Sevenoaks District Draft Local Plan Consultation July 2018

Document Section Draft Local Plan July 2018 Supporting a Vibrant and Balanced Economy Visitor Economy Policy 14 - Town and Local Centres [View all comments on this section]
Comment ID DLPP802
Respondent Mark Adams ID-3516 [View all comments by this respondent]
Response Date 19 Sep 2018
Current Status Accepted

Object - Clarification and Amendment
Policy 14 includes reference to the protection of community facilities, stating
The loss of local services and facilities will be resisted where they are serving a local need.
Exceptions will be made where equivalent replacement facilities equally accessible to the population
served are provided, or where it is demonstrated, through evidence submitted that the continued
operation of the service or facility is no longer needed or financially viable.
Where school and community buildings become vacant or redundant and there is no
requirement for an alternative educational use or the existing community use, priority will
be given to reusing the buildings or site to address local need for community facilities.
Proposals for change of use or redevelopment for alternative non community uses will only
be considered if it is demonstrated by the applicant that there is no identified community
need that can be facilitated through the site, or that community facilities that meet the
identified need are incorporated into a wider mixed use scheme.
To confirm, a property can only be released for disposal or alternative use by NHSPS once Commissioners
have confirmed that it is no longer required for the delivery of NHS services. Furthermore, NHSPS estate
code requires that any property to be disposed of is first listed on “e-PIMS”, the central database of
Government Central Civil Estate properties and land, which allows other public sector bodies to consider their
use for it.
The ability of the NHS to continually review the healthcare estate, optimise the use of land, and deliver
health services from modern and fit for purpose facilities is crucial. It is important to note that there are
separate, rigorous testing and approval processes employed by NHS commissioners to identify unneeded
and unsuitable healthcare facilities. These must be satisfied prior to any property being declared surplus and
put up for disposal. This often includes extensive public consultation on any proposed service relocations.
Given that there is very careful oversight from NHS England and CCGs to ensure sufficient services are reprovided, and that the estate is fit-for-purpose, additional protection through planning policy should be
unnecessarily in relation to public healthcare facilities.
Faced with financial pressures, the NHS requires flexibility in its estate. In particular, the capital receipts and
revenue savings generated from the disposal of unneeded or unsuitable sites and properties for best value is
an important component in helping to provide funding for new or improved services and facilities.
Restrictive policies, especially those which require substantial periods of marketing, could
prevent or delay required investment in new/improved services and facilities.
Therefore, where NHS commissioners can demonstrate that all/part of a site is no longer
required for the provision of services (declared surplus to operational requirements), there
should be a presumption that such sites are suitable for other appropriate uses (including
housing), and should not be subject to restrictive policies or periods of marketing.
We would therefore suggest inclusion of the following text within the policy for clarification;
<INSERT>The loss or change of use of existing health facilities will be acceptable if it is
shown that this forms part of a wider estate reorganisation programme to ensure the
continued delivery of services. Evidence of such a programme will be accepted as a clear
demonstration that the facility under consideration is neither needed nor viable and that
adequate facilities are or will be made available to meet the ongoing needs of the local
population. In such cases, any restrictions under Policy 14 would not apply, and
proposals for an alternative use of the site (e/g residential) would be considered
acceptable. <END>
NHSPS would only support Policy 14 where it includes clarification as above
NHS PS would welcome any further discussion on these matters.