Warwick District Green Party response to the Council’s consultation on https://southwarwickshire.oc2.uk/document/148
Central government mandates the number of houses that each Council must say that they will build each year. The Green Party thinks thinks these numbers are ludicrously high and based on unsound projections, but central government controls this number, not us.
If a Council refuses to pass a Local Plan with this number developers will be allowed to apply to build houses anywhere – the worst of situations the Council loses more of any control it does have.
However, the Council can choose where to allocate sites for building and also the density, which is the purpose of the local plan.
It can also choose how long the Local Plan period is. The Green Party argued that we should shorten the length of the plan by 10 years meaning fewer housing sites in the countryside would need to be brought forward this time. Hopefully by the time a new plan was needed common sense would have prevailed and required numbers reduced! We brought this proposal forward formally in 2024, but it was not supported by any other party, including the Conservatives. This meant it did not pass.
We are also advocating slightly increasing the density of housing in urban centre areas which again reduces the number of sites in the countryside that need to come forward.
We are not saying that no new houses need to be built. We need high quality affordable houses, not a system that is a developer’s charter that allows them to maximise profit without building the right infrastructure to go with new properties. We have been consistently clear that developers should not be able to get away with building houses without amenities like shops, schools, GP surgery and leisure and will continue to make this case strongly.
The lastest Council consultation on the local plan has now finished, but below you can read the local Green Party response to the Council’s consultation and below that more detail on the consultation itself.
Green Party response to the preferred options consultation
Chapter 4: Meeting South Warwickshire’s Sustainable Development Requirements
4.1 Spatial Growth Strategy
Strategic Growth Locations
SG01 South of Coventry Group
No. The development of this area will in effect remove the last strand of greenbelt between Coventry and Burton Green / Kenilworth. As the government has removed the urban uplift in housing numbers, Coventry is likely to meet its housing needs within its own boundaries without further need to cooperate making this area even less attractive. The University of Warwick is planning an Eco Park on their portion of this land. Connecting this up with the existing areas of woodland on the site into new habitats to enhance nature would both increase biodiversity and ensure the essential greenbelt corridor between Coventry and Kenilworth remains. Also, note that Kings Hill, which is in the current local plan to cater for Coventry overspill, is being developed very slowly, indicating that further overspill allocations are unnecessary.
Draft Policy Direction 1 – Meeting South Warwickshire’s Sustainable Development Requirements
Other. We do not agree with the government’s mandate to require 2188 houses every year to be built in south Warwickshire. This will not happen because developers will not be able to maintain high profit margins if they sell at that rate, but will mean these developers cherry pick the most profitable sites, often without suitable infrastructure. However, we acknowledge that this local plan must follow the government’s mandate.
The most effective way to reduce the number of green fields to be allocated in this local plan is to shorten the plan period so that it would end in 2042. This would mean that only about half as much new Green Belt or other green field land would be scheduled for concreting over. Making only about half the new land available for development would put the Council in a much stronger negotiating position with developers and will make it easier to enforce timely infrastructure, tough Carbon-reduction measures, etc.
Note that Greens proposed 2042 as the end date; unfortunately, Lib Dems, Labour and Conservatives did not support this proposal. Our view is that the policies within this local plan document will not deliver the Government’s 2050 Net Zero target, potentially making the plan unsound. The 2042 date would allow the possibility of getting closer or indeed meeting the legally binding 2050 Net Zero target.
The absurdly high number of houses to be built is due to the government’s formula which is based on the fact that houses prices are so high that they are unaffordable for most people. To address this problem, there must be a massive increase in state-funded social housing provision, to bridge the gap between what the market considers profitable to build and the level of need (the housing crisis). This also applies to the rental sector.
Draft Policy Direction 2 – Potential New Settlements
Yes. We strongly agree with the aim of new settlements where residents can fulfil most of their day-to-day needs within the settlement itself. For this to succeed, 20-minute neighbourhood principles are required: minimum size of 6000 homes, high density in the centre, primary and secondary schools, shops and other community infrastructure. This reduces congestion compared with urban sprawl and reduces the number of green fields allocated to housing.
The current criteria for assessment of sites does not include a climate change assessment. The 36 sites should each have a carbon modelling process to determine the highest and lowest CO2 emissions and running costs per home. This would help all stakeholders and decision makers consider the sustainability of the different sites.
Draft Policy Direction -5-
Much of the Green Belt in south Warwickshire is the “best and most versatile agricultural land”; greater attention needs to be paid to the opportunity cost, including loss of food production, carbon costs of importing food, and ensuring security of supply. The plan aims to locate developments near public and active travel. In principle, this is positive but must be accompanied by full awareness of the capacity of travel options. In particular, railway travel in the district is currently operating ‘at capacity’ (as stated in the infrastructure delivery plan, IDP). As such, any developments that are justified based on their location near a railway station need to have evidence that the station can provide sufficient additional capacity before decisions on these sites are made. Any such expansion needs to be seen as Critical or Essential (c.f. IDP, Table 3.2) and occur before development. This point is included here because ‘sustainable travel’ is a key reason stated for siting development in the Green Belt; it is also relevant for Infrastructure Requirements and Delivery (Draft Policy Direction 5).
The NPPF makes it easier to select Green Belt land for development, but also reinforces the idea that building on Green Belt should require a higher % of social/affordable housing (50% plus), which would also require a higher investment in infrastructure to establish sustainable communities. Moving from principle to practicality, this will make Green Belt sites less attractive to developers, without substantial public subsidy.
Draft Policy Direction 7 – Green Belt
Other. Unfortunately, this draft Policy Direction 7 is relatively vague as the government’s new grey belt definition is omitted and only the first stage of the Green Belt review has been included. Of course, the next consultation stage will need to distinguish between Grey Belt and other Green Belt land.
We agree with the opposition to development within the Green Belt expressed in the previous consultation, which means that the “exceptional circumstances” to justify such development would need to be truly exceptional. The Green Belt in Warwick district is vital to “to check the unrestricted sprawl of large built-up areas” from the Coventry conurbation, but increasingly from Kenilworth, Warwick and Leamington as well. . We believe that what is left of the Green Belt between Coventry and Kenilworth is particularly beneficial to the area and that we should make every effort to preserve it.
In our opinion, weakening Green Belt protections is a short-sighted and ineffective response to the housing crisis. Too much of the building on Green Belt land and other green fields primarily benefits developers, delivering high-value homes rather than the affordable housing people need. It destroys vital agricultural land, biodiversity, and carbon sinks while encouraging car dependency and urban sprawl.
Instead, we need creative, sustainable solutions: regenerating brownfield sites, building higher-density housing in towns, and maximizing existing infrastructure. Well-designed apartments and mixed-use developments can provide affordable, high-quality homes for younger people and accessible options for older generations, creating vibrant, walkable communities.
We are advocating smarter, biodiverse, low carbon urban planning for future generations.
Much of the Green Belt in south Warwickshire is the “best and most versatile agricultural land”; greater attention needs to be paid to the opportunity cost, including loss of food production, carbon costs of importing food, and ensuring security of supply. The plan aims to locate developments near public and active travel. In principle, this is positive but must be accompanied by full awareness of the capacity of travel options. In particular, railway travel in the district is currently operating ‘at capacity’ (as stated in the infrastructure delivery plan, IDP). As such, any developments that are justified based on their location near a railway station need to have evidence that the station can provide sufficient additional capacity before decisions on these sites are made. Any such expansion needs to be seen as Critical or Essential (c.f. IDP, Table 3.2) and occur before development. This point is included here because ‘sustainable travel’ is a key reason stated for siting development in the Green Belt; it is also relevant for Infrastructure Requirements and Delivery (Draft Policy Direction 5).
Green Belt should have much greater importance in decisions where to allocate housing and employment land to sensibly address these points. The new NPPF makes it easier to select Green Belt land for development, but requires a higher percentage of social/affordable housing (50% plus), which would also require a higher investment in infrastructure to establish sustainable communities. This will make Green Belt sites less attractive to developers, and so there is a danger that they will not be developed, rendering the local plan ineffective.
Draft Policy Direction -8- Density
Yes. It is not surprising that developers don’t want optimal densities as they have a fiduciary duty to maximise profit, rather than what is good for residents overall. Specifying suitably high densities in urban areas and the centre of new settlements is crucial for effective 20 minute neighbourhoods and reducing the space required for housing. Advantages include making it feasible for most children to walk or cycle to school. Serious consideration must be given to reducing S106 and CIL contribution, as well as car parking requirements in suitable high-density locations.
The Local Plan provides an opportunity to radically re-design and re-provide housing in our towns, through much higher densities and the provision of multi-level living i.e. apartment provision. This is the only practical way to meet housing need where the demand is, making use of existing infrastructure. There is insufficient funding for the new infrastructure needed to create thriving communities in areas other than in town centres. This reality is acknowledged by central government in its decision to delete paragraph 130 of the NPPF, reflecting a policy shift towards prioritizing land efficiency and housing supply over strict adherence to existing local character considerations. This change aims to facilitate higher-density developments in urban areas, promoting housing delivery and sustainable development patterns.
Draft Policy Direction 9 – Using Brownfield Land for Development
Yes. This local plan needs to very strongly promote use of urban brownfield land, because it preserves green field land for agricultural and leisure purposes, as well as adhering to 20 minute neighbourhood principles as brownfields are almost always close to local amenities (see response to draft policy direction 1).
As above, brownfield sites often contain infrastructure and are close to amenities. We need to maximise the potential of the brownfield sites. There must be a commitment to focusing on building affordable housing in the cities and towns where the housing is needed and infrastructure exists, rather than building on the peripheries of our towns and villages, where the infrastructure is weakest.
As above, this approach aligns with the government’s decision to delete paragraph 130 of the NPPF, reflecting a policy shift towards prioritizing land efficiency and housing supply over strict adherence to existing local character considerations. This change aims to facilitate higher-density developments in urban areas, though it has raised concerns about potential impacts on community character and the planning autonomy of local authorities.
Chapter 5: Providing Custom and Self-Building Housing Plots
Draft Policy- B- Providing Custom and Self Building Housing Plots
Yes. However, time scale must be much quicker. Currently in Kenilworth development has been taking place for some 2 years and there are as yet no serviced plots available, we are told until circa 2027. There should be an ongoing supply available each year. There needs to be a strong marketing process to assess demand. The purpose of these Custom and Self Building Housing Plots is for bespoke, innovative homes. Therefore, the design code must rule out the ‘anywhere’ house types that are widely available, and gas should not be provided to encourage low carbon designs.
Chapter 7: A Climate Resilient and Net Zero Carbon South Warwickshire
Wider context: The chapter starts with “The Government’s target is to reach net zero by 2050…” but it’s clear that this local plan falls way short. In this chapter, embodied energy produced during construction and unregulated energy in use will both be present: both of these issues are acknowledged in the consultation.
Draft Policy D: Large Scale Renewable Energy Generation and Storage
Yes. However, given the need to generate cheap energy as well take climate action, a more urgent and comprehensive approach to renewable energy generation is required, including wind as well as solar power. Therefore, the constraints in this section should be less restrictive. Our request to more positively promote both renewable energies and low carbon energy proposals is backed by the new NPPF. As indicated in the Justification section, it specifies that:
· Local Plans should identify suitable areas for renewable and low carbon energy sources, and supporting infrastructure
· Decision makers determining applications should support planning applications for all forms of renewable and low carbon development and give significant weight to the proposal’s contribution to renewable energy generation and a net zero future. (NPPF para 168)
Finally, to note the restrictions in NPPF on onshore wind schemes was already cancelled via policy statement in the July of 2024.
We particularly support solar farms on lower-quality agricultural land (grades 3b-5). Energy storage should be co-located with renewables. We strongly agree with general point c) i.e. there needs to be a minimum percentage of community ownership for all large-scale renewable energy projects.
Draft Policy Direction-22 -Net Zero Carbon Buildings
Yes. However, the proposed standards should be tightened considerably. Criteria should include: solar panels on all new buildings, carbon monoxide monitors, rainwater harvesting, sustainable urban drainage designed to withstand flooding, no gas supply or log burning stoves, and smart controls for energy management. Most importantly, the performance gap must be acknowledged and addressed, perhaps by mandating use of British Standard BS 40101.
Improvements to the mentioned criteria include:
Residential buildings
Criterion 1. SAP 10.2 will be replaced by the Home Energy Model (HEM) possibly later in 2025. HEM is more accurate than SAP and was modelled on the Passivhaus PHPP tool and is based on Energy Use Intensity (EUI) eg kWh/m2/y. Therefore, this criterion should also be written in terms of EUI and contain detailed information such as that used in the Greater Cambridge Local Plan Document with respect to reducing overheating, efficient use of water, and EUI targets.
Criterion 3: A figure is needed; please use 0.6 air changes per hour which is the PassivHaus level, and mandate mechanical ventilation with heat recovery which is essential below 3 air changes per hour.
Criterion 4 needs to be strengthened from “to be considered” to 4kWp rooftop PV is required per home, except in exceptional circumstances. As an alternative, renewable energy generation at or above this minimum could be produced via a smart micro grid. There should also be a provision for a Heat Store together with sufficient controls for zoning the heat.
Criterion 6: Consideration of site density, layout, and coverage: specific recommendations are needed here e.g. how much north facing windows need to be smaller than south facing windows.
Criterion 7: Cool and Green roofs – runoff flooding risks and overheating. Whilst these are often desirable for commercial and civic buildings, they are not usually practical in domestic properties and conflict with the rooftop PV requirements.
Non-residential buildings
Criterion 1: Carbon reductions should be mandated by Passivhaus or equivalent standards. We welcome the use of stringent requirements based on energy use intensity (EUI). Criteria should include: carbon monoxide monitors, rainwater harvesting, sustainable urban drainage, designed to withstand flooding, no gas supply or log burning stoves, and smart controls for energy management.
Criterion 6: Sustainability performance certifications. At least BREEAM Outstanding is required, but preferably Passivhaus or equivalent standard.
This policy direction and others such as Biodiversity Net Gain (Draft Policy Direction-38) can be undermined if developers claim their schemes are not viable. Therefore, any such viability assessments must be independent, robust, and ensure that developers fulfil their responsibilities.
Draft Policy Direction- 23
As with the other net zero policies for buildings in this consultation, we are pleased to see reference to LETI and Passivhaus, but this policy direction needs to set out clearly when each standard should be required as if left to the applicant, it will just not happen.
The AECB CarbonLite Retrofit Standard is better for traditional buildings and also considers many more retrofit risks. The STBA Guidance Wheel provides the opportunity to research the interactions between different options of retrofit. Alternatively, PAS 2035 (for domestic buildings) & Trustmark could be required as it has consumer protection and QA embedded in it. For non domestic buildings, PAS 2038 should be used.
The policy relies heavily on EPCs for domestic buildings, although this system is due to be replaced. See:
Letter from Lord Deben chair, Committee on Climate Change to Lee Rowley MP parliamentary Under Secretary of State dated 2nd February 2023 – Reform of domestic EPC rating metrics to support of Net Zero
National Retrofit Hub response to the ‘Reforms to the Energy Performance of Buildings regime’ consultation 2024-2025 – February 2025.
Draft Policy Direction- 24- Embodied carbon
Other. Building 54,700 new homes will have massive implications in terms of embodied carbon. Building regulations say almost nothing about embodied carbon, so it is good to see that the intention is to go beyond building regulations for this. RIBA 2030 targets rather than 2025 must be used, and there need to be actual requirements in this local plan to reduce embodied carbon in construction.
Draft Policy G- Climate Resilient Design
Other. Most of this is suitable. However, new buildings should have air tightness of <0.6 air changes per hour (see Draft Policy Direction-22) which necessitates mechanical ventilation with heat recovery.
Chapter 11: A Biodiverse and Environmentally Resilient South Warwickshire
We support the direction of travel implied in all the draft policy directions in this chapter. However, effective implementation will be challenging. Here are a few of the key areas.
Draft Policy Direction-36 – Protection of Sites, Habitats and Species
Yes. The mandate to protect, conserve and enhance must be non-negotiable and in no circumstances should offsetting be allowed. The importance of protected sites for natural flood management where appropriate should be highlighted, cross-referenced to draft Policy J in chapter 7 on flood risks. A green / blue map identifying all existing sites, options for new sites and connectivity should form part of the plan. For example, Finham Brook in Kenilworth from upstream of the castle across Kenilworth down to the wetland area to be created under the HS2 bridge over the Brook.
Draft Policy Direction-37- Local Nature Recovery Strategy
Yes. As the LNRS is a statutory requirement this is non-negotiable. However, LNRS for the Warwickshire, Coventry and Solihull is still in preparation. The next iteration of the draft of the plan should take account of the emerging strategy and ensure that its provisions are hard-wired into the plan. This draft policy direction should also build on the WDC Biodiversity Action Programme and the Warwickshire Wildlife Trust Strategy
Draft Policy Direction-38 – Biodiversity Net Gain
Yes. In looking at whether BNG in excess of 10% is desirable the plan should draw on the experience of other local authorities where a higher rate has been approved. Measuring BNG is a process involving both evidence and judgement, and the authorities need to be confident that they have the resources and expertise to review and interrogate BNG plans put forward by developers. There is otherwise a danger that this becomes another box-ticking exercise rather than a genuine commitment to enhance biodiversity. SDC and WDC should start now to develop a scheme of offsite biodiversity units within their areas.
Draft Policy Direction –39- Environmental Net Gain
Yes. This emerging policy feels like work in early progress. Research needs to be done on other authorities that have introduced similar policies. It will be important to avoid overlap with DPD 38 (BNG) so as not to increase the burden on developers through duplication. A clear definition of how ENG goes above and beyond BNG is important as is how ENG will be measured.
Draft Policy Direction-49- Agricultural Land
Yes. Following recent controversies over planning for solar farms this direction is to be welcomed. Combined with a strong mandate elsewhere in the plan to support rooftop solar PV on all new residential and other buildings this should provide a strong framework to drive forward local renewable energy generation in the most appropriate places.
