Issue and Options 2023

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Q-C4.1: Please select all options which are appropriate for South Warwickshire In the absence of evidence being presented by the Council, Crest Nicholson supports option C4.1a. Building Regulation standards are able to change to address and accommodate best practice and the latest technology and standards being brought forward by the development industry on a comparable, national, basis. Local Plan policy is not as agile in responding to such innovation and as such is not an appropriate way to control building standards. Crest Nicholson requests that the South Warwickshire LPAs clarify the evidence they propose to rely upon to justify any proposed additional standards. In the absence of a robust evidence based justification there is still an opportunity for policy wording to encourage developers to exceed the requirements set out within Building Regulations to seek for individual sites and developers to deliver net zero carbon in advance of this becoming enshrined in the Building Regulations, where this is possible. Crest Nicholson is the first UK housebuilder to have its net-zero target validated by the Science Based Targets initiative (SBTi), reflecting its commitment to reducing greenhouse gas (GHG) emissions across its value chain and reaching net-zero GHG emissions by 2045. Crest Nicholson is already making progress in reducing GHG emissions, driving the efficient use of plant and equipment on site, trialling lower carbon technologies including hybrid generators and an electric telehandler, using alternative low carbon fuels and increasing the procurement of renewable electricity. To reduce emissions relating to other organisations in it supply chain, Crest Nicholson continuously reviews the design, technologies and materials used within its homes. It is also a member of the Future Homes Hub’s Embodied and Whole Life Carbon Workgroup, which is developing guidance, tools and an implementation plan to support an industry-wide reduction in whole life carbon. Such measures will be introduced at the Crest Nicholson site to the south of Westwood Heath Road, to minimise the GHG impacts of the proposed development. There are opportunities for other house builders and developers to follow suit without rigid requirements and timescales being set within Local Plan documents. Q-C4.2: What scale of development should the requirements apply to? An approach aligned to Building Regulations will apply to all development. Approaches which seek to introduce a standard which is in excess of the Building Regulation requirements will need to be appropriately justified, including through the use of a viability appraisal. Q-C6.1: Please select the option which is most appropriate for South Warwickshire The preferred option relating to carbon emissions should be informed by reference to a robust evidence base. Neither the National Planning Policy Framework nor the Planning Practice Guidance require embodied carbon emissions to be measured. The proposed policy approach does not provide any detail in relation to: the application of the embodied carbon assessment; what baseline the assessment will be measured against; and how the outcome of the assessment would be enforced. There are currently considered to be data collection issues impacting on the ability to undertake a proper Whole Life Carbon Assessment. Principally, many manufacturers are still lacking the creation and verification of data for Environmental Product Declarations. Any requirements which are over and above national policy need to be clearly evidenced, including through impacts on viability.

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Q-C9.1: Please select the option which is most appropriate for South Warwickshire Crest Nicholson supports Option C9.1b. Option C9.1a maybe at odds with the requirement to make most efficient use of land (NPPF paragraph 125) as well as the requirement to achieve high quality design. Any such requirements which seek to limit hard standing on site need to be considered in tandem with other site requirements, such as open space provision and connectivity requirements, so the overall impact on development can be understood. The evidence base should include examples demonstrating how C9.1a can work in practice without compromising other development requirements, objectives or scheme deliverability if this option is to be taken forward.

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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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Any policy setting out strategic design principles should also include reference to deliverability and viability and how design choices need to be weighed up against these two key issues.

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Q-D2: Please select all options which are appropriate for South Warwickshire A set out in paragraph 128 of the NPPF, all local planning authorities should prepare design guides or codes consistent with the principles set out in the National Design Guide and National Model Design Code, and which reflect local character and design preferences in order to provide maximum clarity about design expectations at an early stage. Such design guides / codes should be high level document and should not be overly prescriptive, thus enabling the design of each site to be considered based on its own merits and the context of the specific site. Detailed design of a site should take into account the specific technical considerations of that location which will not be fully investigated at design guide / code stage. Q-D3: Please select all options which are appropriate for South Warwickshire Crest Nicholson supports Option D3a, which proposes inclusion of a policy which underlines the relevance and importance of density, but which does not identify an appropriate minimum density or range of densities across South Warwickshire. It is considered that this would enable a more locally tailored approach to density, which seeks to make the most efficient use of land, taking into account the specific context each site. This approach would not prevent specific design guides, codes or masterplans from guiding appropriate density ranges in areas of change, as advocated by Paragraph 125 of the NPPF. This approach could also be adapted to align with the general requirement set out within paragraph 125 of the NPPF for Local Plans to include the use of minimum density standards for city and town centres and other locations that are well served by public transport.

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T1: Please select all options which are appropriate for South Warwickshire Crest Nicholson supports Option T1a. National policy does not currently require all developments in all locations to achieve Building for a Healthy Life accreditation or endorse the principles of a 20 minute neighbourhood. The connectivity and context of developments can be determined on a site by site basis.

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