City of York Council

Equalities Impact Assessment

Who is submitting the proposal?

Directorate:		Economy & Place
Service Area:		Housing Delivery
Name of the proposal :		Housing Delivery Programme, November Executive Report, Delivering More Affordable Housing in York
Lead officer:		Sophie Round
Date assessment completed:		31^st October 2023
Names of those who contributed to the assessment :
Name	Job title		Organisation	Area of expertise
Sophie Round	Housing Delivery Programme Manager		CYC	Housing development
Andrew Bebbington	Housing Policy Officer		CYC	Housing strategy & policy

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 paper seeks to increase the provision of affordable housing delivered both through the Council’s Housing Delivery Programme and through Registered Providers operating in the City. The report seeks to increase affordable housing to 100% on Ordnance Lane and Willow House and dispose of two plots of land for affordable housing to Registered providers. The report also seeks to increase the amount of resettlement housing available in the City by purchasing 10 properties for homes for Afghan refugees and temporary housing.

1.2	Are there any external considerations? (Legislation/government directive/codes of practice etc.)
	The grant from the Local Authority Housing Fund sets eligibility criteria for the resettlement homes purchased utilising the grant funding.

1.3	Who are the stakeholders and what are their interests?
	· City of York Council – key stakeholders within the Council include Housing Services, Building Services, Communities team, Climate reduction team · Ward Councillors · Residents and local businesses within existing neighbourhoods surrounding Ordnance Lane, Willow House, 68 Centre and Woolnough House sites

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 (2023-2027) and other corporate strategies and plans.

The recommendations set out in the paper reflect the 4 Core Commitments of the Council Plan 2023-2027 1) Equalities and Human Rights The paper proposes the delivery of increased levels of affordable housing which benefits those from lower socioeconomic backgrounds ensuring good quality housing provision. The new build homes will be built to a minimum standard of Part M4(2) ‘Accessible and Adaptable dwelling’ ensuring that the homes provide a good level of accessibility for residents throughout their lives. Approximately 10% of new build homes will be delivered as Part M4(3) ‘Wheelchair accessible dwelling’ ensuring a supply of adapted housing for residents with additional needs. Ordnance Lane also presents intergenerational housing to support aging communities to live independently. The grant obtained from LAHF to support the purchase of 10 homes for Afghan refugees and those in need of temporary accommodation. 2) Affordability The affordability of housing is a key issue for residents of York evidenced by the fact that the average house price is in excess of 10 times the average salary in the city. Increasing the supply of affordable housing for a broad range of residents including those on the housing waiting list and key workers. 3) Climate All homes delivered directly by the Housing Delivery Programme aims to achieve certified Passivhaus and utilise renewables such as Heat pumps and Photovoltaic panels. 4) Health and Wellbeing Good quality affordable housing has a positive benefit to the health and wellbeing of the residents. This paper aims to improve access to good quality housing for the city’s residents.

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
Resident engagement at Ordnance Lane and Willow House		This information has been gathered throughout the design process by hosting events for local people to promote co-design and ensure residents have influence over the places created as part of the Housing Delivery Programme. Feedback for Ordnance Lane was largely positive however, during consultation local people felt that the level of affordable housing should be increased. This paper responds to that feedback.
Lettings and Housing Management staff within CYC		Understanding the housing demand within the city is critical to designing homes needed by our residents. The Local Housing Needs Assessment demonstrates the greatest need for affordable housing is for smaller properties and therefore a modest redesign of the development to change larger 5 bed homes originally for market sale to apartments reflects this demand. The site maintains a good balance of larger properties to ensure a wide housing need is addressed by these developments
Resettlement housing – engagement with the Refugee Resettlement team		The bid submission to LAHF reflects engagement with the Refugee Resettlement team around the housing needs of the refugee households. This has been used as a basis for the bid and match funding requirements.
Soft market testing with Registered Providers		The disposal of Woolnough House and the 68 Centre depends on interest from Registered Providers to build and manage the properties. Whilst there is interest from RPs the sites are small and therefore there are likely to be some viability challenges in providing 100% affordable housing.

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 report does not bring forward business cases for Ordnance Lane or Willow House. These will need to be presented to Executive once the building contract has been tendered. Moving to 100% affordable housing will require a mixed tenure approach including low cost home ownership and rented homes. The business case will need to manage the financial challenges whilst ensuring the homes are affordable to the residents and meet the objectives of the Council Plan will be critical.		Detailed financial modelling to be undertaken once tenders are received. The Housing Delivery team will need to work closely with wider internal and external stakeholders to ensure the proposed housing meets key affordability criteria, reflecting the needs of residents across the city.
Further consultation is needed as detailed designs are developed to ensure the accessibility standards are met. Whilst we use the standards set within Building Regulations to design the homes, further detailed engagement from the community will have positive benefits to the projects.		Engage with the Council’s Access Officer and present future Designs to the York Access Forum.
Ongoing consultation needed to focus on the integration and community cohesion of refugee communities as part of the LAHF.		Present to the Refugee and Asylum Coordination Group to ensure they are aware of the proposals and that support is in place for refugee communities.

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		Ordnance Lane proposes intergenerational housing alongside homes designed to high accessibility standards. Willow House will be designed to the high accessibility standards and to ensure homes are designed for residents at all stages of life.	Positive	Medium
Disability		A minimum of 10% of new build homes will be designed to meet M4(3) Wheelchair accessible dwellings with all homes designed to meet M4(2) Accessible and Adaptable homes. The proportion of fully accessible homes will be reviewed during engagement with stakeholders and increased where there is a known housing need.	Positive	Medium
Gender		The proposals do not relate directly to gender. There are no known implications related to gender.	Neutral	Low
Gender Reassignment		The proposals do not relate directly to those undergoing gender reassignment. There are no known implications related to gender reassignment.	Neutral	Low
Marriage and civil partnership		The proposals do not relate directly to marriage and civil partnership. There are no known implications related to marriage and civil partnership.	Neutral	Low
Pregnancy and maternity		The proposals do not relate directly to pregnancy and maternity. There are no known implications related to pregnancy and marriage.	Neutral	Low
Race		The proposals would support the housing position of Protected Characteristics Groups and provide accommodation for households with a very high level of need. The risk of community perceptions around this aspect of the Local Authority Housing Fund proposals will be managed with the support of the council’s Minority Communities Officer, and the Communications team, and in particular emphasising that the plans are to increase overall affordable housing capacity which will benefit local residents as a whole within the City.	Positive	Low
Religion and belief		The proposals would support the housing position of Protected Characteristics Groups. Similar considerations would be given to the category of Race as noted above, as there is expected to be a large degree of overall of these Characteristics within the resettlement cohort.	Positive	Low
Sexual orientation		The proposals do not relate directly to sexual orientation. There are no known implications related to pregnancy and marriage.	Neutral	Low
Other Socio-economic groups including :		Could other socio-economic groups be affected e.g. carers, ex-offenders, low incomes?
Carer		The proposals do not relate directly to carers.	Neutral	Low
Low income groups		The proposals benefit low income groups. Affordable housing is more accessible to low income groups.	Positive	High
Veterans, Armed Forces Community		There is a high prevalence of homelessness among this socio-economic group and therefore the increased provision of affordable housing will impact this group.	Positive	Low
Other		The proposal has positive impacts for the Afghan refugee community and others requiring temporary accommodation within the city.	Positive	Medium
Impact on human rights:
List any human rights impacted.		The Universal Declaration of Human Rights (Article 14), which states that everyone has the right to seek and enjoy asylum from persecution in other countries. The provision of additional resettlement housing via the LAHF is in keeping with these protections.	Positive	Medium

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?

No adverse impacts have been noted above through the analysis however the projects will need to be managed thoroughly to ensure the benefits are realised. Affordability is critical to the delivery of the Council Plan’s objectives and therefore this will need to be monitored closely to ensure that these objectives are delivered. The proposal related to the LAHF will report to the Refugee and Asylum co-ordination group.

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
No major change to the proposals		The analysis demonstrates that the proposals are robust with no direct impact to individuals or communities with protected characteristics. However, the Housing Delivery Programme is committed to creating inclusive and welcoming communities and will work collaboratively with stakeholders throughout the design and development process to deliver against objectives and monitor and adjust to any failure to meet these outcomes.

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
Engagement events Willow House		Host regular events and engagement to engage stakeholders in the delivery process	Sophie Round	Spring 2024
Engagement with Refugee resettlement team		Meet regularly to ensure the homes purchased meet expectation of team and community	Sophie Round	Dec 2023 onwards
Engagement with Refugee and Asylum Coordination Group		Attend Group meetings at key points in the process to update and consult on acquisition strategy	Sophie Round	Dec 2023 onwards

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?

Continuous discussion and communication with residents and other stakeholders to identify and issues or improvement. Post occupation surveys to be carried out of new build projects to understand the outcomes for protected characteristic and marginalised groups. Fortnightly cross-department meetings to review progress. The project will also be reviewed by Housing Delivery and Asset Management Board on a monthly basis. The LAHF will be presented to Refugee and Asylum Coordination Group at key stages to consult and update on the acquisitions strategy.