Just 38% of Local Plans require Health Impact Assessments: They all should

 

An analysis of 344 Local Plans from across 314 local planning authorities across England in February 2023 revealed that 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.

 

There is a huge degree of variation in Local Plans where a HIA was required and a wide variety in the triggers which might prompt an 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. 

 

Triggers ranged from five homes to 500 homes, from 500m2 to 10,000m2 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 an HIA, covering different types of development and/or the extent of the 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. The ambition should be to maximise the potential health benefits of development, reduce inequalities, and mitigate 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 wellbeing 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 Health Impact Assessment 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.

After we examined existing local policies in detail, 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 decisionmaking. In response, a series of films were commissioned by TRUUD to give a variety of perspectives and experiences of developing and implementing HIA policies, what has worked and lessons learned.

 

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 an HIA.

 

---

Ed Kirton-Darling is Senior Law Lecturer at the University of Bristol and part of the law intervention team at TRUUD. The underlying research relating to Local Plans was undertaken by Katharine Hanss. Michael Chang undertook the census of Local Plans and for provided this data. With thanks to the Office for Health Improvement and Disparities which collaborated on this work, and the local authorities who took part in the OHID-led workshops in autumn 2023.