Policy HW2 – Healthcare Infrastructure

Comment

Representation ID: 10587

Received: 19/08/2021

Respondent: Mr Ian Satterthwaite

The loss of capacity from the closure of many local hospitals is at odds with the exponentially rising population, also the concentration onto super hospitals makes access more difficult and means greater susceptibility to cross infections, and loss of resilience to the overwhelming of a single facility

Comment

Representation ID: 11783

Received: 08/10/2021

Respondent: Mr Gary Lambert

just want to know why arent you doing that already. we cant get doctor appointments now, its disgraceful yet you keep taking our council tax

Comment

Representation ID: 15101

Received: 01/10/2021

Respondent: Celine Labesse

With the over bearing need of developping house estates I worry about the lack of health infrastructures eg. GP practises, Hopsitals and of course the high need for staff that goes with it. New Schools and definitively many more special Schools should be considered inyo this growing picture of our communities. Workship places, parks and green spaces should be preserved or dedicated to newly builded areas, buse services considered, roads state maintained, roads safety throuroughly thought about and implementation of cycle lanes throughout the county.
I also would like to see old derelic buildings being rehabilitated, converted.

Support

Representation ID: 17544

Received: 11/10/2021

Respondent: Sport England

Sport England supports the reference in part 1d) of this policy to taking opportunities where they arise to co-locate healthcare facilities with facilities for sport to capture opportunities for social prescribing since this can bring about stronger outcomes for physical and mental well-being in line with the plan's objective. A good example of this is Portway Lifestyle Centre in Sandwell (case study link attached below). https://www.sportengland.org/know-your-audience/case-studies/portway-lifestyle-centre

Object

Representation ID: 18473

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 5.3 - "Contributions towards both the provision of acute NHS services and services provided by the CCG are not, as yet, universally verified as being compliant with the tests set out in the NPPF for lawful planning obligations."

Object

Representation ID: 18482

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 5.4 - "Criterion 5 refers to infrastructure contributions being sought on-site or its immediate vicinity. It will be wholly impractical for development of 11 dwellings to deliver infrastructure for healthcare on-site."

Comment

Representation ID: 21261

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy HW2 – Healthcare Infrastructure
The policy requires that major developments must be assessed against the capacity of existing healthcare facilities and where the development would have unacceptable impacts upon capacity then developers will be required to contribute to the provision or improvement of such facilities. Policy WSA2 states that appropriate local facilities, including local health facilities, should be delivered to support new residents and the existing area. Further clarity is required to confirm capacity of local facilities and whether existing facilities can be expanded or a new centre is required. If it is the latter, then further clarity if required to confirm the impact of providing a healthcare facility on site WSA2 to the net developable area. The wider implications of reducing the developable area of strategic sites will inevitably result in more housing being required to meet the needs of the BCA.

Comment

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.

Support

Representation ID: 22274

Received: 21/01/2022

Respondent: Miss Jodi Stokes

Healthcare Infrastructure

5.3 Part 3 of draft Policy HW2 (Healthcare Infrastructure) sets out that “proposals for major residential developments of ten units or more must be assessed against the capacity of existing healthcare facilities and/or services as set out in local development documents. Where the demand generated by the residents of the new development would have unacceptable impacts upon the capacity of these facilities, developers will be required to contribute to the provision or improvement of such services, in line with the requirements and calculation methods set out in local development documents”. We agree that this

policy requirement is reasonable, and that development that has an unacceptable impact of the capacity of these facilities should contribute to provision of improvement of these services. This is in line with the requirements of paragraphs 20 and 34 of the NPPF.

Comment

Representation ID: 23059

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy HW2 – Healthcare Infrastructure

The policy requires that major developments must be assessed against the capacity of existing healthcare facilities and where the development would have unacceptable impacts upon capacity then developers will be required to contribute to the provision or improvement of such facilities. Policy WSA9 states that appropriate local facilities, including local health facilities, should be delivered to support new residents and the existing area. Further clarity is required to confirm capacity of local facilities and whether existing facilities can be expanded or a new centre is required. If it is the latter, then further clarity if required to confirm the impact of providing a healthcare facility on site WSA9 to the net developable area.
The wider implications of reducing the developable area of strategic sites will inevitably result in more housing being required to meet the needs of the BC. Larger scale strategic allocations may be more appropriate to deliver education and health facilities. St Phillips have worked collaboratively with Taylor Wimpey (adjacent landowner to the south) to produce a combined masterplan to show the potential for community infrastructure delivery across a wider strategic development site, including the land to the west of Site WSA9 (Illustrative Masterplan attached with this submission). This site has the potential to deliver circa 800 dwellings, land for a new school, local centre/health facility and significant public open space including a country park. This wider proposal may also be of a scale that could support a new/improved bus service on Chester Road which would enhance the sustainability credentials of the existing settlement. The scale of the combined proposals gives rise to a more comprehensive opportunity than the constrained and fragmented proposition contained in the draft plan at present and would allow for the inclusion of significant community infrastructure.

Support

Representation ID: 23419

Received: 15/02/2022

Respondent: L&Q Estates

Agent: Barton Willmore

6.7 Draft Policy HW2 sets out the requirements for the provision of health infrastructure to serve the residents of new developments. Part 3 of Draft Policy HW2 emphasises that proposals for major residential developments must be assessed against the capacity of existing healthcare facilities and/or services as set out in local development documents.

6.8 We are supportive of this draft policy as it seeks to deliver appropriate local facilities to support residents and to enhance the sustainability of existing areas

Object

Representation ID: 43861

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

6.3 Policy HW2 deals with healthcare infrastructure. Amongst other things it identifies that all residential developments of 10 or more units must be assessed against the capacity of existing healthcare facilities. Where demand generated by residents of the new development would have unacceptable impacts upon the capacity of these facilities, developers would be required to contribute to the provision and improvement of such services.
6.4 It is the position of Taylor Wimpey that contributions towards both the provision of acute NHS services and services provided by the CCG are not, as yet, universally verified as being compliant with the tests set out in the NPPF for lawful planning obligations. As such the element of Policy HW2 relating to such contributions should be removed.
6.5 In addition, Criterion 5 refers to infrastructure contributions being sought on-site or its immediate vicinity. It would be wholly impractical for development of 11 dwellings to deliver infrastructure for healthcare on-site. In addition, it has been proved in a number of locations that where land is set aside to provide for new medical facilities, the delivery of these facilities has proved problematic, and the land becomes surplus. The delivery of specific medical facilities falls outside of the remit for most developers, particularly those engaged in house building. The policy should pay regard to these factors.
6.6 Whilst supporting paragraph 5.30 highlights that whilst many healthcare infrastructure projects will be delivered from mainstream NHS resources, contributions would also be secured through planning agreements in line with the relevant regulations in operation at the time. As stated above, there is some uncertainty as to whether contributions towards such facilities (NHS CCG services) are in accordance with the current CIL Regulations.
6.7 The policy and its supporting text refer to the 'sequential test'. It is unclear why the sequential test is being referred to in the context of the delivery of contributions towards healthcare whether it be on-site or off-site. In planning terms, a sequential test either relates to the location of development relative to areas of flood risk or town centres.
6.8 Paragraph 5.32 refers to the Viability and Delivery Study indicating that, depending on the extent of other planning obligations, contributions towards healthcare provision as required in the policy may not be viable. This contradicts the approach set out in the previous policy DEL1 which states that the Plan has been subject to a viability assessment to ensure policies are deliverable and the supporting text confirms (paragraph 4.21) that greenfield sites will be able to sustain the full range of planning obligations required. As set out above, depending on its site specific S106 requirements, it may well be the case that sites in Plan cannot deliver the full range of planning obligations.

Comment

Representation ID: 43935

Received: 11/10/2021

Respondent: IM Land

Agent: Turley Assocs

Policy HW2 (healthcare infrastructure)
3.39 Subject to there being an evidenced need, IM Land welcomes part 7 of this policy and
the requirement for onsite healthcare provision. Indeed potential provision is already
allowed for in the site’s illustrative masterplan. To satisfy NPPF paragraph 16 the policy
should only refer to an identified requirement, rather than a ‘likely requirement’,
which would render this part of the policy ambiguous.

Comment

Representation ID: 44931

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy HW2 - Healthcare Infrastructure

9.1 Part 3 of Policy HW2 states that proposals for major residential developments which would have unacceptable impacts upon the capacity of these facilities, developers will be required to contribute to the provision or improvement of such services, in line with the requirements and calculation methods set out in local development documents.

9.2 Part 7 notes that for strategic sites, the likely requirement for on-site provision for new health facilities is set out in Chapter 13. In this regard we note that Policy WSA.2 suggests that a local health centre will be required on the allocation.

9.3 The justification text to Policy HW2 [§5.32] states that depending on the extent of other planning obligations required, such contributions may not be viable on some sites. This appears to be inconsistent with §4.21 of the Draft BCP which states that greenfield sites and most brownfield sites will be able to sustain the full range of planning obligations required.

9.4 As this policy requirement will affect allocations in the BCP and will be used to inform infrastructure provision on these sites, Taylor Wimpey considers that these requirements and calculation methods should be identified in the BCP. This is the only way to ensure that the requirements of the policy are transparent and justified and can be appropriately tested through
the viability work which accompanies the plan.

Object

Representation ID: 44969

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

9.0 Policy HW2 - Healthcare Infrastructure
9.1 Part 3 of Policy HW2 states that proposals for major residential developments which would have
unacceptable impacts upon the capacity of these facilities, developers will be required to
contribute to the provision or improvement of such services, in line with the requirements and
calculation methods set out in local development documents.
9.2 Part 7 notes that for strategic sites, the likely requirement for on-site provision for new health
facilities is set out in Chapter 13. In this regard we note that Policy WSA.2 suggests that a local
health centre will be required on the allocation.
9.3 The justification text to Policy HW2 [§5.32] states that depending on the extent of other
planning obligations required, such contributions may not be viable on some sites. This appears
to be inconsistent with §4.21 of the Draft BCP which states that greenfield sites and most
brownfield sites will be able to sustain the full range of planning obligations required.
9.4 As this policy requirement will affect allocations in the BCP and will be used to inform
infrastructure provision on these sites, Taylor Wimpey considers that these requirements and
calculation methods should be identified in the BCP. This is the only way to ensure that the
requirements of the policy are transparent and justified and can be appropriately tested through
the viability work which accompanies the plan.

Object

Representation ID: 45867

Received: 11/10/2021

Respondent: St Modwen Developments Ltd

Agent: Planning Prospects Ltd

Comments on: Policy HW2 – Healthcare Infrastructure


Nature of comment: Objection


5.4 Part 6) of this policy provides that, “The effects of the obligations on the financial viability of development may be a relevant consideration.” This implies that there will be circumstances where viability is not a relevant consideration. That is not the case; it is always relevant, even if only to the extent that it proves a full contribution can be made.

5.5 To remedy this, the word “may be” in part 6) of Policy HW2 should be replaced by the word “is”.

Comment

Representation ID: 47038

Received: 13/09/2022

Respondent: HIMOR

Agent: Turley Associates

Subject to there being an evidenced need, HIMOR welcomes part 7 of this policy and the requirement for onsite healthcare provision. Indeed provision is already allowed for in the site’s illustrative masterplan. To satisfy NPPF paragraph 16 the policy should only refer to an identified requirement, rather than a ‘likely requirement’, which would render this part of the policy ambiguous.