Issue and Options 2023

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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, it is extraordinarily ambitious, complicated, and as yet there is no agreed method to calculate embodied energy. Therefore, this local plan should be written so that whole life-cycle carbon assessments can be required when there is greater clarity.

Regarding decentralised energy systems, the current thinking for true net zero carbon low rise housing is that decentralised energy is not appropriate as it is 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 is the use of the ‘waste’ heat from the Coventry incinerator being used to heat existing buildings in the city. Combined heat and power 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. All new buildings should be net zero carbon, as the Planning Inspector has confirmed that Cornwall Council’s Climate Emergency DPD (Development Plan Document, that has the same status as a local plan) is sound subject to recommended modifications and is due to be adopted. This DPD precisely defines net zero carbon homes. As there are other similarly ambitious DPDs and local plans being developed, it is likely that when this South Warwickshire local plan is approved it won’t be that radical and viability will be less of an issue as net zero costs will have fallen. For too long, the council has prevented retrofit of listed buildings and those in conservation areas even when done sympathetically with high quality materials. Traditional Buildings require a risk-based approach as defined in guidance from Historic England and the Sustainable Traditional Buildings Alliance (STBA).

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Implementation of Schedule 3 of the Flood and Water Management Act 2010 should be incorporated into this local plan. It sets out a framework for the rollout of drainage systems, a sustainable drainage system approving body, and national standards on design, construction, operation and maintenance. It also makes the right to connect surface water runoff to public sewers conditional upon a drainage system being approved before any construction work can start.

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We agree with a pollution policy as it can reduce harm to residents. For example, by improving air quality by accelerating the take-up of EVs with fast EV chargers and incentives.

Improving connectivity (excluding vehicles and motorways) should include broadband/mobile networks and public transport across the district to give people the flexibility about how they choose to live, work and travel in the light of post-pandemic working practices and avoid the constant proliferation of roads at the expense of quality of life.

The consultation document explains the principles of 20 minute neighbourhoods and that responses to the first consultation support these principles which ensure that key infrastructure such as shops, schools and doctors are located close to people’s homes. Therefore this local plan must prioritise 20-minute neighbourhoods and clearly set out “the vision and expectations for new developments and places, to ensure early design incorporation.” Clear design or master planning of major developments is vital to maximise connectivity and minimise walking distances for residents. Sadly, previous haphazard developments have not done this. It is important to create good quality transport links that promote active travel and encourage the use of public transport to decrease car dependence. A full review of integrated transport options is required (timing/quality of services). In Planning terms, active travel must be a requirement for all medium and large development areas. Links beyond the immediate developments should be agreed at outline planning stage. Developments should have footways and cycle provision built to Gear Change standards as an integral part of developments rather than an afterthought. Town Centres should not be dominated by traffic and the creation of small and micro-businesses needs to be encouraged. Development must be holistic and avoid fragmented initiatives which blight smaller towns.