Health impact assessment or equalities assessment
A health impact assessment looks at population health, an equalities impact assessment at protected characteristics and a statutory duty on the council. The scope, triggers and evidence differ.
A health impact assessment and an equalities impact assessment answer different questions, and confusing them is the reason so many applications arrive with one document trying to do both jobs badly. A health impact assessment asks how a development will change the health of the population that uses or lives near it. An equalities impact assessment asks whether a decision will affect people with protected characteristics differently, and it exists to help a public authority discharge a statutory duty under the Equality Act 2010.
Only one of them has a statute behind it. That single difference drives the scope, the evidence and who the document is really written for.
What each assessment is asking
The health impact assessment looks outward at a population. It takes the wider determinants of health, housing quality, access to open space, air quality, noise, active travel, food environment, employment and social connection, and asks how the proposal shifts each one for residents, workers and neighbours. The output is a set of design and management responses, sometimes secured by condition or obligation.
An equalities impact assessment looks at the decision. It identifies which groups sharing a protected characteristic might be affected, how, and whether the authority has enough information to have due regard to the three limbs of the duty when it decides. Its audience is the case officer and, ultimately, the committee.
| Question | Health impact assessment | Equalities impact assessment |
|---|---|---|
| Legal basis | Local plan policy, occasionally national guidance | Section 149 of the Equality Act 2010 |
| Duty holder | The applicant, on the authority's request | The local planning authority as decision maker |
| Unit of analysis | Population groups and health determinants | The nine protected characteristics |
| Typical trigger | Major or referable development, local policy threshold | Any decision where a differential effect is possible |
| Usual length | 20 to 60 pages with a matrix | 6 to 20 pages with an analysis table |
Both are available as PlanScope report types, and both sit in the category where councils expect an author who knows the method. A Health Impact Assessment in particular is one of those reports where professional review is strongly advised, because the screening matrix is only as good as the judgement behind it.
The statutory duty behind the equalities assessment
Section 149 of the Equality Act 2010 requires a public authority, when exercising its functions, to have due regard to the need to eliminate discrimination, harassment and victimisation, to advance equality of opportunity between people who share a protected characteristic and people who do not, and to foster good relations between them. Determining a planning application is exercising a function, so the duty applies to every decision, including householder ones.
The protected characteristics are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation. Marriage and civil partnership engages only the first limb of the duty, which is a detail that a surprising number of submitted assessments get wrong.
Two points matter for an applicant. The duty is the authority's, so your document does not discharge it, it informs it. And the duty is about the process of having due regard, in substance and at the time of the decision, rather than about reaching a particular outcome. An authority that adopts a thin applicant assessment without thinking about it has a weaker position on challenge than one that engages with it in the officer report. That is why a well-structured equality analysis is worth more than a long narrative.
What triggers a health impact assessment
There is no national statutory requirement for a health impact assessment in England. The trigger is almost always local. Adopted plans in many authorities require one for residential schemes above a stated unit count, for development in areas of identified health inequality, or for hot food takeaways within a defined distance of a school. In London, the Mayor's policies require health impact assessment for referable applications, and boroughs apply their own thresholds below that.
Check three documents before you commission anything. The adopted local plan policy that names the requirement. The authority's validation checklist, which tells you whether the application will be validated without one. Any supplementary planning document or health and wellbeing strategy that sets the expected method, because a few authorities specify a named screening tool.
Wales runs a different regime. The Public Health (Wales) Act 2017 introduced a duty on specified public bodies to carry out health impact assessments in prescribed circumstances, so a Welsh application needs the position checked against Welsh legislation and Planning Policy Wales rather than assumed from English practice.
Where the requirement is unclear, ask at pre-application and get the answer in writing. A health impact assessment commissioned late costs more than one scoped at the outset, because the design responses it recommends cost little on a plan and a great deal on a planning permission.
Evidence each one draws on
The two documents draw on different data, which is the practical reason they should stay separate.
A health impact assessment usually builds from published population data: local authority health profiles, indices of deprivation, air quality monitoring from the authority's annual status report, active travel infrastructure, greenspace accessibility and the catchment of existing health facilities. It then relates those baselines to the scheme's own technical work, so the noise assessment, the air quality assessment and the transport evidence feed straight into it rather than being repeated.
An equalities impact assessment draws on the demographic profile of the affected population and on the specific characteristics of the scheme. Step-free access and wheelchair-accessible dwellings for disability. Play space and school capacity for age. Step-free routes to a place of worship for religion or belief. Affordability and tenure for characteristics that correlate with lower incomes, expressed carefully because income is not itself a protected characteristic.
Neither document should invent numbers. Where a figure is not published for your area, describe the effect and say what evidence would settle it. An assessment that quotes a precise percentage with no source is the fastest way to lose an officer's confidence.
Mitigation, conditions and monitoring
Recommendations only count if they can be secured. Sort every recommendation into one of three boxes before the document is finalised.
- Designed in, so it appears on the submitted drawings and needs no further control.
- Conditionable, so it can be worded as a precise, enforceable requirement that meets the six tests for conditions.
- Aspirational, in which case say so plainly rather than dressing it up.
Monitoring is where health impact assessments most often overreach. A commitment to monitor air quality for ten years after occupation is rarely proportionate on a 60-unit scheme and rarely enforceable. A travel plan with a modal share target, a monitoring fee and a review mechanism is enforceable, and it belongs in the travel plan rather than in the health chapter.
For equalities, the useful output is often a single paragraph the officer can lift into the report, recording which characteristics were considered, what differential effect was identified and what the scheme does about it. That is the paragraph a court would look for.
Doing both proportionately on one application
On a major residential scheme that triggers both, the efficient structure is one shared evidence base and two short documents. The baseline chapter, the technical cross-references and the description of the development are written once and cited by both. The health assessment then runs its screening matrix across the determinants, and the equalities assessment runs its analysis across the characteristics.
Resist merging them into a single "health and equalities" chapter. Officers report the two separately, statutory consultees read only one of them, and the legal test applies to only one. A merged document tends to bury the equalities analysis in the middle of a health matrix, which is precisely where a challenger will look.
Scope both at pre-application, alongside the decision about whether the scheme needs an Environmental Impact Assessment, because an EIA brings human health in as a topic in its own right and the boundary between the chapters needs to be drawn deliberately rather than discovered at submission.
This is general guidance, not legal advice. Check the requirement 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.
Browse all 66 PlanScope report types to see where the health and equalities documents sit in a full major application pack.
Frequently asked questions
Is a health impact assessment a legal requirement in England?
No. There is no national statutory requirement for one in the English planning system. The trigger comes from adopted local plan policy, the authority's validation checklist or, in London, the Mayor's policies for referable applications. Check all three before commissioning, and confirm the expected method at pre-application because a few authorities specify a named screening tool.
Who has to comply with the public sector equality duty?
The public authority exercising the function, which for a planning application means the local planning authority as decision maker. An applicant's equalities impact assessment informs that duty rather than discharging it. The authority still has to engage with the analysis in substance at the time of the decision, usually through the officer report.
What are the protected characteristics?
Age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation. Marriage and civil partnership engages only the first limb of the duty, which concerns eliminating discrimination, harassment and victimisation. Assessments that apply all three limbs to that characteristic are a common drafting error.
Can the two documents be combined?
It is better not to. Officers report them separately, different consultees read each one, and the statutory test applies only to the equalities analysis. Share the baseline chapter and the description of development between them, then keep the health screening matrix and the equalities analysis as distinct documents so neither gets buried.
What evidence should a health impact assessment use?
Published population data for the area, including health profiles, indices of deprivation and the authority's air quality annual status report, cross-referenced to the scheme's own technical work on noise, air quality and transport. Avoid quoting percentages that are not published for your area. Where a figure does not exist, describe the effect and say what would settle it.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.