Policy CC1 – Increasing efficiency and resilience

Comment

Representation ID: 11167

Received: 24/09/2021

Respondent: Mr Richard Carter

Something that is worth saying at this point is that there is a place for Artificial Intelligence (AI) and digital technology in our society. However, while investigating possible uses of such technology, there is an underlying requirement to consider the ramifications of any implementation on society, i.e. the benefits of implementing technology need to be balanced against potential negative human impact.

Comment

Representation ID: 11177

Received: 24/09/2021

Respondent: Mr Jack Richards

All major proposals regardless of floor area should include a need for whole life cycle carbon assessments to fully understand the environmental impact of embodied carbon. Then set certain thresholds where the demolition of certain buildings for example would not be supported.

Comment

Representation ID: 11179

Received: 24/09/2021

Respondent: Mr Jack Richards

Suggested additions include supporting development that is denser, and less car dependent.

Support

Representation ID: 11492

Received: 04/10/2021

Respondent: Woodsetton Charitable Trust

The Trust wholeheartedly supports to proposed response to climate change subject to the necessary resources and delivery arrangements being made available.

Support

Representation ID: 11899

Received: 10/10/2021

Respondent: Mr. Dennis R Whittaker

Overall, I support the Policy but disagree with the proposed BC Plan's unrealistic reliance on so-called sustainable forms of transport such as Public Transport, cycling and walking as set out in TRAN6, TRAN7 and elsewhere. Walking is only realistic over short distances and Cycling over longer distances is not an option for most people especially in our climate. Public Transport is unreliable, often uncomfortable and does not always get one directly from "a" to "b" - often one needs to change Buses which sometimes do not connect. It is inefficient. Connections to places outside the conurbation are scarce or absent.

Support

Representation ID: 12041

Received: 10/10/2021

Respondent: Miss Emma Thompson

no comment

Object

Representation ID: 12793

Received: 06/10/2021

Respondent: Rhiannon and Tony Fearn

Number of people: 2

• What legacy is left for future generations when we continue to ignore climate change warnings in a rush to build, build, build

Comment

Representation ID: 13013

Received: 10/10/2021

Respondent: Mrs Elaine Baggott

Concern about climate change.

Comment

Representation ID: 13719

Received: 09/10/2021

Respondent: Mrs Linda Cottrell

All new houses and new builds, regardless of whether public or for private purchase should be fitted with solar panels feeding back into the national grid. The prime ministers office tells me this should be a matter of personal choice - twaddle. I dont see personal choice being applied to cars or our use of them. Who would even notice the cost of solar panels in a new build of £250,000 or more? I would love to move into a new build where my house was paying me back something now and again

Comment

Representation ID: 16742

Received: 11/10/2021

Respondent: Mr John Christophers

Dear Black Country consultation
My main comment on the plan is that all new homes should be built to net zero carbon standards
now.
The policy should include operational carbon emissions but also embodied carbon emissions. For a
new home, the embodied carbon emissions from construction can be as much as half the carbon
footprint measured over its 60-year design life (RICS, 2017).
There is a considerable evidence base for much stronger local standards, a there is no agreed national
standard, “Future Homes standard” still be some years away and subject to consultation.
The statutory Climate Change Committee have repeatedly made clear that national policies for new
homes are not yet driving change at the required pace (CCC, 2019).
The United Nations, IPCC, and other commentators consider 2050 targets will be too late to prevent
irreversible climate change, missing the Paris target to limit global warming to 1.5degC (UNCC, 2021),
(IPCC, 2021).
The Good Homes Alliance (GHA) Vanguard Network unites many local authorities who want to “Build
Net Zero Now”, rather than waiting for 2025 or 2030 (GHA, 2020).
There is clear evidence that new homes built merely to minimum Building Regulations standards - ie
not built to zero carbon standards - would be five times more expensive to retrofit a decade later
(Currie & Brown, 2019).
Construction is clearly the best point at which to make a home both energy efficient and low carbon.
I am happy to amplify/discuss any of these points further if you wish.
References
RICS (2017) Royal Instute of Chartered Surveyors. Whole life carbon assessment for the built
environment. Available at: hps://www.rics.org/globalassets/rics-website/media/news/whole-lifecarbon-assessment-for-the--built-environment-november-2017.pdf [Accessed 16 July 2021]
CCC (2019) Climate Change Commiee. UK Housing: fit for the future? Available at:
hps://www.theccc.org.uk/publicaon/uk-housing-fit-for-the-future/ [Accessed 16 July 2021]
UNCC (2021) United Naons Climate Change. NDS Synthesis report. Available at:
hps://unfccc.int/news/climate-commitments-not-on-track-to-meet-paris-agreement-goals-as-ndcsynthesis-report-is-published [Accessed 16 July 2021]
IPCC (2021) Climate Change 2021: The Physical Science Basis. Contribuon of Working Group I to the
Sixth Assessment Report of the Intergovernmental Panel on Climate Change. Available at:
hps://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_SPM.pdf [Accessed 10 Aug
2021]
GHA (2020) Good Homes Alliance. Build Net Zero Now. Campaign iniave Available at:
hps://goodhomes.org.uk/campaign/build-net-zero-now [Accessed 12 Jan 2021]
Currie & Brown (2019) The costs and benefits of ghter standards for new buildings: A Report for the
Commiee on Climate Change. Available at: hps://www.theccc.org.uk/publicaon/the-costs-andbenefits-of-ghter-standards-for-new-buildings-currie-brown-and-aecom/ [Accessed 12 February
2021]

Comment

Representation ID: 17873

Received: 10/10/2021

Respondent: Mr Peter Hepworth

Given the climate crisis all plans should incorporate the following requirements:
1) The preservation and enhancement of natural ecosystems. This will involve incorporating wildlife
corridors, open watercourses and ponds into development schemes.

Support

Representation ID: 20830

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.19 to 10.21 - L&Q Estates support the principles set out in Policy CC1 as being an appropriate
response to climate change.

Comment

Representation ID: 21355

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

POLICY CC1 – INCREASING EFFICIENCY AND RESILIENCE
The intention of Policy CC1 is recognised by WDH, who has adopted a holistic fabric-first approach in their house type design that seeks to reduce each dwelling’s inherent energy demand and aims to reduce energy waste and CO2 emissions by increasing energy efficiency. With that said, limb e of the policy requires developments to incorporate “grey water recycling and rainwater collection” where possible. Whilst that requirement is recognised, it should be made clear that the use of grey water recycling should only be applied where viable and appropriate.

Comment

Representation ID: 22197

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

We have no objection to the general thrust of the policy and agree that the need to reduce climate change is paramount. However, there is duplication with this policy and other policies that are in draft Plan. As such, this policy is superfluous and should be removed.

Comment

Representation ID: 22222

Received: 11/10/2021

Respondent: Steve Crutchley

Policy CC1 – Increasing Efficiency and Resilience

We have no objection to the general thrust of the policy and agree that the need to reduce climate change is paramount. However, there is duplication with this policy and other policies that are in draft Plan. As such, this policy is superfluous and should be removed.

Comment

Representation ID: 23089

Received: 11/10/2021

Respondent: Canal & River Trust

In addition to river and surface water flooding (which are currently identified in policy CC1(f)), in some cases, it may be necessary for development to incorporate mitigation and resilience measures designed to reduce the risk of flooding from other sources. We suggest that amending this point to refer to any potential source of flooding would be consistent with the NPPF and NPPG.

Comment

Representation ID: 23165

Received: 11/10/2021

Respondent: Environment Agency

Adapting to climate change isn’t just about energy efficiency; it is also about water demand management. Climate change could result in an increase in water scarcity which is why measures to reduce demand and encourage the efficient use of water are so important. In addition, there is energy embedded in water purification, delivery and subsequent treatment of wastewater. This is acknowledged in 10.156 c), but the policy body itself only mentions water efficiency in relation to conversions (g), and greywater and rainwater collection as a means of reducing run-off (e). Although collection and re- use of greywater and rainwater does reduce the demand on potable water supplies, this hasn’t been stated explicitly.
Pressures on water supply to new and existing homes as well what is available to the environment could also have detrimental impacts on water quality due to dilution etc in the associated waterbodies (rivers and groundwater in the underlying aquifers) both in the Black Country and wider area. We recommend CC1 include reference to the need to ensure both water resources and quality are considered in this policy to ensure water efficiency and protection and enhancement of the water environment is a priority. We
note the WCS includes a recommendation for further assessment as part of the phase 2
WCS that water quality modelling in should include
sensitivity testing to a reduction in river flow. The outcomes of this should feed into this policy.

In light of the above we recommend the policy is reworded as follows:

1(i) new developments should reduce their water usage as far as possible through sustainable water demand management (in line with the requirements of ENV9)

Comment

Representation ID: 23274

Received: 11/10/2021

Respondent: Historic England

We support the references in clause h. Every care should be taken to ensure that appropriate and sensitive measures are undertaken.

Comment

Representation ID: 23318

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

We have no objection to the general thrust of the policy and agree that the need to reduce climate change is paramount. However, there is duplication with this policy and other policies that are in draft Plan. As such, this policy is superfluous and should be removed.

Object

Representation ID: 23389

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

Policy CC1
The policy on Climate Change is in our view inadequate. The policy deals entirely with how developments will individually be designed with climate change in mind. The policy does not seek to influence where development happens. Climate Change needs to be a core element of the plan including a target for reaching Net-Zero in line with the Councils position terms of the Climate Emergency. It also needs to influence which sites are included in the plan and their transport impact in terms of car-dependency.
Such a policy should be at the core of meeting the Climate Challenge in the Borough. It should also be included as a Core Strategic Policies.

Object

Representation ID: 23572

Received: 11/10/2021

Respondent: Save the Seven Cornfields Campaign Group

Agent: Save the Seven Cornfields Campaign Group

Broadly and Summarised:
1) We support the exclusion / non-inclusion of the Seven Cornfields as a site for housing development.
2) We support the saving of the Green Belt Seven Cornfields site.
3) We oppose development on the Green Belt and important greenfield sites.
4) We do not support the housing forecast model used. Equality Impact assessment is needed.
5) We do not support the excessive housing target of 76,000 homes.
6) We believe there should be greater equity and equality within the local planning process and Nolan standards of public office be upheld.
7) We believe the Seven Cornfields is an important carbon sink, it contributes to care of the planet and local areas, avoids flooding and provides equality of access.
8) The report addresses amongst others Para 3.15-3.16, Policy DEL2, Policy HOU1, Policy CC1
9) Brownfield, derelict land, retail and office spaces can meet the housing demands.
The Black Country Plan 2039 policy on Climate Change is inadequate and falls within other objections about lack of innovation and total reliance on sustained growth of existing models of production, wealth generation and income generation. Alternatives don’t have to be absolutely alternative than present ones but, in many instances, just require a bit more creativity and imagination from policy makers and employers.

Applying the right discretion to the Black Country Local Plan and Local Planning process can ensure that the pioneering and guiding principles are adhered to and this ought to be the genesis of an Option that takes proper account of:

1.Exercise Free at the point of participation.
Quality of Life especially in relation to Health Improvement and declining provision of Health Care and Treatment. In essence, wise decisions and actions should result in more people exercising and undertaking mental exercises to reduce mental ill health. Exercises such as walking in Green Spaces provides such overall health benefits which are free at the point of participation. More so than in richer areas where residents have the residual income to purchase subscriptions, poor folk have difficulty with ensuring capacity to buy and rely on free at point of participation facilities.

2.Life choice changes following Covid 19The pandemic and consequential lock downs has informed many of the different life choices available. None of these are considered in the assumptions generated in Housing Demand forecasts. Spending more time and working at home has highlighted the dis-benefits of daily commutes. It has also raised the question of a life well lived which need not be premised on full time work and constant consumptions.

3.The Care of the Planet and Protection of Green Belt paradigm In less than a decade the realisation that the Planet needs to be protected from polluting industries and unthinking exploitation, this is coupled with a need to safe important clusters of flora and fauna. Natures Carbon Sinks must be sustained. Fundamentally, investors and developers should not be able to make income or wealth destroying the planet or a locality. (Policy CC1)

4.Dramatic Weather Patterns and Flooding Few could dispute in Britain, Europe and the World dramatic changes in weather patterns have resulted in Floods which the consequential economic, social and physical damages and costs. It is beyond stupid to develop on sites where the risks of Flooding on the site and adjacent areas is probable or already demonstrated. The Seven Cornfields site, for instance, has suffered from changes in the water layers and there has been frequent flooding of the Penn Golf Club site. This problem will in every likelihood of greater flooding and damage on the Golf course if the Seven Cornfields site is developed. Policy CC1

5.Fungal diversification
Increasingly, scientists are realising that the microscopic action of fungi are important in maintaining a viable ecosystem. These takes a long period to develop and cannot easily be built up once lost. Many Green Belt and important green field sites are hosts to a very diverse biosphere of fungal networks that are important to above ground plant life. Policy CC1

6.Pollution
Air pollution increases with development and traffic. Some but not all air borne pollutants are reduced where large green tracks exists. Put another way, a fully developed and built area with
stagnant air leads to respiratory problems. Policy CC1

7.Business Growth does not always require extra buildings
(In reality, it is people and their activities - not buildings and physical infrastructure - which release and realise creativity and productive potential that then creates income and wealth. Relationships between individuals, groups and communities create income and wealth. Traditional economics and that contained in the Local Plan considered an old formulae which is entrepreneur plus land, labour and capital creates wealth. A brief consideration of some of the largest businesses to date with phenomenal growth, these demonstrate Land is not so critical. Consider Facebook, Bit Coin, Uber, Amazon and Google. Policy CC1

Support

Representation ID: 43882

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

11.31 Policy CC1 identifies the proposals for development will need to demonstrate how they have been designed to maximise resistance and resilience to climate change through addressing a number of specified requirements. These include:
· Being orientated to maximise natural heating and ventilation;
· Including a range of sustainable land low carbon transport modes as alternatives to private car use;
· Use of trees and other planting to provide for shading, air quality mitigation and connection of fragmented habitats;
· Utilising a mix of native tree species and plants;
· Minimising surface run-off; and
· Incorporate mitigation and resilience measures to reduce the risk of river and surface water flooding.
11.32 Taylor Wimpey supports the principles set out in Policy CC1 as being an appropriate response to climate change.

Comment

Representation ID: 46196

Received: 11/10/2021

Respondent: Vulcan Property II Limited

Agent: Maddox Planning

The Framework sets outs clear guidance on planning for climate change:

‘Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes, and the risk of overheating from rising temperature’

It continues that development plan policies should support appropriate measures to ensure the future resilience of communities and infrastructure to climate change impacts, such as providing space for physical protection measures, or making provision for the possible future relocation of vulnerable development and infrastructure. New development should be planned for in a way that avoids increased vulnerability, manages risks and makes best user of location, orientation and design. There is support for the use and supply of low carbon energy, including community-led initiatives.

To provide clarity for applicants, Draft policy CC1 should include assessment criteria against which the local planning authority can determine whether a development is in compliance with its climate change and energy policies in the context of local requirements and site specific circumstances.