Q-C10.1: Please select all options which are appropriate for South Warwickshire
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Yes WWT supports the use of Climate change assessments, but the Council needs a clearer plan for actually delivering and monitoring in line with the climate change priories of COP27, the Governments Climate change strategy and in line with the declared Climate Change Emergencies in both Council areas.
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Q-C10.1: Option C10.1c: None of these The SWLP should not be imposing additional requirements over and above national guidance.
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We do not have the expertise to advise on the precise nature of climate change modelling but would note that it would be onerous and unreasonable to require all applications for planning permission eg a small porch or a dropped kerb to have to produce a detailed Climate change risk assessment. We suggest that a threshold approach of 10 or more dwellings like that proposed elsewhere in the document is used.
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3.38 IM supports the Council’s overall goal of tackling climate change and achieving Net Zero Carbon. It is considered that directing growth to sustainable locations will assist the Councils in their endeavours to transition to a zero-carbon economy and would avoid the need for development to be brought forward in less sustainable locations elsewhere in the Districts. 3.39 The 2019 Spring Statement included a commitment that by 2025 the Government will introduce a Future Homes Standard for new build homes to be future-proofed with low carbon heating and ‘world-leading levels of energy efficiency’. The Government hosted public consultations from October 2019 – February 2020 and January 2021 – April 2021 respectively on the changes to Part L, Part 6 and Part F of the Building Regulations, which subsequently came into effect in June 2022. Furthermore, Building Regulations now require housebuilders to build more resilient homes to assist the Council in achieving their targets. Any policies that are contained in the Local Plan should be sufficiently flexible to allow for a continued evolution of these policies during the Plan period.
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Issue C10: Climate Change Risk Assessments At the planning stage, where decisions such as exact materials and finishes haven’t been made there often isn’t sufficient information available to consultants to make these reports accurate. There is no existing industry guidance on what a Climate Change Risk Assessment should include and cover within it. In addition, Iceni, who have experience with writing such reports, find that the information included would likely be covered in other elements of a planning submission, such as a Flood Risk Assessment or Energy and Sustainability Statement. There are therefore concerns that this is another technical, yet unnecessary, report, which will largely summarise the work of other technical reports. Moreover, most Council’s do not have the in-house abilities required to assess these reports, and therefore rely on the use of external consultants to undertake these assessments, at the cost to the applicant. This would only further increase the cost of submitting and determining an application for the Greenhill Street Site.
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Q-C10.2. Further information/ evidence testing and further consultation is required in relation to the need for new development to undertake a Climate Change Risk Assessment. At present, based on the information available it could be viewed as duplication of other proposed policies (such as adapting to higher temperatures, carbon emission etc).
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Q-C10.2. Further information/ evidence testing and further consultation is required in relation to the need for new development to undertake a Climate Change Risk Assessment. At present, based on the information available it could be viewed as duplication of other proposed policies (such as adapting to higher temperatures, carbon emission etc).
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Historic England supports the use of ‘Climate Change Risk Assessments’ as a means of determining how a development is likely to be affected by climate change. This in turn will inform which measures would be appropriate to mitigate and adapt to these effects and will be helpful in deciding on a specific course of action for historic buildings.
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Further information is required on Climate Change Risk Assessments and how these would operate. Crest Nicholson wishes to avoid any need to submit a document which might replicate what is already required by other documents submitted as part of a planning application. However if such a document is to be required, a policy should be developed that is informed by a suitable level of evidence to ensure that it is adequately justified for use in determining planning applications. Overall, the SWLP should not be imposing additional requirements over and above national guidance.
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Q-C10.1: Please select all options which are appropriate for South Warwickshire (Climate Change Risk Assessments) Bellway support option C10.1c: None of these. Option C10.1a proposes to include a policy requiring new development to undertake a climate change risk assessment to identify climatic factors likely to affect the development and the measures that can be incorporated to mitigate and adapt to these effects. Option C10.1b seeks to include a policy requirement for proposals for new development to provide a climate change checklist setting out the appropriate range of adaption and mitigation measures to be incorporated. SWLP should not be imposing additional requirements over and above national guidance. If a policy is pursued, then it should be sufficiently supported by evidence and tested in the viability assessment.
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As per Option C10.1c, Climate Change Risk Assessments (or Checklists) should not be required for all new build development and changes to existing buildings. Such a requirement would be unduly onerous and disproportionate in many cases, particularly where planning applications are submitted for minor developments or works to existing buildings. Often relevant information is already provided across the lengthy suite of application documents submitted for major applications. The need to prepare a checklist or further assessment is likely to create duplication. If a Risk Assessment is taken forward, it is vital that the LPA has sufficient expertise to review these assessments rather than putting additional burden upon applicants unnecessarily. Checklists, that are not a mandatory submission document, may be a helpful prompt for applicants to consider as part of the design process and would not result in the duplication of efforts or require the need for applicants to instruct additional parties to prepare application material
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IM Land supports the Council’s overall goal of tackling climate change and achieving Net Zero Carbon. It is considered that directing growth to sustainable locations will assist the Councils in their endeavours to transition to a zero-carbon economy and would avoid the need for development to be brought forward in less sustainable locations elsewhere in the Districts. The 2019 Spring Statement included a commitment that by 2025 the Government will introduce a Future Homes Standard for new build homes to be future-proofed with low carbon heating and ‘world-leading levels of energy efficiency’. The Consultation document (October 2019) highlighted that changes to Part L, Part 6 and Part F of the Building Regulations are anticipated to come into force by mid/late 2020. The Future Buildings Standard consultation (January 2021), which relates to non-domestic buildings and existing dwellings, provided an update on the implementation of the changes to Part L, Part 6 and Part F of the Buildings Regulations will now come into force in 2021.Therefore, Building Regulations will require housebuilders to build more resilient homes to assist the Council in achieving their targets. Any policies that are contained in the Local Plan should be sufficiently flexible to allow for a continued evolution of these policies during the Plan period.
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Further information/ evidence testing and further consultation is required in relation to the need for new development to undertake a Climate Change Risk Assessment. At present, based on the information available it could be viewed as duplication of other proposed policies (such as adapting to higher temperatures, carbon emission etc).
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Yes WWT supports the use of Climate change assessments, but the Council needs a clearer plan for actually delivering and monitoring in line with the climate change priories of COP27, the Governments Climate change strategy and in line with the declared Climate Change Emergencies in both Council areas.
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51. A checklist approach is agreed, the Council’s Development Requirements SPD Part V on Climate Change Adaptation and Mitigation is an appropriate tool which should continue to be used.
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Q-C10.1: the checklist needs to be constantly updated