City of York Council

Equalities Impact Assessment

Who is submitting the proposal?

Directorate:		Place
Service Area:		Environmental Services – Waste Services
Name of the proposal :		Subscription scheme for garden waste
Lead officer:		Ben Grabham; Head of Environmental Services
Date assessment completed:		28^th December 2023
Names of those who contributed to the assessment :
Name	Job title		Organisation	Area of expertise
Ian Hoult	Head of Fleet and Operations		City of York Council	Fleet/Operations
Rebecca Copley	Business Manager; Environmental Services		City of York Council	Business Management, Communications
Suzanne Middleton	Strategy and Development Manager		City of York Council	Strategy and Development, Business Processes

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 Council is considering adopting a subscription scheme for garden waste collections in York. This could see an annual charge introduced for kerbside garden waste collection in York.

1.2

Are there any external considerations? (Legislation/government directive/codes of practice etc.)

The collection of garden waste is not a statutory service and under the Controlled Waste Regulations 2012, the Council has the discretion to charge for this service. It is also important to point out that the Government consulted on its Waste and Resources Strategy in 2021 and a recent Government response in November 2023, outlined that “local authorities will be required to provide a garden waste service where it is requested but as is currently the case, they can continue to choose to charge for the service”.

1.3

Who are the stakeholders and what are their interests?

All residents of York are considered to be stakeholders. If a subscription service for garden waste collections is adopted then residents will have options to decide how they dispose of their garden waste; this could be subscribing to the kerbside garden waste service (for an annual charge), home composting and/or disposing of garden waste at a household waste recycling centre (for free). In addition, residents can also share a garden waste subscription with a neighbour.

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 part of the Council’s four core commitments and in line with the Council Plan:- · Equalities and Human Rights - Equality of opportunity – At this current time the garden waste service is not available to all households and the fact that some properties remain on a bagged waste service means we cannot provide garden waste collections to these properties. · Affordability – Whilst imposing a charge for garden waste collections may have some negative impacts for those on a low income there are environmentally friendly, cost effective and free alternatives to subscribing to a garden waste collection service such as home composting and/or disposal at a household waste recycling centre.  There is an option for members to approve a 50% discount on the subscription rate for the garden waste service where affordability may be an issue e.g. for residents in receipt of Council Tax Support. · Climate - Environment and the climate emergency – Reducing the mileage and making the service more efficient through optimising collection routes and rounds will have benefits for the environment and carbon and other emissions will be reduced. By focussing collections in an area of the city will enable a review of the way public realm management and service delivery is undertaken. Reducing the number of properties on a bagged collection is expected to increase levels of recycling in those areas

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
Comparison to other local authorities		Over 70% of local authorities in England charge for garden waste collections at the kerbside. More local authorities, like York are considering introducing a charge for garden waste collections as it is not a statutory service. In terms of a local context, all other authorities in North Yorkshire charge for garden waste collections.

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 Council knows which households currently receive garden waste collections from the kerbside (circa 66,000 households).   · The Council does not know which households compost garden waste at home as this is individual choice.		The Council can monitor how much garden waste is collected at the kerbside and can also monitor garden waste collected at household waste recycling centres. The Council can also monitor how many home composters are purchased (through the Council). It will be important for this monitoring to continue so that the impact of any scheme can be effectively assessed.

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		Any residents who receive an assisted collection for their bins will continue to receive this if they subscribe to the service.	(0)
Disability		Any residents who receive an assisted collection for their bins will continue to receive this if they subscribe to the service	(0)
Gender		n/a	(0)
Gender Reassignment		n/a	(0)
Marriage and civil partnership		n/a	(0)
Pregnancy and maternity		Any residents who receive an assisted collection for their bins will continue to receive this if they subscribe to the service	(0)
Race		n/a	(0)
Religion and belief		n/a	(0)
Sexual orientation		n/a	(0)
Other Socio-economic groups including :		Could other socio-economic groups be affected e.g. carers, ex-offenders, low incomes?
Carer			(0)
Low income groups		There could be a 50% discount available on the subscription rate for the garden waste service for residents . Residents could also share a garden waste subscription with their neighbours if they so wish as a means to reduce cost. If residents do not wish or cannot afford to subscribe to the garden waste subscription service, then there are other alternatives which are available for the free disposal of garden waste (e.g. home composting and/or disposal at a household waste recycling centre).	(-)	(L)
Veterans, Armed Forces Community			(0)
Other		Residents who do not have a vehicle and cannot access the household waste recycling centre can either compost garden waste at home or share a garden waste subscription with a neighbour.	(-)	(L)
Impact on human rights:
List any human rights impacted.		n/a

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 options for alternatives to subscribing to the garden waste subscription service have been identified throughout the document. By moving to a subscription service, the Council will be able to extend the offer of a garden waste service to more properties across the city (as the current service is at capacity). In addition, moving to a subscription service will allow the Council to generate an income to cover the cost of providing the garden waste service (which is much valued by householders) and help to protect other services delivered by the Council.

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 proposal – the EIA demonstrates the proposal is robust.		Introducing a subscription charge for the garden waste service is a relatively low charge, as it is an annual charge for service. Residents have a choice as to whether they subscribe to the garden waste subscription scheme or not. There could be a 50% discount available on the subscription rate for the garden waste service for residents where affordability may be an issue e.g. for those in receipt of Council Tax Support. If residents do not wish or cannot afford to subscribe to the garden waste subscription service, then there are other alternatives which are available for the free disposal of garden waste (e.g. home composting and/or disposal at a household waste recycling centre). Residents could share a garden waste subscription with their neighbours if they so wish as a means to reduce cost.

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?

· The Council will review the number of households that subscribe to the garden waste subscription service and any discounts if approved by Executive. · The Council will also continue to monitor the amount of garden waste that is collected at the kerbside alongside the amount of garden waste that is taken to the household waste recycling centres in the city. · The Council will keep a record of home composters that are purchased through the Council.  · The Council will monitor if there is an increase of incidence of fly tipping of garden materials.