Issue and Options 2023

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Q-C2: Please select the option which is most appropriate for South Warwickshire At this stage Bellway supports option C2c: None of these. Option C2a proposes to require decentralised energy systems on developments of 2,500 dwellings or more or 10ha+ of employment land which Bellway cannot support without evidence to justify that this is deliverable on these sites. Any policy requirement, should only ‘encourage’ this provision and agreed on a site by site basis. Larger strategic sites normally have significant infrastructure costs, particularly where they are new settlements, so this requirement will need to be factored into the site’s viability and delivery timescales. 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? No – introducing this policy without national guidance is likely to lead to delays in the delivery of dwellings. There is also no local evidence to support this requirement and it will need to be tested through ‘needs’ evidence and the viability assessment for the plan. New homes are not required to be zero carbon until 2050 and policy should not be going further than the Future Homes Standard.

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Bellway considers that the SWLP should not set their own targets, national guidance should lead on dates and thresholds.

Q-C6.1: Please select the option which is most appropriate for South Warwickshire (Whole Life-Cycle Carbon Emission Assessments) Bellway supports Option C6.1c: None of these. The preferred option relating to carbon emissions should be informed by reference to a robust evidence base. Neither the NPPF nor the PPG 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-C7: Please select the option which is most appropriate for South Warwickshire (adapting to higher temperatures) Bellway supports option C7b: Do not include a policy that requires new developments and changes to existing buildings to incorporate measure to adapt to higher temperatures. The preferred option should be determined by reference to a robust evidence base. National policy does not require buildings to be adaptive to higher temperatures, so therefore is not consistent with national policy. Q-C8: Please select the option which is most appropriate for South Warwickshire (adopting to flood and drought events) In the absence of any evidence, Bellway supports 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. Bellway considers that this approach offers more flexibility than Option C8a which proposes to set a policy which goes beyond building regulations. Any policy which seeks to go above national requirements needs to be properly evidenced and justified. Q-C9.1: Please select the option which is most appropriate for South Warwickshire (Mitigating Biodiversity Loss) Bellway supports Option C9.1b: Do not include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity. Option C9.1a proposes to potentially set a specific percentage of a site to have paved/hard surfaced areas. Bellway object to this approach as it goes against the NPPF’s requirement to make efficient use of land (Chapter 11). Any 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 BNG requirements, so the overall impact on the net developable area of a site 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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Q-C10.1: Please select all options which are appropriate for South Warwickshire (Climate Change Risk Assessments) Bellway support option C10.1c: None of these. Option C10.1a proposes to include a policy requiring new development to undertake a climate change risk assessment to identify climatic factors likely to affect the development and the measures that can be incorporated to mitigate and adapt to these effects. Option C10.1b seeks to include a policy requirement for proposals for new development to provide a climate change checklist setting out the appropriate range of adaption and mitigation measures to be incorporated. SWLP should not be imposing additional requirements over and above national guidance. If a policy is pursued, then it should be sufficiently supported by evidence and tested in the viability assessment.

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No - Comprehensive development is listed as one of the key strategy design principles on page 138. Bellway considers that the approach to comprehensive development needs to be flexible and not hold the delivery of sites back should all landowners not be fully engaged.

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