Core Strategy and Policies Development Plan Document (DPD) Main Modifications

Support

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.

Object

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.

Object

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.

Object

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.