Issue and Options 2023

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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.

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Zero Carbon Buildings Issue C4: New Buildings 67. The HBF supports the Government’s intention to set standards for energy efficiency through the Building Regulations. The key to success is standardisation and avoidance of individual Council’s specifying their own policy approach to energy efficiency, which undermines economies of scale for product manufacturers, suppliers and developers. The Councils do not need to set local energy efficiency standards in a Local Plan policy because of the higher levels of energy efficiency standards for new homes set out in the 2021 Part L Interim Uplift and proposals for the 2025 Future Homes Standard. Issue C6- Whole Life- Cycle carbon emission assessment 68. The HBF would question the justification and purpose of a policy that requires a whole life-cycle carbon emission assessment. It is not evident how a decision maker would be expected to react to development proposals using such a policy. Although the consultation questions suggest requiring the calculation of the whole life cycle carbon emissions and actions to reduce life cycle carbon emissions, it is not clear from the consultation how it will be determined what the appropriate level of emissions is, or what would be an appropriate level of emission reductions. 69. The HBF also has significant concerns in relation to this policy particularly in relation to the elements in relation to performance and monitoring. It is not clear what the Councils would do with the information in relation to performance information or the monitoring information once the development is completed and is a home. The HBF also considers that it is unlikely that any household would wish to share their personal energy usage information with the developer of the site or the Council, how they choose to live in their home once purchased is surely down to the individual household.

Issue C8: Adapting to flood events and drought 70. As set out in the NPPF (para 31), all policies should be underpinned by relevant and up to date evidence, which should be adequate, proportionate and focussed tightly on supporting and justifying the policies concerned. Therefore, a policy requirement for the optional water efficiency standard must be justified by credible and robust evidence. 71. If the Council wishes to adopt the optional standard for water efficiency of 110 litres per person per day, then the Council should justify doing so by applying the criteria set out in the PPG (ID: 56-014-20150327). PPG states that where there is a ‘clear local need, Local Planning Authorities (LPA) can set out Local Plan Policies requiring new dwellings to meet tighter Building Regulations optional requirement of 110 litres per person per day’. PPG (ID: 56-015-20150327) also states the ‘it will be for a LPA to establish a clear need based on existing sources of evidence, consultations with the local water and sewerage company, the Environment Agency and catchment partnerships and consideration of the impact on viability and housing supply of such a requirement’. The Housing Standards Review was explicit that reduced water consumption was solely applicable to water stressed areas. 72. Building Regulations require all new dwellings to achieve a mandatory level of water efficiency of 125 litres per day per person, which is a higher standard than that achieved by much of the existing housing stock. This mandatory standard represents an effective demand management measure. The Optional Technical Housing Standard is 110 litres per day per person. Issue C11: Water Management 73. Development should only be asked to mitigate its own impact. It would be unreasonable and fail the CIL tests for developers too be expected to pay to address existing sewerage leaks in South Warwickshire.

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Chapter 10 A well connected South Warwickshire Issue T1: 20 minute neighbourhoods 74. The HBF comments on 20 minutes neighbourhood concept can be found in response to the Spatial Strategy in Section 4.2

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Chapter 11 A biodiverse and environmentally resilient South Warwickshire Issue B6: Environmental Net Gain 75. It is the HBF’s opinion that the Council should not deviate from the Government’s requirement for biodiversity net gain as set out in the Environment Act. There are significant additional costs associated with biodiversity gain, which should be fully accounted for in the Council’s viability assessment. It is important that BNG does not prevent, delay or reduce housing delivery.