Q-C6.1: Please select the option which is most appropriate for South Warwickshire
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Q-C4.1: Please select all options which are appropriate for South Warwickshire Option C4.1a: Do not have a policy and allow new development to comply with the national building regulation requirements, which may change over time. Without a policy in the plan, we would be tied in with national minimum requirements, and have no control over changes to these standards over time. If a net zero carbon policy is to be implemented by the Council, it must be fully evidenced and justified and included in viability considerations. The Building Regulations Part L 2021 Target for Fabric Efficiency would be applicable to all proposed dwellings and sets the Government’s standards for energy efficiency. The Council does not need to set local efficiency standards to achieve the shared net zero goal. Q-C6.1: Please select the option which is most appropriate for South Warwickshire It is understood that a Whole Life-Cycle Carbon Assessment considers a building’s carbon impact on the environment as a whole and are most usefully undertaken once a building has been constructed but prior to occupation. The value of Whole Life-Cycle Carbon assessments is recognised and there is no in principle objection to the need for some forms of post construction, pre-occupation assessment, however if a policy is to be pursued on this matter there are a number of key considerations: • Once sold, the purchasers and/or mortgagees will own the properties. It is unclear how units once occupied would be required to share information in respect of energy use, air quality and overheating risk data with a third party, where the developer no longer holds ownership and therefore does not have responsibility of maintaining the property. Enforcement of such a policy for future owners and occupiers could also fail the test of conditions on any subsequent planning permission. • The purpose of such information would also need to be clearly set out. It will not be possible to post factum make alterations to the constructed buildings, so what would be the benefit or purpose of such a significant amount of data collation? If the purpose is to inform and advise as to future construction methods, then this could be equally achieved by an informed and targeted research exercise by organisations such as the BRE in advising Governments and through amendments to Building Regulations.
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Q-C4.1: Should be aligned with the national approach. Q-C4.2: Should be aligned with the national approach. Q-C5: Should be aligned with the national approach. Q-C6.1: Should be aligned with the national approach.
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Q-C4.1: Should be aligned with the national approach. Q-C4.2: Should be aligned with the national approach. Q-C5: Should be aligned with the national approach. Q-C6.1: Should be aligned with the national approach.
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Q-C4.1: Please select all options which are appropriate for South Warwickshire 5.1. If a net zero carbon policy is to be employed by the Council it must be fully evidenced and justified, and included in viability considerations. 5.2. The Building Regulations Part L 2021 Target for Fabric Efficiency would be applicable to all proposed dwellings and sets the Government’s standards for energy efficient. The Council does not need to set local efficiency standards to achieve the shared net zero goal. Q-C6.1: Please select the option which is most appropriate for South Warwickshire 5.3. Whilst the value of Whole Life-Cycle Carbon assessments is recognized and there is no in principle objection to the need for some forms of post construction, pre-occupation assessment, if a policy is to be pursued on this matter there are a number of key considerations: • Once sold, properties will be owned by the purchaser and mortgagees. Any policy would need to be carefully worded such that it would not require the sharing of energy use, air quality and overheating risk data with a third party, where the developer no longer owns the dwelling as this could raise GPDR issues. Enforcement of such a policy for future owners and occupiers could also fail the test of conditions on any subsequent planning permission. • The purpose of such information would also need to be clearly set out. It will not be possible to post factum make alterations to the constructed buildings, so what would be the benefit or purpose of such a significant amount of data collation? If the purpose is to inform and advise as to future construction methods, then this could be equally achieved by an informed and targeted research exercise by organisations such as the BRE in advising Governments and through amendments to Building Regulations.
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Issue C4 – New Buildings Q-C4.1 – Please select the building regulations requirement option that is appropriate for South Warwickshire Option C4.1a: Do not have a policy and allow new development to comply with the national building regulation requirements, which may change over time. The SWLP is being prepared to cover the period up to 2050. During the course of the plan period building regulations will change. It is appreciated that it is highly likely that there will be at least one Local Plan review within the next 5 to 10 years, however, by the time a replacement Local Plan is in place updated building regulations could have been implemented and could result in an out of date policy in the SWLP.
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Q-C4.1 – Please select the building regulations requirement option that is appropriate for South Warwickshire Option C4.1a: Do not have a policy and allow new development to comply with the national building regulation requirements, which may change over time. The SWLP is being prepared to cover the period up to 2050. During the course of the plan period building regulations will change. It is appreciated that it is highly likely that there will be at least one Local Plan review within the next 5 to 10 years, however, by the time a replacement Local Plan is in place updated building regulations could have been implemented and could result in an out of date policy in the SWLP.
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Q-C4.1 – Please select the building regulations requirement option that is appropriate for South Warwickshire Option C4.1a: Do not have a policy and allow new development to comply with the national building regulation requirements, which may change over time. The SWLP is being prepared to cover the period up to 2050. During the course of the plan period building regulations will change. It is appreciated that it is highly likely that there will be at least one Local Plan review within the next 5 to 10 years, however, by the time a replacement Local Plan is in place updated building regulations could have been implemented and could result in an out of date policy in the SWLP.
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Issue C4: New Buildings: Warwick District Council should set a higher local standard beyond the building regulations requirements to achieve net zero carbon in all new developments.
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Q-C6.1: The Church Commissioners acknowledge that it is important to consider the emissions resulting from materials, construction activities and the use of a building over its lifetime. However, the Councils have not presented any evidence to justify the options presented at this stage. Therefore, at present, without viability evidence and a baseline for emissions data, it is not possible, or justified to introduce Option C6.1a as a Policy. Option C6.1a would have a detrimental impact upon the viability of developments, and would potentially impact upon delivery of sites coming forward. A Policy requiring new developments to have a target for 100% reduction in embodied emissions would negate the requirements of the Plan to deliver much needed houses and employment land, and therefore not achieve the overall Vision. 5.7 To put this Option into perspective, within London, only those developments that are referrable to the Mayor are required to produce and calculate a whole life-cycle carbon emission assessment. Furthermore, paragraph 152 of the NPPF sets out that the planning system should support the transition to a low carbon future, noting the word transition, as such the proposed 100% reduction does not accord with a transitional approach. Option C6.1b provides potential for a flexible approach, whereby developments of certain size criteria should demonstrate their calculations within a whole life-cycle carbon emission assessment, however the required reduction in embodied emissions needs to be viability tested and strongly considered, as this may negatively impact upon sites coming forward for development. The Council also need to decide their priorities in terms of what they want developments to achieve, as having a higher required reduction in embodied emissions, may then impact upon the ability to provide the policy required affordable housing percentage, or the required additional infrastructure. The Issues and Options Document sets out that ‘the SWLP must contribute to the achievement of sustainable development, and this means balancing the need for more jobs and homes against the impact on the built and natural environment.’ Consequently, the Councils need to establish the balance and levels of priority, in order to establish the requirement of this proposed policy. The Church Commissioners suggests further evidence is conducted by the Councils to decipher the potential requirement and to establish their balance in greater detail, followed by further stakeholder engagement on the matter. Q-C6.2: If a phased approach is used, what dates and thresholds should be used? 5.8 The dates and thresholds should be realistic and justified, but underpinned by evidence undertaken by the Councils. The approach should correspond with Part L of the Building Regulations to ensure consistency throughout. It is important to also accord with the NPPF, which sets out within Paragraph 152 that the planning system should support the transition to a low carbon future in a changing climate, thus any proposed planning policy should be transitional, but also prepared positively, ensuring aspiration but deliverability, as per paragraph 16 of the NPPF.
Q-C4.1: Please select all options which are appropriate for South Warwickshire Option C4.1a should be pursued by the Councils, whereby national Building Regulations will stipulate the levels required for new buildings in order to minimise emissions. The national Building Regulations will be updated, in accordance with the climate emergency and net-zero carbon agenda pursued by the Government. This will ensure that new developments align with planning policy and building regulations. Whereas, by utilising Option C4.1b, setting higher standards, will make new developments more expensive due to the additional requirements to be met in order to achieve policy compliance, which will impact upon the overall viability of the scheme, and ultimately affect obligations, in terms of the quantity of affordable housing that can be required, the infrastructure requirements and other associated financial contributions, which would have a greater negative effect, where the harm would outweigh the benefit. 5.5 Overall, Option C4.1a would ensure that new development is built in accordance with National Building Regulations, therefore ensuring that homes must produce 30% less carbon dioxide emissions than previous standards, which will increase to 75-80% less emissions by 2025, to eventually become zero-carbon. This structure therefore clearly demonstrates the need for developments to acknowledge the need to reduce carbon emissions, which will increase gradually, achieving South Warwickshire’s desire to be carbon neutral, thus achieving sustainable developments. Q-C6.3: Please add any comments you wish to make about Net Zero Carbon buildings in South Warwickshire. The Church Commissioners reiterates that the Councils need to undertake greater research to inform their evidence base in relation to reducing embodied emissions and thus whole lifecycle emissions. The Church Commissioners acknowledges the need to consider the carbon emissions associated with the process of developing a site, taking into account during construction and operationally, however re-emphasises the need for the Councils to consider viability of sites. The councils need to strike a balance between the deliverability of housing and employment land, to ultimately achieve sustainable development and the overall vision of the Local Plan, whilst also considering the environmental impacts and the opportunities available to minimise carbon emissions. 5.10 As per Paragraph 009 (Reference ID: 6-009-20150327), there is a requirement for local planning authorities when setting any local requirement for a building’s sustainability to do so in a way consistent with the government’s zero carbon buildings policy, ie in accordance with Part L of the National Building Regulations. The PPG continues to state that local requirements will need to be based on robust and credible evidence and pay careful attention to viability.
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The Parish Council does not have the expertise to respond to these options. QC5 The Parish Council does not have the expertise to respond to these options
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Issue C6: Whole Life-Cycle carbon emission assessments 5.23.1 St. Modwen believe that requiring a policy which seeks Whole Life-Cycle Carbon (WLC) Assessments for all new developments is a challenging target. Seeking a target for 100% reduction in embodied emissions is a bold ambitious target that would be quite challenging for the market to deliver at this point in time. That said, the industry is evolving rapidly and by the time the Plan comes into force it is likely that there will be more WLC Tools on the market. Careful consideration should be given to the wording of SWLP policy and the potential use of an SPD to cover this topic may provide more Local Plan flexibility to adapt as technology changes.
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Household and business water use is a carbon intensive resource, both in the supply and the use of it in the home i.e heating of water. Any Net Carbon Approach should incorporate water use efficiency as a core element which will have multiple benefits.
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Requiring whole life-cycle carbon assessments is most definitely the right thing to aspire to on the journey to net zero by 2050. However the paragraph outlining this on page 129 seems to have been written based on incorrect assumptions. Here is the paragraph: “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. “ The Whole Life Cycle calculations can and must be done during the design stage and look to reduce the carbon impact of both the construction process the materials used and future maintenance. The Whole Life-Cycle would include: • Design • Construction process • Construction materials • Regulated carbon in operation • Un-regulated carbon in operation. • Future retrofitting, repairs and maintenance Consider the definitions used by LETI: Make no mistake – this is extremely complicated and time consuming and MUST not detract from making progress towards true net zero carbon for regulated and unregulated energy. This certainly requires a policy but implementation MUST be after the mandate for true net zero for regulated and unregulated carbon as part of the operation of the building. Requiring this now will just hold back the key issue of improving energy efficiency and reducing carbon emissions from the operation of a building. Reducing the carbon emissions by 100% for construction and materials WILL NOT HELP REDUCE energy costs for occupants. As yet there is no agreed method to calculate embodied energy and the following was published by UK Green Buildings Council (UKGBC) in January 2023: “The https://www.ukgbc.org/ukgbc-work/net-zero-whole-life-roadmap-for-the-built-environment/ sites measurement and targets for embodied carbon as one of the key priorities for decarbonising the built environment. Embodied carbon has also become increasingly important within wider political contexts with the suggestions of Part Z and Grade III listed status. UKGBC has opened applications to join the Task Group of Industry experts for Its project on embodied carbon. The project aims to build on the Net Zero Whole Life Carbon Roadmap and seek to provide clarity on measurement and reporting on embodied carbon, as well as how Embodied Carbon Assessments can link into scope 3 reporting.“ As the SWLP develops there will be national guidance available later in 2023.
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Option C4.1c: Have a phased approach to net zero carbon, setting a future date by which all new development will need to achieve net zero standards. In the intervening period new development will need to meet building regulation standards. To encourage all developments to deliver a net zero carbon development there should be an allowance for flexibility and support from the council in each individual planning consent, to incentivise developers to use sustainable development methods and materials to ensure that there is a level playing field for developers. As well as this, there should be a document that clearly sets out sustainable development methods and materials that are allowed under permitted development. Some Councils have implemented a ‘Net Zero Carbon Toolkit’ to set out why we need to deliver net zero carbon home and how we can achieve this in line with relevant legislation. We suggest the above suggestions are uniformly implemented. It is suggested that as well as the Council looking at the implementation of Net Zero Carbon developments on a site-by-site basis, it is recommended that the council should avoid onerous planning obligations such as CIL and S106 obligations when looking into how to encourage and implement net zero carbon developments to ultimately increase the viability of projects. Improvements or requirements will have implications on the viability across the majority of schemes.
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The dates and thresholds should be realistic and justified, but underpinned by evidence undertaken by the Councils. The approach should correspond with Part L of the Building Regulations to ensure consistency throughout. It is important to also accord with the NPPF, which sets out within Paragraph 152 that the planning system should support the transition to a low carbon future in a changing climate, thus any proposed planning policy should be transitional, but also prepared positively, ensuring aspiration but deliverability, as per paragraph 16 of the NPPF.
Q-C4.1: Option C4.1a should be pursued by the Councils, whereby national Building Regulations will stipulate the levels required for new buildings in order to minimise emissions. The national Building Regulations will be updated, in accordance with the climate emergency and net-zero carbon agenda pursued by the Government. This will ensure that new developments align with planning policy and building regulations. Whereas, by utilising Option C4.1b, setting higher standards, will make new developments more expensive due to the additional requirements to be met in order to achieve policy compliance, which will impact upon the overall viability of the scheme, and ultimately affect obligations, in terms of the quantity of affordable housing that can be required, the infrastructure requirements and other associated financial contributions, which would have a greater negative effect, where the harm would outweigh the benefit. 5.5 Overall, Option C4.1a would ensure that new development is built in accordance with National Building Regulations, therefore ensuring that homes must produce 30% less carbon dioxide emissions than previous standards, which will increase to 75 -80% less emissions by 2025, to eventually become zero-carbon. This structure therefore clearly demonstrates the need for developments to acknowledge the need to reduce carbon emissions, which will increase gradually, achieving South Warwickshire’s desire to be carbon neutral, thus achieving sustainable developments. Q-C6.1: Caddick Land acknowledges that it is important to consider the emissions resulting from materials, construction activities and the use of a building over its lifetime. However, the Councils have not presented any evidence to justify the options presented at this stage. Therefore, at present, without viability evidence and a baseline for emissions data, it is not possible, or justified to introduce Option C6.1a as a Policy. Option C6.1a would have a detrimental impact upon the viability of developments, and would potentially impact upon delivery of sites coming forward. A Policy requiring new developments to have a target for 100% reduction in embodied emissions would negate the requirements of the Plan to deliver much needed houses and employment land, and therefore not achieve the overall Vision. 5.7 To put this Option into perspective, within London, only those developments that are referrable to the Mayor are required to produce and calculate a whole life-cycle carbon emission assessment. Furthermore, paragraph 152 of the NPPF sets out that the planning system should support the transition to a low carbon future, noting the word transition, as such the proposed 100% reduction does not accord with a transitional approach. Option C6.1b provides potential for a flexible approach, whereby developments of certain size criteria should demonstrate their calculations within a whole life-cycle carbon emission assessment, however the required reduction in embodied emissions needs to be viability tested and strongly considered, as this may negatively impact upon sites coming forward for development. The Council also need to decide their priorities in terms of what they want developments to achieve, as having a higher required reduction in embodied emissions, may then impact upon the ability to provide the policy required affordable housing percentage, or the required additional infrastructure. The Issues and Options Document sets out that ‘the SWLP must contribute to the achievement of sustainable development, and this means balancing the need for more jobs and homes against the impact on the built and natural environment.’ Consequently, the Councils need to establish the balance and levels of priority, in order to establish the requirement of this proposed policy. Caddick Land suggests further evidence is conducted by the Councils to decipher the potential requirement and to establish their balance in greater detail, followed by further stakeholder engagement on the matter. Q-C6.3: Caddick Land reiterates that the Councils need to undertake greater research to inform their evidence base in relation to reducing embodied emissions and thus whole lifecycle emissions. Caddick Land acknowledges the need to consider the carbon emissions associated with the process of developing a site, taking into account during construction and operationally, however re-emphasises the need for the Councils to consider viability of sites. The councils need to strike a balance between the deliverability of housing and employment land, to ultimately achieve sustainable development and the overall vision of the Local Plan, whilst also considering the environmental impacts and the opportunities available to minimise carbon emissions. 5.10 As per Paragraph 009 (Reference ID: 6-009-20150327), there is a requirement for local planning authorities when setting any local requirement for a building’s sustainability to do so in a way consistent with the government’s zero carbon buildings policy, ie in accordance with Part L of the National Building Regulations. The PPG continues to state that local requirements will need to be based on robust and credible evidence and pay careful attention to viability.
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Do not have a policy and allow new development to comply with the national building regulation requirements, which may change over time.