Support

Representation ID: 21284

Received: 11/01/2022

Respondent: NHS Property Services

Policy DEL1 states that unless material circumstances or considerations indicate otherwise, development proposals will only be permitted if all necessary infrastructure improvements, mitigation measures and sustainable design requirements and proposals are provided and /or can be phased to support the requirements of the proposed development. These will be secured through planning obligations, the Community Infrastructure Levy, planning conditions or other relevant means or mechanisms, to an appropriate timetable that is prioritised, resourced, managed, delivered and co-ordinated across the sub-region, where appropriate. NHSPS supports the policy.

Context
The NHS, Council and other partners must work together to forecast the infrastructure and costs required to support the projected growth and development across the borough. A vital part of this is ensuring the NHS continues to receive a commensurate share of s106 and Community Infrastructure Levy (CIL) developer contributions to mitigate the impacts of growth and help deliver transformation plans.

It is important the boroughs maximise opportunities to use planning obligations to secure healthcare infrastructure.

Paragraph 34 of The NPPF is clear that ‘Plans should set out the contributions expected from development. This should include setting out… infrastructure (such as that needed for… health) ’

Large residential developments often have very significant impacts in terms of the need for additional healthcare provision for future residents, meaning that a planning obligation requiring that the development delivers a new healthcare facility is necessary. The requirement that planning policies recognise the role development sites can play in delivering necessary health facilities is welcomed.

The significant cumulative impacts of smaller residential developments should also be welcomed, and health facilities should be put on a level footing with affordable housing and public transport improvements, given their strategic importance, when receiving funds.


We’d also make clear that whilst large sites have an important role to play in delivering necessary health infrastructure as a s106 in kind, the supporting test should acknowledge that a s106 in kind health facility provided as shell and core let to the NHS at a market rent is in fact a c ommercial arrangement and not a planning obligation.

It is imperative that planning policies are positively prepared, in recognition of their statutory duty to help finance improved healthcare services and facilities through effective estate management.

We suggest that when setting planning obligations policies, the Council should seek to address strategic as well as local priorities in planning obligations. In the instance where planning obligations cannot viably be supported by a specific development, then no priority should be stated, and each planning application should be addressed on its merits.

NHSPS therefore welcomes Policy DES1 and supports its inclusion in the Draft Black Country
Plan.