Equalities Impact Assessment outline for a planning submission

An Equalities Impact Assessment submitted with a planning application is not a document the applicant is legally required to produce. The duty belongs to the local planning authority: section 149 of the Equality Act 2010 requires public bodies, when exercising their functions, to have due regard to the need to eliminate discrimination, advance equality of opportunity and foster good relations between people who share a protected characteristic and those who do not. Your assessment exists to give the decision-maker the material to discharge that duty properly. Written well, it also removes a ground of challenge from anybody minded to bring one.

What the duty requires of the authority

The duty is one of process rather than outcome. It does not require a particular decision, and it does require the decision-maker to consider the effects on people with protected characteristics with rigour and an open mind, before the decision is taken rather than afterwards.

Courts have set out what "due regard" means in practice. The duty must be exercised in substance, with rigour and an open mind, at the time the decision is being taken. It cannot be delegated away, and a general awareness of equality issues is not enough. Retrospective justification does not discharge it.

For an applicant, three consequences follow. Provide the analysis before committee rather than in response to an objection. Make it specific to the scheme and the place. And be honest about adverse effects, because an assessment that finds no effect on anybody reads as a box-ticking exercise and gives the officer nothing to rely on.

The assessment should be proportionate. A householder extension needs nothing. A scheme affecting a community facility, a large residential development, a transport intervention or anything displacing an existing use needs real analysis.

Protected characteristics considered

Work through the nine characteristics in the Act, and say explicitly where you find no effect rather than omitting the heading.

• Age, which in practice means children, older people, and sometimes young people specifically.
• Disability, including physical, sensory, cognitive and mental health conditions.
• Gender reassignment.
• Marriage and civil partnership, which the duty covers only in relation to eliminating discrimination.
• Pregnancy and maternity.
• Race, including ethnicity and national origin.
• Religion or belief.
• Sex.
• Sexual orientation.

Add socio-economic considerations separately if the local authority's own framework asks for them, noting that they sit outside the section 149 characteristics in England. Do not merge them into the protected characteristics analysis, because doing so obscures which duty you are addressing.

Baseline population data

Use published data for the actual area, at the smallest sensible geography, and cite it with the source and year.

Census data from the Office for National Statistics gives age structure, disability and health, ethnic group, religion, and household composition at ward and output area level. The Index of Multiple Deprivation gives the relative position of the neighbourhood. The local authority's joint strategic needs assessment gives health and care data. Where the scheme affects a specific facility, the operator's own published usage data is better than area-wide figures.

State the geography you used and why. A scheme on the edge of a district serves a catchment that crosses the boundary, and using the whole-authority figures will understate the characteristics of the people actually affected.

Two honest limitations belong in the text. Census data ages, and small-area figures carry wide margins. Say so once, then use the data anyway, because the alternative is an assessment with no baseline at all.

Effects identified by characteristic

Structure this as a table, one row per characteristic, with four columns: the effect identified, whether it is positive, negative or neutral, the evidence, and the mitigation or enhancement proposed.

Then write the analysis underneath the table for the characteristics where there is something to say. The effects that recur in planning cases are worth checking against your scheme:

Construction phase effects on people with respiratory conditions, on shift workers, and on people at home during the day, which disproportionately includes older and disabled people. Loss or relocation of a facility used mainly by one group, such as a place of worship, a youth service or a day centre. Housing mix and whether it meets the needs of older households and disabled people. Accessibility of the streets and spaces, entrances, level changes and wayfinding. Play provision and space for children. Personal safety after dark, including lighting, sightlines and the design of routes. And affordability, where the tenure mix affects groups with lower average incomes.

Where an effect is negative and cannot be removed, say so and record the mitigation. The duty is not a prohibition on schemes that affect people unequally, and it does require the decision-maker to know that they do.

Access and inclusive design measures

This is where the assessment connects to the drawings, and it should reference them by number rather than describing intentions.

Cover step-free approach and entrance, door widths and opening forces, lift provision and car size, accessible WC provision, changing places facilities where the use justifies them, blue badge parking with its location and dimensions, dropped kerbs and tactile paving, seating and rest points on longer routes, colour and tonal contrast, signage and wayfinding, hearing enhancement systems in assembly spaces, and the proportion of dwellings designed to accessible and wheelchair user standards.

The building regulations guidance on access and the British Standard on inclusive design of the built environment are the references to cite, and an access audit by a specialist is the evidence councils treat most seriously. Where the scheme is residential, state the proportion of units at each accessibility standard and show the compliant layouts.

Much of this material also appears in the Design and Access Statement, and the two documents should agree. Contradictions between them are the most common criticism officers make.

Engagement with affected groups

Consultation that reaches only the people who read planning notices misses most of the characteristics you are assessing.

Record who you engaged, how, when and what they said. Targeted engagement means contacting the organisations that represent or serve the groups affected: a disability access group, a faith organisation whose premises are nearby, a school, a residents' association on an estate adjoining the site. Offer accessible formats and accessible venues, and say in the assessment what you offered.

Then close the loop. State what changed as a result, or state that nothing changed and why. An engagement section that lists meetings without outcomes is evidence of activity rather than of regard.

Where the scheme requires a Statement of Community Involvement, the equalities engagement sits within it rather than being duplicated, with a cross-reference in each direction.

Recording the assessment

Keep the document short, dated and auditable. A typical structure runs to eight parts.

1. The proposal and the decision the assessment supports.
2. The legal framework, stated in a paragraph.
3. Scope and proportionality: what you assessed and what you excluded, with reasons.
4. Baseline data with sources and geography.
5. Effects table by characteristic.
6. Analysis of the material effects.
7. Mitigation, enhancement and how each measure is secured, whether by condition, obligation or drawing.
8. Monitoring, where a measure needs it, and the review point.

Name the author and the date. Where the scheme changes during determination, reissue the assessment rather than leaving the officer to reconcile an old version with new drawings. An Equalities Impact Assessment drafted this way gives the officer something they can quote in the committee report, which is the practical measure of whether it has worked.

Illustrative example: a scheme replacing a community hall used by a lunch club for older residents and by a faith group. The assessment identified temporary loss of both uses, evidenced the user profile from the operator's booking records, and secured a phased delivery condition keeping the hall in use until the replacement opened. The committee report quoted the assessment in three places.

Enter your postcode on PlanScope to see which supporting documents your scheme is likely to need.

This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.