Object

Draft Black Country Plan

Representation ID: 44762

Received: 03/10/2021

Respondent: Churchill Retirement Living and McCarthy Stone Retirement Lifestyles

Agent: Planning Issues

Representation Summary:

This policy stipulates that some development proposals will need to demonstrate how they address any adcerse health impacts through the submission of a HIA, although the thresholds for doing so are not defined. HIA should be limited to:
1) Forms of development that result in acknowledged adverse impacts on health and well-being, such as hot food takeaways, betting shops and payday loan shops, should be required to submit a HIA.
2) B) Most of the questions in the Health Urban Planning Checklist which is in our experience the most frequently cited template by Las seeking HIA are only relevant to strategic development proposals and have little relevance to small and mid-sized developments.

We would advocate that the threshold for a HIA should be residential development in excess of 100 unit or forms of development in which there are clear issues of health and well-being, such as hot food takeaways and payday loan shops.
Recommendation:
Additional clarity on the thresholds for HIA should be provided in the Black Country Strategy. We would request that HIA’s are limited to developments with a clear detrimental impact on health and well-being and / or housing development in excess of 100 units.