Produced by Planning Policy and Public Health teams - updated September 2021
The links between planning and health are long-established; planning originated as a response to address public health concerns arising from sub-standard housing and living conditions.
Although a person’s health is in part determined by genetics, age and lifestyle, the built and natural environment within which people live and work has a major influence. Planning for health therefore needs to ensure that we plan for and build a health-promoting environment, that improves the health of those who live, work or visit the city.
The World Health Organisation defines health as including good physical, mental and social wellbeing. Good health is not just about the absence of illness. This definition of health is used in Health Impact Assessments (HIA) as HIAs cover both the factors that support good health as well as those that cause ill-health.
The purpose of this guidance is to provide technical advice for developers and applicants on undertaking a HIA, and guidance for local authority officers and public health professionals on assessing HIAs submitted with planning applications.
It provides guidance and interpretation of the policies most relevant to health, and provides a local Checklist which will support the HIA process (see Appendix 1).
The Checklist comprises various criteria of relevance to health for four overarching themes; Healthy Housing, Active Lifestyles, Healthy Environment, and Safe & Vibrant Neighbourhoods. The Checklist includes examples of measures that can support good health for each of the criteria.
This guidance also outlines the different types of HIAs and the various stages of the HIA process.
The aims of this guidance note are to:
The objectives of this guidance note are to:
The planning system in place today seeks to address health issues through implementation of national and local planning policies.
Read The National Planning Policy Framework.
The NPPF requires public health to be taken into account in both plan-making and decision-taking and states the purpose of planning is to contribute to the achievement of sustainable development, with delivery of the social objective of sustainable development being paramount to supporting health.
Paragraph 8b: a social objective - supports strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being.
Links to health can be found throughout, with key areas including policies on delivering homes (section 5), transport (section 9), design (section 12), climate change (section 14), and the natural environment (section 15).
In addition, section 8, Promoting Healthy and Safe Communities, paragraph 92, requires planning policies and decisions to aim to achieve healthy, inclusive and safe places which promote social interaction, that are safe and accessible, and enable and support healthy lifestyles, especially where this would address identified local health and well-being needs.
Paragraph 93 requires planning policies and decisions to provide the social, recreational and cultural facilities and services the community needs, through planning positively for the provision and use of shared spaces, community facilities and other local services to enhance the sustainability of communities and residential environments, taking into account and supporting the delivery of local strategies to improve health, social and cultural well-being for all sections of the community, and guarding against the unnecessary loss of valued facilities and services.
In addition, paragraph 98 recognises the importance of access to quality open space and opportunities for sport and physical activity for health and well-being.
Read the National Policy Guidance.
The NPPF is supported by additional guidance set out in the NPPG. The NPPG recognises that the built and natural environment has a major influence on health and wellbeing and states that planning has a role in creating environments that support and encourage healthy lifestyles.
The NPPG describes a healthy place as one which supports and promotes healthy behaviours and environments, and one which reduces health inequalities.
It also describes a healthy place as one which:
The NPPG regards Health Impact Assessment as a useful tool to use where there are expected to be significant impacts.
The City Plan Part 1 (2016), saved policies from the Local Plan (2005), the Waste & Minerals Local Plan and the Shoreham Harbour Joint Area Action Plan comprise the local Development Plan and provide the local planning policy framework. City Plan Part 2 is currently being prepared. Once adopted, this will replace the Local Plan 2005 and sit alongside City Plan Part 1.
Health is a cross-cutting theme that is embedded within City Plan Part 1 which includes the following strategic objectives to support achieving the vision of becoming a “Healthy City”:
SO19: Contribute towards the delivery of more sustainable communities and the reduction of inequalities between neighbourhoods in Brighton & Hove.
City Plan Policy CP18 “A Healthy City” is the key policy that aims to reduce health inequalities and promotes healthier lifestyles.
Key policy points are:
Various other policies of both City Plan Part 1 and the Local Plan are also of relevance to health and wellbeing and support achieving many of the social determinants of health; for example provision of open space, encouragement of walking and cycling, and ensuring housing delivered is of an acceptable standard.
The Waste and Minerals Local Plan also includes objectives and policies of relevance to health, including Strategic Objective 4: To protect and enhance the environment, communities and human health.
Although the Shoreham Harbour JAAP does not have a specific objective relating to health, various objectives of the JAAP are relevant including:
A list of the various local planning policies of relevance to health can be found in Appendix 2.
There are various strategies which set the context and provide evidence of how the planning system can address health issues and improve health outcomes.
“Fair Society, Healthy Lives”(the Marmot Review) (2010). The review found that individual health is influenced by wider determinants such as income, education, local environmental quality and employment; the ‘social determinants of health’. The review set out 6 policy objectives for reducing health inequalities including ‘to create and develop healthy and sustainable places and communities’.
“Healthy Lives, Healthy People: our strategy for public health in England” (2010). This White Paper sets out the Government’s long-term vision for the future of public health in England. It adopts the Marmot Review’s framework for tackling the social determinants of health, and aims to support healthy communities including by:
“Prevention is Better than Cure” (DoH, 2018). This seeks to improve healthy life expectancy and reduce health inequalities, recognising that various factors influence health including housing, neighbourhoods, education, safety, transport, food, leisure, greenspace and employment.
Brighton & Hove’s Joint Health and Wellbeing Strategy (2019). This recognises the various factors that influence health and includes an overarching vision to improve health and wellbeing and reduce health inequalities. It states that “Planning of major developments and transport schemes will promote health and wellbeing”.
Brighton & Hove’s Joint Strategic Needs Assessment provides local evidence on the health needs of the city and is used in formulating local policy.
City Plan Part 1 Policy CP18 sets out the requirements relating to HIA.
CP18.2 Require HIA on all strategic developments in the city.
CP18.3 Require larger developments to demonstrate how they minimise negative impacts and maximise positive impacts on health within the development or in adjoining areas.
Further information on “strategic developments” can be found in sections 4.3 to 4.12.
More information on “larger developments” can be found in sections 4.13 to 4.17.
The supporting text to Policy CP18, paragraph 4.201, defines “strategic developments” as either:
City Plan Part 1 designates 8 Development Areas in the city. HIA is required for the Strategic Site Allocations within these Development Areas. See below the Development Areas and Strategic Allocations/Areas whereby policy CP18.2 applies.
Strategic allocation:
Once adopted, City Plan Part 2 will also include some further Strategic Site Allocations.
These will also require HIA:
Other developments that do not form a strategic allocation within City Plan Part 1 or City Plan Part 2, but which are considered to be of an equivalent size, will also be required to carry out an HIA.
Policy CP18.2 also requires HIA for development that requires an Environmental Impact Assessment (EIA).
Some types of development automatically require EIA, including those set out in Schedule 1 of the EIA Regulations (Town and Country Planning (Environmental Impact Assessment) Regulations 2017). This includes, for example certain types of waste disposal installations, waste water treatment plants and certain types of industrial plants. Developments that automatically require EIA are therefore required to carry out an HIA.
Other types of development, as set out in Schedule 2 of the EIA Regulations, are only required to carry out EIA if a screening exercise determines the likelihood of significant effects.
See below the types and sizes of development most likely to come forward locally that are required to undergo screening in accordance with Schedule 2 of the EIA Regulations. Developments that are smaller than the threshold indicated are not required to undertake EIA.
If the screening exercise determines that significant effects are likely and EIA is required, then HIA is also required.
For more information on EIA and the links to HIA see section 6.3.
Other developments could come forward in the city which are not required to carry out an HIA as described above, however may be of a scale that could have health impacts.
CP18 policy point 3 addresses such developments and requires:
“Larger developments to demonstrate how they minimise negative and maximise positive impacts on health within the development or in adjoining areas”.
For these purposes, “larger” developments are considered to be those providing:
Applications to vary conditions of approved applications associated with the above types of development may also be subject to this requirement, particularly where the variation relates to changes to the approved drawings.
A lighter touch approach will be appropriate for larger developments to demonstrate how they meet the requirement of CP18.3. A statement should be provided which initially identifies potential negative and positive impacts and then summarises how negative impacts have been minimised and how positive impacts have been maximised, for both new occupiers and existing communities.
The checklist provided in Appendix 1 can be used to help identify how a development might positively or negatively influence health. This can form the basis of this statement.
A Health Impact Assessment (HIA) is undertaken to indicate the health implications on a population of implementing a project, such as a new development proposal, policy or programme. It is a tool that can be used to assess the positive aspects of a proposal, for example, creation of new jobs and the negative effects, for example, pollution on different population groups. It is particularly focused on looking at how disadvantaged groups may be affected, to minimise the risks of widening inequalities.
It is a tool that is based upon considering the wider determinants of health, which are the range of personal, social, economic and environmental factors which determine the health of an individual or population. These are illustrated in Figure 1.
Barton, H. and Grant, M. (2006) “A health map for the local human habitat”, The Journal for the Royal Society for the Promotion of Health, 126 (6). pp.252 to 253.
HIA is usually used to assess a proposal that does not have health improvement as a primary objective, for example a planning application for a proposed development. The assessment considers whether the implementation of a proposal may achieve its objectives but with unintended or unanticipated consequences for health, which may be either good or bad.
The purpose of an HIA is to ascertain whether the impact on health of a particular proposal is acceptable or not. They assist decision-makers by giving them better information, but do not make the decision for them.
HIAs give valuable information not only about potential effects on health, but also how to manage them. It therefore provides the opportunity to amend the design of a proposed development to protect and improve health. Changing a proposal as a result of a HIA means that not only is its implementation more likely to promote health, but it is also less likely to cause ill-health in the community, with the consequential benefits for individuals and the wider economy.
An HIA should:
HIAs are beneficial because they can lead to better developments that reflect the health and wellbeing needs of the local population and help build a healthier city. By predicting the negative impacts they can prevent damage from happening.
The cross-sectoral nature of some HIAs involves multiple stakeholders, which helps in the development of partnership working. Involving local stakeholders who will be affected by the proposals, or who have knowledge of the local area, ensures that developments are informed by their views and health needs.
There can also be long-term savings to health and social care budgets, for example, through the promotion of good health and prevention of ill-health.
For relevant developments, HIAs should commence at the start of the planning process, at the pre-application stage.
This will enable the HIA findings to be incorporated into changes to the proposed development, where necessary.
For developments that seek approval under separate outline and reserved matters applications, an HIA should be undertaken at both stages, with HIA reflecting the content of the applications. For example, an HIA undertaken at outline stage would likely assess the overarching principles and amounts of development; an HIA undertaken at reserved matters stage would assess the remaining matters of the scheme, such as access, appearance, layout, scale and therefore quality of housing or development provided.
The production of an HIA at reserved matters stage may be secured by planning condition at outline stage, as may other elements of the scheme in relation to health impacts.
There are a range of different types of HIA.
1. Desktop HIAs – encompass a small number of participants working together using existing knowledge and evidence to assess a proposal, policy, or plan.
2. Rapid HIAs – establish a small steering group and often use the approach of a participatory stakeholder workshop. This typically involves a brief investigation of health impacts, including a short literature review of quantitative and qualitative evidence and the gathering of knowledge and further evidence from a number of local stakeholders.
3. Comprehensive HIAs – in-depth analysis, with extensive literature searches and collection of primary data. This will include the comprehensive involvement of stakeholders such as focus groups, panels/public consultations, and interviews.
An HIA will often fit in-between two of these categories, as the approach taken will be determined by the nature and scale of the proposal and the timescales involved. For the majority of development coming forward in Brighton & Hove, it is considered likely that a desktop or rapid HIA will be most suitable. However, the most appropriate type of HIA should be discussed with the Public Health team.
EIA is a statutory requirement for certain types of developments. It is also a requirement for certain types and sizes of developments if they are determined to result in significant effects following a screening exercise. Recent changes to the EIA Regulations have resulted in the need to consider “population and human health” within an EIA.
Where EIA is required, HIA can be integrated into the EIA process. However, this will require a more structured assessment that meets the requirements of the EIA Regulations. In addition EIA only requires consideration of significant effects and allows consideration of mitigation resulting in a residual assessment.
The EIA Regulations also require a formal stage of consultation.
HIAs commonly have four main stages:
Not all development proposals will require an HIA; this will depend on the type, scale and location of the development or proposal. The screening stage of the HIA is therefore to decide whether or not an HIA needs to be undertaken.
City Plan policy CP18 requires certain developments to carry out a HIA, as described in Section 4.1. These developments should therefore go straight to scoping stage.
The issues to be considered include:
The following will also help in filtering out development proposals that are unlikely to benefit from an HIA:
The Checklist in Appendix 1 can be used at screening stage to help determine whether HIA is required.
The Scoping Stage of an HIA is about planning how the HIA will be undertaken and deciding which type of HIA is the most appropriate. This will depend upon the type and size of the project. Most development proposals are likely to require a Desktop or Rapid HIA, however there may be cases where a more comprehensive HIA is required. The Public Health team may be able to advise on this.
The scoping stage should:
When carrying out the Screening and Scoping stages it is important to ensure that:
The assessment process has two main stages; the development of the local profile and the appraisal of the proposal.
A health profile of the local population should be produced as a baseline for assessing the health impacts of the development. The health profile should contain data on:
As the HIA will need to consider the impacts on both the existing local population and any future population, the profile should also consider any changes to population that would arise from the development, e.g. an increase in any particular type of group or significant change in demographics.
Appendix 3 includes links to sources of local demographic and health data that can be used in preparation of the local profile.
The purpose of the appraisal is identify all the potential health impacts and will involve assessing the proposal and considering how it relates to the range of wider determinants of health of the local population.
The appraisal stage should include consideration of the potential positive and negative impacts of the proposal on the local population, including sub-population groups.
The Checklist in Appendix 1 should be used to assist in the identification of impacts.
Impacts can affect different groups in different ways, can be direct or indirect, and could arise through unforeseen consequences. Impacts can also vary occur at different stages of a proposed development and this should be considered and documented.
The HIA should make it clear which impacts will affect which groups of people and be scored as either positive, negative or no impacts for each population group. It may also be appropriate to clarify whether impacts are significant. For example, where adverse impacts affect a large number of people, where they are irreversible, or where they affect people who already suffer from poor-health; or where positive impacts have significant potential for health improvements.
The assessment should be systematic and transparent about how impacts were identified.
If a Rapid or Comprehensive HIA has been recommended the appraisal stage should also include engagement with the local stakeholders, for example consultation for their views on health impact through questionnaire, focus groups and workshops, depending on the scale of development. The applicant will need to demonstrate how they have engaged with local stakeholders and incorporated their views into their plans.
Following the appraisal, recommendations should be developed by those undertaking the HIA to remove or mitigate adverse health impacts and to enhance the positive effects of proposals.
Recommendations should be practicable, achievable and have an evidence base for effectiveness. Recommendations could be prioritised based on significant impacts.
Recommendations may sometimes impinge on other areas of the proposal and therefore a balance needs to be struck to ensure any recommendations have the greatest chance of being acted upon.
The applicant will need to ensure that any HIA recommendations are worked through to an acceptable conclusion, for example, amendments to design.
It is suggested that an HIA report should include:
Monitoring and review are important components of the planning system. The process of undertaking and producing the HIA should be evaluated. This includes determining whether the HIA recommendations influenced decision making.
Brighton & Hove City Council will provide commentary on the progress on City Plan policies through the annual Authorities Monitoring Report (AMR) which forms the local planning monitoring framework. This will include monitoring the number of HIAs submitted for strategic developments, as required under the existing monitoring framework for City Plan Part 1.
Production of the HIA is the responsibility of the applicant. It should be undertaken whilst a proposed scheme is being developed, and needs to be submitted alongside the planning application. If an applicant intends to secure planning permission through separate outline and reserved matters applications, an HIA should be submitted at both stages and should reflect the associated application as described in paragraph 5.11.
An HIA review team, consisting of Brighton & Hove City Council officers including those within Public Health, will appraise the HIA submitted by the applicant making use of the Checklist in Appendix 1. The effects of the proposal on different population groups identified in the HIA will be considered, as well as the impact on the wider determinants of health and health inequalities.
The HIA review team will provide feedback on the HIA to the Planning Case Officer, in the form of a formal consultation response on the planning application from Public Health. This will be publically available on the council’s Planning Register.
Consultation comments received on the HIA may form the basis of further negotiations between the Case Officer and the applicant.
The HIA will be considered along with all other documentation submitted with the planning application, as well as any consultation responses received by members of the public and other consultees.
Recommendations arising from the HIA, which have not been incorporated into revised proposals, may form the basis of any planning conditions in order to make the development acceptable in planning terms. In addition, for outline and reserved matters applications, the decision could include conditions to undertake HIA at reserved matters stage, as well as secure recommendations of the HIA.
Any conclusions or recommendations from the HIA to remove or mitigate adverse effects or maximise beneficial effects provided to the applicant
Identify if HIA required. Checklist in Appendix 1 can help this process
Any conclusions or recommendations from the HIA to remove or mitigate adverse effects or maximise beneficial effects provided to the applicant
This checklist has been designed to support an HIA. It provides questions to consider when assessing a proposal and examples to support implementation. The questions are not exhaustive, and not all questions will be of relevance to all proposals.
The potential for adverse or positive impacts on the local population, including relevant sub-population groups, should be considered against each question, as well as any other health-related consideration of relevance to the development.
Sub-population groups include:
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BREEAM = Building Research Establishment Environmental Assessment Method: sustainability assessment and certification for development proposals; includes a category on health & wellbeing.
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Policies may be listed more than once as relevant to the different topics of:
City Plan Part 2 policies are also included as these gather weight as they go through the various stages of plan preparation.
This list is not exhaustive and other policy requirements may also influence health.
City Plan Part 1 | Local Plan | City Plan Part 2 |
|---|---|---|
| SA6 Sustainable Neighbourhoods | HO5 Private amenity space
| DM1 Housing quality, choice and mix |
CP8 Sustainable Buildings
| HO11 Residential care and nursing homes | DM4 Housing and accommodation for older people |
CP12 Urban Design
| HO12 Sheltered and managed housing | DM5 Supported accommodation (specialist and vulnerable needs) |
CP14 Housing Density
| HO13 Accessible housing and lifetime homes | DM6 Build to rent housing
|
| CP19 Housing Mix | DM7 Houses in Multiple Occupation | |
| CP20 Affordable Housing | DM8 Purpose Built Student Accommodation | |
| CP21 Student Housing and Houses in Multiple Occupation | DM44 Energy efficiency and renewable |
City Plan Part 1 | Local Plan | City Plan Part 2 |
|---|---|---|
SA6 Sustainable Neighbourhoods
| TR7 Safe development
| DM18 High quality design and places |
CP9 Sustainable Transport
| TR11 Safe routes to school
| DM33 Safe, sustainable and active travel |
CP12 Urban Design
| TR12 Helping the independent movement of children | DM35 Travel plans and transport assessments |
| CP13 Public Streets and Spaces | TR14 Cycle access and parking
| DM36 Parking and servicing |
CP16 Open Space
| TR15 Cycle network | DM22 Landscape Design and Trees |
CP17 Sports Provision
| QD15 Landscape Design
|
City Plan Part 1 | Local Plan | City Plan Part 2 | Waste and Minerals Local Plan |
|---|---|---|---|
SA1 The Seafront
| SU9 Pollution and nuisance control | DM18 High quality design and places | WMP25 General Amenity |
| SA2 Central Brighton | SU10 Noise nuisance | DM20 Protection of amenity | |
| CP8 Sustainable Buildings | QD15 Landscape design | DM22 Landscape design and trees | |
| CP9 Sustainable Transport | QD16 Trees and hedgerows | DM37 Green infrastructure and nature conservation | |
| CP10 Biodiversity | QD18 Species protection | DM40 Protection of the environment and health - pollution and nuisance | |
CP11 Flood Risk
| QD27 Protection of amenity
| DM42 Protecting the water environment | |
| CP13 Public Streets and Spaces | DM43 Sustainable urban drainage |
City Plan Part 1 | Local Plan | City Plan Part 2 |
|---|---|---|
| SA2 Central Brighton | HO19 New community facilities | DM4 Housing and accommodation for older people |
| SA6 Sustainable Neighbourhoods | EM4 New business and industrial uses | DM9 Community facilities |
| CP2 Sustainable Economic Development | EM9 Mixed uses
| DM11 New business floorspace
|
CP4 Retail Provision CP5 Culture and Tourism
| SR4 Regional shopping centre | DM12 Primary, secondary and local centre shopping frontages |
CP8 Sustainable Buildings
| SR5 Town and district shopping centres | DM13 Important local parades, neighbourhood parades and individual shop units |
| CP12 Urban Design | SR6 Local centres | DM16 Markets
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| CP13 Public Streets and Spaces | SR7 Local parades | DM18 High quality design and places |
CP16 Open Space
| SR11 Markets and car boot sales | DM22 Landscape design and trees
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| QD8 Shop shutters | DM23 Shop fronts | |
| QD15 Landscape design | ||
| QD21 Allotments |
BH Joint Health and Wellbeing Strategy 2019.
BH Joint Strategic Needs Assessment (JSNA).
BH JSNA Executive Summary 2019
Community Insight Brighton & Hove - facts and figures for different geographic levels in Brighton & Hove.
Public Health England Local Authority Health Profiles.
Local Plan 2005 (retained) policies.
City Plan Part 2 (Proposed Submission, 2020).
Waste and Minerals Development Local Plan.
Shoreham Harbour Joint Area Action Plan.
Supplementary Planning Documents (SPDs).
Active Design (Sport England).
Healthy New Towns Programme (NHS/TCPA).
Creating Healthy Places (Design Council).
Creating Health Promoting Environments (TCPA).
The following examples are for information only.
HIA on the relocation and construction of a new railway station.
HIA of a residential development delivering 39 dwellings for older people.