Support

Representation ID: 932

Received: 21/11/2024

Respondent: Dennis R Whittaker

None.

Support

Representation ID: 994

Received: 26/11/2024

Respondent: Sport England

Sport England is pleased to see the amendments made to para 7.2 as requested, and to the inclusion of reference to our Active Design Guidance as relevant evidence for the policy.

Support

Representation ID: 1060

Received: 28/11/2024

Respondent: NHS Black Country Integrated Care Board

The Policy is supported and complies with the collaboration undertaken between the Black Country Integrated Care Board NHS Estates Team and Dudley Council Planning & Policy Team to arrive at the wording herein.

Object

Representation ID: 1077

Received: 28/11/2024

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? No

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.

Comment

Representation ID: 1247

Received: 29/11/2024

Respondent: Churchill Retirement Living

Agent: Planning Issues Ltd

This policy stipulates that some development proposals will need to demonstrate how they address any adverse health impacts through the submission of a health impact assessment.

Older Persons' Housing produces a large number of significant benefits which can help to reduce the demands exerted on Health and Social Services and other care facilities - not only in terms of the fact that many of the residents remain in better health, both physically and mentally, but also doctors, physiotherapists, community nurses, hairdressers and other essential practitioners can all attend to visit several occupiers at once. This leads to a far more efficient and effective use of public resources.

A report "Healthier and Happier' An analysis of the fiscal and wellbeing benefits of building more homes for later living" by WPI Strategy for Homes for Later Living explored the significant savings that Government and individuals could expect to make if more older people in the UK could access this type of housing. The analysis showed that: 'Each person living in a home for later living enjoys a reduced risk of health challenges, contributing to fiscal savings to the NHS and social care services of approximately £3,500 per year. Building 30,000 more retirement housing dwellings every year for the next 10 years would generate fiscal savings across the NHS and social services of £2.1bn per year. On a selection of national well-being criteria such as happiness and life satisfaction, an average person aged 80 feels as good as someone 10 years younger after moving from mainstream housing to housing specially designed for later living.'
Furthermore, sub-clause 2 e) requires a screening assessment for the loss of community facilities and public open space. There is a presumption against the loss of public open space and recreational facilities in national policy (Para. 97 of the NPPF) and in other emerging Local Plan policies (i.e. DLP16, 23, 26, 37, 38) unless it can be comprehensively demonstrated that these facilities are no longer required or have been replaced. There would accordingly appear to be a significant amount of overlap therefore between the evidence required for the loss of community facilities / open space and the Health Screening Assessment and we would respectfully ask the Council to consider if sub-clause 2 e) is necessary on that basis.
RECOMMENDATIONS:
For the future plan to be in line with national policy and effective the following wording should be included to recognise the health benefits of older persons housing.
Specialist Housing for older people has a number of health benefits and proposals for such schemes will not be required to submit a Health Impact Assessment

Support

Representation ID: 1283

Received: 27/11/2024

Respondent: Dudley Group NHS Foundation Trust

Number of people: 2

Agent: Claremont Planning Consultancy

The draft Policy DLP8 identifies that the Council will support developments that create an environment that promotes healthy communities, protects and improves the health and wellbeing of residents, and which reduces health inequalities. This is supported, recognising the importance of ensuring that new developments maximise opportunities to improve health and wellbeing. However, in this regard, it is considered that the Council should recognise the importance of securing indirect opportunities to enhance heath infrastructure, such as through the realisation of development on land that the NHS currently owns, but has identified as surplus to requirements. The sale of the land to facilitate its redevelopment for housing, will provide significant capital receipts that will be directly invested into local health infrastructure, which is demonstrably required to address the health inequalities identified by the emerging Plan. This should be a strong material consideration which supports the allocation of the land for housing in the emerging Plan.

The requirement identified within Policy DLP8 to provide health impact assessments for all planning applications over 150 dwellings / 5ha in size is queried however, as it appears to represent an arbitrary threshold that hasn’t been justified. If the Council is seeking health impact assessments for such developments, the policy and supporting text should clarify what the purpose of this is, and why it is considered appropriate, in order to ensure that the policies are justified and requirements set appropriately, in accordance with the tests of soundness set out in Paragraph 35 of the Framework.

Support

Representation ID: 1368

Received: 27/11/2024

Respondent: Charles Church Homes

Number of people: 2

Agent: Claremont Planning Consultancy

The draft Policy DLP8 identifies that the Council will support developments that create an environment that promotes healthy communities, protects and improves the health and wellbeing of residents, and which reduces health inequalities. This is supported, recognising the importance of ensuring that new developments maximise opportunities to improve health and wellbeing. However, in this regard, it is considered that the Council should recognise the importance of securing indirect opportunities to enhance heath infrastructure, such as through the realisation of development on land that the NHS currently owns, but has identified as surplus to requirements. The sale of the land to facilitate its redevelopment for housing, will provide significant capital receipts that will be directly invested into local health infrastructure, which is demonstrably required to address the health inequalities identified by the emerging Plan. This should be a strong material consideration which supports the allocation of the land for housing in the emerging Plan.

The requirement identified within Policy DLP8 to provide health impact assessments for all planning applications over 150 dwellings / 5ha in size is queried however, as it appears to represent an arbitrary threshold that hasn’t been justified. If the Council is seeking health impact assessments for such developments, the policy and supporting text should clarify what the purpose of this is, and why it is considered appropriate, in order to ensure that the policies are justified and requirements set appropriately, in accordance with the tests of soundness set out in Paragraph 35 of the Framework.

Support

Representation ID: 1402

Received: 21/11/2024

Respondent: National Trust

DLP8 Health and Wellbeing
We maintain support for 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.

Comment

Representation ID: 1474

Received: 29/11/2024

Respondent: Canal and River Trust

Repeat Regulation 18 request for the incorporation of cross referencing to Canal Policy DLP36 within the justifying text to this section and/or Policy DLP8 Health and Wellbeing.

Support

Representation ID: 1477

Received: 28/11/2024

Respondent: NHS Black Country Integrated Care Board

Agent: Winterburn Heritage & Planning

Policy DLP8 Health and Wellbeing
Planning Policies have a very important role to play in addressing these issues. The NPPF contains measures aimed at reducing health inequalities, improving access to healthy food and reducing obesity, encouraging physical activity, improving mental health and wellbeing, securing proposals that meet the needs of all sections of the community and improving air quality to reduce the incidence of respiratory diseases.

The design of the built environment can have a significant impact on both physical and mental wellbeing. Well-designed built environment can help to reduce health inequalities in Dudley; while poor environmental quality, housing conditions or pollution can exacerbate them.

Obesity is a major risk factor for several diseases such as Type 2 diabetes, cancer and heart disease. It can also affect people's mental health. The design of the built environment should encourage physical activity and healthier lifestyles which can help reduce obesity in both adults and children. New homes should be adaptable to the changing needs of their occupants and be designed with all community groups in mind, including, disabled and older people.

The ICB supports the use of Health Impact Assessments (HIAs) as a tool to ensure that impacts on health and wellbeing of the population are considered, and these should be properly encouraged at the planning and design stage. Early dialogue with the local planning authority (such as through pre-application advice) is therefore expected to help establish the extent and content of HIA. HIAs should be assessed by Dudley Council in consultation with the relevant Public Health Bodies and should be a material consideration in the planning application process.

The ICB therefore supports the aims and objectives of Policy DLP 8 parts 1 - 4

Support

Representation ID: 1505

Received: 29/11/2024

Respondent: NHS Property Services Ltd

Draft Policy DLP8 sets out the Council’s commitment to making sure that new developments promote healthier lifestyles and improve overall health and wellbeing. NHSPS welcomes and supports the inclusion of policies that support healthy lifestyles, and the requirement for a full Health Impact Assessment for developments of 100 or more dwellings or non-residential development that extends to 5,000sqm or more, and a rapid Health Impact Assessment for developments of 20 to 100 dwellings or non-residential development that extends from 1,000 - 5,000sqm. There is a well-established connection between planning and health, and the planning system has an important role in creating healthy communities. 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.