Comment

Representation ID: 91

Received: 13/12/2023

Respondent: Mr Graham Wright

More Doctors & dental surgeries are required as are local amenities.
I remember when the Wordsley hospital site was developed that all these amenities were promised and still never delivered to this day.

Support

Representation ID: 109

Received: 19/12/2023

Respondent: Mr John Davison

installation of seating in public areas can support this. Lack of rest points (seats) can be a barrier to the infirm for venturing out.

Comment

Representation ID: 312

Received: 21/12/2023

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Policy DLP 9 Healthcare Infrastructure
Barberry acknowledge that in new residential development there may be a requirement to mitigate the impact of the development by providing additional healthcare infrastructure where there is an increase in demand on this. This can, however, be mitigated through the provision of additional capacity of existing GP surgeries or through the creation of new facilities secured by developer contributions of CIL as part of the planning application process. Clearly any obligations or contributions arising through new development would need to ensure that the development remains viable in order to deliver these and would need to be considered as part of an overall package of measures and policy aims to be set out in the Plan.

Comment

Representation ID: 379

Received: 21/12/2023

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Policy DLP 9 Healthcare Infrastructure
WL acknowledge that in new residential development there may be a requirement to mitigate the impact of the development by providing additional healthcare infrastructure where there is an increase in demand on this. This can, however, be mitigated through the provision of additional capacity of existing GP surgeries or through the creation of new facilities secured by developer contributions of CIL as part of the planning application process. Clearly any obligations or contributions arising through new development would need to ensure that the development remains viable in order to deliver these and would need to be considered as part of an overall package of measures and policy aims to be set out in the Plan.

Comment

Representation ID: 398

Received: 22/03/2024

Respondent: Home Builders Federation

Agent: Home Builders Federation

In relation to criteria three of this policy HBF would draw the Council’s attention to HBF would draw attention to the High Court Decision on R (on the application of the University Hospitals of Leicester NHS Trust) versus Harborough District Council. This has drawn into question the legitimacy of asking for develop contributions for acute healthcare that is funded through general taxation.

Support

Representation ID: 514

Received: 21/12/2023

Respondent: NHS Black Country Integrated Care Board

Agent: Winterburn Heritage & Planning

DLP9:
The ICB supports the Health and Wellbeing section of the Local Plan in its expression of stakeholders committing to change at a whole systems level and to working together to achieve a sustainable and resilient Dudley, with citizens involved at every level of governance for health and wellbeing. This can be achieved by determining the right proportion of resource that is committed to delivering prevention, treatment and care for health and wellbeing through the following:

The first priority should be to addressing the integration of health and care systems. It includes harnessing the available information and intelligence into a more complete picture. This will strengthen the relationships between the organisations involved, to develop more seamless and co-ordinated responses to health and wellbeing needs. It will also ensure that the community gets the best value and outcomes possible from the local health care economy and infrastructure.
A commitment to addressing improvements to the determinants of health within Dudley such as housing, education, employment, active lifestyles and transport.
Enabling a population that is equipped with the right skills to be informed about health, care and wellbeing and also be able to access and navigate systems to appropriate self-care or services for themselves and others.

In summarising the key health impacts identified through the Policy drafting process, the ICB is of the opinion that the Draft Dudley Local Plan makes a positive contribution to addressing the identified health issues. Policy DLP9 Healthcare Infrastructure in particular is supported for recognising the connection between housing development, local population change and their potential impact on the Primary and Secondary Healthcare Network.

DLP9(4)- Support

DLP9 (5)- In respect of DLP9 (5), it is acknowledged that developer contributions can affect the financial viability of certain developments and will therefore not always be appropriate or reasonable to apply. The ICB would not wish to support the imposition of a regime that would see the viability of development compromised by such contributions.
However, based on an independent viability assessment, the ICB suggests that developer contributions for Healthcare infrastructure could be deferred or discounted where this would not make the development unacceptable in planning terms. This would retain a degree of flexibility in applying the standard contributions/charges where affordability based on development viability is clearly demonstrated, without compromising the planning necessity for identified infrastructure and facilities.
Where developer contributions are deferred the ICB would support Dudley Council potentially applying clauses in Planning Obligations relating to deferred contributions, which will seek to recover all or part of the discount in circumstances where the financial climate and economic viability of the development improves. Here, any recaptured discount will be limited to the full standard developer contributions for the Healthcare infrastructure applicable at the time the planning obligation for a development was signed.

The ICB also supports paragraph 7.24 of the Supporting Text and its requirement for Applicants to consult the ICB in advance of the submission of a planning application where a significant amount of housing is to be provided.
The ICB also supports the intention to produce separate guidance as part of an SPD, on the methodology used for calculating the appropriate level of developer contributions.

Comment

Representation ID: 515

Received: 22/12/2023

Respondent: Medcentres PLC

DLP9
In our experience of developing primary care across the UK and locally, including supporting the ICB in respect of developing healthcare plans, this policy should include a specific requirement to identify and allocate sites suitable for primary care. This could include allowing exceptional development on greenbelt land.

A significant barrier to developing new NHS estate is both the physical availability of land, and the terms on which it is available (cost and timing).

Urban areas compound these problems with poor land availability in local centres, particularly as the strategic drive is to develop larger buildings that provide greater scale and efficiency and need to be supported by good access (and parking)

Object

Representation ID: 556

Received: 15/12/2023

Respondent: Dudley Group NHS Foundation Trust

Agent: Claremont Planning Consultancy

3.1. The draft Plan recognises within Chapter 7 the importance of health and wellbeing as a key objective of the Council, with the Council’s aim to achieve healthy inclusive and safe places that support healthy lifestyles to be supported by the Plan. The local NHS Foundation Trust plays a key role in supporting health and wellbeing in the Borough, however the draft Plan fails to recognise this.

3.2. The emerging Plan through Policy DLP8 and DLP9 fails to recognise the role that development can play in securing investment in health infrastructure. The Land at Corbett Hospital, promoted on behalf of the Dudley Group NHS Foundation Trust and Charles Church Homes, was the subject of a planning application which sought to secure permission for residential development
under application reference P22/1050. Despite the application’s refusal, it is maintained that the site is suitable and available to accommodate a form of residential development. The land is surplus to the NHS requirements, and as a result was included on the register of public sector land available for disposal in 2017, offered firstly to public sector bodies before being offered to the open market, and anticipated disposal was expected during 2021/22. Whilst the disposal has been delayed by the Council’s refusal of planning permission, it remains the case that the NHS is obliged by the Government to secure the disposal of the site and secure ‘best value’ at the earliest opportunity. The land is owned freehold by the Dudley Group NHS Foundation Trust, and as a result, once secured, 100% of net proceeds of the sale of the land at Corbett Hospital would be spent on the Dudley health economy.

3.3. It is therefore considered that this section of the Plan should be reviewed to acknowledge the role that the NHS Trust plays locally in respect of health infrastructure and identify support for releasing surplus land to support investment and secure the delivery of much needed homes on surplus land in the urban area. In particular, the Plan could support these aims through allocating the site at Corbett Hospital for residential development, enabling the disposal of this site and release of funds needed locally to support improvements to local services and infrastructure.

Object

Representation ID: 572

Received: 21/12/2023

Respondent: Charles Church Homes

Agent: Claremont Planning Consultancy

3.
Health and Wellbeing
Policy DLP8 and Policy DLP9
3.1.
The draft Plan recognises within Chapter 7 the importance of health and wellbeing as a key objective of the Council, with the Council’s aim to achieve healthy inclusive and safe places that support healthy lifestyles to be supported by the Plan. The local NHS Foundation Trust plays a key role in supporting health and wellbeing in the Borough, however the draft Plan fails to recognise this.
3.2.
The emerging Plan through Policy DLP8 and DLP9 fails to recognise the role that development can play in securing investment in health infrastructure. The Land at Corbett Hospital, promoted on behalf of the Dudley Group NHS Foundation Trust and Charles Church Homes, was the subject of a planning application which sought to secure permission for residential development
under application reference P22/1050. Despite the application’s refusal, it is maintained that the site is suitable and available to accommodate a form of residential development. The land is surplus to the NHS requirements, and as a result was included on the register of public sector land available for disposal in 2017, offered firstly to public sector bodies before being offered to the open market, and anticipated disposal was expected during 2021/22. Whilst the disposal has been delayed by the Council’s refusal of planning permission, it remains the case that the NHS is obliged by the Government to secure the disposal of the site and secure ‘best value’ at the earliest opportunity. The land is owned freehold by the Dudley Group NHS Foundation Trust, and as a result, once secured, 100% of net proceeds of the sale of the land at Corbett Hospital would be spent on the Dudley health economy.
3.3.
It is therefore considered that this section of the Plan should be reviewed to acknowledge the role that the NHS Trust plays locally in respect of health infrastructure and identify support for releasing surplus land to support investment and secure the delivery of much needed homes on surplus land in the urban area. In particular, the Plan could support these aims through allocating the site at Corbett Hospital for residential development, enabling the disposal of this site and release of funds needed locally to support improvements to local services and infrastructure.

Comment

Representation ID: 681

Received: 25/01/2024

Respondent: NHS Property Services Ltd

We support Part (1.) of the policy in relation to the requirements for new healthcare facilities.
We are generally supportive of Part (2.) of the policy relating to existing healthcare infrastructure
and services, as this acknowledges that the NHS is required to ensure land and property is used
efficiently. The NHS requires flexibility with regards to the use of its estate to deliver its core objective
of enabling excellent patient care and support key healthcare strategies such as the NHS Long Term
Plan. In particular, the disposal of redundant or no longer healthcare suitable sites and properties
for best value (open market value) is a critical component in helping to fund new or improved services
within a local area.
All NHS land disposals must follow a rigorous process to ensure that levels of healthcare service
provision in the locality of disposals are maintained or enhanced, and proceeds from land sales are
re-invested in the provision of healthcare services locally and nationally. The decision about whether
a property is surplus to NHS requirements is made by local health commissioners and NHS England.
Sites can only be disposed of once the operational health requirement has ceased. This doesn’t
mean that the healthcare services are no longer needed in the area, rather it means that there are
alternative provisions that are being invested in to modernise services.
Where it can be demonstrated that health facilities are surplus to requirements or will be changed
as part of wider NHS estate reorganisation and service transformation programmes, it should be
accepted that a facility is neither needed nor viable for its current use, and policies within the Local
Plan should support the principle of alternative uses for NHS sites. We therefore recommend that
the wording of Part (2.) be refined to provide additional clarification about how the policy will be
interpreted:
Proposed clarification to Part (2.) of Policy DLP9:
Where healthcare facilities are declared surplus or identified as part of an estates strategy or
service transformation plan where investment is needed towards modern, fit for purpose
infrastructure and facilities, there will be no requirement to retain any part of the site in a healthcare
use.
We support Part (3.) of the policy that requires major residential development to assess the capacity
of existing healthcare facilities/services and required developers to contribute to the provision of
improvement of services when the demand generated by the residents of the new developer would
have unacceptable impacts on the capacity of these facilities. We note that paragraph 7.24 refers to
an established method adopted by the ICB, and would recommend that the Council add further detail
to the approach regarding primary healthcare provision within the supporting text to ensure that the
assessment of existing healthcare infrastructure is robust, and the mitigation options secured align
with NHS requirements.
Part (4.) of the policy prioritises identified infrastructure contributions on site in the site’s immediate
vicinity. To align with the NHS Long Term Plan, healthcare providers should have flexibility in
determining the most appropriate means of meeting the relevant healthcare needs arising from a
new development. Where new developments create a demand for health services that cannot be
supported by incremental extension or internal modification of existing facilities, this means the
provision of new purpose-built healthcare infrastructure will be required to provide sustainable health
services. Options should enable financial contributions, new-on-site healthcare infrastructure, free
land/ infrastructure /property, or a combination of these. It should be clarified that the NHS and its
partners will need to work with the council in the formulation of appropriate mitigation measures.
In relation to Part (5.) of the policy Paragraph 7.25 refers to the potential to seek alternative funding
sources where it can be proved that it is not viable for a housing developer to fund all its own
healthcare needs. Please refer to our comments on Policy DLP6 in relation to the need to ensure
that healthcare is appropriately prioritised when viability is an issue. Having reviewed the Viability
Assessment published alongside the draft Plan, we note that relevant healthcare costs have been
factored into the appraisals for the relevant typologies. We are supportive of this approach because
it means that developers are adequately informed in advance that they may be required to make
contributions towards healthcare infrastructure. A separate cost input for health infrastructure in the
plan viability assessment should ensure that healthcare mitigation is appropriately weighted when
evaluating the potential planning obligation necessary to mitigate the full impact of a development.

Comment

Representation ID: 858

Received: 21/12/2023

Respondent: McCarthy Stone

Agent: The Planning Bureau Limited

For the plan to be in line with national policy and effective the following text should be added to policy
DLP9:
Specialist housing to meet the needs of older peoples have a number of health benefits to residents
and cost saving to health providers and therefore schemes delivering specialist housing for older
people do not need to be assessed against the requirements of Policy DLP9.