Preferred Options 2025
9. A Healthy, Safe, and Inclusive South Warwickshire
Good planning is about more than just bricks and mortar. To deliver a healthy, safe and inclusive South Warwickshire, it is important to consider the less tangible aspects of planning which will enable healthy lifestyles and the development of strong communities.
Many aspects which impact on health, safety and inclusion are woven through other chapters of this document – for example, sections on infrastructure, design, and the natural environment all overlap with this overarching principle. This chapter contains sections on pollution and Health Impact Assessments.
9.1 Pollution
South Warwickshire is alive to matters of pollution, and actively monitors a number of pollutants, particularly those associated with emissions from road traffic. In South Warwickshire there are currently 4 Air Quality Management Areas where pollution levels are continually monitored to ensure levels fall below the national thresholds. Whilst the existing air quality management areas look at levels of pollutants associated with traffic, pollution can take many forms including chemical, dust, fumes, sound/noise, and light. Pollution in all its forms erodes the quality of the natural environment, as well creates negative impacts on human health, local economic growth and climate change.
The purpose of an overarching pollution policy is to ensure that where pollution is a reasonably foreseeable consideration, that this approach can be consistent. In the first instance development should avoid impact from pollution, however, where it cannot be avoided, then it is mitigated against once the harms are quantified.
What was said in the I&O
The Issues and Options asked whether the plan should include a policy on pollution, where the policy would cover 'all pollution', and ensure that where development would create significant detrimental impacts to the health and wellbeing of people in an area as a result of pollution, that the development would not be permitted unless effective mitigation could be achieved.
The Issues and Options highlighted very strong support for this policy, with 100% of total respondents wanting the inclusion of this policy.
Draft Policy Direction-29-Pollution
- Development should seek to minimise pollution and where possible contribute to the protection and improvement of the quality of air, land, and water. In achieving this, development should be designed from the outset to improve air, land and water quality and promote environmental benefits.
- Development that, on its own or cumulatively, would result in significant air, light, noise, dust, land, water or other environmental pollution or harm to amenity, health well-being, or safety will only be permitted if the potential adverse effects can be mitigated to an acceptable level, as set by the legal requirements or other environmental controls at the time of development, or by measures included in the proposals. It should also be ensured that new development proposals do not have an adverse impact on existing operations.
- Development that would lead to deterioration or may compromise the ability of a water body or underlying groundwater to meet good status standards required by the Water Framework Directive will not be permitted.
- Areas which are within Air Quality Management Areas (areas where air quality is a particular issue) will be protected, requiring air quality assessments, and where necessary, a mitigation plan that will need to demonstrate that practical and effective measures have been taken to avoid any adverse impacts.
Do you agree with the approach laid out in Draft Policy Direction-29-Pollution? Comment
Justification
A pollution policy is required to help address the council's climate and ecological emergency declarations, as well as ensure that development is not permitted where it may pose unacceptable levels of risks to the health of people and/or the natural environment.
In England there are regulations relating to the air pollutant fine particulate matter (PM2.5), which is of most harm to human health. The Environmental Targets (fine particulate matter) (England) Regulations 2023 set two PM2.5 targets requiring that:
- The annual mean concentration is 10 µg m-3 or lower.
- That the population exposure is reduce by 35% compared to the base year 2018 levels.
The NPPF emphasises that planning policies and decisions should contribute to, and enhance, the natural environment. This should be done by preventing new and existing development from contributing to, or being adversely affected by, unacceptable levels of soil, air, water, or noise pollution (paragraph 174). As well as this, it is important that planning decisions should be compliant with relevant limit values or national objectives for pollutants, considering Air Quality Management Areas and Clear Air Zones (paragraph 186).
The NPPF makes clear that any new development in Air Quality Management Areas and Clean Air Zones should be consistent with the local air quality action plan.
9.2 Health Impact Assessment for Major Development
National Planning Policy Guidance refers to Health Impact Assessments (HIAs) as a useful planning tool as they can help to address any major impacts that major development proposals may have on the health and wellbeing of the population. This is also backed up by recent National Government Guidance published in 2020 on the use of Health Impact Assessments.
A HIA is a process that identifies the health and wellbeing impacts (benefits and harms) of any plan or development project. A properly conducted HIA recommends measures to maximise positive impacts; minimise negative impacts; and reduce health inequalities. HIAs put people and their health at the heart of the planning process. An HIA supports the planning system to address local health and wellbeing needs and tackle inequalities though influencing the wider determinants of health which are a diverse range of social, economic and environmental factors.
A HIA should appraise the potential positive and negative impacts of a proposal on new communities and adjacent existing communities, identify any differential distribution of impacts on health among groups within the population, and suggest actions to minimise any potential negative health impacts and maximise potential positive health impacts.
HIAs can be a freestanding report, or they can be incorporated into another required appraisal, such as an Environmental Impact Assessment, to avoid duplication. Where HIA is integrated into another assessment, it is recommended that a separate chapter is included in the assessment on health impacts, with cross-referencing to other relevant chapters, such as transport, noise, and air quality.
What was said in the I&O
Question W2 asked whether a Health Impact Assessment (HIA) should be required for all major developments. There was strong support for a HIA policy from individual respondents, but concern expressed by developers/landowners in relation to the perceived costs and little benefit. The submissions encouraged flexibility for any HIA requirement, rather than a blanket approach - via a screening process and/or only requiring a HIA to appropriate major planning applications.
Draft Policy Direction-30- Health Impact Assessment for Major Development
All major development (proposals, and developments resulting in the loss of educational, health, leisure and community facilities, or public open space, will be required to demonstrate that they would have an acceptable impact on health and wellbeing. This should be demonstrated through a:
- Health Impact Assessment Screening Report which demonstrates that the proposed development would not overall give rise to negative impacts in respect of health and wellbeing; or
- Health Impact Assessment where significant impacts on health and wellbeing would arise from that proposal.
The policy will require a HIA of development proposals to a level of detail appropriate to its scale and nature and addressing the relevant elements of healthy design.
Developments which have a significant negative impact on health and wellbeing will not be supported where applicants cannot provide mitigation of, or compensation for such impacts through planning conditions and/or financial/other contributions secured through planning obligations.
Do you agree with the approach laid out in Draft Policy Direction-30- Health Impact Assessment for Major Development? Comment
Justification
Proposals for major development, or other proposals with the potential to generate significant negative effects on the mental and physical health and wellbeing of communities, should provide an assessment of their potential impacts through the use of health impact assessments, as set out in the policy.
The NPPF promotes the role of planning to create healthy and safe communities by supporting local strategies to improve health, social and cultural wellbeing for all. It also encourages applicants to engage early and proactively with the community and other consultees. It states that planning policies and decisions should aim to achieve healthy, inclusive and safe places which promote social interaction, are safe and accessible and enable and support healthy lifestyles. Additional national planning guidance highlights the importance of planning in improving health and wellbeing and states that a health impact assessment is a useful tool to use where there are expected to be significant impacts.
The Stratford District Council Plan 2023-2027 has health and wellbeing as one its key areas and states that "health and wellbeing will be at the heart of the decisions we make". The Warwick District Council Corporate Strategy 2030 includes "creating vibrant, safe and healthy community of the future" in its top 3 priorities.
Moving forward from Preferred Options, the SWLP authorities will liaise with Warwickshire Public Health in using the London Healthy Urban Development Unit (HUDU) in assessing HIA applications. https://assets.publishing.service.gov.uk/media/5a7c0c6eed915d01ba1cacfe/dh_120106.pdf
Do you broadly support the proposals in the A Healthy, Safe, and Inclusive South Warwickshire chapter? If you have any additional points to raise with regards to this chapter please include them here. Comment
