Object

Publication Plan November 2022

Representation ID: 5381

Received: 09/12/2022

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

This policy refers to proposed developments causing ‘unacceptable impact’ on existing healthcare facilities but fails to define what level of impact is deemed unacceptable or how that is to be measured. The policy should acknowledge that not all residents of a development will be new to a catchment area and may indeed already be registered by the local health care provider, thereby not creating a net additional burden.
Careful analysis is required therefore with regard to the capacity of existing infrastructure to accommodate new patients, before reaching a conclusion as to what any CIL Regulation 122 compliant financial request might be. The requirement for CIL Reg compliance of any request should be clearly specified within policy.
The policy is considered unsound without amendment, as it is neither justified nor consistent with national policy for the reasons set out above.