Yes

ID sylw: 107843

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Taylor Wimpey strongly support the need for the Draft Plan to respond positively to the identification of unmet housing need arising from the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) and Coventry and Warwickshire Housing Market Area (CWHMA).
Across the GBBCHMA the current standard method suggests a need for approaching 16,000 homes per annum, whilst the need across the CWHMA has slightly decreased to 5,295 (102 lower than the previous standard method). The need for the GBBCHMA is notably higher than that concluded in the 2018 Strategic Growth Study, which suggested a need between circa 10,200 and 12,400 homes per annum. This is a substantive increase, whilst recognising the latter range projected needs only to 2031, and demonstrates the importance of the Plan responding positively to ensuring that needs across the HMA are accommodated over the course of this Plan period. Although Warwick is outside the GBBCHMA, Stratford is within the HMA and as such, this should be taken in to consideration. There continues a need for any shortfalls arising from the GBBCHMA and CWHMA to be considered within the SWLP.
Taylor Wimpey supports the approach set out in Draft Policy Direction 4 to work with the HMA authorities, this accords with the NPPF Duty to Cooperate (Paragraph 24).
Given the scale of the need and the failure for authorities across the HMA to provide for this need in the current generation of Local Plans, there is an imperative on joint working to positively respond. The Council must ensure that the Draft Plan adopts a sufficiently positive and flexible approach to ensure that a proportionate contribution to addressing unmet needs which are identified through discussions and the publication of joint evidence.

Yes

ID sylw: 107844

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

3.56 Overall, Taylor Wimpey support development being consistent with and contributing to the implementation of transport strategies, reflecting the ‘sustainable travel and economy’ approach, the true ‘modal shift’ described at p46, and the improvement of public transport. This is considered to broadly align with Section 9 of the NPPF. Sites which benefit from existing access to public transport should be prioritised for future growth, particularly in the instance that additional sites need to be identified to meet the additional needs calculated for South Warwickshire.
3.57 The site promoted by Taylor Wimpey on land to the north east of Hampton Magna benefits from easy access to Warwick Parkway train station, located to the north of the site. The Illustrative Masterplan for the site sets out opportunities to provide pedestrian/cycle connectivity through the site to the existing pedestrian connections, adjoining the railway station.
3.58 Taylor Wimpey welcomes the reference to site specific infrastructure and other requirements in any forthcoming allocation policies given this will provide better certainty going forward. However, this needs to be proportionate to the scale of development proposed, based on up-to-date evidence of need and subject to viability (which should be explicitly referenced in the policy wording). These requirements will also need to be justified through the evolving IDP.

Yes

ID sylw: 107846

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Taylor Wimpey welcomes the consideration of Green Belt release through the emerging plan and agrees that many of the most sustainable locations in South Warwickshire are within the Green Belt, including areas around key railway stations, such as Warwick Parkway.

The latter part of the Draft Policy Direction also comments on the potential for the identification of additional safeguarded sites to meet longer term needs. Although this may be appropriate in principle, as set out in respect of Draft Policy Direction 1, there is a substantial amount of need to meet at the current time, as such, sites that are assessed as deliverable, should be considered for allocation in this plan.
Land to the north east of Hampton Magna (Appendix 1 of this note) is assessed as two parcels by the Green Belt Review, identified as:
• HMG1 - comprising the northern part of the site south of the railway line
• HMG2 - comprising the southern extent, to the immediate east of the settlement of Hampton Magna.
Overall HMG1-Weak HMG2-Weak
Considering the above assessment, and inherent sustainability of the site, being in close proximity to Warwick Parkway railway station and being otherwise unconstrained, this site is considered to represent an opportunity to meet a proportion of the additional needs identified for South Warwickshire. It should be removed from the Green Belt and proposed for allocation to deliver new homes.

Yes

ID sylw: 107857

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Taylor Wimpey has no objection to the emerging policy direction and agrees that density should be considered in accordance with different types of locations of development.
In respect of any overarching Design Code to be adopted by the Council, this should give a degree of flexibility to allow consideration on a site-by-site basis and to ensure it remains adaptable to a changing market.

Yes

ID sylw: 107859

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Taylor Wimpey agree that the policy should reflect the most up to date evidence.
However, the policy should be flexible and able to respond to changes to evidence at any point after the policy is adopted.

Other

ID sylw: 107860

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Requirements that go above and beyond the standard building regulation requirements as set out by the Draft Policy, applying the higher Building Regulations standard M 4(2) and M4 (3), should be justified and otherwise considered on a site-by-site basis, and on a needs basis. This will ensure that homes are being built in the most appropriate locations to meet needs at the time of development. A blanket approach is not considered to be appropriate

Yes

ID sylw: 107862

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Taylor Wimpey supports the need for new development to reduce carbon emissions and incorporate climate resilience measures. 3.73 The anticipated requirements of the 2025 Future Building Standards and Building Regulations will require new development and significant refurbishment of development to improve energy efficiency and incorporate low carbon renewable energy generation.

Other

ID sylw: 107865

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Taylor Wimpey 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. This type of system does not benefit from the electricity generation in a CHP system which has implications for the financial viability of alternative 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. When considering cost, consideration should be given to the implications of delivering heat networks and tying residents into long term heating contracts with no options on choice of network supplier.
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: 107871

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Taylor Wimpey 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.
The WMS states, ‘the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations. The proliferation of multiple, local standards by local authority area can add further costs to building new homes by adding complexity and undermining economies of scale.
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.
It is noted that the draft Policy relates to both regulated and unregulated energy. While Taylor Wimpey support the delivery of low carbon development, it is considered any targets should be restricted to regulated energy only. Developers only have the ability to influence the regulated energy demand through design and specification of materials and systems and renewable energy technologies.
Further reductions in air tightness would necessitate the use of mechanical ventilation, which has a cost implication for development beyond current and proposed future Building Regulations.
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.
The technical constraints to delivery requirements for onsite energy generation, need to be considered in line with the 2023 WMS noted above. Setting an energy-based requirement does not align with the requirements of the WMS.
We would recommend that it is noted that Form Factor are set out in the context of needing to balance design with performance.
The draft Policy also requires residential development to include the consideration of green roofs and walls. We would note that while green roofs and walls can have multiple benefits, reducing the surface run off whilst having a positive impact on biodiversity, they have a significant implication in terms of design and cost and are not suitable for residential development where residents are responsible for their ongoing maintenance.
Recommendation – 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 which aligns with the Governments 2025 FHS and FBS, and 2023 23 Written Ministerial Statement on setting requirements which exceed the requirements of the Building Regulations.

Other

ID sylw: 107873

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Taylor Wimpey 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 DPD {Net Zero Carbon DPD-Adopted May 2024 - Download - Warwick District Council.} and supporting SPD {Net Zero Carbon SPD-May 2024 - Download - Warwick District Council.} 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.