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?
Issue C3 Carbon Sequestration Q-C3.1 A carbon off-setting approach to new developments could be supported in principle, if it was demonstrated that it is not possible to achieve net carbon zero requirements on a particular site. Further information is required on this subject and presumably this will be included in subsequent consultations.
No answer given
No answer given
Consideration should be given to communities benefiting in terms of a reduction to their cost of electricity for the time that the development is in place, as should giving the public the opportunity to buy shares in any wind farm and get a return in electricity cost reduction. The rooves of schools, warehouses, public buildings should be equipped with solar panels, and there should be a policy that all new buildings are equipped with appropriate levels of solar panels. Carbon offsetting policies will be very important, especially to ensure that they are not abused by developers. There is no definition of offsetting in the glossary and this must be addressed.
No answer given
It is considered important for the South Warwickshire Authorities to develop a carbon off-setting approach to new developments where carbon offsetting cannot be achieved. This will ensure flexibility and assist in limiting impacts on viability.
No answer given
It is considered important for the South Warwickshire Authorities to develop a carbon off-setting approach to new developments where carbon offsetting cannot be achieved. This will ensure flexibility and assist in limiting impacts on viability.
Q-C3.1: Yes, subject to this approach not undermining the attractiveness of the plan area for investment. Q-C3.2: No.
No answer given
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7.1 Large Scale renewable energy generation and battery storage. The opening two paragraphs set the scene well. However there is no mention of the need to urgently upgrade the capacity of the grid to accommodate the move to heat pumps and the increased requirement for EV charging at home. Issue C1: Solar and wind power. Solar farms and onshore wind will be the key areas of focus. The document clearly sets out the need for consideration of the impact of landscape and heritage assets, the loss of agricultural land and the sterilisation of mineral reserves. The latter is not quite accurate as solar and wind farms are not permanent fixtures. Community support for these projects will be important. However local communities will benefit from a reduction to their cost of electricity for the time that the development is in place. This may provide a driver for certain communities to ask for solar farms and on shore wind developments. There are also a small number of community wind schemes (e.g. Ripple Energy) where the public have the opportunity to buy shares in a wind farm and get a return in reduced electricity costs. What is not mentioned are the significantly large areas of roofs on both residential and non residential buildings that could be equipped with PV. This could include schools, warehouses, public buildings etc.We suggest that the Plan should include a policy that all new buildings are equipped with appropriate levels of PV panels. As stated earlier, this should at least provide the electricity to match the EUI and where possible additional panels to aid EV charging. Issue C2 Decentralised energy systems. The current expert thinking for true net zero carbon low rise housing is that decentralised energy is not appropriate as it is basically not needed. Decentralised energy is a possible solution for the deep retrofit to true net zero carbon standards for existing domestic and non-domestic buildings. A good example is the use of the ‘waste’ heat from the Coventry incinerator being used to heat existing buildings in the city. Combined Heat and Power (CHP) is a solution that can be considered for non domestic buildings such as civic amenity buildings, Leisure and Sports Centres. However as the main aim is to remove fossil fuels for the generation of energy, consideration should be given to first significantly reduce the need for energy using the Passivhaus Standard or equivalent as has been achieved by Exeter City Living with the recent construction of St Sidwell’s Point Leisure centre. Issue C3 Carbon Sequestration. The information provided on carbon sequestration is correct but there needs to be a separate section on Offsetting. Offsetting policies will be very important most especially to ensure that they are not abused by developers. There is no definition of Offsetting in the Glossary and this must be addressed. Carbon emission offsetting is quite a wide subject and takes a number of forms which include: • Trees • Off-site renewable energy • Developer payment for retrofit of existing properties off-site to reduce carbon. • Offsetting outside the UK Carbon emission offsetting is necessary for specific new build categories such as flats, office buildings and industrial buildings where on site renewable energy is not possible. Carbon emission offsetting should NOT be used for low rise new residential dwellings where all of the EUI must be matched by on site renewables.
No answer given
QC.1.1Please select the option which is most appropriate for South Warwickshire: The JPC supports the priority being given to climate change and option C1.1b. The JPC in particular supports the monitoring of emissions and the proposals for retrofitting dwellings. There are local concerns about flooding in the area and the risk that more new developments might bring more regular flood damage to the town. Renewal of the Victorian water and drainage system would therefore need to go hand-in-hand with the development of any additional homes and commercial properties. QC 3 .1Do 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? Too often a false economy and not effectively delivered.
No answer given
Chapter 7 A Climate Resilient and Net Zero Carbon South Warwickshire Issue C2: Decentralised energy systems 63. The HBF does not support any policy that would require new development to connect to existing district heating or cooling networks or provide new networks. The HBF does not consider it is necessary to make more connections to the heat network. Heat networks are one aspect of the path towards decarbonising heat, however currently the predominant technology for district-sized communal heating networks is gas combined heat and power (CHP) plants. Over 90% of district networks are gas fired. As 2050 approaches, meeting the Government’s climate target of reducing greenhouse gas emissions to net zero will require a transition from gas-fired networks to renewable or low carbon alternatives such as large heat pumps, hydrogen or waste-heat recovery, but at the moment one of the major reasons why heat network projects do not install such technologies is because of the up-front capital cost. The Councils should be aware that for the foreseeable future it will remain uneconomic for most heat networks to install low-carbon technologies. 64. Furthermore, some heat network consumers do not have comparable levels of satisfaction as consumers on gas and electricity networks, and they pay a higher price. Currently, there are no sector specific protections for heat network consumers, unlike for people on other utilities such as gas, electricity or water. A consumer living in a building serviced by a heat network does not have the same opportunities to switch supplier as they would for most gas and electricity supplies. All heat network domestic consumers should have ready access to information about their heat network, a good quality of service, fair and transparently priced heating and a redress option should things go wrong. Research by the Competition and Markets Authority (CMA) found that a significant proportion of suppliers and managing agents do not provide pre-transaction documents, or what is provided contains limited information, particularly on the on-going costs of heat networks and poor transparency regarding heating bills, including their calculation, limits consumers’ ability to challenge their heat suppliers reinforcing a perception that prices are unjustified. The monopolistic nature of heat networks means that future price regulation is required to protect domestic consumers. 65. The CMA have concluded that “a statutory framework should be set up that underpins the regulation of all heat networks.” They recommended that “the regulatory framework should be designed to ensure that all heat network customers are adequately protected. At a minimum, they should be given a comparable level of protection to gas and electricity in the regulated energy sector.” The Government’s latest consultation on heating networks proposes a regulatory framework that would give Ofgem oversight and enforcement powers across quality of service, provision of information and pricing arrangements for all domestic heat network consumers. The Plan should therefore not include a policy requiring connections to heating networks. Issue C3: Carbon Sequestration 66. The HBF comments in relation to Biodiversity Net Gain can be found in response to issue B6. The HBF does not support the need for any additional policies that makes carbon offsetting a compulsory part of the planning process. Any further requests for development contributions will impact on viability and would need to be included in viability testing.
No answer given
7.1 Large Scale renewable energy generation and battery storage. The opening two paragraphs set the scene well. However there is no mention of the need to urgently upgrade the capacity of the gird to accommodate the move to heat pumps and the increase requirement for EV charging at home. Issue C1: Solar and wind power. Solar farms and onshore wind will be the key areas of focus. The document clearly sets out the need for consideration of the impact of landscape and heritage assets, the loss of agricultural land and the sterilisation of mineral reserves. The latter is not quite accurate as solar and wind farms are not permanent fixtures. Community support is also important and here consideration should be given to the immediate community to a new facility benefiting in terms of a reduction to their cost of electricity for the time that the development is in place. This may provide a driver for certain communities to ask for solar farms and on shore wind developments. There are also a small number of community wind schemes (e.g. Ripple Energy) where the public have the opportunity to buy shares in a wind farm and get a return in electricity cost reduction What is not mentioned are the significantly large areas of roofs on both residential and non residential buildings that could be equipped with PV. This could include schools, warehouses, public buildings etc. There should also be a policy that all new buildings are equipped with appropriate levels of PV panels. As stated earlier, this should at least provide the electricity to match the EUI and where possible additional panels to aid charging. To summarise the PV should be maximised. Issue C2 Decentralised energy systems. The current thinking for true net zero carbon low rise housing is that decentralised energy is not appropriate as it is basically not needed. Decentralised energy is a possible solution for the deep retrofit to true net zero carbon standards for existing domestic and non-domestic buildings. A good example if the use of the ‘waste’ heat from the Coventry incinerator being used to heat existing buildings in the city. CHP is a solution that can be considered for non domestic buildings such as civic amenity buildings, Leisure and Sports Centres. However as the direction of travel is to remove fossil fuels for the generation of energy, consideration should be given to firstly significantly remove the need for energy using the Passivhaus Standard or equivalent as has been achieved by Exeter City Living with the recent construction of St Sidwell’s Point Leisure centre. Issue C3 Carbon Sequestration. The information provided on carbon sequestration is correct but there needs to be a separate section on Offsetting. Offsetting policies will be very important most especially to ensure that they are not abused by developers. There is no definition of Offsetting in the Glossary and this must be addressed. Carbon emission offsetting is quite a wide subject and takes a number of forms. • Trees • Off-site renewable energy • Developer payment for retrofit of existing properties off-site to reduce carbon. • Offsetting outside the UK • etc Carbon emission offsetting is necessary for specific new build categories such as flats, office buildings, industrial buildings where on site renewable energy is not possible. Carbon emission offsetting should NOT be used for low rise new residential dwellings where all of the EUI must be matched by on site renewables.
No answer given
Q-C3.1 44. It would be appropriate for a carbon off-setting approach to be established in South Warwickshire as a whole. There is an advantage to this approach because the opportunity exists to improve biodiversity thereby reinforcing the green and blue infrastructure network which are being considered.
No answer given
C3.3. Solar should not be taking up increasing swathes of good productive farmland. (I know what was being grown in my fields in the Domesday Book. To be in continuous use for 937 years, it must be exceptional farmland). The SWLP employment and Industrial land needs should incorporate a duty to fit solar panels on every factory and office roof. And as in France, all future car parks should be covered in solar panels, under which cars park, at huge benefit to local provision.
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Q-C1.1: Please select the option which is most appropriate for South Warwickshire A combination of Options C1.1a and C1.1b would seem sensible. Q-C2: Please select the option which is most appropriate for South Warwickshire General comment: We would suggest a combination of both C2a and C2b – requiring large scale developments over a threshold as a must deliver, but also encouraging decentralised energy systems regardless of scale (viability changes and in some circumstances. Having a threshold would be to deny smaller schemes that are above micro generation – so would represent an opportunity missed. Suitability should be a case-by-case appraisal against criteria but should not be dismissed on green belt land, just because its in the GB but depend on the case. 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? Yes, subject to this approach not undermining the attractiveness of the plan area for investment.
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Q-C1.1: Please select the option which is most appropriate for South Warwickshire Option C1.1c: None of these Policy should ensure roof space is allocated for renewable energy production. Large warehouses have huge unused roof spaces for example which, with government led policy, could be utilised for green energy. This would mean space which could be allocated to agriculture/green belt/housing can be used for such rather than large solar/wind farms. Where land/space is in demand we need to utilise our roof and air space more effectively. 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? Don’t Know – Entirely depends on the nature of the offsetting scheme. Is this just green washing such as planting trees in the wrong site which will then not be looked after and not flourish or is this an offsetting scheme which actually makes a true beneficial impact?
Pay for widespread publicity on how households and businesses can reduce emissions, starting with the elimination of woodburning stoves.
Carbon off-setting is increasingly viewed as an easy way out for developments, and largely ineffective; e.g. it takes 40 years for a sapling to become an effective carbon-reducing tree. Building regulations should compel developers of new housing, factories, warehouses etc to have solar panels added; Install solar panels on council properties; keep solar panels of prime agricultural land.
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Q-C3.1: Don’t know. As recognised in the Consultation Document, some developments may not be able to completely neutralise their carbon emissions on site and in these cases a carbon off-setting approach would seem reasonable. However, it will be imperative that the SWLP provides an appropriate mechanism for carbon offsetting. The Consultation Document suggests that in addition to natural solutions such as tree planting that a fund could be created through the pooling of financial contributions from developers which will enable the existing housing stock to be retrofitted with measures to help reduce carbon emissions. However, it is not clear how such a scheme would operate in practice (i.e., how will financial contributions be calculated and who would be responsible for administrating, delivering and monitoring such a scheme?) or if it would meet the tests of Regulation 122 of the CIL Regulations 2010 (as amended). Without more information it is therefore very difficult to comment. Accordingly, the Respondent reserves their right to comment once more information is made available in this regard. Q-C3.3: The integration of renewable energy and carbon sequestration within new developments could both be feasible options in helping to achieve net zero carbon development but, as stated elsewhere in this Statement, anything above standard requirements will need to be carefully considered in the context of other policy requirements to ensure that any approach adopted by the Councils is justified, viable and deliverable. In the Respondent’s view, significantly more information needs to be provided before developers can provide any sort of meaningful comments on the suggested approach to renewable energy generation or carbon sequestration in South Warwickshire. The Respondent therefore reserves their right to make further comments once more information is made available in this regard.
No answer given
Q-C2: Lockley Homes would select Option C2a referred to above, with some reservations. Whilst we support the principles behind the emerging policy approach and the need to incorporate climate change mitigation features within new buildings, incorporating these types of features can significantly increase the financial build costs for new build residential schemes, at a time when the house building construction industry is already experiencing an unprecedented rapid increase in both materials and labour costs. We would advise that a pre-cautionary policy approach is therefore taken by the LPA’s in relation to this issue given the severe adverse set of economic circumstances now facing the Local Plan area as discussed below. The Council’s proposed planning policy approach on these issues is far too onerous and will place a highly damaging financial burden on the house building development industry within South Warwickshire. This is supported by the issues discussed below. Impacts of the global coronavirus (COVID-19) pandemic on Local Plan preparation within the UK According to central Government (London) estimates released by the Chancellor of the Exchequer (the now Prime Minister and former Chancellor of the Exchequer Rishi Sunak) during his Autumn Budget and Spending Review to Parliament, on Wednesday, 27th October 2021, the global coronavirus (COVID-19) pandemic has caused one of the worst economic recessions to affect the United Kingdom economy of a scale and severity not experienced across the UK for the last 300 years. Causing unprecedented record levels of Government borrowing due to the huge decline in economic activity during the years 2020 and 2021 ongoing COVID-19 pandemic, and the pro-longed 15 months of continuous lock-down restrictions, and the previous sustained long-term shutdown of the UK economy during the years 2020 and 2021. This severe and unprecedented long-term economic recession and the irresponsible handling of the public finances by central government (London) during the years 2022 to 2022 coronavirus pandemic, is highly likely to have long lasting implications in terms of a significant and long-term economic downturn. Causing one of the worst economic recessions in living memory across the South Warwickshire Region and the wider UK. Extending a long way into the shelf life of the Council’s new SWLP period once the new Local Plan has been formally adopted. This significant economic downturn driven by the various multiple adverse economic factors discussed above all coming together at the same time, is highly likely to harm the future financial viability and deliverability of many new housing development sites, resulting in some stalled housing sites, and some new housing sites not coming forward at all across the South Warwickshire Region. Due to the very challenging set of adverse economic circumstances discussed above. In addition, the house building industry is currently experiencing a severe spike in the financial costs of both building materials and labour costs, due to rising inflation and rapidly rising energy costs. Given the above factors, the housing market across the UK is currently very fragile. Consistent with our earlier substantial objections to the Council’s SWLP ‘Scoping and Call for Sites Report’ (May 2021) (Regulation 18) public consultation, Lockley Homes continues to maintain its view that the potentially massive implications of this severe UK economic recession (which will extend across the shelf life of the new Local Plan once it has been formally adopted) on both future housing delivery and future employment land delivery across the emerging Local Plan area, and how the recession will affect adversely affect future new housing and employment land delivery within the South Warwickshire Region and wider West Midlands Region area going forward, over the lifespan of the new Local Plan Review, once it has been formally adopted, has all been given an insufficient level of material planning policy weight and planning policy consideration by Stratford-on-Avon and Warwick District Council’s Planning Policy Teams when preparing both the emerging SWLP and SAP Local Plan Reviews. Or seemingly absolutely no planning policy weight at all – which is a highly alarming situation given the unprecedented severe adverse economic landscape now facing the local area for the reasons explained above. Local Plan preparation has refused and substantially failed to respond effectively to guidance within paragraph 82 (indent d) of the Revised NPPF (2021). Notably, the emerging Plan has substantially failed to respond effectively to the rapidly changing set of severe adverse economic circumstances now facing the Local Plan area. This underlines the ongoing failure and continued incompetence being taken towards Local Plan preparation by the Council’s within the South Warwickshire Region. To make things worse, the Council’s are now proposing to produce two separate versions of the SWLP – a Stage 1 SWLP and Stage 2 SWLP, which will add a significant time delay to Local Plan preparation, and substantially delay new inward investment opportunities coming forward within the South Warwickshire Region. We are concerned about the level of economic harm and damage that the Council’s proposed Plan making approach is causing to the local economy. We continue to object to the “incapable” management and leadership approach being taken towards Local Plan-preparation within the South Warwickshire Region, within both the SWLP (2023) and Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP) (2023). The presence of an unprecedented severe 300-year-economic-recession-event (driven largely by record levels of central government borrowing and weak economic growth during the years 2020 to 2022 coronavirus pandemic, and Russia’s Spring 2022 invasion of Ukraine) now facing the South Warwickshire Region and wider United Kingdom economy, should now result in an urgent and major re-shaping of all Policies coming forward within the emerging SWLP and SAP Local Plan Reviews. In order to ensure that the Council’s Plan-making approach on these matters is sufficiently robust, and responds effectively to guidance reinforced within paragraphs 31 (policies need to be based on a platform of the most up-to-date and sufficiently robust evidence) and 82 (indent d) (policies should remain sufficiently flexible to rapidly changing economic circumstances) of the Revised NPPF (2021). The implications for all climate change policies coming forward within the SWLP (2023) Given the above issues, it is important to ensure that a less financially onerous planning policy regime is placed on the housing building development industry going forward within the SWLP (2023) to help support the future financial viability of new housing development sites during the very fragile post-COVID-19 economic recovery. The impact of the sharp increase in energy prices during Spring 2022 The impact of rising energy prices during Spring 2022 and the major increase in the energy price cap on the 1st April 2022, with an average United Kingdom (UK) household gas and electricity bill rising to £1,971 a year, and a further increase anticipated during October 2022, which could take the cost up to £3,300, means that the need for modern energy efficient housing with good quality insulation standards has never been more important. The Spring 2022 price increase is driven by more demand on energy as worldwide economies gradually recover from the effects of the global coronavirus (COVID-19) pandemic, with supply unable to keep up with demand. Russia’s Spring 2022 invasion of Ukraine has also exacerbated the issue, with some countries stopping or limiting their purchasing of Russia’s oil and gas. In conclusion therefore, these emerging new housing development proposals proposed for the Village of Broom settlement will play a key role in helping to deliver a much needed supply of modern, energy efficient housing for the local community, in a part of the rural area which is currently suffering from and dominated by poorly insulated, sub-standard historic mid-17th century housing (built from 1st January 1601 to the 31st December 1700) and 18th century housing (built from 1st January 1701 to 31st December 1800) located inside the Village of Broom Conservation Area. All these historic properties, which in some cases are now over 300-years-old, all lack cavity wall insulation and are all energy inefficient. These new modern energy efficient housing development proposals are therefore coming forward at an absolutely critical time for the local community when the local area is facing a rapid increase in energy prices. These new housing development proposals should therefore be strongly encouraged by the Local Planning Authority. Q-C3.3: Whilst we support the principles behind the emerging policy approach and the need to incorporate climate change mitigation features within new buildings, incorporating these types of features can significantly increase the financial build costs for new build residential schemes, at a time when the house building construction industry is already experiencing an unprecedented rapid increase in both materials and labour costs. We would advise that a pre-cautionary policy approach is therefore taken by the LPA’s in relation to this issue given the severe adverse set of economic circumstances now facing the Local Plan area as already considered in our Representations Statement (2023). The Council’s proposed planning policy approach on these issues is far too onerous and will place a highly damaging financial burden on the house building development industry within South Warwickshire. The presence of an unprecedented severe 300-year-economic-recession-event now facing the South Warwickshire Region and wider United Kingdom economy, should now result in an urgent and major re-shaping of all Policies coming forward within the emerging SWLP and SAP Local Plan Reviews. In order to ensure that the Council’s Plan-making approach on these matters is sufficiently robust, and responds effectively to guidance reinforced within paragraphs 31 (policies need to be based on a platform of the most up-to-date and sufficiently robust evidence) and 82 (indent d) (policies should remain sufficiently flexible to rapidly changing economic circumstances) of the Revised NPPF (2021).
No answer given
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? Don’t Know – Entirely depends on the nature of the offsetting scheme. Is this just green washing such as planting trees in the wrong site which will then not be looked after and not flourish or is this an offsetting scheme which actually makes a true beneficial impact?
No answer given
The following statement regarding energy generation doesn’t say that the plan is taking the need for green energy with the urgency needed. 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. Carbon Sequestration is being promoted. I am unaware that this technology is currently more than theoretical. I am unsure the following statement can being supported. 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.
No answer given
Q-C1.1: An appropriate approach might combine elements of a and b. This would allocate land where this could be achieved based on current knowledge but also encourage other schemes to come forward at a later date. Q-C2: We would suggest a combination of both C2a and C2b – requiring large scale developments over a threshold as a must deliver, but also encouraging decentralised energy systems regardless of scale. Having a threshold would be to deny smaller schemes that are above micro generation – so would represent an opportunity missed. Suitability should be a case-by-case appraisal against criteria but should not be dismissed on green belt land, just because it’s in the GB but depend on the case. Q-C3.1: Yes, subject to this approach not undermining the attractiveness of the plan area for investment.
No answer given
Q C3.1 Don’t Know – Entirely depends on the nature of the offsetting scheme. Is this just green washing such as planting trees in the wrong site which will then not be looked after and not flourish or is this an offsetting scheme which actually makes a true beneficial impact?
No answer given
Q-C3.1: Yes, subject to this approach not undermining the attractiveness of the plan area for investment.
No answer given
Issue C1: Solar and wind power: Consideration should be given to communities benefiting in terms of a reduction to their cost of electricity for the time that the development is in place, as should giving the public the opportunity to buy shares in any wind farm and get a return in electricity cost reduction. The rooves of schools, warehouses, public buildings should be equipped with solar panels, and there should be a policy that all new buildings are equipped with appropriate levels of solar panels. Issue C3: Carbon Sequestration: Carbon offsetting policies will be very important, especially to ensure that they are not abused by developers. There is no definition of offsetting in the glossary and this must be addressed.
Q-C3.1: A carbon offsetting approach should be introduced as part of the new Local Plan to allow for flexibility in instances where it is not feasible to achieve net carbon zero requirements on a site, whether that be due to site constraints, viability or practicality of being able to develop the site. However, it is important to consider the offsetting costs from a viability perspective and ensure sufficient viability testing has been conducted to support the Policy.
Issue C2: Decentralised energy systems Q-C2: Please select the option which is most appropriate for South Warwickshire The Church Commissioners considers that Option C2a is the appropriate Option for South Warwickshire. However, the wording of Option C2a needs amending to remove the word ‘require’ and replace with ‘encourage.’ Furthermore, the size threshold needs to be specified, supported by relevant evidence, including viability. The NPPF states within Paragraph 155 to help increase the use and supply of renewable and low carbon energy and heat, plans should identify opportunities for development to draw its energy supply from decentralised, renewable or low carbon systems. 5.2 In addition, the Council must ensure Plan compliance with Paragraph 157 of the NPPF, whereby development should comply with any new development plan policies for decentralised energy unless it can be demonstrated by the applicant that it is not feasible or viable, thus ensure policy wording is reflective of viability concerns and allows for flexibility where these scenarios can be illustrated.
No answer given
QC2 The Parish Council does not have the expertise to respond to this point QC 3 .1 Don’t Know Too often a false economy and not effectively delivered. QC32 The Parish Council does not have expertise to respond to these options QC3.3 The Parish Council does not have the expertise to respond to this question
No answer given
Issue C2: Decentralised energy systems 5.22.1 St. Modwen support C2b the use of flexible policy wording to allow arrangements for carbon offsetting. We acknowledge that the consultation document has recommended a number of forms of different decentralised energy systems from the more infrastructure intensive district heating to the power only option of micro-grids. We would advocate a site specific approach with some flexibility not forcing everyone down the route of specific technologies.
Carbon offsetting policies will be very important most especially to ensure that they are not abused by developers. There is no definition of Offsetting in the Glossary and this must be addressed. Carbon emission offsetting is quite a wide subject and takes a number of forms which include: • Trees • Off-site renewable energy • Developer payment for retrofit of existing properties off-site to reduce carbon. • Offsetting outside the UK Carbon emission offsetting is necessary for specific new build categories such as flats, office buildings and industrial buildings where on site renewable energy is not possible. Carbon emission offsetting should NOT be used for low rise new residential dwellings where all of the EUI must be matched by on site renewables.
No answer given
No answer given
Climate change adaptation and climate change mitigation are core threads of the NPPF via the delivery of sustainable development. 3.48 In this context, the five overarching principles of the SWLP are welcomed and supported, in particular those that relate to climate resilience, net zero, biodiversity and environmental resilience in South Warwickshire. 3.49 Taylor Wimpey published its Environment Strategy (Appendix 3) in 2021 which established objectives and targets for climate change, nature, resource consumption and waste generation up to 2030 on new developments. 3.50 The Environmental Strategy aligns with the emerging vision, objectives and principles for the SWLP and in summary Taylor Wimpey is committed to the following targets: (i) Reduce operational carbon emissions intensity by 36% by 2025 from a 2019 baseline. (ii) Reduce carbon emissions intensity from its supply chain and customer homes by 24% by 2030 from a 2019 baseline. (iii) Increase natural habitat by 10% on new sites from 2023 and include priority wildlife enhancements from 2021. (iv) Cut waste intensity by 15% by 2025 and use more recycled materials. 3.51 Taylor Wimpey has formed several partnerships with nature organisations including Hedgehog Street and Buglife to protect and enhance natural habitats in new neighbourhoods. 3.52 It is recommended that the site selection process is informed by those strategic sites which can provide climate change adaptation and climate change mitigation as referred to in National Planning Practice Guidance (PPG) [Paragraph 003 Reference ID: 6-003-20140612 and Paragraph 007 Reference ID: 6-007-20140306].
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I want to see building reguations changed to compel new developments, whether domestic dwellings or vast logistics warehouses and factories, to have solar panels sited upon them. And the Local Authorities could set an example by requiring their own car parks (and those privately owned) to have solar panels under which cars park, thereby keeping agricultural land for food production.
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Q-C2: Caddick Land considers that Option C2a is the appropriate Option for South Warwickshire. However the wording of Option C2a needs amending to remove the word ‘require’ and replace with ‘encourage.’ Furthermore, the size threshold needs to be specified, sup ported by relevant evidence, including viability. The NPPF states within Paragraph 155 to help increase the use and supply of renewable and low carbon energy and heat, plans should identify opportunities for development to draw its energy supply from decentralised, renewable or low carbon systems. 5.2 In addition, the Council must ensure Plan compliance with Paragraph 157 of the NPPF, whereby development should comply with any new development plan policies for decentralised energy unless it can be demonstrated by the applicant that it is not feasible or viable, thus ensure policy wording is reflective of viability concerns and allows for flexibility where these scenarios can be illustrated. Q-C3.1: A carbon offsetting approach should be introduced as part of the new Local Plan to allow for flexibility in instances where it is not feasible to achieve net carbon zero requirements on a site, whether that be due to site constraints, viability or practicality of being able to develop the site. However, it is important to consider the offsetting costs fr om a viability perspective and ensure sufficient viability testing has been conducted to support the Policy.