NPPF, CIL and local Infrastructure needs disconnect.
Firstly, there are some extremely good people here in our community and also at Bradford Council. The outgoing Parish Council Chair, Jan Lepley has worked really hard for our community and has been involved in ongoing discussions at the local GP Surgery. I could not carry out my role as district councillor without the help of the community, particularly the member of the community leaders group (All our Vicars, Jan Lepley, Nicola Swan, Caroline Rayment, Susan Collins, Becky Berry, Dementia Friends, Love Burley, schools, and all numerous others). Take a bow for the community.
Burley GP Surgery – letter to Staurt Andrew MP, Philip Davies MP and Sajid Javid MP
I have spent time looking at revisions to the NPPF which were made in 2021. These are summarised in the attached Changes to the NPPF 2021. You will also need to look at the Council’s Statement of Proof (pages 37,38 & 39) and the Burley in Wharfedale Neighbourhood Plan.
Philip Davies MP had communicated issues at the surgery to council on the 16th of November 2021 and received the following response. This was echoed in a Bradford press release to the Ilkley Gazette and in emails from Bradford. Clearly, statements made to the public inquiry have been conveniently forgot, which is why the petition was setup. If no funding is forthcoming, then there could an opportunity for a judicial review at Sun Lane.
It is with the 2021 changes in mind, and proposed changes to the NPPF, which Stuart discussed on Saturday 14th, that I write.
As you are aware, issues at Grange Park Surgery in Burley in Wharfedale and a similar set of potential issues at the Kirklands Surgery in Menston which is linked to a surgery in Guiseley.
To give you a background at Grange Park Surgery, we have:
- The building was opened in 1984 and was to accommodate 4,600 patients. The surgery now has a little under 7,000 patients, with that number set to rise significantly.
- We now have an additional 600+ homes that are to be delivered in our community, plus a 52-apartment retirement home and a 76-bed care home. The first 100 homes at Greenholme Mills have just been released for occupancy.
- The existing surgery does not have the space, or the Doctors required to handle the additional head count, and the surgery is now considering closing its books to new patients. I have already suggested that the Surgery do so ahead of completion of the new care home at the Generous Pioneer, as this will stretch the service beyond its current capacity.
To put things plainly, the existing nursing home requires a half day, one day per week for surgery visits, and it is anticipated that the new home will require an additional half day each week for visits. This will further exacerbate issues at Grange Park for patients and patient waiting times.
- The Doctors already experience a tripling of duty appointments on a Monday morning from 15 to 45 appointments within the last 18 months.
- First-time routine appointments now take more than a week to schedule, although emergency appointments are available daily. The doctors often stay at the surgery after hours and have to catch up on paperwork in the evening.
Clearly, this situation cannot go on indefinitely, and investment in infrastructure to support additional housing is urgently needed. The issue as I see things, relates to Paragraph 11 of the NPPF, The presumption in favour of sustainable development.
Broadly speaking, paragraph 11 assumes that a development is sustainable. Parts c and d (i & ii) are not normally considered in an up-to-date planning policy, which is precisely where there’s one disconnect in current planning policy. Council’s and developers have the wherewithal in such a situation, and the public are at a disadvantage. Realistically, Council’s and developers need to demonstrate how sustainability can be achieved, and I know that Stuart Andrew is working on this issue (NPPF paragraphs 7 and 134 of the revised NPPF 2021). I don’t believe that these policies are sufficiently robust at present.
The disconnect in CIL and the New Homes Bonus.
The methodology of CIL and the New Homes Bonus do not currently support local infrastructure need, rather councils can choose to spend CIL and the New Homes Bonus on what/wherever they choose, and it is they who receive the Lions share.
Town and Parish Councils, receive 15% or 25% of the CIL, dependant on whether a Neighbourhood Plan is in place. This is normally used to support local initiatives, Doctors surgeries in their nature as a private business (although providing almost totally an NHS service) are not normally considered. If a Town or Parish Council was to allocate CIL to such a project, then this would undermine the need for a local council to provide any support. Yet it is local Councils who benefit the most from new housing development, particularly that on green belt. Green belt is perhaps the least well served in terms of infrastructure, simply because green belt is often located in rural communities.
I know that changes are in the pipeline, however, these are not likely to be retrospective. I would therefore request that CIL charging authorities should receive a mandate to spend at least 30% of their portion of the CIL on local infrastructure. If that’s not possible, could this rule be applied to the New Homes Bonus? Bradford Council are currently to receive £4 million in CIL, plus a substantial figure for the New Homes Bonus.
The requirement at Grange Park Surgery, Burley in Wharfedale.
Here in Burley in Wharfedale, we’re not unique, the GP Surgery needs to increase its capacity by at least 50%. This requires:
- A building extension with an additional 50% floor space.
- This would provide 3 additional consulting rooms.
- 3 more offices
- A staff room, currently there are no staff facilities for doctors to have lunch/breaks.
- A meeting room.
- A community room for community work, eg: Mental Health, Wellbeing Services, etc. These are all currently supported by community groups in external facilities, all currently funded by charitable donations and organisations.
- Total building cost of £500,000 – £700,000.
Dr. Caroline Rayment has already had meetings with Philip Davies MP, Robbie Moore MP, the CCG and NHSE. Whilst help and advice has been given, there’s a lack of ministerial and NHSE support.
For the avoidance of doubt, the NHSE have £12 million to spend improving health care facilities over the next 3 years for the whole of West Yorkshire. Grange Park Surgery are already on the application list but have been told that they are unlikely to receive any funding. There are 6 Doctors Surgeries on the list in the Bradford District, 2 of which have been already allocated funding. Here in Burley in Wharfedale, we are informed by the NHS that the only way forward is for Partners at Grange Park Surgery to borrow money against the surgery. This could then be claimed back as an NHS rental payment over a 25-year period.
Update at the Doctor’s surgery.
Firstly, the application to extend the doctor’s surgery has been approved.
We met with the NHS and Bradford Council’s CEO, Kersten England and the Director of place, following our recent petition and received the following statement from Bradford Council:
“The Council supports the vision for your practice, particularly in light of the housing growth that is to take place in the area and as you know, we agree that the scheme would be eligible for CIL funding. As I outlined, there is an annual round of submissions for CIL funding that is agreed by Councillors. I would suggest that we discuss further details in time for our CIL allocations report to the Council’s Executive Committee in July 2023.
As we also discussed, there are many calls on CIL funding and it should not be assumed that CIL will cover the total cost of the project. Therefore, I suggest that you continue to explore the other avenues of funding that you outlined.
I hope that this information reassures you that the council wishes to work with the practice in order to deliver high quality General Practice services for our communities.”
There obviously are a number of lines of enquiry that the surgery and I are following up on, and the petition is currently on hold.
“The doctors are continuing to push the NHS both in terms of a capital improvement grant and/or increase in rent payments. I have also spoken to the bank this morning to start the process of putting forward costings and loan figures. We have 2 quotes approximately £750,000. It would make life considerably easier for us – and the bank, if we could get 3-400,000 funded from public sources. Currently we cant go ahead with no additional sources of money as our rent would not cover the increase.
We have written back to the council asking for clarification on a couple of things and informing them we require a substantial contribution – I didn’t mention a figure as yet. We have also reached out to the people that Council & the NHS they said will help with this.”
Watch this space for regular updates.
Grange Park Surgey update March 30th, 2023.
In a statement from Bradford Council, we have:
Thank you for your email. I think we are all aligned in wanting to ensure that wherever new development takes place, there are adequate health (and other) services locally to cater for the needs of a growing population.
On the question of CIL, you are correct in saying that not all developments attract the Levy. However, the National Planning Policy Framework against which we must base our planning decisions, sets out a very clear presumption in favour of sustainable development. That is the basis upon which developments such as McCarthy and Stone, Greenholme Mills and Avery Care Home were approved. In my (now lengthy!) experience, the challenges that this creates for local services that you describe, are most certainly not unique to Bradford District, nor your surgery specifically!
When we first met back in October 2022, I did make it clear that CIL would be available as part of a funding package if it could be justified. We identified that the earliest that the allocation of CIL could be considered would be summer 2023.
I understood that you wanted certainty of a CIL contribution to enable access to other funding sources and so I was pleased to assist as soon as we possibly could to provide that certainty for you. However at present, no units on the Sun Lane site have been completed and sold. CIL is only payable when revenues start to accrue from a site, linked to an agreed set of instalments based on the phases of development over several years. At present this means the current available CIL from the site is nil. I understand that Barratts aim to complete their first sale this calendar year (December) and so I hope that you understand that the generation of CIL will only realistically start to accrue during 2024.
Therefore, hopefully, the information that you provide on the package of funding required to extend the surgery will be sufficient for the council to make a decision on commitment of CIL in future years.
We will continue to progress your submission and expedite all of the processes within our control. I hope that we can work together to deliver the outcomes that we both seek!
Having had dialogue with David Wilson Homes, it appears that the first CIL contribution will be made in October of this year. We therefore continue to seek a resolution from Bradford Council, and if necessary will, once again, start a new petition for submission to Council.
He’s right about the NPPF presumption of sustainable development, however, the word is presumption. Bus and train services have been cut since these planning applications were made, so the presumption, in this case, is hyperbole.
I’m not bothered about the rest of the country, just our patch in Burley in Wharfedale, and to that end I continue to work with our MP and the Secretary of State; Steve Barclay.
this is all being driven by housing, and that time is of the essence but believe that we need to tread carefully, take our time and consider our response. I want to be sure that if or when we have to play our cards, that all other avenues have been exhausted.
