Core Strategy and Policies Development Plan Document (DPD) Main Modifications
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Core Strategy and Policies Development Plan Document (DPD) Main Modifications
MM66 - Page 97-98, Policy CS17
Representation ID: 26706
Received: 17/09/2021
Respondent: East Suffolk and North Essex NHS Foundation Trust (ESNEFT)
Of note, it is welcomed that Policy CS17 (Delivering Infrastructure) now makes reference to acute hospital facilities and ESNEFT is content with these amendments which allow for developer contributions for essential healthcare services. Furthermore, within Policy CS19 (Provision of Health Services) it is acknowledged that ‘further inpatient and outpatient accommodation and facilities’ are identified as acceptable related uses.
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Core Strategy and Policies Development Plan Document (DPD) Main Modifications
MM68 - Page 101, Policy CS19
Representation ID: 26707
Received: 17/09/2021
Respondent: East Suffolk and North Essex NHS Foundation Trust (ESNEFT)
Legally compliant? Yes
Sound? No
Policy CS19’s wording, along with its supporting text, continues to refer to ‘safeguarding’ the site for healthcare purposes. This runs contrary to ESNEFT’s planning requirements and is also unnecessary and unreasonable. This policy basis is essentially overly restrictive and would not provide sufficient flexibility and discretion to ESNEFT to enable it to realise its development requirements and does not reflect the most appropriate strategy for the site. Consequently, whilst Policy CS19 remains as currently proposed to be amended by the Local Planning Authority, the draft Local Plan remains ‘unsound’ when considered against the tests set out in paragraph 35 of the NPPF.
It is requested that Policy CS19 reads as follows:
The Council supports the development of healthcare related facilities at the Heath Road Hospital Campus as identified on the policies map. Related uses may include:
Further inpatient and outpatient accommodation and facilities;
Staff accommodation;
Residential care home;
Intermediate facilities;
Education and teaching centre;
Therapies centre; and
Other ancillary uses.
Proposals for new and improved healthcare, ancillary facilities and other compatible development at Heath Road Hospital Campus will be supported providing they form part of the Hospital Trust’s Estate Strategy for the provision of healthcare facilities, consistent with an overall site wide masterplan prepared by the Trust and associated Transport Strategy including suitable travel plan measures and parking provision.
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Core Strategy and Policies Development Plan Document (DPD) Main Modifications
MM69 - Page 101, Paragraph 8.229
Representation ID: 26708
Received: 17/09/2021
Respondent: East Suffolk and North Essex NHS Foundation Trust (ESNEFT)
Legally compliant? Yes
Sound? No
Following our representations to the Final Draft consultation, ESNEFT are pleased the majority of our suggested wording has been incorporated within paragraph 8.229, as shown within Main Modification 69. However a sentence previously requested to be removed due to it covering healthcare matters beyond the scope of the Local Planning Authority’s remit remains, while ‘other compatible uses’ within the second sentence has been replaced with ‘ancillary uses’. This does not provide the Trust with sufficient flexibility or allow for the introduction of non-health care uses where appropriate and acceptable in planning terms, which could result in future planning policy tensions within any future planning application.
It is requested that paragraph 8.229 is amended to read as follows:
The Heath Road Hospital is a strategic health facility serving Ipswich and the surrounding area. It is important that any rationalisation of uses there takes place in the context of a planned strategy for healthcare provision which itself takes account of the future growth of Ipswich and the Ipswich Strategic Planning Area. The policy allows for a range of healthcare and other compatible uses, including staff support services to assist with recruitment and retention. Additional ancillary uses may also include shared facilities to deliver a mutual benefit to other public sector organisations aligned with the one public estate agenda.
See scanned representation.
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Core Strategy and Policies Development Plan Document (DPD) Main Modifications
MM70 - Page 101, Paragraph 8.230
Representation ID: 26709
Received: 17/09/2021
Respondent: East Suffolk and North Essex NHS Foundation Trust (ESNEFT)
Legally compliant? Yes
Sound? No
Within MM70, the replacement of ‘existing’ with ‘proposed’ in relation to parking issues hasn’t been incorporated. ESNEFT considers it unreasonable to insist proposed development should tackle existing parking issues, particularly when they may not be associated with the Hospital. Traffic, travel and parking impacts of hospital development should be considered on its individual merits, consistent with NPPF paragraphs 55-57.
In addition, the replacement of ‘possible’ with ‘practicable’ hasn’t been incorporated as it could be misinterpreted as allowing for economic or other reasons for not pursuing sustainable travel modes. ESNEFT dispute this and consider ‘practicable’ more appropriate in the context of the travel opportunities and constraints of a working acute hospital.
It is requested that paragraph 8.230 be amended to the following:
It is also essential that the travel implications of hospital related developments are fully considered and measures are put in place to encourage the use of sustainable modes where practicable by staff, out-patients, and visitors. In particular, measures should tackle parking issues in surrounding residential areas associated with proposed Hospital activity and the Hospital should put in place monitoring to ensure that any measures are proving to be effective.
See scanned representation.
