Comment

Preferred Site Allocations 2018

Representation ID: 18291

Received: 12/03/2018

Respondent: Essex County Council

Representation Summary:

Healthcare

Full text:

Healthcare - General Practice -
BBC should be advised that Public Health is the responsibility of ECC, in addition to the roles of the CCG.

ECC considers the information provided in paragraph's 97 to 105 and figure 17 of the consultation document provides a good general overview of the up to date evidence relating to GP's in the borough; however there is no consideration of the wider health implications that need to be addressed as part of the plan making process.

Supporting the design and creation of healthy communities is fundamental to the NPPF. ECC is supportive of the general objectives around health within the plan, but consider that these could be greatly enhanced. ECC therefore question if the Draft Plan, at present, ensures that the inclusion of health and wellbeing can be fully assured. This is due to the lack of specific policy on health and wellbeing or associated requirements for the submission of Health Impact Assessments (HIA) with planning applications.

ECC considers that without such policies, the opportunities to support the positive impacts that development can have on health, wellbeing and the wider determinants may be missed. In addition, any negative impacts on health could be more difficult to remove or be mitigated against. The allocation of Section 106 monies to health and wellbeing may also be challenged without the appropriate policy background.

The Essex Planning Officers Association (EPOA) support the use of HIA and have guidance notes on thresholds. HIA, as a material consideration, ensures health and wellbeing is addressed. ECC recommends that HIA is undertaken to inform the preparation of the Local Plan.

Priorities for public health within spatial planning include reducing health inequalities, by supporting access to quality open and green/blue space, healthy diets including improving access to local and fresh food, improving community cohesion and reducing social isolation, supporting air quality through active travel, increasing physical activity opportunities through increasing movement and play across all ages and supporting good quality housing design across the life course. EEC recommends that such matters should be considered as the plan progresses towards submission.

ECC Public Health has been engaged with the Town and Country Planning Association (TCPA) on work around Garden Communities. In addition, Health and Wellbeing has been incorporated into the Essex Design Guide refresh and addresses Garden Community developments. ECC strongly encourage BBC to engage early with the ECC Director of Public Health and team for advice on healthy urban planning for this development.

In addition, ECC works closely with various health partners to support their healthcare estates including NHS England East and Community Health Partnership, on access of healthcare infrastructure and would be happy to be part of conversations with our partners to ensure that the whole health system is considered as part of the plan making process.

With regards to food retailers and premises, ECC would signpost BBC to the tool developed by the Centre for Diet and Activity Research (CEDAR) on food geography. This enables local authorities to see the types of food outlets in their areas. It includes A5 premises (under a wider scope of fast food). ECC advises that the management of A5 premises should be considered as part of the plans overall health and wellbeing approach, together with some emerging evidence base on overconcentration of fast food outlets and obesity. There are a number of authorities developing and adopting specific A5 policies, and ECC would be happy to support BBC on building on these principles.

ECC Public Health is engaged with planning teams for many Essex Garden Community proposals. This is to ensure that healthy urban design principles are incorporated into the design and planning of these strategic sites. ECC wish to be engaged in any HIA process that would be part of the development planning for DHGV. The refresh of the Essex Design Guide (EDG) provides references/advice on garden principles, and Sport England provide guidance on active design principles and health.

ECC Public Health is supportive of lifetimes, adaptable homes. This would include housing design for older people. ECC encourages design to be inclusive and allow for accessibility. These aspects have been raised as part of the Essex Design Guide refresh. ECC also promotes dementia friendly community principles, such as those set out in the RTPI dementia friendly practice guidance.

On key worker homes and affordable housing for NHS key staff, ECC advise that discussions on workforce planning with NHS providers should be considered to support the development of their workforce strategies. This would support the health and wellbeing of communities and also access to healthcare infrastructure to which the workforce should be considered as an integral part (as per the NPPF).

With regard to specialist housing, ECC Public Health advise that the social care team at ECC should be engaged on this matter. The relevant CCG should also be engaged to ensure GP provision is available to support these specialist homes.

ECC support the inclusion of an air quality policy, as part of the overall health and wellbeing agenda. ECC recommend that this can be further supported by active travel encouragement.

Other references that may be of assistance are PHE health profiles and PHE guidance on planning and PH.