Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

Draft Policy ST1 sets out the Council’s commitment to making sure that new developments support
health and wellbeing and contribute to reducing health inequalities through the built and natural
environment. NHSPS support the inclusion of a standalone health policy that supports healthy lives.
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 promoting healthy and safe communities. In accordance with the NPPF, these
requirements should be based on identified needs in the joint strategic needs assessment and
support delivery of relevant health strategies, such as the health and wellbeing board’s joint local
health and wellbeing strategy and the integrated care board’s infrastructure plan.

The policy also includes the requirement for a Health Impact Assessment for all residential
developments of more than 50 units. The use of health impact assessment is a useful tool to ensure
planning applicants and the Local Planning Authority have the right information to make sound
planning decisions in promoting healthy and safe communities. The Planning Practice Guidance
supports the use of health impact assessments. NHSPS supports the requirement for Health Impact
Assessment to focus on major developments with potential for significant health impacts

Draft Policy ST7 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 necessary infrastructure, with
an expectation that development proposals will make provision to meet the cost of healthcare
infrastructure made necessary by the development. We also note and support this being reflected
within Policy CS2 in instances where there is an identified need for the enhancement or provision of
community facilities. 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.

Draft Policy CS1 focuses on ensuring there is sufficient community and social infrastructure to meet
the identified local need and seeks to do so through the inclusion of requirements to be demonstrated
where a proposed development results in the loss of an existing facility. 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.

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 or submission of onerous information. To ensure the Plan is
positively prepared and effective, NHSPS are seeking the following modification (shown in red italics)
to Draft Policy CS1 or as an addition in supporting paragraphs to ensure the principle of alternative
uses for NHS land and property will be fully supported:

Proposed modification to Draft Policy CS1:
“Any proposal that would result in the loss of a site or building currently or last used for, or allocated
for the provision of community / social infrastructure including community facilities, services,
leisure or cultural activities that benefit the community, will only be supported in cases where the
Council is satisfied that:

a. An alternative, equivalent community facility to meet local needs is, or will be, provided in
an equally or more accessible location within a minimum walking distance of the locality
(800m or the minimum distance based on that appropriate for the facility being provided
as set out in the relevant evidence); or
b. It has been proven to the satisfaction of the Council that there is no longer a proven need
for the community facility; and
c. It has been proven to the satisfaction of the Council based on written evidence as detailed
in a-c below, submitted with the Planning Application, that it would not be economically
viable to retain the site/building for the existing or an alternative community use; and (in all
cases)
d. The community facility could not be provided or operated by either the current occupier or
by any alternative occupier, and it has been marketed to the satisfaction of the Council in
order to confirm that there is no interest for any community use and the site or building is
genuinely redundant.

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 (a) to (d) above will not apply.”

Proposed addition to supporting paragraphs:
“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 (a) to (d) will not apply.”

NHSPS support the principle of delivering affordable housing in order to meet identified local needs.
To further support this policy, 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