Draft Core Strategy and Policies Focused Review

Diagram 1 should make reference to NHS England (NHSE) and NHS Property Services Ltd (NHSPS), as well as the Ipswich & East Suffolk Clinical Commissioning Group.
The role of NHSE is to commission all healthcare services, incorporating the provision of primary care facilities within its administrative area, including within Ipswich Borough. NHSPS is responsible for advising NHSE and local Clinical Commissioning Groups on all NHS estate related matters.

NHS Property Services Ltd, on behalf of NHS England, objects to the policy requirement for the Northern Fringe District Centre to provide "a reserved site for a health centre".
The submissions made by the NHS to the Ipswich Northern Fringe SPD consultation in July 2012, to the Ipswich Northern Fringe SPD Issues & Options Document consultation in February 2013 and to the current Garden Suburb SPD consultation, identify that, in order to mitigate the healthcare impacts arising directly from the proposed development, the land required for the phased construction and fitting out of the new health centre floorspace would need to be provided and fully funded by the developer and brought forward in accordance with a planning obligation and related phasing plan to be agreed with the NHS and the Borough Council.
The allocation of land for a health centre along with utility connections would not provide any new primary healthcare capacity to mitigate the impacts arising from the new community. It would therefore be inadequate mitigation and fail the tests in paragraph 204 of the NPPF and Sec 122 of the CIL Regulations.

NHS Property Services Ltd, on behalf of NHS England objects to the deletion of "new healthcare provision" from the list of infrastructure requirements to be provided as part of the Northern Fringe Garden Suburb, as detailed in paragraph 8.115. This deletion does not correspond with the text of Policy CS10 and contradicts Policy CS17 and Table 8B of the Core Strategy and Policies Focussed Review

NHS Property Services Ltd, on behalf of NHS England objects to the limitations imposed by the proposed changes to Policy CS17 on securing direct provision of infrastructure by developers, as well as the payment of financial contributions towards mitigating the impacts arising from proposed developments.
The policy, as currently worded, would preclude the direct provision of infrastructure as mitigation would only be able to take the form of a "Section 106 Agreement commuted sum or CIL charge".

NHS Property Services Ltd, on behalf of NHS England, objects to the requirement for the Northern Fringe District Centre to provide "a reserved site for a health centre".
The submissions made by the NHS to the Ipswich Northern Fringe SPD consultation in July 2012, to the Ipswich Northern Fringe SPD Issues & Options Document consultation in February 2013 and to the current Garden Suburb SPD consultation, identify that, in order to mitigate the healthcare impacts arising directly from the proposed development, the land required for the phased construction and fitting out of the new health centre floorspace would need to be provided and fully funded by the developer and brought forward in accordance with a planning obligation and related phasing plan to be agreed with the NHS and the Borough Council.
The allocation of land for a health centre along with utility connections would not provide any new primary healthcare capacity to mitigate the impacts arising from the new community. It would therefore be inadequate mitigation and fail the tests in paragraph 204 of the NPPF and Sec 122 of the CIL Regulations.

In light of the revised requirement across the Borough over the period 2013-2031, NHS England has updated its Evidence Base in respect of the healthcare charge to be included in the Borough Council's CIL Charging Schedule. This updated Evidence Base is attached to this consultation form.