The following has been submitted on your behalf by HAG with regards to a suggested medical centre
Objection comment on outline planning application reference 17/04923/OUTMAJ – specifically the proposal to provide a medical centre to replace the branch surgery currently at Winksey Cottage, High Street, Hampsthwaite
Hampsthwaite Action Group has seen the submissions by the applicant regarding a replacement medical facility on their site at Elton Lane.
The relevant part of the Planning Statement states: “The medical facility will allow for the creation of new practice in Hampsthwaite and discussions have commenced with the existing practice with a view to relocate that facility to improve the offer available to the local residents.”
There is nothing in the original application details to indicate the size of this new facility (in terms of consulting rooms and services) and this ought to be the minimum information you require to enable an assessment of traffic generation, floor area requirements, visual impact, landscape impact and heritage impacts. Neither is there any information to indicate if the medical facility is to be funded through the development and how this would be delivered (for example through a Section 106 Agreement). This is necessary because if the medical facility is intended to be a public/community benefit there must be sufficient evidence to give assurance that it can be delivered alongside the housing. In the absence of that evidence the proposed medical facility can carry no weight as a public benefit in the planning decision.
By email dated 12 December, the applicant provided an update: “I can confirm that discussions are on-going with Church Avenue and they are still very keen to relocate into a new facility. They have stated that the existing premises is not fit for purpose and a new facility would allow them to provide an improvement facility with additional services. They are clear that all of the above would need to be agreed with the CCG/NHS England and a business case would be required but on the basis of additional residents and the existing level of service provision I do not believe this is expected to be an issue. I am currently obtaining more information regarding the likely rent required at a new premises and the rateable value to allow the practice to progress their business case.”
We believe it would be helpful to the consideration of this planning application if you had clearer facts regarding the delivery of a replacement medical facility, and steer away from unsupported claims by the applicant such as: “I do not believe this is expected to be an issue”.
It goes without saying that, if circumstances allowed it, the surgery would wish to move to improved facilities. But this is subject to economic viability, appropriate funding and ensuring they maintain their list of patients – and if possible increase the number of patients registering with them – as the surgery income is based on the list size.
Whilst the surgery would welcome the opportunity to move into a brand new surgery, the increased cost in rent and general running costs of a new building would not currently be supported by the local CCG or NHS England. This is because there is no extra funding currently available within the NHS. Therefore, just building a new surgery and expecting the branch surgery to move in is just not workable or feasible without approved extra funding from the local and national NHS bodies. Submitting a business plan to the CCG and NHS England will not guarantee increased funding for rental and building upkeep.
If this medical facility is to be delivered as a public benefit, any funding from the owner of the land to support the new surgery would have to be in perpetuity and not for just a year or two. The situation is far more complex than obtaining more information regarding the likely rent.
Finally, we note that the medical facility is located within the area of the site which is in Flood Zone 2. We cannot understand the logic of selecting such a location. Paragraph 103 of the NPPF suggests consideration should only be given to development in flood risk areas following a Sequential Test. We cannot find anything in the submissions by the applicant which considers a Sequential Test for the location of a medical facility in this flood zone area. You will be aware that development should not be permitted if there are reasonably available sites, appropriate for the proposed development, in areas with a lower probability of flooding. It is not just the Environment Agency which should be interested in the results of a Sequential Test. External funding via the NHS – even if it were available – would not be made available to support a new medical facility at risk of flooding.
The absence of clear submissions from the applicant regarding deliverability of a replacement facility means no weight can be applied to this part of the planning application in terms of delivering sustainable development or providing a public benefit.