No

ID sylw: 107954

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments 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.

Other

ID sylw: 107955

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments 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.

Yes

ID sylw: 107956

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

The policy is broadly supported, with it being underpinned and justified by the evidence and recommendations in the Coventry and Warwickshire Sub-Regional Water Cycle Study (August 2024).

Other

ID sylw: 107958

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments 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, applicants would not need to apply the sequential test again for planning applications for sites allocated in the South Warwickshire Plan.

Other

ID sylw: 107959

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments 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: 107967

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

Rainier Developments 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.

Other

ID sylw: 107968

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

The Government has a National Design Guide and National Model Design Code which are in place to guide design of development. Introduction of different design codes covering a range of geographic areas and with varying degrees of detail, is supported by national planning policy, including NPPF Paragraph 134, which states design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale. There would be no need to replicate the content of the National Design Guide and National Model Design Code in the SWLP Part 1.; it will be sufficient to simply refer to the document(s).

Whilst our client supports high-quality design and design codes in principle, it is important that innovation and the need to respond to the unique requirements of a site are not unduly inhibited by an overly prescriptive approach. The individual character of each site and settlement should be considered on a case-by-case basis in terms of design. There must be flexibility within the Design Codes and Local Plan policy to allow developments to come forward even if not strictly in accordance with all criteria. It should not be used as a blanket reason to refuse development where divergences do not have detrimental impacts.

Yes

ID sylw: 107969

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

The draft policy direction is considered to provide a suitable framework for a strategic historic environment policy, which would be justified and consistent with the NPPF.

Yes

ID sylw: 107970

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

There is no objection to this policy direction, which is consistent with the NPPF. Paragraph 187(e) states that new and existing development should be prevented from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution, whilst Paragraph 199 notes that planning policies should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas.

Other

ID sylw: 107971

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

There is clear support within the NPPF (Section 8) for the creation of healthy and safe communities, and Paragraph 005 of the Healthy and Safe Communities section of the PPG highlights that health impact assessments can be a useful tool where there are expected to be significant impacts on health. The policy direction states that where there will be a significant impact on health and wellbeing, and this cannot be mitigated, applicants will need to compensate for such impacts, through financial contributions.

Viability should be taken into consideration; it is imperative for such a policy to not risk undermining the deliverability of much-needed housing sites, in instances where it may be challenging to provide adequate mitigation. This should have been acknowledged within the SA, in relation to potential impacts on SA Objective 9 (Housing).