Over the last year I’ve seen more and more reports of the tensions in local communities created by new housing development and the provision of local GP services.
In many cases it’s manifested as reduced service provision, leading some to suggest that housing developments are worsening the healthcare crisis.
But in other places like Shropshire and West Yorkshire new GP services are being funded through CIL, the Community Infrastructure Levy.
Community Infrastructure Levy (CIL) is a charge set by Local Authorities on developers to raise the funds to help upgrade local infrastructure, facilities and services needed to support the growth and expansion of areas as a result of new development within communities.
Neighbourhood CIL (NCIL) allows a proportion of this community infrastructure levy (ranging from 15% up to 25% if the area has an established Neighbourhood Plan in place) to be allocated towards communities, providing financial support for a broader range of non-infrastructure related items for the benefit of locally driven, neighbourhood focused projects. It is a hugely valuable source of funding that offers significant benefit to communities.
I went to HUDU – the NHS Healthy Urban Development Unit -- to seek guidance on uses of CIL for health-based community infrastructure. Its focus is on new building and clinical facilities, and advises health organisations on using CIL:
The introduction of CIL significantly changes the way developer contributions, and the subsequent release of any infrastructure funding works. It is important that health organisations have systems and plans in place to:
Set out any health infrastructure requirements at the time the CIL Charging Schedule is prepared
Monitor development trends and population change to identify when to trigger a request for release of funds
Make the case for releasing funds against other potentially competing demands
Adjust their infrastructure needs and demands in the light of experience and changing circumstances.
NCIL funds, focused on neighbourhood-specific initiatives. are used for smaller, non-clinical projects, often initiated by local community groups. These can be highly impactful. In Westminster, for example, NCIL is currently being used to fund several health-related projects, including improved access to health services in a local church and a plan to improve public toilet provision in Soho.
Moreover these smaller initiatives often address social determinants of health, which taken collectively can have a big impact on health equity.
But there’s very little research or evidence to understand the links between CIL, health and health equity to fully and comprehensively design policy.
So it didn’t surprise me to see the recent focus at NIHR on developer contributions to health equity
The National Institute of Health and Care Research is currently seeking research proposals that address the question “What are the health and health inequality impacts of developer contributions?” Citing data from 2019, the NIHR describes how CIL monies are allocated across the country:
“in the 2018/2019 financial year, the total value of developer contributions was £7 billion, of which £4.7 billion was in the form of affordable housing contributions. However, there is considerable regional disparity in the amount of developer contributions secured. London, the South East and South West typically account for the majority of agreed developer contributions in England. While London accounted for 28% of the national total, the North East accounted for only 3%.”.
Further,
“delivery on planning obligations is sometimes inconsistent with what was originally agreed. In the current system developers are able to ‘negotiate down’ what was originally agreed if they can prove that fulfilling their obligations would significantly affect profit margins and make the development financially unviable”.
This is corroborated in a recent report on NCIL by EcoWorld London, who have delivered a range of regeneration projects across London, including the Aberfeldy Estate regeneration in Poplar, and the Kew Bridge Gate in Brentford which includes the new Brentford stadium, funded by developer contributions.
During 2023 EcoWorld London worked with Kanda Consulting to speak with community groups across the capital’s boroughs, and undertook a survey of those involved in the allocation of Neighbourhood CIL to understand how this operated across London and whether communities could be helped to access this important source of funding.
This research shows that there is no consistent mechanism or guidance in place to govern the allocation and accessing of NCIL funding. This means that the experience varies from borough to borough and there is often little awareness of the funding available at a local level and much confusion about the process and criteria for accessing it, so community groups may lose out on critical funding.
Perhaps most significant of all is the growing amount of CIL monies that are left unspent. Last year the Home Builders Federation revealed that councils across England are “sitting on £2.8 billion in developer contributions, and the “worst offenders” are in London.
There is a clear need for both consistency and clarity in CIL funding of community infrastructure, and the aims of improving health and health equity provide a timely opportunity for developers to work collaboratively to achieve this. Why? Three reasons:
First, as health leaders in government and the NHS begin to shift their focus from treatment to prevention, attention is increasing on the social determinants of health which are inherently place-based, and this is where community infrastructure can play a big role.
A recent manifesto on public health by the Institute of Health Promotion and Education calls for shifting the focus from “telling people what to do” to “creating health promoting environments”, giving local communities and developers of the built environment an opportunity to improve the social determinants of health.
Second, improving social determinants of health will improve health equity. Sir Michael Marmot has built a comprehensive evidence base on this through his Marmot Review, and is applying the principles to local places through the Marmot Places programme.
Third, building engagement with local people around health improvement will ease adversarial relationships that so often underpin regeneration projects, and serve as a constructive forum on how regeneration and development can deliver benefits to all members of a local community.
Developers, housebuilders and property investors have an opportunity to shape and direct how CIL monies are allocated to improve the health and health equity of the local places where they invest. They must be encouraged and inspired to do so.
Clare Delmar
Listen to Locals
13 June 2024
