Comment

Representation ID: 46198

Received: 11/10/2021

Respondent: Vulcan Property II Limited

Agent: Maddox Planning

Preceding draft policy CC2 regarding energy infrastructure sets a minimum threshold for development proposals to which it applies, whereas policy CC3 is drafted such that it applies to all development proposals without distinction. Whilst all development proposals can be subject to design materials choices in the context of managing heat risk, it is potentially only on larger development sites where there is the potential for layout and orientation choices to have a nearing on heat risk. Similarly, the cooling hierarchy set out in the draft policy is not necessarily appropriate or applicable to all development proposals.

Paragraph 16 of the Framework is clear that development plans should contain policies that are clearly written and unambiguous. Draft policy CC3 should be revised such that it is clear for which size/scale of development the draft policy can be reasonably applied and include a clear indication of on what grounds applicants will be able to demonstrate that expectations cannot be viably or reasonably met, including in context with the cooling hierarchy. Added clarification is necessary to ensure that the draft policy is sound in the context of it being clear, positively prepared and fit for purpose in seeking to managing in the most effective way heat risk from new development.