Paragraph 22.1’s recognition that “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” is welcomed, as is the Local planning Authority’s commitment to “…work with the Cambridgeshire & Peterborough Integrated Care System (ICS) to assess the need for additional health infrastructure and ensure that all residents have easy access to the care they need when they need it.” The definition of healthcare infrastructure must be in its widest form (incorporating secondary, community and tertiary care) to support growth.

Paragraph 22.3 – The commitment by the local planning authority to impose “…planning obligations … to mitigate the impact of the development and secure the required additional health infrastructure provision” is welcomed. Again the definition of healthcare infrastructure must be in its widest form.

Following the wording proposed for primary healthcare contributions in Paragraph 22.23 the ICS partners will be commencing work to develop an evidence-based methodology for mitigating the impact of development on the wider healthcare system and would welcome the opportunity to further explore this with officers how this could be applied

Paragraph 22.9, line 5; replace the work “are” with the word “and”

Paragraph 22.10 – the bullet points are misleading. The following section should be moved to the end of the bullet point list to aid clarity:
o “To note, there are two surgeries within the Greater Cambridgeshire boundary which do not fall within the Cambridgeshire & Peterborough ICS:
▪ Bassingbourn Surgery – branch surgery of the Ashwell Surgery which falls under Hertfordshire and West Essex ICS
▪ Gamlingay Surgery – branch surgery of Greensand Medical Practice which falls under Bedfordshire, Luton and Milton Keynes ICS”

Paragraph 22.10 – the bullet point referencing the hospitals within the ICS should be reworded to read “Three Hospitals (Addenbrooke’s Hospital, Rosie Hospital and Royal Papworth Hospital)”

Paragraph 22.36, bullet point 2 (New build health facilities), line one to read “this may be either on-site or off-site depending…”

Please see attached document for representations on behalf of Pigeon.

Please consider two High Court decisions were The University Hospitals of Leicester NHS Trust, R (On the Application Of) v Harborough District Council [2023] EWHC 263 (Admin) (“the Leicester NHS Trust”) and Worcestershire Acute Hospitals NHS Trust, R (On the Application Of) v Malvern Hills District Council & Ors [2023] EWHC 1995 (Admin) (“the Worcestershire NHS Trust”). These suggest that such contributions are now lawful.

The setting out of a well-worked up scheme for quantifying and securing developer contributions towards primary care facilities is a welcome step forward.
The draft SPD refers to the Integrated Care System (ICS) as being the body responsible for determining health facility needs and gives the impression that s.106 agreements will be entered into by the ICS. This cannot be the case, as the ICS is neither a statutory nor a corporate body. The standard wording in paragraph 2.23 suggests that the LPA knows that any s.106 agreement will be entered into with the Integrated Care Board (ICB) as the statutory, executive NHS body with planning and commissioning responsibilities. The statutory responsibilities of the ICB, and the non-statutory nature of the ICS, should be further clarified in the draft SPD.
The draft SPD focuses almost exclusively, and with some specificity, on primary care infrastructure needs. Other requirements, such as hospitals, mental health services, and community services facilities, are hardly mentioned, apart from the ‘may be’ statement in paragraph 22.19. The mismatch in the current draft between the well-developed scheme for primary care and this minimalistic statement is stark. It can be assumed that the almost exclusive focus on primary care infrastructure reflects the sectoral interests of the ICB which has direct responsibility for the provision of primary care services in addition to its wider commissioning role. It is reasonable for the ICB to have focused on primary care needs as a place to start, but if healthcare facilities are going to be developed in a comprehensive and balanced way that will be required then more work is needed to develop a scheme for obtaining developer contributions towards hospitals and other facilities. The ICB, working with its Integrated Care Partnership (ICP – a non-statutory joint working arrangement), has a statutory responsibility for comprehensive planning (Health and Care Act 2022 s.26.4), which includes planning for infrastructure requirements. This should be reflected in the SPD.
Paragraph 22.21 says that ‘it is important that needs assessments reflect the most up-to-date ICS standards of health infrastructure provision for planning purposes as set out in this SPD.’ Has the LPA satisfied itself that such standards exist? If they do, then please cross refer to them in the SPD.

It is well-recognised that A&E, secondary and tertiary health care infrastructure in Greater Cambridge (which serves a far larger population than the residents of Greater Cambridge) is overloaded and has not kept pace with population growth. The same is true of social care, dentistry, pharmacy services, mental health services and community health services, as well as GP practices. Of these, only GP practices are covered in any detail in this chapter. This is unsatisfactory. The chapter needs significant expansion to develop schemes for obtaining developer contributions towards hospitals, hospices and other health and social care facilities. The significant funding gap that exists for the proposed Cambridge Children's hospital and the potentially long timescale for the redevelopment of Addenbrooke's are only two illustrations of the problem that needs to be addressed.

This section of the SPD is based on Policy 75 and 85 of the Cambridge Local Plan and Policy SC/4 of the South Cambridgeshire Local Plan. The SPD suggests that planning obligations will be sought from residential development of all tenures. The SPD states that new residential development will be required to mitigate its impact on health infrastructure, and that the type of provision and associated financial contributions required will be determined on the needs generated by the development and the existing capacity of impacted health infrastructure. All major development will be required to assess their impact on primary health infrastructure within the health care catchment of the proposed development.

The HBF is concerned with the overly simplified assumption within this section of the SPD that new housing developments increase the total number of patients that need primary care in a localised area. This may not always be the case, this very much depends on where people are moving to and from and potentially the reason for the move. It may be that only a small number of households are actually moving from outside of the area, and therefore a simple calculation of the total population of the newly built homes may significantly over estimate the health requirements. The HBF is also concerned by the assumption in paragraph 22.28 which states that if the baseline position is that the existing primary care infrastructure does have capacity to accommodate the additional population growth caused by the development a contribution will be required. The HBF hopes this is a typographical error and it should be if the primary care infrastructure does not have capacity, otherwise the HBF considers this requirement highly inappropriate. As with other requirements the HBF remains concerns about the resources required to undertake this planning obligation, the resources required to identify the appropriate evidence, to undertake the calculation and to actually provide the provision. The HBF considers this has potential to significantly impact on the viability and deliverability of homes.

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 Planning Obligations SPD
We support the inclusion of Chapter 22: Healthcare within the SPD and the provision of details of the means
in which the Council expects developers to mitigate the impact of development on local health provision. It
is noted that the SPD recognises the role of C&P ICB in assessing impact on local health infrastructure and
in determining how this is to be mitigated within the local estate. This sets a clear expectation of the provision
to be made for essential healthcare infrastructure through on-going engagement with the ICB as well as the
methodology that will be followed in determining required level of additional primary care provision will
support the effective implementation of the SPD.

Draft paragraph 22.23 details the standard wording to be used within the S106 Heads of Terms where a
financial contribution towards primary care is required. The final two sentences of this paragraph should not
form part of the standard wording example – appears that the document formatting has pulled this up into
the example wording.

To ensure that the SPD accurately reflects the provision and commissioning standards of C&P ICB, the
suggested wording amendments recommended to be made are (in red italics) as follows:

“22.23 Where a planning obligation is likely to be required, the applicant should indicate this
in any draft S106 Heads of Terms proposed. For applications where financial contributions
towards primary care are required, the following standard wording will generally be used:

• ‘Health Contribution: means the sum of £x (index linked) to be applied by the Cambridgeshire
& Peterborough Integrated Care Board (ICB) or subsequent successor body towards the
provision of additional primary care led capacity through the extension and/or remodelling of
[insert name of facility], or through the extension or remodelling of other facilities within the
local primary care networks (PCNs) – or subsequent successor - in which the development is
located, or through the extension and/or remodelling of other facilities that would specifically
provide services to serve the development <new paragraph added>

22.24 Expenditure of planning obligations related to primary care facilities will normally be
area-based on facility within the local PCN(s) serving the development. In limited
circumstances expenditure may be directed at a wider scale where this is deemed necessary
to support service delivery objectives.

22.25 For smaller schemes, to enable the required additional capacity to be in place…”

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 Planning Obligations SPD (Chapter 22) but consider the suggested
amendments above will contribute to ensuring the SPD reflects adopted health commissioning standards.

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

Please find attached a response from the University of Cambridge to the Planning Obligations SPD consultation.

Please find attached a response from the University of Cambridge to the Planning Obligations SPD consultation.

Please find attached a letter from CBC Ltd setting out our support for proposals raised by CUH in relation to S106.

Please find attached a letter from CBC Ltd setting out our support for proposals raised by CUH in relation to S106.

Please find attached a letter from CBC Ltd setting out our support for proposals raised by CUH in relation to S106.

Please find attached a letter from CBC Ltd setting out our support for proposals raised by CUH in relation to S106.

Please find attached a letter from CBC Ltd setting out our support for proposals raised by CUH in relation to S106.

Please find attached a letter from CBC Ltd setting out our support for proposals raised by CUH in relation to S106.

Please find attached a letter from CBC Ltd setting out our support for proposals raised by CUH in relation to S106.

On behalf of Hill Residential Ltd (Hill), we have set out in the attached letter a response to the following draft Greater Cambridge Planning Obligations SPD.