Democracy in Name or Process?
This Learning and Reflection piece on the CHIA process discusses the role of governance and democracy. It contextualises the WHOs agenda of "democracy" through a lens of governance and distributed power in reference to the people of Southall's experience.
picture of Joe Bhangu
CASH member Joe Banghu has frequently challenged members of Southall’s political institutions on their capacities to uphold and represent the voices of the people they represent. Many like Joe have grown to feel that those who propose, draft, write, and approve local government policy have too much power, can be easily swayed, and whose only oversight is an election cycle.
Once the ballot box is closed, so does accountability. This has very much been the case of a community advocating for the people who politically represent them to stand alongside and fight for them. It became apparent to us during a call with Ealing Council’s leader, Peter Mason, on this project that despite being acutely aware of the problems the community was facing, planning and property law meant that it is very hard and legally (and politically) risky stop the development taking place unless it was demonstrably in real time breaking the laws under which its consents were granted - Britain is arguably built on the epistemological basis of property ownership is everything.
When reviewing the initial 2008 planning documents for the Southall Waterside development it was clear that all parties were aware of the problems of contaminated land. Even to the extent of drafting the following language in West Southall Environmental Statement, Volume 1, Part D:
“Excavation activities during construction or once the Site is occupied may disturb contaminants currently immobilised within the soil profile to create new, or extend existing, pathways. This would introduce additional contaminant sources with new or faster pathways to identified receptors. Potential health effects could occur including ingestion of toxic heavy metals and skin irritation caused by contact with hydrocarbons. These human health pathways and effects are most likely to concern on-site workers, with limited exposure to off-site receptors...
“…Remediation works will need to be managed in accordance with best practice and controls [sic] measures used during these works so as to reduce the likely significant effects as identified above. If no measures are introduced, the existence of contaminated land at the Site is identified as potentially causing moderate adverse effects to local receptors (local controlled waters, construction workers and local residential areas)” .
Frequently during construction members of CASH were aghast to see the tarpaulins of soil hospitals flying around in the wind. This was not a case of illegal activity but of poor compliance and oversight - who is there to hold people accountable to the nuances of planning applications and conditions of approval? Reporting mechanisms between citizen-to-authority-to-accused are laborious and often a battle. Anyone who has tried to report neighbourly issues to authorities have often given up or found themselves acting as pseudo-detectives building a case against another person, not something we should need to do to uphold a sense of dignified living.
Therefore, when we think about the term ‘democracy’ in light of the WHOs guidance we chose to expand what this could mean from a systems perspective. For us, democracy in this case was seen more in terms of governance. What systems are in place to ensure that a community-led voice has the ability to feedback on the successes of compliance? This meant that for us that the ecosystem in which the HIA is performed is as crucial as the assessment itself. We chose to rewrite the rules and ignore current political hierarchies and imagine what would make a successful HIA in a community's eye.
There were some key issues to resolve: who owns the data; who owns the process; who oversees the process; who validates the outcome? For us this meant redesigning the system:
The community owns the HIA and is requested by the applicant.
A member of the community is nominated to oversee the process.
Results are fed back to the community in a discursive format in order to co-design solutions.
A member of the community is nominated to oversee the compliance of the HIA related planning conditions.
The completed HIA is returned to the community and made available to all other community organisations across the UK.
This challenges the status quo in how an HIA is performed, often done by individuals with no relationship to the local community or area and at times without technical or professional insight/qualifications on health, and the results are rarely shared with members of the public and stored within inaccessible (to the lay-person) planning websites.
Again, it is not the form that is wrong but the method/function, the cart leading the horse. Upholding democracy is predicated on robust governance systems and transparency.
Top-Down vs Bottom-Up Indicators on What Makes a Healthy Place
This Learning and Reflection piece looks at what happens when a bottom-up approach is taken to asking the question of what makes a healthy place?
In the paper The Messy Challenge of Environmental Justice in the UK: Evolution, Status and Prospects (2019) Gordon Mitchell discusses the differences of environmental justice perspectives, approaches, and practices between the USA and UK/Europe. They argue that in the USA environmental justice has primarily been led and culturally shaped by grassroots community groups. This has resulted in the narratives of environmental justice being a socio-political issue given the acute geographic localisation of injustices. Whereas in Europe the narrative has been shaped by NGO action from the 1970s on the problems of carbon emissions being the problem of climate change, framing it more closely to a broader socio-economic issue. A bottom-up versus top-down approach.
So what about Health?
The Health and Care Act (2022), and its predecessor the Health and Social Care Act (2012), do not provide an active working definition of health. It is often assumed in these cases that any understanding of health is through the WHOs definition: Health is a state of complete physical, mental, and social well-being and not merely the absence of disease or infirmity. The Ministry for Housing, Communities, and Local Government also does not offer a working definition of health in its overarching guidance document the National Planning Policy Framework (NPPF).
A lack of working definitions leads to interpretations, and as people such as Alastair Parvin write, British planning law is a culture of interpretations rather than rules, showing this is by design. Based on people's own attitudes, learnings, and epistemological framings they can make interpretations in many different ways.
This means that Local Plan policies can be designed using “legitimate evidence” and be problematic as depending on the subjective framing of authors and publishers the work can be biassed, misinformed, ignorant, or at worse, malicious. Therefore, well-meaning references to health around initiatives of access to natural space, good housing, local services, etc. the policy interpretation can exacerbate existing inequities when they fail to address the social, cultural, and political/governance issues that underpin them.
What did our research show?
In the case of our HIA we noticed that when reviewing the document September 2023 Rapid Health Impact Assessment for The Green Quarter by planning consultancy Lichfields, which used the GLA advised HUDU template, that a generalised access to food spaces would be seen as a positive health indicator. However, what makes food a healthy benefit for local people can mean many different things. For example, the Green Quarter HIA refers to the diverse demographics of Southall but the guidance for determining the health impacts of food spaces through new real estate don’t reflect this. Meaning that the provision of another large scale supermarket may tick a box and present a positive benefit to the needs of the community on paper but not meet the nutritional needs of all cultures, resulting in the need to travel further to access goods or go without, unhealthy in many ways.
When comparing the indicators from the HUDU template to ours we saw many comparisons. However the metrics were different. Our more bottom-up approach also brought in a wider range of issues that demonstrated what helps sustain a healthy place from a community point of view. For example, in our HIA we created an indicator asking for the assessing in the numbers of school aged children in and around a construction site. This was done under experiencing the impact of construction noise at critical times family-oriented times, such as when children are at home trying to do homework or for dinner time. Disturbances to this can cause multiple systemic issues to family life and increase stress on everyone involved. The indicator asked to a use of ONS or local authority data to understand the potential scale of impact, and therefore augment actions to reduce impacts. The solutions on which could be a range of things depending on the situation, for example, this could mean traffic management at specific times; noisy construction avoided between hours such as 3-6pm; a special after-school homework place for children and families otherwise impacted by the noise.
Another indicator/metric difference was on social infrastructure. The mere mention of providing social infrastructure in a planning document receives a positive mark however that can mean many different things. In the case of our HIA we talked about this meaning more secular social spaces, and a focus on childcare provision given the challenges many families and communities are facing over costs and lack of services. Inadequate provisions for childcare can reduce people’s capacity for employment in full- or part-time work or even shift-work, meaning the aforementioned positive benefit of employment as a health indicator being meaningless to some. Inadequate provisions for childcare can also mean children spend less time with their families or are forced to live irregular patterns, which goes against the majority of research and guidance that children need stability and routine in early years to develop good mental health. Disturbances and insecurity at young ages can lead to developing emotional, and thus behavioural, problems impacting school and social lives. The rest speaks for itself.
Conclusion
Whilst we mostly may be on the same page around issues, the approaches, framings, and details are different. This is what gets lost on a technocratic approach that becomes revealed when doing things bottom-up. The main issues remain however the methods evolve.
Systemic Thinking
This Learning and Reflection piece looks at how systems thinking in context to the Determinants of Health can expand indicators and metrics on health so that they become more justice and lived experience led.
The planning documentation seeking consent to redevelop the Gasworks in 2008 appears to have been influenced by the 2003 UK Government paper ‘Tackling health inequalities - a programme for action’. Whilst the 2003 report uses meritable actions for reducing health inequalities they fail to address the systemic conditions in which the recommendations sit as well as their abilities to unintentionally exacerbate determinants of health if not they’re not addressed at source.
Increasing opportunities for employment has typically been seen as pathways to reducing health inequalities as it relates to the ability to purchase good quality foods, access to services, and the chances to access a quality of home that would infer better health opportunities. However, as many have pointed out, if the economic system in which the employment opportunities sit are from extractive methods this can have an impact on a range of systemic factors that influence long term health.
If labour rights are diminished in the name of powering the economy this can result in unfair working conditions such as zero-hour contracts, shift-work, and a hostile and fragile employment status, all of which impact health in a number of ways.
Additionally within the extractive economics framing is the capacity for business and economic practices to impact wider determinants of health such as climate change and political instability. Another example of an extractive economic practice can be whether systems contribute to community wealth building or not. Katz et al from the Drexel University Lindy Institute for Urban Innovation have demonstrated at length in Towards a New System of Community Wealth how without addressing community wealth building from the ground up, a slow erosion of social infrastructure and capital takes place where local tax bases diminish whilst conditions for quality of life also decrease.
A row of closed shops in the UK
This is one example of good intentions not accurately reflecting the conditions in which they sit. Another example can be housing, and to keep it simple, whilst ‘Tackling health inequalities - a programme for action’ may state that “good” housing is a pathway to good health there are issues to navigate such as the number of volatile organic compounds found in modern building tools, the quality and quantity of tenure for those that rent is crucial, and whether the types of homes being made reflect the cultural realities of modern life - such as multi-generational households. Without these issues being addressed more accurately the promise of a direction of good health can in fact lead to a different set of health problems.
This brings to light the need for the inclusion of a Determinants of Health framework to guide the conditions under which indicators and metrics within an assessment sit. Sir Michael Marmot has worked to establish the Social Determinants of Health in modern British lexicon however it’s time we go one-step further and ensure that commercial and political determinants are also considered - side note: we take issue with the term “social” as this implies there is an inherent societal, or personal, attribute that causes factors such as unemployment (e.g. lazy) and treating them as issues at a local level, whereas we would refer to them as “socialised” determinants of health as they are the conditions set by political and commercial actions, such as the investment in employment opportunities and training by governmental and industry actors.
Lastly, it’s worth bringing to light the timescales involved in such projects. A document from 2008 refers to another document in 2003 (itself most likely produced over 2001-02) and influenced an activity taking place in 2018. It can be argued that in 2003 (white) society was less aware of social determinants of health and systems thinking theory and practice and therefore it wasn’t debated as extensively. However, by the mid-2010s the breadth of knowledge and insight produced in these fields is undeniable. By these points in time, and certainly in response to the 2008-era Global Financial Crisis, the social awareness and practice of systems design were mainstream. Meaning that we have a time-based problem.
Conclusion
We ask a simple question that surely planning processes should have mechanisms in place to be reflected in a more real time, socially relevant manner? Why couldn’t a process such as an HIA be completed with up-to-date theory and practice be submitted within 12 months of an application?