Improving the consideration of human health in environmental planning and decision-making – perspectives from Germany

Abstract

The effects of projects, plans or programmes on human health are currently often dealt with unsatisfactorily in terms of the indicators and methods used in current German environmental assessments – whether in environmental impact assessments (EIA) or in strategic environmental assessments (SEA). The absence of more stringent techniques for the identification, prognosis and evaluation of effects on human health (like health impact assessments, many approaches are difficult to understand, especially in light of international efforts to improve the implementation of health concerns in planning and decision-making processes. As a result of an interdisciplinary initiative, a working group, affiliated with the German EIA Association, published the ‘Guideline Human Health – supporting an efficient examination of health effects within planning decision-making processes’. In the current process of transposing the new demands of the revised EIA Directive into German EIA law, the Guideline can only be a first step towards supporting practitioners and administrative actors involved in environmental assessments, enhancing the perception of health effects and fostering their better incorporation within environmental assessments.

Keywords:

• Human health
• environmental assessment, methodology, actor constellation, planning procedures, Germany

1. Introduction and objectives

The protection of human health has been considered as an aspect of environmental impact assessment (EIA) in Germany since the EIA EU Directive was implemented in German law in 1990, although this was considerably later than in some countries where EIA was implemented in the 1970s and HIA in the 1980s. EIA requires the examination of the environmental impacts of a project. Although more than two decades of experience with environmental assessment¹ has now been gathered, there have only been rare cases of the precautionary protection of human health.² The reasons for this are manifold and can only be briefly outlined here rather than discussed in detail. On the one hand, this neglect is caused by the way that the factors requiring protection are examined in the EIA studies for potential impacts. The common anthropocentric view leads to an emphasis on the human health-related aspects of other elements that are to be protected (soil, water, air, climate, landscape, cultural assets and other property). The human health-related aspects are viewed as integral parts of these elements, preventing the separate identification and further consideration of impacts on humans or human health. Consequently, the assessment of the protection of human health is reduced to compliance with the relevant thresholds, for instance avoiding the loss of settlement or recreational areas or their exposure to noise or air pollution. On the other hand, there is a lack of involvement of institutions (such as health authorities) that can actually contribute to the comprehensive and qualified inclusion of health issues in the assessment framework of EIA studies and environmental reports. Moreover, beside the consideration of human health within environmental assessments, in Germany there is no obligation for HIA to be carried out nor is there a real HIA practice on a voluntary basis.

At the same time the burden of disease from environmental causes is dramatic, particularly in urban agglomerations. As an illustration of many urban environmental loads on human health in Germany, Figure 1 shows the number of premature deaths caused purely through particulate matter pollution. Although at first glance a downward trend is apparent, numbers have remained at a consistently high level since 2007 with a total of 41,100 premature deaths in 2014 (UBA 2016). In Europe (EU-28) in 2011, the number of premature deaths from lung cancer and related respiratory and cardiovascular diseases caused by particulate matter was estimated at around 430,000 (EEA 2015). These estimates are based on the WHO method to estimate the ‘environmental burden of disease’.

Figure 1. Premature deaths caused by particulate matter pollution in Germany. Source: UBA 2016, translation by authors.

Thus, there is a need to shift the focus to the consideration of the impact of environmental factors on human health. For example, this could involve the efficient integration of health issues in the procedures and instruments of environmental assessment. This is the starting point of this Guideline.³ The Guideline can be understood as contributing towards the formation of generally agreed upon good practice in the development of health protection in planning and development control processes.⁴ The Guideline should support actors – ranging from the project proponents and the relevant authorities to the stakeholders and all those affected by planning and development control processes – and also the process of integrated environmental assessment. It provides for an effective and precaution-oriented introduction of health-related issues into such processes and procedures. Against this background, the Guideline aims to achieve ‘good practice’ in consideration of health issues in environmental assessment. This shall be carried out in two steps. In the first step a general framework of health impact assessment (HIA) following the form of the Guideline is to be created; the first step is already completed, although the Guideline will be revised and amended as appropriate. In the second step, level-specific guidelines and workflows should be developed for integration into the sequence of planning and decision-making processes.

A central objective of the Guideline is to put into practice ‘effective precautionary environmental protection’ with regard to the consideration and assessment of environmental impacts embedded in the German EIA legislation. Consideration of cause–effect processes between environmental conditions and health – including individual health determinants – leads to the question of the vulnerability of the individual or of population groups who may potentially react more sensitively than others to environmental stress factors on their health. It is therefore important to present not just the legal limits but also an overview of the precautionary thresholds.

Section 2 of this article presents an overview of the structure and main components of the Guideline. Aspects of the assessment and suitable criteria are presented in Section 3. The scope for use in strategic planning is discussed in Section 4, and finally a summarising outlook is formulated in Section 5.

2. Structure and main components of the Guideline

2.1. Introduction, explanation of terminology and the relevant legislation

The Guideline’s introductory chapters deal with two central definitions: health and disease. Closely related to this is health equality which is also dealt with in the introduction, but cannot be considered in depth here. Health is broadly defined and based on the WHO definition from 1948 where health is ‘a state of complete physical, mental, and social well-being and not merely the absence of disease or infirmity’. The WHO model is applied in the Guideline in such a way that the focus is on the environmental embeddedness of human health. In newer definitions health is understood as an equilibrium state between humans and the physical, biological and social environment as part of a dynamic continually changing process (Fehr, Claßen 2014). As well as the natural environment, the social environment is another important factor from the range of health determinants that has to be considered. The core fifth section of the Guideline addresses health determinants, focusing on social environment, natural environment, and chemical, physical and biological determinants of health.

As well as looking at the explanatory models of disease origin and the definition of so-called adverse effects as an expression of health impairment such as dysfunction or clinical disease, it is also necessary to look at the notion of salutogenesis (Antonovsky 1997). In contrast to pathogenesis, the salutogenic approach focuses on the causes and factors necessary for the creation and maintenance of health. This concept provides the basis for health promotional activities and measures that can contribute to an improvement of individual and collective resources for health, well-being and quality of life, and so counter health risks.

A further core concept of the Guideline concerns the requirements for the protection of human health with regard to effective precautionary environmental protection. The principle of the precautionary consideration and assessment of environmental impacts embedded in the EIA legislation requires relevant assessment criteria. Therefore, the analysis of health determinants in Section 5 of the Guideline pays attention to the levels of protection implied by the relevant legal minimum standards of environmental quality. The focus has to be placed on standards that prioritise precautionary health protection. The assessment values and quality objectives of national and international boards and organisations (DIN, VDI, WHO, UNECE) as well as the ambitious national thresholds of neighbouring countries should be considered as potential sources.

For the process-related practice with a view to support planning and decision-making processes, the linking of health impacts to the relevant legislation is important. In a separate section national environmental legislation is analysed in terms of content and health standards. The summary provides clear binding standards as well as non-specific legal terms such as ‘protection of neighbourhoods and the public from risks, disadvantages and nuisance caused by pollution’. The binding standards that have a normative character in planning practice could also be made available as part of an assessment, for example, standards for air quality, protection from noise pollution or electromagnetic radiation.

2.2. The determinants of health

Section 5 of the Guideline considers the determinants of health in more depth. For the social and natural environment determinants, factors are summarised that influence health both in terms of positive and negative impacts on human health and well-being. This includes all aspects of living and working environments such as the sociodemographic, the socio-economic and the psychosocial aspects and the natural environment expressed in the cityscape, the landscape or in local climatic conditions. The complexity of the direct and indirect relationships between health and the natural, built, social and cultural environments is shown in the Health Map (Barton and Grant 2006; adapted from Dahlgren and Whitehead 1991) in Figure 2.

Figure 2. The Health Map. Source: Barton and Grant 2006, p. 252, adapted from Dahlgren and Whitehead 1991.

This figure shows the complex relationship between the individual and social determinants of health in the residential environment as well as the key elements of settlements including their built environment. People and individual person-specific health determinants are placed at the core of the Health Map. This core is surrounded by a series of spheres that show the different social, environmental and economic systems in settlements, and also represent the global dimension. As far as assessment criteria for the social and natural environment are concerned, there are generally no binding fixed standards that go beyond the generally formulated and statutory issues defined in the German planning and environmental legislation; for example, such issues as ‘the consideration of healthy housing and working conditions, the preservation of social and cultural needs of the population or the protection of the diversity, uniqueness and beauty as well as the recreational value of nature and landscape’ from the legislation on nature conservation and landscape protection. These are not conflict-free but rather provide the basis for a content-related consideration and deliberation process to achieve a desirable quality of the social and natural environment.

On the level of chemical, physical and biological determinants, there are many more binding standards for health protection. However, the extent of the precautionary approach varies greatly. The focus is on pollutants, which are substances or factors that occur naturally in the environmental media (air, soil, water and foodstuffs) or that are released by humans into the environment and that can impact on health. In general, a noxious substance is an agent of a potentially adverse environmental or health impact (Risikokommission 2003). Physical pollutants include non-material factors such as radiation, noise (infrasound, low frequency sound etc.), vibration and light pollution. Biological pollutants include bacteria, viruses, fungi, parasites and biological toxins; these mostly occur in the environment as airborne microorganisms which can also be called bio-aerosols.

2.3. Planning and development control processes: other instruments for HIA

A further section of the Guideline focuses on the planning and decision-making processes of integrated environmental assessment responsible for the protection of human health. The processes of spatial/regional planning, land-use planning and development plans at the local level and plan approval procedures are outlined in order to pinpoint the location of interfaces with the protection of human health or with objectives concerning health and health protection. Furthermore, the content and objectives of various methods of HIA are discussed, for example:

•	Quantitative risk assessment (QRA),
•	Human and biomonitoring,
•	HIA,
•	Sectoral health plan on the municipal level,
•	Climate analysis and vulnerability assessment.

Regarding these methodological approaches, a pioneering role can, for example, be taken by the sectoral health plan drawn up on the municipal level. With this instrument data and information at the interface between environment, health and social setting can be brought together, not only in terms of content but also spatially. On the basis of the analysis of potential health-related deficits as well as development potential, health-related objectives should ultimately be developed and operationalised; this in turn should lead to the creation of an action plan. Furthermore, the health plan aims to assist the health authorities with their responsibilities and their stipulations on urban planning procedures. The focus lies on the spatial, cross-departmental and cross-sectoral representation of health issues. To test the concept of such a sectoral plan, pilot projects were run in two German municipalities (Baumgart 2013; Hartlik et al. 2016).

3. Assessing the health impacts

3.1. Health, vulnerability and resilience

The population can be exposed to many different environmental factors that can affect their health. In order to estimate the impacts that would result from a particular development project, impact factors are defined and the environmental media (air, soil, water and foodstuffs) examined. Health impacts can then be estimated indirectly through indicators from the various environmental media. To describe these impact factors it is possible to differentiate between chemical pollutants, physical impact factors and biological determinants. But also social and natural aspects such as recreational value and residential area functions have a considerable role in the sum of the influences on human health. In the Guideline, a simplified schematic overview of the complex and dynamic interaction of the determinants of health has been developed (see Figure 3).

Figure 3. Model of the health relevant determinants in planning projects. Source: Machtolf 2014.

In past planning and decision-making processes in Germany there have only been rare cases when the determinants of health were treated holistically and on an equal footing with other considerations, involving the intense participation of health authorities. In assessments of potential health risks – at least in the strongly regulated consent procedures that comply with legislation on pollution control – it is more common to take assessment values from the relevant environmental media legislation (for example, threshold values and limit values of the various directives on pollution control and the trigger values from the German Federal Soil Protection and Contaminated Sites Ordinance). Little attention is thus paid to the underlying levels of protection (precaution and hazard prevention) in the objectives of the specific laws. Embedded in the German EIA legislation, however, is also the principle of ‘consideration and assessment with regard to effective environmental protection’, which has to be taken into account and can thus be used as a basis for demands for appropriate benchmarks.

The definition of health according to the WHO (see above) has the aim of precautionary health protection, as can be seen in the use of the terms mental and social well-being. Another definition that has a significant role is that of the sensitivity or vulnerability of humans. Vulnerability is characterised by the WHO (2002, p. 13) as ‘the degree to which a population, individual or organization is unable to anticipate, cope with, resist and recover from the impacts of disasters’. According to the Advisory Council on the Assessment of Developments in the Health Care System, increased vulnerability can be found in groups whose full participation in society is at risk or impaired (for example, the unemployed or old people) and this is combined with constrained or poor material conditions (Sachverständigenrat zur Begutachtung des Gesundheitswesen 2007). Vulnerability can also result from the individual disposition (state of health, chronic disease and disabilities) or biological factors (age, sex, genetic predisposition), independent of the social setting. A frequently mentioned antonym of vulnerability is resilience. This term, as multifaceted as vulnerability, expresses the ability of an individual to react to changing conditions and to maintain health in a dynamic process (also called adaptation or buffer capacity). A lack of resilience accompanies increasing vulnerability and vice versa.

When humans are the focus of the assessment then deciding factors include physical, chemical and biological determinants, the relevant pathways and the internal exposure to the pollutants, as well as their perceptibility. Furthermore, social and natural landscape determinants are important.

3.2. Assessment of health effects using statutory instruments for HIA – QRA

QRA can be understood as a technique with a scientific and technical basis that aims to quantitatively describe existing or expected health risks subject to the particular exposure. An assessment of the chemical, the physical and the biological determinants considers the likelihood of contact subject to the length and frequency of exposure, concentrations in the respective environments and, finally, health impacts on various endpoints of the human body.

To date, the typical models for assessing health impacts use the definition of so-called adverse effects. An adverse effect is, according to the definition of the WHO (1994), a change in the morphology, physiology, growth or development of an organism and the related impairment of the functional capacity of that organism. In addition, a change in the life expectancy, the capacity to compensate for additional stress and increased susceptibility to the harmful effects of other environmental influences are part of the definition of adverse effect.

Dose-response estimates describe the relationship between the exposure to pollutants or determinants and the effects on humans. Existing experimental toxicological and/or epidemiological data are used to define these estimates. The German Ministry of the Environment derives thresholds for chemical pollutants to assess the human toxicological effect (tolerable absorbed dose – TRD). Depending on the quality of data used and with the help of safety margins, the pollutant-specific sensitivity to pollution of particular groups is considered. A cancer risk assessment is carried out for carcinogenic substances or suspected carcinogens that cannot be allocated a threshold (Heller and Machtolf 2014).

Extensive descriptions of the substances as well as the derivation of the tolerable absorbed dose values and cancer risk assessments are presented in the loose leaf booklet by Heinzow (1999ff). There are 141 substances in Germany that have more or less agreed-upon human toxicological assessment criteria available from the Ministry of the Environment. Other institutions provide similar criteria, such as the Federal Institute for Risk Assessment (BfR), EFSA and the WHO.

Exposure estimations are used to quantify how much of a pollutant a person is exposed to because of their location or their behaviour. To examine various exposures, pathways are defined and so-called exposure scenarios are created to describe which groups within the population come into contact with which pollutants or health determinants, where, for how long, how often and in what form (AGLMB 1995; Eikmann et al. 2012).

Comparing the estimated exposure and the toxicological threshold values, criteria for existing or projected environmental conditions can be derived.

In the following, several examples from planning and procedural practice are described in order to show how the current legal guidelines define levels of protection for human health and to examine the opportunities for putting into action demands for the effective protection of health.

3.3. Assessment of health effects in the development control process – the example of German legislation on pollution control

Pollution control uses human toxicological assessments of pollutants and determinants and sets legally binding guidelines for chemical pollutants in the form of pollution control limits and target values. These can be understood in terms of hazard prevention. The level of protection of the admissible risk for carcinogens lies, depending on the substance, in the area of 10–4 to 10–5. Clear and binding guidelines for the quantification of precautionary health requirements do not exist. In the various regulations as well as in the scientific literature the admissible risk for the precautionary level of protection is one order of magnitude smaller – in the area of 10–5 to 10–6 (Heller 2014a).

For physical determinants such as high and low frequency electromagnetic fields, the Ordinance on Electromagnetic Fields (26th BImSchV) lays down thresholds for the protection of the population. Vulnerable groups within the population, for example children, are not explicitly considered. Nor is the effect on risk groups, such as people with implants, reflected (Kühling and Hornberg 2014).

The current regulatory system for noise protection includes technical regulations and legislation for industrial noise, noise from roads and railways, and recreational noise, and comes into effect at the respective sources. This means that noise is separately assessed and restricted for each of the different polluter groups. There is no summation or assessment of the noise that arrives in total at the recipient due to several, simultaneously occurring sources of noise (Kühling 2014a).

For other potential physical determinants, such as infrasound and low frequency sound, vibrations or light, the actual state of knowledge is not yet satisfactory with regard to cause and effect or standardised and professional measurement techniques. Legally binding standards for these determinants therefore exist only indirectly or are limited. As a consequence of this, good practice is the application of (regional) regulations of distance control, DIN standards (German Institute for Standardization regulations; for example, DIN 4150-2 for the assessment of vibration severity) or recommendations of the Federal and State Taskforce for Pollution Control (LAI) (UVP-Gesellschaft e.V. 2014).

For biological determinants such as bio-aerosols there are no thresholds derived from the findings of toxicological and environmental epidemiological studies. In this case there are also no legally binding standards. Guidelines regarding content for the identification of pollution indicators are set out in the Association of German Engineers (VDI) standards (VDI 4250 and VDI 4251). Scientific articles on the problems of assessment (Heller 2014b) recommend guidelines for the background concentration of bio-aerosols as an assessment benchmark for ensuring protection from hazards to human health; these could then be used within the framework of the approval procedure according to the legislation on pollution control (BImSchG) and the ‘Technical Instructions on Air Quality Control’ (TA Luft). In an ordinance from 19 January 2013 on legal requirements for the pollution control of livestock farms, the state of North Rhine Westphalia formulated key parameters and guideline values that are based on quantitative limits of the parameters in question.

3.4. Assessment of health impacts in the planning and decision-making processes – the example of the legislation on soil protection

In the sense of aftercare or hazard prevention, the German Federal Soil Protection and Contaminated Sites Ordinance (BBodSchV) defines use-specific trigger values of existing soil contamination for children’s playgrounds, residential areas or park and recreational facilities. These are subject to scenario-specific exposure considerations.

The level of protection for human health according to the principle of hazard prevention uses the notion of reasonable suspicion. This involves a concept for detecting so-called hazard-combining factors (Konietzka 1998). For carcinogens without a threshold an additional risk of cancer of 5 × 10–5 is laid down.⁵ According to this, the trigger values derived for the various scenarios according to the German Federal Soil Protection and Contaminated Sites Ordinance can be classified as definite indicators. When these values are exceeded, there is probable risk to human health through harmful soil changes and further examination is necessary.

Should an examination of existing harmful soil changes go beyond such hazard prevention, for example within the scope of a planning proposal, the ARGE BAU (2001) requires compliance with the trigger values laid down in the Federal Building Code (BauGB) for ‘healthy living and working conditions’ (see §1 Section 5 of BauGB). Legally binding standards for the assessment of soil with regard to health precautions are non-existent (Machtolf 2014).

3.5. Assessment of health impacts in the planning process – the example of building and planning law

Health impacts and their assessment are a classic topic of urban land-use planning. In Germany, land-use planning consists of a preparatory land-use plan for the whole territory of the municipality and a binding land-use plan for local urban development. §1, Section 6, No. 1 of the Federal Building Code, which is a set of guiding principles at the federal level and provides the framework for urban land-use planning, stipulates ‘in the preparation of land-use plans the following must be considered: the general requirements of healthy living and working conditions and the safety of citizens that reside or work in the relevant areas’. Furthermore, according to §1, Section 6, No. 7, c ‘environmental impacts on humans and human health as well as the population as a whole’ need to be considered. German planning law therefore contains objectives and criteria for precautionary health protection among the principles that have to be deliberated in the consultation and consideration process of land-use planning. These principles must be considered along with the interests of other public and private stakeholders. The relevant legal concepts, which are not specifically defined, can be interpreted in a precautionary way by the municipal authorities responsible for land-use planning. For example, in its urban planning the city of Cologne uses a guideline value that is lower by a factor of 100 than the pollution control legislation threshold of 100 microtesla as a precautionary measure for the protection of residents’ health from electromagnetic radiation (Stadt Köln 2015).

3.6. Summary – the opportunities and limitations of a precautionary assessment of health impacts

QRA presents a transparent model with the help of which comparative and comprehensible assessment criteria for different uses can be derived. The level of protection is variable – it can and must be defined according to the aims and issues at hand. Depending on the choice of the required safety factors and uncertainties, the probability of damage can vary by orders of magnitude.

In terms of hazard prevention, the idea of the probable occurrence of a hazard can be represented through lower safety factors. However, for precautionary health protection higher safety factors and adverse assumptions and agreements should be made in order to provide sufficient protection of health for sensitive and vulnerable groups within the population.

The limits of an approach within the planning process are linked to it being exclusively based on technical legal requirements. Thus, on the one hand, with the use of a specified threshold the concept of ‘health’ is defined in the narrow sense of ‘being free from disease and infirmity’ and hazard prevention is used as a basis for the level of protection. On the other hand, multiple burdens and vulnerable groups are not sufficiently considered. Dose-response estimates are for the effects of specific pollutants. It is not currently possible to make reliable statements on multiple burdens caused by various pollutants or determinants because of the state of scientific research (exception: in the examination of substance groups the use of toxicity equivalents such as for dioxins or nitroarenes) (Kühling 2014b).

Risk groups are generally considered to be those with a high exposure and/or sensitivity (also in terms of previous illnesses) to the individual pollutants. Examples of these groups are children, pregnant women, breastfeeding women, the elderly and those with a compromised immune system. More stringent requirements (exposure variations) because of spatial features, hotspots, multiple burdens, landscape, etc. are not sufficiently covered by this.

If the definition of health is extended to consider the vulnerability of the population, then concepts for incorporating social environmental determinants are necessary. These allow a closer examination of the living environments of the affected people (Riedel 2014). Approaches to this can be found in work on environmental justice and health equity.

4. Application to strategic planning approaches

The Guideline that has been outlined here can provide a basis for the practical operationalisation of the protection of human health in planning and decision-making processes with integrated environmental assessment. It can be seen as contributing to the development of good professional practice, in particular bringing the aspect of precaution-oriented HIA to the fore. A focus on protecting human health within environmental assessment inevitably involves discussion of the degree of environmental protection used as a criterion for expected health impacts. The Guideline offers a comparative view, presenting international thresholds, reference values and orientation values according to application type. As a result, the considerably higher precaution-orientated values for health protection are included more effectively and given more emphasis in the decision-making process.

Generally, it would be desirable to extend the definition of health. For example, indicators could be developed that operationalise human well-being and allow for the effective consideration of particular vulnerabilities. The parity of living conditions, in particular in socio-economically deprived areas, should be given more attention and multiple burdens should be adequately considered. Areas where multiple burdens occur are known as hotspots in which environmental and health hazards overlap. Discussion should focus on the extent to which these burdens represent a need for planning that would justify the drawing up of a new development plan. Aspects such as demographic change or the increase of extreme weather hazards should be highlighted, as the vulnerability of the population can be affected by dynamic change. In many municipalities integrated concepts for climate adaptation are currently being prepared and are financially supported by the federal government as well as by the federal state concerned through urban development grants.

The inclusion of issues concerning the social environment or topics such as environmental justice may initially seem to contradict the mandate of the German EIA legislation and the EU EIA directive, as the focus in environmental assessment is on environmental issues and the pooling of them. However, an examination of the pathogenic and salutogenic explanatory models of disease origin and development and health promotion quickly shows that health and well-being do not solely depend on the cleanness and quality of the environmental media. Adverse health effects are seldom one-dimensional: they are often caused by multiple burdens and overlapping triggers. Moreover, they have complex, dynamic explanatory models. The overlaying of social and environmental data and the problem situation thus derived should feed into the aims, strategies and planning measures. For such an approach, the above-mentioned sectoral health plan would be a suitable instrument at the municipal level.

Various fields of application and target groups involved in planning strategy would be well served by the use of the Guideline. The primary recipients are the health authorities that are legally obliged to raise health issues during the planning and development control processes. Furthermore, the Guideline is of fundamental importance for all actors involved in environmental assessment, as it, along with its practical orientation, integrates knowledge from various disciplines (as shown by the 24 co-authors of the Guideline from many disciplines and fields of activity) and offers explanatory models of health-related interdependencies. As well as the consultants that produce the EIA studies, the authorities that manage the procedure as well as objectors and those personally affected can all use the Guideline in order to more effectively influence procedures, particularly those of local land-use planning. Here the strategic environmental assessment (SEA) is able to provide alternatives for urban planning solutions regarding environmental and health impacts in the consideration process, comprehensively reflected by Fischer. His conceptual model to approach to consider health determinants supports transparent consideration and negotiation procedures with regard to the contested spheres in the spatial and institutional context (Fischer 2014, p. 35).

In this way the strategic scope of environmental assessment is also to be incorporated, as proposed by Stöglehner (2009, p. 263) who underscores the need to examine not just the individual variants but also the fundamental system variants related to the functional logic of systems (for example, waste management or transport) and the achievable mitigation potential including the inclusion of global arguments. He calls for an assessment of alternatives during target definition, before even starting the planning procedure. The inclusion of scenarios in the formal logical planning process can similarly serve to fulfil this intention. Here, the Guideline can also be factually supportive in terms of criteria and the assessment of those criteria.

A look at the various stakeholders and rationales raises questions about the planning phase in which environmental impacts are examined. It touches on valuation processes and the related theoretical understanding of the various dimensions of assessment logic: the professional functionaries involved tend to take a positive approach while the local politicians take a normative approach and are mostly guided by common knowledge.

These approaches impact on the organisation of the planning procedure and may require increased personnel resources. It is not always possible to separate the positive and normative levels; particularly in small and medium-sized towns in Germany there is a tendency for individualised and professionally informal communication structures that are moulded by procedures with newly predefined structures and processes (Rüdiger 2009). However, the content and form of communication required by the Aarhus convention varies with the different actors according to the target audience, including communication with the public and its broad spectrum of interests. ‘Public involvement is the underlying principle of EIA. Therefore raising public awareness on environmental issues is as important to the EIA as direct environmental goals.’ (Faith-Ell et al. 2014, p. 13). The necessity of the audience-specific preparation of the data and materials on health-related topics in order to achieve professional, political and public opinion forming seems wise if not indispensable. In terms of procedural justice the inclusion of all groups within the population with various educational and linguistic or articulatory competences is an essential requirement. Again, this is something that the Guideline could potentially contribute to.

Through the early involvement of health and environmental authorities, assessment can potentially contribute to the training of the administration and local politicians and can improve the policy consultancy of municipal representatives. Environmental assessment contributes to the transparency of decision-making processes, which is particularly important for the objectives of urban development in existing areas. The production of specific information for individual citizens, such as figures related to number of residents per doctor or the spatial ease of access to a hospital, should increase public awareness of these topics. Such information should be included in the environmental assessment for land-use plans that adhere to the protection of human health. The development of easily manageable indicators that allow the systematic comparison of cities and districts can strengthen the importance of environmental assessment for spatial planning even in built-up areas. The indicators should not just be generally applicable standards but also refer to distinct site-specific qualities. The Guideline on ‘The Protection of Human Health’ offers the possibility to compare national thresholds with international thresholds, reference values and orientation values. In this way, precaution-oriented values for the protection of health – in particular for vulnerable groups – can be more effectively included in the decision-making process.

Environmental assessment has the potential to prepare the structure, extent and comprehensibility of complex information in a recipient specific manner. With activity stimulating forms of participation the dissemination of decision-making criteria in transparent processes offers communication tools that can be used by and with the planning authorities. A public display of sectoral statements related to the environment provides further relevant information (Baumgart 2012).

5. Outlook

In summary, health impacts are much more complex and have to be much more broadly considered than is currently the case due to the lack of a HIA in Germany. This was the motivation to establish a working group consisting of inter- and transdisciplinary experts in the various fields related to environmental issues. Considering the core physical, chemical and biological determinants of health, cause–effect chains, indicators, scales and standards were the focus of the exchange. In particular, not only legal standards but also thresholds and precautionary values with respect to potentially vulnerable groups have been scrutinized.

In light of the objections and obstacles coming from the Ministry of Environment in the current process of transposing the new demands of the revised EIA Directive into German EIA law, the elaborated Guideline can only be a first step towards supporting practitioners and administrative actors involved in environmental assessments, enhancing the perception of health effects and fostering their better incorporation within environmental assessments.

Of course, the Guideline has limitations, particularly regarding the WHO definition of health and well-being. Social determinants have not so far been addressed. In the context of the acceleration of planning procedures demanded by the current requirements of urban development, the comprehensive Guideline is a challenge to practitioners. An evaluation of the administrative application is pending. Recent amendments of German planning law even refer to the simplification of environmental and health determinants.

As the German EIA procedure is linked to urban and regional planning procedure (as a so-called piggy-back procedure) the legally required entry points of the spatial planning process have to be connected with strategic planning approaches. This addresses the various stakeholders and their involvement in the planning process as well as the instruments applied to deliver differentiated sectoral requirements. Therefore, one of the core objectives is to support the health authorities in the municipalities and districts in contributing useful and targeted statements within EIAs and SEAs concerning likely impacts on human health. Particularly the sectoral health plan has been introduced, highlighting deficits and potentials as well as targets relevant to human health and well-being. In order to provide a broad understanding of health that includes well-being, mental health, the social environment and the individual factors and determinants of health, the Guideline mainly focuses on environmentally related effects on health. Thus, the Guideline should be understood as being of value for the qualification of health authorities as well as to the planning procedure as such.

Disclosure statement

No potential conflict of interest was reported by the authors.

Notes

1. Used here as a general term for the EIA of certain projects as well as the strategic environmental assessment of certain plans and programmes.

2. Estimation based on the experiences of the expert members of the working group.

3. The guideline is a product of the working group on human health of the German EIA Association. The working group was established on the initiative of the North-Rhine Westphalia Centre of Health and the EIA Association in April 2008. Members include representatives of the disciplines of public health, environmental health, medicine, nutritional science, landscape ecology, landscape planning, spatial planning, geography, climatology and social science, from public authorities, universities and the private consulting sector. There are two meetings a year with the whole working group as well as further meetings of subgroups.

4. The Guideline was published by the German EIA Association after a review process. In February 2017, a Spanish version was published by the Peruvian Ministry of Environment for general use for its EIA and SEA practice, excluding the sections dealing with German law.

5. This is the risk that five of 100,000 people will additionally develop cancer.