City of York Council

Equalities Impact Assessment

Who is submitting the proposal?

Directorate:		Housing and Communities
Service Area:		Housing Delivery and Asset Management
Name of the proposal :		Disposals and Acquisitions Policy
Lead officer:		Andrew Bebbington
Date assessment completed:		26^th June 2024
Names of those who contributed to the assessment :
Name	Job title		Organisation	Area of expertise
Andrew Bebbington	Housing Strategy Officer		Housing Strategy and Performance at City of York Council	Housing
Kerry Courts	Sales and Asset Manager		Housing Delivery at City of York Council	Housing
Sophie Round	Housing Delivery Programme Manager		City of York Council	Housing

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.
	Establish policy for process of selling the lowest performing and most difficult council homes in order to purchase homes on the open market that will be easier and cheaper to maintain. The aim of the policy is to improve stock quality and where possible, increase the provision of social housing for vulnerable households

1.2	Are there any external considerations? (Legislation/government directive/codes of practice etc.)
	The ability to purchase homes will be subject to the external conditions of the housing market.

1.3	Who are the stakeholders and what are their interests?
	Internal stakeholders including Building Services, Housing Management, Housing Delivery and Carbon Reduction. External stakeholders will be the tenants and they will be interested in the quality and in the availability of council homes.

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.

The main outcome that this policy hopes to achieve is to improve the Housing stock of the council. This intention links to the Council Plans objective to increase the supply of quality affordable housing which will benefit our tenants. Additionally, the aim is to increase provision of the quality of the social housing for the most vulnerable tenants. For example, households where one or more of the tenants is disabled will benefit from homes that are accessible and can be adapted. This policy aims to do this by selling homes that would be more expensive to improve and replacing with newer homes and less difficult homes on the open market. Furthermore, the homes that the council are considering disposing of are older and more expensive to heat. The ability to sell and replace with newer homes that are more energy efficient will benefit our tenants as it will be more affordable to hear their homes. Another desired outcome is to increase stock where possible which will benefit our tenants and the wider community as there will hopefully be more social homes available.

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
Engagement work with tenants and residents has indicated that quality of homes and access to social housing are important priorities which are intended to be supported by this policy. Right to adequate housing is a human right that this policy aims to contribute to, and tenants have a clear desire for.		Tenant engagement is a good way to understand the desires of tenants.
The policy principles are reflected in the 2023-2028 Housing Asset Management and Energy Efficiency Retrofit Plan, which were approved by Executive in December 2022.		Senior council staff have support for this policy so there it clearly aligns with councils aims and priorities.
Local Housing Needs Assessment shows that there are a higher proportion of people who are disabled who are low income and therefore more likely to be a social housing tenant.		It shows that this policy will have an impact on people who are disabled. The aim to increase provision and improve quality of social housing will have a positive impact on disabled people.

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
Cannot guarantee there will always be homes available and affordable on the Housing market in the future.		Can base on housing market currently and keep up to date with any changes or predictions that could impact the policy. There is a re-purchase model that has been created.

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 proposals do not directly relate to age although increasing the accessibility of the council housing stock will help to support residents to remain independent in their homes as they age.	Positive	Medium
Disability		The proposals should have a positive impact on disabled people as there will be more council homes that will be appropriate for adapting to meet their needs.	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 do not relate directly to race. There are no known implications related to race.	Neutral	Low
Religion and belief		The proposals do not relate directly to race. There are no known implications related to race.	Neutral	Low
Sexual orientation		The proposals do not relate directly to sexual orientation. There are no known implications related to sexual orientation.	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. Improving quality and increasing the quantity of social homes will have a positive impact on this group.	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		None
Impact on human rights:
List any human rights impacted.		Should have positive impact on the right to adequate housing as the policy intends to improve quality of council homes. Replacing older, less energy efficient stock with newer homes that will be more affordable to heat and keep warm will improve standard of living as tenants will be more likely to use the heating. Fuel poverty impacts the ability of lower income households to heat their homes and damages their standard of living. More efficient homes will be cheaper to heat and reduce impact of fuel poverty, therefore improving tenant’s standard of living.	Positive	Low

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.

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. The Housing Delivery Programme is committed to creating inclusive and welcoming communities and will work collaboratively with stakeholders to ensure acquisitions improve the overall quality of housing stock and these will be closely monitored with feedback from tenant and wider housing teams to ensure the aspirations of the policy are realised.

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 and post-occupancy feedback		Monitor the acquisitions and obtain feedback from residents and housing and building services teams	Sophie Round	July 2024 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?
	Annual post-occupancy surveys for all homes acquired within a year with both internal and external stakeholders to help shape and evolve the policy. Annual policy review will be undertaken.