Support
Part One: Spatial Strategy and Policies (Regulation 18)
Representation ID: 108
Received: 19/12/2023
Respondent: Mr John Davison
Inclusion of provision for wildlife such as nest bricks in refurbished industrial and in new buildings, can contribute to this policy.
Support
Part One: Spatial Strategy and Policies (Regulation 18)
Representation ID: 219
Received: 05/01/2024
Respondent: Dennis R Whittaker
I support the general aims of the Policy.
I note:-
Paragraph 2-The need to provide a screening Health Impact Assessment as part of the planning
application for certain developments.
Paragraph 4-To support the physical, social, and mental health and wellbeing of its residents,
Dudley will support vibrant centres and local facilities, this will include managing the location,
concentration of and operation (including opening hours) of businesses which contain uses running contrary to these aims including:
a. Proposed developments for Hot food takeaways (including hybrid uses incorporating such uses). Developments will only be supported where they support this aim and Policy DLP29
Comment
Part One: Spatial Strategy and Policies (Regulation 18)
Representation ID: 311
Received: 21/12/2023
Respondent: Barberry Summerhill Limited
Agent: Harris Lamb
Policy DLP 8 Health and Wellbeing
The policy requires that residential developments of 150 dwellings or 5 hectares will be required to provide a Health Screening Impact Assessment as part of the planning application. Barberry acknowledge that significant residential development such as that being promoted at the Triangle site in Kingswinford, has the ability to make significant contributions to the health and wellbeing of new and existing residents alike. This can be principally through the provision of areas of public open space and recreational amenities on site, including measures to make active travel by the provision of new footway and cycleway and the provision of on-site facilities such as new allotments or community orchards. These measures would not all be possible on previously developed sites within urban areas and, therefore, the benefits of identifying larger strategic greenfield sites, such as the Triangle site, could actually have a positive impact on the health and wellbeing of residents for the Borough.
Support
Part One: Spatial Strategy and Policies (Regulation 18)
Representation ID: 378
Received: 21/12/2023
Respondent: Worcester Lane Limited
Agent: Harris Lamb
Policy DLP8 Health and Wellbeing
We welcome the proposal that Health Impact Assessments should only be undertaken on larger residential developments of more than 150 dwellings.
Comment
Part One: Spatial Strategy and Policies (Regulation 18)
Representation ID: 397
Received: 22/03/2024
Respondent: Home Builders Federation
Agent: Home Builders Federation
The policy seeks to require a screening Health Impact Assessment (HIA) as part of the planning application on (amongst other things) residential developments over 150 dwellings or 5has. However, the justification text refers to HIA. HBF understand that screening HIAs are a different thing from full HIAs. The Plan neds to be clear which it is referring to and provide definitions of both to avoid any confusion.
Comment
Part One: Spatial Strategy and Policies (Regulation 18)
Representation ID: 513
Received: 21/12/2023
Respondent: NHS Black Country Integrated Care Board
Agent: Winterburn Heritage & Planning
DLP8:
The Black Country ICB commissions healthcare services in Dudley. The ICB brings NHS services together locally to improve population health and establish shared strategic priorities. Services provided by an ICB include the following:
GP services
Pharmacies
Community health services
Mental health services
Adult social care
Voluntary organisations
Further to this, GP surgeries are grouped into Primary Care Networks (PCNs) serving populations generally of between 30,000 and 50,000 registered patients, enabling greater provision of coordinated and integrated health and social care. PCNs therefore by necessity span larger geographies to meet the needs of communities, including areas beyond Dudley's Boundaries.
The ICB supports the Local Plan Policy intention to promote the health & wellbeing of Dudley's local communities, and require the assessment and mitigation of development proposals on the above services.
Comment
Part One: Spatial Strategy and Policies (Regulation 18)
Representation ID: 529
Received: 21/12/2023
Respondent: Churchill Retirement Living
Agent: Churchill Retirement Living
There would appear to be a significant amount of overlap between the evidence required for the loss of community facilities / open space and the Health Screening Assessment and we would ask the Council to consider if sub-clause 2 e) is necessary on that basis.
Object
Part One: Spatial Strategy and Policies (Regulation 18)
Representation ID: 555
Received: 15/12/2023
Respondent: Dudley Group NHS Foundation Trust
Agent: Claremont Planning Consultancy
Policy DLP8 and Policy DLP9
3.1. The draft Plan recognises within Chapter 7 the importance of health and wellbeing as a key objective of the Council, with the Council’s aim to achieve healthy inclusive and safe places that support healthy lifestyles to be supported by the Plan. The local NHS Foundation Trust plays a key role in supporting health and wellbeing in the Borough, however the draft Plan fails to recognise this.
3.2. The emerging Plan through Policy DLP8 and DLP9 fails to recognise the role that development can play in securing investment in health infrastructure. The Land at Corbett Hospital, promoted on behalf of the Dudley Group NHS Foundation Trust and Charles Church Homes, was the subject of a planning application which sought to secure permission for residential development
under application reference P22/1050. Despite the application’s refusal, it is maintained that the site is suitable and available to accommodate a form of residential development. The land is surplus to the NHS requirements, and as a result was included on the register of public sector land available for disposal in 2017, offered firstly to public sector bodies before being offered to the open market, and anticipated disposal was expected during 2021/22. Whilst the disposal has been delayed by the Council’s refusal of planning permission, it remains the case that the NHS is obliged by the Government to secure the disposal of the site and secure ‘best value’ at the earliest opportunity. The land is owned freehold by the Dudley Group NHS Foundation Trust, and as a result, once secured, 100% of net proceeds of the sale of the land at Corbett Hospital would be spent on the Dudley health economy.
3.3. It is therefore considered that this section of the Plan should be reviewed to acknowledge the role that the NHS Trust plays locally in respect of health infrastructure and identify support for releasing surplus land to support investment and secure the delivery of much needed homes on surplus land in the urban area. In particular, the Plan could support these aims through allocating the site at Corbett Hospital for residential development, enabling the disposal of this site and release of funds needed locally to support improvements to local services and infrastructure.
Object
Part One: Spatial Strategy and Policies (Regulation 18)
Representation ID: 571
Received: 21/12/2023
Respondent: Charles Church Homes
Agent: Claremont Planning Consultancy
3.
Health and Wellbeing
Policy DLP8 and Policy DLP9
3.1.
The draft Plan recognises within Chapter 7 the importance of health and wellbeing as a key objective of the Council, with the Council’s aim to achieve healthy inclusive and safe places that support healthy lifestyles to be supported by the Plan. The local NHS Foundation Trust plays a key role in supporting health and wellbeing in the Borough, however the draft Plan fails to recognise this.
3.2.
The emerging Plan through Policy DLP8 and DLP9 fails to recognise the role that development can play in securing investment in health infrastructure. The Land at Corbett Hospital, promoted on behalf of the Dudley Group NHS Foundation Trust and Charles Church Homes, was the subject of a planning application which sought to secure permission for residential development
under application reference P22/1050. Despite the application’s refusal, it is maintained that the site is suitable and available to accommodate a form of residential development. The land is surplus to the NHS requirements, and as a result was included on the register of public sector land available for disposal in 2017, offered firstly to public sector bodies before being offered to the open market, and anticipated disposal was expected during 2021/22. Whilst the disposal has been delayed by the Council’s refusal of planning permission, it remains the case that the NHS is obliged by the Government to secure the disposal of the site and secure ‘best value’ at the earliest opportunity. The land is owned freehold by the Dudley Group NHS Foundation Trust, and as a result, once secured, 100% of net proceeds of the sale of the land at Corbett Hospital would be spent on the Dudley health economy.
3.3.
It is therefore considered that this section of the Plan should be reviewed to acknowledge the role that the NHS Trust plays locally in respect of health infrastructure and identify support for releasing surplus land to support investment and secure the delivery of much needed homes on surplus land in the urban area. In particular, the Plan could support these aims through allocating the site at Corbett Hospital for residential development, enabling the disposal of this site and release of funds needed locally to support improvements to local services and infrastructure.
Comment
Part One: Spatial Strategy and Policies (Regulation 18)
Representation ID: 680
Received: 25/01/2024
Respondent: NHS Property Services Ltd
We support the focus of Policy DLP8 on ensuring that development promotes healthy communities,
and the requirement for Health Impact Assessment (HIA) on significant residential developers of 150
units or more. The planning system is critical not only to the provision of improved health services
and infrastructure by enabling health providers to meet changing healthcare needs, but also to
addressing the wider determinants of health.
Identifying and addressing the health requirements of existing and new development is a critical way
of ensuring the delivery of healthy, safe, and inclusive communities. We recommend the Council
continues to engage with the NHS partners on this matter, and suggest that the Council takes the
following recommendations into account when preparing the Publication version of the Plan.
Specific policy requirements to promote healthy developments should include:
• Development proposals to consider local health outcomes.
• Design schemes to encourage active travel, including through providing safe and attractive
walking and cycling routes, and ensuring developments are connected by these routes to local
services, employment, leisure, and existing walking and cycling routes.
• Provide access to healthy foods, including through access to shops and food growing
opportunities (allotments and/or providing sufficient garden space)
• Design schemes in a way that encourages social interaction, including through providing front
gardens, and informal meeting spaces including street benches and neighbourhood squares
and green spaces.
• Design schemes to be resilient and adaptable to climate change, including through SUDs,
rainwater collection, and efficient design.
• Consider the impacts of pollution and microclimates, and design schemes to reduce any
potential negative outcomes.
• Ensure development embraces and respects the context and heritage of the surrounding area.
• Provide the necessary mix of housing types and affordable housing, reflecting local needs.
• Provide sufficient and high quality green and blue spaces within developments.
Comment
Part One: Spatial Strategy and Policies (Regulation 18)
Representation ID: 702
Received: 22/12/2023
Respondent: Canal and River Trust
Given our request elsewhere in this response, that the canal network’s contribution to the broader well-being agenda be explicitly included with the wording of Policy DLP36 - Canals, the Trust requests the incorporation of cross-referencing to Canal Policy DLP36 within the justifying text to text to this section and/or Policy DLP8 Health and wellbeing (ACTION REQUEST).
Support
Part One: Spatial Strategy and Policies (Regulation 18)
Representation ID: 775
Received: 21/12/2023
Respondent: National Trust
We welcome the acknowledgement that the Dudley Local Plan makes in respect of the impact of climate change on health and wellbeing in paragraph 7.4. it is our view that well resourced green infrastructure and publicly accessible open space could have a significantly positive impact on health and wellbeing, and this is part of our motivation in promoting the concept of the 8 Hills Regional Park.
We are supportive of the wording of policy DLP8, especially the need for mitigation or compensation for developments which would be likely to have a negative impact on health and wellbeing through planning conditions and/or financial/other contributions secured through planning obligations. Whilst it is not explicitly specified where such a financial contribution would be directed, given the benefits that publicly accessible open space can have towards health and wellbeing, we would expect that a proportion of the contributions go to the enhancement and maintenance of green infrastructure.
Support
Part One: Spatial Strategy and Policies (Regulation 18)
Representation ID: 834
Received: 19/12/2023
Respondent: Sport England
Support part 1 policy references. Suggest Sport England Active Design is referenced in the justification and evidence for this policy.
Request para 7.2 is amended to reference the role of infrastructure for sport and physical activity in addition to health infrastructure.
Request para 7.34 is amended to make a similar addition in relation to the built and natural environment.