Comment

Draft Black Country Plan

Representation ID: 23090

Received: 11/10/2021

Respondent: Canal & River Trust

Representation Summary:

The Trust’s waterways provide a heat source that can be effectively used to provide heat and hot water to adjacent developments using water sourced heat pumps. We welcome the expectation in policy CC2 that heat sources for a communal heating system should be chosen to minimise likely emissions. The use of fossil fuels and all forms of energy generation that rely upon the combustion of carbonaceous feedstocks will need to be phased out and replaced by zero carbon, non-polluting and energy-efficient sources. Sustainably maximising the use of heat extraction from the canal network should have a valuable role to play in this.

The expectation that eat sources for a communal heating system should be chosen to minimise likely emissions could be strengthened by setting out a hierarchy against which developers and decision makers will be expected to assess proposals. Such an approach is set out in policy SI 3 (D) of the recently adopted
London Plan. It gives preference to zero-emission and local secondary heat sources over lower emission solutions like combined heat and power. The definition of secondary heat within the plan includes heat that exists naturally within the environment (air, ground and water)