Other

ID sylw: 107743

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

Bellway supports the need to utilise low carbon heating for new development. However, further consideration needs to be given to the feasibility and suitability of including requirements for decentralised energy systems to provide heating and cooling.
Currently the majority of district heating schemes make use of gas fired Combined Heat and Power (CHP) systems to generate electricity and heat. However, the continued decarbonisation of the electricity network means that this option will emit more carbon than compared to an individual gas boiler.
Future Heat Networks will need to incorporate low carbon technologies, for example Air Source Heat Pumps, or make use of low carbon waste heat from other sources.
Further to the technical constraints noted above the Council’s evidence base supporting this particular policy does not adequately consider the implications of the FHS and FBS on the likely heating requirements and heat density of new development. Nor does it consider the cost and viability of this type of system at this stage.
It is recommended the Council give further consideration to the technical feasibility of heat networks and costs as part of the next stage of Plan preparation to ensure any proposals are feasible and viable.

Other

ID sylw: 107744

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

Bellway 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. Below a number of key issues have been identified and are considered.
As part of the Bristol Local Plan Review examination the Examiner has reviewed Bristol’s Net Zero policies which set out similar energy performance targets, and as part of the main modifications has removed these requirements3 . In place of the energy performance targets the modifications include a requirement for development to achieve a 100% reduction in regulated carbon emissions only. This reason for the change is noted as the 2023 WMS set out above.
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.
While we support the delivery of low carbon development it is considered any targets should be restricted to regulated energy only.
With regards to air tightness the FHS consultation notes that as part of the consultation consideration was given to, ‘better walls, floors, roofs, triple glazing and improved thermal bridging. However, the only cost effective and practical improvement we found could be made to the standard was an improvement in airtightness. This improvement in airtightness is matched with the change to a decentralised mechanical extract ventilation system’.
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. Furthermore, where there may be sufficient roof space available it is likely that this requirement would have unintended design implications, reducing the potential for design including roof lights, dormer windows, split roofs etc which are often considered a requirement to create a well-designed development.
It is noted that the form factor targets set out here are recommendations only, we would recommend that it is noted that these are set out in the context of needing to balance design with performance.
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 this which aligns with the Governments 2025 FHS and FBS, and 2023 Written Ministerial Statement on setting requirements which exceed the requirements of the Building Regulations.

Other

ID sylw: 107745

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

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. We would also note that these targets are limited to a small number of potential building types and do not necessarily provide sufficient breadth of uses to be able to apply to all development. We would recommend that embodied carbon considerations focus on upfront embodied carbon as further downstream emissions cannot be controlled by the developer.
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.

Other

ID sylw: 107746

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

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
As part of new design we give consideration to preventing overheating through application of the colling hierarchy as noted, focussing on passive design measures in the first instance. This can include design, orientation and tree planting.
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: 107747

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

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.
While very large development may have the scale to overcome the technical issues noted above, smaller development will likely have similar issues around the need for greywater use, i.e. space, treatment and cost.
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: 107748

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

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: 107749

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

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: 107750

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

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.
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: 107751

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

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.

Other

ID sylw: 107752

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

Bellway are generally supportive of draft Policy Direction 28 which states that ‘Development that supports the regeneration of canals and would improve access and sense of place will be supported’. However, contributions sought to deliver restoration of canals/waterways as part of a development must be fair, directly related and acceptable in planning terms, paragraph 58 NPPF.