Purpose
This Policy Position Statement promotes the preparation of
appropriate guidelines for Health Impact Assessment (HIA) for major
new developments to assist decision making in the planning system.
CIWEM supports science-based decision making to protect the
environment and human health.
CIWEM believes that:
1. Heath Impact Assessment (HIA) can add value to decision
making in the land use planning process.
2. Whilst guidelines for HIA have been developed1
and they may be appropriate for development plans at regional and
local levels, for major individual planning applications a formal
approach is needed.
3. New guidelines need to be drawn up for a range of land
development projects, in consultation with a range of professional
bodies, that will be acceptable to developers, consultants, local
planning authorities, Primary Care Trusts (PCTs) and the Health
Protection Agency. These should draw on the general guidance on HIA
issued to date, such as that produced by the Liverpool Public
Health Observatory's HIA programme.
4. HIA should not become a statutory requirement for any
planning application at this point in time, but should be
undertaken on a voluntary basis (with the agreement of the
developer, the local planning authority and PCT) until new
guidelines acceptable to all key stakeholders are agreed.
5. Given the mandatory nature of Environmental Impact
Assessment for major developments, and the voluntary nature of HIA,
they should generally be treated as stand-alone reports and not
form part of the Environmental Statement. As improved
guidelines are developed and agreed, it might be appropriate to
fully integrate HIA into EIA.
6. There should be co-operation in the early stages of
significant planning applications between the local planning
authority, PCT (and, if relevant, the licensing authority) and
developer to ensure that any HIA is appropriate in scope and scale
to the proposed development.
7. There is official guidance on the preparation of Health
Statements for Integrated Pollution Prevention and Control (IPPC)
Permit applications. Practical experience should inform
future reviews of the guidance. Generally, local Pollution
Prevention and Control (PPC) applications do not require Health
Statements. An impact assessment is required but stops at a
comparison with National Air Quality Objectives and Environmental
Assessment Levels (EALs). By way of comparison, in France,
full human health risk assessments for all Permitted activities are
required.
Context
The planning system aims to regulate the development and use of
land in the public interest, promoting a sustainable pattern of
land use that will contribute to meeting the country's economic,
social and environmental needs, whilst recognising the
precautionary principle. Use of land, under the new planning regime
introduced with the Planning and Compulsory Purchase Act 2004, will
be set out in Regional Spatial Strategies and Local Development
Documents, jointly known as 'development plans'. Local
planning authorities decide upon planning applications according to
the development plan, unless there are other key
considerations.
The Government is promoting a new planning regime as being a more
strategic, proactive force for economic, social and environmental
well-being. At the same time health professionals have come
to realise that a wide range of factors in addition to simply the
provision of health services are important for determining public
health. These include employment, education, housing and the
environment. This has led to the development of health impact
assessments (HIAs) of policies, plans and projects.
Planning Policy Statement 23 Planning and Pollution Control
(PPS23), published in November 2004, states that any potential
health impact arising from a development is capable of being a
material planning consideration. It goes on to state that the
precautionary principle should be invoked where there is good
reason to believe that harmful effects may occur to human health
and where the level of scientific uncertainty is such that best
available scientific advice cannot assess the risk with sufficient
confidence to inform decision-making. Furthermore, it advises that
the 'objective perception of unacceptable risk to the health or
safety of the public arising from the development' needs to be
taken into account in the decision-making process.
Large planning applications are generally required to be
accompanied by Environmental Impact Assessments (EIAs) documented
in Environmental Statements (ESs), which often play an important
role in influencing the decision to grant or refuse planning
consent for proposed developments. Although ESs, or the
general application documentation, can include assessments of
health impacts, they rarely cover the wider social and
psychological elements or even the direct impacts in a systematic
manner. In general, environmental benchmarks such as the
health protection-based National Air Quality Objectives (NAQO), are
used to assess the significance of the potential impacts.
However, there is little discussion of the health impacts of
achieving or not achieving the benchmarks.
Health Impact Assessments (HIA) are designed to check whether a
proposal might reinforce health inequalities, or inadvertently
damage people's health in its widest sense. Over the
past five years there has been growing use of HIA and organisations
including the World Health Organisation, the Health Protection
Agency, the Welsh Assembly, the London Health Commission and
Primary Care Trusts have been promoting their use and have begun to
develop good practice guides drawing on the experience of
Environmental Impact Assessment. At the same time, the
Department of Health has ensured that local Primary Care Trusts are
statutory consultees on any new local Pollution PPC permit
applications.
HIA should provide a systematic approach for assessing the
potential impacts of proposed policies, plans and projects on the
social, psychological and physical health of communities. It
is a tool to appraise both positive (e.g. creation of new jobs) and
negative (e.g. generation of pollution) impacts on the different
affected subgroups of the population that might result from the
proposal being implemented. Public participation is
considered a major component of the process.
In the UK, over 120 HIAs have already been undertaken, largely for
the assessment of new policies by the public sector. One of
the problems with the current guidance (although some might see it
as its strength) is that it covers such a wide range of
applications. However, the type and scope of issues covered
in a HIA for a policy proposal will be very different to those
covered for a specific physical development.
There are three types of HIA:
-
Prospective (prior to implementation)
-
Concurrent (during implementation)
-
Retrospective (after implementation).
Of most relevance to the planning system are prospective HIAs,
because they can influence a planning decision. Once a
development has planning consent, it is too late to undertake a
meaningful HIA, as the consent will not be revoked.
Key Issues
1. The planning process requires health issues to be
taken into account, but no systematic approach exists
At present, the planning system is unable to cope adequately with
difficult public health issues. The consequence has been the
evolution of somewhat contradictory case law. For example, a
High Court decision regarding a proposed chemical waste treatment
plant in Wales concluded that perceived fears of the public, even
though they were not based upon scientific fact, were a relevant
planning consideration. Another High Court decision, this
time for an expansion of a landfill site in Cornwall, concluded
that given the tentative nature of any health effects the council
were correct in assuming that the risks, small as they were, could
be adequately addressed by the Environment Agency as the regulator
of the Waste Management Licence. There is no evidence that the new
planning system will be better equipped to deal with such
issues.
2. There is a requirement for training and better
understanding of the planning system, developers' needs and the
science-based approach of EIA amongst HIA
professionals
HIA is currently a young and immature activity, largely practised
at present by people with little or no knowledge of land use
planning and still less of the needs of developers. Largely,
the HIA community is rooted in the public sector and academia, an
almost opposite situation to EIA where practitioners are largely in
the private sector. This has produced a set of methods and
approaches which are often ill suited to development proposals.
3. There is a difference in approach between HIA
(largely qualitative) and EIA (largely quantitative) that must be
reconciled before the two may be integrated
The majority of HIA practitioners believe strongly in the community
consultation process and place the views expressed through such
means above all other evidence. A 'quantitative' v
'qualitative' schism runs through the HIA community at present,
with few in the former camp. The two things are, of course,
complementary, but the majority feel uncomfortable with
science-based approaches, which are commonplace in EIA and are the
cornerstone of the planning system, and are confirmed in PPS
23.
4. Health concerns are more widely
recognised
The new planning regime requires greater public consultation than
previously, and therefore local health concerns are likely to
figure more prominently in the planning process.
5. Guidance is required on appropriate methodologies and
criteria for HIA under IPPC
HIAs have sometimes been required for pollution permit applications
for industrial processes. Since planning consent is not
always required for the developments involved (they may fall within
an existing planning consent), this forms a separate category of
HIA. Guidance does exist specifically for this application;
however, similar issues to HIA for planning applications have
arisen. All cases of industrial HIAs to date involve a
specific local health impact of great concern to the local
population - although not necessarily significant in terms of a
technical risk assessment. The introduction of IPPC requires
formal consideration of health impacts, although still only based
on comparison with the NAQOs and EALs for an assessment of
potential impact. The development of appropriate
methodologies and criteria is still at a very early stage and is
key for all involved.
Discussion
Developers, particularly of those projects large enough to have a
potential impact on community health, have to meet increasing
demands for contributions to, for example, the local highway
infrastructure, social provisions such as GP surgeries, schools and
public open space, and affordable/key worker housing. The
cost of obtaining planning permission can run to several million
pounds while the cost of providing the desired facilities can run,
if it is a large project, to tens of millions or more.
Currently, there is no statutory requirement for developers to
undertake an HIA. However, local planning authorities are
beginning to request them for significant developments within their
local authority boundaries. There may be a perception that
developers have ample budgets for incorporating new assessments
into their proposals. The reality is that every land
development project has a point at which it is no longer
commercially viable and developers are unlikely to agree to
undertake an HIA unless it is requested by law, or clearly adds
value to the planning process. Either way, what is required must be
clearly defined at the outset.
As there is no legal driver for HIA, the fundamental question is
'why should the developer commssion one?'
One of the benefits of HIA to developers is that it is able to
demonstrate positive effects for the community, as well as negative
impacts. EIA tends to highlight the negative
aspects. Thus, the major incentive for developers is the
possibility that HIA can be used to promote the proposal.
Producing guidelines in co-operation with other professional
groups, e.g. town planners, developers and Primary Care Trusts will
encourage the use of HIA where appropriate. In particular, it
will reduce developers' fear of the unknown and set boundaries on
their commitment. It will assist in addressing perceived
health issues unsupported by mainstream medical evidence with the
local community prior to the application being submitted.
Provided appropriate guidance is developed and accepted by the
range of professional bodies involved, developers are likely to see
benefits in commissioning HIAs.
In summary, HIAs are being undertaken but this kind of assessment
is currently an immature activity and the approach used is often
incompatible with the land use planning regime's requirement for
science-based evidence. Therefore, the following issues need
to be addressed to ensure that HIA has a useful role to play in
planning decisions:
-
There is an urgent need to develop appropriate HIA guidelines for
the land use planning process
-
There is a need for consultation between the professional bodies
involved and other stakeholders when developing the guidelines
-
There should be co-operation in the early stages of land
development projects between the local planning authority, PCT,
licensing authority (where relevant), and developer to ensure that
the HIA is appropriate and adequate in scope and scale to
development proposals
-
The related issue of guidance for heath statements for IPPC permit
applications needs to be kept under review to ensure that these
also add value to the process. The benefits of the more
formal approach to health impacts adopted in France, for example,
should be assessed against the costs of adopting such an
approach.
Reference
1. See Health Impact Assessment Gateway, www.publichealth.nice.org.uk
December 2005
Note: CIWEM Policy Position Statements (PPS) represents the
Institution's views on issues at a particular point in time.
It is accepted that situations change as research provides new
evidence. It should be understood, therefore, that CIWEM
PPS's are under constant review, that previously held views may
alter and lead to revised PPS's.
