Dr Andrew Buroni, Technical Director and Health Impact specialist, reflects on the impact of bringing human health considerations under the EIA Regulations, and discusses how developers and scheme promoters should deal with this new challenge.
Following the amended EIA Regulations coming into force on 16th May 2017, Environmental Statements now need to include ‘Human Health’. Whilst this comes as no surprise following the lead in time from the new Directive, it’s no longer theory but practice, and a new potential pitfall if not approached and assessed appropriately. Technical Director at RPS and Health Impact specialist Dr Andrew Buroni discusses how developers and scheme promoters should deal with this new challenge.
Human health is already a firmly established planning consideration. It features in the National Planning Policy Framework and the assessment principles for Nationally Significant Infrastructure Projects, and has recently become a statutory requirement for projects in Wales promoted by public bodies. For advocates of Health Impact Assessment (HIA), however, bringing it under the umbrella of the EIA Regulations raises the profile of health and well-being and is a step towards more health-conscious planning and decision making for EIA development. However, for applicants (and their advisors) a number of questions remain as to what this means in practice. These include:
Does the renaming of what was previously “Human Beings” to “Human Health” really imply a wider set of considerations to be assessed?
In the absence of any formal guidance, is the new topic heading more or less inclusive?
What definition of health is to be applied and does it include health risk prevention and aspirational policies for health and wellbeing?
What health parameters can actually be assessed quantitatively and appraised qualitatively through EIA?
Do these complement or conflict with the health pathways already covered within EIA, e.g. air quality, noise, transport, socio-economics and water?
What significance criteria can be applied, and how will these overlap or potentially conflict with the other technical assessments?
How will consultees and decision makers scope and review EIAs for human health and will it affect how applications are determined?
While guidance and practice on these questions is still evolving, the objective of the amendment is clear, namely to reinforce the consideration and communication of how communities and their health are influenced (both positively and negatively) from a proposed project to aid decision making, where relevant.
It places a public health lens on major projects from the outset, and in so doing reinforces the consideration of local community and health circumstance; local perceptions, priorities and needs; and ways in which a project can be tailored to support local health objectives (including the more intangible aspects important to good health and well-being).
We already have useful examples of how population and human health have been addressed alongside the EIA process for projects such as Hinkley Point C. This set the benchmark for Nationally Significant Infrastructure Project HIA, applying an innovative process and methodology, a comprehensive evidence base and an unprecedented level of integration within the planning, environment and engagement teams. It showed how effective HIA can be in addressing potential and perceived risks from major development projects.
In an EIA context, health impact assessment will need to show a high standard of evidence, with clear criteria and well-tested approaches to predicting impacts and effects. We will need to focus on likely significant effects and inform the public and decision makers on what’s important and how any significant effects will be mitigated and/or monitored. Scoping will be critically important together with engagement with the relevant public health bodies, particularly given the emergence of various Supplementary Planning Documents concerning public health. Fortunately we have some good examples now of what needs to be covered and how consultee and public concerns can be addressed.
RPS will be staying at the forefront of this work, building on 17 years of experience on projects such as Hinkley Point C, the M4 Corridor around Newport, and a wide range of development projects in the UK and internationally. I am confident that practical and effective approaches to Health Impact Assessment can be incorporated into EIA to the betterment of projects and communities alike.