Comment
Draft Black Country Plan
Representation ID: 21283
Received: 11/01/2022
Respondent: NHS Property Services
Introduction
Policy HW2 states that existing primary and secondary healthcare infrastructure and services will be protected. Whilst NHSPS supports the provision of healthcare infrastructure, the currently worded Policy HW2 fails to provide appropriate flexibility to NHS PS assets should these become surplus to NHS demand.
Context
Policy HW2 fails to address the need for flexibility within the NHS estate. NHSPS would advise the Council that policies aimed at preventing the loss or change of use of community facilities and assets, where healthcare is included within this definition, can have a harmful impact on the NHS’s ability to ensure the delivery of facilities and services for the community. Where such policies are overly restrictive, the disposal of surplus and unsuitable healthcare facilities for best value can be prevented or delayed.
The NPPF is clear in stating that Local Plans should adopt policies that “take into account and support the delivery of local strategies to improve health, social and cultural well -being for all sections of the community” (Paragraph 93b).
The policy currently fails to consider that some public service providers, such as the NHS, routinely undertake strategic reviews of their estates. Reviews of the NHS estate are aimed at improving the provision of healthcare services by increasing efficiencies, including through the disposal of unneeded and unsuitable properties. This means that capital receipts from disposals, as well as revenue spending that is saved, can be used to improve facilities and services.
Where it can be demonstrated that health facilities will be changed as part of a wider NHS estate reorganisation programme it should be accepted that a facility is neither needed nor viable for its current use.
With this in mind, we are keen to encourage that a greater level of flexibility be granted to t he NHS via modification of the wording of Policy HW2. This will ensure that the NHS can promptly and efficiently respond to the healthcare needs of the residents as they arise.