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Comment

Draft Greater Cambridge Health Impact Assessment Supplementary Planning Document

Representation ID: 200178

Received: 08/01/2025

Respondent: Cambridge Past, Present and Future

Representation Summary:

We are concerned that the HIA is yet another document needed to support a planning application. The SPD could make reference the pragmatic use of HIAs so as not to add extra bureaucracy to the submission and consideration of a planning application. It could be, for instance that impact on health forms part of the Design and Access Statement.

Full text:

We are concerned that the HIA is yet another document needed to support a planning application. The SPD could make reference the pragmatic use of HIAs so as not to add extra bureaucracy to the submission and consideration of a planning application. It could be, for instance that impact on health forms part of the Design and Access Statement.

Support

Draft Greater Cambridge Health Impact Assessment Supplementary Planning Document

Representation ID: 200265

Received: 23/01/2025

Respondent: Hill Residential Limited

Agent: Tor & Co

Representation Summary:

It is noted that the implications of HIA and environmental impact assessment are included in the SPD. Hill specifically welcomes the approach set out in paragraph 4.10, specifically, the opportunity to undertake pre-application consultation to determine if health can be incorporated as part of the environmental statement or if an independent HIA would be required, as it reduces the need for duplicated information.

Full text:

Dear Sir / Madam,

Following my email below, I just received a bounce back as it appears the link for the email address provided on the consultation page was incorrect.

Hopefully this will now be received, if you could please confirm receipt.

Kind regards
Sophia

--
Sophia Goodhead MRTPI
Technical Director

Comment

Draft Greater Cambridge Health Impact Assessment Supplementary Planning Document

Representation ID: 200333

Received: 24/01/2025

Respondent: NHS Property Services Ltd

Representation Summary:

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.
We support the approach of the draft Health Impact Assessment SPD but suggest amendments (refer to the Planning Obligations SPD and engagement with the ICB) to ensure the SPD reflects adopted health commissioning standards and that an accurate assessment of health infrastructure can be conducted.

Full text:

Thank you for the opportunity to comment on the above document. The following comments are submitted
by NHS Property Services (NHSPS) for and on behalf of NHS Cambridgeshire and Peterborough ICB (C&P
ICB). C&P ICB has delegated authority from NHS England for the commissioning of most NHS health
services in the Greater Cambridgeshire area. This includes consideration of estate requirements to deliver
these services.

General Comments on Health Infrastructure to Support Housing Growth
The delivery of new and improved healthcare infrastructure is 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 adds further pressure to the system. Residential developments often have very
significant impacts in terms of the need for additional healthcare provision for future residents, particularly
primary care. To ensure the delivery of necessary health infrastructure, it is essential that new development
makes a proportionate contribution to funding the health infrastructure needs arising from new homes.

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.

Detailed Comments on draft Health Impact Assessment SPD
The Health Impact Assessment SPD details the method of assessing the impacts of development on health
and wellbeing. We support the level of detail and guidance that has been provided within the draft SPD but
would note that the (currently in draft) Planning Obligations SPD has not been referenced to within the draft
Health Impact Assessment SPD.

Chapter 22 of the Planning Obligations SPD contains detailed guidance on the method to assessing impact
on local health provision. We would recommend that the Health Impact Assessment SPD clearly set out that
the guidance contained within the Planning Obligations SPD should be followed when assessing the capacity
of health infrastructure, to ensure that there is consistency within the local area when assessing impact on
health and wellbeing, specifically on healthcare provision.

Alongside the importance of consideration at the early stages, we would also recommend that there is
commitment to engagement with the Cambridge and Peterborough Integrated Care Board (C&P ICB) at the
early stages to accurately determine the potential impact of development on health provision and
infrastructure and enable the appropriate delivery of healthcare infrastructure. C&P ICB is the health
commissioning body within the Greater Cambridgeshire area and is therefore best placed to be able to
assess the likely impact of proposals on healthcare infrastructure capacity within the locality. These
amendments will ensure the Health Impact Assessment SPD provides sufficient detail to guide the method
of assessing the impact on local health and wellbeing.

Conclusion
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.
We support the approach of the draft Health Impact Assessment SPD but consider the suggested
amendments above will contribute to ensuring the SPD reflects adopted health commissioning standards
and that an accurate assessment of health infrastructure can be conducted.

Attachments:

Comment

Draft Greater Cambridge Health Impact Assessment Supplementary Planning Document

Representation ID: 200346

Received: 27/01/2025

Respondent: Vistry Group

Agent: Turley Economics

Representation Summary:

The HIA SPD’s definitions of the following various forms of HIA that would be expected to support the planning applications for schemes of various scales (paras 4.1 – 4.3) is noted. However, it is understood that the scope and depth of stakeholder engagement would be a key point of difference between HIAs of varying scales of schemes (and would, for example, account for a notable point of difference between the ‘Full/Comprehensive’ HIA prepared for a 100 home development compared to a 2,000 home scheme.

If this assumption is correct, then this is welcomed, and we would recommend that greater prominence is given to such distinction within the main text of the SPD (e.g. Section 4: ‘When is a HIA Required?’).

Full text:

On behalf our client Vistry Strategic Land, please find attached our representations to the current HIA SPD consultation.

We would be grateful for confirmation of safe receipt.

Kind regards

Donna

Donna Brearley
Associate Director

Comment

Draft Greater Cambridge Health Impact Assessment Supplementary Planning Document

Representation ID: 200376

Received: 24/01/2025

Respondent: University of Cambridge

Representation Summary:

The HIA should not need to replicate anything that is controlled by building regulations or assessed in detail as part of the EIA.

There is no reference to the distinction between outline and detailed planning applications – where the nature and scope of an HIA needs to be quite different.

We would ask for additional clarity on the thresholds included in the SPD. For development of over 100 homes a Rapid HIA should be sufficient, including a steering group with the LPA who will have very good knowledge of local issues already. We do not think a Full HIA it is realistic for development of this scale.

Full text:

Dear Lizzie,

Please find attached a response from the University of Cambridge to the Health Impact Assessment SPD consultation.

Best wishes,

Paul
Paul Milliner MRTPI I Head of Planning

Comment

Draft Greater Cambridge Health Impact Assessment Supplementary Planning Document

Representation ID: 200539

Received: 24/01/2025

Respondent: Cambridgeshire County Council

Representation Summary:

Paragraph 4.5 refers to “Development proposals that include potentially hazardous uses or installations” which would include some waste management facilities – for example Energy from Waste facilities.

The County Council supports the level of discretion included in Paragraph 4.7. Where relevant we require noise, AQ, odour, vibration & dust assessments and have asked waste developers to draw from these to inform a focussed HIA.

Full text:

Dear Sirs

Greater Cambridge Supplementary Planning Documents Consultation
1) Planning Obligations
2) Health Impact Assessment
3) Cambridge Biomedical Campus
Consultation Response by Cambridgeshire County Council

I refer to the consultation on the above supplementary planning documents and thank GCSPS for affording the County Council the opportunity to comment. Please find attached to this letter comments that I have received from services at the County Council. I trust that this will be of assistance to GCSPS in progressing the supplementary planning documents.

Please feel free to contact me if you wish to discuss this further.

Yours sincerely

Colum Fitzsimons
Development and Policy Manager
Planning, Growth and Environment

Comment

Draft Greater Cambridge Health Impact Assessment Supplementary Planning Document

Representation ID: 200568

Received: 24/01/2025

Respondent: Carter Jonas

Number of people: 6

Representation Summary:

It would be appropriate for the Councils, in the SPD, to identify those locations that ‘have a higher proportion of protected characteristic groups’. The SPD is currently unclear on that point.

Also, what is meant by ‘areas with limited infrastructure or facilities’? This needs to be clarified as it is too imprecise and will not be readily understood by all.

Full text:

Dear Sir / Madam,

Here are some representations in respect of the above reference consultation draft SPD’s submitted on behalf of the following named clients:
• TLC Group
• Rockley Dene Homes Ltd
• The Fellows House Ltd
• SPK Residential Cambridge Ltd
• London Inn Hotels (Cambridge) Ltd

Yours faithfully

Colin Brown

Colin Brown MRTPI
Partner, Head of Planning & Development