Congleton Neighbourhood Plan Regulation 16 Consultation
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Congleton Neighbourhood Plan Regulation 16 Consultation
Submitted Plan
Representation ID: 68
Received: 10/11/2025
Respondent: Cheshire and Merseyside Integrated Care Board and NHS Property Services Ltd
BY EMAIL ONLY
RE: Consultation on Congleton Neighbourhood Plan Submission Version (Regulation 16)
Thank you for the opportunity to comment on the above document. The following representations are submitted by NHS Property Services (NHSPS) on behalf of Cheshire and Merseyside Integrated Care Board (ICB).
Background
Cheshire and Merseyside ICB commissions (plans, designs and purchases) many of the health services that local people use, including medicines, hospital care, urgent and emergency services, mental health care, GP services, Community Pharmacy, dentistry and general ophthalmology (eye care services) and many community services.
NHSPS is part of the NHS and is wholly owned by the Department of Health and Social Care (DHSC). NHSPS manages, maintains and improves NHS properties and facilities, working in partnership with NHS organisations to create safe, efficient, sustainable and modern healthcare environments. We partner with local NHS Integrated Care Boards (ICBs) and wider NHS organisations to help them plan and manage their estates to unlock greater value and ensure every patient can get the care they need in the right place and space for them.
Developments often have very significant impacts in terms of the need for additional healthcare provision for future residents, meaning that a planning obligation requiring that the development contributes to or delivers a new healthcare facility is often necessary.
General Comments on Health Infrastructure to Support Housing Growth
The delivery of new and improved healthcare infrastructure is significantly resource intensive. The NHS as a whole is facing significant constraints in terms of the funding needed to deliver healthcare services, and population growth from new housing development adds further pressure to the system. New development should make a proportionate contribution to funding the healthcare needs arising from new development. Health provision is an integral component of sustainable development – access to essential healthcare services promotes good health outcomes and supports the overall social and economic wellbeing of an area.
Residential developments often have very significant impacts in terms of the need for additional primary and community healthcare provision for future residents. Given health and care infrastructure’s strategic importance to supporting housing growth and sustainable development, it should be considered at the forefront of the priorities for infrastructure delivery. The ability to continually review the quality and utilisation of healthcare, and wider public estate, optimise land use, and deliver health services from modern fit for the future facilities is crucial. Infrastructure including access to digital solutions must be supported to develop, modernise, or be protected in line with integrated NHS strategies. Planning policies should enable the delivery of essential health and care infrastructure.
Policy 10 Accessibility to Health and Wellbeing
We support the inclusion of a reference at Policy 10 (Accessibility to Health and Wellbeing) that proposals for new health and wellbeing facilities and services will be strongly supported. We also support the requirement for Health Impact Assessments to be undertaken for major developments, taking into consideration the implications on mental wellbeing.
We are pleased to see that the Regulation 16 version now includes reference to the scenario whereby the sale or reuse of health assets is reinvested into services. All NHS land disposals 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.
It is noted that in the justification for Policy 10 of the Neighbourhood Plan, it states that the Neighbourhood Plan cannot request or identify new or expanded provision. We do however recommend that the Neighbourhood Plan makes reference to the use of developer contributions towards healthcare infrastructure to ensure alignment with national planning policy.
For accuracy, when referring to new or expanded provision of services and facilities in the justification text, Cheshire and Merseyside Integrated Care Board (ICB) should also be referenced this is the NHS organisation responsible for commissioning services, such as GP practices, at the local level.
Policy 12 The Future of Local Community Facilities
We note that both Policies 10 and 12 refer to the potential loss of community facilities. It should therefore be considered whether these policies can be amalgamated to ensure consistency.
As currently worded Policy 12 is restrictive for the NHS from an estate redevelopment perspective, which could be harmful to the NHS and the ability to adapt to changing requirements. This seems to be an unintended consequence of the policy, which at present does not reflect the ownership and management of NHS facilities that are often different from other forms of community infrastructure, such as those owned and managed by the local authority.
Where healthcare facilities are included within the Local’s Plan definition of community facilities, policies aimed at preventing the loss or change of use of community facilities and assets can potentially have a harmful impact on the NHS’s ability to ensure the delivery of essential facilities and services for the community.
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.
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. The following amendment is therefore recommended:
Proposed Modification to Policy 12:
Where healthcare facilities are formally declared surplus to the operational healthcare requirements of the NHS or identified as surplus as part of a published estates strategy or service transformation plan, there will be no requirement to retain any part of the site in an alternative community use.
Conclusion
Cheshire and Merseyside ICB and NHSPS thank the Council for the opportunity to comment on the Regulation 14 consultation. Should you have any queries or require any further information, please don’t hesitate to contact us. NHSPS would be grateful to be kept informed of the progression of the Neighbourhood Plan via our dedicated email address, town.planning@property.nhs.uk.
Yours faithfully,
Lucy Andrews and Laura Allen RTPI
BY EMAIL ONLY
RE: Consultation on Congleton Neighbourhood Plan Submission Version (Regulation 16)
Thank you for the opportunity to comment on the above document. The following representations are submitted by NHS Property Services (NHSPS) on behalf of Cheshire and Merseyside Integrated Care Board (ICB).
Background
Cheshire and Merseyside ICB commissions (plans, designs and purchases) many of the health services that local people use, including medicines, hospital care, urgent and emergency services, mental health care, GP services, Community Pharmacy, dentistry and general ophthalmology (eye care services) and many community services.
NHSPS is part of the NHS and is wholly owned by the Department of Health and Social Care (DHSC). NHSPS manages, maintains and improves NHS properties and facilities, working in partnership with NHS organisations to create safe, efficient, sustainable and modern healthcare environments. We partner with local NHS Integrated Care Boards (ICBs) and wider NHS organisations to help them plan and manage their estates to unlock greater value and ensure every patient can get the care they need in the right place and space for them.
Developments often have very significant impacts in terms of the need for additional healthcare provision for future residents, meaning that a planning obligation requiring that the development contributes to or delivers a new healthcare facility is often necessary.
General Comments on Health Infrastructure to Support Housing Growth
The delivery of new and improved healthcare infrastructure is significantly resource intensive. The NHS as a whole is facing significant constraints in terms of the funding needed to deliver healthcare services, and population growth from new housing development adds further pressure to the system. New development should make a proportionate contribution to funding the healthcare needs arising from new development. Health provision is an integral component of sustainable development – access to essential healthcare services promotes good health outcomes and supports the overall social and economic wellbeing of an area.
Residential developments often have very significant impacts in terms of the need for additional primary and community healthcare provision for future residents. Given health and care infrastructure’s strategic importance to supporting housing growth and sustainable development, it should be considered at the forefront of the priorities for infrastructure delivery. The ability to continually review the quality and utilisation of healthcare, and wider public estate, optimise land use, and deliver health services from modern fit for the future facilities is crucial. Infrastructure including access to digital solutions must be supported to develop, modernise, or be protected in line with integrated NHS strategies. Planning policies should enable the delivery of essential health and care infrastructure.
Policy 10 Accessibility to Health and Wellbeing
We support the inclusion of a reference at Policy 10 (Accessibility to Health and Wellbeing) that proposals for new health and wellbeing facilities and services will be strongly supported. We also support the requirement for Health Impact Assessments to be undertaken for major developments, taking into consideration the implications on mental wellbeing.
We are pleased to see that the Regulation 16 version now includes reference to the scenario whereby the sale or reuse of health assets is reinvested into services. All NHS land disposals 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.
It is noted that in the justification for Policy 10 of the Neighbourhood Plan, it states that the Neighbourhood Plan cannot request or identify new or expanded provision. We do however recommend that the Neighbourhood Plan makes reference to the use of developer contributions towards healthcare infrastructure to ensure alignment with national planning policy.
For accuracy, when referring to new or expanded provision of services and facilities in the justification text, Cheshire and Merseyside Integrated Care Board (ICB) should also be referenced this is the NHS organisation responsible for commissioning services, such as GP practices, at the local level.
Policy 12 The Future of Local Community Facilities
We note that both Policies 10 and 12 refer to the potential loss of community facilities. It should therefore be considered whether these policies can be amalgamated to ensure consistency.
As currently worded Policy 12 is restrictive for the NHS from an estate redevelopment perspective, which could be harmful to the NHS and the ability to adapt to changing requirements. This seems to be an unintended consequence of the policy, which at present does not reflect the ownership and management of NHS facilities that are often different from other forms of community infrastructure, such as those owned and managed by the local authority.
Where healthcare facilities are included within the Local’s Plan definition of community facilities, policies aimed at preventing the loss or change of use of community facilities and assets can potentially have a harmful impact on the NHS’s ability to ensure the delivery of essential facilities and services for the community.
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.
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. The following amendment is therefore recommended:
Proposed Modification to Policy 12:
Where healthcare facilities are formally declared surplus to the operational healthcare requirements of the NHS or identified as surplus as part of a published estates strategy or service transformation plan, there will be no requirement to retain any part of the site in an alternative community use.
Conclusion
Cheshire and Merseyside ICB and NHSPS thank the Council for the opportunity to comment on the Regulation 14 consultation. Should you have any queries or require any further information, please don’t hesitate to contact us. NHSPS would be grateful to be kept informed of the progression of the Neighbourhood Plan via our dedicated email address, town.planning@property.nhs.uk.
Yours faithfully,
Lucy Andrews and Laura Allen RTPI
