Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 26461

Received: 22/07/2024

Respondent: NHS Property Services

General Comments on Health Infrastructure to Support Housing Growth
The delivery of new and improved healthcare infrastructure is significantly resource intensive. The
NHS as a whole is facing significant constraints in terms of the funding needed to deliver healthcare
services, and population growth from new housing development adds further pressure to the system.
New development should make a proportionate contribution to funding the healthcare needs arising
from new development. Health provision is an integral component of sustainable development –
access to essential healthcare services promotes good health outcomes and supports the overall
social and economic wellbeing of an area.
Residential developments often have very significant impacts in terms of the need for additional
primary healthcare provision for future residents. Given health infrastructure’s strategic importance
to supporting housing growth and sustainable development, it should be considered at the forefront
of priorities for infrastructure delivery. The ability to continually review the healthcare estate, optimise
land use, and deliver health services from modern facilities is crucial. The health estate must be
supported to develop, modernise, or be protected in line with integrated NHS strategies. Planning
policies should enable the delivery of essential healthcare infrastructure and be prepared in
consultation with the NHS to ensure they help deliver estate transformation.

Comment

Representation ID: 26462

Received: 22/07/2024

Respondent: NHS Property Services

Draft Policy HWB1 Supporting Health and Wellbeing
Draft Policy HWB1 sets out Council’s commitment to making sure that developments promote
healthier lifestyles and improve overall health and wellbeing. NHSPS support the inclusion of policies
that support healthy lifestyles. There is a well-established connection between planning and health,
and the planning system has an important role in creating healthy communities. The planning system
is critical not only to the provision of improved health services and infrastructure by enabling health
providers to meet changing healthcare needs, but also to addressing the wider determinants of
health.
Identifying and addressing the health requirements of existing and new development is a critical way
of ensuring the delivery of healthy, safe, and inclusive communities. On this basis, we welcome the
inclusion of a comprehensive policy on health and wellbeing in the Local Plan and encourage the
Council to engage with the NHS on this matter ahead of the Regulation 19 document being prepared.

Comment

Representation ID: 26463

Received: 22/07/2024

Respondent: NHS Property Services

Draft Policy HWB4 focuses on the provision or improvement of community facilities and services to
meet local needs. NHSPS supports the provision of sufficient, quality community facilities but does
not consider the proposed policy approach to be effective in its current form. Where healthcare
facilities are included within the Local’s Plan definition of community facilities, policies aimed at
preventing the loss or change of use of community facilities and assets can potentially have a harmful
impact on the NHS’s ability to ensure the delivery of essential facilities and services for the
community.
The NHS requires flexibility with regards to the use of its estate to deliver its core objective of
enabling excellent patient care and support key healthcare strategies such as the NHS Long Term
Plan. In particular, the disposal of sites and properties which are redundant or no longer suitable for
healthcare for best value (open market value) is a critical component in helping to fund new or
improved services within a local area. Requiring NHS disposal sites to explore the potential for
alternative community uses and/or to retain a substantial proportion of community facility provision
adds unjustified delay to vital reinvestment in facilities and services for the community.
All NHS land disposals must follow a rigorous process to ensure that levels of healthcare service
provision in the locality of disposals are maintained or enhanced, and proceeds from land sales are
re-invested in the provision of healthcare services locally and nationally. The decision about whether
a property is surplus to NHS requirements is made by local health commissioners and NHS England.

Sites can only be disposed of once the operational health requirement has ceased. This does not
mean that the healthcare services are no longer needed in the area, rather it means that there are
alternative provisions that are being invested in to modernise services.

Comment

Representation ID: 26464

Received: 22/07/2024

Respondent: NHS Property Services

Where it can be demonstrated that health facilities are surplus to requirements or will be changed
as part of wider NHS estate reorganisation and service transformation programmes, it should be
accepted that a facility is neither needed nor viable for its current use, and policies within the Local
Plan should support the principle of alternative uses for NHS sites with no requirement for retention
of a community facility use on the land. To ensure the Plan is positively prepared and effective,
NHSPS are seeking the following modification (shown in italics) to Draft Policy DEV4 to ensure the
principle of alternative uses for NHS land and property will be fully supported:
Proposed Modification to Draft Policy DEV4
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 Policy DEV4 point i and ii will not apply.

Comment

Representation ID: 26465

Received: 22/07/2024

Respondent: NHS Property Services

Draft Policy INF1 Strategic Infrastructure Requirements
Draft Policy INF1 sets out the overarching policy for ensuring development makes a positive
contribution to sustainable growth through the delivery of appropriate infrastructure in a timely
manner. NHSPS welcomes the recognition of health infrastructure as essential infrastructure. In
areas of significant housing growth, appropriate funding must be consistently leveraged through
developer contributions for health and care services to mitigate the direct impact of growing demand
from new housing. Additionally, the significant cumulative impact of smaller housing growth and the
need for mitigation must also be considered by the Plan.
We also emphasise the importance of effective implementation mechanisms so that healthcare
infrastructure is delivered alongside new development, especially for primary healthcare services as
these are the most directly impacted by population growth associated with new development. The
NHS, Council and other partners must work together to forecast the health infrastructure and related
delivery costs required to support the projected growth and development across the Local Plan area.
NHSPS recommend 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. This
would ensure that the assessment of existing healthcare infrastructure is robust, and that mitigation
options secured align with NHS requirements.
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. NHSPS recommends that the Council engage
with the relevant Integrated Care Board (ICB) to add further detail within the Local Plan and
supporting evidence base (Infrastructure Delivery Plan) regarding the process for determining the
appropriate form of contribution towards the provision of healthcare infrastructure where this is
justified. As a starting point, we suggest the following process:
• Assess the level and type of demand generated by the proposal.
• Work with the ICB to understand the capacity of existing healthcare infrastructure and the
likely impact of the proposals on healthcare infrastructure capacity in the locality.
• Identify appropriate options to increase capacity to accommodate the additional service
requirements and the associated capital costs of delivery.
• Identify the appropriate form of developer contributions.
Healthcare providers should have flexibility in determining the most appropriate means of meeting
the relevant healthcare needs arising from a new development. Where new development creates a
demand for health services that cannot be supported by incremental extension or internal
modification of existing facilities, this means the provision of new purpose-built healthcare
infrastructure will be required to provide sustainable health services. Options should enable financial
contributions, new-on-site healthcare infrastructure, free land/infrastructure/property, or a
combination of these. It should be emphasised that the NHS and its partners will need to work with
the Council in the formulation of appropriate mitigation measures.

Comment

Representation ID: 26466

Received: 22/07/2024

Respondent: NHS Property Services

Draft Policy HOU2 Affordable Housing
In undertaking further work on local housing needs, we 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. The sustainability of the NHS is largely dependent on the recruitment and retention
of its workforce. Most NHS staff need to be anchored at a specific workplace or within a specific
geography to carry out their role. When staff cannot afford to rent or purchase suitable
accommodation within reasonable proximity to their workplace, this has an impact on the ability of
the NHS to recruit and retain staff.
Housing affordability and availability can play a significant role in determining people’s choices about
where they work, and even the career paths they choose to follow. As the population grows in areas
of new housing development, additional health services are required, meaning the NHS must grow
its workforce to adequately serve population growth. Ensuring that NHS staff have access to suitable
housing at an affordable price within reasonable commuting distance of the communities they serve
is an important factor in supporting the delivery of high-quality local healthcare services. We
recommend 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.

Comment

Representation ID: 26467

Received: 22/07/2024

Respondent: NHS Property Services

Draft Policy GTC1 and GTC2 seeks to promote Net Zero standards in new and existing buildings.
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.

Comment

Representation ID: 26468

Received: 22/07/2024

Respondent: NHS Property Services

Draft Policy GTC1 and GTC2 seeks to promote Net Zero standards in new and existing buildings.
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.

Comment

Representation ID: 26469

Received: 22/07/2024

Respondent: NHS Property Services

Draft Policy GTC1 and GTC2 seeks to promote Net Zero standards in new and existing buildings.
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.

Comment

Representation ID: 26470

Received: 22/07/2024

Respondent: NHS Property Services

General Comments on Evidence Base relating to Healthcare Infrastructure
The provision of adequate healthcare infrastructure is in our view critical to the delivery of sustainable
development. We recommend 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 both planning obligations and the capital allocation processes for the CIL 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.