Regulation 18 Draft Local Plan

Support

Representation ID: 1791

Received: 25/04/2024

Respondent: NHS Property Services

NHSPS fully support policies that promote carbon neutral development, and the securing of financial contributions where on-site carbon mitigation requirements cannot be met. In considering the implementation of policies related to net zero, we would highlight that NHS property could benefit from carbon offset funds. This would support the NHS to reach the goal of becoming the world’s first net zero healthcare provider.

Support

Representation ID: 1792

Received: 25/04/2024

Respondent: NHS Property Services

NHSPS fully support policies that promote carbon neutral development, and the securing of financial contributions where on-site carbon mitigation requirements cannot be met. In considering the implementation of policies related to net zero, we would highlight that NHS property could benefit from carbon offset funds. This would support the NHS to reach the goal of becoming the world’s first net zero healthcare provider. Support the inclusion of policies that support healthy lifestyles. Suggests the inclusion of a separate comprehensive policy on health and wellbeing in the Local Plan which includes guidelines and requirements for the implementation of Health Impact Assessment’s (HIAs), and encourage the Council to engage with the NHS on this matter ahead of the Regulation 19 document being prepared. Provides suggestions on specific policy requirements to promote healthy developments.

Support

Representation ID: 1793

Received: 25/04/2024

Respondent: NHS Property Services

NHSPS fully support policies that promote carbon neutral development, and the securing of financial contributions where on-site carbon mitigation requirements cannot be met. In considering the implementation of policies related to net zero, we would highlight that NHS property could benefit from carbon offset funds. This would support the NHS to reach the goal of becoming the world’s first net zero healthcare provider.

Object

Representation ID: 1794

Received: 25/04/2024

Respondent: NHS Property Services

Suggest the Council consider the need for affordable housing for NHS staff and those employed by other health and care providers in the local authority area.
Recommends that the Council:
• Engage with local NHS partners such as the local Integrated Care Board (ICB), NHS Trusts and other relevant Integrated Care System (ICS) partners.
• Ensure that the local need for affordable housing for NHS staff is factored into housing needs assessments, and any other relevant evidence base studies that inform the local plan (for example employment or other economic policies).
• Consider site selection and site allocation policies in relation to any identified need for affordable housing for NHS staff, particularly where sites are near large healthcare employers.

Object

Representation ID: 1795

Received: 25/04/2024

Respondent: NHS Property Services

Supports the provision of sufficient, quality community facilities but does not consider the proposed policy approach to be effective in its current form. To ensure the Plan is positively prepared and effective, NHSPS are seeking the following modification (below) to Draft Policy SP6 to ensure the principle of alternative uses for NHS land and property will be fully supported.

Where healthcare facilities 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, the requirements listed under Part D and E of the Policy will not apply.

Object

Representation ID: 1796

Received: 25/04/2024

Respondent: NHS Property Services

Welcomes the recognition of health infrastructure as essential infrastructure, with an expectation that development proposals will make provision to meet the cost of healthcare infrastructure made necessary by the development. Recommends that the Local Plan have a specific section in the document that sets out the process to determine the appropriate form of developer contributions to health infrastructure. The Local Plan should emphasise that the NHS and its partners will need to work with the Council in the formulation of appropriate mitigation measures. Recommends engaging with relevant Integrated Care Board (ICB) to add further detail within the Local Plan and supporting evidence base (IDP) regarding the process for determining the appropriate form of contribution towards the provision of healthcare infrastructure where this is justified. Provides suggestions to processes as a starting point.

Object

Representation ID: 1797

Received: 25/04/2024

Respondent: NHS Property Services

Recommends the Council engage with the NHS, particularly the ICB, on an on-going basis as part of preparing the Infrastructure Delivery Plan (IDP). A sound IDP must include sufficient detail to provide clarity around the healthcare infrastructure required to support growth, and to ensure that planning obligations effectively support and result in capital funding towards delivery of the required infrastructure. Related to this, appropriate healthcare costs should be factored into the Local Plan Viability Assessment for relevant typologies. Such an approach means that developers are adequately informed in advance that they may be required to make contributions towards healthcare infrastructure. A separate cost input for health infrastructure in the plan viability assessment would ensure that healthcare mitigation is appropriately weighted when evaluating the potential planning obligations necessary to mitigate the full impact of a development. This is particularly important in situations where a viability assessment demonstrates that proposals are unable to fund the full range of infrastructure requirements.