KENT COUNTY COUNCIL
EQUALITY ANALYSIS / IMPACT ASSESSMENT (EqIA)
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Directorate:Growth, Environment and Transport (GET)
Name of policy, procedure, project or service
Gypsy and Traveller Service newservice charge
What is being assessed?
Introduction of a new service charge for all plots on KCC-owned or managed gypsy and traveller sites from 2018.
Responsible Owner/ Senior Officer
Pal Sandher
Date of Initial Screening
04/08/2017
Date of Full EqIA:
Version / Author / Date / Comment0.1 / Ian Lofting / 04.08.2017
0.2 / Pal Sandher / 07.11.2017
0.3 / Akua Agyepong / 8/11/2017 / Sent to PS for comment and review 9/11/2017
0.4 / Pal Sandher / 9/11/2017
0.5 / Akua Agyepong / 10/11/2017 / Comments for review
0.6 / Pal Sandher / 10.11.2017
0.7 / Pal Sandher / 13.11.2017
0.8 / Mike Overbeke / 13.11.17 / Agreed, No further comments from me
0.9 / Katie Stewart
Screening Grid
Characteristic / Could this policy, procedure, project or service affect this group less favourably than others in Kent? YES/NOIf yes how? / Assessment of potential impact
HIGH/MEDIUM
LOW/NONE
UNKNOWN / Provide details:
a) Is internal action required? If yes what?
b) Is further assessment required? If yes, why? / Could this policy, procedure, project or service promote equal opportunities for this group?
YES/NO - Explain how good practice can promote equal opportunities
Positive / Negative / Internal action must be included in Action Plan / If yes you must provide detail
Age / YES / High / Medium / YES. There is the need to identify whether those on benefits can have some or all of the proposed service included in their benefit claim. / NO
Disability / YES / Medium / Medium / YES. There is the need to identify whether those on benefits can have some or all of the proposed service included in their benefit claim / NO
Gender / NO / Medium / Medium / YES. There is the need to identify whether those single mothers on benefits can have some or all of the proposed service included in their benefit claim / Females make up the majority of applicants and licence holders for our pitches.
Gender identity / NO / None / None / No further assessment required. / NO
Race / NO / High / Medium / No further assessment required. / YES. The sites managed by the Gypsy and Traveller Service are specifically for those from within these communities and the new charge will improve the quality of the sites on which they live in line with the housing sector provision.
Religion or belief / NO / None / None / No further assessment required. / NO
Sexual orientation / NO / None / None / No further assessment required. / NO
Pregnancy and maternity / NO / None / None / Not applicable within this process / NO
Marriage and Civil Partnerships / NO / None / None / Not applicable within this process / NO
Carer's responsibilities / No / None / Low / No further assessment required at this time. We are aware that caring goes on within this community but they do not always claim carer’s allowance. Our staff will encourage the take up of carer’s allowance. / Yes. Our Officers will assist families to apply for carer’s allowance.
Part 1: INITIAL SCREENING
Proportionality – From the Risk Matrix which has been completed above, the initial screen suggests that the potential for a negative impact on certain protected characteristics as a result of implementingthe new service charge is MEDIUM.
Low / Medium / HighLow relevance or Insufficient information/evidence to make a judgement. / Medium relevance or Insufficient information/evidence to make a Judgement. / High relevance to equality, /likely to have adverse impact on protected groups
Context
The service charge will be implemented for each plot, with the same level of charge applied irrespective of which site the plot is on. This policy is proposed to promote equity amongst our KCC sites.The service charge will bring our service in line with the housing sector the introduction of a flat charge is unique to our service and service provision. However, consideration was given to not proposing a service charge. However, based on KCC’s current financial situation, the year on year increases in costs to the service and the need to prepare for growing demand and expensive refurbishment and site improvements, such an option was not viable. The charge will be reviewed annually and aims to cover the costs of maintaining the sites and plots. Most housing providers include a service charge for their accommodation and this change will bring us further in line with the national practice and will allow KCC to invest in the fabric of our sites and raise standards.
Aims and Objectives
The principal aim of this new policy is to improve the standard of living for those on the Gypsy and Traveller sites managed by the Gypsy and Traveller Service.It will allow the service to invest in the upkeep and improvement of its sites to meet modern day standards. This will enable the service to continue to provide public gypsy and traveller sites in future. The introduction of a service charge will allow for investment for the future provision and longevity of our sites.
Beneficiaries
The key beneficiaries of this change will be the tenants and those visiting family members on our sites.
Information and Data
The KCC Gypsy and TravellerService currently manage 10 sites across Kent, although applications and licences for the two Maidstone sites are administered by Maidstone Borough Council. These ten sites have a total of 163 plots; 131 x KCC, 32 x Maidstone Borough Council. The information below covers our KCC sites and for safeguarding and data protection reasons the data has been anonymised.
During a census in December 2016 we identified 343 occupants on our KCCsites.
KCC G&T Sites / Adult Males / Adult Females / Children / Children / Adults (65+) / Disabled (DLA) / Race English Romany / Race Irish Traveller(16+) / (16+) / (0-4) / (5-16)
TOTALS / 23% / 37% / 16% / 24% / 9% / 3% / 83% / 17%
Involvement and Engagement
Engagement with the communities impacted by the site charge will begin 14/11/17 when a five and half week consultation exercise will commence. Our site managers have regular dialogue with our site residents about their wish to have improvements and better facilities on site and this has better informed the need for change. Currently all our sites are below market value and are in essence subsidised. This increase is necessary to ensure the survival of these sites continues. The alternative is we could be forced to close sites down. The consultation will establish views and concerns. In addition, KCC will be engaging with the affected six benefits departments to discuss approximately 131 householdscurrently on housing benefit administered by these local authorities.This consultation and engagement processwill take place before the new charge is operational in spring 2018.
Potential Impact
After completing the assessment, it is evident that the proposed service chargemay have an impact on the Gypsies and Travellers living on the KCC sites. Implementation is expected to negate any adverse issues as tenants adjust to those changes.
Adverse Impact:
The initial screening grid demonstrates that the change could have a medium adverse impact on those tenants who struggle financially. It is expected that those on benefits will have the service charges paid as with rental, initial contact with the district and borough councils is that they will do recalculations of benefit to determine awards on an individual basis. For those not, assistance in financial planning will be made available through the site managers.They will look at those who have difficulties with managing their finances and with those that find it hard to budget for other reasons. There is a potential for enforcement action being taken against residents possibly leading to eviction action being taken.
Positive Impact:
Thischarge will aim to provide the tenants with a higher standard of living than they have enjoyed over many years and will provide much needed new income to invest in the upkeep and improvements to the fabric of the sites and plots for years to come.
JUDGEMENT
Option 2– Action Plan required
We fully recognise there may be some adverse impact as this is a major policy change to introduce the service charge which is within the licence agreement as such KCC will need to consult.
Action Plan (Delete if option 1 is agreed)
The Action Plan
Protected Characteristic / Observations made / Action to be taken / Expected outcomes / Owner / Time Scales / Cost ImplicationsAction Plan prior to implementation
Age / See screening above / Ascertain with benefits providers (see above) whether charge can be covered by them Initial contact has revealed that calculations will be made by the providers on an individual basis to determine level of benefit award. / If yes, then no action required other than to confirm amounts.
If no, then need to revisit service charge amounts to consider delayed implementation, discounting etc. / Pal Sandher / November 2017 / Nil
Disability / See screening above
Gender / See screening above
On-going Action Plan
EqIA monitoring / Need to ensure no characteristic is negatively impacted due to the charge / Revisit when service charge is reviewed annually / Any implications affecting the characteristics are identified and addressed. / Ian Lofting / 1 April 2018 / Nil
EqIA monitoring / Our site managers will engage with site residents / Engagement for those requiring help with financial planning and assistance around payment / This will help those that need it with targeted and direct action to mitigate the risks / Pal Sandher / 1 April 2018
Monitoring and Review
The EqIA will be reviewed at the three year stage, or earlier if circumstances require it.
Sign Off
Senior Officer
Signed: Name:Pal Sandher
Job Title:Head of Gypsy and Traveller ServiceDate:
DMT Member
Signed: Name: Mike Overbeke
Job Title: Group Head - Public ProtectionDate: