Draft Black Country Plan

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: 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.