By Laurence Carmichael…..
Tower Hamlets (TH) Health Impact Assessment (HIA) policy was adopted as part of the London Borough of Tower Hamlets (LBTH) Local Plan in January 2020.
The policy aimed to be part of a set of local planning policies addressing major health challenges in the borough, including poor housing quality, overcrowding, social isolation, poor air quality, lack of access to affordable healthy food, and lack of green spaces.
In September 2019, I was recruited as HIA Officer on a secondment from UWE Bristol’s WHO Collaborating Centre to lead on the policy implementation programme. The focus of this shifted quickly from its original quality assurance ambition towards a broader political-economic approach to maximise HIA policy leverage. Outputs of the programme included:
- An internal cross sector planning/public health partnership to maximise the legal levers of the policy
- A suite of capacity building and review tools including:
- Guidance tools for officers and applicants
- Training for internal and external stakeholders
- Evaluation work (NIHR funded)
- National HIA policy advocacy and development:
- Contribution to Public Health England’s national HIA guidance
- Leading on submissions to the Ministry of Housing, Communities and Local Government consultations on the reform of the English planning system on behalf of London Association of Directors of Public Health
Over the two-year review period a number of significant challenges were identified, including:
- A lack of cross sector knowledge and silo working
The programme had to be adapted to reflect planning governance and policy drivers. These challenges reflect earlier findings from the literature.
- The lack of a HIA statutory policy
HIA was not a statutory instrument despite being embedded into the local plan. Planning power is also limited as the local HIA Policy does not benefit from a Supplementary Planning Document (SPD) which would give it more leverage. Planning officers will decide to give or refuse planning consent on the basis of interpretation and judgement in the light of the development plan and other material considerations. They weigh up HIA evidence potentially against other material considerations and other legal obligations and this can be at the expense of health (e.g. Heritage considerations, established land use)
- Housing policy drivers
The London Plan sets high housing targets for TH, leaving upper density levels open and giving developers the opportunity for more speculative planning applications. Government policy requires local planners de facto to lower scrutiny over some standards which have health implications and could be highlighted by HIAs (e.g. reducing affordable housing requirements)
- Poor understanding of HIA and emerging practical issues
Over a period of 22 months, the HIA Officer commented on 64 planning applications. HIAs were in the main very weak (poor methodologies, poor identification of baseline, no recommendations).
The practice of HIA in development management process also raised a number of practical issues in relation to various types of planning applications, for instance, can we expect a detailed HIA on a S73 amendment application? (i.e. minor amendment)
The in-depth understanding of these challenges acquired over the two-year period of the review facilitated the following recommendations:
HIA in development management:
- Focus HIAs on the largest applications
- Ensure a public health presence in pre-applications
- Review assessment criteria of the HIA guidance focussing on assessment topics where end user/community knowledge is most appropriate.
- Strengthen the Statement of Community Involvement guidance for applicants
- Continue capacity building efforts internally
- Design a quality assurance framework “for the reality of planning “
- Supply developers with a locality baseline
- Continue monitoring/evaluating HIA effectiveness through research
HIA in planning policy:
- Consider the upstreaming of HIA in planning policy and strategy
- Identify a timeline of strategic masterplans to ensure health is considered in strategic place-shaping decisions.
- Promote HIA approach for local design guides or codes
- Learn from HIAs over time to inform design policies in local plans
Local authorities interested in progressing their HIA agenda on urban developments are advised to learn from Tower Hamlets experience and be mindful of challenges. This should not deter them from ensuring new urban developments promote health and equity, in particular as the Covid-19 pandemics has further demonstrated the importance of the living environment on health.
For more information on the Tower Hamlets HIA policy, please contact Matthew Quin, Public Health Programme Lead – Healthy Environments Public Health, London Borough of Tower Hamlets email@example.com
For information on the two-year LBTH HIA review and NIHR funded evaluation,
Please contact Laurence Carmichael, Senior Lecturer in Healthy Cities, UWE, Bristol. firstname.lastname@example.org
 • Carmichael, L., Townshend, T., Fischer, T., Lock, K., Sweeting, D, Petrokofsky, C., Ogilvie, F and Sheppard, A. (2019). Urban planning as an enabler of urban health: challenges and good practice in England following the 2012 planning and public health reforms, in Land Use Policy, 84, p. 154-162, https://www.sciencedirect.com/science/article/pii/S0264837718307361 .