Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation

Thank you for the opportunity to comment on the above document. The following comments are submitted
by NHS Property Services (NHSPS) for and on behalf of NHS Cambridgeshire and Peterborough ICB (C&P
ICB). C&P ICB has delegated authority from NHS England for the commissioning of most NHS health
services in the Greater Cambridgeshire area. This includes consideration of estate requirements to deliver
these services.

General Comments on Health Infrastructure to Support Housing Growth
The delivery of new and improved healthcare infrastructure is resource intensive. The NHS as a whole is
facing significant constraints in terms of the funding needed to deliver healthcare services, and population
growth from new housing adds further pressure to the system. Residential developments often have very
significant impacts in terms of the need for additional healthcare provision for future residents, particularly
primary care. To ensure the delivery of necessary health infrastructure, it is essential that new development
makes a proportionate contribution to funding the health infrastructure needs arising from new homes.

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 ability to
continually review the healthcare estate, optimise land use, and deliver health services from modern facilities
is crucial. The health estate must be supported to develop, modernise, or be protected in line with integrated
NHS strategies. Planning policies should enable the delivery of essential healthcare infrastructure and be
prepared in consultation with the NHS to ensure they help deliver estate transformation.

Detailed Comments on draft Planning Obligations SPD
We support the inclusion of Chapter 22: Healthcare within the SPD and the provision of details of the means
in which the Council expects developers to mitigate the impact of development on local health provision. It
is noted that the SPD recognises the role of C&P ICB in assessing impact on local health infrastructure and
in determining how this is to be mitigated within the local estate. This sets a clear expectation of the provision
to be made for essential healthcare infrastructure through on-going engagement with the ICB as well as the
methodology that will be followed in determining required level of additional primary care provision will
support the effective implementation of the SPD.

Draft paragraph 22.23 details the standard wording to be used within the S106 Heads of Terms where a
financial contribution towards primary care is required. The final two sentences of this paragraph should not
form part of the standard wording example – appears that the document formatting has pulled this up into
the example wording.

To ensure that the SPD accurately reflects the provision and commissioning standards of C&P ICB, the
suggested wording amendments recommended to be made are (in red italics) as follows:

“22.23 Where a planning obligation is likely to be required, the applicant should indicate this
in any draft S106 Heads of Terms proposed. For applications where financial contributions
towards primary care are required, the following standard wording will generally be used:

• ‘Health Contribution: means the sum of £x (index linked) to be applied by the Cambridgeshire
& Peterborough Integrated Care Board (ICB) or subsequent successor body towards the
provision of additional primary care led capacity through the extension and/or remodelling of
[insert name of facility], or through the extension or remodelling of other facilities within the
local primary care networks (PCNs) – or subsequent successor - in which the development is
located, or through the extension and/or remodelling of other facilities that would specifically
provide services to serve the development <new paragraph added>

22.24 Expenditure of planning obligations related to primary care facilities will normally be
area-based on facility within the local PCN(s) serving the development. In limited
circumstances expenditure may be directed at a wider scale where this is deemed necessary
to support service delivery objectives.

22.25 For smaller schemes, to enable the required additional capacity to be in place…”

Conclusion
Health provision is an integral component of sustainable development – access to essential healthcare
services promotes good health outcomes and supports the overall social and economic wellbeing of an area.
We support the approach of the draft Planning Obligations SPD (Chapter 22) but consider the suggested
amendments above will contribute to ensuring the SPD reflects adopted health commissioning standards.