Background
Centric Lab and Clean Air for Southall & Hayes have been working together since 2018 with a focus on the injustices that have led to poor health outcomes in Southall in relation to urban planning systems. Our collaboration has primarily centred around the redevelopment of a former Gasworks site that sits at the southern border of Southall (and Ealing borough) adjacent to railway tracks, with Hillingdon Council on the other side of the tracks.
In 2018 residents of Southall were experiencing a range of ill health issues - headaches, coughs, tiredness, difficulty sleeping, and more. Over time, neighbours began to share their stories and noticed that it happened to coincide with the beginning of redeveloping the land of the former Gasworks site.
The gasworks had been decommissioned since the mid 1970s and concreted over and used as a car park. However, as part of an asset disposal plan, National Grid Plc formed a joint venture partnership with St. Williams Homes LLP (a company from the Berkeley Homes Group) in order to generate income from latent assets to invest back into the National Grid.
“National Grid has over 20 sites in London and the South East with the potential to provide over 14,000 homes over the next 10-15 years. In its first phase, St William aims to develop more than 7,000 new homes, including over 2,000 affordable homes. Development at this scale would also deliver 5,500 jobs, 2 new schools and 22 acres of public open space, transforming 84 acres of former industrial land and contributing over £150m to local infrastructure and amenities.” (source)
The planning application for a redevelopment of the land from a car park to a residential-led scheme of around 3,500 homes faced backlash from the community and local authorities. Primary concerns were on the impact of air pollution from vehicles and commercial activity that would descend upon an already saturated road network. Although the scheme sat within the London borough of Ealing, Hillingdon Council also raised concerns about the redevelopment on a number of conditions, one of which being the issue that the land was contaminated with toxic chemicals due to its use as a heavy industrial site. However, the Mayor of London’s Office exercised their power and “called-in” the planning application and used their executive powers to override the decision of the local authority and grant consent. The Mayor of London, at that time Boris Johnson, saw the scheme as necessary for the growth of London’s economy and an ideal location for new homes to be delivered alongside London’s new Crossrail, which stops at Southall.
In 2018, some years after consent had been granted, the land started to be remediated and the chemicals released into the air. As Angela Fonso, lead organiser for CASH, said “A putrid like smell hung in the air”.
We have written extensively about the health impacts of air pollution, gasworks, the experience of being gaslight by authorities, and shared our collaborative research project with CASH. Therefore, this work is going to focus on one specific area: the inadequacy of the health impact assessment.
What is a Health Impact Assessment?
Health Impact Assessment (HIA) is a practical approach used to judge the potential health effects of a policy, programme or project on a population, particularly on vulnerable or disadvantaged groups. Recommendations are produced for decision-makers and stakeholders, with the aim of maximising the proposal's positive health effects and minimising its negative health effects. The approach can be applied in diverse economic sectors and uses quantitative, qualitative and participatory techniques. HIA provides a way to engage with members of the public affected by a particular proposal. It also helps decision-makers make choices about alternatives and improvements to prevent disease or injury and to actively promote health. It is based on the four interlinked values of democracy (promoting stakeholder participation), equity (considering the impact on the whole population), sustainable development and the ethical use of evidence.
It is very clear what the merits of an HIA bring. However, when reviewing the planning application submitted in 2008, the review of health impacts were negligible…..FILL IN DETAILS.
It became clear to us that principles set forward by the WHO were not being represented in the UK planning system. Despite overtures of community engagement and shaping of public policy National Planning Policy Framework and Local Plan development is a heavily technocratic approach. Top-down objectives on economic, social, and climate agendas are carried down and shaped into local contexts. Sadly, what can also be seen is that NGO guidance can be used but watered down and weaponised by vested interests to support those interests.
For local authorities in London, the NHS London Healthy Urban Development Unit (HUDU) produces a HIA Toolkit that can be used where local authorities express their desire for impact assessments to be produced as part of a planning application. By using it, the applicant (typically a developer) demonstrates best practice in doing so. In turn this means that by using this template it can be interpreted that the applicant has fulfilled their obligations in ensuring that health impacts have been understood and addressed. Local authority planning departments more often that not are not specialists in health, meaning that word is taken as gospel and the matter is resolved and they can get on with more important matters such as affordable housing numbers or contributions. The HIA is wedged into the multi-hundred page application documents and buried deep into technical websites.
It feels hard to see the WHOs pillar of democracy being represented.
Given the HIA produced for the application was, in our opinion, inadequate we realised that the system needs a rethink.
We saw an opportunity to reimagine what an HIA would look like if designed from the community out: what would it look like; how would it work; who does it; what role does the community play? These were the types of questions we wanted to ask ourselves to think what would happen if this very simple layer of policy work could actually mean something and be upheld to a high standard just as issues on design, why not health? Why not the very thing that guides our life?
Why do things have to be so British that we hold organisations accountable for whether a building - this immovable, dead, climate-wrecking pile of bricks and piping - looks nice, but not life itself? Surely there was a way to bridge the gap between development actions and health outcomes?
Policy Context
The World Health Organisation states that a “Health Impact Assessment (HIA) is a practical approach used to judge the potential health effects of a policy, programme or project on a population, particularly on vulnerable or disadvantaged groups. Recommendations are produced for decision-makers and stakeholders, with the aim of maximising the proposal's positive health effects and minimising its negative health effects. The approach can be applied in diverse economic sectors and uses quantitative, qualitative and participatory techniques.
“HIA provides a way to engage with members of the public affected by a particular proposal. It also helps decision-makers make choices about alternatives and improvements to prevent disease or injury and to actively promote health. It is based on the four interlinked values of democracy (promoting stakeholder participation), equity (considering the impact on the whole population), sustainable development and the ethical use of evidence.
Health impact assessment can be a valuable tool for helping to develop policy and assisting decision-makers in these (transport, agriculture and housing) and other areas. Because HIA provides a way to engage with members of the public affected by a particular proposal, it can show that an organization or partnership wants to involve a community and is willing to respond constructively to their concerns. The views of the public can be considered alongside expert opinion and scientific data, with each source of information being valued equally within the HIA.
“Health impact assessments begin by identifying the relevant stakeholders. This usually produces a large number of relevant people and organizations. HIA is a framework to implicate stakeholders in a meaningful way, allowing their messages to be heard. The process draws on all resources in the project and wider community to help guide decision making, including developers and planners, employers and unions, local and national health workers, and those living in the community— particularly the most vulnerable members of the community and those directly impacted by the programme or project.”
UK Context
The Health and Social Care Act 2012 (‘the Act’) states that the Secretary of State’s (‘SoS’) duty is to promote a comprehensive health service designed to secure the improvement of the physical and mental health of people in England and the prevention, diagnosis, and treatment of physical and mental health. The Act outlines the purpose of clinical commissioning as the function for the provision of services in accordance with the Act.
The National Planning Policy Framework (‘NPPF’) places a strong emphasis on sustainable development, and for planning to support national growth. Founded on separate economic, social, and environmental objectives, the NPPF seeks to work towards achieving each objective through plan-making and decision-taking, thereby achieving the overarching aim of sustainable development and pursue the United Nations’ (‘UN’) 17 Sustainable Development Goals (‘SDGs’) in the period to 2030. Paragraph 9 states that in order to accomplish these objectives:“Planning policies and decisions should play an active role in guiding development towards sustainable solutions, but in doing so should take local circumstances into account, to reflect the character, needs and opportunities of each area.”
Section 8 of the NPPF places significant emphasis on using planning policies and decisions on promoting health and safe communities. This includes through promoting social interaction, creating safe and accessible places to minimise crime and disorder, and enabling healthy lifestyles through the provision of community space, access to healthy food, and safe and accessible green infrastructure.
The Planning Practice Guidance (‘PPG’) highlights the need to consider the impact of the built and natural environment on health and well-being and to “undertake positive planning to create environments that support and encourage healthy lifestyles” (Reference ID: 53-001-20190722). The PPG sets out the Government’s vision of a ‘healthy place’ as a place that supports and promotes healthy behaviours, reduces health inequalities, and supports community engagement and social interaction. It emphasises the importance of meeting the needs of children and young people, the increasingly elderly population, and those with dementia and other sensory or mobility impairments (Reference ID: 53-003-20191101).
HIAs are recognised as useful tools in the consideration of planning applications where there are expected to be significant impacts (Reference ID: 53-005-20190722). The PPG also focusses on how planning can play a crucial role in the creation of sustainable, inclusive, and healthy communities. This guidance is to be read alongside the National Model Design Code, which provides further detail on how design can promote social interaction, physical activity, and safe communities.
The National Model Design Code5 (‘NMDC’) provides detailed guidance on the production of design codes, guides, and policies to promote successful (as well as a healthy) design. This places a greater emphasis on development supporting wider health outcomes, such as:
How the design of new development should enhance the health and wellbeing of local communities and create safe, inclusive, accessible and active environments;
How landscape, green infrastructure and biodiversity should be approaches including the importance of streets being tree-lined; and
The environmental performance of place and buildings ensuring they contribute to net zero targets.
Public Health England’s guide, Health Impact Assessments in Spatial Planning, describes the health and well-being outcomes that can be influenced or optimised as part of the plan- making and planning application process.
The guide sets out an evidence-based approach for preparing HIAs, which includes establishing the baseline for the project, identifying HIA health outcomes, identifying specific population groups that could be affected, assessing the potential impacts of wider determinants of health as part of the scheme, and identifying recommendations for implementation and monitoring that will support positive health outcomes. It sets out that the extent of assessment within HIAs should be proportionate to the significance of impact of a proposed development. This HIA follows the approach set out in this document.
There are also Regional and Local context’s to the use of HIAs. The NHS London Health Urban Development Unit advise in their guidance:
Community engagement can provide the contextual knowledge that is often missing from purely quantitative evidence. It allows people to become involved in assessing the potential impact of a development proposal on their own health and wellbeing while also providing key information on the way in which impacts may be distributed across a whole population. Engagement should be ongoing, particularly during the different phases of large developments.
There are different methods to engage community and stakeholder groups, which vary according to the type of HIA used and the amount of time and resources available.
Participatory workshops
Interviews and focus groups
Recruiting public members to HIA steering groups
Surveys
A community led HIA, for example on a neighbourhood plan.
Development proposals and local plans are subject to statutory consultation. It may be beneficial to link HIA consultation and engagement with pre-application consultation on development proposals and early consultation on a Local Plan at the issues and options stage. The Council’s Statement of Community Involvement provides the minimum standards for public consultation on planning applications and local plans, including details of who should be consulted as well as techniques of community involvement. Community engagement may be linked to wider regeneration programme, for example a Council estate regeneration scheme. In such instances, engagement on the HIA may form part of wider consultation and engagement. The use of regeneration ballots and charters may encourage community engagement and highlight issues and concerns to be addressed in a HIA.
In the following chapter, Methods, we’ll detail our approach to reviewing the efficacy of this guidance and whether it has resembled reality for those living in Southall.
Background
Centric Lab and Clean Air for Southall & Hayes have been working together since 2018 with a focus on the injustices that have led to poor health outcomes in Southall in relation to urban planning systems. Our collaboration has primarily centred around the redevelopment of a former Gasworks site that sits at the southern border of Southall (and Ealing borough) adjacent to railway tracks, with Hillingdon Council on the other side of the tracks.
In 2018 residents of Southall were experiencing a range of ill health issues - headaches, coughs, tiredness, difficulty sleeping, and more. Over time, neighbours began to share their stories and noticed that it happened to coincide with the beginning of redeveloping the land of the former Gasworks site.
The gasworks had been decommissioned since the mid 1970s and concreted over and used as a car park. However, as part of an asset disposal plan, National Grid Plc formed a joint venture partnership with St. Williams Homes LLP (a company from the Berkeley Homes Group) in order to generate income from latent assets to invest back into the National Grid.
“National Grid has over 20 sites in London and the South East with the potential to provide over 14,000 homes over the next 10-15 years. In its first phase, St William aims to develop more than 7,000 new homes, including over 2,000 affordable homes. Development at this scale would also deliver 5,500 jobs, 2 new schools and 22 acres of public open space, transforming 84 acres of former industrial land and contributing over £150m to local infrastructure and amenities.” (source)
The planning application for a redevelopment of the land from a car park to a residential-led scheme of around 3,500 homes faced backlash from the community and local authorities. Primary concerns were on the impact of air pollution from vehicles and commercial activity that would descend upon an already saturated road network. Although the scheme sat within the London borough of Ealing, Hillingdon Council also raised concerns about the redevelopment on a number of conditions, one of which being the issue that the land was contaminated with toxic chemicals due to its use as a heavy industrial site. However, the Mayor of London’s Office exercised their power and “called-in” the planning application and used their executive powers to override the decision of the local authority and grant consent. The Mayor of London, at that time Boris Johnson, saw the scheme as necessary for the growth of London’s economy and an ideal location for new homes to be delivered alongside London’s new Crossrail, which stops at Southall.
In 2018, some years after consent had been granted, the land started to be remediated and the chemicals released into the air. As Angela Fonso, lead organiser for CASH, said “A putrid like smell hung in the air”.
We have written extensively about the health impacts of air pollution, gasworks, the experience of being gaslight by authorities, and shared our collaborative research project with CASH. Therefore, this work is going to focus on one specific area: the inadequacy of the health impact assessment.
What is a Health Impact Assessment?
Health Impact Assessment (HIA) is a practical approach used to judge the potential health effects of a policy, programme or project on a population, particularly on vulnerable or disadvantaged groups. Recommendations are produced for decision-makers and stakeholders, with the aim of maximising the proposal's positive health effects and minimising its negative health effects. The approach can be applied in diverse economic sectors and uses quantitative, qualitative and participatory techniques. HIA provides a way to engage with members of the public affected by a particular proposal. It also helps decision-makers make choices about alternatives and improvements to prevent disease or injury and to actively promote health. It is based on the four interlinked values of democracy (promoting stakeholder participation), equity (considering the impact on the whole population), sustainable development and the ethical use of evidence.
It is very clear what the merits of an HIA bring. However, when reviewing the planning application submitted in 2008, the review of health impacts were negligible…..FILL IN DETAILS.
It became clear to us that principles set forward by the WHO were not being represented in the UK planning system. Despite overtures of community engagement and shaping of public policy National Planning Policy Framework and Local Plan development is a heavily technocratic approach. Top-down objectives on economic, social, and climate agendas are carried down and shaped into local contexts. Sadly, what can also be seen is that NGO guidance can be used but watered down and weaponised by vested interests to support those interests.
For local authorities in London, the NHS London Healthy Urban Development Unit (HUDU) produces a HIA Toolkit that can be used where local authorities express their desire for impact assessments to be produced as part of a planning application. By using it, the applicant (typically a developer) demonstrates best practice in doing so. In turn this means that by using this template it can be interpreted that the applicant has fulfilled their obligations in ensuring that health impacts have been understood and addressed. Local authority planning departments more often that not are not specialists in health, meaning that word is taken as gospel and the matter is resolved and they can get on with more important matters such as affordable housing numbers or contributions. The HIA is wedged into the multi-hundred page application documents and buried deep into technical websites.
It feels hard to see the WHOs pillar of democracy being represented.
Given the HIA produced for the application was, in our opinion, inadequate we realised that the system needs a rethink.
We saw an opportunity to reimagine what an HIA would look like if designed from the community out: what would it look like; how would it work; who does it; what role does the community play? These were the types of questions we wanted to ask ourselves to think what would happen if this very simple layer of policy work could actually mean something and be upheld to a high standard just as issues on design, why not health? Why not the very thing that guides our life?
Why do things have to be so British that we hold organisations accountable for whether a building - this immovable, dead, climate-wrecking pile of bricks and piping - looks nice, but not life itself? Surely there was a way to bridge the gap between development actions and health outcomes?
Policy Context
The World Health Organisation states that a “Health Impact Assessment (HIA) is a practical approach used to judge the potential health effects of a policy, programme or project on a population, particularly on vulnerable or disadvantaged groups. Recommendations are produced for decision-makers and stakeholders, with the aim of maximising the proposal's positive health effects and minimising its negative health effects. The approach can be applied in diverse economic sectors and uses quantitative, qualitative and participatory techniques.
“HIA provides a way to engage with members of the public affected by a particular proposal. It also helps decision-makers make choices about alternatives and improvements to prevent disease or injury and to actively promote health. It is based on the four interlinked values of democracy (promoting stakeholder participation), equity (considering the impact on the whole population), sustainable development and the ethical use of evidence.
Health impact assessment can be a valuable tool for helping to develop policy and assisting decision-makers in these (transport, agriculture and housing) and other areas. Because HIA provides a way to engage with members of the public affected by a particular proposal, it can show that an organization or partnership wants to involve a community and is willing to respond constructively to their concerns. The views of the public can be considered alongside expert opinion and scientific data, with each source of information being valued equally within the HIA.
“Health impact assessments begin by identifying the relevant stakeholders. This usually produces a large number of relevant people and organizations. HIA is a framework to implicate stakeholders in a meaningful way, allowing their messages to be heard. The process draws on all resources in the project and wider community to help guide decision making, including developers and planners, employers and unions, local and national health workers, and those living in the community— particularly the most vulnerable members of the community and those directly impacted by the programme or project.”
UK Context
The Health and Social Care Act 2012 (‘the Act’) states that the Secretary of State’s (‘SoS’) duty is to promote a comprehensive health service designed to secure the improvement of the physical and mental health of people in England and the prevention, diagnosis, and treatment of physical and mental health. The Act outlines the purpose of clinical commissioning as the function for the provision of services in accordance with the Act.
The National Planning Policy Framework (‘NPPF’) places a strong emphasis on sustainable development, and for planning to support national growth. Founded on separate economic, social, and environmental objectives, the NPPF seeks to work towards achieving each objective through plan-making and decision-taking, thereby achieving the overarching aim of sustainable development and pursue the United Nations’ (‘UN’) 17 Sustainable Development Goals (‘SDGs’) in the period to 2030. Paragraph 9 states that in order to accomplish these objectives:“Planning policies and decisions should play an active role in guiding development towards sustainable solutions, but in doing so should take local circumstances into account, to reflect the character, needs and opportunities of each area.”
Section 8 of the NPPF places significant emphasis on using planning policies and decisions on promoting health and safe communities. This includes through promoting social interaction, creating safe and accessible places to minimise crime and disorder, and enabling healthy lifestyles through the provision of community space, access to healthy food, and safe and accessible green infrastructure.
The Planning Practice Guidance (‘PPG’) highlights the need to consider the impact of the built and natural environment on health and well-being and to “undertake positive planning to create environments that support and encourage healthy lifestyles” (Reference ID: 53-001-20190722). The PPG sets out the Government’s vision of a ‘healthy place’ as a place that supports and promotes healthy behaviours, reduces health inequalities, and supports community engagement and social interaction. It emphasises the importance of meeting the needs of children and young people, the increasingly elderly population, and those with dementia and other sensory or mobility impairments (Reference ID: 53-003-20191101).
HIAs are recognised as useful tools in the consideration of planning applications where there are expected to be significant impacts (Reference ID: 53-005-20190722). The PPG also focusses on how planning can play a crucial role in the creation of sustainable, inclusive, and healthy communities. This guidance is to be read alongside the National Model Design Code, which provides further detail on how design can promote social interaction, physical activity, and safe communities.
The National Model Design Code5 (‘NMDC’) provides detailed guidance on the production of design codes, guides, and policies to promote successful (as well as a healthy) design. This places a greater emphasis on development supporting wider health outcomes, such as:
How the design of new development should enhance the health and wellbeing of local communities and create safe, inclusive, accessible and active environments;
How landscape, green infrastructure and biodiversity should be approaches including the importance of streets being tree-lined; and
The environmental performance of place and buildings ensuring they contribute to net zero targets.
Public Health England’s guide, Health Impact Assessments in Spatial Planning, describes the health and well-being outcomes that can be influenced or optimised as part of the plan- making and planning application process.
The guide sets out an evidence-based approach for preparing HIAs, which includes establishing the baseline for the project, identifying HIA health outcomes, identifying specific population groups that could be affected, assessing the potential impacts of wider determinants of health as part of the scheme, and identifying recommendations for implementation and monitoring that will support positive health outcomes. It sets out that the extent of assessment within HIAs should be proportionate to the significance of impact of a proposed development. This HIA follows the approach set out in this document.
There are also Regional and Local context’s to the use of HIAs. The NHS London Health Urban Development Unit advise in their guidance:
Community engagement can provide the contextual knowledge that is often missing from purely quantitative evidence. It allows people to become involved in assessing the potential impact of a development proposal on their own health and wellbeing while also providing key information on the way in which impacts may be distributed across a whole population. Engagement should be ongoing, particularly during the different phases of large developments.
There are different methods to engage community and stakeholder groups, which vary according to the type of HIA used and the amount of time and resources available.
Participatory workshops
Interviews and focus groups
Recruiting public members to HIA steering groups
Surveys
A community led HIA, for example on a neighbourhood plan.
Development proposals and local plans are subject to statutory consultation. It may be beneficial to link HIA consultation and engagement with pre-application consultation on development proposals and early consultation on a Local Plan at the issues and options stage. The Council’s Statement of Community Involvement provides the minimum standards for public consultation on planning applications and local plans, including details of who should be consulted as well as techniques of community involvement. Community engagement may be linked to wider regeneration programme, for example a Council estate regeneration scheme. In such instances, engagement on the HIA may form part of wider consultation and engagement. The use of regeneration ballots and charters may encourage community engagement and highlight issues and concerns to be addressed in a HIA.
In the following chapter, Methods, we’ll detail our approach to reviewing the efficacy of this guidance and whether it has resembled reality for those living in Southall.