Net Zero Carbon Development Plan Document - Regulation 19

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Comment

Net Zero Carbon Development Plan Document - Regulation 19

4.1 Aim

Representation ID: 72190

Received: 08/06/2022

Respondent: Warwick District Labour Party

Representation Summary:

Covered in previous Comment

Comment

Net Zero Carbon Development Plan Document - Regulation 19

4.2 Objectives

Representation ID: 72191

Received: 08/06/2022

Respondent: Warwick District Labour Party

Representation Summary:

4.2.1 needs to be reworded as zero carbon on new builds will not be achieved or sustained - see comments under 1.3 and 4.1 above.

Comment

Net Zero Carbon Development Plan Document - Regulation 19

5 Overarching strategy – Achieving Net Zero Carbon Development

Representation ID: 72193

Received: 08/06/2022

Respondent: Warwick District Labour Party

Representation Summary:

Not just a strategy for newbuilds.

Set higher standards than anticipated 2025 national ones.

SAP and SBEM out of date and poor methodologies for calculating emissions eg performance gap not measured - see Jan 22 WDC policy review

We must have robust and specific tools here eg PHPP and with scope for LPA to update and toughen as methodologies improve.

Specify achieved energy standards test of all newbuilds at 9 years within 10 year guarantee period.

Why lim it standards to buildings over 1000sqm? What standards apply to smaller buildings?

Comment

Net Zero Carbon Development Plan Document - Regulation 19

6 Reducing Energy Demands: Energy Efficient Buildings

Representation ID: 72194

Received: 08/06/2022

Respondent: Warwick District Labour Party

Representation Summary:

DPD should require solar panels as default on all developments to reflect the latest technology which enables successful installation even on oblique roofs. The clear WDC objective should be to encourage installation on all roofs.

WDC should apply higher standards than the anticipated 2025 National future Homes Standard if legal? Can this be done where the trade-off costs v carbon emission reduction is reasonable (whole life cost analysis)?

The DPD should explicitly allow the LPA to vary such standards as technology and experience evolve

All plans (new and retro) to include reskilling/upskilling of existing workers in clean/green and apprenticeship funds.

Comment

Net Zero Carbon Development Plan Document - Regulation 19

7 Energy sources

Representation ID: 72195

Received: 08/06/2022

Respondent: Warwick District Labour Party

Representation Summary:

The potential 'feasibility' or 'viability' loophole should be removed or at least drastically redrafted to reflect NPPF policy and guidelines (para 2 of draft policy). These clearly indicate that lack of profitability on a scheme will primarily require adjustment to land purchase value not to the delivery of key Plan policies - of which this DPD will be a top priority for the foreseeable future. And that any issues of viability must be raised at or before a planning application is submitted.

Is gas ruled out by 7.3? Can it be made less ambiguous (see fuller comment in 4.1)

Comment

Net Zero Carbon Development Plan Document - Regulation 19

8 Carbon Offsetting

Representation ID: 72197

Received: 08/06/2022

Respondent: Warwick District Labour Party

Representation Summary:

Option to upgrade completed building efficiency may be possible and preferable to a carbon offset payment; this should be made clear in the policy.

If it is necessary to include offsetting (which we do not favour) it must pass a stringent technical alternative test and NOT be permitted simply as an easier or cheaper option.

If a 9-year performance reassessment is required as suggested elsewhere, the same option - upgrade to original standard or costly carbon offset - should also be in the policy.

Will WDC set an example by committing not to seek carbon offset solutions to efficiency challenges?

Comment

Net Zero Carbon Development Plan Document - Regulation 19

9 Embodied Carbon

Representation ID: 72198

Received: 08/06/2022

Respondent: Warwick District Labour Party

Representation Summary:

Why is whole life calculation limited to larger developments and buildings?

9.3 Be specific on tests used - not 'such as' while leaving it to LPA to bring in improved standards and methods

Explicit preference for refurbishment and repurposing or buildings to minimise adding to embodied carbon to be clear requirement.

Consider sliding scale carbon offset charge for all demolitions linked to how far new design achieves zero carbon.

Comment

Net Zero Carbon Development Plan Document - Regulation 19

10 Existing Buildings

Representation ID: 72199

Received: 08/06/2022

Respondent: Warwick District Labour Party

Representation Summary:

Support this outline policy but more specific guidance/policy adjustments are needed for example to enable -
- use of non-traditional materials in conservation areas eg windows
- installation of double glazing on all pre-1914 buildings, both in and outside Conservation areas, with minimal visual harm.
- installation of solar panels/heat pumps on these buildings - but only to supplement the benefits of modern double glazing which should be a policy priority.

Explicit priority to be given to schemes which alleviate energy poverty in all tenures - can this be incentivised in some ways?

Comment

Net Zero Carbon Development Plan Document - Regulation 19

11 Viability

Representation ID: 72200

Received: 08/06/2022

Respondent: Warwick District Labour Party

Representation Summary:

Remove feasibility or viability loophole from policy altogether. If not, then drastically redraft to reflect NPPF policy and guidelines eg remove para 11.2

Support

Net Zero Carbon Development Plan Document - Regulation 19

12 Warwick District Local Plan 2011-2029 - Policies superseded or amended by this DPD

Representation ID: 72201

Received: 08/06/2022

Respondent: Warwick District Labour Party

Representation Summary:

Needs to toughen and supersede former policies

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