The U.S. Department of Health & Human Services solicited input on proposed objectives for Healthy People 2030, a set of health promotion and disease prevention topics to focus attention on the nation’s most critical public health priorities. Based on what we have learned from our work in our Building Healthy Communities program area, NYHealth submitted the following comments to inform the Healthy People 2030 objectives in the areas of (1) Physical Activity and (2) Nutrition and Weight Status.


January 16, 2019

The Honorable Alex M. Azar II
Secretary of Health & Human Services
U.S. Department of Health & Human Services
Office of Disease Prevention and Health Promotion
200 Independence Ave, S.W.
Washington, D.C. 20201

Re: 83 FR 60876 – Public Comment on Healthy People 2030

Dear Secretary Azar:

The New York Health Foundation appreciates the opportunity to respond to the Office of Disease Prevention and Health Promotion’s (ODPHP) Development of the National Health Promotion and Disease Prevention Objectives for 2030 (Healthy People 2030).

The New York Health Foundation is a private, charitable foundation that works to improve the health of all New Yorkers, especially the most vulnerable. Our program called Building Healthy Communities addresses the growing body of evidence that an individual’s ZIP code has a greater impact than his or her genetic code on health. Significant health improvement does not occur only in the doctor’s office, but in the places where people live, work, and play.

Our program is a place-based initiative in neighborhoods across New York State that supports healthier communities by: (1) expanding access to and demand for nutritious foods and (2) expanding access to safe places where residents can be more physically active. Our investment in this work has provided us with in-depth knowledge of how one’s environment, and what is available in one’s neighborhood, can contribute to or impede improvements in health.

Based on our experience, we propose that Healthy People 2030 objectives for Physical Activity and Nutrition and Weight Status take into account the effect of environmental factors, i.e., “place,” on health and develop indicators accordingly.

Environmental factors—such as proximity and accessibility to a park or open space, the safety (or perceived safety) of those places, effective signage and visual cues (wayfinding), and streetscaping activities such as Complete Streets[1]—can play a significant role in an individual’s level of physical activity. For the Physical Activity objective, we recommend adding an indicator that captures the ease with which a person can access parks and open spaces. In developing a measure of park accessibility, a generally accepted rule of thumb is that a quarter-mile proximity is a reasonable walking distance to a park.[2] We also suggest adding an indicator of the availability of safe places to be physically active. Ensuring public safety is a necessary precursor to encouraging use of public and open spaces. Additional environmental indicators that may be informative for ODPHP in finalizing the Healthy People 2030 objectives include:

  • density of recreational facilities;
  • availability of shared-use community facilities (such as school gyms);
  • availability of outdoor recreational space; and
  • implementation of streetscape policies to promote physical activity, such as Complete Streets.

With regard to healthy eating, we have invested in a range of environmental strategies, such as increasing the number of healthy food outlets like farmers markets, and promoting more procurement and visible display of healthier foods by retailers. Our experience affirms that it is critically important to address affordability challenges that can inhibit the consumption of healthier foods. Therefore, we support food incentive programs like Double Up Food Bucks, which increases the purchasing power of SNAP beneficiaries by providing a 1:1 match when SNAP dollars are used to purchase fruits and vegetables at farmers markets.[3]

With this experience in mind, we propose that ODPHP add indicators to the Nutrition and Weight Status objective that capture an individual’s proximity to an accessible healthy food outlet and the ability to use food incentive programs to facilitate the purchase of a healthier diet that includes dark green vegetables, whole grains, and fruits.

Where we live affects our health in multiple and complex ways. Poor health indicators are concentrated in neighborhoods that are most disadvantaged by society’s social, economic, and housing inequities. Communities that have been neglected, rural communities, and communities of color face a disproportionately high burden of chronic diseases like obesity and diabetes.

Research confirms that residents who live within a quarter-mile of a park experience better mental health,[4] that frequency of exercise and the use of parks by adults and children are both associated with park proximity,[5],[6] and that living in close proximity to outlets that sell fresh produce is associated with increased fruit and vegetable intake.[7] Healthy People 2030 can reduce these neighborhood-level health disparities and advance the nation’s health by including core objectives focused on increasing access to and demand for affordable, nutritious foods and expanding access to safe places where residents can be more physically active.

Respectfully submitted,

David Sandman, Ph.D.
President and CEO
New York Health Foundation

[1] National Complete Streets Coalition. “Health: Benefits of Complete Streets.”

[2] Yang, Y., Diez-Roux, A. Walking Distance by Trip Purpose and Population Subgroups. American Journal of Preventive Medicine. July 2012; 43(1): 11–19.

[3] Double Up Food Bucks NYS: How it Works.

[4]  Sturm, R. and Cohen, D.  Proximity to Parks and Mental Health. Journal of Mental Health Policy Econ. March 2014; 17(1): 19–24.

[5] Cohen, D. et al. Contribution of Public Parks to Physical Activity. American Journal of Public Health. March 2007; 97(3): 509–514.

[6] Gordon-Larsen, P. et al. Determinants of Adolescents Physical Activity and Inactivity Patterns. Pediatrics. June 2000; 105(6) E83.

[7] Fiechtner, L., et al. Effects of Proximity to Supermarkets on a Randomized Trial Studying Interventions for Obesity. American Journal of Public Health. March 2006; 106(3).

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