Guidance on equality analysis

Annex A

City of York Council

Equalities Impact Assessment

Who is submitting the proposal?

Directorate:		Place
Service Area:		Parking Services
Name of the proposal:		Cashless consultation, parking ticket machine review and development of procurement specification for parking pay and display machines and pay on exit systems
Lead officer:		Graham Titchener
Date assessment completed:		1-9-2022
Names of those who contributed to the assessment:
Name	Job title		Organisation	Area of expertise
Jav Safder	Parking Patrol Manager		CYC	Parking and areas covering this proposal
Graham Titchener	Parking Services		CYC	Parking and areas covering this proposal including economic development

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.

To take forward Members request to consult on the parking estate moving to cashless.

Review of existing pay and display machines with a view to rationalising these and remove older machines that only work on the 3G network. As the 3G network is due to be turned within a period of the end of 2023 through to 2030, which is wholly dependent on each network supplier. After which these machines will become redundant and not worth the cost to try and upgrade these, especially those well over 20 years old.

In addition the council is keen to take forward pay on exit systems in most of its car parks. This work will also see the consultants brought in to do this work to develop a specification that can be used for procurement of pay and display machines and pay on exit systems.

Due to lack of staff capacity this proposal will be outsourced to a consultancy to take this proposal forward.

1.2	Are there any external considerations? (Legislation/government directive/codes of practice etc.)
	Yes, the turning off of the 3G network.

1.3	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.
	Cashless – it is hoped we will be able to go cashless in order to say on cash collection fees and maintenance of machines due to the working parts that are required to take, sort, and give change. This is a council benefit but will impact on those who currently use and want to continue to use cash. Pay and display machines – many of these are about 20 years old that only run on the 3G network. As this is due to be turned off January next year, we need to consider that these cannot be upgraded but due to the age of the machines this would not be seen as good value for money. In addition, as some of these machines take low amounts of cash we need to consider if it is cost effect to have machines in low use areas both in terms of initial cost and maintenance. These are instead would be covered by the pay by phone service instead. Given the above we may well be in a position of having to buy new pay and display machines. Given the cashless decision will impact on this (as to whether we procure cash and cashless machines or just cashless) there is the drive my officers, Members, and businesses to increase the pay on exit systems. As a result this opportunity will be used to get the consultant to develop a procurement specification to procure new machines and systems as and when funding becomes available. This goes towards helping to improve the local economy and desires from businesses as well as better systems to enable people to park and find their parking spaces more quickly and easier and more convenient to pay for their parking.
1.4	Who are the stakeholders and what are their interests?
	CYC Executive – those requesting this work regarding cashless consultation Car park users – going cashless will impact on those who currently use cash to pay for their parking.

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
What other councils are doing		To compare and demonstrate that York is not the only Local Authority considering or doing this. Also to learn any lessons regarding their work and findings.
Use of parking payment providers intelligence		As above
Public consultation and direct consultation with older people’s groups and associations		It is more likely that older people are used to using cash and less inclined to use cashless payment methods, therefore, to better get their views going to these specific bodies will help to better understand and persuade this group of people but also demonstrate the robustness of this public consultation on going cashless.
Business representative groups		Using their knowledge of how the public is shifting towards more cashless payment measures and their views and steer on the pay on exit systems.
Government statistics to inform and support this approach		To provide a context to the changing environment we are in to support this initiative to move to a cashless service

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
Older peoples view on cashless payment methods		Consult with specific aged representative bodies and commence a public consultation
Other local authorities’ views and work on going cashless		Liaise with LA groups and pay providers

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		This proposal needs to be taken forward to identify this, but it is taken that rolling out a cashless payment only system will have negative impacts on this group who want and may be can only use cash. Therefore, taking this work forward would likely have a negative impact on this group.	+	M
Disability		This proposal needs to be taken forward to identify this, but it is taken that rolling out a cashless payment only system will have neutral impacts on this group who want and may be can only use cash. Therefore, taking this work forward would likely have a neutral or negative impact on this group.	0 and -	M
Gender		Some impact on this groups and some may want or can only pay for goods and their parking by cash or use of mobile phone payments to pay for parking by the pay by phone service only where pay and display machines may be removed. The implementation of pay on exit systems, subject to any faults they may have, should be a positive that allows them to pay for the amount of parking they use rather than estimating then having to either run back to fill the meter up or curtailing their visit.	0, -, +	M
Gender Reassignment		Some impact on this groups and some may want or can only pay for goods and their parking by cash or use of mobile phone payments to pay for parking by the pay by phone service only where pay and display machines may be removed. The implementation of pay on exit systems, subject to any faults they may have, should be a positive that allows them to pay for the amount of parking they use rather than estimating then having to either run back to fill the meter up or curtailing their visit.	0, -, +	M
Marriage and civil partnership		Some impact on this groups and some may want or can only pay for goods and their parking by cash or use of mobile phone payments to pay for parking by the pay by phone service only where pay and display machines may be removed. The implementation of pay on exit systems, subject to any faults they may have, should be a positive that allows them to pay for the amount of parking they use rather than estimating then having to either run back to fill the meter up or curtailing their visit.	0, -, +	M
Pregnancy and maternity		Some impact on this groups and some may want or can only pay for goods and their parking by cash or use of mobile phone payments to pay for parking by the pay by phone service only where pay and display machines may be removed. The implementation of pay on exit systems, subject to any faults they may have, should be a positive that allows them to pay for the amount of parking they use rather than estimating then having to either run back to fill the meter up or curtailing their visit.	0, -, +	M
Race		Some impact on this groups and some may want or can only pay for goods and their parking by cash or use of mobile phone payments to pay for parking by the pay by phone service only where pay and display machines may be removed. The implementation of pay on exit systems, subject to any faults they may have, should be a positive that allows them to pay for the amount of parking they use rather than estimating then having to either run back to fill the meter up or curtailing their visit.	0, -, +	M
Religion and belief		Some impact on this groups and some may want or can only pay for goods and their parking by cash or use of mobile phone payments to pay for parking by the pay by phone service only where pay and display machines may be removed. The implementation of pay on exit systems, subject to any faults they may have, should be a positive that allows them to pay for the amount of parking they use rather than estimating then having to either run back to fill the meter up or curtailing their visit.	0, -, +	M
Sexual orientation		Some impact on this groups and some may want or can only pay for goods and their parking by cash or use of mobile phone payments to pay for parking by the pay by phone service only where pay and display machines may be removed. The implementation of pay on exit systems, subject to any faults they may have, should be a positive that allows them to pay for the amount of parking they use rather than estimating then having to either run back to fill the meter up or curtailing their visit.	0, -, +	M
Other Socio-economic groups including :		Could other socio-economic groups be affected e.g. carers, ex-offenders, low incomes?
Carer		Some impact on this groups and some may want or can only pay for goods and their parking by cash or use of mobile phone payments to pay for parking by the pay by phone service only where pay and display machines may be removed. The implementation of pay on exit systems, subject to any faults they may have, should be a positive that allows them to pay for the amount of parking they use rather than estimating then having to either run back to fill the meter up or curtailing their visit.	0, -, +	M
Low income groups		This may have an impact on these groups who for budgetary or other reason may only be able to use cash. The public consultation will try to capture views from these groups	0 and -	M
Veterans, Armed Forces Community		Some impact on this groups and some may want or can only pay for goods and their parking by cash or use of mobile phone payments to pay for parking by the pay by phone service only where pay and display machines may be removed. The implementation of pay on exit systems, subject to any faults they may have, should be a positive that allows them to pay for the amount of parking they use rather than estimating then having to either run back to fill the meter up or curtailing their visit.	0, -, +	M
Other
Impact on human rights:
List any human rights impacted.		None

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?

Subject to the consultation this is likely to have a medium impact on some groups of the public who want or can only use cash. Removing, albeit not as well used, pay and display machines for pay by phone only may have impacts on those who don’t have access to a mobile phone of cashless payment however there is a pay point option associated with pay by phone methods that do accept cash.

When they work, pay on exit systems do allow for a less stressful parking experience that allows customers to go off and stay for their visit without the fear of receiving a fine for staying longer than the pay for at pay and display car parks that by their nature means the customer has to plan how long they will stay.

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 and you have taken all opportunities to advance equality and foster good relations, subject to continuing monitor 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
At this starting point this selected option is to Continue with the proposal. Following the consultation, it is likely this option will move to Adjust the proposal		As well as the previous Administration’s request to explore cashless, progression and cost savings measures dictates this should start and continue to public consultation and Executive Member decision stages. Following the findings of this consultation it is likely the proposal will be adjusted but not expected by much.

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
Public Consultation		Consultant to report back to lead officers with findings and recommendations for a decision on how this can be taken forward	Graham Titchener	During of the consultation and Exec Member decision stages.
Revenue to pay for new machines		Work with Finance on what is possible and using any cost savings associated with this including machine removal and reduction or elimination of cash collection services to help fund.	Graham Titchener/CYC Finance	During of the consultation and Exec Member decision and procurement development stages.

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?
	Analysis of the public consultation and consulting with the councils Access Officer and disability groups to inform the consultation and this EIA.

Step 8 - Monitor, review and improve

City of York Council

Equalities Impact Assessment

- 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.