City of York Council

Equalities Impact Assessment

Who is submitting the proposal?

Directorate:		Economy and Place
Service Area:		Forward Planning
Name of the proposal :		City of York Planning Policy Housing Delivery Action Plan (PPHDAP)
Lead officer:		Sophie Hall-Thompson, Development Officer
Date assessment completed:		23/11/21
Names of those who contributed to the assessment :
Name	Job title		Organisation	Area of expertise
Alison Cooke	Head of Strategic Planning Policy		City of York Council	Planning policy
Paul Landis-Stamp	Housing Strategy Manager		City of York Council	Housing Strategy
Heidi Lehane	Senior Solicitor		City of York Council	Legal

Step 1 – Aims and intended outcomes 

1.1

What is the purpose of the proposal? Please explain your proposal in Plain English avoiding acronyms and jargon.

The purpose of the Planning Policy Housing Delivery Action Plan (“Action Plan”) is to identify and implement a number of steps that will support the delivery of net additional homes. The Action Plan builds on existing work underway to deliver housing that the City of York has identified in the emerging Local Plan and as such identifies steps that will enhance existing work streams in the Place Directorate. It considers root causes and historic trends in relation to the council’s record of delivering net additional homes in the City of York area with a view to creating an action plan to boost housing delivery in the area.

1.2	Are there any external considerations? (Legislation/government directive/codes of practice etc.)
	The Action Plan is necessitated by central government in accordance with the National Planning Policy Framework (NPPF) as the council did not deliver 95% of the housing requirement, a local housing target provided by central government. The council’s duties under the Equalities Act 2010 and the Human Rights Act 1998 are key considerations.

1.3

Who are the stakeholders and what are their interest

Stakeholders include residents, businesses including private developers, housing associations and landowners across the entirety of the City of York area. The physical impacts of undersupply and or the additional supply of new housing has social, economic and environmental impacts for all users of the City of York area. Interests include, but are not limited to, the quality of the environment in terms of residents and users living, visiting, working and relaxing; the needs of local people to access housing that is affordable, high quality and meets their family and health requirements and the business plans of businesses including developers and landowners. In accordance with the emerging Local Plan and consultation that has taken place, and continues to take place, the Action Plan seeks to provide housing for all groups including those with affordable or specialist need so that quality housing can be accessible for all residents regardless of their income or their protected characteristics.

1.4

What results/outcomes do we want to achieve and for whom?  This section should explain what outcomes you want to achieve for service users, staff and/or the wider community. Demonstrate how the proposal links to the Council Plan (2019 - 2023) and other corporate strategies and plans.

As previously stated, the Action Plan builds on existing work taking place in the Council. Not only the emerging Local Plan but also the Housing Delivery Programme, forthcoming housing strategy and housing focused Supplementary Planning Guidance. The Action Plan directly seeks to support the Council Plan outcome ‘Creating homes and world class infrastructure’ and indirectly contribute to all of the outcomes by ensuring sustainability, quality, health and equality of people and of places are at the core of decision making related to housing. Outcomes include: · delivering high quality net additional housing commensurate with the housing requirement and local need · closer working relationships across corporate teams to realise the action plan · closer working relationships with landowners, developers and their agents to realise the action plan · improved consultation and engagement with residents and businesses to realise the action plan

Step 2 – Gathering the information and feedback 

2.1	What sources of data, evidence and consultation feedback do we have to help us understand the impact of the proposal on equality rights and human rights? Please consider a range of sources, including: consultation exercises, surveys, feedback from staff, stakeholders, participants, research reports, the views of equality groups, as well your own experience of working in this area etc.
Source of data/supporting evidence		Reason for using
Regulation 19 Local Plan, submitted to the Secretary of State, May 2018 and consultation responses prior to and subsequent to this date on the emerging Local Plan.		The purpose of this document was to assess the potential impact of the policies of the Local Plan on different groups within York. The Action Plan seeks to deliver in accordance with the policies established in the emerging Local Plan with the exception of Policy SS1 as the Action Plan seeks to contribute a greater level of net housing than that identified in Policy SS1.
Regulation 19 Local Plan Evidence Base		The Local Plan evidence base includes a considerable amount of data regarding housing need (affordable and market) and delivery and the council’s strategy for delivering against this need. This strategy was subject to an Equalities Impact Assessment (Incorporating the Better Decision Making Tool) in April 2018.
National Planning Policy Framework: Equality Impact Assessment, July 2018		This documents considers changes to the National Planning Policy Framework (NPPF) that introduced the new housing requirement on the City of York council as a Local Planning Authority that the Planning Policy Housing Delivery Action Plan is seeking to achieve. This document has considered the implications of policy changes to policy changes aiming to increase housing supply and therefore the greater level of net housing than that identified in Policy SS1.

Step 3 – Gaps in data and knowledge

3.1	What are the main gaps in information and understanding of the impact of your proposal?  Please indicate how any gaps will be dealt with.
Gaps in data or knowledge		Action to deal with this
The Action Plan establishes steps for further work. It is not feasible to know the impacts of work arising from further work such as the Housing Strategy or Housing SPD and as such there may be consequences that have not been anticipated.		The Housing Strategy and Housing SPD will be supported by an Equalities Impact Assessment. Other actions within the Action Plan will be monitored, reviewed and updated on an annual basis for the foreseeable future and actions and consequences arising from further work will be reviewed and supported by an equalities impact assessment on an annual basis also.
The outcome of the examination of the Regulation 19 Local Plan is not yet known. The outcome may provide further insight into the mechanisms for delivering net additional housing.		The outcome of the examination of the Regulation 19 Local Plan and how this relates to the Planning Policy Housing Delivery Action Plan will be addressed in the next iteration of the Planning Policy Housing Delivery Action Plan.

Step 4 – Analysing the impacts or effects.

4.1	Please consider what the evidence tells you about the likely impact (positive or negative) on people sharing a protected characteristic, i.e. how significant could the impacts be if we did not make any adjustments? Remember the duty is also positive – so please identify where the proposal offers opportunities to promote equality and/or foster good relations.
Equality Groups and Human Rights.		Key Findings/Impacts	Positive (+) Negative (-) Neutral (0)	High (H) Medium (M) Low (L)
Age		The Action Plan supports net additional delivery of housing in line with the emerging Local Plan and will meet housing needs and provide a range of house types for all ages.	+	H
Disability		The Action Plan supports net additional delivery of housing in line with the emerging Local Plan and will meet housing needs and provide a range of house types.	+	H
Gender		No impacts identified	0	n/a
Gender Reassignment		No impacts identified	0	n/a
Marriage and civil partnership		No impacts identified	0	n/a
Pregnancy and maternity		No impacts identified	0	n/a
Race (including migrants, asylum seekers and refugees, and ethnic minorities.)		Meeting Gypsy, Traveller and Travelling Showpeople's accommodation needs in line with the Regulation 19 Local Plan, the supporting evidence base and the outcomes of the emerging Local Plan Examination. Meeting affordable, specialist and supported housing needs in line with the Regulation 19 Local Plan, the supporting evidence base and the outcomes of the emerging Local Plan Examination.	+	H
Religion and belief		No impacts identified	0	n/a
Sexual orientation		No impacts identified	0	n/a
Other Socio-economic groups including :		Could other socio-economic groups be affected e.g. carers, ex-offenders, low incomes?
Carer		No impacts identified	0	n/a
Low income groups and homeless households		Meeting affordable, specialist and supported housing needs in line with the Regulation 19 Local Plan, the supporting evidence base and the outcomes of the emerging Local Plan Examination.	+	L
Those with specialist housing needs		Meeting affordable, specialist and supported housing needs in line with the Regulation 19 Local Plan, the supporting evidence base and the outcomes of the emerging Local Plan Examination.	+	H
Veterans, Armed Forces Community		Meeting affordable (specifically First Homes) housing needs in line with Written Ministerial Statement on 24 May 2021 (Statement UIN HLWS48).	+	H
Other		n/a, no other groups identified	n/a	n/a
Impact on human rights:
List any human rights impacted.		The Convention rights applicable are: · Article 8 - protects the right of the individual to respect for their private and family life, their home and their correspondence. The private life part of this right covers things like wellbeing, autonomy, forming relationships with others and taking part in our community. · Article 14 - protects the right to be free from discrimination when enjoying other rights, such as Article 8. The equalities impact assessment identifies  positive and neutral impacts arising from the Action Plan

Use the following guidance to inform your responses:

Indicate:

- Where you think that the proposal could have a POSITIVE impact on any of the equality groups like promoting equality and equal opportunities or improving relations within equality groups

- Where you think that the proposal could have a NEGATIVE impact on any of the equality groups, i.e. it could disadvantage them

- Where you think that this proposal has a NEUTRAL effect on any of the equality groups listed below i.e. it has no effect currently on equality groups.

It is important to remember that a proposal may be highly relevant to one aspect of equality and not relevant to another.

High impact (The proposal or process is very equality relevant)	There is significant potential for or evidence of adverse impact The proposal is institution wide or public facing The proposal has consequences for or affects significant numbers of people The proposal has the potential to make a significant contribution to promoting equality and the exercise of human rights.
Medium impact (The proposal or process is somewhat equality relevant)	There is some evidence to suggest potential for or evidence of adverse impact The proposal is institution wide or across services, but mainly internal The proposal has consequences for or affects some people The proposal has the potential to make a contribution to promoting equality and the exercise of human rights
Low impact (The proposal or process might be equality relevant)	There is little evidence to suggest that the proposal could result in adverse impact The proposal operates in a limited way The proposal has consequences for or affects few people The proposal may have the potential to contribute to promoting equality and the exercise of human rights

Step 5 - Mitigating adverse impacts and maximising positive impacts

5.1

Based on your findings, explain ways you plan to mitigate any unlawful prohibited conduct or unwanted adverse impact. Where positive impacts have been identified, what is been done to optimise opportunities to advance equality or foster good relations?

The Action Plan supports the positive impact measures contained with the emerging Local Plan. The Housing Strategy and Housing Supplementary Planning Document (SPD), both of which are currently being prepared, will look for opportunities to advance equality and foster good relations, as will all of the actions detailed in the Action Plan. The Planning Policy Housing Development Action Plan will be updated annual and be supported by an annual equalities impact assessment.

Step 6 – Recommendations and conclusions of the assessment

6.1	Having considered the potential or actual impacts you should be in a position to make an informed judgement on what should be done. In all cases, document your reasoning that justifies your decision. There are four main options you can take:
- No major change to the proposal – the EIA demonstrates the proposal is robust.  There is no                         potential for unlawful discrimination or adverse impact. All opportunities to advance equality and foster     good relations have been considered, and the Action Plan will be subject to continuing monitoring  and review.
- Adjust the proposal – the EIA identifies potential problems or missed opportunities. This involves taking steps to remove any barriers, to better advance quality or to foster good relations. - Continue with the proposal (despite the potential for adverse impact) – you should clearly set out the justifications for doing this and how you believe the decision is compatible with our obligations under the duty - Stop and remove the proposal – if there are adverse effects that are not justified and cannot be mitigated, you should consider stopping the proposal altogether. If a proposal leads to unlawful discrimination it should be removed or changed. Important: If there are any adverse impacts you cannot mitigate, please provide a compelling reason in the justification column.
Option selected		Conclusions/justification
No major change to the proposal		The EIA demonstrates the proposal is robust.  There is no potential for                     unlawful discrimination or adverse impacts. Opportunities to advance equality and foster good relations will be applied throughout Action Plan steps and will be subject to annual monitoring and review (including a review of the EIA), with the exception of the Housing Strategy and Housing SPD which will be subject to separate EIAs.

Step 7 – Summary of agreed actions resulting from the assessment

7.1	What action, by whom, will be undertaken as a result of the impact assessment.
Impact/issue		Action to be taken	Person responsible	Timescale
n/a

Step 8 - Monitor, review and improve

8. 1	How will the impact of your proposal be monitored and improved upon going forward?   Consider how will you identify the impact of activities on protected characteristics and other marginalised groups going forward? How will any learning and enhancements be capitalised on and embedded?
	Monitoring and evaluation of the Action Plan will be undertaken on an annual basis. This will be undertaken by the Strategic Planning Policy team and be reported corporately by way of the Planning Policy Housing Delivery Action Plan Update Report. All Action Plan steps are supported by the council’s existing corporate programme.