Issues and Options Document

Rochford Local Plan: Issues and Options (and draft Sustainability Appraisal)
Thank you for the opportunity to comment on the above document. The following comments are submitted by NHS Property Services (NHSPS).
Foreword
NHSPS manages, maintains and improves NHS properties and facilities, working in partnership with NHS organisations to create safe, efficient, sustainable and modern healthcare and working environments. NHSPS has a clear mandate to provide a quality service to its tenants and minimise the cost of the NHS estate to those organisations using it. Any savings made are passed back to the NHS.
Community Facilities (Policy CLT6)
Whilst Paragraph 70 of the National Planning Policy Framework (NPPF) 2012 states that planning policies and decisions should 'guard against the unnecessary loss of valued facilities and services', the overarching objective of this same paragraph is to ensure the delivery of facilities and services for the community.
It is prudent to note that this policy wording is also fully retained in paragraph 93c of the Draft NPPF consultation document (2018), which under paragraph 93b also states that "planning policies and decisions should... take into account and support the delivery of local strategies to improve health, social and cultural wellbeing for all sections of the community".
Restrictive policies that prevent the loss or change of use of 'community facilities' and include healthcare facilities within this definition can prevent or delay required investment in alternative facilities and work against the Council's aim of providing essential services for the community. It is important to note that there are separate, rigorous testing and approval processes employed by NHS commissioners to identify unneeded and unsuitable healthcare facilities. These must be satisfied prior to any property being declared surplus and put up for disposal.
An essential element of supporting the wider transformation of NHS services and the health estate is to ensure that surplus and vacant NHS sites are not strategically constrained by local planning policies, particularly for providing alternative uses (principally housing).

Much surplus NHS property is outdated and no longer suitable for modern healthcare or other C2 or D1 uses without significant investment. Where NHS commissioners can demonstrate that healthcare facilities are no longer required for the provision of services, there should be a presumption that such sites are suitable for housing (or other appropriate uses), and should not be subject to restrictive policies or periods of marketing, which would serve to delay the process of delivering the NHS estate regeneration programme and lead to unnecessary cost to the NHS.

New Healthcare Provision

When planning for new settlements, the Council should continue to work with NHS commissioners and providers to ensure that adequate healthcare infrastructure is provided to support new residential development.
Healthcare facilities are essential infrastructure and where new facilities are required, they should be delivered alongside additional housing units to mitigate the impact of population growth on existing infrastructure. The Council should therefore work with NHS commissioners and providers to consider the quantum and location of healthcare facilities that will be required to ensure that new settlements are sustainable.
Where extended or relocated health facilities are required to mitigate the impact of new development, health commissioners would require Section 106 / CIL funding towards the capital cost of delivering this infrastructure. An assessment of the appropriate mechanisms for delivering the required funding will need to be undertaken at an early stage in collaboration with the Council.

These changes would ensure that the NHS is able to effectively manage its estate, disposing of unneeded and unsuitable properties where necessary, to enable healthcare needs to be met.

Rochford Local Plan: Issues and Options (and draft Sustainability Appraisal)
Thank you for the opportunity to comment on the above document. The following comments are submitted by NHS Property Services (NHSPS).
Foreword
NHSPS manages, maintains and improves NHS properties and facilities, working in partnership with NHS organisations to create safe, efficient, sustainable and modern healthcare and working environments. NHSPS has a clear mandate to provide a quality service to its tenants and minimise the cost of the NHS estate to those organisations using it. Any savings made are passed back to the NHS.
Community Facilities (Policy CLT6)
Whilst Paragraph 70 of the National Planning Policy Framework (NPPF) 2012 states that planning policies and decisions should 'guard against the unnecessary loss of valued facilities and services', the overarching objective of this same paragraph is to ensure the delivery of facilities and services for the community.
It is prudent to note that this policy wording is also fully retained in paragraph 93c of the Draft NPPF consultation document (2018), which under paragraph 93b also states that "planning policies and decisions should... take into account and support the delivery of local strategies to improve health, social and cultural wellbeing for all sections of the community".
Restrictive policies that prevent the loss or change of use of 'community facilities' and include healthcare facilities within this definition can prevent or delay required investment in alternative facilities and work against the Council's aim of providing essential services for the community. It is important to note that there are separate, rigorous testing and approval processes employed by NHS commissioners to identify unneeded and unsuitable healthcare facilities. These must be satisfied prior to any property being declared surplus and put up for disposal.
An essential element of supporting the wider transformation of NHS services and the health estate is to ensure that surplus and vacant NHS sites are not strategically constrained by local planning policies, particularly for providing alternative uses (principally housing).

Much surplus NHS property is outdated and no longer suitable for modern healthcare or other C2 or D1 uses without significant investment. Where NHS commissioners can demonstrate that healthcare facilities are no longer required for the provision of services, there should be a presumption that such sites are suitable for housing (or other appropriate uses), and should not be subject to restrictive policies or periods of marketing, which would serve to delay the process of delivering the NHS estate regeneration programme and lead to unnecessary cost to the NHS.

New Healthcare Provision

When planning for new settlements, the Council should continue to work with NHS commissioners and providers to ensure that adequate healthcare infrastructure is provided to support new residential development.
Healthcare facilities are essential infrastructure and where new facilities are required, they should be delivered alongside additional housing units to mitigate the impact of population growth on existing infrastructure. The Council should therefore work with NHS commissioners and providers to consider the quantum and location of healthcare facilities that will be required to ensure that new settlements are sustainable.
Where extended or relocated health facilities are required to mitigate the impact of new development, health commissioners would require Section 106 / CIL funding towards the capital cost of delivering this infrastructure. An assessment of the appropriate mechanisms for delivering the required funding will need to be undertaken at an early stage in collaboration with the Council.

These changes would ensure that the NHS is able to effectively manage its estate, disposing of unneeded and unsuitable properties where necessary, to enable healthcare needs to be met.