Policy HW1 – Health and Wellbeing 

Support

Representation ID: 21244

Received: 11/10/2021

Respondent: Newlands Developments

Health and Wellbeing (Section 5)
Draft Policy HW1 (Health and Wellbeing) provides a strategic context for how health and wellbeing is influenced by planning. We are supportive of this draft policy, particularly as it aligns with the requirements of NPPF Paragraph 92 as it aims to achieve healthy, inclusive and safe places which promote social interaction, are safe and accessible, and enable and support healthy lifestyles to address identified local health and wellbeing needs.

Part F of Draft Policy HW1 advises that the regeneration and transformation of the Black Country should provide a range of quality employment opportunities for all skill sets and abilities along with the education and training facilities to enable residents to fulfil their potential and support initiatives to promote local employment and procurement during construction.

The development will provide job opportunities during both the construction and operational phases. This will ensure that the development accords with the aims of Draft Policy HW1 in achieving a healthy, inclusive and safe development to address identified local health and wellbeing needs.

Comment

Representation ID: 21480

Received: 11/10/2021

Respondent: Charles Church Homes

Agent: Claremont Planning Consultancy

4. Health and Wellbeing

Policy HW1 – Health and Wellbeing

4.1. This policy seeks to ensure that regeneration and transformation of the Black Country will create an environment that protects and improve the physical, social and mental health and wellbeing of residents. As part of this, it provides a list of requirements that should be delivered through new developments, including enabling active and healthy lifestyles, providing a range of housing types and tenures, and be designed with residential amenity and health and wellbeing in mind. It is considered reasonable to expect new developments to respect these requirements and these will be delivered through the proposed development on land at Corbett Hospital.

4.2. Importantly, as part of this policy it establishes that developments should ‘protect and include a range of social infrastructure such as social care, health, leisure, sport and recreation…. close to where people live’. Unlocking residential development on land at Corbett Hospital will directly contribute towards achieving this objective, by realising capital receipts for the NHS through the disposal of this surplus land. There is a mandate that 50% of this capital receipt is to be reinvested in the local health economy, thereby ensuring that local people will directly benefit from delivery of the development. If the Plan seeks to constrain the ability to secure development on the site through the proposed allocation as Local Green Space, this will have a detrimental impact in

respect of the realisation of capital receipts and accordingly reduce the potential for investment to be secured for local health developments. This will directly conflict with the objective of Policy HW1, and the wider aims of the emerging BCP.

4.3. Furthermore, it is considered that by seeking to resist development on the site, the authorities will be restricting the potential for development in a highly sustainable location within the urban area. This could, to a degree, reduce the need for development to be delivered in less sustainable locations either within the Borough or in neighbouring authorities, which should be a key consideration for the Plan and the need to ensure that it is consistent with national policy aims of achieving sustainable development. Ensuring that development is directed to appropriate locations such as this is a consideration for Policy HW1 specifically, as by securing development within the urban area it is more likely that future residents will be able to utilise active and environmentally sustainable forms of travel for accessing places of work, education and day-to- day services and facilities

Comment

Representation ID: 21491

Received: 11/10/2021

Respondent: Dudley Group NHS Foundation Trust

Agent: Claremont Planning Consultancy

4. Health and Wellbeing

Policy HW1 – Health and Wellbeing

4.1. This policy seeks to ensure that regeneration and transformation of the Black Country will create an environment that protects and improve the physical, social and mental health and wellbeing of residents. As part of this, it provides a list of requirements that should be delivered through new developments, including enabling active and healthy lifestyles, providing a range of housing types and tenures, and be designed with residential amenity and health and wellbeing in mind. It is considered reasonable to expect new developments to respect these requirements and these will be delivered through the proposed development on land at Corbett Hospital.

4.2. Importantly, as part of this policy it establishes that developments should ‘protect and include a range of social infrastructure such as social care, health, leisure, sport and recreation…. close to where people live’. Unlocking residential development on land at Corbett Hospital will directly contribute towards achieving this objective, by realising capital receipts for the NHS through the disposal of this surplus land. There is a mandate that 50% of this capital receipt is to be reinvested in the local health economy, thereby ensuring that local people will directly benefit from delivery of the development. If the Plan seeks to constrain the ability to secure development on the site through the proposed allocation as Local Green Space, this will have a detrimental impact in

respect of the realisation of capital receipts and accordingly reduce the potential for investment to be secured for local health developments. This will directly conflict with the objective of Policy HW1, and the wider aims of the emerging BCP.

4.3. Furthermore, it is considered that by seeking to resist development on the site, the authorities will be restricting the potential for development in a highly sustainable location within the urban area. This could, to a degree, reduce the need for development to be delivered in less sustainable locations either within the Borough or in neighbouring authorities, which should be a key consideration for the Plan and the need to ensure that it is consistent with national policy aims of achieving sustainable development. Ensuring that development is directed to appropriate locations such as this is a consideration for Policy HW1 specifically, as by securing development within the urban area it is more likely that future residents will be able to utilise active and environmentally sustainable forms of travel for accessing places of work, education and day-to- day services and facilities

Support

Representation ID: 22273

Received: 21/01/2022

Respondent: Miss Jodi Stokes

5.0 HEALTH AND WELLBEING

5.1 Draft Policy HW1 (Health and Wellbeing) provides a strategic context for how health and wellbeing are influenced by planning and provides links to other policies in the Black Country Plan. We agree this strategic policy is important in order to support strong, vibrant and healthy communities with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being and the ‘social’ objective of sustainable development. It also reflects chapter 8 of the NPPF.

5.2 Part C of draft Policy HW1 requires that new developments, where relevant, provide a range of housing types and tenures that meet the needs of all sectors of the population including for older people and those with disabilities requiring varying degrees of care; extended families; low income households; and those seeking to self-build as set out in Polices HOU2 and HOU3. Part F refers to the provision of a range of quality employment opportunities for all skillsets and abilities along with the education and training facilities to enable residents to fulfil their potential and support initiatives to promote local employment and procurement during construction as set out in Policies HOU5, EMP2, EMP3 and EMP5. Whilst we agree that all of the requirement’s a-k are important to improving local health and wellbeing, we consider that the provision of a mix of housing and access to employment to be particularly important and agree they will form a key part in improving the wider social, economic and environmental circumstances that determine land. This highlights why the provision of land locally to meet current and future housing and employment needs, is particularly important to local people.

Comment

Representation ID: 22350

Received: 11/10/2021

Respondent: Canal & River Trust

The Trust welcomes the policy aspiration for regeneration of the Black Country to support an environment that protects and improves the physical, social and mental health and wellbeing of its residents, employees and visitors and reduces health inequalities, including by protecting, enhancing and providing new green and blue infrastructure. We believe that the canal network has a significant role to play in this regard, whether it be through offering a place for recreation, a route for sustainable travel or a focal point for community engagement, skills development or volunteering. Research by Simetrica carried out for the Trust has demonstrated the wellbeing benefits of spending time by our waterways. Through protecting and enhancing the quality and accessibility of the canal network, we believe that it can deliver more wellbeing benefits for residents of the Black Country.

We would hope to see green and blue infrastructure properly considered in Health Impact Assessments required under policy HW3.

Comment

Representation ID: 22620

Received: 29/09/2021

Respondent: Chief Constable of West Midlands Police (CCWMP)

Agent: Tyler-Parkes

The Tyler Parkes Partneship Ltd act for the Chief Constable of West Midlands Police (CCWMP).

This Comments Form TOGETHER WITH the accompanying letter dated 29th September 2021 comprise the CCWMP's representations on Policy HW1.

The CCWMP considers it is appropriate for the Health and Wellbeing Introduction to state that the Black Country authorities have the ‘key objective’ of, ‘…Ensuring a healthy and safe environment that contributes to people’s health and wellbeing…’ (paragraph 5.3). Reducing crime, anti-social behaviour and the fear of crime are fundamental to creating a safe environment which will contribute towards people’s health and well-being.

The CCWMP therefore welcomes the wording of Policy HW1 paragraph a. which requires where relevant, for all new development to be ‘inclusive, safe, and attractive, with a strong sense of place; encourage social interaction; and provide for all age groups and abilities as set out in Policies CSP4, ENV5, ENV6, ENV8 and ENV9.’ whilst also promoting road safety.

Comment

Representation ID: 22634

Received: 11/10/2021

Respondent: National Highways

Health and Wellbeing
We support the HW1 policy which outlines the requirement for new development to
ensure access by inclusive, active, and environmentally sustainable form of travel and
through promoting road safety and managing the negative effects of road traffic, and look
forward to working with the authorities to facilitate such travel where interface with the
SRN occurs.
National Highways is committed to continue to work with the Black Country authorities in
a collaborative and constructive manner to support the progression of the Black Country
Plan. As part of this approach we will work with you to develop a greater understanding
of the impact of development allocated within the draft plan on the SRN.
We trust that the above is useful in the progression of the Black Country Plan and
welcome continued discussions with the Council to this end.

Comment

Representation ID: 23147

Received: 11/10/2021

Respondent: Black Country UNESCO Global Geopark Partnership

Agent: Black Country UNESCO Global Geopark Partnership

We think that section 5 is particularly important for the future development of the Black Country and the health and happiness of its residents and visitors. We welcome that Geopark and other Environmental policies so strongly cross referenced here. We concur and support many of the generic statements of paragraphs 5.7 to 5. 13.

We would however recommend that para’s 5.12, 5.16 and 5.22 also include a specific bullet point/statement that highlights the specific importance of accessible natural and cultural places to wellbeing as these are increasingly being prescribed by health professionals for mitigating poor mental and physical health issues.

Comment

Representation ID: 23240

Received: 11/10/2021

Respondent: Member of Parliament

The importance of Green Belt and Green Open Spaces came to the fore at the start of the Covid-19 pandemic, when people being allowed to go out for exercise for one hour per day supported personal health and wellbeing. Whilst none of us will wish to go back into such stringent lockdown arrangements ever again it did open our eyes to the importance of open spaces and the natural beauty of the environment which exists around us. Another point overlooked in the current Plan is that of the wider environment and the impact of this Plan on woodland, hedges, natural habitats and the loss of valuable far land currently used for food production.

Support

Representation ID: 23418

Received: 15/02/2022

Respondent: L&Q Estates

Agent: Barton Willmore

6.1 Draft Policy HW1 (Health and Wellbeing) provides a strategic context for how health and wellbeing is influenced by planning. We are supportive of this draft policy, particularly as it aligns with the requirements of NPPF Paragraph 92 as it aims to achieve healthy, inclusive and safe places which promote social interaction, are safe and accessible and enable and support healthy lifestyles to address identified local health and wellbeing needs.

6.2 Part C of Draft Policy HW1 advises that new developments that provide a range of housing types and tenures that meet the needs of all sectors of the population, including for older people and those with disabilities requiring varying degrees of care; extended families; low-income households; and those seeking to self-build, will create an environment that protects and improves the physical, social and mental health and wellbeing of its residents, and reduces health inequalities

Comment

Representation ID: 23468

Received: 11/10/2021

Respondent: Birchills Agenda 21 Group

Number of people: 339

The lack of appropriate evidence base is
concerning, given that the Council is, and has included, large parts of the Reedswood area (which contains sensitive public open space areas, including Reedswood Town Park) within a so called 'Core Regeneration Area".
This will result in the loss of sensitive public open space areas from the Reedswood area. Walsall Council is encouraging damaging patterns of development within the local area, which will result in a shortage of public open space for local residents to enjoy, to help support more physically active healthy lifestyles.

The Walsall Metropolitan Borough has some of the worst health data within the whole of the United Kingdom. Such as high numbers of childhood and adult obesity cases, a prevalence of Type 2 Diabetes, strokes etc. Walsall Council's planning approach within the Reedswood area of Walsall will make the situation a lot worse.

The situation is concerning and very alarming.

The green space provides an accessible natural green space area located on the doorstep of residential communities within the Reedswood area. It forms a critically important public open space area.

The Coronavirus (Covid-19) global pandemic has shown how important these local nearby natural green space areas are to the health and wellbeing of local communities as they help to support more physically active healthy lifestyles, and tackle the obesity pandemic currently affecting the Walsall area. The Coronavirus
pandemic has highlighted the increased relevance of green space to health.

In my opinion, these "pandemic-related factors" have been given an insufficient level of material planning weight by Walsall Council in its approach to spatial town
planning taken within the wider Reedswood area of Walsall. The Council's position is insufficiently robust and unsound.

5) In accordance with central Government (London) national planning guidance in paragraph 174 (indent e) of the Revised National Planning Policy lung containing areas of mature and semi-mature broadleaved woodland
it therefore helps to mitigate the effects of very fine particulate harmful air pollution from the heavily congested M6 motorway network. By helping to filter-out, remove and reduce harmful levels of air pollution from vehicular traffic using the adjacent congested M6 motorway network, this urban green space area therefore helps to play a fundamental role in helping to protect the
health of thousands of local residents living within the wider Reedswood area.

As local residents, we have a fundamental Legal right to 'Clean Air'. This Legal Right is supported within the European Convention on Human Rights (The Human Rights Act) and should therefore be identified and respected within the emerging Black Country Plan (Review). On this basis, the Pouk Hill green space area 'Urban Green Lung Air Quality Enhancement Benefits'
should therefore be specifically identified and shown as an 'Urban Green Lung Air Quality Enhancement' designation on the main Policies Map of the emerging Black Country Plan (BCP) (Review). This special designation should also cover the area of urban green space located on the opposite side of the M6 motorway network, bordering the Jane Lane Primary School and
Churchill Road. These important urban green space buffers on both sides of the M6 are critically important to the health and well-being of thousands of local residents for the reasons explained above.

Comment

Representation ID: 43860

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

6.1 Policy HW1 states that the regeneration and transformation of the Black Country will protect and improve the health and wellbeing of its residents and reduce health inequalities. It then sets out a number of criteria which will assist in this objective (where relevant), and it includes providing a range of housing types and tenures that meet the needs of all sectors of the population. It includes delivery of employment opportunities and social infrastructure including sport and recreation facilities. To do this new green and blue infrastructure will be provided and this could include allotments and gardens. Taylor Wimpey supports these objectives, although it should be made abundantly clear that not all of the criteria listed are relevant to every proposal.
6.2 In addition, it should be recognised that some of the NGAs provide the opportunity to make a significant difference in regard to provision of both green and blue infrastructure and this would be available not only to new residents within the development but also existing residents in areas where there may be little alternative existing provision. This represents a significant benefit of such development and could be identified in Policy HW1 or its supporting text. Similarly, it could also be referenced within the specific policies dealing with the NGAs.

Object

Representation ID: 43916

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.38 As discussed in response to Policy DEL1, it is important that policies within the BCP do compromise the viability and deliverability of new developments, particularly in respect of the need for and delivery of onsite infrastructure. To ensure HW1 takes a consistent approach to viability with other policies in the plan, part j. of the policy would benefit from cross referencing draft policy DEL1 which sets out the tests for viability.
3.39 The proposals would create 153 jobs during construction, including 11 apprenticeships for every year of construction. Beyond this 215 indirect jobs would be created during construction.

Comment

Representation ID: 43934

Received: 11/10/2021

Respondent: IM Land

Agent: Turley Assocs

Policy HW1 (health and wellbeing)
3.36 As discussed in response to Policy DEL1, it is important that policies within the BCP do
compromise the viability and deliverability of new developments, particularly in
respect of the need for and delivery of onsite infrastructure. To ensure HW1 is takes a




11

consistent approach to viability as other policies in the plan it part j. of the policy would
benefit from cross referencing draft policy DEL1 which sets out the tests for viability.
3.37 In terms of providing employment for all skill sets and abilities, it is estimated that
during construction the proposed development will support 120 gross direct FTE jobs
per annum for circa 10 years, and 85 net additional direct FTE jobs and 45 indirect /
induced FTE jobs in the wider region. Once complete it will support 80 FTE jobs on site
in a range of roles and skill levels, and 190 jobs in retail and leisure businesses annually.
3.38 IM Land is also committed to working with the community to provide enhanced
training opportunities as part of its legacy. This will be explored further.

Object

Representation ID: 44761

Received: 03/10/2021

Respondent: Churchill Retirement Living and McCarthy Stone Retirement Lifestyles

Agent: Planning Issues

Policy HW1: Health & Wellbeing
We welcome the Council's commitment to the health and wellbeing of its residents. As detailed in our representation to Policy HOU 2 the demographic profile of the Black Country is ageing with the SHMA identifying a requirement for 4,907 additional units of sheltered housing and 604 units of extra care accommodation by 2039.
An ageing population inevitably results in an increase in frail individuals and persons with long term health issues. There is a commensurate pressure on care and health services accordingly with many local authorities spending over a third of their budgets on adult social care currently.
It is well established that poor housing can exacerbate health problems in old age, with enormous resultant costs to the NHS and social care. For example:
Falls - Public Health England statistics show that in 2017/18 falls accounted for 335,000 hospital admissions in England of people aged 65 and over.
Cold Homes - Millions of older people in the UK are living in homes that are too cold. A cold home can cause chronic and acute illnesses and lead to reduced mobility, falls and depression.
Social Isolation - 1.5 million people aged 50 and over are always or often lonely, researchers have calculated. Loneliness makes it harder for people to regulate behaviours such as drinking, smoking, and over-eating, which in turn have their own significant negative outcomes.
Specialist older persons' housing has been developed with the needs of the elderly in mind, enabling them to remain independent for longer. These homes are designed to be warm and with features to alleviate the physical impact of ageing (such as level access throughout) and offer opportunities for residents to access support, care, and companionship. The recently published Healthier and Happier Report by WPI Strategy (September 2019) calculated that the average person living in specialist housing for older people saves the NHS and social services £3,490 per year.
The respondents commend the Council for recognizing the key role that specialist older persons' housing plays in the health and well being of the Black Country within sub-clause c) of this Policy. We are however concerned that the housing needs of the elderly are not considered within the housing policies which is addressed in our representations to Policy HOU2.

Comment

Representation ID: 44928

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy HW1 - Health and Wellbeing

8.1 Policy HW1 is generally supported. However, it is considered that the aim of achieving “affordable warmth” in part (d) of the policy is vague and it is not clear what developers would need to do to meet this requirement. The policy as drafted conflicts with the Framework §16 (d) as it is not evident how a decision maker should react to development proposals

Comment

Representation ID: 44968

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

8.0 Policy HW1 - Health and Wellbeing
8.1 Policy HW1 is generally supported. However, it is considered that the aim of achieving
“affordable warmth” in part (d) of the policy is vague and it is not clear what developers would
need to do to meet this requirement. The policy as drafted conflicts with the Framework §16 (d)
as it is not evident how a decision maker should react to development proposals
8.2 It is therefore considered that the text “and achieve affordable warmth” should be deleted from
the policy.

Object

Representation ID: 45866

Received: 11/10/2021

Respondent: St Modwen Developments Ltd

Agent: Planning Prospects Ltd

5. OTHER MATTERS


5.1 This section of the representations addresses other matters within the Draft BCP which fall outside the central issues around residential land, the Green Belt, and the opportunities to meet development need considered elsewhere.

Comments on: Policy HW1 – Health and Wellbeing


Nature of comment: Objection


5.2 The objective as summarised in the opening paragraph of this policy is appropriate.

However, the parts that follow (parts a) to k)) are lengthy, unwieldy, and do little more than direct the reader to other policies in the plan. A number of those other policies are themselves very lengthy. Compliance with these (as all) policies is to be expected and would lead to a positive outcome from a health and wellbeing perspective.

5.3 To remedy this, parts a) to k) of Policy HW1 should be deleted.

Comment

Representation ID: 47037

Received: 13/09/2022

Respondent: HIMOR

Agent: Turley Associates

As discussed in response to Policy DEL1, it is important that policies within the BCP do not compromise the viability and deliverability of new developments, particularly in respect of the need for and delivery of onsite infrastructure. To ensure HW1 takes a consistent approach to viability with other policies in the plan, part j. of the policy would benefit from cross referencing draft policy DEL1 which sets out the tests for viability.

In terms of providing employment for all skill sets and abilities, it is estimated that during construction the proposed development will support 45 gross direct FTE jobs per annum for circa 7 years, and 40 net additional direct FTE jobs and 20 indirect / induced FTE jobs in the wider region. Once complete it will likely provide homes for 78- people of employment age, and 60 jobs in retail and leisure businesses annually.