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Your Ref: Colchester Borough Council Local Plan Tel: 0113 824 9111
Our Ref: CBC/LP/CCG/KHJM
Colchester Borough Council
33 Sheepen Road
Essex, CO3 3WG
16th September 2016
Dear Sir / Madam
Colchester Borough Council - Draft Local Plan Consultation 2016- 2033
1.1 Thank you for consulting NHS England and North East Essex CCG on the above Draft Local Plan (DLP) Document.
1.2 In reviewing the context, content and recommendations of the DLP Document and its current phase of progression, the following comments are with regard to the primary healthcare provision on behalf of NHS England Midlands & East (East) (NHSE) North East Essex Clinical Commissioning Group (CCG) and NHS Property Services (NHSPS).
2.0 Existing Healthcare Position in the Emerging Plan Area
2.1 The DLP Document covers the administrative area of Colchester with reference to the North Essex authorities to include Tendring District Council and Braintree District Council.
2.2 Currently, within the administrative area, healthcare provision incorporates a total of 21 GP Practices and 9 branch surgeries; 36 pharmacies, 30 dental surgeries, 17 opticians, and 1 Acute Hospital.
2.3 These are the healthcare services available that this DLP must take into account in formulating future strategies.
2.4 Growth, in terms of housing and employment, is proposed across a wide area and would likely have an impact on future Primary Care service provision. Existing GP practices in the area do not have capacity to accommodate significant growth.
2.5 In terms of optimal space requirements to encourage a full range of services to be delivered within the community there is an overall capacity deficit, based on weighted patient list sizes¹, within the 21 main GP Practices providing services in the area.
2.6 NHS England working with the North East Essex CCG (CCG) and the local authority has begun to address capacity issues in the area and there are a number of proposals in the pipeline. We are also working with the GP practices within Colchester to identify a preferred option to collocate many of the services provided in the area and significantly increase capacity and the range of services available to the community.
2.7 Optimal space standards are set for planning purposes only. This allows us to review the space we have available and identify the impact development growth will have in terms of capacity and service delivery. Space capacity deficit does not prevent a practice from increasing its list size, however it may impact on the level and type of services the practice is able to deliver.
2.8 NHS England and the CCG are currently working together to help plan and develop new ways of working within our primary care facilities, in line with the Five Year Forward View, to increase capacity in ways other than increasing physical space. The CCG's emerging Strategic Estates Plan will contain further detail on this and the 3 year Primary Care Estates and Technology Transformation Funding programme, which commenced in June 2016, will help to provide funding and solutions for existing capacity issues.
2.9 Existing health infrastructure will require further investment and improvement in order to meet the needs of the planned growth shown in this DLP document. The developments contained within would have an impact on healthcare provision in the area and its implications, if unmitigated, would be unsustainable.
3.0 Identification and Assessment of Policies and Strategies that have Healthcare Implications
3.1 In developing the final Local Plan document, care should be taken to ensure that emerging policies will not have an adverse impact on healthcare provision within the plan area and over the plan period.
3.2 In instances where major policies involve the provision of development in locations where healthcare service capacity is insufficient to meet the augmented needs appropriate mitigation will be sought.
3.3 Policies should be explicit in that contributions towards healthcare provision will be obtained and the Local Planning Authority will consider a development's sustainability with regard to effective healthcare provision.
3.4 The exact nature and scale of the contribution and the subsequent expenditure by NHS England will be calculated at an appropriate time as and when schemes come forward over the plan period to realise the objectives of the DLP.
3.5 Before further progression and amendment of policies are undertaken, the Local Planning Authority should have reference to the most up-to-date strategy documents from NHS England and the CCG which currently constitute The Five Year Forward View and the emerging CCG Strategic Estates Plan & Primary Care Strategy and the Sustainability Transformation Plans.
3.6 Plans and policies should be revised to ensure that they are specific enough in their aims, but are not in any way prescriptive or binding on NHS England to carry out certain development within a set timeframe, and do not give undue commitment to projects.
3.7 Notwithstanding this, there should be a reasonably worded policy within the emerging Local Plan that indicates a supportive approach from the Local Planning Authority to the improvement, reconfiguration, extension or relocation of existing medical facilities. This positive stance should also be indicated towards assessing those schemes for new bespoke medical facilities where such facilities are agreed to in writing by NHS England. New facilities will only be appropriate where they accord with the latest up-to-date NHS England and CCG strategy documents.
3.8 NHS England note the requirement for Colchester Borough Council to deliver a plan for increased levels of housing growth for their area, resulting in approximately 18,400 new dwellings during the plan period 2016 - 2033 and have identified the anticipated impact on infrastructure arising from these proposals.
3.9 NHS England and the CCG would like to draw attention to the fact that as well as infrastructure it is important to take into consideration Workforce. Primary care in Colchester has major issues with GP/Nurse workforce recruitment and retention which has resulted in compromised quality of provision in some areas, with a number of practices being rated by the Care Quality Commission as under special measures, and reduced patient access. It is vital that primary care workforce planning and need is fully considered by CBC when planning for additional housing development to ensure that the health needs of an increased population is met by a sufficient and well trained workforce. CBC also need to consider how the Local Plan can support NHSE and the CGG to pro-actively attract primary care staff to come and work and live in the area to meet the health need challenges of the population both now and in the future and ensure the safe and continuing provision of primary care services in Colchester. It is also important to ensure that workforce across the health and social care network is taken into consideration with any major developments such as the Garden Committee proposals.
3.10 As stated above the exact nature and scale of mitigation required to meet augmented needs of proposed developments will be calculated at an appropriate time, as and when schemes come forward over the plan period to realise the objectives of the LDP. It will be vital that the CCG and NHS England are consulted with by means of participating in the Infrastructure Delivery Plan process. To date it appears there has been a breakdown in communication which has resulted in no healthcare 106 contributions being realised for 2 major developments currently underway being Severalls Hospital Site and Mile End Road. Following recent discussions between the CCG and the Planning Department, a process for future potential 106 contributions has been agreed. However, the council need to take into consideration the potential implications on the health sector services the two major developments underway will have especially on Primary Care provision and ensure that the CCG and NHS England are supported with any potential funding opportunities.
3.11 Policy SP8: East Colchester/West Tendring New Garden Community, point E item 13. should be amended to read 'Primary healthcare facilities as appropriate'.
3.12 Policy SP9: West of Colchester/East of Braintree New Garden Community, point E item 13 should be amended to read 'Primary healthcare facilities as appropriate'.
3.13 Policy SP10: West of Braintree New Garden Community, point E item 12 should read 'Primary healthcare facilities as appropriate'.
3.14 Section 3. Vision and Objectives for Colchester Borough Council 2033: There are numerous paragraphs throughout this section mentioning infrastructure and facilities to support the growing community but no specific mention of working exclusively with stakeholders such as Health to ensure plans for Primary and Community Health Service facilities are factored in. This is supported in my comments of 3.10 where the local Health Service now find itself in a position of lack of essential funding to ensure provision of facilities to new developments in North Colchester. Better processes need to be embedded to ensure any potential funding is realised. In addition, as part of our emerging strategies which include the Primary Care Strategy, Sustainability Transformation Plan and Strategic Estates Plan we are reviewing potential options for Primary Care Hub's which will support services in the community in line with our Care Closer to Home contract.
3.15 Section 4.20: As part of the described Sustainable Development of 3 District Communities (I am assuming this is referring to the Garden Community Settlements) there is a list of accessible community facilities which includes a Doctors Surgery within the list of facilities within a 400m distance. Can this be amended to Health Facility (including Community and Primary Care Services) if appropriate as our emerging strategies including Sustainability Transformation Plan, Primary Care Strategy and Strategic Estates Strategy may establish a different need for a facility to be required/located.
3.16 Section4.56 - 4.57: please provide timescales for when input to the Infrastructure Delivery Plan will be as this is our best opportunity to ensuring Health facility requirements and funding associated with those requirements can be made clearer.
3.17 Section 4.58: Please amend to and healthcare services and facilities by the North East Essex Clinical Commissioning Group and NHS England Midlands & East (East) (NHSE)
3.18 Section 6.177: reference to Winstree Road Medical Practice and the practice being at capacity. As part of the Primary Care Transformation agenda, capacities at existing surgeries are currently under review. The potential additional capacity requirements of this area will be taken into consideration.
3.19 Section 7 DM1 Health and Wellbeing: North East Essex Clinical Commissioning Group and NHSE Midlands and East agree with the statements in this section and welcome discussion to ensure that Health Impact Assessments are undertaken by developers at the point of any preliminary enquiry or outline Planning Application.
4.1 This response follows a consultation by Colchester on the Preferred Options Local Plan.
4.2 In its capacity as healthcare provider, NHS England and the CCG have requested that the Local Planning Authority identifies policies and strategies that are considered to directly or indirectly impact upon healthcare provision and has responded with comments to help shape future policy.
4.3 Assuming the comments are incorporated wholly within the future Local Plan then NHS England or the CCG would not which to raise an objection to the Colchester Preferred Options Local Plan.
4.4 NHS England has also identified shortfalls in capacity at existing premises covered by the DLP. Provision needs to be made within the emerging DLP to address the impacts of development on health infrastructure and to ensure timely cost-effective delivery of necessary infrastructure improvements, in the interests of pursuing sustainable development.
4.5 The recommendations set out above are those that NHS England, the CCG and NHSPS deem appropriate having regard to the projected needs arising from the Colchester Preferred Options Local Plan. However, if the recommendations are not implemented then NHS England reserve the right to make representations about the soundness of the plan at relevant junctures during the adoption process.
Kerry Harding Jane Mower
Estates Advisor (NHSE) Estates Programme Manager (NEE CCG)
CC:. Pam Green - North East Essex CCG - Director of Transformation and Strategy
James Archard - North East Essex CCG - Deputy Director of Transformation & Strategy
Penny Lansdown - North East Essex CCG - Interim Head of Primary Care
David Barter - NHS England- Contracts Manager