Comment

Representation ID: 15437

Received: 09/05/2016

Respondent: North East London NHS Foundation Trust

Agent: Ingleton Wood LLP

NELFT are generally supportive of the Council's Vision and Strategic Objectives, particularly Strategic Objective 11 (SO11), which seeks to enhance social inclusion, health and wellbeing. Our client also recognises the need for the forecast growth of 7,240 new residential dwellings (362 dwellings per annum) in policy 5.2 during the period up to 2033, and the need to provide sufficient social infrastructure including health care facilities to support this growth.

Object

Representation ID: 15438

Received: 09/05/2016

Respondent: North East London NHS Foundation Trust

Agent: Ingleton Wood LLP

NELFT provides community health and mental health services in Essex and the north east London Boroughs of Barking and Dagenham, Havering, Redbridge and Waltham Forest. The area within their jurisdiction includes the Borough of Brentwood. However, NELFT object to Section 10 of the draft Local Plan on the basis that it is not 'sound' in accordance with paragraph 182 of the National Planning Policy Framework (NPPF). More specifically, with regard to the provision of healthcare and associated facilities, it is considered that as drafted the plan does not deliver the most appropriate strategy and does not reflect an effective approach to cross boundary working on strategic issues. Although the draft Plan outlines the need to create healthy, inclusive communities and notes specific requirements relating to open space and community facilities, there is no specific strategic policy regarding the provision of healthcare facilities.

Object

Representation ID: 15440

Received: 09/05/2016

Respondent: North East London NHS Foundation Trust

Agent: Ingleton Wood LLP

As drafted the Local Plan does not identify an effective strategy to promote / require the delivery of adequate social infrastructure for the forecast growth within the Borough. It is requested that a specific policy seeking to promote and support, in principle, the provision of healthcare facilities is incorporated into the Local Plan. The policy should ensure that new and improved facilities are provided in light of assessment of the need for such facilities in the area and support the co-location of health and social care services where this would bring about improvements in access for the community. In addition, the policy should seek to secure the provision, enhancement and maintenance of health and social care facilities through planning obligations.

Object

Representation ID: 15441

Received: 09/05/2016

Respondent: North East London NHS Foundation Trust

Agent: Ingleton Wood LLP

Plan does not adopt a partnership approach to the provision of healthcare. As drafted the document notes that the Clinical Commissioning Group is responsible for planning, designing, buying and the performance management of NHS services. Whilst the Clinical Commissioning Group have a statutory duty to improve the health of the local populations, the approach proposed does not have regard to the role of other health care providers and bodies within the locality and therefore does not consider the local implications of the forecast growth within the plan. In order to ensure the Local Plan is 'sound' a collaborative working arrangement should be established between the Borough Council, Essex County Council, the Clinical Commissioning Group, public health bodies and healthcare organisations to develop a comprehensive plan to the delivery of healthcare to meet local needs across the plan period.

Object

Representation ID: 15444

Received: 09/05/2016

Respondent: North East London NHS Foundation Trust

Agent: Ingleton Wood LLP

request amendments are made to Section 10 of the draft Local Plan to reflect that, in certain circumstances, healthcare facilities can be redeveloped for alternative uses or amalgamated with other facilities if they are no longer required or fit for purpose. It is acknowledged that any such policy would need to incorporate criteria requiring any such proposal to provide evidence that the facility is not required and that its loss will not undermine the provision of services in the Borough. The disposal of facilities no longer required for alternative uses is key to overall strategy for the provision of new modern facilities that meet the ongoing requirements of community. This will ensure a joined up approach to delivering the necessary infrastructure in parallel to the forecast growth, ensuring that the plan is effective, justified and sound.