The London Plan Review outlines ambitious targets for new housing development, including provision for affordable homes and estate regeneration. The targets are centred around improving housing availability and the quality of homes in the city. This stems from a long-held view that housing is a fundamental determinant of health and well-being.
According to the Health Foundation, healthcare itself only accounts for 10% of a population’s health[1]. The rest is shaped by socio-economic factors including access to good quality housing. Indeed, housing plays a crucial role in influencing everything from physical health to mental stability and social connections:
At its most extreme, poor quality housing results in higher rates of emergency hospital emissions and excess deaths. According to the Building Research Establishment (BRE), treating health problems caused by poor housing in England costs the NHS £1.4 billion per year. But the societal costs of people residing in poor housing, such as loss of economic potential and mental health costs, are far higher.
In London, where affordability and quality of housing are pressing concerns, the relationship between housing conditions and public health is particularly significant and requires coordinated efforts from policy makers, developers, planners and communities.
Health Impact Assessments (HIAs) are increasingly required as part of planning submissions and are a means of coordinating information and organisations to have a shared understanding of the likely health impacts of a proposed development. They are designed to enable health and wellbeing to be considered in detail for development proposals (including non-housing proposals) and to identify any enhancement or mitigation measures.
Despite increasing emphasis on HIA’s in planning, the interpretation of what is required and their effectiveness still varies enormously. The current London Plan Policy GG3 refers to the use of HIA’s but with no specific reference to any guidance or template. Boroughs are therefore left to their own interpretation of what is required. A number of London Borough’s require Health Impact Assessments to be undertaken as a planning validation requirement (Tower Hamlets, Richmond, Wandsworth, Lewisham, Greenwich and City of London to name a few). Requirements however vary significantly between boroughs depending on the scale and type of uses proposed. Some boroughs have developed their own HIA guidance, others refer to the London Healthy Urban Development Unit’s (HUDU) HIA toolkit, which was developed in collaboration with the NHS. A number of other local authorities have very little information or guidance on what might be deemed acceptable.
More recently (November 2022), the Institute of Environmental Management and Assessment (IEMA) released guidance on assessing health in Environmental Impact Assessment (EIA) stating that where a standalone health impact assessment is required for planning validation purposes, the requirements should be met within the Environmental Impact Assessment as a stand-alone technical chapter (and separate from Socio-economics).
All of this paints a confusing picture for those trying to navigate the planning system and we are very often asked to draft a HIA (often at the last minute!) simply to meet planning validation requirements that have been overlooked. In an ideal world, HIAs should form a more fundamental part of any development process in order to maximise their effectiveness and genuinely inform decision making around design and development proposals. If this is done effectively, HIA’s provide an opportunity to influence and highlight the genuinely positive impacts that a development may have on the health and wellbeing of those who will live, visit and work in it.
Public Health England recommend that HIA’s are carried out before decisions are made to inform and consider options for development or alternatives that may lead to improved health outcomes and reduced health inequalities. This approach is also recommended in HUDU’s HIA guidance as well as other HIA guidance, but more often than not it isn’t put in to practice.
We have undertaken numerous HIA’s across London for a whole variety of different sizes and types of projects including large-scale housing schemes, and we are well used to navigating the variable requirements of different London boroughs. In order to maximise the effectiveness of HIA’s in supporting the health and wellbeing of Londoners, we recommend:
If you would like to talk through your project and HIA requirements, get in touch with Zoe Crampton, Associate Director, at zoe.crampton@gcinsight.co.uk or Margaret Collins, Director, at margaret.collins@gcinsight.co.uk.
You can learn more about planning services here.
[1] www.health.org.uk