Draft Greater Cambridge Local Plan for consultation

On a wider point, where a site allocation does not make an explicit requirement for an on-site health facility, the specific site allocation wording should include reference to the need for mitigation through financial contributions (for health and other infrastructure) which aligns with the approach being taken through the IDP. This ensures that the to ensure that this is known at the policy stage, and can be considered by developers as they bring schemes forward.
We welcome the engagement with Council Officers during the early stages of plan preparation, and the opportunity to input into the Infrastructure Delivery Plan (process). We note that an additional assessment will be provided by the ICB as part of Stage 2 of the IDP process, which will include more targeted assessment of the key site allocations and overall health infrastructure requirements as part of this process, and would therefore provide more detail to each individual site allocation once this process has concluded.

Whilst all health partners are supportive of the general approach to increasing biodiversity and the positive links to health through this chapter, we have concerns over the implications of Paragraph 2 Policy BG/BG (Biodiversity and Geodiversity) when delivering new health infrastructure of all kinds. As currently drafted, this suggest all ‘non residential floorspace above 1,000 sqm or 0.5 hectares ‘must’ provide a minimum of 20% BNG. As drafted this requirement would apply to new health floorspace above these thresholds including primary care, neighbourhood health facilities and hospital developments. Whilst every effort will be made to maximise BNG on sites, and some schemes may be able to facilitate enhanced BNG provision above statutory requirements, it will not always be possible to deliver a 20% improvement whilst delivering against other priorities (e.g building capacity). Without flexibility in the application of this enhanced requirement, this has the potential to add significantly to the capital cost and complexity of delivering new health and other public sector infrastructure, without the ability to balance this against other significant public benefits that come from schemes which deliver wider public benefit.
We would request that new policy wording is included to specifically exempt the delivery of health and other public service infrastructure from this increased requirement, instead aligning with the Statutory BNG requirements.

Draft Policy CC/NZ sets out how new development can achieve net zero operational emissions, which includes Part D that allows for offsetting payments to be made to invest in additional renewable energy generation. NHSPS fully support policies that promote carbon neutral development, and the securing of financial contributions where on-site carbon mitigation requirements cannot be met. In considering the implementation of policies related to net zero, we would highlight that NHS property could benefit from carbon offset funds. This would support the NHS to reach the goal of becoming the world’s first net zero healthcare provider.

Draft Policy WS/HD sets out the Council’s commitment to making sure that new developments support healthy lifestyles and promote healthier lives through the built and natural environment. NHSPS support the inclusion of a standalone health policy that supports healthy lives. 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.
The use of health impact assessment is a useful tool to ensure planning applicants and the Local Planning Authority have the right information to make sound planning decisions in promoting healthy and safe communities. The Planning Practice Guidance supports the use of health impact assessments. NHSPS also supports the requirement for Health Impact Assessment to focus on major developments with potential for significant health impacts.

Draft Policy WS/NC sets out the requirements for the provision and delivery of new facilities through requiring the inclusion of or contribution towards the delivery of the services and facilities identified as necessary. Point 3 sets out that on-site delivery will be required of developments that are of a sufficient scale unless greater advantages can be demonstrated for the delivery of off-site facilities.
NHSPS recognises the requirement for consultation with relevant service providers to determine the most acceptable provision. We also welcome the inclusion of a specific section for healthcare facilities in the supporting paragraphs which highlights the approach to be taken to ensure the local health service needs are sufficiently met. In line with the below response (Policy I/ID), we would reiterate that healthcare providers should be given flexibility in determining the most suitable form of mitigation and strongly welcome the Council and developers to continue to engage with C&P ICB, or the successor body, at the earliest stages and throughout the planning process.
To ensure consistency in the approach to securing developer contributions for health infrastructure, we would also suggest the Council make reference to the emerging Planning Obligations SPD when relevant, in policy and/or supporting paragraphs. This clearly sets out the expected approach and methodology to be applied where contributions for additional healthcare infrastructure have been identified as being needed.

Draft Policy WS/CF focuses on the provision of new community facilities and redevelopment of existing community facilities. This includes the protection of existing community facilities and the requirement to demonstrate either criterions (a) to (c) under Point 5 to justify the loss of an existing or previously used community facility. NHSPS supports the provision of sufficient, quality community facilities but does not consider the proposed policy approach to be effective in its current form, particularly in relation to Point 5 of the policy. Where healthcare facilities are included within the Local’s Plan definition of community facilities, policies aimed at preventing the loss or change of use of community facilities and assets can potentially have a harmful impact on the NHS’s ability to ensure the delivery of essential facilities and services for the community.

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 sites and properties which are redundant or no longer suitable for healthcare for best value (open market value) is a critical component in helping to fund new or improved services within a local area. Requiring NHS disposal sites to explore the potential for alternative community uses and/or to retain a substantial proportion of community facility provision adds unjustified delay to vital reinvestment in facilities and services for the community.

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 does not 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 with no requirement for retention of a community facility use on the land or submission of onerous information. To ensure the Plan is positively prepared and effective, NHSPS are seeking the following modification (shown in red italics on attached document and summarised below) to Draft Policy WS/CF and supporting paragraphs to ensure the principle of alternative uses for NHS land and property will be fully supported:

Proposed Modification to Draft Policy WS/CF:
“[…]
6. The loss or redevelopment of school sites and educational facilities for other uses will only be permitted if it can be demonstrated that they are not required in the longer term for continued educational use.
<New Text Start> 7. The loss of healthcare facilities will only be permitted if it can be demonstrated that they are formally declared surplus to the operational healthcare requirements of the NHS or identified as surplus as part of a published estates strategy or service transformation plan.”
Proposed addition to Supporting Paragraphs:
“The loss of healthcare facilities will only be permitted if it can be demonstrated that they are formally declared surplus to the operational healthcare requirements of the NHS or identified as surplus as part of a published estates strategy or service transformation plan.” <New Text End>

Draft Policy I/ID sets out the overarching policy for ensuring development makes a positive contribution to sustainable growth through the delivery of appropriate infrastructure in a timely manner. Health infrastructure should be clearly identified in the Local Plan as essential infrastructure, with an expectation that development proposals will make provision to meet the cost of healthcare infrastructure made necessary by the development. In areas of significant housing growth, appropriate funding must be consistently leveraged through developer contributions for health and care services to mitigate the direct impact of growing demand from new housing. Additionally, the significant cumulative impact of smaller housing growth and the need for mitigation must also be considered by the Plan.
We also emphasise the importance of effective implementation mechanisms so that healthcare infrastructure is delivered alongside new development, especially for primary healthcare services as these are the most directly impacted by population growth associated with new development. The NHS, Council and other partners must work together to forecast the health infrastructure and related delivery costs required to support the projected growth and development across the Local Plan area. NHSPS recommend that the Local Plan have a specific section in the document that sets out the process to determine the appropriate form of developer contributions to health infrastructure, in line with the emerging Planning Obligations SPD. This would ensure that the assessment of existing healthcare infrastructure is robust, and that mitigation options secured align with NHS requirements and would ensure consistency in the approach to securing developer contributions for health infrastructure.
In line with Point 3 of draft Policy WS/NC and its supporting paragraph, we emphasise that the NHS and its partners will need to work with the Council in the formulation of appropriate mitigation measures. NHSPS welcomes that the Council continue to engage with the relevant Integrated Care Board (ICB) to add further detail within the Local Plan and supporting evidence base (Infrastructure Delivery Plan) regarding the process for determining the appropriate form of contribution towards the provision of healthcare infrastructure where this is justified. As set out in the draft Developer Contributions SPD, we suggest the inclusion of the following process:
• Assess the level and type of demand generated by the proposal.
• Work with the ICB to understand the capacity of existing healthcare infrastructure and the likely impact of the proposals on healthcare infrastructure capacity in the locality.
• Identify appropriate options to increase capacity to accommodate the additional service requirements and the associated capital costs of delivery.
• Identify the appropriate form of developer contributions.
Healthcare providers should have flexibility in determining the most appropriate means of meeting the relevant healthcare needs arising from a new development. Where new development creates 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 emphasised that the NHS and its partners will need to work with the Council in the formulation of appropriate mitigation measures.

In undertaking further work on local housing needs, 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.

The provision of adequate healthcare infrastructure is in our view critical to the delivery of sustainable development. We recommend the Council engage with the NHS, particularly the ICB, on an on-going basis as part of preparing the Infrastructure Delivery Plan (IDP).
Related to this, appropriate healthcare costs should be factored into the Local Plan Viability Assessment for relevant typologies. Such an approach 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 would ensure that healthcare mitigation is appropriately weighted when evaluating the potential planning obligations necessary to mitigate the full impact of a development. This is particularly important in situations where a viability assessment