Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 28158

Received: 22/07/2024

Respondent: East Sussex County Council

We fully support policy requirement vii) for all developments to address the 12 considerations within ‘Building for a Healthy Life’ and its companion ‘Streets for a Healthy Life’. Policy requirement ‘v) Stewardship’ on community involvement is also welcomed. It is important that this includes all sections of the community. Therefore, it is suggested the requirement is strengthened to:

‘b. Includes a clear participation strategy that sets out how *all sections* of the community *particularly hard to reach and vulnerable groups such as the young, women, girls and ethnic minorities* will be involved in the design and management of places, community assets and green infrastructure, including the use of participatory methods, co-design, co-production, and co-management.’

Comment

Representation ID: 28159

Received: 22/07/2024

Respondent: East Sussex County Council

It is suggested that the Vision for Bexhill should include the following suggested text:

‘Connections and accessibility to settlements that are in close proximity to Bexhill will be enhanced through improved public transport, active travel and road networks. This will ensure that wider services and facilities can continue to be accessed, enabling residents to live well locally *and have healthy lifestyles*.’

It is suggested that the vision should also include the following text to acknowledge the existing health inequalities in Bexhill: *There will be improvements to health inequalities and wellbeing enabling communities to lead healthy and active lifestyles*.

Comment

Representation ID: 28160

Received: 22/07/2024

Respondent: East Sussex County Council

Public Health totally supports and welcomes the chapter on Health and Wellbeing. There is general support for all policies within the chapter.

Comment

Representation ID: 28161

Received: 22/07/2024

Respondent: East Sussex County Council

It is suggested that the Policy should include the following to make specific reference to East Sussex and include a link to the East Sussex Joint Strategic Needs Assessment webpage.

‘…health and wellbeing needs in Rother as identified in the *East Sussex* Joint Strategic Needs Assessment.’

Comment

Representation ID: 28162

Received: 22/07/2024

Respondent: East Sussex County Council

The plan recognises the ageing population in Rother, therefore it is suggested it should
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acknowledge the more complicated conditions they may experience, for example
chronic disease and fall-related injuries, by the inclusion of the suggested text within Paragraph 6.4:

‘The 2021 census also highlights that Rother has an ageing population, with a median age of 53 (the second highest in England and three higher than 2011), far older than the English median of 40, *this comes with an increase in complicated conditions associated with this group of people*.’

Comment

Representation ID: 28163

Received: 22/07/2024

Respondent: East Sussex County Council

Public Health fully supports the policy to set an appropriate requirement for Health Impact Assessments (HIA) to be undertaken. The reference to the East Sussex HIA Toolkit is welcomed. Public Health is working with all Local Planning Authorities in East Sussex through a Planning for Health Working Group to create HIA Guidance within an East Sussex HIA Toolkit. This will support the implementation of HIA requirements across the County and ensure a consistent approach. Public Health will work with the Working Group to confirm the guidance, terminology, and approach to HIA, this should then be reflected in the policy and the supporting text on HIA as the Local Plan is developed through to adoption.

Public Health is committed to supporting Rother District Council (RDC) in the implementation of this policy and to continuing to work with the RDC on establishing appropriate HIA requirement thresholds.

To provide further clarity within the explanatory text the following changes, as outlined in paragraphs 8.17 and 8.18 of this response, are suggested.

Comment

Representation ID: 28164

Received: 22/07/2024

Respondent: East Sussex County Council

The text is misleading and contradicts the policy requirement that an HIA must be submitted with applications. Planning applications should not be validated until an HIA is included.

To see suggested changes to the text please see paragraph 8.17 of the attached submitted representations.

Comment

Representation ID: 28165

Received: 22/07/2024

Respondent: East Sussex County Council

It is suggested that paragraph 6.11 should be amended to clarify the requirement, in line with the policy.

Please see paragraph 8.18 of the attached submitted representations for suggested text amendments.

Comment

Representation ID: 28166

Received: 22/07/2024

Respondent: East Sussex County Council

HWB3: Reducing Harmful Impacts on Health, p204-206; We agree with the overall policy limiting the proliferation of certain uses that may have harmful impacts on health. Making specific reference to restricting the development of new hot food takeaways is supported. We will continue to work with officers to consider other appropriate criteria for inclusion, including sharing public health data and evidence. This could include, for example, using levels of obesity (data from the Public Health Outcomes Framework), or levels of deprivation (using Indices of Multiple Deprivation) to identify where particular vulnerable and at-risk groups are located. Setting thresholds should be explored, such as locations where there are high obesity rates (that are higher than national levels) at ward level for Reception and Year 6 Children, and for adults (overweight and obese) when compared to national data. Another suggested baseline could be from 2006 when the National Child Management Plan was first conducted, for example ‘8% of Reception and 15% of year 6 living with obesity within East Sussex.’

Comment

Representation ID: 28167

Received: 22/07/2024

Respondent: East Sussex County Council

Proposed Policy HWB5: Green and Blue Infrastructure, p211-212; The policy criteria should include recognition and opportunities for multi-functional benefits, therefore, it is suggested that the following text is included.

*‘Maximising opportunities to provide multi-functional benefits for the environment, climate change and communities.’*