Greater Cambridge Local Plan: Proposed Submission

To ensure the policy supports the sustainable delivery of new healthcare infrastructure and other important public sector infrastructure, in line with our Regulation 18 response, we would request that new wording within policy or supporting paragraphs is included to specifically exempt the delivery of health and other public service infrastructure from this increased requirement. This would ensure continued alignment with the Statutory BNG requirements without impacting deliverability of key infrastructure.

Draft Policy BG/BG sets out the requirement for forms of development to deliver BNG in line with national and local requirements. Part 2 sets the requirement for major development to provide a minimum 20% BNG, beyond the statutory 10% BNG requirement. In line with the definitions within Appendix A, this would mean the minimum 20% BNG requirement would be applicable for non-residential floorspace above 1,000sqm or 0.5ha. As drafted, CE ICB reiterate our concern over the application of this requirement as this would include 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 service infrastructure, without the ability to balance this against other significant public benefits that come from schemes which deliver wider public benefit.
To ensure the policy supports the sustainable delivery of new healthcare infrastructure and other important public sector infrastructure, in line with our Regulation 18 response, we would request that new wording within policy or supporting paragraphs is included to specifically exempt the delivery of health and other public service infrastructure from this increased requirement. This would ensure continued alignment with the Statutory BNG requirements without impacting deliverability of key infrastructure.

Vision
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.

Healthy Planning
Draft Policy WS/HD sets out the Council’s commitment to making sure that new developments promote healthier lives and help reduce health inequalities through the built and natural environment. CE ICB 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.

Delivery of Healthcare Infrastructure
In ensuring development promotes health and wellbeing, Part 2(b) of the policy specifically requires the delivery of health facilities to meet the needs generated by the development. To support the delivery of health facilities, where there is an identified need, Part 3 further requires major development proposals to consider the aims of wider local and regional primary care and other health strategies. CE ICB welcome the requirement for development proposals to deliver healthcare facilities and support the additional requirement for major proposals to ensure alignment with wider strategic healthcare strategies.

CE ICB is a statutory body with responsibility for commissioning NHS health services. Alongside the need for alignment with wider primary care and health strategies, including the ICB’s estate strategies, we would highlight the need to engage with the ICB as early as possible on individual sites to discuss mitigation priorities.
This would support the sustainable delivery of new / additional healthcare infrastructure as and when it is needed. We would therefore recommend the inclusion of wording within the policy which clearly signposts the need for engagement with CE ICB as healthcare commissioners at an early stage in the planning and design process.

Health Impact Assessments
The use of health impact assessment is an important 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. It would be sensible for the Council to set out its own HIA requirement to help implement its strategic objective on healthy communities.
CE ICB support the use of Health Impact Assessment to focus on major developments with potential for significant health impacts – to consider both Health Infrastructure and the wider determinants of health in new developments at a much earlier stage in the planning process.

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, including health facilities (supporting paragraph 6.24). Part 2 seeks to ensure the scale and range of facility and service provision or contribution is proportionate to the level of need as generated by the development.

To ensure the requirement for additional healthcare infrastructure is accurately identified, CE ICB would highlight the need for early engagement with the ICB. This would ensure that the impact on existing healthcare service provision is robustly assessed and the required healthcare infrastructure mitigation is identified.

Point 3 further 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. CE ICB support this approach and emphasise 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 CE ICB 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 refer to the adopted 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.

Overall, we consider Draft Policy WS/NC to be positively prepared and effective and therefore sound.

Proposed Modification to Draft Policy [KM4.1][EM4.2]WS/CF: should be amended to (////amendments/////) - see attached marked up version
“[…]

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.

///// 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 Modification to Supporting Paragraph 6.54: should be amended to (////amendments/////) - see attached marked up version

“Alternatively, applicants will need to demonstrate, both quantitatively and qualitatively, that the facilities are surplus to requirements and that the proposal will not cause significant negative impacts on the vitality of other local facilities (such as through demand pressures created by displaced users of the lost facility). In most cases, this will require a marketing exercise for a sustained period of at least 12 months to demonstrate a lack of demand; exceptions to this requirement include the loss of educational and healthcare uses as the ongoing need for these facilities will need to be determined with the relevant Education Authorities or Health Authorities. The policy is applicable to existing facilities and sites last used for community, sports or leisure purposes to avoid situations where these facilities are lost through demolition without any planned replacement facility, but they are still needed. ///// Where healthcare facilities are declared surplus or identified as part of an estates strategy or service transformation plan where investment is needed towards modern, fit for purpose infrastructure and facilities, this will satisfy the requirements under Policy WS/CF.” /////

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 Part 5 to justify the loss of an existing or previously used community facility. CE ICB support the provision of sufficient, quality community facilities but does not consider the proposed policy approach to be positively prepared or effective in its current form in relation to Part 5 of the policy. [KM3.1]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.

We note the provision under supporting paragraph 6.54 which excludes healthcare uses from the requirement of a marketing exercise to sufficiently demonstrate the facility as surplus to requirements. However, we consider the policy does not provide sufficient flexibility or clarity which will allow sole demonstration of a healthcare facility being surplus to local healthcare requirements to fully justify the loss of the facility and meet the requirements under Part 5 of the policy. To ensure the amendments in supporting paragraph 6.54 is reflected and clarified in policy, we would request amendments to ensure healthcare facilities are given the same provisions as in the case of the loss of school sites and educational facilities (Part 6.).
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 that could delay investment. To ensure the Plan is positively prepared and effective, CE ICB are seeking the following modification (shown in red italics - see attached document) to Draft Policy WS/CF and supporting paragraphs.

CE ICB support the delivery of affordable housing in line with local need. As such, we support Policies S/GF and S/WNT which include the delivery of key worker housing. To support the implementation of this policy, [KM5.1]we suggest the Council consider the need for affordable housing (where there is an identified need) 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.

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. In the provision of the necessary infrastructure, Part 2 sets the requirement for alignment with the Infrastructure Delivery Plan. CE ICB further note the inclusion of healthcare facilities, with the expectation that development proposals will make provision to meet the cost of healthcare infrastructure made necessary by the development.

CE ICB support the requirement for infrastructure provision to be in accordance with the requirements set out within the IDP. As the ICB and wider health partners are in continued engagement with the Council in refining the healthcare infrastructure requirements in the IDP, Part 2 of the policy would ensure the delivery of healthcare infrastructure is consistent with updated NHS strategies and identified needs, facilitating a robust approach to healthcare infrastructure provision. In line with our comments above, we therefore reiterate the importance of the Plan making clear reference to the IDP and/or policies such as this, to ensure the effective implementation particularly of wider site allocation policies. We would also highlight that the IDP inputs are a ‘point in time’ assessment, and that NHS strategies and priorities may evolve over time, which is particularly important noting some of the larger strategic sites are not due to commence on site until the mid-2030s.

It is therefore essential that healthcare providers should have flexibility in determining the most appropriate means of meeting the relevant healthcare needs arising from a new development. Where new developments create 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, land/infrastructure/property (at nil cost to NHS), or a combination of these. Specific healthcare requirements on a site-by-site basis will be further provided within the IDP as the ICB continues to engage with the Council.

As drafted, we consider Draft Policy I/ID to be positively prepared and effective and therefore sound.

Evidence Base: Local Plan Viability Assessment
The draft policy requirements identified in the Plan are supported by the Main Viability Report (July 2026)/ Having reviewed the report, we note that where contributions towards healthcare have been identified in the policy requirements for site-specific testing, the assessment includes a specific allowance for contributions towards healthcare. The report tests a lump sum for S106 contributions of £45,500 per dwelling to cover site specific mitigation.

CE ICB welcome the inclusion of costs toward healthcare infrastructure within the S106 cost assumptions. This would ensure that healthcare mitigation is appropriately weighted when evaluating the potential planning obligations necessary to mitigate the full impact of a development.

A separate cost input for health also means that developers are adequately informed in advance, in accordance with ICB's estate strategy and the development's location and size, that they may be required to make on-site provision or off-site financial contributions to mitigate the impact on healthcare infrastructure resulting from their development. We consider the Council’s approach to support the effective implementation of Draft Policy I/ID in situations when a viability assessment demonstrates that development proposals are unable to fund the full range of infrastructure requirements.

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 support the level of growth proposed by the Plan.

As agreed with the Shared Planning Service, this Local Plan submission should be treated as an interim response while CE ICB, NHS Property Services and wider healthcare partners continue to work with the Shared Planning Service on the Infrastructure Delivery Plan (IDP) beyond the close of this consultation. Further detailed comments will be provided at later stages, where necessary, in line with the IDP’s findings.

We welcome the Council’s continued engagement with CE ICB in adding further detail to the approach regarding healthcare infrastructure provision to ensure that the assessment of existing healthcare infrastructure is robust, and the mitigation options secured align with NHS requirements.

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.

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.