In December, the Government released the draft NPPF for consultation until the 10th March 2026. It has been wholly restructured, differentiating between policies that are for national decision-making and for plan-making, and in many ways has been 'Reimagined, ramped up and revisited' - as discussed by our colleagues Jennie Baker and Sean Farrissey in their recent blog. In terms of the delivery of important new public infrastructure, the timing of the new consultation coincides with recent research from Lichfields which uncovered a real misalignment between local planning frameworks and strategic healthcare plans in particular. Lichfields’ Insight piece ‘Prescription pending: Strategic Planning for Healthcare’, released in September last year, demonstrated a lack of synergy between planning policy at a local level and health infrastructure investment strategies, and called for better integration between the two to support the delivery of all important healthcare infrastructure.
As part of the current consultation, Chapter 8 of the current NPPF ‘Promoting healthy and safe communities’ has been revisited and newly titled ‘Promoting healthy communities’ (and is now found at Chapter 16 of the draft NPPF document). Public service infrastructure itself is also now newly defined within the document as ‘Education and healthcare facilities of all types, and facilities for blue light, social care, library and criminal justice uses’. The proposed changes to the Chapter themselves, whilst not revolutionary, provide for some clear distinctions from the current NPPF, which we consider further in this blog, and are important to the delivery of healthcare infrastructure nationally.
In this context, an effective framework to plan for and deliver healthcare infrastructure is particularly important in light of the Government’s ambitious plans, announced in the recent Budget, for a major push in the delivery of Neighbourhood Health Centres (NHCs) in England; aiming for 250 "one-stop-shop" hubs with GPs, nurses, and dentists, prioritizing deprived areas, with 120 ready by 2030, funded partly by public-private partnerships. So, do the proposed reforms to the NPPF assist in providing a more effective planning policy framework for delivering healthcare infrastructure and meeting the Government’s ambitions for the NHS?
A greater emphasis on engagement
The importance of engagement with both relevant service providers and local communities in the delivery of community facilities and public service infrastructure is clearly emphasised by Plan-making policy HC1 (part 2) and NDMP HC4 (part 2) in the new NPPF. Specifically, policy HC1 (part 2) calls for ‘considerable importance’ to be attached to [our emphasis] ‘providing for sufficient education facilities (including early years, school and post-16 provision), health care provision and other essential community facilities and public service infrastructure over the plan period, in a way that aligns with the needs of the local population and any wider requirements for improvements in public service infrastructure identified by the government or public agencies (recognising that some public service infrastructure serves a larger than local population).’ Whilst NDMP HC4 (part 2) calls for developers and local authorities to ‘collaborate in a positive and proactive manner’.
These policies elaborate upon the requirements of Paragraphs 100 and 101 in the current NPPF, for Local Planning Authorities to work proactively with relevant bodies such as health trusts and calls for clear alignment with identified needs for public service infrastructure; as well as placing greater emphasis on developers also engaging with providers at an early stage. The new policy-based requirements for early engagement invite greater opportunity for healthcare bodies needs and strategies to be discussed and established from early on. In the context of the Government’s broader housing delivery objectives, and the implications of this in terms of accelerated local plan preparation, this offers real opportunities to provide better alignment between planning policy at a national and local level, and also streamline the practicalities of delivering public infrastructure, such as healthcare centres, with service providers central to this process. The introduction of this requirement for early engagement is positive, as the better informed the planning process is, the more effectively we can plan for the much-needed new infrastructure – including the delivery of the 25 new hospitals outlined in Governments the New Hospitals Programme.
Allocating land for community facilities and public service infrastructure
The restructuring and distinction between pan-making policies and decision-making policies applies across all Chapters of the new NPPF. With respect to the ‘Promoting healthy communities’ chapter, the new plan-making policies and NDMPs provide greater clarity over what is expected at the plan making stage and at the planning application stage relative to the current NPPF. In particular, the new Plan-making policy HC1 (part 1) now requires Local Planning Authorities to ‘allocate land specifically for community facilities and public service infrastructure’ - this surpasses the expectations of Paragraph 20 in the current NPPF which requires Local Planning Authorities’ strategic polices to set out an overall strategy for the pattern scale and design of places and make sufficient provision for community facilities, but does not require land to be allocated for such facilities.
Particularly in the context of the accelerated development programme for the delivery of Neighbourhood Health Centres, our Insight research revealed that currently there is an absence of specific health-related planning policies at a local level to guide the delivery of healthcare infrastructure. Findings showed that around 63% of ‘up-to-date’ Local Plans, in NPPF terms, contained strategic policies with high-level objective to improve health within the Local Planning Authority area, and that only around a quarter (26%) of the same plans contained site-specific policies, allocations or designations for the delivery of healthcare related infrastructure projects. Crucially, many Neighbourhood Health Centre sites will need to progress without any formal planning status through an allocation or site-specific designation. The new NPPF positively provides for greater clarity on national healthcare infrastructure policy expectations and appears to increase its importance on the agenda for new development through the proposed new site allocations. It is not clear at this stage how this may transition into local plans; however, we may expect something similar to designations for employment areas and housing areas.
Conclusion summary
Overall, the new ‘Promoting healthy communities’ chapter encourages more proactive planning for public facilities, including healthcare facilities, and sets clear policy expectations for Local Planning Authorities and developers accordingly. In this context, early and proactive engagement between developers and service providers delivering projects and Local Planning Authorities is an increasingly important process in bringing these crucial developments forward. This should be a positive step towards greater synergy between planning and public infrastructure service providers and for the communities that such infrastructure will serve.
Whether it is a new clinic, hospital, estate masterplan or site disposal strategy, Lichfields provides expert advice to de-risk the planning process and can assist right from the early stages to help achieve our clients’ objectives – from submitting sites to Local Planning Authorities call for sites, undertaking pre-application engagement, right through to obtaining planning permission. Please do get in touch regarding any health-related proposals or if you would like assistance in preparing representations to the NPPF consultation or to future development plan consultations.
Image credit: Assura and P+HS Architects