Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

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Representation ID: 8396

Received: 03/09/2021

Respondent: NHS

am writing to provide a response on behalf of Bedfordshire, Luton and Milton Keynes Clinical Commissioning Group (BLMK CCG) in relation to the Council’s consultation on the Local Plan Strategy Options, and to re-confirm our commitment to working in partnership with the Council to jointly plan the necessary infrastructure to help local communities in Bedford Borough thrive.

Council colleagues will recall that the CCG worked closely with Bedford Borough Council to support the development of the Infrastructure Delivery Plan (IDP) for the currently adopted Local Plan to 2030, which sets out the health infrastructure requirements associated with the current housing growth ambitions.

In addition, the CCG worked with the Council to carry out a detailed assessment in 2019 of the future need for primary healthcare services across the Borough, including as a result of projected housing growth. These pieces of work have been incorporated into the CCG’s existing Primary Care Estates Strategy, enclosed for your information.

The CCG/ICS (or successor NHS body as appropriate) would expect to similarly work closely with the Council to fully assess the health infrastructure requirements associated with delivering the additional target of 12,500 additional homes by 2040, over and above the existing Local Plan commitments. In particular, health partners would hope to engage with the Council next year as the revised IDP is developed as a supporting document to the 2040 Local Plan.

It is important to raise that the cumulative effect of housing developments across the Borough, and surrounding Local Authorities, is having a significant impact on demand for community, mental health, Acute Trust and Ambulance Trust services. Whilst the previous infrastructure discussions have primarily related to primary healthcare services, it is important for Planners to note the wider health infrastructure impact and for this to be factored into infrastructure planning. We hope this will enable us to jointly continue to develop ourapproach to securing adequate contributions from developers – to ensure that the new and growing communities proposed can be adequately served by local health services.

Whilst we expect you may receive responses directly from other partner organisations within the Bedfordshire, Luton & Milton Keynes Integrated Care System, this response summarises the impact of the proposed development sites for the healthcare system across Bedford Borough.

We welcome further discussions with the Council around how we collectively can mitigate the cumulative impact of housing developments across the health infrastructure serving Bedford Borough, in a way which complies with the statutory tests in CIL regs 122, i.e.
A planning obligation may only constitute a reason for granting planning permission for the development if the obligation is—
(a)necessary to make the development acceptable in planning terms;
(b)directly related to the development; and
(c)fairly and reasonably related in scale and kind to the development.

Every effort is made to ensure every CCG request for a S106 developer contribution is tailored to each individual development. The methodology has been accepted by all the Local Authorities the CCG works with and at Appeal stage.

Impact of Proposed Strategy Options
All of the proposed options are expected to have a significant impact on community, mental health, Acute Trust and Ambulance Trust services. The full impact will require further detailed assessment next year.

Acute Trust
The cumulative effect of housing developments across the Borough are placing strain on the capacity of Bedford Hospital. As a result, Bedfordshire Hospitals Foundation Trust expects to need to bring forward a number of projects to increase capacity over the next 5-10 years and beyond, related to:

• Increasing the capacity of Urgent and Emergency Care services
• Expanding the number of surgical theatres
• Accommodating growth in demand for outpatient appointments and diagnostics.

We would expect acute contributions to be secured via the larger proposed developments within the new Local Plan to contribute to these key health infrastructure projects.

Ambulance Trust
The East of England Ambulance Service Trust (EEAST) are in the process of developing an evidence-based formula to identify the impact of population growth for housing developments on ambulance services. This will include key projects to enable delivery of their services, such as changes to road infrastructure and developments for nursing and care homes or over 55 developments. The CCG and EEAST would welcome further discussions around how the infrastructure impact of the Borough’s 2040 Local Plan can be collectively addressed.

Primary Care
A significant transformation programme is underway across primary care in Bedfordshire, Luton and Milton Keynes (BLMK) in line with national strategy; for primary care at scale, improved patient access to services, workforce expansion to enable a wider and effective skill-mix for integrated multi-disciplinary working and delivery of personalised and proactive care to reduce referrals into hospitals to support the delivery of the NHS long term plan.

This means that the preferred Commissioning Strategy for Bedford Borough (as part of the Bedfordshire, Luton and Milton Keynes system)for areas of significant housing growth has changed over the last 5-10 years. It is generally less viable as an operating model to commission a new primary care provider in addition to the existing primary care providers who within their Primary Care Networks (PCNs) are able to collectively employ a wider skill-mix of clinicians to enable the multi-disciplinary working and personalised and proactive care as described above. Estates solutions need to support the development of integrated teams of GPs and other clinical professionals, community health and social care staff and with other community-based services that can positively impact on health and wellbeing (e.g. via social prescribing and voluntary sector).

Therefore, requests for contributions from developers need to be seen in the context of primary care operating at scale in an integrated manner with other health and social care partners. Providing appropriate infrastructure for new and/or growing communities will often require the relocation of an existing provider from their current premises, or extensions/reconfigurations of existing premises, as opposed to the establishment of new GP practices.

This means that to address the impact of the proposed developments in the Local Plan Strategy Options consultation on health services, some schemes may require land allocations but for others a capital contribution will be more appropriate. It is worth noting that given the complexity of the NHS capital regime, land allocations without capital contributions are not of great value to the health service. Generally, some form of capital contribution will always be required to ensure the deliverability of the proposed infrastructure mitigation.

Community and Mental Health Services
As set out above, community and mental health services are being increasingly organised around Primary Care Networks (PCNs – groupings of GP practices working in collaboration). Estates solutions will increasingly be designed around this way of working. We would expect the capacity impact of the proposed housing growth in the next iteration of the Borough’s Local Plan to be partly mitigated through relocation of existing services into multi-purpose Hub facilities also serving primary care, providing the additional capacity required.
In addition, local community and mental health providers have a number of critical infrastructure projects planned to support the growing demand for their services. These include a proposed new mental health inpatient unit in Bedford, and the relocation of the county’s wheelchair service to Bedford Borough.
The CCG will expect to work with the Council to seek contributions from developers to support these important infrastructure projects in a way that it is reasonable and proportionate to the size of each development.

Assessment of Strategy Options
This section provides further assessment of the impact of each of the proposed options on primary healthcare services across the Borough, and the likely mitigations to be considered as part of the Infrastructure Delivery Plan next year.
(see tables in attachment)
e hope that this information provides a useful indication of the expected impact on health services of the proposed Strategy Options set out in the Local Plan 2040 consultation document. We look forward to working with the Council throughout the development of the Local Plan and associated Infrastructure Delivery Plan.