Guidance on equality analysis

City of York Council

Equalities Impact Assessment

Who is submitting the proposal?

Directorate:		City Development Directorate
Service Area:		Strategic Planning Policy
Name of the proposal:		Plan-making activity and Local Plan Review
Lead officer:		Alison Cooke – Head of Strategic Planning Policy
Date assessment completed:		30 March 2026
Names of those who contributed to the assessment:
Name	Job title		Organisation	Area of expertise
Alison Stockdale	Strategic Planning Policy Manager		City of York Council	Planning

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 purpose of this report is to present the forthcoming Plan-making activity being undertaken by City of York Council as well as presenting a proposal to refresh York’s Local Plan. This activity sets a framework for the future development of the area in relation to housing, the economy, community facilities and infrastructure – as well as considering how to conserve and enhance the natural and historic environment, mitigate and adapt to climate change, and achieve well designed places. The schedule includes starting a new Local Plan aligned to the new plan-making system from summer 2026. Documents supporting the Local Plan review are delegated for a decision to the Director of City Development; this includes updates to the timetable, consultation strategy, evidence base and submission of technical work through each statutory gateway. The Statement of Community Involvement, which sets out how we intend to consult on plan-making and planning decisions, is also presented for adoption. This sets out a flexible and bespoke approach to each plan-making process. Any consultation strategies are to be made via officer decision delegated to the Director of City Development.
1.2		Are there any external considerations? (Legislation/government directive/codes of practice etc.)
		Plan making activities must accord with the following legislation: Planning and Compulsory Purchase Act 2004 (as amended) Localism Act 2011 Levelling Up and Regeneration Act 2023 (LURA 2023) Planning and Infrastructure Act (PIA) 2025 Town and Country Planning (Local Planning) (England) Regulations 2026 The Neighbourhood Planning (General) Regulations 2012 The Neighbourhood Planning (Referendums) Regulations 2012 Under the Town and Country Planning (Local Planning) (England) Regulations 2026, Local Authorities are required to publish a Local Plan Timetable for the preparation of new plans. This is included within the plan-making activity schedule. A new National Planning Policy Framework expected in summer 2026 will provide the overarching policy context, with local plans expected to avoid duplication of national policy. This will dictate the content of plans. Statements of Community Involvement are a statutory requirement. Under the provisions of the Planning and Compulsory Purchase Act 2004, local authorities are required to update their adopted SCI every 5 years. Whist the Town and Country Plannign regulations are updating requirements for consultation, this presents a flexible approach to determine bespoke consultation and engagement startegies for planning policy purposes. The Equality Act 2010 provides a legal framework to protect the rights of individuals and advance equality of opportunity for all. It provides a discrimination law which protects individuals from unfair treatment and promotes a fair and more equal society. Under the Act, the Gypsy, Roma and Traveller community are specifically protected under the protected characteristics for ‘Race’.
1.3	Who are the stakeholders and what are their interests?
	Plan-making in York is relevant to anyone who lives, works or carries out business in the authority. This includes Local Communities, Voluntary and community Sector, officers at City of York Council and Planning Agents and Developer community. It also includes stakeholders, such as statutory consultees, who may have an interest in strategic planning in the city.
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.
	York is operating within a rapidly changing policy, economic, social, and environmental context. National reforms to the planning system, regional strategies through the York and North Yorkshire Combined Authority, and evolving expectations on a complex range of issues require the Council to maintain an up-to-date spatial framework. Our local policy will be able to set an effective spatial response that optimises benefits for communities. The activity schedule focuses on delivery and implementation of the adopted local plan, implementation of the Community Infrastructure Levy, continuation of Neighbourhood Plan making, the updated Statement of Community Involvement and initiation of a Local Plan Review. Each of these documents is subject to a separate decisions to proceed. Since preparation of the current adopted Local Plan there has been significant city-wide strategy development in York, articulated in the city’s collective vision set out in ‘York 2032: The 10-Year Plan’. The refreshed Local Plan must reflect the city’s strategic ambitions as articulated in York 2032 and related strategies on climate change, the economy, health and wellbeing, transport, skills and culture. The plan will provide a coherent basis for delivering sustainable development across the city.  All of the above need to shape the development plan for the city. The proposal directly reflects the core aims of the Council Plan (One City for All – 2023-2037), equalities, affordability, climate action and population health.

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[CAD1] [RJ2]		Reason for using
Statutory legislation (as set out in Section 1.2 above)		Sets the requirements and formal framework for plan-making
National Planning Policy Guidance		Provides guidance about the requirements
National Planning Policy Framework		National planning policy for England and how it should be applied
Public consultation		The new plan-making system includes a minimum of 3 statutory consultation stages which should be advised by a consultation strategy. The proposal allows for approval of the consultation strategy to be delegated to the Director of City Development; this will set out in detail stakeholder mapping, events and how consultation will be conducted. Preparation will be subject to iterative EIA and these will be published at each statutory consultation stage and/or when applicable.
York’s Adopted Local Plan (2025)		Provides the local policy framework against which the CIL, non-statutory guidance and neighbourhood Plans will be developed. This was subject to extensive consultation and public examination and is supported by evidence base, including iterative EIA.
Community Infrastructure Levy (2025)		City-wide consultation on the Community Infrastructure levy charging schedule was undertaken schedule has been undertaken. This was supported by evidence base, EIA and was subject to public examination prior to adoption in November 2025.
Neighbourhood Plans		These are subject to legislative and procedural requirements during their preparation prior to being ‘made’ by the council. Executive take the decision to ‘make’ a plan. EIA is undertaken and published for the ‘submission consultation’, when the Council start to lead the process, and published with Executive decisions.

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
Full details of the new plan-making system and revised NPPF are not yet available; these are being incrementally released by MHCLG.		Officers to keep up to date with changes in planning policy and guidance
Full impacts of the new Local Plan cannot be known until it has been progressed		Further information will be gained via public consultation at statutory stages and continued annual monitoring of the adopted Local Plan

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		For plan-making, there will be opportunities to engage with all age groups through various consultation stages; this will be outlined in forthcoming consultation strategies. Overall, the Local Plan and planning policy may consider age specific spatial policy; this is to be determined and will be reported on in the future.	+	L
Disability		For plan-making, there will be opportunities to engage and work with those who identify as either having an impairment or being a disabled person through various consultation stages; this will be outlined in forthcoming consultation strategies. The Local Plan and planning policy guidance may consider disability specific spatial policy; this is to be determined and will be reported on in the future.	+	L
Gender		This proposal is not expected to impact on that characteristic	O	N/A
Gender Reassignment		This proposal is not expected to impact on that characteristic	O	N/A
Marriage and civil partnership		This proposal is not expected to impact on that characteristic	O	N/A
Pregnancy and maternity		This proposal is not expected to impact on that characteristic	O	N/A
Race		For plan-making, there will be opportunities to engage and work with harder to reach groups such as gypsies and travellers. The timetable potentially proposes a new Supplementary Plan for Gypsy and Travellers relating to pitch design and site allocations. This would have a positive impact, subject to agreement for its production.	+	L
Religion and belief		This proposal is not expected to impact on that characteristic	O	N/A
Sexual orientation		This proposal is not expected to impact on that characteristic	O	N/A
Other Socio-economic groups including :		Could other socio-economic groups be affected e.g. carers, ex-offenders, low incomes?
Carer		This proposal is not expected to impact on that characteristic. However, there is potential for this group to be considered as part of future evidence base.	O	N/A
Low income groups		This proposal outlines the production on non-statutory guidance in relation to affordable housing which will support affordable housing provision. This will be considered in more detail when the guidance is presented for a decision.	+	H
Veterans, Armed Forces Community		This proposal is not expected to impact on that characteristic. However, there is potential for this group to be considered as part of future evidence base.	O	N/A
Other		This proposal is not expected to impact on that characteristic	N/A	N/A
Impact on human rights:
List any human rights impacted.		This proposal is not expected to impact on that characteristic	O	N/A

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?
There are no negative adverse impacts identified with this report and the recommendation to approve the plan-making activity timetable and Local Plan Review. Future EIAs will be developed to consider the detail of each of the documents included in the timetable and their impacts.

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. There are opportunities to advance equality and foster good relations through targeted and specific consultation in plan-making, which will be subject to continuing monitor and review.

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
Review of adopted Local Plan implications		Monitoring of adopted Local Plan and its impacts to inform future Local Plan production.	Alison Cooke	Annual
EIA of Local Plan review		Future EIA to consider the impact and implications of evidence base/ new and revised Local Plan policy	Alison Cooke	TBC – aligned to relevant stages of Local Plan production. EIA to be undertaken prior to statutory consultation and published as part of the suite of evidence.
Review of detailed Neighbourhood Plans when produced		Impacts of the detail of each NP to be considered prior to a decision being made.	Alison Cooke	TBC - aligned to plan production

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 Local Plan Timetable and Activity Schedule will be updated as necessary to ensure the plan-making timetable remains up-to-date. Iterative EIA will also be carried out to inform Local Plan preparation and will be published as part of statutory consultations and/or when relevant.

The adopted Local Plan (2025) policies will be monitored in accordance with an agreed monitoring framework and reported through the statutory Annual Monitoring Report. This will be used to inform the detail of future plan-making.

Once adopted it is anticipated that the new Local Plan will be monitored annually and reviewed every 5 years, in line with the Regulations.

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.