The Malta Association of Public Health Medicine (MAPHM) welcomes the Planning Authority’s (PA) proposal to ensure that a standard procedure for Social Impact Assessments (SIA) is introduced as part of the planning system. This is an important step forward that will help to mitigate the frequent negative impacts of large developments on the social fabric of the surrounding community, as well as on individuals. However, several issues in the proposal need to be addressed in order to ensure a truly comprehensive policy that is fit for purpose.
MAPHM is recommending the use of Health Impact Assessment (HIA) as another valuable tool, which should be included alongside social and other impact assessments. HIAs predict health implications of proposed projects, programs, plans, or policies, thereby informing decision-makers on the positive and negative impacts of proposals and providing the possibility of managing these impacts appropriately, keeping the health and well-being of the public in mind. HIA focuses on what is most important for human health by using a wide definition of health as proposed by the World Health Organization, to include ‘physical, mental and social well-being and not merely the absence of disease or infirmity’, and is underpinned by values such as recognition of human rights, democracy, equity, sustainable development, and ethical use of evidence.[i]
Whilst integrating assessments of impacts on human health within EIAs and SIAs are advantageous as they are often mandatory and favour sustainability, independent HIAs have more impact.[ii]
Below we highlight the main reasons why we believe HIAs should be performed.
- The proposal states that SIAs will only be obligatory if the tall buildings policy (11 storeys) applies to the proposed project. Large residential and commercial projects which do not fall within the parameters of the tall building policy, high-rise developments, and development clusters will not be obliged to carry out such assessments. Furthermore, commissioning of SIAs will remain discretionary i.e. on a case-by-case basis following Strategic Environment Assessment (SEA) screening within the Planning Authority. The scope for conducting SIAs should be much wider than the proposal suggests. We believe that the proposed limited application of SIAs is a serious shortcoming that can easily be addressed by having a (publicly available) standardised screening tool that can be applied to screen projects, policies and programmes regarding the need for an SIA.
- The MAPHM fully agrees with the obligation of the planning authority to publish for public consultation any SIA reports prepared as part of the plan and policymaking process and development proposals. It is however not clear how interested parties and communities are informed of the arguments used by the Planning Authority to waive the need for a SIA and the procedures to contest such a decision. Robust criteria and full transparency need to be in place.
- Whilst SIAs do consider the impact of planning on human health to some extent, unfortunately health is not the primary focus,[iii] and SIAs use narrow definitions of health, focusing on the impact of a few physical risk factors. To date in Malta, the few formally commissioned HIAs occurred as part of an Environmental Impact Assessments.
- We are therefore highly recommending the MAPHM would like to take this opportunity to emphasise that the environment a person lives in affects their health and quality of life. Our physical, mental and social well-being is dependent on our surroundings. This includes the air we breathe, where we live, work and play, and the way our towns and roads are planned and built.[iv]
Given this situation, the MAPHM further recommends that:
- HIAs are introduced as a legal requirement for any development that may potentially impact human health (i.e. large scale developments; residential and commercial establishments, policies, plans and any project that may impact on the natural environment and/or human health; infrastructural projects such as roads etc)
- A task force within the PA is set up to develop guidelines and standards for HIAs. The MAPHM is willing to offer its expertise in this regard
Association of Public Health Medicine (MAPHM) was founded in 1999 with its main
objectives being to promote high standards in teaching and practice of public
health medicine as well as to advocate for and contribute to the advancement of
public health in Malta. It is a voluntary, independent and non-profit making
organization composed of public health doctors and other public health specialists.
[i] Martuzzi M, Cave B, Nowacki J, Viliani F, Vohra S. Health Impact Assessment [Internet]. Iaia.org. 2014 [cited 26 June 2019]. Available from: https://www.iaia.org/uploads/pdf/Fastips_8Health.pdf
[ii] Gonzales et al. 2011. HIA Implementation: Different models, different results? A review of HIA implementation worldwide [online]. Available at: http://si.easp.es/eis2011/wp-content/uploads/2011/04/HIA-models_granada_14abril2011.pdf
[iii] Vanclay, F., Esteves, A., Aucamp, I. and Franks, D. (2015). Social Impact Assessment: Guidance for assessing and managing the social impacts of projects. [online] International Association for Impact Assessments. Available at: https://www.socialimpactassessment.com/documents/IAIA%202015%20Social%20Impact%20Assessment%20guidance%20document.pdf.