Policy CC3 – Managing Heat Risk
Support
Draft Black Country Plan
Representation ID: 11730
Received: 08/10/2021
Respondent: Mr Greg Ball
Buildings and open spaces used by large numbers of people should balance the benefits of sunlight and ventilation with the need for shelter from extremes of weather - heat, cold and rain and snowfall. The covered colonnade, common in many countries, is under-used in the UK. COVID exposed the paucity of provision of sheltered outdoor seating, noticeably outside catering venues.
Support
Draft Black Country Plan
Representation ID: 12042
Received: 10/10/2021
Respondent: Miss Emma Thompson
none
Comment
Draft Black Country Plan
Representation ID: 23091
Received: 11/10/2021
Respondent: Canal & River Trust
The University of Manchester has undertaken research into the effect of urban cooling from the Rochdale Canal on Manchester City Centre and concluded that there is a notable cooling effect from the canal. Policy CC2 should recognise the benefit of maintaining and enhancing (including through restorations) the Black Countrys waterway network as part of efforts to manage heat risk.
Comment
Draft Black Country Plan
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.