Draft Greater Cambridge Health Impact Assessment Supplementary Planning Document

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 Health Impact Assessment SPD
The Health Impact Assessment SPD details the method of assessing the impacts of development on health
and wellbeing. We support the level of detail and guidance that has been provided within the draft SPD but
would note that the (currently in draft) Planning Obligations SPD has not been referenced to within the draft
Health Impact Assessment SPD.

Chapter 22 of the Planning Obligations SPD contains detailed guidance on the method to assessing impact
on local health provision. We would recommend that the Health Impact Assessment SPD clearly set out that
the guidance contained within the Planning Obligations SPD should be followed when assessing the capacity
of health infrastructure, to ensure that there is consistency within the local area when assessing impact on
health and wellbeing, specifically on healthcare provision.

Alongside the importance of consideration at the early stages, we would also recommend that there is
commitment to engagement with the Cambridge and Peterborough Integrated Care Board (C&P ICB) at the
early stages to accurately determine the potential impact of development on health provision and
infrastructure and enable the appropriate delivery of healthcare infrastructure. C&P ICB is the health
commissioning body within the Greater Cambridgeshire area and is therefore best placed to be able to
assess the likely impact of proposals on healthcare infrastructure capacity within the locality. These
amendments will ensure the Health Impact Assessment SPD provides sufficient detail to guide the method
of assessing the impact on local health and wellbeing.

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 Health Impact Assessment SPD but consider the suggested
amendments above will contribute to ensuring the SPD reflects adopted health commissioning standards
and that an accurate assessment of health infrastructure can be conducted.