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We support the creation of new allotments (with appropriate parking facilities) and open spaces where any new building occurs. Allotments are always in demand, and open spaces will enhance the lives of those who move to the village.

I object to the lack of provision in the Langham 900 plan for allotments and an orchard for shared growing in the new community

Whilst West Bergholt Parish Council generally supports this policy it believes that the first sentence of the policy should be amended to clarify that it isn’t referring to commercial crops when considering safeguarding.
“New development should safeguard and, where appropriate, create or enhance the role of allotments, community orchards, community gardens and food markets to promote healthy lifestyles...”

ECC welcome and support the inclusion of the Healthier Food Environments policy in line with the NPPF Paragraph 97 looking to manage hot food takeaway in the City.

The NPPG (paragraph: 004 reference ID:53-004-20190722) states planning can influence the built environment to improve health and reduce obesity and excess weight in local communities. Local planning authorities can have a role by supporting opportunities for communities to access a wide range of healthier food production and consumption choices. Planning policies and supplementary planning documents can, where justified, seek to limit the proliferation of particular uses where evidence demonstrates this is appropriate (and where such uses require planning permission). In doing so, evidence and guidance produced by local public health colleagues and Health and Wellbeing Boards may be relevant. Planning policies and proposals may need to have particular regard to the following issues:

• proximity to locations where children and young people congregate such as schools, community centres and playgrounds
• evidence indicating high levels of obesity, deprivation, health inequalities and general poor health in specific locations
• over-concentration of certain uses within a specified area
• odours and noise impact
• traffic impact
• refuse and litter

ECC recommend reviewing emerging example from Castle Point Local Plan Regulation 19 Policy – Policy TC5
Office for Health Improvement and Disparities (previously Public Health England), provides guidance on healthy weight environments: using the planning system including planning restriction on fast food takeaways.

ECC recommend the following according to the Cambridge University Takeaway Management Zone Guidance – a toolkit for managing takeaways near schools - giving consideration to the following:
o The links between takeaway use, health impacts, obesity, deprivation and research
o Links to national and local strategies objectives around health and wellbeing
o Purpose for limiting access to takeaway by addressing clustering and concentration
o Defining areas where children and young people congregate
o Defining boundaries and distance of the restriction zones
o Consideration of takeaway opening times within permitted areas
o The applicability of the policy to addressing concentration of takeaways
o Providing a distinction between:
 Over-proliferation: where the hot food takeaway would be located equals or exceed the UK national average per 1000 population
 Over-concentration: permission not granted where % of HFT exceed certain % within designated centres
 Clustering: preventing the clustering of HFT where not allowing X amount to not be located adjacent to each other
o Consider links to local healthier catering commitments such as Tuck-IN adopted across Essex.

Suggested preceding text:
The NPPF states that planning policies should ‘enable and support healthy lifestyles and reduce health inequalities. The PPG states that planning can influence the built environment to improve health and reduce obesity and excess weight in local communities. This includes through access to a wide range of healthier food production and consumption choices.
Poor diet and obesity are leading causes of mortality. The location of takeaways, particularly where young people gather such as schools, youth facilities and other locations, can have the potential to influence behaviour which is harmful to health and the promotion of healthy lifestyles. There are clear and evidenced links between takeaways and fast food and obesity amongst all age groups. This policy takes those health considerations into account and seeks to support both national and local promotion of healthy lifestyles and healthy weight which is one way to achieve this through promoting healthier food environments to enable people to make healthy choices to live well.
In line with the NPPF, controlling the development of takeaways within walking distances of places where young people gather will limit children’s exposure to the influences on making less healthy food choices. This policy also seeks to avoid concentration of takeaways which can harm the health of all sections of the community by reducing choice and opportunities for less healthy food choices and preventing such outlets from dominating the street of local centres.
Policy Text

New development must safeguard and, where appropriate, create or enhance the role of allotments, orchards, community gardens and food markets to promote healthy lifestyles by providing access to healthy, fresh, and locally produced food, providing food growing opportunities and for exercise and recreation. Allotment provision must be well located to residential areas and community spaces, with suitable access arrangements for all.
Some locations are more suited than others for fast food outlets and takeaways. All proposals for these uses need to consider to the following factors, and should reflect the relevant evidence, to inform the planning decision:

Impacts on children and young people:
a) The Council will refuse proposals for hot food takeaways and fast-food outlets within 400m walking distance of the boundary of a nursery, a primary school, a secondary school, a community college, playground, or youth facilities and other places where children and young people frequent.

b) Within designated centres proposals for hot food takeaways and fast-food outlets will be supported unless there is evidence that the impacts of clustering or cumulative impact resulting from an over concentration of such uses is having an adverse impact on local health, pollution or anti-social behaviour;

Concentration of takeaways:
c) In order to ensure that excessive concentration of hot food takeaways and fast-food outlets are avoided, proposals for hot food takeaways falling within sui generis use class will be supported where the following thresholds are not exceeded:
a. Within a Town Centre, no more than X% of shop units comprise hot food takeaways;
b. Within local shopping parades comprising 6 or less shop units, no more than X% of the shop units comprise hot food takeaways;
c. Within local shopping parades comprising X to X shop units, no more than X% of the shop units comprise hot food takeaways; and
d. Within local shopping parades comprising X or more units, no more than X% of the shop units comprise hot food takeaways.

Amenity Impacts and Health Impact Assessment:

d) In all other areas proposals for hot food takeaways and fast-food outlets a Health Impact Assessment will be required in order to appropriately consider the impacts of such uses on local health, pollution or anti-social behaviour. Where impacts are shown as having an adverse impact as a result of the proposal, or cumulative impacts on communities / catchments they are intended to serve, proposals will be refused unless they can be satisfactorily mitigated.

In cases applying to criteria b) and c), evidence will need to include indicators such as levels of obesity, areas of deprivation, or other health indications with a recognised link to healthy eating. Evidence demonstrating significant levels of adverse health impacts arising from air quality and pollution, and evidence of excessive anti-social behaviour in the immediate vicinity of the proposed use will also be relevant.
Where the Council are minded to approve proposals, conditions may be used to restrict the hours of operation where this is appropriate and supported by relevant evidence.

Reasoned Justification/ Supporting Text:
In seeking to promote access to healthy, fresh, and locally produced food. It is important that we create a healthy food environment in our town centres and local communities. The policy supports the aims and objectives of the Essex Healthy Weight Strategy and NHS North East Essex Health and Wellbeing Alliance in improving health and wellbeing, tackling obesity (particularly childhood obesity), and reducing health inequalities in the City.
The Essex Healthy Weight Strategy (2024 – 2034) priorities addressing factors that influence the food environment, ensuring that the environment in Essex supports and enables people to maintain a healthy weight and minimises the risks of excess weight. Some focus areas include healthy food and drink advertising policies and how new developments can support healthier food provision. Promoting access to healthy and locally sourced food, providing communal and individual food growing opportunities, ensuring provision and access to local food shops, limiting access to hot food takeaways (e.g., limits on distances from school or limits on the proportion within town and city centres) are recognised as planning measures that can enable residents to live healthier lives.
The policy aligns with and supports national public health and planning policy that seeks to ensure communities live in an environment which enables and promotes healthier lifestyles, the Government’s National Obesity Strategy highlights that eating out can contribute towards obesity through the consumption of more calories.
The Joint Strategic Needs Assessment shows that obesity for adults in Colchester is higher than the national average and slightly lower for children in year (including overweight).Obese children are more likely than children of a healthy weight to be obese adults and have an increased risk of developing chronic diseases in adulthood. It is there necessary to ensure that the mix of uses, and the way in which buildings and spaces in town centres are designed promote active lifestyles and a healthy food environment.
The policy applies to those facilities where young people’s behaviour and dietary choices may be influenced by the proximity and concentration of takeaways outlets. The policy is supported by national strategies to reduce childhood obesity, which is identified as public health priority with significant health and economic consequences. Locally, this policy seeks to help achieve strategic public health objectives to stop the increase in childhood obesity and to close the childhood obesity gap, in which children in more deprived areas are more likely to be obese that those in less deprived areas.
‘Schools and other places where children and young people frequent’ is defined as the entry points to nursery, primary and secondary schools, a community college, youth, and community centres, and playgrounds.
In assessing whether a proposal for a new takeaway would be acceptable, its distance from the definitions above will be measured according to realistic walking routes. In some cases, a new takeaway located beyond 400m from the defined youth facilities may not be acceptable due to local factors which would result in the outlet being likely to have a harmful influence on children’s behaviour and choices, for example by being prominently located on a main walking route.
Within designated centres, it may also be necessary to reduce or limit the influence of a takeaway outlet through the use of a planning condition to restrict opening hours. This would seek to restrict opening hours during school lunch breaks and the end of the school day, when the behaviours of children and young people are most likely to be influenced.
A group of researchers including the University of Cambridge, University College London and Office for Health Improvement and Disparities conducted economic analysis and found that takeaway management zones are associated with net economic benefits for local authorities, national government, and the NHS. They also found that there were general public acceptability and young people perceived takeaway management zones to have some positive impacts.
Concentration of takeaways
Hot food takeaways are now a common features of town centres, high streets, and local centres and are recognised as a popular choice in the food offer. However, they have a greater potential to have a detrimental impact on residential amenity and environmental quality. Where concentration of hot food takeaways is present, this can result in adverse impacts on the vitality and viability of a retail centre and limit investment of other retail use.
Traditionally, hot food takeaways (sui generis use class) differ in purpose from restaurants or cafes (use class E(b)), however some businesses classified as restaurants also offer takeaway services. This increased proliferation of hot food takeaways over recent decades is reducing the diversity of retail offer, as well as having significant influence over food consumption patterns.
Whilst local shopping parades are a sustainable location for hot food takeaways because they are close to where people live, there are, in some instances where the number of takeaways in such parades dominates use class E(a) shopping provision, reducing diversity of local retail available.
Hot food takeaways can contribute towards unhealthy lifestyles. The Office for Health Improvement and Disparities (previously, Public Health England) has advised that increased exposure and opportunity to buy fast food (including proximity and opening hours) results in increased consumption levels which can have negative effects on health. This is because over exposure to takeaways is shown to increase the risk ill health and obesity by encouraging ‘out of home’ eating, where meals are more likely to contain high levels of sugar, salt, and fat which are linked to obesity and related health conditions. A proliferation of takeaways is likely to be harmful to people’s health by reducing the diversity and range of food choices on offer, restricting potential access to healthy food.
England has one of the highest rates of obesity in Europe and in the developed world. Public health evidence and the Global Burden of Disease highlights that obesity is one of the most widespread threats to health and well-being in the country and that there is a link between excess body weight and diseases such as type 2 diabetes, cancer, and heart disease. This impacts on the cost of health and care provision and the ability of health services to support local communities.
It is considered that the concentration or clustering of takeaways uses in centres can dominate the retail environment, limiting the number of units available for healthier food choices ad resulting in an over-exposure of takeaway uses which may influence behaviour. Managing the clustering, proliferation, and overconcentration of takeaways in retail centres can help reduce the harmful impact and prevention the creation of fresh food deserts, in which residents have limited access to nutritious, affordable, and appropriate food.
An overconcentration of takeaways is considered to be where hot food takeaways and fast-food outlets constitute X% or more of the total number of units within local centre or parade. An unacceptable concentration will also be considered to arise where X% or more hot food takeaways and fast-food outlets would be adjacent to each other.
Amenity impacts and Health Impact Assessment
Takeaways have the potential to negatively affect their surroundings due to issues associated with noise, odour, fumes, litter, highways impact and increased activity associated with both customer and delivery riders.
Litter has the potential to cause considerable annoyance to residents, other businesses and can even have public health implications. Whilst takeaway operators cannot always control where waste is deposited by customers, the council may see fit to require conditions such as asking premises to undertake litter picking beyond the immediate vicinity for litter generated from off-sales and the provision of bins and advisory signage.
National Institute for Health and Care Excellence (NICE) guidance on prevention of cardiovascular disease and prevention of Type 2 diabetes state that local authorities should influence planning permission for food retail in relation to preventing and reducing cardiovascular disease including improving the nutritional quality of the food they provide. Across Essex, Environmental Health has developed and implemented a healthier catering scheme, TuckIN, to support healthier eating objectives, hot food takeaways and fast-food outlets will be encouraged to support this scheme.
A Health Impact Assessment will be required to appropriately consider the impacts. Health Impact Assessments are a useful tool in ensuring that the wellbeing of the community is considered as part of the design process and will be required to ensure that proposals for development selling hot food takeaway contribute to the creation of a healthy food environment.

Officer summary of full submission. See attachment with detailed comments on numerous policies:
The overall message is one of support for CCC undertaking a review of the adopted Local Plan to ensure an up to date plan prepared in accordance with the NPPF is in place. ECC will continue the on-going engagement with CCC, through the Duty (or any replacement), to assist progress of the Plan to Regulation 19 (the Pre-Submission Plan), particularly with regards the strategic and cross boundary implications, including cumulative issues and opportunities arising from growth to ensure that the infrastructure requirements are identified, quantified, costed and phased where appropriate. ECC service areas have clearly outlined where further collaborative work/assessment needs to be undertaken (e.g. education provision and ongoing transportation modelling) to refine and resolve an issue; and ECC will continue to be engaged, alongside NH, on the proposals which have an impact on the A12 strategic transport corridor, in particular A12 junctions 25 to 28, A12 widening and junction improvements, and the A120 Corridor Maks Tey to Braintree.

There is support for the Draft Plan’s vision which covers environmental, social and economic needs and emphasises healthy living environments and green networks, environmental protection and economic growth. There is support that the mandatory housing target will be met in full and exceeded over the Plan period in accordance with the NPPF, and that future employment needs will be met (noting that some clarifications are sought) by providing a range in scale of additional employment land supply. ECC provides strong support for policies related to net zero carbon (in operation and embodied), water efficiency, health and well-being, and the environment (green and blue infrastructure and BNG. Recommendations are made throughout the response on policy wording (including policy omissions) and justification to strengthen clarity, effectiveness and delivery.

There is strong support for the inclusion of site-specific Place Policies and references to infrastructure requirements, but these will need to be reviewed and confirmed with ECC following this consultation and the agreement of a final spatial strategy by CCC. It is noted there are some omissions in the Draft Plan such as the allocation of a new secondary school. On this issue, ECC acknowledges the requirement is stated in the Infrastructure Assessment Delivery Plan (Stage 3) for site allocation PP18 Land North of A120 Marks Tey; and in the Infrastructure Topic Paper prepared by CCC, where Appendix A lists the infrastructure requirements for the preferred options site allocations (including those for education). Land for the secondary school (and all education requirements) will need to be allocated in the Pre-Submission Plan.

The review of the IDP and full plan viability assessment are key documents for ECC engagement and input following this round of consultation. The Viability Assessment will need to be reviewed following consultation to ensure it can align with the most up to date evidence relating to the EPOA net zero development policies and its viability evidence. Mention is also made in the response to specific localities and sites – notably Marks Tey and Langham – where discussion needs to take place and recommendations are made to ensure effective delivery if these proposed allocations are taken forward to the Pre-Submission Plan.