Detailed critique by Hillingdon Council of the Airports Commission’s failure to cover health issues adequately

In its response to the Airports Commission consultation, Hillingdon Borough Council has been highly critical of the Commission’s failure to deal properly with health impacts of a new runway. They say a specific Health Impact Assessment (HIA) would have been the best way of addressing weaknesses on health matters. There is no proper baseline for the health and wellbeing status of local communities. They say it is inequitable that existing airport-related impacts are not considered as a key part of the overall assessment of the three schemes. “There seems to be an implicit weighting for economic development and against health evidence.” Hillingdon say “it is unclear how local stakeholder feedback would be incorporated” on health issues. And “The Department of Health and Public Health England do not seem to have been consulted” during the Commission’s work. “Aggregating positive and negative impacts is flawed and inequitable. The negative impact of noise cannot be ‘bundled’ together with the positive impact of employment, because most often the negative and positive impacts are experienced by different groups of people.” “Impacts on children are not considered as part of this assessment either qualitatively or quantitatively. This is a significant omission.”  And so on.  A long catalogue of failures and omissions. 


Airports Commission’s Assessments

November 2014 Consultation

Equity Focused Review Report of the Airports Commission’s Community Health Relevant Assessments

FINAL REPORT January 2015
Commissioned by the London Borough of Hillingdon


This is a long document (52 pages) but copied below are a few sections:

Executive Summary


ES.1 This Review Report has been commissioned by the London Borough of Hillingdon (LBH).

ES.2 The aim of the Review was to review the Airports Commission’s Appraisal Framework, published in April 2014, and the completed community health-relevant Assessments, published in November 2014, from a health equity perspective i.e. using a “health equity lens”.

Appraisal framework

ES.3 A specific Health Impact Assessment (HIA) within the Appraisal Framework would be (would have been) the best way of addressing the following weaknesses of the Framework.

ES.4 Firstly that the existing baseline health and wellbeing status of local communities and existing airport-related impacts are not considered as a key part of the overall assessment of the three schemes. This is inequitable because the existing burden of adverse health impacts of the existing airports and their activities is very different between Gatwick and Heathrow, i.e. many more residents around Heathrow currently experience the adverse health and wellbeing impacts of airport operations. It is also less likely to give a complete picture of the health and wellbeing impacts (the Quality of Life, Community, Air Quality and Noise assessment modules of the Airports Commission’s Appraisal Framework).

ES.5 Secondly, there seems to be an implicit weighting for economic development and against health evidence by the ranking and range of wellbeing indicators being used in the Quality of Life Assessment.

ES.6 Thirdly, it is unclear how local stakeholder feedback would be incorporated into the Assessments described in the Framework. Stakeholder feedback is important in helping to assess and provide additional evidence on the likely type and scale of impacts. (triangulation)

ES.7 Fourthly, the Department of Health and Public Health England do not seem to have been consulted during the development of the Framework.

Quality of life assessment

ES.8 Aggregating positive and negative impacts is flawed and inequitable. The negative impact of noise cannot be ‘bundled’ together with the positive impact of employment, because most often the negative and positive impacts are experienced by different groups of people.

ES.9 There is no in-depth discussion of inequality, fairness or equity in the Quality of Life Assessment. This is a significant omission.

ES.10 Impacts on children are not considered as part of this assessment either qualitatively or quantitatively. This is a significant omission.

ES.11 The Quality of Life Assessment makes use of data obtained from a smartphone software application (Mappiness) to estimate wellbeing effects of proximity to airports. This data is unlikely to be representative of the population living in proximity to the schemes considered.

ES.12 The Quality of Life Assessment assumes an equivalence between subjective or personal wellbeing and broader concepts and measures such as the ONS national wellbeing (quality of life) scale i.e. that subjective or personal wellbeing can capture all the dimensions of quality of life and wider wellbeing. This is problematic as it can miss out important aspects of quality of life and health and wellbeing. For example, a person with a chronic health condition may have wellbeing levels similar to a person with no chronic health conditions. Using only a wellbeing measure would not necessarily be sensitive enough to pick up the fact that the person with the chronic health condition, alongside high levels of wellbeing, also has limitations to their dayto-day activities and are not able to do all the things that they may wish to do. Most measures of wellbeing or quality of life are multi-dimensional so that they can pick up such nuances and subtleties, this is not the case in the Commission’s approach. There is an over-emphasis on quantitative indicators of quality of life, placing less value on a qualitative assessment approach. This has the danger both of discounting good quality qualitative assessments and setting a precedent for future airport assessments that only quantitative impact assessment methods have value. This is contrary to international good practice.

Community assessment

ES.13 A fuller discussion of the implications of the loss of housing and community facilities and associated social capital and community cohesion effects on existing communities and new communities should be undertaken.

ES.14 The Index of Multiple Deprivation and national wellbeing datasets are not explicitly mentioned and do not seem to have been used to inform the Community Assessment contrary to what the appraisal framework states.

Place assessment

ES.15 A fuller assessment of the public and community health impacts of the loss of agricultural land; green, open and play space; and heritage should be undertaken. The permanent loss of good quality agricultural land has implications for food security and sustainability and the loss of the overall amount of greenspace also has potential adverse inter-generational and adverse health and wellbeing impacts.

ES.16 The only community health and wellbeing related analysis and discussion is on the potential loss of health centres and in relation to the health hazards associated with the management of waste.

ES.17The waste assessment identifies potential additional noise, air quality impacts and traffic impacts from the construction and operation of airport waste collection and treatment facilities. It is currently unclear whether these potential impacts have been considered in the Noise and Air Quality Assessments.

Local economy impact assessment

ES.18 More detailed information on the likely mix of part-time and full-time, low vs. high skill and low vs. high paid jobs generated by the three schemes is needed to assess the quality of the employment likely to be generated, and the likely uptake of jobs by young, unemployed and deprived residents living around the schemes should be provided.

ES.19 The potential localised road impacts should be assessed quantitatively and qualitatively as these could be potential economic costs e.g. the potential for an increase in road traffic incidents, accidents and congestion on roads that are likely to get busier. Noise assessment

ES.20 Effects on children are not considered specifically and the distribution of impacts on other sensitive/vulnerable groups have been assessed only to the extent of considering three types of sensitive buildings: schools, hospitals and places of worship and their exposure to noise

ES.21 A mapping of the Index of Multiple Deprivation (i.e. overall and health deprivation and disability domains) to population density, noise contours and flight paths should be undertaken to get a better sense of how existing deprived communities are likely to be affected by the changes in noise levels, both increases and decreases.

ES.22  A more detailed description of the monetisation methodology including a worked example would be useful for assessing the validity of the methodology used as well as its applicability in future airport assessments.

Air quality assessment

ES.23  The Airports Commission’s Air Quality Assessment report is the first of a two-stage assessment. This stage only assesses national air quality impacts in detail. Local impacts on air quality and associated effects are not yet available. The Commission has stated this will be captured as part of a future detailed assessment. This is a significant omission in regard to this consultation.

ES.24 An impact pathway assessment approach as part of the second stage assessment should be used as this approach can provide a more comprehensive quantification of health endpoints.

Water and flood risk assessment

ES.25 An estimate of the number and characteristics of people currently residing in areas of flood risk is not provided, nor how these numbers may change in the future as a result of the different schemes. This estimate would provide a good indication of the magnitude of potential human health effects due to flooding for the different schemes.


ES.26 Overall, the Airports Commission’s Assessments would have benefited from a further detailed assessment of health and health equity impacts of each potential new scheme through a separate Health Impact Assessment (HIA) that sits alongside and synthesises the findings of the suite of health-relevant assessments (including the Quality of Life Assessment) undertaken by the Airports Commission.

ES.27 The recommendations identified in this Review Report, if undertaken, are likely to improve the quality of the analysis, in regard to the health and wellbeing impacts, of the existing suite of Assessments undertaken by the Airports Commission.



The full report is at

Equity Focused Review Report of the Airports Commission’s Community Health Relevant Assessments


11.  Conclusion

11.1.1  This conclusion considers the ten equity-focused criteria used to review the Airports
Commission’s Appraisal Framework in the light of the completed community health
relevant Assessments.

11.1.2  Overall, the Airports Commission’s Assessments would have benfited from a further
detailed assessment of health and health equity impacts of each potential new scheme
through a separate Health Impacts Appraisal Module and subsequent Assessment that
sits alongside and synthesises the findings of the suite of health-relevant assessments
undertaken by the Airports Commission.

11.1.3 The recommendations identified in this Review Report if undertaken are likely to improve the quality of the analysis of the existing suite of Assessments undertaken by the Airports Commission.

11.1.4 The Appraisal Framework and the methodologies used within the completed
Assessments reviewed in this report would have benefited from the advice and expertise
of Department of Health and Public Health England.

11.1.5 Though key environmental and social determinants of health have been considered, the approach to assessing quality of life is narrow and weak and has not fully synthesised the implications of the other community health-relevant assessments. The inter-related, interconnected nature of the health and wellbeing impacts identified in the suite of
Assessments has not therefore been fully considered and therefore the Assessments do
not consider the in-combination effects from, for example, changes to air pollution,
noise, water and flood risk, community, place and local economy.

11.1.6 A key health relevant scenario that was not considered in the Appraisal Framework and Assessments was the further lowering of current thresholds for air quality and noise

11.1.7 A key weakness of the Appraisal Framework and the Assessments was that they did not consider or take account of the existing health burdens on communities from the existing airport operations. There was also no development of a detailed community health and wellbeing baseline based on available public health data to support the analysis of
potential health and wellbeing impacts.

11.1.8 Distributional impacts and health equity/inequality issues are poorly considered in the Assessments. While part of this is related to lack of data there are existing routine
statistics/datasets that could have been used to provide useful information on likely
distributional and health equity impacts e.g. taking account of existing health burdens
and mapping indices of deprivation. For example, the Appraisal Framework states that
the Community Assessment will use the Index of Deprivation and national wellbeing
datasets however these information sources have not been used to inform the
Community Assessment.

11.1.9 Scientific, policy and practice evidence has informed the Assessments. However,
scientific evidence on the social determinants of health has not been considered in any
systematic way.

11.1.10 Information on how local stakeholders have informed the findings of the Assessments is lacking.

11.1.11 There is a strong explicit and implicit weighting of quantitative assessment findings and little detailed qualitative discussion of the full range of environmental and social
determinant of health and wellbeing.

11.1.12 Uncertainties and assumptions in relation to health and wellbeing impacts are only
partially considered, taken into account or made explicit.

11.1.13 Physical health, mental health and wellbeing impacts are not given an appropriate
weighting across the suite of health-relevant assessments.




The full report is at

Equity Focused Review Report of the Airports Commission’s Community Health Relevant Assessments



Hillingdon Borough Council has also sent this response to the Commission:




AirportWatch note below (not Hillingdon):

What the Airports Commission says on Health Impact Assessment

The words “health impacts” do get a couple of minor mentions by the Airports Commission in this document 
Discussion Paper 05: Aviation Noise   July 2013.
All they say (Page 37):
Monetising health impacts
4.32   As discussed in Chapter 2, several pieces of research have found links between noise exposure and health effects. These health effects are typically
accounted for in appraisal by estimating the size of the population exposed, and then linking this to scientific research on the level of noise and the risk of
cardiovascular disease associated with it.
4.33   However, more recent research by Berry and Flindell (2009)70 and Health and Safety Laboratory (HSL) (2011)71, is being reflected by the IGCB in its
forthcoming guidance. For instance, HSL (2011) considers a wide range of heath effects from noise-related hypertension, including acute myocardial
infarction, strokes and dementia. The approach proposed by the IGCB  [the  Government’s Interdepartmental Group on Costs and Benefits (IGCB), a Defra-led group of government analysts ]    uses dose-response functions to estimate the prevalence of these health impacts in the population, which is then monetised in relation to the value of Quality Adjusted Life Years (QALY).72   Once the additional number of noise related disease cases is calculated, a monetary value can be estimated.
4.34 Based on this approach the HSL (2011) estimate the noise impacts from road traffic and rail could equate to around £1bn and £43m of health effects per
annum, respectively.73 Aircraft noise impacts were not estimated in this report. For further information on the health monetisation methodology please
see the WHO report and HSL (2011).
Berry and Flindell (2009), ‘Estimating dose-response
relationships between noise exposure and human health
impacts in the UK’.
Commissioned by Defra and is available at: http://randd.
72 ‘QALYS are calculated by estimating the years of life
remaining for a patient following a particular treatment or
intervention and weighting each year with a quality of life
score (on a scale of zero to one, where zero is equivalent
to death and one is equivalent to full health). It is often
measured in terms of the person’s ability to perform the
activities of daily life, free from pain and mental disturbance’
(National Institute for Health and Care Excellence definition).
The Department for Health guidance suggests a central
value for a QALY of £60,000. For more detailed information
on the approach please see HSL (2011).
73 Note these cover 23 agglomerations in the UK,
accounting for roughly 40% of the population.
In the Airports Commission’s “Appraisal Framework”   April 2014 at
there is not one mention of the term “Health Impact Assessment” but it does talk in general terms of health impacts (about 10 mentions)  from air pollution and from noise, and it considers how these can be monetised, as part of a sustainability assessment.  [The Commission only really seem interested in health in terms of its cost.]
 In the Airports Commission’s “Interim Report”  December 2013 at
   (Page 66)
there is no mention of health, other than a few short mentions of the fact that there are effects from noise.  One says:  “A number of respondents testified that living under a flight path can cause annoyance, adverse health and, at times, deep unhappiness.” [sic]
The Airports Commission’s “Community: Impact Assessment”  Jan 2014 document 
HAL’s equalities screening
4.20 HAL has not carried out an explicit equalities screening exercise, although it is
experienced in such matters, having produced a joint Health Impact Assessment
and Equalities Impact Assessment as part of their recent planning application to
remove the Cranford agreement. That exercise concluded that a full equalities
assessment was necessary, based on answers to five health-related questions, with
regard to the designated protected characteristics. It was identified that the key
issues for that exercise were likely to be the effects on the population associated
with noise and air quality.
4.21 An equalities screening for this exercise might also consider other impacts on
protected groups from construction and operation – such as land acquisition and
demolition of property (residential and community), land clearance and construction
activity, noise impacts from surface transport, and income and employment
(displaced and created). The exercise would need to gather data on protected
groups, some of which are not currently available.
(But nothing specifically on health).


More on Health Impact Assessments

On this website, the  NHS Healthy Urban Development Unit


Health Impact Assessment

The recently published online National Planning Practice Guidance refers to health impact assessment (HIA) as a useful tool to assess and address the impacts of plans and development proposals. The London Plan and many borough Local Plans also refer to the use of HIA.

“The impacts of major development proposals on the health and wellbeing of communities should be considered through the use of Health Impact Assessments (HIA).” 
(Policy 3.2C London Plan, July 2011)

A health impact assessment (HIA) helps ensure that health and wellbeing are being properly considered in planning policies and proposals. HIAs can be done at any stage in the development process, but are best done at the earliest stage possible. [AirportWatch highlighting.]  HIAs can be done as stand-alone assessments or as part of a wider Sustainability Appraisal, Environmental Impact Assessment, or Integrated Impact Assessment.

HUDU is able to provide bespoke advice and support on assessing the health and wellbeing impacts of development, and has undertaken a number of HIAs on behalf of primary care organisations.

The process looks at the positive and negative impacts of a development as well as assessing the indirect implications for the wider community. The aim is to identify the main impacts and prompt discussion about the best ways of dealing with them to maximise the benefits and avoid any potential adverse impacts.

HIAs are commonly categorised as ‘full’, ‘rapid’ or ‘desktop’. A full HIA involves in depth evidence-based analysis of all potential health and wellbeing impacts on different population groups, using research and community engagement.

HUDU Rapid Health Impact Assessment (HIA) Tool
HUDU has developed a rapid HIA tool which is less resource intensive using existing evidence to quickly assess the impacts of a development plan or proposal and recommend measures to address negative impacts and maximise benefits.

The tool does not identify all issues related to health and wellbeing, but focuses on the built environment and issues directly or indirectly influenced by planning decisions. Health impacts may be short-term or temporary, related to construction or longer-term, related to the operation and maintenance of a development. The tool has been used on strategic planning applications in London’s ‘Opportunity Areas’ and on infrastructure projects, such the Northern Line Extension.

The rapid HIA tool can be downloaded here and a fillable form version can be downloaded here.

Healthy Urban Planning Checklist
HUDU, along with the six east London Growth Boroughs and Groundwork London has also published a healthy urban planning checklist which is a desktop assessment aiming to ‘mainstream’ health into the planning process. The checklist poses a series of questions based on London Plan policy requirements and standards which if met can positively influence health and wellbeing.

It is intended that the checklist should be applied to major, but not strategic development proposals and could use to help prepare a Local Plan or neighbourhood plan or to screen possible health impacts for a rapid or full HIA. Whilst developed for the east London Growth Boroughs, other London boroughs are encouraged to use the checklist and customise it for local use.

The Healthy Urban Planning Checklist can be downloaded here.

In addition, Public Health England’s ‘HIA Gateway’ includes a wide range of HIA examples and resources

It also says:

For large scale development proposals a Health Impact  Assessment (HIA) may be required, with a full assessment providing information on health needs and priorities, including

community engagement, and setting out a detailed assessment of health impacts and proposed mitigation and enhancement measures. For large scale development proposals such as strategic planning applications referred to the Mayor of London, it is recommended that other assessment tools, such as the HUDU Rapid HIA Tool is used.


There is lots more.  ………… It is largely aimed at smaller developments, but it realises there are huge developments too, and these should be covered.

Their contact details are:

Address is:
NHS London Healthy Urban Development Unit (HUDU)
1 Lower Marsh


Vernon Herbert  (Director) and Malcolm Souch (Project Director).




There is more from a Hillingdon Borough Council document in May 2013

“Health and Equalities Impact Assessment. Enabling works to allow implementation of full runway alternation during easterly operations at Heathrow Airport”



There was this interchange in Parliament

Hansard source (Citation: HC Deb, 2 April 2008, c1015W)


Nick Hurd (Whip, Whips; Ruislip – Northwood, Conservative)

To ask the Secretary of State for Transport what plans she has to make a health impact assessment of the proposed expansion of Heathrow Airport.

Jim Fitzpatrick (Parliamentary Under-Secretary, Department for Transport; Poplar and Canning Town, Labour)

While our principal focus has been on meeting the key noise and local air quality limits, we plan to update the initial impact assessment incorporated in our recent Heathrow consultation in the light of responses and relevant evidence received. We have made it clear that any proposals for future development would need to be the subject of a full health impact assessment by the airport operator at the planning stage.