No

ID sylw: 98654

Derbyniwyd: 06/03/2025

Ymatebydd: X2 New Settlement Consortium

Asiant : Mr Jack Barnes

The thrust of this chapter, which aims for climate resilience and zero carbon in the plan area is in line with national policy and targets. Some of the figures and requirements, however, along with the wording of some of the policies are considered to be unsound, as set out in the above responses. In particular some policies will need to be evidenced for feasibility, and all will need to be viability tested

No

ID sylw: 98655

Derbyniwyd: 06/03/2025

Ymatebydd: X2 New Settlement Consortium

Asiant : Mr Jack Barnes

Planning Practice Guidance quotes the NPPF as stating that SuDS should be used in development unless this would be inappropriate for the site. It is considered that this exception should be included in any policy requiring SuDS in the SWLP, as Draft Policy K does not currently allow for the exception, therefore meaning that the current policy is ‘unsound’.

No

ID sylw: 98656

Derbyniwyd: 06/03/2025

Ymatebydd: X2 New Settlement Consortium

Asiant : Mr Jack Barnes

It is considered that the advice of Environment Agency should be applied in full to any policy relating to flood risk mitigation, rather than just partly applied as is the case with Draft Policy J.

Yes

ID sylw: 98657

Derbyniwyd: 06/03/2025

Ymatebydd: X2 New Settlement Consortium

Asiant : Mr Jack Barnes

The requirement for development to mitigate any increase in surface water runoff with SuDS is supported, along with ensuring that there is adequate water supply resulting from any development proposals.

No

ID sylw: 98658

Derbyniwyd: 06/03/2025

Ymatebydd: X2 New Settlement Consortium

Asiant : Mr Jack Barnes

In our experience and analysis it is difficult to reduce water use to the levels described without compromising functionality, unless Rainwater Harvesting (RWH) for internal use is incorporated. RWH is rarely used on housing due to the cost, ongoing management issues and additional embodied carbon. Research also suggests that RWH increases CO² emissions at a time when we are seeking to reduce emissions. A target of 110 litres per person is considered more achievable and in line with the Government’s own guidance .

Yes

ID sylw: 98659

Derbyniwyd: 06/03/2025

Ymatebydd: X2 New Settlement Consortium

Asiant : Mr Jack Barnes

The importance of climate resilient design in development is recognised, along with the cooling hierarchy, optimising the use of permeable surfaces and Green Infrastructure, mitigating flood risk, and incorporating water efficiency measures. It is appropriate for development in the Plan area to be accompanied by a completed Climate Change Checklist, in line with the existing development plan for Stratford-on-Avon.

No

ID sylw: 98660

Derbyniwyd: 06/03/2025

Ymatebydd: X2 New Settlement Consortium

Asiant : Mr Jack Barnes

The importance of lowering embodied carbon in building materials is understood, and this being encouraged by policy is noted. The quantitative targets within Policy Direction 24 refer however to the Low Energy Transformation Initiative (LETI) and the Royal British Institute of Architects (RIBA) rather than specific analysis for the Plan area. A local analysis of the ability of different types and scales of development to meet an embody carbon policy should be prepared and subsequently tested through viability.

No

ID sylw: 98661

Derbyniwyd: 06/03/2025

Ymatebydd: X2 New Settlement Consortium

Asiant : Mr Jack Barnes

The definition of net zero carbon buildings within draft Policy Direction 22 is unclear. A requirement for all new buildings to be designed and built to be Net Zero Carbon in operation is likely to come at the expense of housing delivery on some sites. In order to be sound, any Net Zero policy will need to ensure that it has been viability tested. With regards to Criteria 1, 3, 4, 5, and 6 of Part A, as per paragraph 164 b) of the Framework, the requirements in Local Plans should be in line with the requirements of Building Regulations.

No

ID sylw: 98662

Derbyniwyd: 06/03/2025

Ymatebydd: X2 New Settlement Consortium

Asiant : Mr Jack Barnes

It is not considered that the draft Policy, in its current state, is effective in accordance with Paragraph 36 c) of the NPPF. The current definition of ‘major’ development means that it will not be realistic to expect the majority of such applications to demonstrate the use of decentralised energy systems. The Councils will need to ensure that any Policy at Regulation 19 stage evidences the feasibility of decentralised energy systems for development and expectations in relation to the scale of development. Any approach should be viability tested.

No

ID sylw: 98663

Derbyniwyd: 06/03/2025

Ymatebydd: X2 New Settlement Consortium

Asiant : Mr Jack Barnes

The Council must monitor and ensure that the appropriate evidence is updated throughout the period of the Plan once adopted, and that policies can rely on this future evidence to quantify the need for different tenures and types of residential accommodation. Explicitly quantifying a level of tenures, mixes and types at the Plan’s adoption risks the Plan becoming quickly outdated, which would result in the Plan not being positively prepared or effective, as is required by Paragraph 36 of the NPPF.