Central Bedfordshire Pre-submission Local Plan (January 2018)

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Central Bedfordshire Pre-submission Local Plan (January 2018)

Policy HQ3: Provision for Social and Community Infrastructure

Representation ID: 8904

Received: 21/02/2018

Respondent: NHS Property Services

Representation:

POLICY - does not comply with NPPF
POLICY - needs clarification with regards to the loss of facilities and services

06



Full text:

Policy HQ3 (Provision for Social and Community Infrastructure) of the Local Plan restricts the loss or change of use of existing�community facilities�. Whilst Paragraph 70 of the NPPF 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. 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 unneeded and unsuitable healthcare facilities for best value can be prevented or delayed. This has a direct impact on the provision and quality of healthcare facilities and services, as it can prevent or delay the reinvestment of capital in modern and fit-for-purpose facilities and require ongoingrevenue to be spent on maintaining inefficient parts of the estate. Furthermore, most surplus healthcare facilities are purpose built and at the end of their useful lives, and thus highly unlikely to be viable or suitable for other uses. 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 Much surplus NHS property is outdated and no longer suitable for modern healthcare or other C2 or D1 uses without significant investment.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.

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