Consultation Question Q10

Comment

Representation ID: 13885

Received: 20/03/2021

Respondent: John Finnigan

Question 10 asks for comment, and I agree with SP 9 B 4 but am dubious that SP 9 C 1 measures are effective except in areas of low flood risk – they deal with small scale unusual and flash flooding situations but not with a vastly increased flood risk pursuant to large scale housing development and the introduction of non-permeable surfacing on a large scale.

Comment

Representation ID: 15771

Received: 24/03/2021

Respondent: West Yorkshire Combined Authority (WYCA)

The Plan sets out, primarily in Policy SP9: Climate Change, Environmental Sustainability and Resource Use, its target to achieve net-zero carbon emissions by 2038.

This is in broad alignment with the ambition for the City Region to become a resilient net-zero carbon economy by 2038. Tackling the climate emergency is one of the priorities of the Combined Authority and we are committed to reducing carbon emissions to meet our 2038 net-zero carbon target. The upcoming ‘Tackling the Climate Emergency action plan’ due to be published later in 2021 will lay the foundations as we work towards becoming a net-zero carbon City Region. There will be an expectation that local policies support the action plan
including local plans that will need to evolve with it.

Comment

Representation ID: 15821

Received: 24/03/2021

Respondent: West Yorkshire Combined Authority (WYCA)

Policy SP9 provides direction on how developments can build in resilience to the impacts of climate change, including through incorporation of Sustainable Drainage Systems (SuDS), tree planting and green roofs which is welcomed.

Further consideration could also be given to how properties can be made more resilient to flooding when it occurs to ensure they are brought back into use sooner and with less resources required for the recovery/repair phase. This Policy could also be enhanced by referencing the role of digital infrastructure/technology in supporting climate change ambitions and environmental sustainability, for instance by reducing the need to travel or supporting smart monitoring of energy use.

Object

Representation ID: 16722

Received: 24/03/2021

Respondent: Shipley Town Council

We are very supportive of the target of zero carbon by 2038. To ensure this we want to see elements in the plan strengthened.

Point A3 needs to be strengthened by calling for modelling by developers for all new developments to demonstrate that the proposed development is carbon neutral or carbon negative; in terms of emissions from construction, building energy use and travel resulting from the development.

This policy also needs additional wording to ensure developments are being designed to incorporate measures to adapt to climate change.

We want the following added to SP9:
The following measures shall be incorporated into all development:
Wherever possible, new buildings shall be orientated to maximise the opportunities for both natural heating and ventilation and reducing exposure to wind and other elements;
● Proposals involving both new and existing buildings shall demonstrate how they have been designed to maximise resistance and resilience to climate change, for example by including measures such as solar shading, thermal mass, heating and ventilation of the building and appropriately coloured materials in areas exposed to direct sunlight, green and brown roofs, green walls, etc;
● Use of trees and other planting, where appropriate, as part of a landscape scheme to provide shading of amenity areas, buildings and streets and to help to connect habitat, designed with native plants that are carefully selected, managed and adaptable to meet the predicted changed climatic conditions; and
● All development shall minimise the impact of surface water runoff from the development in the design of the drainage system, and where possible incorporate mitigation and resilience measures for any increases in river flooding levels as a result of climate change

Object

Representation ID: 19775

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

The target date for net zero carbon should be brought forward from 2038 to 2030.

SP9 A3 should be strengthened to ensure that the developers demonstrate that their proposals are carbon neutral or carbon negative in relation to construction, building energy use (see below) and travel.

A number of specific measures that developers should be required to incorporated into all developments are provided relating to
- opportunities for both natural heating and ventilation and reducing exposure to wind and other elements;
- maximise resistance and resilience to climate change e.g. solar shading, thermal mass, heating and ventilation, appropriately coloured materials, green and brown roofs, green walls, etc;
- use of trees and other planting to provide shading, to connect habitat with carefully selected native plants
- minimising the impact of surface water runoff from the development in the design of the drainage system

Object

Representation ID: 19811

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

The target date for net zero carbon should be brought forward from 2038 to 2030.

SP9 A3 should be strengthened to ensure that the developers demonstrate that their proposals are carbon neutral or carbon negative in relation to construction, building energy use (see below) and travel.

A number of specific measures that developers should be required to incorporated into all developments are provided relating to
- opportunities for both natural heating and ventilation and reducing exposure to wind and other elements;
- maximise resistance and resilience to climate change e.g. solar shading, thermal mass, heating and ventilation, appropriately coloured materials, green and brown roofs, green walls, etc;
- use of trees and other planting to provide shading, to connect habitat with carefully selected native plants
- minimising the impact of surface water runoff from the development in the design of the drainage system

Object

Representation ID: 19837

Received: 01/04/2021

Respondent: Natural England

We advise that wording of both points 3 and 4 could be made more robust through the following amendments which emphasise the role of the natural environment in delivering measures to reduce the effects of climate change through nature-based solutions (for example tree planting to moderate heat island effects), and the importance of restoring natural assets where possible:

3. Incorporating green infrastructure into the scheme from the outset, including such measures as the provision of: areas of green space and green corridors, landscaping, tree planting and retention of existing trees and hedgerows, and nature-based solutions such as green roofs and walls, and SuDS (Policy SP10).

4. Facilitating the management, restoration, enhancement and expansion, of vulnerable habitat types: primarily blanket bog and woodland, which are important for carbon sequestration; and ensuring a net gain in biodiversity (Policy EN2).

Specific reference to net gain is also made within policies SP9, SP10 and TR2, however, the minimum 10% net gain is only stated in TR2. For the sake of consistency it is recommended that these policies either state the 10% minimum net gain requirement or make specific reference to Policy EN2.

Comment

Representation ID: 21614

Received: 23/03/2021

Respondent: Bradford District Ward Councillor (Conservative)

For any new developments an assessment should be made on the environmental impact for neighbouring homes. New developments should not proceed if it adversely hinders neighbouring homes to achieve this aspiration, for example by blocking natural light to solar heating panels.

A mandatory delivery of energy efficient cost-neutral housing would set a standard for Lifetime Homes for future generations.

Object

Representation ID: 21803

Received: 23/03/2021

Respondent: Duncan Watson

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 21886

Received: 23/03/2021

Respondent: Catherine Starling

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 21915

Received: 23/03/2021

Respondent: Dr Samantha Cook

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 21944

Received: 23/03/2021

Respondent: Birgit Almond

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 21973

Received: 23/03/2021

Respondent: Mrs Corrie Hardaker

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 22002

Received: 23/03/2021

Respondent: Carly Mitchell

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 22031

Received: 23/03/2021

Respondent: Helen Ross

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 22063

Received: 23/03/2021

Respondent: Rebecca Spencer

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 22092

Received: 23/03/2021

Respondent: Lucy Ashton

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 22121

Received: 23/03/2021

Respondent: Mr Chris Turner

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 22150

Received: 23/03/2021

Respondent: Judy Breckett

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 22190

Received: 23/03/2021

Respondent: Mr Paul Hardaker

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 22219

Received: 23/03/2021

Respondent: Helen Taylor

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 22248

Received: 23/03/2021

Respondent: Dr Ceri Pitches

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 22277

Received: 23/03/2021

Respondent: Mrs Sonya Hampton

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 22306

Received: 23/03/2021

Respondent: Vivienne McCabe

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 22335

Received: 23/03/2021

Respondent: John McCabe

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 22364

Received: 23/03/2021

Respondent: Natalie Shaw

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 22475

Received: 23/03/2021

Respondent: Harri Pitches

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 22504

Received: 23/03/2021

Respondent: Miss Teresa McDonell

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 22533

Received: 23/03/2021

Respondent: Mrs Vicky Gordon

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.

Object

Representation ID: 22562

Received: 23/03/2021

Respondent: Mr Robin McDonell

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.