Torbay Local Plan Regulation 19 Publication Version and Consultation
Search representations
Results for NHS Devon Integrated Care Board & Torbay & South Devon NHS Foundation Trust search
New search
New search
Torbay Local Plan Regulation 19 Publication Version and Consultation
Strategic Policy SCS: Sustainable and inclusive communities strategy
Respondent: NHS Devon Integrated Care Board & Torbay & South Devon NHS Foundation Trust
Representation Summary:
The NHS strongly supports Strategic Policy SCS.
The policy appropriately recognises:
• the role of development in improving quality of life;
• the need to reduce health inequalities;
• access to health and other community facilities;
• the maintenance and improvement of strategic health services;
• the particular importance of Torbay Hospital; and
• the need for development to contribute to health services where it would exacerbate shortfalls.
The associated explanation is also strongly supported, particularly the acknowledgement that the NHS has identified severe shortfalls in primary and secondary healthcare provision and that contributions will be sought where development is likely to increase pressure upon health services.
Reason for proposed update
The policy provides a strong strategic foundation but should be updated to use the August 2026 NPPF terminology of public service infrastructure and to recognise primary, community and acute healthcare infrastructure expressly.
This would remove any potential uncertainty as to whether the policy applies only to access to healthcare services or also to the physical infrastructure required to provide those services.
Change suggested by respondent:
Suggested amendment
Amend the relevant parts of Strategic Policy SCS to state:
The maintenance and improvement of strategic healthcare services and public service infrastructure in Torbay, commensurate with the size, distribution, needs and age structure of the population, with a key focus on Torbay Hospital and the primary, community and acute healthcare infrastructure serving Torbay.
And:
Contribute towards health services and healthcare infrastructure, policing and other public service infrastructure where development generates additional demand or would exacerbate an identified shortfall in provision.
Add to the supporting text:
Healthcare infrastructure includes primary, community and acute healthcare facilities and associated healthcare estate. The Council will work with NHS Devon Integrated Care Board, Torbay and South Devon NHS Foundation Trust and other relevant healthcare providers to identify the infrastructure required to support planned growth and ensure that development-related requirements are reflected within the Infrastructure Delivery Plan.
Torbay Local Plan Regulation 19 Publication Version and Consultation
Strategic Policy SC1: Public health and wellbeing
Respondent: NHS Devon Integrated Care Board & Torbay & South Devon NHS Foundation Trust
Representation Summary:
NHS support
The NHS strongly supports Policy SC1 and its emphasis upon:
• reducing health inequalities;
• healthy lifestyles;
• sustainable neighbourhoods;
• active travel;
• appropriate housing;
• social connectedness;
• employment;
• access to nature;
• public transport; and
• healthy food environments.
These matters are important determinants of population health and should remain central to the Plan.
Reason for proposed update
The determinants of health and the provision of healthcare infrastructure are closely connected but distinct planning considerations.
A development may provide high-quality homes, active travel, green infrastructure and healthy public spaces while still generating additional demand that cannot be accommodated within existing healthcare premises.
The policy should therefore distinguish:
1. creating places that support good health and reduce inequalities; and
2. ensuring that the physical healthcare infrastructure required to provide access to treatment keeps pace with development.
Change suggested by respondent:
Suggested amendment
Add the following to Policy SC1:
Development must address both the wider determinants of health and its implications for access to, and the capacity of, healthcare infrastructure. Where development is likely to generate additional demand for primary, community or acute healthcare infrastructure that cannot be accommodated within available infrastructure capacity,
proposals must be informed by proportionate engagement with the relevant NHS organisation and must identify any necessary development-related mitigation.
Where the Plan retains a Health Impact Assessment requirement, add:
Health Impact Assessments must consider both the wider determinants of health and the implications of the development for healthcare access, capacity and infrastructure. The scope of the assessment should be proportionate to the development and informed by engagement with the Council’s public health function and the relevant NHS organisation.
This would ensure that Health Impact Assessments do not focus solely upon healthy placemaking while overlooking the infrastructure required to provide healthcare.
Torbay Local Plan Regulation 19 Publication Version and Consultation
Strategic Policy INS: Sustainable infrastructure
Respondent: NHS Devon Integrated Care Board & Torbay & South Devon NHS Foundation Trust
Representation Summary:
The NHS strongly supports Strategic Policy INS, including its requirements that development:
• provide or contribute to the infrastructure required to meet the needs it generates;
• deliver infrastructure at the appropriate time;
• phase development and infrastructure where necessary;
• provide infrastructure on site where possible; and
• secure off-site infrastructure through planning obligations where appropriate.
These provisions establish an effective starting point for infrastructure delivery.
Reason for proposed update
The reference to physical, social and environmental infrastructure is broad enough potentially to include healthcare. However, the examples of critical infrastructure focus upon flood defence, highway safety, water, sewerage, waste and environmental requirements.
The August 2026 NPPF now expressly includes healthcare facilities of all types within public service infrastructure. The NHS therefore recommends that the policy identify healthcare expressly.
The purpose of this change is not to suggest that every development will require a healthcare contribution. Any mitigation must remain justified by the circumstances and impacts of the development. Rather, it ensures that healthcare is treated as a mainstream infrastructure consideration alongside education, transport and utilities.
Change suggested by respondent:
Suggested amendment
Amend the opening paragraph of Strategic Policy INS to read:
All development will be expected to provide the physical, social, environmental and public service infrastructure needed to make it acceptable in planning terms. Public service infrastructure includes healthcare facilities of all types, including primary, community and acute healthcare infrastructure.
Add:
Where proportionate evidence provided by the relevant NHS organisation demonstrates that development, either individually or cumulatively with other planned growth, generates a requirement for additional healthcare infrastructure, the necessary development-related mitigation will be identified and secured through appropriate on-site provision, appropriately serviced land, works, premises reconfiguration, extension, relocation, replacement, new healthcare floorspace, direct delivery or financial contributions, subject to the relevant statutory and national policy tests.
Add:
Infrastructure must be delivered at the stage at which it is required. For phased or strategic development, an infrastructure delivery strategy must identify healthcare requirements, delivery responsibilities, funding arrangements and appropriate delivery or occupation triggers.
Torbay Local Plan Regulation 19 Publication Version and Consultation
Strategic Policy IN1: Prioritisation of planning obligations
Respondent: NHS Devon Integrated Care Board & Torbay & South Devon NHS Foundation Trust
Representation Summary:
The NHS welcomes the express inclusion of healthcare contributions within Policy IN1.
The policy provides an important basis for ensuring that development contributes towards the infrastructure required to mitigate its impact. The NHS also supports:
• application-specific consideration of obligations;
• independent assessment where viability is relied upon;
• review mechanisms where contributions are reduced;
• pooling of contributions where appropriate; and
• the acknowledgement that specialist accommodation may generate different healthcare requirements.
Need for clarification
The policy places employment and healthcare contributions at priority four. However, paragraph 7.10 appears to describe priority four as employment and town-centre regeneration while placing health facilities within broader sustainable development contributions.
This internal inconsistency could create uncertainty when infrastructure requirements are prioritised, particularly where viability is constrained.
The policy should also make clear that the hierarchy does not override an application-specific assessment of whether healthcare mitigation is necessary to make a particular development acceptable.
Change suggested by respondent:
Suggested amendment
Retain healthcare infrastructure within priority four and amend both the policy and explanatory text consistently:
4. Healthcare and employment infrastructure contributions.
Supporting text:
Healthcare infrastructure contributions will be sought where proportionate evidence provided by the relevant NHS organisation demonstrates that development would generate additional demand that cannot be accommodated within available infrastructure capacity. Contributions may support primary, community or acute healthcare infrastructure and must relate only to the mitigation of development-generated impacts.
Healthcare infrastructure mitigation may comprise land, appropriately serviced land, premises reconfiguration, extension, relocation or replacement, new healthcare floorspace, direct delivery of infrastructure, associated works, or financial contributions, as justified by proportionate evidence.
The priority hierarchy is a starting point and does not displace the assessment of individual obligations against the applicable statutory and national policy tests. Where healthcare infrastructure mitigation is necessary to make a development acceptable, that requirement will be considered on its individual planning merits.
Opportunities to align healthcare infrastructure investment with town-centre regeneration, neighbourhood renewal, co-location, public-sector estate optimisation and prevention objectives should be considered where appropriate. However, healthcare infrastructure requirements must be identified and prioritised principally on the basis of population need, service catchments, infrastructure capacity, clinical requirements, operational requirements and deliverability. While wider regeneration, estate optimisation and prevention benefits may represent important additional outcomes, the absence of such benefits should not reduce the planning weight afforded to healthcare infrastructure that is otherwise necessary to accommodate development-generated demand or address identified infrastructure requirements.
Where viability evidence results in a proposed reduction in identified healthcare mitigation, the Council will consult the relevant NHS organisation and, where appropriate, secure a viability review mechanism through the planning obligation.
Reason for modification
The policy correctly recognises healthcare infrastructure within the planning obligations hierarchy. However, additional clarification is necessary to ensure the policy and supporting text provide a clear and effective framework for considering development-related healthcare infrastructure requirements.
The proposed changes would clarify the circumstances in which healthcare mitigation may be required, recognise the full range of mitigation measures that may be appropriate, and confirm that the priority hierarchy does not override the assessment of individual obligations against the applicable statutory and national policy tests.
The amendments would also support opportunities to align healthcare infrastructure investment with wider regeneration and public estate initiatives where appropriate, whilst confirming that healthcare infrastructure priorities should continue to be informed principally by population need, service catchments, infrastructure capacity, clinical requirements and deliverability.
These changes would strengthen the effectiveness of the policy and supporting text without altering the Council's overall infrastructure hierarchy or approach to viability.
Torbay Local Plan Regulation 19 Publication Version and Consultation
Strategic Policy SS1: Torbay Growth Strategy - Prioritising our communities through improved health, housing, place making and opportunities for all
Respondent: NHS Devon Integrated Care Board & Torbay & South Devon NHS Foundation Trust
Representation Summary:
The NHS supports the identification of Torquay Gateway and West of Paignton as Future Growth Areas and welcomes the requirement for development to be supported by timely infrastructure.
The scale and cumulative nature of development within these areas make early and coordinated infrastructure planning particularly important.
Change suggested by respondent:
Suggested amendment
Add the following to the Future Growth Area and relevant strategic allocation policies:
Masterplans and infrastructure delivery strategies must be prepared following proportionate engagement with NHS Devon Integrated Care Board and Torbay and South Devon NHS Foundation Trust. They must assess the individual and cumulative implications of development for primary, community and acute healthcare infrastructure and identify any necessary land, appropriately serviced land, floorspace, works, infrastructure projects, direct provision or financial contributions. Healthcare infrastructure must be appropriately coordinated and phased with housing delivery.
For the Torquay Gateway and Torbay Hospital area, add:
Development must safeguard and, where appropriate, support the safe and effective operation, accessibility, modernisation, redevelopment, estate transformation and reasonable future expansion of Torbay Hospital as strategic public service infrastructure. Proposals must not prejudice the delivery of existing or future healthcare infrastructure projects, including strategic hospital redevelopment or replacement facilities, or introduce incompatible access, amenity or operational constraints.
This would strengthen rather than alter the spatial strategy and would give practical effect to the Plan’s existing focus on Torbay Hospital.
For instructions on how to use the system and make comments, please see our
help guide.
