Issue and Options 2023
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Q-H5: Please select all options which are appropriate for South Warwickshire Option H5c: Rely on a case-by-case approach whereby planning applications for self and custom build homes will be assessed against a range of criteria to determine their suitability. 2.61. The Respondent has experience of providing self-build plots on developments in other parts of the Country and would caution that there is often a disparity between the number of people that register an interest in such plots and those that will make a firm commitment and complete a purchase. 2.62. As the Consultation Document points out, there are people who may express an interest for a self-build property but do not want to live within or on the edge of a new housing estate. In a largely rural authority, it is considered likely that the demand for self/custom build is for single plots on the edge of small villages/hamlets or on plots within the open countryside. A case-by-case approach as per that suggested under Option H5c would therefore seem most appropriate in South Warwickshire or for specific sites on the edge of existing settlements to be allocated specifically for this purpose where there is identified demand (Option H5a). 2.63. If Option 5b is to be taken forward, then there must be the flexibility to revert self-build plots back to normal build plots once they have been marketed for an appropriate amount of time. The period of marketing required to demonstrate a lack of demand should not prevent the main developer from completing the self-build plots before the construction programme finishes, since it would not be desirable for developers to be left with vacant plots or for new residents to be subjected to construction activities for a prolonged period.
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Q-C3.1: Do you think we should develop a carbon offsetting approach to new developments where it is demonstrated that it is not possible to achieve net carbon zero requirements on site? Y/N/DK 2.64. Don’t know. As recognised in the Consultation Document, some developments may not be able to completely neutralise their carbon emissions on site and in these cases a carbon off-setting approach would seem reasonable. However, it will be imperative that the SWLP provides an appropriate mechanism for carbon offsetting. The Consultation Document suggests that in addition to natural solutions such as tree planting that a fund could be created through the pooling of financial contributions from developers which will enable the existing housing stock to be retrofitted with measures to help reduce carbon emissions. However, it is not clear how such a scheme would operate in practice (i.e., how will financial contributions be calculated and who would be responsible for administrating, delivering and monitoring such a scheme?) or if it would meet the tests of Regulation 122 of the CIL Regulations 2010 (as amended). Without more information it is therefore very difficult to comment. Accordingly, the Respondent reserves their right to comment once more information is made available in this regard.
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2.65. The integration of renewable energy and carbon sequestration within new developments could both be feasible options in helping to achieve net zero carbon development but, as stated elsewhere in this Statement, anything above standard requirements will need to be carefully considered in the context of other policy requirements to ensure that any approach adopted by the Councils is justified, viable and deliverable. 2.66. In the Respondent’s view, significantly more information needs to be provided before developers can provide any sort of meaningful comments on the suggested approach to renewable energy generation or carbon sequestration in South Warwickshire. The Respondent therefore reserves their right to make further comments once more information is made available in this regard. Q-
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Q-C4.1: Please select all options which are appropriate for South Warwickshire Option C4.1a: Do not have a policy and allow new development to comply with the national building regulation requirements, which may change over time. 2.67. The Respondent considers it superfluous to include a policy requiring new development to comply with national building regulation requirements given that developers will need to comply with Building Regulations in any event. 2.68. While the Councils’ aspirations to raise the standard of design and achieve net zero carbon is understood, and to some extent supported, achieving this will come at a significant cost to development which, given the time frames involved, is unlikely to be easily absorbed and therefore has the potential to put at risk the delivery of sites and, in turn, the timely delivery of market and affordable homes. 2.69. Considering these concerns, Option 4.1a is considered to be most appropriate. If, however, the Councils are minded to set a higher local standard, then it is advised that realistic transitional arrangements are allowed for to enable the development industry time to respond. In the Respondent’s view, the timeframe indicated in Option C4.1c is the minimum that should be adopted. In imposing standards caution also needs to be shown to ensure that redundant technology is not prescribed and that developers can make an appropriate choice of systems at the time houses are being delivered. In addition, the Plan will have to be supported by evidence demonstrating that the viability both technical and financial has been taken into account.
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2.71. If the decision is made to proceed with a policy that seeks reductions in embodied emissions, then a phased approach should be adopted. However, it is difficult to advise where this threshold should be set without more information being provided regarding the potential implications of such a policy. The Councils should therefore look to test the various options and present this work as part of a preferred strategy which can be commented on in due course.
2.70. While the Councils’ aspiration to raise standards and seek greater reductions in embodied emissions is appreciated, the Respondent has significant concerns regarding the additional cost to the development industry, which cannot be easily absorbed.
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Q-C8: Please select the option which is most appropriate for South Warwickshire Option C8b: Do not include a policy that goes beyond existing building regulations, requiring new development and changes to existing buildings to incorporate measures to adapt to flood and drought events 2.72. The Respondent is generally supportive of the management and use of water within new developments and already seeks to incorporate SUDS in its schemes where it is feasible to do so. Furthermore, the Respondent has no in principle objection to the implementation of measures to reduce water consumption, however, they would not currently support a policy which goes beyond existing Building Regulations. Q-C9.1: Please select the option which is most appropriate for South Warwickshire Option C9.1b: Do not include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity 2.73. The Respondent is generally supportive of incorporating measures to increase biodiversity within new developments and notes that the need to provide 10% Biodiversity Net Gain (BNG) is soon to become mandatory under the Environment Act 2021. In light of which the need for an additional policy is unclear. 2.74. The introduction of any policy that has the potential to affect the viability and delivery of sites needs to be cautiously considered, with overly prescriptive requirements (such as limitations on the amount of hard landscaping that can be used within sites etc.) avoided. In the Respondent’s view, suggestions regarding how a development might go about achieving biodiversity increases on site should be set out in supporting text and not directly in policy wording to reflect best practice rather than a strict policy requirement. 2.75. While the delivery of on-site BNG may be preferred, the ability to deliver off-site BNG should not be ruled out, since there will be sites where BNG on site is not achievable. In this regard it is imperative that the SWLP provides an appropriate mechanism for offsetting when it is simply impractical to provide the level of net gain by any calculator being adopted by Natural England. 20 2.76. For the avoidance of doubt, the Respondent would have significant objections if the level of BNG required in South Warwickshire were to extend beyond the 10% required in line with the provisions of the Environment Act 2021.
