Q-W4: Please add any comments you wish to make about a healthy, safe and inclusive South Warwickshire

Q-W3: Please select the option which is most appropriate for South Warwickshire Sport England would strongly support the provision of an overall strategic policy on health. The provision of the policy should focus both on informal and formal activities, which would assist in promoting an active environment. The policy should also seek to maximise and make more effective use of sites that provide community services such as schools through community use agreements, where this would help to meet identified needs as identified within the Council’s strategic evidence base documents related to indoor and outdoor sports provision. Q-W4: Please add any comments you wish to make about a healthy, safe and inclusive South Warwickshire In line with National Planning Policy Framework paragraph 98 local plan policies should be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision. Information gained from the assessments should be used to determine what open space, sport and recreational provision is needed, which plans should then seek to accommodate. As such, Sport England would advocate that the SWLP (as per paragraph 1.8 of consultation document) is informed by an up to date Playing Pitch Strategy and Built Facilities Strategy which would consider current and future demand up to 2050. The findings of these Strategies should then be incorporated into the strategic policies contained within the plan i.e. informing playing pitch needs for strategic housing allocations or a sporting/recreation allocation. It should be noted that Sport England’s has planning tools and guidance’s related to the assessing the demand generated from development sites for indoor and outdoor sports provision, which together with the aforementioned strategies will help inform best way to meet the identified needs. Whilst noting the consultation document reasoning as to why Public Open Space is not considered to be a strategic issue to be addressed within part 1 of the Local Plan, Sport England considers that the provision of open spaces plays a key role in meeting a number of South Warwickshire’s Sustainable Development Needs objectives. Access to open spaces is highlighted in a number of sections within the consultation document as such it should be made clear how this will be achieved in the Local Plan as this will help to inform the strategic housing allocations.

Q-W1. Should the Part 1 plan include a policy on pollution? Yes. In the context of the Cotswolds National Landscape, two particularly relevant issues and light pollution and noise pollution, as these adversely affect the dark skies and tranquillity of the National Landscape, which are two of the area’s ‘special qualities’. The policy on pollution should explicitly address these two forms of pollution. The supporting text should explicitly address the relevance / significance of these two forms of pollution in relation to the Cotswolds National Landscape. The issue of tranquillity and dark skies are addressed in Policies CE4 and CE5, respectively of the Cotswolds AONB Management Plan 2018-2023,38 which provides some useful wording in relation to noise and light pollution. They are also addressed in the Board’s position statements on: (i) tranquillity39;and (ii) dark skies and artificial light40. We recommend that the supporting text for the pollution policy should explicitly refer to these two position statements. With regards to road traffic, we recommend that the supporting text for the pollution policy should explicitly refer to the ‘Guidelines for the Assessment of Road Traffic’, in particular, the two ‘rule of thumb’ thresholds specified in paragraph 3.1 for Environmental Impact Assessments: 1. Where traffic flows will increase by more than 30% (or the number of heavy goods vehicles will increase by more than 30%). 2. Sensitive areas where traffic flows have increased by 10% or more. In other words, the policy should specify that an EIA would normally be required where a proposed development would result in an increase in traffic flows that exceed these thresholds. In this context, the Cotswolds National Landscape should be treated as a ‘sensitive area’. The Board has addressed this issue in it’s Tranquillity Position Statement which applies the following thresholds:41 . Rule 1: Where traffic flows will increase by more than 30% (or the number of heavy goods vehicles (HGVs) will increase by more than 30%). . Rule 2: Any other sensitive areas where traffic flows have increased by 10% or more. 38 Cotswolds National Landscape Board (2018) Cotswolds AONB Management Plan 2018-2023. Policies CE4 and CE5. 39 Cotswolds National Landscape Board (2019) Tranquillity Position Statement. 40 Cotswolds National Landscape Board (2019) Dark Skies and Artificial Light Position Statement 41 Cotswolds National Landscape Board (2019) Tranquillity Position Statement. Section 4.5. Q-W4. Please add any comments you wish to make about a healthy, safe and inclusive South Warwickshire. The Local Plan should make explicit reference to Natural England’s new Green Infrastructure Framework42 and, ideally, require development to comply with the standards and other guidance that is set out in the Framework. 42 https://designatedsites.naturalengland.org.uk/GreenInfrastructure/Home.aspx

As set out in Para 7 of the NPPF and reflected within the vision for the sub region, the purpose of planning is to achieve sustainable development which is underpinned by three overarching objectives, of which one is a social objective. Included within this is the need to ensure 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 (Lichfields emphasis added). Housing underpins this objective of the NPPF by being the key factor in delivering welldesigned, safe places, and Cala therefore supports the requirement for some form of health policy that will require the design of new developments to have appropriate regard to the health and safety of future residents.

Comment: W2a. Support. Warwickshire Local Transport Plan - Key themes consultation, January 2021, points out, transport emissions account for 28,000-35,000 premature deaths pa in the UK. As a council that has declared a Climate change emergency, its transport policies need to be radically changed accordingly, so that alternatives to road construction are prioritised. As stated, Road transport is responsible for 80% of Nitrogen Dioxide emissions and rail just 1.6%, yet the District and County Councils are still focussed on road transport as its transport investment priority. Investment in rail over major road investment needs to be a key policy change in the South Warwickshire Local Plan. Road traffic currently accounts for 72% of total greenhouse gas (GHG) emissions from transport (73% of passenger-kilometres), aviation accounts for 14% (8% of passenger-kilometres), and rail accounts for less than 1% (6% of passenger-kilometres).* * European Environment Agency (2019), ‘Share of transport greenhouse gas emissions’, data visualization.

Q W.1 Should the Part 1 plan include a policy on pollution? Yes. In August last year, the United Nations General Assembly declared that everyone on the planet has a right to a healthy environment, including clean air, water and a stable climate. The Clean Air (Human Rights) Bill is being considered by the UK government to ensure the government takes action to bring air quality in every community up to World Health Organisation minimum standards PM 2.5 Air Pollutants on Henley High street already exceed WHO guidelines. Further development will increase congestion and pollution. Uptake of electric vehicles is slow so it is questionable that this will significantly mitigate this in our lifetimes. So yes, pollution should absolutely be taken into account. W4 There is great concern that there appears to little reassurance in terms of planning, resources and funding that shows local authorities will meet the additional needs of local populations where significant expansion of these populations are made. This will result in the reduction of access to preventative medicine at both a personal and population level. On top of this on-going care of chronic disease will be negatively impacted. These services would need to be in place prior to any planning consideration. There appears to be no identification of access to A&E or minor accident units. Henley residents are required to make over 30 minute car journeys to reach any facility.

Q W.1 Should the Part 1 plan include a policy on pollution? Yes. In August last year, the United Nations General Assembly declared that everyone on the planet has a right to a healthy environment, including clean air, water and a stable climate. The Clean Air (Human Rights) Bill is being considered by the UK government to ensure the government takes action to bring air quality in every community up to World Health Organisation minimum standards PM 2.5 Air Pollutants on Henley High street already exceed WHO guidelines. Further development will increase congestion and pollution. Uptake of electric vehicles is slow so it is questionable that this will significantly mitigate this in our lifetimes. So yes, pollution should absolutely be taken into account. QW4 There is great concern that there appears to little reassurance in terms of planning, resources and funding that shows local authorities will meet the additional needs of local populations where significant expansion of these populations are made. This will result in the reduction of access to preventative medicine at both a personal and population level. On top of this on-going care of chronic disease will be negatively impacted. These services would need to be in place prior to any planning consideration. There appears to be no identification of access to A&E or minor accident units. Henley residents are required to make over 30 minute car journeys to reach any facility.

Issue W1: Pollution: The plan currently considers air quality impacts on human health. But air quality is also significant threat to biodiversity. Many designated sites in Warwickshire receive damaging rates of air pollution, especially ammonia and nitrogen deposition. The plan should specifically address air quality impacts on designated sites. Commonly encountered air quality impacts to designated sites are associated with increased traffic resulting from housing development and industrial development, or from intensive agriculture proposals. The local plan HRA should assess the air quality impacts of increasing road traffic according to Natural England’s guidance document NEA001 (http://publications.naturalengland.org.uk/publication/4720542048845824). The plan should also consider the impacts of agricultural air pollution. It would be helpful if the plan could consider whether a Site Nitrogen Action Plan (SNAP) would be beneficial in alleviating some of the impacts - if indeed relevant to this next planning phase in Warwickshire. We encourage the Plan makers to keep abreast of and consider the ongoing developments that relate to Developing the UK Emissions Trading Scheme consultation and the Mission Zero Independent Review of Net Zerov- Review of Net Zero - GOV.UK (www.gov.uk) (https://www.gov.uk/government/publications/review-of-net-zero) Yes - we feel the Plan should begin to accommodate any policy development on Air Quality, for both human health and biodiversity, as early as possible in the plan making process. Issue W3: Ensuring the built environment provides healthy and inclusive communities: The plan should include a policy on light pollution to accommodate the needs of both nocturnal nature, astronomical night sky and peoples health and wellbeing. Light pollution - GOV.UK (www.gov.uk) In valuing the benefits of outdoor spaces, the Outdoor Recreation Valuation Tool (ORVal) is a web application developed by the Land, Environment, Economics and Policy (LEEP) Institute at the University of Exeter with support from DEFRA. ORVal’s primary purpose is to help quantify the benefits that are derived from accessible outdoor recreation areas in England. Those outdoor recreation areas, or greenspaces, include an array of features such as beaches, parks, nature reserves and country paths. ORVal Outdoor Recreation Valuation (exeter.ac.uk) (https://www.leep.exeter.ac.uk/orval/) Issue W4: Public Open Space for leisure and informal recreation: NE support the ethos behind this policy. In support of this you will find NE’s recently launched Green Infrastructure Framework (GIF) guidelines of use in helping design spaces. Natural England unveils new Green Infrastructure Framework - GOV.UK (www.gov.uk) https://www.gov.uk/government/news/natural-england-unveils-new-green-infrastructure-framework The standards for Accessible Natural Greenspace standards in Towns (ANGSt) have been updated and included within the new GI framework. Large data surveys carried out by NE will be very useful in informing this policies ongoing development. The People and Nature Survey (PANS) for England gathers evidence and trend data through an online survey relating to people’s enjoyment, access, understanding of and attitudes to the natural environment, and it’s contributions to wellbeing. It began collecting data in April 2020 and has been collecting data since. So far, data is published that was collected between April 2020 and March 2022 – the survey is ongoing. The People and Nature Survey - GOV.UK (www.gov.uk) Natural England’s - Monitor of Engagement with the Natural Environment (MENE): The MENE survey provided trend data for how people experience the natural environment in England – 2014 to 2022. Tranquillity is an important landscape attribute in certain areas e.g., within National Parks/AONBs. Local Planning Authorities should consider whether there are any such areas of tranquillity in their areas, and map (or otherwise spatially identify) them and provide appropriate policy protection. The only currently available national data source on tranquillity is held by CPRE here: Tranquillity Map: England - CPRE. https://www.cpre.org.uk/resources/tranquility-map-england/ Green infrastructure: A network of multi-functional green and blue spaces and other natural features, urban and rural, which is capable of delivering a wide range of environmental, economic, health and wellbeing benefits for nature, climate, local and wider communities and prosperity. There should be a strategic approach to Green Infrastructure (GI) provision and the plan should set out a clear strategy for its delivery. This could include GI targets, standards, requirements for development and opportunity areas. The strategy may be based on current GI strategies, upcoming GI strategies, other natural environment strategies or biodiversity opportunity/ecological network mapping. The plan should identify deficiencies in GI provision and opportunities for new GI. The GI policy should support and align with other natural environment and active travel policies (e.g., BNG investment can support wider GI outcomes). Green Infrastructure policy needs to ensure that health and wellbeing outcomes are being maximised for all. The policy should address unequal access to natural green space and the needs of different user, age, and socio-economic groups. See also section 7.4 of this letter. Refer to PPG on GI here: Natural environment - GOV.UK (www.gov.uk). https://www.gov.uk/guidance/natural-environment#green-infrastructure Green Infrastructure standards and guidance, currently under development should be embedded in future local plans once finalised.

Issue W2: Health Impact Assessments for major development Option W2b. We do not consider that a specific policy on Health Impact is required. From our experience the health impact screening requests often required by LPA’s (to understand whether a full HIA for the specific proposals are required) is just a tick box exercise with no real purpose. Issue W3: Ensuring the built environment provides healthy and inclusive communities Q- W3a. We consider option a which would include an overall policy on heath is the most appropriate for South Warwickshire. A policy worded to aim all aspects of health and assist in creating communities which are safe, healthy and inclusive would be consistent with chapter 8 of the NPPF and build upon existing health policies within the Warwick District Local Plan and the Stratford Core Strategy.

Air Quality and the Environment: Development of the scale proposed will have a disproportionate and adverse impact on air quality and other factors driven by additional traffic from the aggressive development proposed by the town.

Issue W2: Health Impact Assessments for major development Option W2b. We do not consider that a specific policy on Health Impact is required. From our experience the health impact screening requests often required by LPA’s (to understand whether a full HIA for the specific proposals are required) is just a tick box exercise with no real purpose. Issue W3: Ensuring the built environment provides healthy and inclusive communities Q- W3a. We consider option a which would include an overall policy on heath is the most appropriate for South Warwickshire. A policy worded to aim all aspects of health and assist in creating communities which are safe, healthy and inclusive would be consistent with chapter 8 of the NPPF and build upon existing health policies within the Warwick District Local Plan and the Stratford Core Strategy.

Issue W3: Ensuring the built environment provides healthy and inclusive communities Historic England welcomes the recognition of the SWLP of the important role that spatial planning has in the creation of healthy, safe and inclusive communities. However, we suggest that the Plan also references the role of heritage in communities and acknowledges the link between heritage and improvements in physical and mental health and well-being, as mentioned in the Scoping version of the SWLP. Whilst we are supportive of a policy on ‘health’, we consider that the policy title and content should encompass ‘well-being’, as well as ‘health’.

In our view it is not necessary for the SWLP to include a Health Impact Assessment policy requiring new developments to be submitted with a Health Impact Assessment. HLPC operate in a variety of authorities where Health Impact Assessments are required. In our experience, they add little to the overall application submission and create additional cost. Matters such as pollution, air quality, access to services and facilities can be addressed in the wider planning submission.

The section on a “healthy, safe and inclusive S Warks” is good motherhood and apple pie stuff but we might want to ensure that this doesn’t evolve into street lighting and overturning dark skies policies. We might also point out that, in rural areas, a big factor is speeding and that the plan might address this.

QW2 – Please select a Health Impact Assessment option which is most appropriate for South Warwickshire In our view it is not necessary for the SWLP to include a Health Impact Assessment policy requiring new developments to be submitted with a Health Impact Assessment. HLPC operate in a variety of authorities where Health Impact Assessments are required. In our experience, they add little to the overall application submission and create additional cost. Matters such as pollution, air quality, access to services and facilities can be addressed in the wider planning submission.

Issue W2: Health Impact Assessments for major development Option W2b. We do not consider that a specific policy on Health Impact is required. From our experience the health impact screening requests often required by LPA’s (to understand whether a full HIA for the specific proposals are required) is just a tick box exercise with no real purpose. Issue W3: Ensuring the built environment provides healthy and inclusive communities Q- W3a. We consider option a which would include an overall policy on heath is the most appropriate for South Warwickshire. A policy worded to address all aspects of health and assist in creating communities which are safe, healthy and inclusive would be consistent with chapter 8 of the NPPF and build upon existing health policies within the Warwick District Local Plan and the Stratford Core Strategy.

Q-W2: Please select the option which is most appropriate for South Warwickshire We are supportive of Option W2a and consider a policy should be included on Health Impact Assessments. This option seeks to deliver appropriate local facilities to support residents and to enhance the sustainability of existing areas. The Vision Document prepared for the Site has been structured to follow Building for a Healthy Life (BHL) principles. BHL is one of the most widely used design tools in England for creating places that are better for people and nature. It was written in partnership with Homes England, NHS England and NHS Improvement and is structured to set clear expectations for new developments. By following BHL, a critical aspect of the Vision for the Site is to design for active travel and access to green space. The ability to be able to walk and cycle within the new neighbourhood and the site’s good accessibility to the built-up area of Kenilworth, a town with many local services, is key in order to minimise traffic and mitigating climate change. Equally, and as BHL sets out, the COVID-19 pandemic has reinforced the importance of designing for active travel. This is in recognition that design choices that help people feel disposed to walk or ride a bicycle in their neighbourhood are critical to supporting a sense of well-being from outdoor exercise. It is considered that the healthcare requirements for strategic sites should be set out in the Infrastructure Delivery Plan, once prepared. We note that work is ongoing in relation to the Infrastructure Delivery Plan. We therefore reserve the right to comment further at a later stage, once the specific requirements for sites have been clearly defined.

CDC supports a policy or clause on HIA for major development Option W2a. Given our generally ageing population, rise in obesity and dementia as causes of ill health, and the recent pandemic, it seems prudent to use this tool to help inform decisions and predict health consequences of development proposals. HIA can identify opportunities such as ‘more and better active travel infrastructure in areas of poor air quality will lead to improved cardiovascular health; safer and more inclusive spaces for older people as well as those with a mental or physical health problem will deliver benefits to individual quality of life…. By bringing such health considerations to the fore, HIAs add value to the planning process’ . National guidance (PPG) on healthy and safe communities also suggests the use of HIA can be beneficial “where there are expected to be significant impacts”.

ISSUE W2: HEALTH IMPACT ASSESSMENT Q-W2: Please select the option which is most appropriate for South Warwickshire 2.52 Ellis Machinery would support the requirement for impacts on health as a result of development on strategic site allocations that could be included in the strategic allocation planning policy. For smaller schemes such as a residential development on Land at Old Town, Gaydon, other environmental planning polices should cover issues such, as pollution, noise, land contamination. 2.53 Ellis Machinery would support Option W2b.

I write as an allotment holder and wish to raise concerns about the potential for building developments to affect the lives, well-being, morale and mental health of the many families involved. A glance at older Leamington OS maps and comparison with current ones reveals the disappearance of hundreds of acres of local allotment space. This is not a trivial matter as allotments are central to the the lives of so many. It is essential that this concern is prioritised in considering the South Warwickshire Local Plan.

Q-W2 54. The threshold for any Health Impact Assessments being required should be a high threshold (e.g. 150 dwellings) because it is usually the scale of the proposal which has the greatest effect on healthcare provision.

Q-W2 56. The threshold for any Health Impact Assessments being required should be a high threshold (e.g. 150 dwellings) because it is usually the scale of the proposal which has the greatest effect on healthcare provision.

Q-W2 56. The threshold for any Health Impact Assessments being required should be a high threshold (e.g. 150 dwellings)because it is usually the scale of the proposal which has the greatest effect on healthcare provision.

Q-W2 53. The threshold for any Health Impact Assessments being required should be a high threshold (e.g. 150 dwellings) because it is usually the scale of the proposal which has the greatest effect on healthcare provision.

Q-W2 54. The threshold for any Heah Impact Assessments being required should be a high threshold (e.g. 150 dwellings) because it is usually the scale of the proposal which has the greatest effect on healthcare provision.

Q-W1: This is a national and regional issue Q-W2: The JPC does not support work on this as it is inappropriate for a sub-regional plan

Issue W2: Health Impact Assessments Our client considers that the need for a Health Impact Assessment should be dictated by the potential health impacts of the proposal i.e., there should be a screening process to determine whether HIA is required. This should be reflected in any policy.

There is great concern that there appears to little reassurance in terms of planning, resources and funding that shows local authorities will meet the additional needs of local populations where significant expansion of these populations are made. This will result in the reduction of access to preventative medicine at both a personal and population level. On top of this on-going care of chronic disease will be negatively impacted. These services would need to be in place prior to any planning consideration. There appears to be no identification of access to A&E or minor accident units. Henley residents are required to make over 30 minute car journeys to reach any facility.

Q W.1 Should the Part 1 plan include a policy on pollution? Yes. In August last year, the United Nations General Assembly declared that everyone on the planet has a right to a healthy environment, including clean air, water and a stable climate. The Clean Air (Human Rights) Bill is being considered by the UK government to ensure the government takes action to bring air quality in every community up to World Health Organisation minimum standards PM 2.5 Air Pollutants on Henley High street already exceed WHO guidelines. Further development will increase congestion and pollution. Uptake of electric vehicles is slow so it is questionable that this will significantly mitigate this in our lifetimes. So yes, pollution should absolutely be taken into account. W4 There is great concern that there appears to little reassurance in terms of planning, resources and funding that shows local authorities will meet the additional needs of local populations where significant expansion of these populations are made. This will result in the reduction of access to preventative medicine at both a personal and population level. On top of this on-going care of chronic disease will be negatively impacted. These services would need to be in place prior to any planning consideration. There appears to be no identification of access to A&E or minor accident units. Henley residents are required to make over 30 minute car journeys to reach any facility.

Q-W2: Please select the option which is most appropriate for South Warwickshire • Option W2a: Include a policy on Health Impact Assessments. • Option W2b: Do not include a policy on Health Impact Assessments. We are supportive of Option W2a and consider a policy should be included on Health Impact Assessments. This option seeks to deliver appropriate local facilities to support residents and to enhance the sustainability of existing areas. The Vision Document prepared for the Site has been structured to follow Building for a Healthy Life (BHL) principles. BHL is one of the most widely used design tools in England for creating places that are better for people and nature. It was written in partnership with Homes England, NHS England and NHS Improvement and is structured to set clear expectations for new developments. By following BHL, a critical aspect of the Vision for the Site is to design for active travel and access to green space. The ability to be able to walk and cycle within the new neighbourhood and the site’s good accessibility to the built-up area of Alcester, a town with many local services, is key in order to minimise traffic and mitigating climate change. Equally, and as BHL sets out, the COVID-19 pandemic has reinforced the importance of designing for active travel. This is in recognition that design choices that help people feel disposed to walk or ride a bicycle in their neighbourhood are critical to supporting a sense of well-being from outdoor exercise. It is considered that the healthcare requirements for strategic sites should be set out in the Infrastructure Delivery Plan, once prepared. We note that work is ongoing in relation to the Infrastructure Delivery Plan. We therefore reserve the right to comment further at a later stage, once the specific requirements for sites have been clearly defined.

Issue W2: Health Impact Assessments for major development Option W2b. We do not consider that a specific policy on Health Impact is required. From our experience the health impact screening requests often required by LPA’s (to understand whether a full HIA for the specific proposals are required) is just a tick box exercise with no real purpose. Issue W3: Ensuring the built environment provides healthy and inclusive communities Q- W3a. We consider option a which would include an overall policy on heath is the most appropriate for South Warwickshire. A policy worded to aim all aspects of health and assist in creating communities which are safe, healthy and inclusive would be consistent with chapter 8 of the NPPF and build upon existing health policies within the Warwick District Local Plan and the Stratford Core Strategy.