Issue and Options 2023

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Review of Chapter 7. Foreword: The SWLP is for a 25-year period to 2050. One question we should be asking is: What will the people in 2049 be thinking of those who developed this Local Plan? Will they be pleased, or will they wonder at the poor ambitions and insight of those of today? The most important part of this section is 7.2 Zero Carbon Buildings. With currently circa 40% of CO2 from buildings (27% domestic and 13% non-domestic) the issue in terms of carbon reduction in relation to the climate emergency is of the utmost importance. Consider first the definitions included within the glossary of the consultation document. There are three definitions to consider which is quite confusing. The Net Zero Carbon definition in the Glossary is ambiguous and also not completely transparent. What is meant by “balancing carbon dioxide emissions by removal”? Is this allowing offsetting and if so, what offsetting is acceptable and what is not acceptable. The wording “….or simply eliminating carbon dioxide emissions altogether” is much clearer and unambiguous. As yet there is not a nationally agreed definition of net zero carbon. This is set to change with an initiative launched in 2022 the UK Net Zero Carbon Buildings Standard. This is being developed by the following organisations with the support of an advisory group of some 500 UK experts. The ambition is to have an agreed definition and a verification process by the summer of 2023. What is clear from the work of the advisory group is that it is almost impossible to get to net zero carbon using the tools currently within the building regulations namely SAP and SBEM. This fact is actually recognised by Warwick District Council. The following is an extract from a document included within the submission in 2022 for the Warwick DC Net Zero Carbon DPD. From the above it is clear that WDC are fully aware that the entire methodology of SAP and SBEM are not fit for purpose as compliance tools now and most especially for the requirements of true Net Zero Carbon It should be noted that there are experts who are of the opinion that the WDC Net Zero Carbon title for the DPD is both incorrect and misleading. In order to provide the direction of travel for a true net zero carbon definition the following might be useful: To understand what is required for true net zero carbon the direction of travel is to get away from % improvements and instead develop what is called an Energy Use Intensity (EUI) target. For housing this could be set at approximately 30 kWh/m2/yr. EUI will include all regulated and unregulated energy – i.e. All metered energy. For low rise housing ALL of the EUI will be met by on site renewables – i.e. PV panels. For apartments higher rise buildings and many non-domestic buildings, it is generally not possible to meet all of the EUI with on site renewables and so appropriate offsetting (not including trees) is allowed. More on offsetting later. In order to give an insight of how policy requirements will deliver true net zero carbon the following is an extract from the Cornwall Climate Emergency DPD Cornwall Council submitted the Climate Emergency DPD for independent examination in November 2021. The Planning Inspector has confirmed that the plan is sound subject to recommended modifications. The plan can now proceed to adoption on 21st February 2023 A similar ambitious document also confirmed as sound by the Planning Inspector is the Bath and Northeast Sommerset Local Plan (BNES) Similar ambitious Local Plans are being prepared by Greater Cambridge and Central Lincolnshire amongst others. All have developed a similar direction of travel towards true Net Zero Carbon. It should be noted that: Scotland mandates Passivhaus equivalent legislation A seismic change in building standards is underway in Scotland. All new build homes in Scotland will soon have to meet greater levels of energy efficiency after the Scottish Government agreed to progress legislation proposed by Scottish Labour MSP Alex Rowley. In December 2022 Scottish government ministers announced plans to make all new build housing meet a Scottish equivalent to the Passivhaus standard within the next two years. Work to develop the standard will commence early in 2023, seeking the laying of amending regulations in mid-December 2024. This is HUGE and a potentially game-changing move for building performance, comfort, very low energy bills, and climate action in Scotland! Its ripples will extend far beyond Scotland and is already attracting global attention. 7.2 Net Zero Carbon Buildings. The consultation document says “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. “ In reality it is almost impossible to get to true net zero carbon using % reduction through the 2021 Building Regulations. The guaranteed way to get to true net zero carbon is to have specific energy targets known as Energy Use Intensity (EUI) – in kWh/m2/y and match this with the generation of renewable energy - where possible on site. (e.g. for low rise housing). A definition for Energy Use Intensity should be added to the Glossary. Importantly there is no mention of the Performance Gap, nor is there a definition of this in the Glossary. This needs to be addressed. Page 125 – states “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” However the National Design Code 2019 has been replaced by the National Model Design Code 2021, which does not have this wording. We suggest the local plan should include the following wording: 1. Reduce the need for energy to a target EUI for example 30kWh/m2/yr. for dwellings. Separate targets are needed for regulated and unregulated energy the sum of which amount to the EUI. 2.Use energy efficient mechanical and electrical systems, including heat pumps, heat recovery and LED lights; 3. Renewable energy on site to at least match the EUI. Decentralised sources are not relevant for true net zero carbon low rise dwellings. Figure 24 – The Energy Hierarchy is basically out of date BREEAM: There is no mention of the use of BREEAM in the text. The only mention is in the information relating to existing policy documents from Stratford and Warwick. BREEAM is also not included in the Glossary. Stratford use BREEAM ‘Good’ and Warwick use BREEAM ‘Very Good’. Regretfully both are totally inadequate. Indeed although BREEAM does provide sustainable benefits it will not on its own deliver true net zero carbon as demonstrated in the following extract from the Cornwall Climate Emergency DPD recently approved by the Inspector. The way forward / direction of travel to true net zero carbon is set out in the Foreword to section 7. Issue C4 New buildings The following statement on page 127 is absolutely correct, however the way forward proposed in section 7.2 will not deliver this ambition. 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. The document should contain reference to the tools available for the design and construction of new buildings. Commercial buildings: • BREEAM • NABERS • Passivhaus Domestic Buildings: • Passivhaus • AECB • BEPIT (Building energy performance improvement toolkit) • Assured Performance Process (APP) Definitions for all of these tools should be included in the Glossary. I have not answered the questions containing in the consultation document as Chapter 7 needs to be completely revised. Take for answer Option C4.1b.set out as follows: Option C4.1b: Set a higher local standard beyond the building regulations requirements to achieve net zero carbon in all new developments. This would require all new development to achieve net zero carbon from adoption of the plan, expected in 2025. However, it would be at a cost as the development industry may not be ready to viably deliver this and as a consequence we may see less affordable housing built and maybe fewer other social and community benefit from development to offset the cost of achieving net zero carbon. Viability work would be needed to establish the impact of this approach. The cost of going to net zero carbon using for example the Passivhaus Certification or equivalent route (as set out by the Scottish Government) involves an additional capital cost of less than 10%. Some put the additional cost at between 6% and 8%. To keep the additional cost to be neutral, the amount could be taken off the cost of the land! The second point regarding the industry not being ready is nonsense. The sector has been aware of this for years most especially for housing with the Code for Sustainable Homes and the then ‘Zero Carbon new homes from 2016’ abandoned by the Conservative administration in 2015. The third point is that the sector does not want true net zero carbon buildings as they (designers, developers and contractors) will need to demonstrate this through building performance evaluation in use. Currently and within this document they can continue with ignoring the ‘performance gap’ Issue C5: Existing Building There is a huge challenge in getting all existing buildings to be true net zero carbon. The policy needs to recommend that all retrofit should be undertaken to a specific standard. The reason for this is that the current supply chain out there in the market can be likened to the ‘wild west’. If deep retrofit is not done properly the health and wellbeing of occupants and indeed building fabric will suffer. The following is a list of appropriate standards: • PAS 2035 for domestic buildings • PAS 2038 for non-domestic buildings • EnerPHit Standards – this is retrofit using the Passivhaus Standard • Energiesprong – this would be useful for council homes and social housing. • AECB or LETI - Retrofit Standard for housing. Other initiatives to consider: • National Retrofit Hub - There is an initiative which has just received funding (January 2023) from Innovate UK to establish a National Retrofit Hub and regional/ local retrofit hubs emerging around the country (e.g. https://retrofit.coop/ in Manchester, https://cosyhomesoxfordshire.org/ . SWLP should look to establish a local partnership with the National Retrofit Hub to train the supply chain including procurers, designers and contractors. • Historic Buildings: There needs to be a clarification around definitions of 'Historic Buildings'. This implies listed buildings / conservation area status etc. The 'better' term would be 'Traditional Buildings' - this then includes all solid walled / timber framed buildings. Traditional Buildings require a risk-based approach as defined in guidance from Historic England and the Sustainable Traditional Buildings Alliance (STBA) • EnerPHit Standards – this is retrofit using the Passivhaus Standard – although an excellent standard it probably goes too far for most buildings, except for linear blocks (e.g., blocks of flats, either horizontal or vertical blocks). There seems to be a consensus starting to emerge around “heat-pump ready” as an acceptable first step on the retrofit journey. This means doing sufficient fabric improvement to allow a heat pump to work efficiently, and hence not to drive up energy costs when switching from gas to electric heating. There are still arguments about exactly how far the fabric improvements should go – should it be far enough that you can re-use the existing heating system, which will operate at lower temperatures and therefore put out less heat? Or do you not need to go that far and accept that you need to add in more radiators – you just do it based on the sizing of the heat pump. Either way, it needs to be done as part of a whole house retrofit plan, so that any changes don’t waste any measures that are installed i.e. they won’t need ripping out again later if any further improvements are planned. Anyway, that seems to be the general position that’s emerging from both LETI and the AECB. • Energiesprong – this would be useful for council homes and social housing – this is another excellent solution but probably also goes too far for most buildings. See above The relation between the new AECB Standard and PAS is as follows: PAS is a process that requires you to take a whole house approach. The AECB standard (now two levels) sets actual performance targets. Operational Energy in kWh/m2/y – Lifetime Carbon kg/CO2e and kg/CO2/m2 Note – all the information in the SWLP being about % reduction is NOT the way forward. The solution is to use Energy Use Intensity as explained elsewhere in this document. Energy Performance Certificates. In assessing an existing building for a deep retrofit it is appreciated that currently for local authorities the only tool is the EPC. It should be carefully noted that the EPC is considered by experts to be not fit for purpose. The Climate Change Committee have set out the need to reform the domestic EPC rating metrics to support the delivery of Net Zero. The letter was sent to Lee Rowley MP, Parliamentary Under Secretary of State, Department for Levelling Up, Housing and Communities on the 2nd February 2023. Issue C6 Whole Life-Cycle carbon emission assessments page 129 Requiring whole life-cycle carbon assessments is most definitely the right thing to aspire to on the journey to net zero by 2050. This is extraordinarily ambitious and must be undertaken as part of the design stage. The paragraph outlining this on page 129 is bonkers. 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. Why do it once the building has been constructed? The Whole Life-Cycle would include: • Design • Construction process • Construction materials • Regulated carbon in operation • Un-regulated carbon in operation. • Future retrofitting, pairs and maintenance Most usefully, the exercise must be undertaken during the design stage and look to reduce the carbon impact of both the construction process the materials used and future 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 regulated in 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 UKGBC earlier in January 2023. The Net Zero Whole Life Carbon Roadmap 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. 7.3 Climate responsive development design: page 129 The two opening paragraphs set the scene quite well and are seriously ambitious. What is clear is that the 4 existing policies from Stratford and Warwick that follow will not deliver the aspirations of what needs to be done NOW. The comments on BREEAM that are made earlier in this submission apply. BREEAM is good to have and will help deliver a better Climate response – however BREEAM Good and Very Good are inadequate and BREEAM MUST be included in the design to achieve the highest category available at the time of the final publication of the SWLP. To emphasise an earlier point - all current BREEAM categories will not deliver true net zero carbon.

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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 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.

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Issue C7: Adapting to higher temperatures Table 14 – The cooling Hierarchy. The four points require modification and updating. There is no mention of MVHR (mechanical ventilation with heat recovery). This is ESSENTIAL for true net zero carbon buildings and on all buildings new or existing where the air tightness is less than 3 cubic metres per square metre of internal surface area of the building m3. At 50Pa The notation is 3m 3/(h·m 2)@50Pa The reason for this is in relation to the health and wellbeing of the occupants. A definition for `MVHR should be added to the Glossary. Need to add specific comments on the size and orientation of windows. Windows should also be triple glazed. Specific comments referring to the numbered items in the table on page 131. 1. The sentence here is wrong - ‘Such ventilation should be cable to preserve air tightness in cold weather” Closing ventilation will adversely affect the indoor air quality. For example, in Scotland all new housing must have CO2 monitors in bedrooms. This should also apply to schools. 2. This should be MVHR 3. Again, this should be MVHR 4. All building ventilation to have MVHR. The mistake that has been made in developing this table is that the assumption is that the airtightness will be 3 or more. The 2021 regulations have air tightness at <8m 3/(h·m 2)@50Pa – for true net zero carbon it needs to be at about 0.6 which is the requirement for Passivhaus certification. The paragraphs on the use of cool materials and green infrastructure are correct. Green roofs also help with flood control through attenuation of rainwater see later comment. Issue C8 Adapting to flood and drought events. SUDS. This paragraph is fine but does not go far enough. There needs to be a policy that for existing domestic and non-domestic buildings such that SUDS MUST apply where a driveway or hardstanding is being added or replaced. Green Roofs. In continental Europe Green Roofs are used to help control storm water flooding. This is because a Green Roof will go some someway to attenuate the flow of storm water. Will there be the need before 2050 to account for the carbon footprint of water used in the manufacture of construction materials………and during the construction process? A point to consider. Reducing water consumption. Reducing to 100 litres per person per day sounds OK – However need to look at what is best practice internationally.

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Issue C10: Climate change Risk Assessments. Whilst the contents of the single paragraph seem sensible, will this process be fit for purpose in 2050? It is important that a climate change risk assessment is required by planning for all new developments. A barrier here is the fact that the climate emergency is NOT considered to be a material planning issue. Can this be mandated in the SWLP?

C11: Water Management The two currently adopted policies that are highlighted in the table refer to the maintenance of ‘good’ status of water bodies. Is ‘good’ status the highest-level status in existence? If not, the highest status MUST be included. Water quality offsetting! Yet another example of Offsetting that will require careful policy interventions. Issue C12: Flood risk. It should be noted that the Government has recently put the NPPF out to consultation. This section can only be revied when Part 2 of the SWLP is published.

Issue 1 Sustainability Appraisal. Consideration should be given to investigating the use of a new tool which is being used to help local authorities with spatial carbon modelling. This has recently been used to assist Greater Cambridge and Central Lincolnshire to identify the lowest-carbon route for new developments.

Growth opportunities in the Green belt should be limited to the development of infill sites and the revision of village boundaries to take account of the existing built environment. To illustrate the potential for growth, we propose moving the Kingswood village boundary as shown on the attached plan no. 29 from the Warwick Local Plan 2011-1019 adopted 2017. The land we proposed to be included in the BUAB is of the same character as what is already included within the BUAB i.e. land which is already built upon and a very different character to the green fields beyond taking into account the urban grain and character of the built up area of Kingswood. The following facts support the proposal. 1. There is a footpath on the north side of the B4439 that extends eastwards beyond the canal bridge over the Grand Union past the Navigation car park and past Clinton House and turns into the bridleway that is part of the designated Heart of England Way which we propose should define the new boundary. 2. The footpath is lit eastwards beyond the entrance to Clinton House. 3. From the new boundary it is a 12 minute walk to Lapworth station on the Chiltern Line. 4. Kingswood is served by three bus routes, nos. 511, 513 and 514, each of which travel along the B4439 and stop adjacent to Station Lane on the B4439 in the village centre. 5. The distance to the shops in the village centre comprising a general store, post office, off-licence, hairdresser, car workshop and garage is approximately 300m. The village also has a primary school and a medical practice with 3 GPs. 6. The position of the 30mph speed limit is currently shown on the attached plan, being just within the proposed boundary. By reference to the Stratford Site Allocation Plan and the methodology used to decide what should be included within the BUAB the proposal meets the criteria, see page 318 of the document. See link https://www.stratford.gov.uk/doc/209801/name/Composite%20version%20v3.pdf In conclusion, by making a limited and judicious adjustment to the village boundary it opens up potential development sites that could accommodate growth shown in hatching on the attached plan.