Policy HW3 – Health Impact Assessments (HIAs) 

Support

Representation ID: 17545

Received: 11/10/2021

Respondent: Sport England

Sport England supports the policy to require HIA's for relevant development proposals in part 1) and the requirement to mitigate negative health impacts in part 2). We support the reference in para 5.34 to applying this to relevant infrastructure for physical activity, recreation and active travel, and would encourage the Authorities to develop further guidance to explain how this policy will be applied in practice.

Object

Representation ID: 18048

Received: 11/10/2021

Respondent: Brierley Hill Community Forum

We would urge that community impact statements should be introduced or, at least, incorporated as part of Health Impact statements in HW3, and that housing policies should be reviewed to put greater emphasis on balanced communities.

Comment

Representation ID: 19380

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 5.6 - "The policy and its supporting text refer to the 'sequential test'. It is unclear why the sequential test is being referred to in the context of the delivery of contributions towards healthcare whether it be on-site or off-site."

Comment

Representation ID: 19381

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 5.7 - Paragraph 5.32 in relation to viability of healthcare provision contradicts the claims in DEL1 about the sites being tested for viability and able to deliver policy requirements.

Comment

Representation ID: 21344

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

POLICY HW3 – HEALTH IMPACT ASSESSMENTS (HIAs): COMMENT
Policy HW3 requires development proposals to “demonstrate that they would have an acceptable impact on health and wellbeing through either a Health Impact Assessment (HIA) or Health Impact Assessment Screening Report.” Whilst the intention of that policy requirement is understood, the policy should clearly set out the threshold at which a HIA is required, to ensure consistency between planning applications.

Object

Representation ID: 43862

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

6.9 Policy HW3 requires development proposals to demonstrate that they would have an acceptable impact on health and wellbeing through either a Health Impact Assessment (HIA) or Health Impact Assessment Screening Report "where required in individual Local Planning Authorities’ local development documents, as specified in the relevant local development document".
6.10 This is not supported by Taylor Wimpey, as it does not provide clarity for applicants as to whether or not such an assessment is required. Furthermore, an assessment should only be required where there is genuine potential for a proposal to detrimentally impact upon health and wellbeing, rather than simply because such a document is listed in a validation checklist.

Object

Representation ID: 44762

Received: 03/10/2021

Respondent: Churchill Retirement Living and McCarthy Stone Retirement Lifestyles

Agent: Planning Issues

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.

Comment

Representation ID: 44933

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy HW3 - Health Impact Assessments

10.1 The justification text to Policy HW3 states that policy provides for the individual Black Country authorities to require Health Impact Assessments for development proposals, in line with locally determined criteria, to be set out in local development documents.

10.2 Part 2 of the policy states that where a development has significant negative impacts on health and wellbeing, the Council may require applicants to provide for mitigation.

10.3 As such impact assessments could be applicable to sites allocated in the BCP and may be needed to inform infrastructure provision on these sites, Taylor Wimpey considers that these criteria should be identified in the BCP rather than local development documents. This is the only way to ensure that the soundness of the policy can be properly tested and assessed through the
viability work which accompanies the plan.

Object

Representation ID: 44970

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

10.0 Policy HW3 - Health Impact Assessments
10.1 The justification text to Policy HW3 states that policy provides for the individual Black Country
authorities to require Health Impact Assessments for development proposals, in line with locally
determined criteria, to be set out in local development documents.
10.2 Part 2 of the policy states that where a development has significant negative impacts on health
and wellbeing, the Council may require applicants to provide for mitigation.
10.3 As such impact assessments could be applicable to sites allocated in the BCP and may be needed
to inform infrastructure provision on these sites, Taylor Wimpey considers that these criteria
should be identified in the BCP rather than local development documents. This is the only way
to ensure that the soundness of the policy can be properly tested and assessed through the
viability work which accompanies the plan.