Health for development decision making: the role of Health Impact Assessment
Ed Kirton-Darling from our law intervention team, sets out what we’ve learnt about the use and effectiveness of Health Impact Assessments with tips for getting it right at a local plan level.
Moving away from the tick-box
How can we help to bring health into the development decision making process without placing yet another burden on already overstretched local government officers? This was the question which prompted our work on Health Impact Assessments (HIA).
We know that local authorities have a wide range of urgent and competing demands to contend with, and we also know that many in local government are keen to get health taken seriously in decisions about development. When it comes to those decisions, the National Planning Policy Framework contains requirements to support healthy lifestyles, and the Planning Practice Guidance on healthy and safe communities describes HIA as “a useful tool”, and we know that there has been an increase in requirements for HIAs to be undertaken.
However, we have come across many stories of HIAs being little more than a tick box exercise, a hoop to be jumped through with little attention in the process being given to wider questions of health for the community.
In this context, our central question is, how can we help to ensure that HIAs work effectively, to place responsibility onto a developer to bring health into their plans for development, to provide analysis and evidence of the ways that the development might improve health outcomes and to provide a basis for consideration of health issues as material considerations in a planning decision?
As there is no national requirement for HIAs, it is up to local authorities to decide whether, how and when to require that a HIA be provided as part of an application for development. This is something local authorities can require under S.62(3) of the Town & Country Planning Act 1990 and the Development Management Procedure Order – as the law provides that a local planning authority can require than an application includes details or evidence they think necessary (as long as the request is reasonable, taking into account the nature and scale of the development and it is reasonable to think that the information will be a material consideration in the determination of the application).
Based on this, a HIA is required for certain types of individual planning applications by some local planning authorities in England through their local plans, which set planning policies locally and form the basis for planning decisions. We have identified that 38% of local plans in England had an HIA policy at February 2023, but it is relatively unregulated otherwise (unlike the more prescriptive Environmental Impact Assessment process), with significant variance in relation to specifications on approaches and required outcomes.
We looked at these local policies in detail, and in a series of workshops led by the Office for Health Improvement and Disparities in autumn 2023, we met with local authorities across England to find out how we could help. Amongst other things, they told us that what they really wanted was more examples of how HIAs can work in practice, with illustrations from others who have used HIAs in development decision making. Our new suite of films give a variety of perspectives and experiences of developing and implementing HIA policies, what has worked and lessons learned.
In the rest of this blog, we set out more detail about our analysis of local plans, with some reflections on how they might be framed and used to make HIAs as effective as possible.
The drive for clarity
We analysed 344 local plans from across 314 local planning authorities across England. Those familiar with local authorities will know that this is a complex and shifting landscape, and this survey is a snapshot in time, but at the time of the census (February 2023) 101 of those plans, or 29.4%, included a requirement that a HIA be provided, with a specific trigger for when the HIA was to be undertaken. A further 14 had a requirement for a HIA without a specific trigger, and 16 more referenced HIAs in supporting text, rather than the local plan itself.
We have undertaken an extensive analysis of those policies, and publications on this are forthcoming, but in brief, we found a huge degree of variation in local plans where a HIA was required. This variation included wide variety in the triggers which might prompt a HIA; sometimes prompting a requirement for a full detailed HIA, sometimes for screening to determine whether a full HIA was needed, and alternatively for a rapid HIA/healthy planning checklist. They ranged from five homes to 500 homes, from 500 m2 to 10,000 m2 of non-residential or commercial floorspace, and included different use types such as takeaways, betting shops, and leisure facilities. Sometimes they specified certain locations, such as deprived areas or particular sites identified by the local plan. Policies could have more than one trigger for HIA, covering different types of development and/or the extent of HIA expected.
There were many other variations, and drawing on this analysis, we set out some reflections on how local policies might ensure that HIA requirements are as effective as possible.
Our starting point is that the main goal of an HIA policy should be to ensure that developers incorporate health considerations into their proposed developments, maximising the potential health benefits of development, reducing inequalities, and mitigating potential harms. An ambiguous HIA requirement in Local Plan policy risks being missed, misunderstood, or challenged by developers, creating more work for Local Planning Authorities and developers, and ultimately losing opportunities to improve the health and well-being of people and communities.
To improve HIA implementation for planners, public health officials and developers we recommend taking these steps in Local Plans:
- A clear statement of the HIA requirement in Local Plan policy wording. This can be accompanied by additional supporting text and guidance, but a standalone HIA policy, or a clear statement about HIA as part of a health and wellbeing policy, gives greater clarity.
- An unambiguous trigger for an HIA within policy wording. Use clearly defined triggers, whether these are defined terms, or precise thresholds such as number of homes, size of floorspace, location and/or type of business, depending on local circumstances.
- A clear scope for an HIA within policy wording. Avoid the need for judgment about whether an aspect of wider policy is tied in and expected to be addressed in the HIA.
- Be explicit about proportionality, with precision about the scale of HIA required depending on the size and/or type of development proposed.
- Consider setting out the HIA process. Some policies clearly state expectations in relation to process.
- Consider the outcomes of HIAs. Some policies explain how the results of HIAs will be implemented, for example through planning conditions. Some state that HIAs should include details of implementation, ongoing management of issues and/or monitoring.
- Include explicit metrics. Some plans had defined metrics for monitoring HIAs. Most of these monitored how many HIAs were submitted, but a small number included metrics designed to reveal the way in which the HIA had impacted on the subsequent process, which could provide valuable information to inform evaluation of the effectiveness of HIAs in a given location.
Our analysis, and discussions with local authorities who have sought to make HIAs more effective, highlight the importance of HIA being undertaken early in the process. It is important that the resulting development proposal clearly shows how the conclusions of the HIA have informed the scheme design. There is also clear value in ensuring that those who undertake HIAs are competent to do so, and a local authority could require that an assessor set out their competence to complete a HIA.
We’d be interested to hear from you on all of this. Please do email the lead author at e.kirton-darling@bristol.ac.uk with any questions, thoughts and feedback. And if you are interested to learn more about our work, follow us on social media and sign up for our newsletter – we hope to be able to announce more publications on this work shortly.
This blog was written by Ed Kirton-Darling. The underlying research relating to local plans was undertaken by Katharine Hanss, but any mistakes in interpreting that analysis are the responsibility of EKD. We are grateful to Michael Chang for undertaking the census of local plans, and for providing this data to us. We are also grateful to OHID for collaborating with us in this work, and to those local authorities who took part in the OHID-led workshops in autumn 2023.
