City of York Council

Equalities Impact Assessment

Who is submitting the proposal?

Directorate:		Housing & Communities
Service Area:		Housing Delivery
Name of the proposal :		Delivering More Affordable Housing in York – update on the Housing Delivery Programme
Lead officer:		Sophie Round
Date assessment completed:		14/08/2025
Names of those who contributed to the assessment :
Name	Job title		Organisation	Area of expertise
Charlotte Bates	Housing Development Manager		CYC	Housing 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.

The paper seeks to establish a construction budget and enter a build contract to deliver 101 homes at Ordnance Lane as an 100% affordable, net-zero carbon development and apply to Homes England for funding to deliver Shared Ownership properties; seek authorisation to procure a development partner for Willow House and Lowfield A; seek approval to deliver wider area regeneration work in on HRA land within South Walmgate using the newly established Neighbourhood Improvement Programme; seek to develop a strong new build pipeline with a budget to commence design work on Former Manor School, and submit a planning application; note that grant funding bids will be submitted to YNYMCA Brownfield Fund for Castle Mills, Former Manor School, Morrell House and 68 Centre.

1.2	Are there any external considerations? (Legislation/government directive/codes of practice etc.)
	. The Homes England Social and Affordable Homes Programme (SAHP) sets eligibility criteria for the Shared Ownership properties funded 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 business within existing neighbourhoods surrounding Ordnance Lane, Willow House, Lowfield A, and Manor School site

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 development and delivery of affordable housing across the City 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. Lowfield Plot A proposes to deliver specialist housing for adults with learning disabilities and/or autism. 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, key workers, and adults with learning disabilities and/or autism. 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 deliver high levels of affordable housing and 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 from the Willow House events has resulted in working collaboratively with the local community to codesign the planning application.
Stakeholder events at Lowfield Plot A		To date three events have taken place, two with people with lived experience of learning disabilities and autism and one for neighbours to scheme. The events will inform the future scheme refinement.
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 which is considered during each projects design phase. A good balance of smaller and larger properties to ensure a wide housing need is addressed by these developments

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 Willow House or Lowfield A. 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.
Engagement with Former Manor School residents, and neighbouring British Sugar site, Morell House and 68 Centre residents is needed as designs are developed to ensure a collaborative approach is taken.		Arrange engagements events at the relevant time within each project.

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. Lowfield A is providing specialist housing for adults with learning disabilities and/or autism	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 do no relate directly to religion and belief. There are no known implications related to religion and belief.	Neutral	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
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?
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 negative 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 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 at pipeline sites		Host regular events to engage stakeholders in the delivery process	Sophie Round	Spring 2026

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.