Comment
NPPF2 brings health into sharper focus
What has changed?
Health considerations continue to be a binding thread throughout the NPPF. Section 8 of the NPPF specifically deals with ‘promoting healthy and safe communities’. However, health is not just confined to a single section of the framework; it is a common theme running through a number of topics, such as open space and sustainable transport.
The NPPF continues to promote an integrated approach towards planning. Retained paragraph 93 sets out the need to ensure that the location of housing, economic uses, community facilities and services are planned together. This is a key principle of well-planned and healthy places, with the interaction between uses a key consideration in assessing potential health impacts of development.
The NPPF had originally recognised the planning system’s role in delivering recreational space, healthy food environments, education facilities and reducing crime. NPPF2 retains these and adds to the list of considerations for plan making and development management. For example, regard should now be paid to the economic and social benefits of estate regeneration (para 93), promoting public safety (para 95) and balancing density with “well-designed, attractive and healthy places” (para 122). The changes to the framework strengthen and accentuate the importance of planning for healthy places.
Diagnosis: What is likely to change in practice?
The NPPF helped to establish a definition of what constitutes ‘healthy planning’ when it was published in 2012. The revisions to the framework sharpen the focus on health considerations. As a result local authorities may now look to achieve the same focus on health in their own Local Plan policies and decisions.
While some existing Local Plan policies will already play this role (for example green space standards), local authorities may choose to devise or strengthen policies as Local Plan reviews occur. For areas with specific health related issues (for example those where air quality is a particular concern) we may see the emergence of area specific or supplementary guidance.
The onus may increasingly be on applicants to demonstrate the health impacts of proposed developments. This is reflected in our experience, with more local planning authorities requesting Health Impact Assessments to aid in their decision making.
Remedy: How to respond successfully
The requirement to assess the health impacts of a development is an opportunity for developers. It is an opportunity to engage with the public health team and Clinical Commissioning Group in a positive and proactive way, and to flag up any potential issues or sensitive human health receptors. Knowing up front about potential health issues ensures “no surprises” in pre application or determination of planning applications.
Undertaken sufficiently early, a Health Impact Assessment (HIA) can influence the design process in a positive way. It can lead to health considerations becoming an informing factor in design and development layout choices. It can also help to inform the mix of development and need to provide or contribute towards social infrastructure such as health care facilities.
It is positive that the revised framework retains and sharpens the focus on health. In order to respond proactively, it is important to engage early with health issues and to design developments with the health of people and end users in mind.
For further information about any issues raised in this article please contact Richard Laming or Amber Morley.
3 August 2018