South Warwickshire local plan – response & comments
Below are key Green Party responses to the local plan consultation, which is at https://www.southwarwickshire.org.uk/swlp/Issues-and-Options-Consultation.cfm and closes on 6th March 2023.
Because these questions are complex, we’ve explained our reasoning, including broader context. We owe it to our children and grandchildren to make tough changes which may seem radical to some, but are essential to meet the ecological and climate crises.
Chapter 4. Meeting South Warwickshire’s Sustainable Development Needs
See https://southwarwickshire.oc2.uk/document/124/3728#d3728
Issue I1: Sustainability Appraisal
Although we support the intention of this sustainability appraisal, the implementation has too many issues to be used with confidence. The underlying methodology to the whole exercise is based on simple scores, many of which are contentious because they depend on intention or policy rather than factual information. As a result, the findings are very sensitive to particular scoring values and provide relatively weak discriminatory power (i.e. many of the rose diagrams look very similar). Yet the scores are used to rank locations (e.g. Best Performing Location) as evidence for the Issues and Options report. Minor errors in the scorings, rose diagrams and ‘averaging’ across objectives could result in quite different findings. (Further explanation & information available below).
Issue S2: Intensification
The feedback from the first consultation and associated commentary in the current consultation document provide compelling reasons to have strong policies to support intensification. These include increasing active travel, maintaining local services and reducing the need to build on greenfield sites. Both options S2a and S2b have merit, but S2b is preferable as it effectively includes S2a. S2b is “Have a policy with ‘in principle’ support for intensification development, applicable across South Warwickshire; and develop design codes” this approach should be used in conjunction with Option T1c about 20 minute neighbourhoods: see chapter 10, below.
Issue S3: Using Brownfield Land for development
The urban capacity study identifies relatively little room for growth in the number of residential properties in existing urban areas. However, over the life of the local plan, major changes may increase this number. For example, reduction in office and retail space may provide development opportunities, as does the trend for fewer residents living in each property. It is important to maximise the potential for brownfield and currently used urban sites as explained in the previous response (Intensification).
Chapter 6. Delivering homes that meet the needs of all our communities
See https://southwarwickshire.oc2.uk/document/124/3763
Issue H1: Providing the right number of new homes
QH1-1 & 2. The basis for the proposed housing numbers is the 341 page report: “Coventry & Warwickshire Housing & Economic Development Needs Assessment (HEDNA)” found at https://www.southwarwickshire.org.uk/doc/211518/name/CW%20HEDNA%20Final%20Report%20171122%20Clean%20.pdf Chapter 5 describes the ‘standard method’ for calculating required housing numbers:
- Previous rate of building houses.
- . Increase the rate depending on the affordability ratio (median house price divided by median salary)
- Impose a cap if necessary (not applicable locally), and
- Increase the rate for large urban centres (applies to Coventry). Therefore, it requires faster and faster housebuilding locally.
There are several contentious issues here.
The government expects 2014-based Household Projections to be used, whereas the report sensibly indicates that the 2021 census is more accurate and recent. Using the census figures would require higher housebuilding in south Warwickshire but lower building in Coventry and north Warwickshire. However, this doesn’t adjust for the fact that Warwick District’s current local plan already includes 5,976 over-spill homes for Coventry, which the census shows were based on grossly inflated claims regarding population growth in Coventry. Therefore, it could be argued that both the ‘2014’ and census figures are too high for Warwick District.
The government’s formula requires exponential increases in housebuilding which are clearly unsustainable both environmentally and socially. The affordability ratio is based on single incomes, whereas many properties are bought by couples who are both working. No adjustment is made for inherited wealth (and the bank of mum & dad), which is increasingly important for house purchases. Thus, the government’s bizarre self-reinforcing calculations are not evidence based, do not reflect how people finance house purchases, and make no effort to address regional issues.To tackle the housing crisis, the government needs to reduce the wealth gap in society and regional variations rather than building more houses, particularly in hot spots like south Warwickshire, that are unaffordable for too many.
One of the factors of the overheated housing market is investors buying additional properties to rent meaning that there are fewer available for people wanting to own their own home. For these people the properties exist, but are unaffordable. The Council should take a stronger line on enforcing higher standards for landlords, so that not only do tenants have good properties, but that other investments will yield a higher return leaving more properties for people aspiring to own their own home.
Regarding the number of houses to be built, the government has recently announced “This number should, however, be an advisory starting point, a guide that is not mandatory.” Unfortunately, it is unclear how far a local plan can deviate from this number nor what justifications are required. At the same time, it was announced that it was “ending the so-called ‘duty to co-operate'” which implies that Warwick District will not be required to take any future Coventry over-spill.
Given the current chaotic, uncertain and illogical regulatory environment, it is extremely difficult to make rational decisions on housing numbers in the best interests of local residents. If it is assumed that the duty to cooperate has ended and that local plans no longer need to closely follow HEDNA numbers, it would be sensible to decide a number significantly lower than the 2014-based projections for Warwick district. This is because it is unclear of the impact of the enormous house building programme currently underway, particularly south of Leamington/ Warwick and from Kenilworth to Coventry. It may be that this, current economic uncertainty and other factors will reduce the affordability ratio and slow the demand for further housing.
Chapter 7. A climate resilient and Net Zero Carbon South Warwickshire
See https://southwarwickshire.oc2.uk/document/124/3770#d3770
Issue C1: Solar and wind power
Solar farms and onshore wind will be the key areas of focus. The document clearly sets out the need for consideration of the impact of landscape and heritage assets, the loss of agricultural land and the sterilisation of mineral reserves. The latter is not quite accurate as solar and wind farms are not permanent fixtures.
Community support is also important and here consideration should be given to the immediate community to a new facility benefiting in terms of a reduction to their cost of electricity for the time that the development is in place. This may provide a driver for certain communities to ask for solar farms and on shore wind developments. There are also a small number of community wind schemes (e.g. Ripple Energy) where the public have the opportunity to buy shares in a wind farm and get a return in electricity cost reduction
What is not mentioned are the significantly large areas of roofs on both residential and non residential buildings that could be equipped with PV. This could include schools, warehouses, public buildings etc. There should also be a policy that all new buildings are equipped with appropriate levels of PV panels. As stated earlier, this should at least provide the electricity to match the building’s energy requirements.
Issue C2: Decentralised energy systems
The current thinking for true net zero carbon low rise housing is that decentralised energy is not appropriate as it is basically not needed. Decentralised energy is a possible solution for the deep retrofit to true net zero carbon standards for existing domestic and non-domestic buildings. A good example is the use of the ‘waste’ heat from the Coventry incinerator being used to heat existing buildings in the city.
Combined heat and power is a solution that can be considered for non-domestic buildings such as civic amenity buildings, Leisure and Sports Centres. However, as the direction of travel is to remove fossil fuels for the generation of energy, consideration should be given to firstly significantly remove the need for energy using the Passivhaus Standard or equivalent as has been achieved by Exeter City Living with the recent construction of St Sidwell’s Point Leisure centre.
Issue C3: Carbon Sequestration
The information provided on carbon sequestration is correct but there needs to be a separate section on Offsetting. Offsetting policies will be very important, especially to ensure that they are not abused by developers. There is no definition of Offsetting in the Glossary and this must be addressed.
Carbon emission offsetting is a wide subject and includes:
- Trees
- Off-site renewable energy
- Retrofit of existing properties off-site to reduce carbon
Carbon emission offsetting is necessary for specific new build categories such as flats, office buildings, industrial buildings where on site renewable energy is not possible. Carbon emission offsetting should NOT be used for low rise new residential dwellings where all of the energy requirements must be matched by on site renewables.
Issue C4: New Buildings
We agree with “Option C4.1b: Set a higher local standard beyond the building regulations requirements to achieve net zero carbon in all new developments.” The Planning Inspector has confirmed that Cornwall Council’s Climate Emergency DPD (Development Plan Document, that has the same status as a local plan) is sound subject to recommended modifications and is due to be adopted. This DPD precisely defines net zero carbon homes. As there are other similarly ambitious DPDs and local plans being developed, it is likely that when this South Warwickshire local plan is approved it won’t be that radical and viability will be less of an issue as net zero costs will have fallen.
Issue C5: Existing Buildings
We agree with “Option C5a: Include a policy that requires net zero carbon requirements for all building proposals that require planning permission; including conversions, changes of use, and householder residential applications”. The policy should require that all retrofit is undertaken to a specific standard that requires performance levels in terms of air tightness and insulation. If retrofit is not done properly, the health and wellbeing of occupants and indeed building fabric will suffer, and before 2050 the building will need to be retrofitted again! As this is an extremely difficult area, the standard must be nationally recognised.
We also agree with “Option C5b: Include a policy that encourages the retrofit of climate change measures, such as solar panels and heat pumps, including those on traditional buildings or within historic areas”. For too long, the council has prevented retrofit of listed buildings and those in conservation areas even when done sympathetically with high quality materials. Traditional Buildings require a risk-based approach as defined in guidance from Historic England and the Sustainable Traditional Buildings Alliance (STBA).
Chapter 10. A well-connected South Warwickshire
Issue T1: 20-minute neighbourhoods
See https://southwarwickshire.oc2.uk/document/124/3798
The consultation document explains the principles of 20 minute neighbourhoods and that responses to the first consultation support these principles which ensure that key infrastructure such as shops, schools and doctors are located close to people’s homes. Therefore preference must be given to Option T1c: “Include a bespoke policy requiring the principles of 20-minute neighbourhoods to be included within development proposals.” This option would clearly set out “the vision and expectations for new developments and places, to ensure early design incorporation.” Clear design or master planning of major developments is vital to maximise connectivity and minimise walking distances for residents. Sadly, previous haphazard developments have not done this.
Chapter 11. A biodiverse and environmentally resilient South Warwickshire
See https://southwarwickshire.oc2.uk/document/124/3803
The introduction to this chapter includes powerful aspirations (Strengthening green and blue infrastructure and achieving a net increase in biodiversity) but the challenge will be to incorporate these into the plan. It is important to understand that enhancing biodiversity is not a bolt-on extra after everything else has been decided, but should be hard-wired into the plan from the start. The plan should seek to consolidate criteria for the four specially designated areas (Areas of Restraint, Vale of Evesham Control Zone, Special Landscape Areas and Cotswold AONB) and bring these together with the consideration of the greenbelt. The aim should be to develop a consistent plan-wide approach with policies that can be unambiguously implemented by planners to protect special landscapes and enhance biodiversity.
Issue B1: Areas of Restraint
The areas of restraint are an important component of the current SDC plan, but do not feature in the current Warwick Plan. They should be retained in the new plan, whilst extending these principles into appropriate areas in Warwick District. There is also a need for a consistent approach to designating these areas within the framework of the nationally mandated greenbelt. The current greenbelt designation concerns issues of openness, inappropriate development and traffic generation. The new plan should extend these policies (possibly through definitions in the Areas of Restraint) to include biodiversity enhancement. Any development in the greenbelt / area of restraint should only be permitted (in addition to the other conditions) if there is a measurable increase in biodiversity.
Issue B5: Environmental Net Gain
Committing to a Biodiversity net gain not only on all new developments but across the whole of the Local Plan area. This goes beyond tree planting and must include a multivariate approach with appropriate environmental stewardship in agriculture and properly planned open spaces to provide for recreation and community use.
The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. However, carbon offsetting is still a very contested policy, with some arguing that some forms of offsetting allow developers to avoid their obligations to the areas they are developing while blighting other areas where the offset is applied – for example planting non-native trees on high-grade agricultural land, sometimes many miles from the development site. Other types of offsetting, for example committing to retrofitting existing houses, make more sense. Definitions of offsetting need to be tightly drawn in the plan to prevent ‘greenwashing’.
‘Natural Capital’ is another concept of concern, as it tends to reduce the natural world to monetary values. If a value is assigned to, say, a woodland, there is a danger that a road that destroys the woodland may be ascribed a higher value, and therefore the woodland goes. Only if natural assets are ascribed a non-negotiably high value can areas rich in biodiversity be preserved. The plan should reference the lessons of the Economic Review of Biodiversity: the Dasgupta review (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/957292/Dasgupta_Review_-_Abridged_Version.pdf ) before settling the policy in this area.