GNLP 2045 Regulation 20 Scoping Consultation

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Comment

GNLP 2045 Regulation 20 Scoping Consultation

Question 1 – Are there any

Representation ID: 26449

Received: 25/09/2026

Respondent: NHS Norfolk and Suffolk Integrated Care System (ICS)

Representation Summary:

The (ICB) integrated care board stakeholders support a strong “health in all policies” approach and highlight both the opportunities and risks associated with growth in Greater Norwich. Strengths include the area’s natural environment, green infrastructure, community networks and foundations for active travel, which support health and wellbeing. Key weaknesses are capacity pressures on GP, dental and community services, an ageing population, health inequalities, limited affordable and accessible housing, and poor public transport connectivity in rural areas. Opportunities include designing healthy and age-friendly neighbourhoods, integrating health and community infrastructure into new developments, expanding active travel networks, using health data to inform growth decisions, co-locating services in community hubs, and improving digital access to healthcare. Threats include increasing demand from an ageing population, widening health inequalities, workforce shortages, inadequate infrastructure investment alongside growth, and climate-related health risks such as flooding and extreme heat. Overall, respondents emphasise that future growth should be planned to improve health outcomes and reduce inequalities through timely investment in healthcare, transport and community infrastructure.
(See attached response for full details)

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Comment

GNLP 2045 Regulation 20 Scoping Consultation

Question 2 – Is there any

Representation ID: 26490

Received: 25/09/2026

Respondent: NHS Norfolk and Suffolk Integrated Care System (ICS)

Representation Summary:

Health evidence should play a key role in informing the GNLP evidence base and growth strategy. The Norfolk and Suffolk ICB recommend using Norfolk Insight, which provides extensive local health and demographic data and mapping, alongside ICB demand and capacity information and datasets such as STRATA/SHAPE to assess pressures on healthcare services. Key evidence should include population growth and ageing trends, healthy life expectancy, deprivation, prevalence of long-term health conditions, housing need, access to healthcare and community services, GP and care capacity, workforce challenges, transport and connectivity, and climate-related health issues. Norfolk County Council's Public Health Team highlights the importance of the Joint Strategic Needs Assessment (JSNA) as a source of health and wellbeing data, wider determinants of health, and population projections to support infrastructure planning and ensure future development is aligned with community health needs.
(See attached response for full details)

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Comment

GNLP 2045 Regulation 20 Scoping Consultation

Question 3 - Do you agree

Representation ID: 26497

Received: 25/09/2026

Respondent: NHS Norfolk and Suffolk Integrated Care System (ICS)

Representation Summary:

The Norfolk and Suffolk Integrated Care Board (ICB) supports the proposed plan structure and its alignment with new plan-making requirements but emphasises that healthcare infrastructure should be embedded throughout the planning process rather than treated as a secondary consideration. The ICB recommends incorporating healthcare assessment criteria into all site allocation policies, requiring health impact assessments where locally relevant, and using access to healthcare services as a key factor in determining the settlement hierarchy. The Central Locality Team also supports the proposed structure, noting that it provides a clearer distinction between strategic growth, site allocations and policy requirements, and suggests that the plan could be strengthened by including measurable outcomes to monitor delivery and effectiveness.
(See attached response for full details)

Attachments:

Comment

GNLP 2045 Regulation 20 Scoping Consultation

Question 4

Representation ID: 26498

Received: 25/09/2026

Respondent: NHS Norfolk and Suffolk Integrated Care System (ICS)

Representation Summary:

The Norfolk and Suffolk ICB supports the overall growth strategy, recognising its focus on directing development to sustainable locations with access to employment, education, healthcare and public transport, protecting smaller villages from excessive growth, supporting economic development, and benefiting from a collaborative approach across Greater Norwich. However, it notes that healthcare infrastructure is often already constrained in growth areas and that cumulative impacts from village cluster development can place additional pressure on services. The ICB emphasises the need for earlier engagement on healthcare capacity, stronger integration of health and wellbeing objectives, including active travel and reducing health inequalities, and greater consideration of the needs of an ageing population. It also highlights a common perception that infrastructure such as roads, healthcare, schools and community facilities does not keep pace with housing delivery, suggesting that future growth strategies should address these concerns more effectively.
(See attached response for full details)

Attachments:

Comment

GNLP 2045 Regulation 20 Scoping Consultation

Question 5

Representation ID: 26499

Received: 25/09/2026

Respondent: NHS Norfolk and Suffolk Integrated Care System (ICS)

Representation Summary:

The Norfolk and Suffolk ICB supports a brownfield-first approach where sites are in sustainable locations, noting that redevelopment of underused land can protect green spaces and support town centre regeneration. However, it stresses that site selection should consider healthcare accessibility and capacity, active travel connections, emergency service access, environmental health impacts, and climate resilience measures such as green and blue infrastructure. The ICB recommends a balanced approach to growth distribution based on infrastructure capacity, environmental constraints, access to services, and health outcomes. While larger settlements, urban extensions and new settlements can support more efficient infrastructure provision and the creation of healthy communities, new healthcare facilities cannot be assumed and may instead be delivered through enhancements to existing services. The ICB also highlights the risks of increased pressure on healthcare infrastructure, health inequalities, air pollution, car dependency and cumulative impacts associated with dispersed rural growth and village cluster development. Early engagement with healthcare providers and the delivery of high-quality green infrastructure are identified as key requirements for future development.
(See attached response for full details)

Attachments:

Comment

GNLP 2045 Regulation 20 Scoping Consultation

Question 6

Representation ID: 26500

Received: 25/09/2026

Respondent: NHS Norfolk and Suffolk Integrated Care System (ICS)

Representation Summary:

The Norfolk and Suffolk ICB emphasises the importance of early engagement to understand healthcare demand and capacity so that growth can be planned alongside the necessary infrastructure. It recommends that additional healthcare facilities required as a result of development are planned in advance and funded through developer contributions, rather than delivered after residents move in. The ICB supports prioritising the reuse of vacant, underused and previously developed land, ensuring meaningful community engagement, and only permitting development where essential infrastructure, services and facilities can be provided without undue pressure on existing provision. It also highlights the value of preventative health measures, including safe active travel networks, green and blue infrastructure, community spaces and allotments, which can improve physical and mental wellbeing. The Central Locality Team further stresses that new settlements should incorporate health, transport, digital and community infrastructure from the outset, including GP capacity, community health facilities, mental health services, pharmacies, care services and space for multidisciplinary teams, alongside accessible housing, active travel infrastructure, community hubs, green spaces and digital connectivity.
(See response for full details)

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Comment

GNLP 2045 Regulation 20 Scoping Consultation

Question 7

Representation ID: 26501

Received: 25/09/2026

Respondent: NHS Norfolk and Suffolk Integrated Care System (ICS)

Representation Summary:

The Norfolk and Suffolk ICB emphasises that proximity to healthcare facilities should not automatically be taken as evidence that a location is suitable for growth. It recommends that the capacity of GP practices and other healthcare services is assessed at the earliest stage of site allocation, with consideration given to the cumulative effects of multiple developments on local healthcare infrastructure. The ICB notes that tools such as the DfT Connectivity Tool can assess accessibility but do not provide information on healthcare capacity, highlighting the need for early engagement with the ICB to identify constraints and mitigation requirements. The Central Locality Team further recommends strengthening the settlement hierarchy by incorporating health and wellbeing considerations, ensuring that future growth supports healthy, age-friendly communities without placing unsustainable pressure on existing health and care services.
(See attached response for full details)

Attachments:

Comment

GNLP 2045 Regulation 20 Scoping Consultation

Question 8

Representation ID: 26502

Received: 25/09/2026

Respondent: NHS Norfolk and Suffolk Integrated Care System (ICS)

Representation Summary:

The Norfolk and Suffolk ICB supports a diversified approach to housing delivery, recognising that small and medium-sized builders can help accelerate delivery rates, while larger strategic sites, sustainable urban extensions and new settlements can more effectively support coordinated infrastructure and healthcare provision. The ICB stresses that key infrastructure, including healthcare and schools, should be funded and delivered ahead of housing occupation through appropriately structured site policies and early engagement with infrastructure providers. It also highlights the importance of delivering accessible and adaptable homes to meet the needs of an ageing population. The ICB and Norfolk County Council Public Health Team emphasise that future housing growth should include affordable housing, specialist and extra care accommodation, and homes designed to promote health and wellbeing through good design, adequate space, natural light, ventilation and private outdoor areas.
(See attached response for full details)

Attachments:

Comment

GNLP 2045 Regulation 20 Scoping Consultation

Question 9

Representation ID: 26503

Received: 25/09/2026

Respondent: NHS Norfolk and Suffolk Integrated Care System (ICS)

Representation Summary:

The Norfolk and Suffolk ICB advises that the benefits and drawbacks of allocating a high proportion of housing to small and medium-sized sites should be carefully assessed. While such sites can support faster housing delivery, assist smaller builders, make use of infill and brownfield land, and generally have lower individual infrastructure impacts, they can also limit opportunities to deliver strategic infrastructure, secure meaningful developer contributions, provide comprehensive active travel networks, and deliver affordable housing. The ICB also warns that the cumulative impact of multiple smaller developments can place significant pressure on healthcare services, transport networks and other infrastructure. The Central Locality Team supports maintaining a balanced mix of strategic, medium-sized and small sites to improve delivery resilience and reduce reliance on a few major developments. Norfolk County Council Public Health further emphasises that all housing growth should provide access to green infrastructure, active travel routes, healthcare, education and community facilities, while supporting specialist housing that enables people to live independently and reduces pressure on health and care services.
(See attached response for full details)

Attachments:

Comment

GNLP 2045 Regulation 20 Scoping Consultation

Question 10

Representation ID: 26504

Received: 25/09/2026

Respondent: NHS Norfolk and Suffolk Integrated Care System (ICS)

Representation Summary:

The Norfolk and Suffolk ICB recommends that the Local Plan include robust mechanisms to deliver affordable housing, supported by an up-to-date assessment of housing need, clear percentage targets, tenure requirements, and a mix of site sizes to encourage delivery by a range of developers. The ICB advocates increasing the supply of affordable and accessible housing, including specialist accommodation, homes meeting M4(2) and M4(3) accessibility standards, and provision that supports independent living for an ageing population. It also highlights the importance of dementia-friendly design, healthy homes that prevent damp and mould, and energy-efficient housing that maintains comfortable indoor temperatures and supports health and wellbeing. The Central Locality Team similarly stresses that affordable housing should meet identified local needs, provide a range of tenures, include wheelchair-accessible homes, and be located close to services, public transport and community facilities. It also supports age-friendly neighbourhoods with safe walking routes and access to green spaces.
(See attached response for full details)

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