per day to be achieved using a fittings- based approach, due to evidence of pressures on the environment, and on public water supply. Thus, such a policy, though unnecessary given that this is addressed in the Building Regulations, could be justified.

Other

ID sylw: 107840

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

This is a comprehensive policy which is generally consistent with national guidance on flood risk in the NPPF and PPG. Notably, the sequential and the exception tests for flooding, referred to in Paragraphs 173 – 178 of the NPPF, are omitted from the policy, although these are briefly discussed in the supporting justification. It is recommended that reference to both tests should be made within the policy itself; this will need to acknowledge, as per Paragraph 175 of the NPPF, that the sequential test is not necessary in situations where a site-specific flood risk assessment demonstrates that no built development within the site boundary, including access or escape routes, land raising or other potentially vulnerable elements would be located on an area that would be at risk of flooding from any source. Paragraph 176 adds that applications for some minor development and changes of use should also not be subject to the sequential test. In line with Paragraph 180 of the NPPF, planning applications for sites allocated in the South Warwickshire Plan, applicants would not need to apply the sequential test again.

Other

ID sylw: 107842

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

This policy is broadly supported, although the Councils are reminded that whilst Paragraph 181 of the NPPF encourages the incorporation of sustainable drainage systems, it also recognises that this is unnecessary where there is clear evidence that this would be inappropriate. As such, the policy must make clear that there may be instances in which exceptions can be made, with SUDS not delivered providing that there is a clear justification for this, in line with the NPPF.

Furthermore, the policy should be amended to allow for more flexibility, for example, below- ground SUDS features may be suitable in some instances, and there may be sites and schemes where it is not possible to achieve a site-wide dispersal of SUDS, as currently stipulated in the draft policy. It is noted that the NPPF provides no such requirements for SUDS.

No justification from the Council has been provided for this policy. This may have been omitted in error, but it is imperative for the emerging policy to be fully justified to be found sound. It is considered that the policy can be adequately justified, subject to the amendments recommended above.

Other

ID sylw: 107845

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

Catesby Estates Plc support high quality design. The overarching strategic design principles align with national policy.

The policy direction refers to 20-minute neighbourhoods, which the SA notes would result in positive impacts for many SA Objectives. The policy should clearly define the principles of such neighbourhoods. This may be based on the Town and Country Planning Association (TCPA)’s 20-minute Neighbourhoods guidance (March 2021). It will be necessary to clarify that meeting these principles may not be possible for all developments, particularly in more rural locations. 20-minute neighbourhoods are typically associated with urban areas - existing towns, urban extensions, and new settlements. It is easier to deliver facilities and services in denser areas. Higher densities may not be appropriate for all sites, particularly in rural settlements, as recognised in Paragraph 130 of the NPPF.

The TCPA’s guidance acknowledges the challenges of implementing 20-minute neighbourhoods in rural areas, noting two approaches:

• Focus on achieving a complete and compact 20-minute neighbourhood nearby such as a local market town, which residents in comparatively smaller settlements can travel to.
• Create a network of villages that collectively provide what most people need for their daily lives. This aligns with NPPF Paragraph 83, which states development in one village may support services in a village nearby.

NPPF Paragraph 82 states thousing developments in rural areas should meet local needs and Paragraph 83 that this should be located where it will enhance or maintain the vitality of communities. It will be important for the Councils to justify inclusion and promotion of 20-minute neighbourhoods in the next stage of the plan if this is to become a central part of this policy.