IPH welcomed the opportunity to respond to the consultation on the Key Issues Consultation Paper on the transposition of EIA Directive 2014/52/EU in the Land Use Planning and EPA Licensing Systems held by the Department of Housing, Planning, Community and Local Government (ROI). 

Our response focuses on the proposed approaches relating to population and human health on pages 11-12 of the Key Issues Paper and echoes points recently made to the Department of Housing, Planning, Community and Local Government in a consultation response to the National Planning Framework and to the Department for Infrastructure on the Planning (Environmental Impact Assessment) Regulations (Northern Ireland). 

IPH calls for greater recognition of the opportunity provided in Article 3(1) to broaden the understanding of health in the conduct of Environmental Impact Assessments. In light of the available evidence, adopting a ‘business as usual’ stance presents a missed opportunity to maintain and improve the health and wellbeing of the population. 

Furthermore it is inconsistent with national policy which supports an understanding of population and human health that spans environmental, social and economic determinants of health and wellbeing and the interrelationship between these. IPH believes a more holistic approach to health in EIA may enhance partnership work with public health stakeholders and practitioners and prevent duplication by reducing the need for separate health impact assessments.