Regulation 19 - Proposed Draft Local Plan Submission

after section 3 d) or
e) Where healthcare facilities are declared surplus or identified as part of an estate’s strategy or service transformation plan where investment is needed towards modern, fit for purpose infrastructure and facilities, there will be no requirement to retain any part of the site in an alternative community use

The NHS requires flexibility with regards to the use of its estate to deliver its core objective of enabling excellent patient care and support key healthcare strategies such as the NHS Long Term Plan. In particular, the disposal of sites and properties which are redundant or no longer suitable for healthcare for best value (open market value) is a critical component in helping to fund new or improved services within a local area. Requiring NHS disposal sites to explore the potential for alternative community uses and/or to retain a substantial proportion of community facility provision adds unjustified delay to vital reinvestment in facilities and services for the community.

All NHS land disposals must follow a rigorous process to ensure that levels of healthcare service provision in the locality of disposals are maintained or enhanced, and proceeds from land sales are re-invested in the provision of healthcare services locally and nationally. The decision about whether a property is surplus to NHS requirements is made by local health commissioners and NHS England. Sites can only be disposed of once the operational health requirement has ceased. This does not mean that the healthcare services are no longer needed in the area, rather it means that there are alternative provisions that are being invested in to modernise services.
Where it can be demonstrated that health facilities are surplus to requirements or will be changed as part of wider NHS estate reorganisation and service transformation programmes, it should be accepted that a facility is neither needed nor viable for its current use, and policies within the Local Plan should support the principle of alternative uses for NHS sites with no requirement for retention of a community facility use on the land or submission of onerous information.

Proposed Modification to Draft Policy:
Proposals resulting in the loss of existing community facilities will only be supported where the
applicant demonstrates that:
a) a replacement facility is being provided on the same site, with efforts made to provide
temporary alternative provision where feasible; or
b) an alternative facility on another site to meet local needs is available that is both equally
accessible and provides equal or enhanced benefits to the community in advance of closure; or
c) all options for continuation in its current use have been fully explored, including diversification, and none remain which would be financially viable; and
d) it is demonstrated that the site is no longer required and is unlikely to be re-used for its current use or re-developed for an alternative community use as evidenced by active
marketing for at least 12 months at an appropriate price for its current use free of tie and restrictive covenant and there has been no definite interest in either the freehold or
leasehold during that specified period; or
e) Where healthcare facilities are declared surplus or identified as part of an estate’s strategy or service transformation plan where investment is needed towards modern, fit for purpose infrastructure and facilities, there will be no requirement to retain any part of the site in an alternative community use.

NHSPS request a modification to policy DM12 to reflect flexibility in the policy to allow for NHS estate transformation. This flexibility, will allow for the policy to be positively prepared and effective.