Other

ID sylw: 108924

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire County Council

WCC Ecology would like the policy to include a porous surface metric to be included in the policy. A simple metric that calculates the current and future permeable surface values based on the CIRIA methodology and where there is a residual loss compensation is required. Reason: to ensure aquifer recharge is not impacted upon through development.

Yes

ID sylw: 108925

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire County Council

WCC welcomes the consideration of large-scale renewable energy generation and storage as this will provide an important aspect of decarbonising the county of Warwickshire and being able to provide greater energy security for residents and businesses. Yes, we agree with the approach laid out.

Other

ID sylw: 108926

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire County Council

It is important to protect existing renewable infrastructure to support low-carbon energy generation within Warwickshire and therefore WCC agrees with the approach set out.

However, the filters in Table 7 requires further considerations. These will include All Priority Habitats and Local Wildlife Sites plus Heritage features. It is recommended that the lists used in the formation of the Woodland Opportunities Mapping project (see below) is used followed by the methodology used in the Warwickshire Local Nature Recovery Strategy mapping, which is currently being formulated. In this way the SWLP would be in conformity with the Warwickshire LNRS.

Urban Areas
Roads
Railway infrastructure
Scheduled Ancient Monuments
World Heritage Sites
Airports and military air
National Grid gas pipelines
National Grid overhead cables
Open water & Canals
Grade 1 Agricultural Land
Floodplain buffer around urban centres and along roads
Riparian zone of designated Main Rivers
Land behind raised flood defences
EA floodplain washlands
Ministry of Defence land
SSSI
National Nature Reserves
Common Land
RSPB Reserves
Historic Parks & Gardens
Battlefields
National Park
Areas of Outstanding Natural Beauty
Undesignated BAP Habitats

Other

ID sylw: 108927

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire County Council

Warwickshire County Council agrees with Draft Policy Statement F, however further emphasis is required in regard to:
Stakeholder engagement. The affected building occupants are to have the opportunity to respond to any proposed decentralised heating system to ensure that the solution deployed is fair and equitable.

Affordable. A contract between the zone coordinator and the operator must ensure that the cost of delivered heat to the consumer is affordable over the long term. Affordable should be referenced in relation to the pricing of the current heat source and comply with guidance from the central body or appropriate national requirements or guidance.
Clarity is required on the intent of the application of the policy to existing developments.

Other

ID sylw: 108928

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire County Council

Part A-Residential Buildings

We question the need to include the phase ‘hybrid as necessary’ as a new building should be able to optimise design to have a dedicated or communal heat pump or alternatively connect to a heat network.

It is not clear in the approach what compensation will be required should a development not meet the policy requirements.

The outcome enshrined by the statement ‘It is expected that new developments will achieve higher airtightness than the FHS notional building where possible’ is in danger of not being met in practice. Consider tightening up the wording to specify the FHS airtightness should be met as a minimum.

The statement ‘Additional indoor control systems should be considered if they deliver additional value for the additional capital costs’ should place emphasis on running costs instead of value.

There is the absence of a criterion related to overheating and the use of cooling. Criterions 6 and 7 relate (shading, overheating) but consideration should be given to a dedicated criterion to minimise the need for cooling

Part B-Non-Residential Buildings

Consideration should be given to requiring the developer to prove they have ruled out ‘sourcing 100% renewable electricity’ rather than ‘consider sourcing’ to enhance the effect of this criterion.

WCC fully supportive of the proposed policy although it is not clear in the approach what compensation will be required should a development not meet the policy requirements. This needs clarification..

Other

ID sylw: 108929

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire County Council

Warwickshire County Council agrees with Draft Policy Direction 23- Reducing Energy Consumption in Existing Buildings and suggests the following.

It is appreciated that this policy is directed at a wide range of existing buildings and so specific limit values are not appropriate and this has been dealt with through the statement ‘Retrofit schemes should align with key industry standard guidance…’ with supporting best practice guidance bullet points. Following implementation of this policy it is suggested that clear guidance should be developed for developers on what standards are expected for the range of architypes covered by this policy to give certainty to the market.

Other

ID sylw: 108930

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire County Council

‘All new major developments should demonstrate how the embodied carbon of materials has been considered and reduced where possible’ does not state any reference to compared ‘reduced’ to. This should be considered.

In relation to the statement ‘In addition to the above requirements proposals for development of 50 or more new dwellings and/or 5,000sqm or more of new non-residential floorspace should be accompanied by a whole-life assessment of the materials used’. Consideration of how this will be assessed within the planning process (could this include a sensitivity analysis for smaller developments?) will help to give this statement weight as well as the rationale behind the 50 dwelling breakpoint.

The benefit may already be recognised given the statement in the justification statement which relates to the report on embodied carbon by the House of Commons Environmental Audit Committee: ‘The report recommended that a mandatory requirement to carry out whole-life embodied carbon assessments be introduced through building regulations and planning policy’. This may suggest application of this assessment to a greater number of developments than currently proposed by the policy is beneficial.

It is not clear in the approach what compensation will be required should a development not meet the policy requirements.

Other

ID sylw: 108931

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire County Council

WCC specifically appreciates the introduction of checklist idea but there is no defined monitoring and evaluation of checklist. It would be a good practice if they could be regularly updated to reflect the latest scientific data and best practices.

Can the inclusion of climate adaptation strategies in development plans be mandated, as well as climate risk assessments?

WCC Ecology supports the approach a laid out, however, it is not clear in the approach what compensation (if any) will be required should a development not meet the policy requirements.

Other

ID sylw: 108932

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire County Council

WCC support this and would encourage the use of rainwater harvesting for landscape watering and other uses.

WCC Ecology supports the approach a laid out, however, it is not clear in the approach what compensation (if any) will be required should a development not meet the policy requirements

Other

ID sylw: 108933

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire County Council

WCC Ecology supports the approach a laid out, however, it is not clear in the approach what compensation (if any) will be required should a development not meet the policy requirements