Part One: Spatial Strategy and Policies (Regulation 18)

Comment

Representation ID: 679

Received: 25/01/2024

Respondent: NHS Property Services Ltd

We support the general approach to infrastructure delivery set out within Policy DLP6, and welcome
the acknowledgement in paragraph 6.23 that additional GP consulting rooms may be required in
certain areas of the borough depending on the scale and nature of housing growth. To better reflect
the NHS Long Term Plan to develop integrated services locally, it would be preferable to refer to the
need for additional primary healthcare facilities rather the narrower focus on GP consulting rooms
as this does not reflect the full impact of population growth on healthcare services infrastructure in
the locality.
As set out above, given health infrastructure’s strategic importance to supporting housing growth
and sustainable development, it should be considered at the forefront of priorities for infrastructure
delivery. The provision of healthcare services to meet the needs of new residents is essential
infrastructure and should be given a significant amount of weight in decision-making. To ensure that
healthcare mitigation is appropriately weighted in situations when a viability assessment
demonstrates that development proposals are unable to fund the full range of infrastructure
requirements, healthcare facilities should be identified as a key priority in the supporting planning
documents and planning guidance referenced in part (3.) of the policy

Comment

Representation ID: 680

Received: 25/01/2024

Respondent: NHS Property Services Ltd

We support the focus of Policy DLP8 on ensuring that development promotes healthy communities,
and the requirement for Health Impact Assessment (HIA) on significant residential developers of 150
units or more. The planning system is critical not only to the provision of improved health services
and infrastructure by enabling health providers to meet changing healthcare needs, but also to
addressing the wider determinants of health.
Identifying and addressing the health requirements of existing and new development is a critical way
of ensuring the delivery of healthy, safe, and inclusive communities. We recommend the Council
continues to engage with the NHS partners on this matter, and suggest that the Council takes the
following recommendations into account when preparing the Publication version of the Plan.
Specific policy requirements to promote healthy developments should include:
• Development proposals to consider local health outcomes.
• Design schemes to encourage active travel, including through providing safe and attractive
walking and cycling routes, and ensuring developments are connected by these routes to local
services, employment, leisure, and existing walking and cycling routes.
• Provide access to healthy foods, including through access to shops and food growing
opportunities (allotments and/or providing sufficient garden space)
• Design schemes in a way that encourages social interaction, including through providing front
gardens, and informal meeting spaces including street benches and neighbourhood squares
and green spaces.
• Design schemes to be resilient and adaptable to climate change, including through SUDs,
rainwater collection, and efficient design.
• Consider the impacts of pollution and microclimates, and design schemes to reduce any
potential negative outcomes.
• Ensure development embraces and respects the context and heritage of the surrounding area.
• Provide the necessary mix of housing types and affordable housing, reflecting local needs.
• Provide sufficient and high quality green and blue spaces within developments.

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: 682

Received: 25/01/2024

Respondent: NHS Property Services Ltd

Part (3.) of the policy sets out minimum net densities that should be achieved based on the
accessibility standards in Table 8.2, including access to primary care, and paragraph 8.12 seeks
investment to improve identified gaps in service provision against the standards in Table 8.2. As per
our comments on Policy DLP9 Part (4.), healthcare providers should have flexibility in determining
the most appropriate means of meeting the relevant healthcare needs arising from a new
development. We recommend the Council liaise with the ICB and other appropriate stakeholders to
ensure that the implementation of Policy DLP11 aligns with ICB requirements.

Comment

Representation ID: 683

Received: 25/01/2024

Respondent: NHS Property Services Ltd

We suggest the Council consider the need for affordable housing for NHS staff and those employed
by other health and care providers in the local authority area. The sustainability of the NHS is largely
dependent on the recruitment and retention of its workforce. Most NHS staff need to be anchored at
a specific workplace or within a specific geography to carry out their role. When staff cannot afford
to rent or purchase suitable accommodation within reasonable proximity to their workplace, this has
an impact on the ability of the NHS to recruit and retain staff.
Housing affordability and availability can play a significant role in determining people’s choices about
where they work, and even the career paths they choose to follow. As the population grows in areas
of new housing development, additional health services are required, meaning the NHS must grow
its workforce to adequately serve population growth. Ensuring that NHS staff have access to suitable
housing at an affordable price within reasonable commuting distance of the communities they serve
is an important factor in supporting the delivery of high-quality local healthcare services. We
recommend that the Council:
• Engage with local NHS partners such as the local Integrated Care Board (ICB), NHS Trusts
and other relevant Integrated Care System (ICS) partners.
•
Ensure that the local need for affordable housing for NHS staff is factored into housing needs assessments, and any other relevant evidence base studies that inform the local plan (for example employment or other economic policies).
•
Consider site selection and site allocation policies in relation to any identified need for affordable housing for NHS staff, particularly where sites are near large healthcare employers.