EIA – a new role for the planning system in considering the health impacts of development?
The role of the planning system in protecting or improving public health is the subject of some debate. Will the new Environmental Impact Assessment Regulations, which come into force on 16 May 2017, put the position on surer footing?
For some years, applicants for EIA development have had to consider the likely significant effects of the development on 'population' – usually covered primarily in a "socio-economic" chapter within the environmental statement. In practice, this treatment of socio-economic issues has varied significantly. Some have argued that EIA does not currently sufficiently cover the impact of developments on human health and the quality of life, health and wellbeing, and that much more could and should be done by the planning system in this regard.
Applicants will, once the new Regulations are in force, be specifically required to assess the direct and indirect significant effects of the proposed development on "population and human health". To understand this, it is perhaps worth recalling the WHO definition of "health" which refers to "complete physical, mental and social well-being". To date, socio-economic chapters have tended to focus on issues such as the generation of jobs and the provision of school places and increased public open space, so there would seem to be a shift in emphasis here, even though there is no specific UK guidance on what precisely should be considered under this new "health" umbrella, and how potential impacts should be assessed.
An obvious factor for developers to consider under this new "health" umbrella is the availability of GP surgeries etc - often a factor which raises objections from existing communities who feel that their area cannot bear any population increases - but what about the impact of social isolation on mental health or how the design of buildings can ensure appropriate temperature levels in new homes? The range of issues to be covered by is seemingly vast.
Has the planning system already got this covered? Health Impact Assessments are specifically required by many local authorities, as are transport assessments which will look at matters such as walking distance to public transport and the promotion of cycling over car use. Air quality environmental statement chapters already consider the impact of air pollution from roads and contaminated land. Daylight, sunlight and overcrowding should already be being considered too.
Even if it is already all in the application material somewhere, I see no harm in making health a specific EIA consideration. This should give confidence to stakeholders that the issue of human health has been considered holistically, and act as a focal point for interested parties who might otherwise be faced with considering a number of separate documents to be sure that they have the whole picture.
That said, the new EIA Regulations are likely to lead to more front-loading of the assessment process but possibly also in fewer full assessments, so it remains important that these issues can be dealt with elsewhere.Please do get in touch if you would like to discuss this or the other changes brought about by the new EIA Regulations in any further detail.