Issue and Options 2023

Ended on the 6 March 2023
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7: A climate resilient and Net Zero Carbon South Warwickshire

Chapter 7 sets out various options regarding climate change and Net Zero Carbon. The chapter is split into 4 sections and seeks your views on the following issues:

7.1 Large scale renewable energy generation and battery storage

7.2 Net Zero Carbon Buildings

7.3 Climate responsive development design

7.4 Flooding and water management

The Government's target is to reach net zero by 2050, and its 2021 Net Zero strategy highlights the importance of the planning system in combatting climate change and supporting sustainable growth.

The Plan has a legal duty and decisive role in tackling climate change across South Warwickshire through helping to shape places that reduce carbon emissions and adapt to the expected changes that climate change will bring thereby improving resilience.

Both Councils declared a climate emergency in 2019 and have subsequently produced a Climate Change Action Programme which sets out the actions we must take to deliver on our climate change ambitions including from the business, housing and transport sectors. The Local Plan is one of the ways we can facilitate the delivery of the identified actions.

What you said:

  • Significant number of respondents suggest that the Plan should give more priority and urgency to the need to address climate change
  • Approach needs to be workable, deliverable and follow a flexible approach
  • Most respondents agreed with the measure proposed within the Scoping Consultation
  • A range of further suggestions were put forward including:
  • Net Zero Carbon building standards
  • Location of new development
  • Creating good quality transport links that promote active travel and encourage the use of public transport
  • Green and Blue Infrastructure
  • Improving water resource efficiency
  • Retrofitting buildings and streets
  • Improving air quality
  • Committing to a biodiversity net gain
  • A strategy for a green economy
  • Flood mitigation
  • Generation of renewable energy
  • Green education and training

To inform the approach taken to drive forward the change that new development must embrace, an assessment of the causes, effects and potential future impacts of climate change is essential. Providing a clear picture of the current state of play is a critical part of understanding the starting point, defining future targets, and setting the trajectory to get there. A Climate Change Baseline Report has been independently produced to support the Issues and Options consultation which sets the baseline and identifies opportunities to embed climate change considerations into the local planning process based on the following six themes:

  • Housing Growth
  • New Buildings, Design and Retrofit
  • Economy
  • Environment
  • Infrastructure and Utilities

To mitigate climate change in South Warwickshire there are three key findings from the data:

  • Road transport is the most significant source of emissions across South Warwickshire, representing higher than average per capita emissions compared with the UK as a whole
  • Buildings – especially residential buildings – are also a major source of emissions for the area, pointing to the need both to reduce emissions through building retrofits and to avoid emissions through the planning and design of new buildings
  • There is a significant opportunity to enhance carbon sequestration through protection, restoration and appropriate management of green land uses.

7.1 Large scale renewable energy generation and battery storage

A key element in achieving net zero is moving away from fossil fuels in electricity generation. While national schemes are likely to provide the bulk of our electricity, Local Authorities also have a role to play in enabling renewable energy generation schemes to go ahead. For example, national policy states that onshore wind projects can only be approved if they are in areas identified as suitable in a Local Plan, that the planning impacts identified by the affected local community have been fully addressed and the proposal has their backing.

In order to increase the use and supply of renewable and low carbon energy and heat, national policy requires plans to provide a positive approach that maximises the potential for suitable development whilst ensuring that adverse impacts are satisfactorily addressed. This would include renewable, such as solar, wind, hydrogen, and low carbon energy sources and supporting associated infrastructure such as battery storage. Where feasible dual uses can maximise the benefits from a site, for example incorporating both a solar farm and land cultivation/biodiversity opportunities.

Issue C1: Solar and wind power

What you said:

Locations identified for renewable energy need to be appropriate and should consider the impact on the landscape and the loss of good quality agricultural land, and should only be allowed where mitigation can be provided.

Better to list or map specific locations for renewable energy generation rather than react to individual planning applications on an ad-hoc basis.

Different areas of South Warwickshire may be more suited to solar and wind generation than others. As well as the amount of sunlight and wind experienced in a location, a careful balance is required that considers factors including the impact on the landscape and heritage assets, the loss of agricultural land, the sterilisation of mineral reserves, and community support.

Current adopted policy

Policy document

Policy reference

Page no.

Policy Summary

Stratford-on-Avon District Core Strategy

CS.3

30

In principle support of renewable energy schemes, including solar and wind, subject to conditions. Land is not allocated.

Warwick District Local Plan

CC2

104

In principle support of renewable energy schemes, including solar and wind, subject to conditions. Land is not allocated.

(115)Q-C1.1: Please select the option which is most appropriate for South Warwickshire

The criteria against which schemes would be considered are likely to be broadly in line with existing policies CS.3 and CC2, for example considering the impact on:

  • Agricultural land
  • Landscape and visual amenity
  • Ecology and biodiversity
  • Light and glare, particularly with reference to aviation and biodiversity
  • Historic assets
  • Traffic generation
  • Potential sterilisation of minerals reserves
  • Community impacts

(55)Q-C1.2: Are there any other criteria which should be considered when assessing proposals for large scale renewable energy developments?

Allocating land for other renewable energy or related uses is not presented as an option here. In contrast to solar and wind farms, the land area needed for a battery storage or hydrogen production facility is relatively small; allocation is not necessary for these schemes to come forward; and as emerging technologies it is difficult to predict industry requirements in the coming years.

The current Call for Sites exercise invites submissions of available land, including land which might be appropriate for wind or solar energy development. Knowing what land is available will help us to undertake a fully informed exploration of the potential for renewable energy allocations. It is not intended to pre-judge which of the above policy options might be most suitable for South Warwickshire.

Issue C2: Decentralised energy systems

Decentralised energy systems supply heat and / or power to specific residential and commercial developments or localities. This may be by capture of waste heat from other processes or generated on site. Decentralised energy systems can be the most efficient way to provide energy, heating and cooling to dwellings where a development is of sufficient size, use mix and density to make such a scheme viable. This may be in the form of District Heating (heat only), Combined Heat and Power, or Micro-grid (power only). These systems can be provided in different ways including through community energy schemes.

Current adopted policy

Policy document

Policy reference

Page no.

Policy Summary

Stratford-on-Avon District Core Strategy

CS.3

30

New developments in district heating priority areas are required to incorporate infrastructure for district heating, and to connect to existing systems where and when this is available, unless unviable. Developments in other areas are encouraged to incorporate district heating infrastructure.

Warwick District Local Plan

CC.3

105

Applicants to consider the potential to incorporate decentralised district heating networks on the strategic sites identified in the Plan.

(83)Q-C2: Please select the option which is most appropriate for South Warwickshire

Issue C3: Carbon Sequestration

Carbon sequestration is the long-term storage of carbon in plants, soils, geological formations and the ocean, and has the potential to make a significant contribution to the removal of carbon dioxide from the atmosphere. The Plan provides an opportunity to enhance carbon sequestration through the protection, restoration and appropriate management of green land uses.

Restoration and management activities can include afforestation (conversion of non-forested land to forest), reforestation (conversion of previously forested land to forest), improved forestry or agricultural practices, and revegetation. Encouraging the shift from pasture to arable land enables a reduction in livestock emissions whilst freeing up land for arable agriculture and woodland which have sequestration benefits.

Environmental net gain can be an effective way to assist in offsetting the unavoidable impacts of new development. Such an approach could incorporate carbon emission offsetting. Some developments may not be able to completely neutralise their carbon emissions and in these cases a carbon offsetting approach could be developed whereby a contribution would be paid by the developer. These contributions could then be used to reduce carbon emissions elsewhere, for example through the retrofitting of the existing housing stock. More detailed consideration of environmental net gain and carbon offsetting is set out within Issue B5: Environmental Net Gain.

(182)Q-C3.1: Do you think we should develop a carbon offsetting approach to new developments where it is demonstrated that it is not possible to achieve net carbon zero requirements on site?

Q-C3.2: Do you have any proposals for projects/schemes within South Warwickshire in which developer (or local business) offset payments could be invested to secure emissions removals or reductions?

Q-C3.3: Please add any comments you wish to make about renewable energy generation or carbon sequestration in South Warwickshire

7.2 Net Zero Carbon buildings

What you said:

  • Some respondents felt that applying the energy hierarchy might set a negative precedent for moving forward, and that a fabric first approach should be applied in the first instant rather than relying on energy saving technology or renewable energy generation
  • Some concerns raised about viability and that policies applying the energy hierarchy must be proportionate to the scale of development, justified and not overly prescriptive.
  • The approach should include some level of flexibility to make sure it doesn't make schemes unviable
  • Some respondents consider that the Councils should rely on building regulation standards and not go further than that, in that it will create uniformity, and that it is not appropriate for Councils to set additional local energy efficiency standards through planning policy.
  • The use of the energy hierarchy aligns with national targets as the move to Net Carbon continues.

The Planning and Energy Act 2008 gives local planning authorities the ability to set energy efficiency standards in their development plan policies that exceed the energy efficiency requirements of the Part L Building Regulations.

In 2021 the government published the outcome of the Future Homes Standard consultation, outlining what changes will be made to Building Regulations for new dwellings, and at what pace. With effect from June 2022, changes to Building Regulations mean that all new homes must produce 30% less carbon dioxide emissions than previous standards. From 2025 all new homes will be required to produce 75-80% less carbon dioxide emissions and will need to be 'zero-carbon ready' requiring no further energy efficiency retrofit work to enable homes to become zero-carbon as the electricity grid decarbonises. The Future Building Standard builds on this by setting out energy and ventilation standards for non-domestic buildings and existing homes, providing a pathway to zero carbon ready non-domestic buildings.

In 2021 the government also published its Net Zero Strategy: Build Back Greener which outlines how the UK will manage its carbon budgets and sets out how the UK's vision for a net zero economy by 2050, and measures to transition to cleaner energy and reduce the UK's reliance on imported fossil fuels. The strategy includes decarbonisation pathways and proposals to reduce sector-specific emissions to support the transition to net zero. There is a recognition that local authorities play an essential role to influence key sectors in the transition to net zero.

The Climate Change Action Programme (2021) for both South Warwickshire Councils sets out a number of ambitions, of which Ambition 2 (Low Carbon South Warwickshire 2030) aims to reduce net carbon emissions from across South Warwickshire by a minimum of 55% by 2030 and alongside this, plan how to further reduce carbon emissions to net zero by 2050.

Well-designed schemes should be considered at the beginning of any planning process, and the building and retrofit of low and zero carbon homes will require the Energy Hierarchy to be taken into account from the outset. The National Design Code 2019 identifies the need for new developments to follow the energy hierarchy to:

  1. Reduce the need for energy through passive measures, including form, orientation and fabric
  2. Use energy efficient mechanical and electrical systems, including heat pumps, heat recovery and LED lights; and
  3. Maximise renewable energy especially through decentralised sources, including on-site generation and community-led initiatives

Figure 24 - The Energy Hierarchy

An inverted triangle showing the Energy Hierarchy. From top (largest) to bottom: Reduce the need for energy, Use energy more efficiently, Use renewable energy, Use low carbon energy sources, Use fossil fuels more cleanly and efficiently.

Current adopted and emerging policy

Policy document

Policy reference

Page no.

Policy Summary

Stratford-on-Avon District Core Strategy

CS.2

26

Encourages high sustainability standards in buildings and promotes the application of the energy hierarchy. Non-residential development is expected to comply with the BREEAM 'good' standard and extensions/reuse of buildings are expected to improve overall energy performance.

Warwick District Local Plan

CC1

102

Requires development to be designed to be resilient to, and adapt to the future impacts of climate change through the inclusion of a range of appropriate measures.

Warwick District Local Plan

CC3

105

Requires non-residential development over 1,000 sq.m to achieve a 'very good' BREEAM standard.

The Warwick District Council Net Zero Carbon Development Plan Document (DPD) Consultation Draft (April 2022)

Policies NZC1-4.

Various

Aims to minimise carbon emissions from new buildings within the District to support the achievement of national and local carbon reduction targets

Issue C4: New Buildings

Buildings are a major source of emissions for South Warwickshire and so the need to minimise those that are generated from new development is critical in achieving the climate emergency ambitions.

(170)Q-C4.1: Please select all options which are appropriate for South Warwickshire

Q-C4.2: What scale of development should the requirements apply to?

Issue C5: Existing Buildings

The existing building stock will continue to form the vast bulk of buildings within South Warwickshire, even by 2050. As such, most of the climate impacts relating to buildings will come from those already built. Opportunities for retrofitting come through proposals for conversions, changes of use and residential householder applications. It can also come about by the addition of measures, such as solar panels and heat pumps, to existing buildings.

The type, location and scale of the measure(s) will determine whether or not planning permission will be required. Some measures may be capable of being installed without needing planning permission.

In relation to historic buildings, Historic England highlights that sympathetically upgrading and reusing existing buildings, rather than demolishing and building new, could dramatically improve a building’s energy efficiency and would make substantial energy savings because the emissions already embodies within existing buildings would not be lost through demolition. They advise that locally-specific policies about retrofit are essential for achieving this objective.

(107)Q-C5: Please select all options which are appropriate for South Warwickshire

Issue C6: Whole Life-Cycle carbon emission assessments

Whole Life-Cycle Carbon emissions are those resulting from the material, construction and the use of a building over its entire life, including its demolition and disposal. A Whole Life-Cycle Carbon Assessment considers a building's carbon impact on the environment and are most usefully undertaken once a building has been constructed but prior to occupation. In order to drive down emissions a policy approach would be necessary to establish appropriate targets to reduce emissions.

(197)Q-C6.1: Please select the option which is most appropriate for South Warwickshire

Q-C6.2: If a phased approach is used, what dates and thresholds should be used?

Q-C6.3: Please add any comments you wish to make about Net Zero Carbon buildings in South Warwickshire

7.3 Climate responsive development design

Climate change is anticipated to increase average annual temperatures and the occurrence of extreme temperature events, and increase the occurrence of extreme weather events including both flooding and drought events. In addition, it is predicted to have negative impacts on biodiversity and wildlife habitats thereby affecting oxygen production, carbon storage and the natural filtering of toxins. Ensuring that new development and changes to existing buildings respond to these changes is therefore a crucial element in responding to the climate emergency and will create more resilient communities for the future.

At the same time new development should acknowledge the imperative to minimise consumption-based emissions, building in identifiable initiatives to influence sustainable lifestyle choices and behaviours. This includes locally grown food, active travel and electric vehicle charging points.

Current adopted policy

Policy document

Policy reference

Page no.

Policy Summary

Stratford Core Strategy

CS.4

36

Sustainable drainage systems (SuDs) to be proportionately included in all scales of development. All development proposals to control and discharge 100% of runoff into SuDs. Presumption against the underground storage of water.

36-41

No specific policy requirements on water consumption, though there is reference to minimising water consumption.

Warwick District Local Plan

CC3

105

Non-residential development over 1000 sq.m to achieve BREEAM very good standard. Applicants to consider potential to incorporate large scale decentralised district heating networks.

Warwick District Local Plan

FW2

108

All developments to include sustainable drainage, with a presumption against water storage underground.

Warwick District Local Plan

FW3

109

The Council will require all new residential development of one dwelling or more to meet a water efficiency standard of 110litres /person/ day. This includes 5 litres/ person/ day for external usage.

Issue C7: Adapting to higher temperatures

Future-proofing new development to adapt to the effects of higher and more extreme temperature change can be achieved through a range of design features including:

  • Use of shade and ventilation applying a cooling hierarchy to ensure that developments are cooled in the most sustainable and energy efficient manner possible.

Table 14 – The Cooling Hierarchy

  1. Passive design – using energy efficient design to reduce the amount of heat entering the building in the warmer months. This can be achieved through appropriate orientation, overhangs and shading, albedo, fenestration, insulation and green roofs. Heat can also be reduced within the building through high ceilings and exposed internal mass; however, provision must be made for night purging of heat through secure ventilation. Such ventilation should be closable to preserve air tightness in cold weather.
  1. Passive / natural cooling – using outside air to ventilate and cool a building without using a powered system.
  1. Mixed mode cooling – using a mixture of both passive cooling methods and:
  1. Mechanical cooling, such as fan powered ventilation (preferred option)
  2. Air conditioning (not preferred option due to being energy intensive).
  1. Full building mechanical ventilation / cooling system using the lowest carbon / energy options – only to be considered after all other elements of the hierarchy have been considered.
  • Use of cool materials, for example roofs and paving, which are light in colour or have solar reflective properties and can significantly reduce the solar heat gain thus reducing the need for artificial cooling in summer. Cool pavements and hardstanding can be achieved by using permeable surfaces and light-coloured materials. Permeable surfaces can cool local temperatures through the process of evapotranspiration, whilst light materials are more solar reflective and therefore absorb less heat.
  • Green Infrastructure through the use of green roofs and walls on buildings and green and blue corridors within developments can provide multiple benefits including providing a natural cooling effect and enhancing biodiversity. The use of trees and landscaping can also cool temperatures and provide shading and can provide benefits in streets, pedestrian and cycle routes, public open space and car parks.

(118)Q-C7: Please select the option which is most appropriate for South Warwickshire

Issue C8: Adapting to flood and drought events

Designing new development to sufficiently manage the use and storage of water is critical in mitigating the effects of climate change, there are a number of ways this can be achieved including:

  • Sustainable Urban Drainage Systems (SuDS). To manage risk of surface water flooding, sustainable drainage schemes are commonly required or at least encouraged within new developments. In addition to flood risk reduction and potential resultant improvements to the quality of the water environment, they have added potential benefits in terms of habitat creation and biodiversity. There are many different types of SuDS suitable or all scales and types of developments and they can be incorporated into new developments and contribute towards creating a strong sense of place. New SuDS should follow the Drainage Hierarchy as set out within the NPPF. In addition, permeable surfaces for hardstanding, driveways and paved areas allow for enhanced drainage of surface water
  • Reducing water consumption. Climate change and population growth are increasing pressure on our water resources and South Warwickshire is an area of serious water stress. There is a need to reduce our demand for water and supporting water efficiency through rainwater harvesting and greywater recycling reduces the amount of water required from the mains supply and the amount entering drains. This can be achieved through both building and development wide schemes.
    Policy options in relation to reducing water consumption include specifying a water efficiency target above Building Regulation requirements for new residential developments. The existing Warwick District Local Plan sets a requirement of 110 litres per person per day which could be carried forward into the new South Warwickshire Local Plan, however consideration could be given to going beyond this standard to 100 litres per person per day or even lower.

(117)Q-C8: Please select the option which is most appropriate for South Warwickshire

Issue C9: Mitigating Biodiversity loss

Incorporating high levels of green infrastructure, including street trees, into built-up areas can bring people closer to nature, restore biodiversity, aid carbon sequestration, enable the movement of wildlife, soak up pollutants and reduce flood risk. The Environment Agency Report 'Working with Nature' (July 2022) highlights a range of nature-based solutions. Some of the types of measures that can be applied include:

  • Bio-enhancing developments both within green spaces and throughout the design as part of background wildlife capacity through the provision of wildlife friendly and biodiverse planting and landscaping, features such as hedgerows, trees, bird/bat boxes, hedgehog holes and homes, appropriate external lighting. In major developments it may be appropriate to require less than 50% of the wider site (excluding buildings) to consist of paved/hardsurfaced areas.
  • Local wildlife nodes and blue and green corridors can link developments to the surrounding biodiversity network, enabling the bridging of habitats where they have been separated by human development. The creation of local wildlife nodes, utlilising underused land such as verges at junctions and street corners provide an opportunity to increase biodiversity.

(194)Q-C9.1: Please select the option which is most appropriate for South Warwickshire

Q-C9.2 Please add any comments you wish to make about climate responsive development design in South Warwickshire

Issue C10: Climate Change Risk Assessments

The modelling of future climatic impacts for a site to determine how it is likely to be affected by climate change helps to understand the issues and inform how best it can be planned and designed for resilience. Climate change risk assessments can be a useful way in which to identify the climatic factors likely to affect a particular development and the measures that can be incorporated to mitigate and adapt to these effects. As a baseline for such assessment, Representative Concentration Pathways (RCPs) (as described by the Intergovernmental Panel on Climate Change) represent different plausible trajectories for the climate, depending on the concentration of greenhouse gas emissions. There are a range of RCP scenarios depending upon different assumptions up to RCP 8.5 which is based upon a worst case scenario. Further information on RCPs is available.

(116)Q-C10.1: Please select all options which are appropriate for South Warwickshire

Q-C10.2 Please add any comments you wish to make about Climate Change Risk Assessments in South Warwickshire

7.4 Flooding and water management

Issue C11: Water Management

Whilst water supply is clearly a key issue for growth, dialogue with stakeholders placed greatest emphasis on water efficiency measures rather than supply infrastructure (which is a statutory obligation). Policy FW4 in the Warwick District Local Plan emphasises need to minimise the need for new infrastructure, though for the purposes of the Part 1 plan this will be considered through the spatial strategy.

Both the Stratford-on-Avon Core Strategy and the Warwick District Local Plan include policy pertaining to water quality. These focus on protecting the status of water bodies in line with the Water Framework Directive's objectives, from the impacts of surface and ground water pollution and waste water treatment discharges. It is acknowledged that there have been recent issues with sewage leaks in some locations across South Warwickshire, which emerging policy may also seek to tackle. Further evidence on the issue of water quality is anticipated in a Water Cycle Study.

Current adopted policy

Policy document

Policy reference

Page no.

Policy Summary

Stratford-on-Avon District Core Strategy

CS.4

38

Water bodies must maintain 'good' status in River Severn, Humber and Thames Basin Management Plans. Developments which would have a negative impact on water quality either directly or indirectly should be resisted.

Warwick District Local Plan

FW4

110

Protect and maintain 'good' status of waterbodies in River Severn Bain Management Plan.

(99)Q-C11: Please select the option which is most appropriate for South Warwickshire

Environmental net gain can be an effective way to assist in offsetting the unavoidable impacts of new development. Such an approach could incorporate water quality offsetting. Some developments may not be able to completely achieve water quality requirements and in these cases an offsetting approach could be developed whereby a contribution would be paid by the developer. These contributions could then be used to improve water quality elsewhere. More detailed consideration of environmental net gain and water quality is set out within Issue B5: Environmental Net Gain.

Issue C12: Flood risk

There are 31 main rivers within South Warwickshire, and as such parts of the area are at risk of flooding. Whilst the NPPF sets out a clear national approach to flood risk, both SDC and WDC have existing policies which seek to consider the issue at a local level. Such local policies are required by paragraph 156 of the NPPF, which compels local plans to address flood risk from all sources, taking account of predicted impacts of climate change.

A Strategic Flood Risk Assessment (Part 1) has been undertaken by external consultants, and a SFRA (Part 2) and Water Cycle Study will follow. The SFRA (Part 1) examines the flood risk from different sources across South Warwickshire, including taking account of the impacts of climate change. Part 2 at a later date will examine flood risks in specific locations based on a preferred spatial strategy as it emerges. These pieces of evidence, once complete, will further inform emerging policies to address flood risk from all sources, plus spatial strategy options. This will include consideration of predicted climate impacts on these flood risks.

Current adopted policy

Policy document

Policy reference

Page no.

Policy Summary

Stratford-on-Avon District Core Strategy

CS.4

36

Flood zone 1 (low risk) preferred. Sequential test (and exception test where appropriate) required for sites in flood zones 2 and 3. Maintenance of functional floodplain, and where possible restoration.

Warwick District Local Plan

FW1

106

See FW1

Presumption against development in flood zone 3. Must meet sequential and exception tests where required. Requirements a-e.

The scope of this policy is yet to be determined. However, flood risk is considered a strategic planning matter in terms of developing the spatial strategy and policy. It will therefore be included in the Part 1 plan.

(162)Q-C12: Please add any comments you wish to make about water management or flood risk in South Warwickshire

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