Part One: Spatial Strategy and Policies (Regulation 19)

Support

Representation ID: 1504

Received: 29/11/2024

Respondent: NHS Property Services Ltd

Draft Policy DLP6 requires that all new developments be supported by necessary infrastructure to meet their needs, minimize environmental and community impacts, and ensure sustainability. Development proposals will only be permitted if all required infrastructure and mitigation measures are provided, which will be secured through planning obligations, the Community Infrastructure Levy, or other mechanisms.

NHSPS supports the policy but requests continued collaboration with the NHS Integrated Care Board (ICB) to refine healthcare needs and solutions to match the planned growth. They emphasize that healthcare providers should have flexibility in addressing healthcare demands, including the possibility of new, purpose-built healthcare facilities. The NHS should work with the Council to develop appropriate mitigation measures, which could involve financial contributions, new infrastructure, or other forms of support.

Support

Representation ID: 1505

Received: 29/11/2024

Respondent: NHS Property Services Ltd

Draft Policy DLP8 sets out the Council’s commitment to making sure that new developments promote healthier lifestyles and improve overall health and wellbeing. NHSPS welcomes and supports the inclusion of policies that support healthy lifestyles, and the requirement for a full Health Impact Assessment for developments of 100 or more dwellings or non-residential development that extends to 5,000sqm or more, and a rapid Health Impact Assessment for developments of 20 to 100 dwellings or non-residential development that extends from 1,000 - 5,000sqm. There is a well-established connection between planning and health, and the planning system has an important role in creating healthy communities. 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.

Support

Representation ID: 1506

Received: 29/11/2024

Respondent: NHS Property Services Ltd

Draft Policy DLP9 aims to protect existing healthcare infrastructure, allowing for its loss only if part of a broader public service transformation plan. NHSPS supports the policy’s flexibility, particularly regarding the sale of redundant healthcare properties to fund new services. The policy also requires that major residential developments (10 or more units) assess the capacity of local healthcare facilities. If new development strains existing services, developers must contribute to healthcare provision, either on-site or off-site.

NHSPS welcomes the policy but requests continued collaboration with the NHS Integrated Care Board (ICB) to refine healthcare needs and solutions in line with the Local Plan’s growth. They emphasize that healthcare providers should have flexibility in meeting new demands, including the provision of purpose-built healthcare infrastructure, and that NHS partners should work with the Council on mitigation measures.

Comment

Representation ID: 1507

Received: 29/11/2024

Respondent: NHS Property Services Ltd

NHSPS supports Draft Policy DLP12 but suggests that the Council consider the need for affordable housing for NHS staff and other healthcare workers in the local area. The recruitment and retention of NHS staff depend on their ability to afford housing near their workplace. As new housing developments grow, there will be a need for more healthcare services, requiring a larger NHS workforce. NHSPS recommends that the Council:

- Engage with local NHS partners to assess housing needs for NHS staff.
- Factor the need for affordable housing for NHS staff into housing assessments and relevant studies.
- Consider site allocation policies for affordable housing near major healthcare employers to support workforce availability.

Comment

Representation ID: 1508

Received: 29/11/2024

Respondent: NHS Property Services Ltd

'Draft Policy DLP41 Increasing Efficiency and Resilience'

Draft Policy DLP41 sets out that development should be designed to mitigate climate change impacts and provide adaptations that will help communities and individuals to continue to avoid or mitigate adverse effects on human health. The NHS requires all new development projects to be net zero carbon, and NHSPS fully support policies that promote carbon neutral development. In considering the implementation of policies related to net zero, we would highlight that NHS property could benefit from carbon offset funds collected if one were to be introduced. This would support the NHS to reach the goal of becoming the world’s first net zero healthcare provider.

Comment

Representation ID: 1510

Received: 29/11/2024

Respondent: NHS Property Services Ltd

Evidence Base Local Plan Viability Assessment
The draft policy requirements identified in the Plan are supported by the Local Plan Viability Assessment. Having reviewed the Assessment, we note that it includes a specific allowance for S106 contributions towards health of £3,107 per home applied to typologies over 10 units. Healthcare facilities are currently experiencing significant strain. If appropriate mitigation is not secured, the growth strategy outlined in the Plan is expected to exacerbate this situation. Without prejudice to any future representations the NHS or its partners may make on specific planning applications with respect to S106 obligations or applications for CIL funding, in our view the S106 contribution allowance towards health is generally sufficient to enable suitable financial contributions to be secured for healthcare. Therefore, we consider that overall, the assessment of plan-wide viability demonstrates that policy requirements in relation to healthcare infrastructure contributions are deliverable. This would also ensure that healthcare mitigation is appropriately weighted when evaluating the potential planning obligations necessary to mitigate the full impact of a development.

Comment

Representation ID: 1512

Received: 29/11/2024

Respondent: NHS Property Services Ltd

Evidence Base Infrastructure Delivery Plan

The provision of adequate healthcare infrastructure is in our view critical to the delivery of sustainable development. A sound IDP must include sufficient detail to provide clarity around the healthcare infrastructure required to the level of growth proposed by the Plan, and to ensure that both planning obligations and the capital allocation process for the Community Infrastructure Levy (CIL) effectively support and result in capital funding towards delivery of the required infrastructure.
We welcome the engagement undertaken to date with the ICB and the detailed analysis of the potential impacts of new development on the proposed site allocations which has revealed specific areas of need.
To ensure that any mitigation options secured align with NHS requirements we suggest the following process (set out in red text below) for determining the appropriate form of contribution for the provision of healthcare infrastructure associated with new development is included in the IDP: Proposed addition to Section 6 of the Infrastructure Delivery Plan relating to Healthcare Infrastructure:
The requirement for a contribution towards healthcare infrastructure from new development will be determined by working with the ICB and other key stakeholders as appropriate, in accordance with the following process:
• Assessing the level and type of demand generated by the proposal.
• Working with the ICB to understand the likely impact of the proposals on healthcare infrastructure capacity in the locality.
• Identifying appropriate options to increase capacity to accommodate the additional service requirements and the associated capital costs of delivery.
• Identifying the appropriate form of developer contributions.