Issue and Options 2023

Yes

Q-C3.1: A carbon offsetting approach should be introduced as part of the new Local Plan to allow for flexibility in instances where it is not feasible to achieve net carbon zero requirements on a site, whether that be due to site constraints, viability or practicality of being able to develop the site. However, it is important to consider the offsetting costs from a viability perspective and ensure sufficient viability testing has been conducted to support the Policy.

Issue C2: Decentralised energy systems Q-C2: Please select the option which is most appropriate for South Warwickshire The Church Commissioners considers that Option C2a is the appropriate Option for South Warwickshire. However, the wording of Option C2a needs amending to remove the word ‘require’ and replace with ‘encourage.’ Furthermore, the size threshold needs to be specified, supported by relevant evidence, including viability. The NPPF states within Paragraph 155 to help increase the use and supply of renewable and low carbon energy and heat, plans should identify opportunities for development to draw its energy supply from decentralised, renewable or low carbon systems. 5.2 In addition, the Council must ensure Plan compliance with Paragraph 157 of the NPPF, whereby development should comply with any new development plan policies for decentralised energy unless it can be demonstrated by the applicant that it is not feasible or viable, thus ensure policy wording is reflective of viability concerns and allows for flexibility where these scenarios can be illustrated.

selected

selected

selected

selected

selected

selected

selected

selected

Q-C6.1: The Church Commissioners acknowledge that it is important to consider the emissions resulting from materials, construction activities and the use of a building over its lifetime. However, the Councils have not presented any evidence to justify the options presented at this stage. Therefore, at present, without viability evidence and a baseline for emissions data, it is not possible, or justified to introduce Option C6.1a as a Policy. Option C6.1a would have a detrimental impact upon the viability of developments, and would potentially impact upon delivery of sites coming forward. A Policy requiring new developments to have a target for 100% reduction in embodied emissions would negate the requirements of the Plan to deliver much needed houses and employment land, and therefore not achieve the overall Vision. 5.7 To put this Option into perspective, within London, only those developments that are referrable to the Mayor are required to produce and calculate a whole life-cycle carbon emission assessment. Furthermore, paragraph 152 of the NPPF sets out that the planning system should support the transition to a low carbon future, noting the word transition, as such the proposed 100% reduction does not accord with a transitional approach. Option C6.1b provides potential for a flexible approach, whereby developments of certain size criteria should demonstrate their calculations within a whole life-cycle carbon emission assessment, however the required reduction in embodied emissions needs to be viability tested and strongly considered, as this may negatively impact upon sites coming forward for development. The Council also need to decide their priorities in terms of what they want developments to achieve, as having a higher required reduction in embodied emissions, may then impact upon the ability to provide the policy required affordable housing percentage, or the required additional infrastructure. The Issues and Options Document sets out that ‘the SWLP must contribute to the achievement of sustainable development, and this means balancing the need for more jobs and homes against the impact on the built and natural environment.’ Consequently, the Councils need to establish the balance and levels of priority, in order to establish the requirement of this proposed policy. The Church Commissioners suggests further evidence is conducted by the Councils to decipher the potential requirement and to establish their balance in greater detail, followed by further stakeholder engagement on the matter. Q-C6.2: If a phased approach is used, what dates and thresholds should be used? 5.8 The dates and thresholds should be realistic and justified, but underpinned by evidence undertaken by the Councils. The approach should correspond with Part L of the Building Regulations to ensure consistency throughout. It is important to also accord with the NPPF, which sets out within Paragraph 152 that the planning system should support the transition to a low carbon future in a changing climate, thus any proposed planning policy should be transitional, but also prepared positively, ensuring aspiration but deliverability, as per paragraph 16 of the NPPF.

Q-C4.1: Please select all options which are appropriate for South Warwickshire Option C4.1a should be pursued by the Councils, whereby national Building Regulations will stipulate the levels required for new buildings in order to minimise emissions. The national Building Regulations will be updated, in accordance with the climate emergency and net-zero carbon agenda pursued by the Government. This will ensure that new developments align with planning policy and building regulations. Whereas, by utilising Option C4.1b, setting higher standards, will make new developments more expensive due to the additional requirements to be met in order to achieve policy compliance, which will impact upon the overall viability of the scheme, and ultimately affect obligations, in terms of the quantity of affordable housing that can be required, the infrastructure requirements and other associated financial contributions, which would have a greater negative effect, where the harm would outweigh the benefit. 5.5 Overall, Option C4.1a would ensure that new development is built in accordance with National Building Regulations, therefore ensuring that homes must produce 30% less carbon dioxide emissions than previous standards, which will increase to 75-80% less emissions by 2025, to eventually become zero-carbon. This structure therefore clearly demonstrates the need for developments to acknowledge the need to reduce carbon emissions, which will increase gradually, achieving South Warwickshire’s desire to be carbon neutral, thus achieving sustainable developments. Q-C6.3: Please add any comments you wish to make about Net Zero Carbon buildings in South Warwickshire. The Church Commissioners reiterates that the Councils need to undertake greater research to inform their evidence base in relation to reducing embodied emissions and thus whole lifecycle emissions. The Church Commissioners acknowledges the need to consider the carbon emissions associated with the process of developing a site, taking into account during construction and operationally, however re-emphasises the need for the Councils to consider viability of sites. The councils need to strike a balance between the deliverability of housing and employment land, to ultimately achieve sustainable development and the overall vision of the Local Plan, whilst also considering the environmental impacts and the opportunities available to minimise carbon emissions. 5.10 As per Paragraph 009 (Reference ID: 6-009-20150327), there is a requirement for local planning authorities when setting any local requirement for a building’s sustainability to do so in a way consistent with the government’s zero carbon buildings policy, ie in accordance with Part L of the National Building Regulations. The PPG continues to state that local requirements will need to be based on robust and credible evidence and pay careful attention to viability.

selected

selected

selected

selected

selected

selected

Q-C7: Please select the option which is most appropriate for South Warwickshire The Church Commissioners submits that the Councils should not include a requirement for development to accommodate measures to adapt to higher temperatures (Option C7c). Instead, this issue should be left to Building Regulations. Issue C8: Adapting to Flood and Drought Events Q-C8: Please select the option which is most appropriate for South Warwickshire Option C8b should be followed, where a policy is not included that goes beyond Building Regulations. 5.13 At present, Stratford’s Core Strategy has Policy relating to SUDs, stating that all development proposals to control and discharge 100% of runoff into SUDs, which is consistent with Policy FW2 of Warwick’s Local Plan. Whilst Stratford doesn’t currently have a policy requirement with regards water consumption, there is reference to minimising water consumption, and Warwick’s Local Plan stipulates specific requirements for water efficiency standards of 110 litres per person, per day for residential developments. Furthermore, whilst the above presents a number of Options, wording identified within Issue C8 states that consideration could be given to decreasing the requirement to 100 litres or lower per person, per day which isn’t included within the Options. 5.14 As the two local authorities have current policies in relation to SUDs provision, and Warwick has water efficiency requirements, it would be appropriate and consistent to pursue this within the South Warwickshire Local Plan. However, any specific water efficiency requirements should be tested via evidence and viability assessments completed, to ensure the Policy is realistic, achievable and deliverable.

selected

selected

selected

selected

selected

selected

Q-C10.1: Option C10.1c should be followed, whereby none of the above options are suitable. The Church Commissioners is supportive of measures to tackle climate change, but clarity should be provided as to what is actually required through a Climate Change Risk Assessment. It is not clear at present and therefore a evidenced decision is not possible on the most appropriate option to address climate change, based on the information and wording available. As a result, the Councils should conduct further research to inform their evidence base, prior to deciding whether a Policy is required and to what extent.

Issue C11: Water Management Q-C11: please select the option which is most appropriate for South Warwickshire Option C11a has the potential to be the most appropriate policy, however this is subject to its specific wording. At present, the existing policies concerning water management state the term ‘good’, however there is no definition of ‘good’ and the term remains subjective, therefore unclear and has potential to be unachievable. 5.17 As Issue C12 highlights, flood risk is considered a strategic planning matter and will therefore be addressed within Part 1 of the Plan. At present, there is not sufficient evidence to properly judge what sort or level of Policy is required. Until the additional evidence is undertaken, it is not appropriate to comment on water management or flood risk. However, The Church Commissioners reiterates that as per validation requirements, all major applications require a Flood Risk Assessment to assess a site, and mitigate against any potential problems. 5.18 Furthermore, the wording within Issue C12 infers that the Part 2 work will be based upon the strategy, however the work undertaken should inform the strategy, therefore all work undertaken should underpin any proposed policy. 5.19 In addition, whilst the Level 1 Strategic Flood Risk Assessment states that it can be used to inform the Local Plan on the location of future development and the preparation of sustainable policies, there is not sufficient evidence to fully decipher this, and this report should only be considered as a factor towards the wider review of sites suitable for development. As per Paragraph 0073 (Reference ID: 7-007-20220825), Diagram 1 outlines that following the completion of a Level 1 Strategic Flood Risk Assessment, the authority then identify where development can be located in areas with a low risk of flooding and assess alterative development options using the Sustainability Appraisal, considering flood risk and other planning objectives. Following this exercise, the Council can then apply the Sequential Test to identify appropriate allocation sites and development, which can then require a Level 2 Strategic Flood Risk Assessment. As a result, a greater amount of work and evidence is required to inform the Local Plan, as the Council have not yet reviewed the availability of sites, to identify those in areas of low risk flooding and those not. 5.20 In addition, the SFRA summarises that there are urban areas of Stratford upon Avon and Warwick that are at risk of fluvial and surface water flooding. As a result, the Councils need to take this into account when reviewing their available urban sites. This may require greater areas of Green Belt land to be released, if urban areas are at greater susceptibility to flooding. 5.21 At present, two reports have been produced to cover Stratford and Warwick separately. In the future, it would be more useful and appropriate to look at South Warwickshire as an entity, with supporting joint evidence. In addition, Appendix D within both reports identifies Flood Alert and Flood Warning Areas, and it would be more appropriate to have accompanying maps of these areas to identify clearly those locations. At present, it is unclear.

Nothing chosen

Q-D1.1: Do you agree that this is an appropriate range of topics for a strategic design policy? 6.1 Design is not a strategic issue and should therefore be addressed within the respective Part 2 Plans. 6.2 The topics for a strategic design policy should be based upon those identified within Paragraph 130 of the NPPF. The principles set out are acceptable as worded, however further clarity should be made to provide greater detail of the requirements of each topic. Therefore, the principle of the topics are acceptable, however the detail associated with each topic needs to be considered and engaged upon further.

selected

selected

selected

selected