Greater Cambridge Local Plan: Proposed Submission

Thank you for the opportunity to comment on the above document. The following representations are submitted by NHS Property Services (NHSPS) for and on behalf of Central East Integrated Care Board (CE ICB).

As agreed with the Shared Planning Service, this Local Plan response should be considered as an ‘interim’ response in light of CE ICB’s, NHS Property Services and wider healthcare partners continued engagement with the Shared Planning Service in preparing the Infrastructure Delivery Plan (IDP), which will continue after the close of this consultation. Further detailed comments, where needed, will be provided at later stages in line with the IDP outputs.


Central East ICB (CE ICB)

CE ICB is a statutory body with responsibility for commissioning NHS health services, and serves approximately 3.5 million people across Cambridgeshire, Peterborough, Bedfordshire, Luton, Milton Keynes, and Hertfordshire. With our population living longer but with a growing challenge of long-term illness, widening inequalities linked to deprivation, our role is to manage the clinical and financial risk for the 3.5 million people we serve, ensuring that the right health interventions are in place to improve lives, reduce avoidable harm, and use public resources responsibly.
CE ICB has produced a five-year Strategy called ‘Our Way’, published on 1st April 2026, which sets out a five-year approach to health commissioning, built on improving quality in terms of access to, experience of, outcomes of, and effectiveness of health services, with quality being the mechanism through which the CEICB will deliver a sustainable NHS for the population it serves.
Integral to CE ICB’s five-year Strategy is neighbourhood health which focuses on delivering joined up, local, preventative care at a neighbourhood level. Primary and community health services will act as the anchor of neighbourhood delivery, providing continuity, proactive management of long-term conditions, and coordination across the NHS, social care, local authorities and the voluntary sector, integrated around people and places. CEICB is working with partners to develop Neighbourhood Health Plans, alongside more detailed Primary Care Action Plans which will be published later this year.

As commissioners of NHS services for our area, we work with local people and communities and use information and insights to make clear decisions about the services that are needed, the outcomes we expect and the quality of care that people should expect to receive. We work closely with other health, care, voluntary sector and community organisations. Together, we aim to improve lives and keep the NHS strong for the future.

NHS Property Services

NHS Property Services (NHSPS) manages, maintains and improves NHS properties and facilities, working in partnership with NHS organisations to create safe, efficient, sustainable and modern healthcare environments. We partner with local NHS Integrated Care Boards (ICBs) and wider NHS organisations with planning and managing their estates for best patient outcomes. NHSPS is part of the NHS and is wholly owned by the Department of Health and Social Care (DHSC) – all surplus funds are reinvested directly into the NHS to tackle the biggest estates challenges including space utilisation, quality, and access with the core objective to enable excellent patient care.

CE ICB support the Vision for Greater Cambridge, with the seven strategic priorities highlighting the important role that both health infrastructure and healthy planning, design and placemaking principles have on achieving the Local Plan vision.

Delivering new and improved healthcare infrastructure requires substantial resources. The NHS already faces significant funding constraints, while population growth from new housing places additional pressure on services. New development should therefore contribute proportionately to the healthcare infrastructure it necessitates. As an essential element of sustainable development, access to healthcare improves health outcomes and supports an area’s social and economic wellbeing.

Residential developments often have very significant impacts in terms of the need for additional health infrastructure provision for future residents. 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 and modernise 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.

Our detailed comments set out below are focused on ensuring that the needs of the health service are embedded into the Local Plan in a way that supports sustainable growth. When updating or developing any additional guidance to support implementation of Local Plan policies relevant to health, for example in relation to developer contributions or health impact assessments, we would request the Council engage the NHS in the process as early as possible.

Draft Policy S/JH: New Jobs and Homes
Draft Policy S/JH seeks to deliver a minimum of 48,069 new homes throughout the plan period. To ensure the required healthcare infrastructure is delivered to support the delivery of new homes we would highlight that in areas of significant housing growth, new healthcare infrastructure and 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.

In line with our comments below under Section 3, draft Policies WS/HD, WS/NC and I/ID, we would recommend the Council engage as early as possible with CE ICB on key strategic sites. Overall, we consider draft Policy S/JH to be sound.

Draft Policy S/JH seeks to deliver a minimum of 48,069 new homes throughout the plan period. To ensure the required healthcare infrastructure is delivered to support the delivery of new homes we would highlight that in areas of significant housing growth, new healthcare infrastructure and 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.

In line with our comments below under Section 3, draft Policies WS/HD, WS/NC and I/ID, we would recommend the Council engage as early as possible with CE ICB on key strategic sites. Overall, we consider draft Policy S/JH to be sound.

To ensure there is clarity at an early stage for applicants, and to ensure consistency, we would recommend that each of the draft site allocations make clear reference to the IDP either in policy or in supporting paragraphs or linked to relevant policies within the Local Plan.

Addittional comments are provided on specific site allocations

Section 3: Proposed Site Allocations 3.1-3.5

Reference to Infrastructure Delivery Plan

To deliver the aims of draft Policy S/JH and key sites identified within draft Policy S/DS, Section 3 sets out the site allocations proposed to contribute to the delivery of new homes within the plan period. Alongside the delivery of a significant number of new homes as allocated under Sections 3.1 to 3.5, CE ICB highlight the need to ensure this is effectively supported by the necessary healthcare infrastructure.
We would highlight that the ICB and wider health partners have engaged positively with the Councils and Shared Planning Service in relation to the Infrastructure Delivery Plan (IDP) at multiple stages, providing inputs assessing the impact of planned growth on healthcare infrastructure and the mitigation measures likely to be required to support the scale and location of growth set out in the Local Plan. CE ICB note, with the exception of the sites identified below, the site allocation requirements do not consistently reflect the need for proposals to be aligned with the IDP, nor do these make clear reference to relevant policies which set out the requirement for alignment with the IDP.

To ensure there is clarity at an early stage for applicants, and to ensure consistency, we would recommend that each of the draft site allocations make clear reference to the IDP either in policy or in supporting paragraphs or linked to relevant policies within the Local Plan.

Identified Provision of Healthcare Facilities

The draft Site Allocation policies identified below reference the supporting 2026 IDP regarding the delivery of the required supporting infrastructure, including the requirement for healthcare facilities. Whilst we support clear reference to the IDP, we note some of the draft Site Allocation policies go further and specify the form of healthcare mitigation required to be delivered alongside the site allocation (e.g. Health Hub).
As Strategic Health Commissioners, the ICB are continuing to engage with the Council in refining the local healthcare infrastructure requirements as part of the IDP, and these are subject to change as NHS delivery models and guidance emerge and change over time. This is particularly important noting some of the larger strategic sites are not expected to commence until the mid-2030s. It is therefore essential that the ICB and wider NHS partners have the flexibility to decide the most appropriate form of healthcare infrastructure mitigation at the point the sites come forward. To ensure the Plan is positively prepared and effective and supports the delivery of the most suitable form of healthcare infrastructure, we would request some minor amendments to policy requirements in line with the below table. This will support a co-ordinated approach to delivering the required healthcare infrastructure in line with ICB strategic direction.
- Suggested minor amendments in red below against relevant site allocations

Supporting Paragraph 3.2.9 - should be amended to (////amendments/////) - see attached marked up version

In addition to the above, the Greater Cambridge Infrastructure Delivery Plan (IDP) (2026) has identified that the site will require: two new primary schools with integrated nurseries; two new secondary schools; ////new healthcare infrastructure provision (as confirmed through engagement with local and regional health stakeholders)////, approximately 1,250 square metres community space, and 440 square metres library space to be delivered as a key library; a fire operational drop off point; and a sports hall (4 badminton court sizes), to support the delivery of the site during the plan period and beyond. The exact quantum and phasing of infrastructure will need to be kept under review as the development comes forward, including phases beyond the plan period. This should be informed by on-going engagement with statutory bodies and undertakers.

Identified Provision of Healthcare Facilities
The draft Site Allocation policies identified below reference the supporting 2026 IDP regarding the delivery of the required supporting infrastructure, including the requirement for healthcare facilities. Whilst we support clear reference to the IDP, we note some of the draft Site Allocation policies go further and specify the form of healthcare mitigation required to be delivered alongside the site allocation (e.g. Health Hub).
As Strategic Health Commissioners, the ICB are continuing to engage with the Council in refining the local healthcare infrastructure requirements as part of the IDP, and these are subject to change as NHS delivery models and guidance emerge and change over time. This is particularly important noting some of the larger strategic sites are not expected to commence until the mid-2030s. It is therefore essential that the ICB and wider NHS partners have the flexibility to decide the most appropriate form of healthcare infrastructure mitigation at the point the sites come forward. To ensure the Plan is positively prepared and effective and supports the delivery of the most suitable form of healthcare infrastructure, we would request some minor amendments to policy requirements in line with the below table. This will support a co-ordinated approach to delivering the required healthcare infrastructure in line with ICB strategic direction.

Draft Policy S/ED – Part 3(e) - should be amended to (////amendments/////) - see attached marked up version

“3. Eddington is allocated for mixed-use development that will provide:
[…]
/////e. Addittional healthcare infrastructure provision (as confirmed through engagement with local and regional health stakeholders)///// to meet the needs generated by the development;

Identified Provision of Healthcare Facilities
The draft Site Allocation policies identified below reference the supporting 2026 IDP regarding the delivery of the required supporting infrastructure, including the requirement for healthcare facilities. Whilst we support clear reference to the IDP, we note some of the draft Site Allocation policies go further and specify the form of healthcare mitigation required to be delivered alongside the site allocation (e.g. Health Hub).
As Strategic Health Commissioners, the ICB are continuing to engage with the Council in refining the local healthcare infrastructure requirements as part of the IDP, and these are subject to change as NHS delivery models and guidance emerge and change over time. This is particularly important noting some of the larger strategic sites are not expected to commence until the mid-2030s. It is therefore essential that the ICB and wider NHS partners have the flexibility to decide the most appropriate form of healthcare infrastructure mitigation at the point the sites come forward. To ensure the Plan is positively prepared and effective and supports the delivery of the most suitable form of healthcare infrastructure, we would request some minor amendments to policy requirements in line with the below table. This will support a co-ordinated approach to delivering the required healthcare infrastructure in line with ICB strategic direction.

Policy S/CBN: Cambourne North Draft Policy S/CBN – Part 12(c)(i) - should be amended to (////amendments/////) - see attached marked up version:

[…]
c. Community services and facilities and infrastructure provision including:
/////i. New healthcare infrastructure provision as confirmed through ///// engagement with local and regional health stakeholders

Identified Provision of Healthcare Facilities
The draft Site Allocation policies identified below reference the supporting 2026 IDP regarding the delivery of the required supporting infrastructure, including the requirement for healthcare facilities. Whilst we support clear reference to the IDP, we note some of the draft Site Allocation policies go further and specify the form of healthcare mitigation required to be delivered alongside the site allocation (e.g. Health Hub).
As Strategic Health Commissioners, the ICB are continuing to engage with the Council in refining the local healthcare infrastructure requirements as part of the IDP, and these are subject to change as NHS delivery models and guidance emerge and change over time. This is particularly important noting some of the larger strategic sites are not expected to commence until the mid-2030s. It is therefore essential that the ICB and wider NHS partners have the flexibility to decide the most appropriate form of healthcare infrastructure mitigation at the point the sites come forward. To ensure the Plan is positively prepared and effective and supports the delivery of the most suitable form of healthcare infrastructure, we would request some minor amendments to policy requirements in line with the below table. This will support a co-ordinated approach to delivering the required healthcare infrastructure in line with ICB strategic direction.

Supporting Paragraph 3.3.33 - should be amended to (////amendments/////) - see attached marked up version

“The Greater Cambridge Infrastructure Delivery Plan (IDP) (2026) has identified that the site, in combination with Cambourne North, will require the delivery of or financial contributions towards: Upgrade to increase capacity at Uttons Drove WRC, two new primary schools with integrated nurseries; one 8FE secondary school, ///// additional healthcare infrastructure provision (as confirmed through engagement with local and regional health stakeholders) /////, approximately 983 square metres community space, 342 square metres library space to be delivered as a hub library; provision of 206 square metres of swimming pools, a sports hall (four badminton court sizes), and a range of outdoor sports pitches to support the delivery of the site during the plan period and beyond. The exact quantum and phasing of infrastructure will need to be kept under review as the development comes forward, including phases beyond the plan period. This should be informed by on-going engagement with statutory bodies and undertakers.

Identified Provision of Healthcare Facilities
The draft Site Allocation policies identified below reference the supporting 2026 IDP regarding the delivery of the required supporting infrastructure, including the requirement for healthcare facilities. Whilst we support clear reference to the IDP, we note some of the draft Site Allocation policies go further and specify the form of healthcare mitigation required to be delivered alongside the site allocation (e.g. Health Hub).
As Strategic Health Commissioners, the ICB are continuing to engage with the Council in refining the local healthcare infrastructure requirements as part of the IDP, and these are subject to change as NHS delivery models and guidance emerge and change over time. This is particularly important noting some of the larger strategic sites are not expected to commence until the mid-2030s. It is therefore essential that the ICB and wider NHS partners have the flexibility to decide the most appropriate form of healthcare infrastructure mitigation at the point the sites come forward. To ensure the Plan is positively prepared and effective and supports the delivery of the most suitable form of healthcare infrastructure, we would request some minor amendments to policy requirements in line with the below table. This will support a co-ordinated approach to delivering the required healthcare infrastructure in line with ICB strategic direction.

Draft Policy S/GF – Part 11(h) - should be amended to (////amendments/////) - see attached marked up version

“11. Development proposals must make a positive and meaningful contribution to the creation of a fully functional, self-contained new settlement. To achieve this, the site is allocated for mixed use development comprising:
[…]
///// h. New healthcare infrastructure provision (as confirmed through engagement with local and regional health stakeholders) ///// to meet the needs of the development;

Identified Provision of Healthcare Facilities
The draft Site Allocation policies identified below reference the supporting 2026 IDP regarding the delivery of the required supporting infrastructure, including the requirement for healthcare facilities. Whilst we support clear reference to the IDP, we note some of the draft Site Allocation policies go further and specify the form of healthcare mitigation required to be delivered alongside the site allocation (e.g. Health Hub).
As Strategic Health Commissioners, the ICB are continuing to engage with the Council in refining the local healthcare infrastructure requirements as part of the IDP, and these are subject to change as NHS delivery models and guidance emerge and change over time. This is particularly important noting some of the larger strategic sites are not expected to commence until the mid-2030s. It is therefore essential that the ICB and wider NHS partners have the flexibility to decide the most appropriate form of healthcare infrastructure mitigation at the point the sites come forward. To ensure the Plan is positively prepared and effective and supports the delivery of the most suitable form of healthcare infrastructure, we would request some minor amendments to policy requirements in line with the below table. This will support a co-ordinated approach to delivering the required healthcare infrastructure in line with ICB strategic direction.

Draft Policy C/NZ seeks to ensure new development achieve net zero operational emissions. The NHS requires all new development projects to be net zero carbon, and CE ICB fully support policies that promote carbon neutral development. In considering the implementation of policies related to net zero and in line with our response at Regulation 18 stage, we would highlight that NHS infrastructure could benefit from carbon offset funds collected where on-site carbon mitigation requirements cannot be met. This would support the NHS to reach the goal of becoming the world’s first net zero healthcare provider.

As such, we consider Draft Policy CC/NZ to be sound.