Impact Needs/Requirement Assessment Completion Form
Department:Environment and Culture / Person Responsible:Planning Policy OfficerService Area:Planning Service / Timescale for Equality Impact Assessment :
Date:12 November 2008 / Completion date:
12 November 2008
Name of service/policy/procedure/project etc:
Local Development Framework – Core Strategy / Is the service/policy/procedure/project etc:
New
Old
Predictive
Retrospective / Adverse impact
Not found
Found
Service/policy/procedure/project etc, amended to stop or reduce adverse impact
Yes No
Is there likely to be a differential impact on any group?
Yes No / Please state below:
- Grounds of race: Ethnicity, nationality or national origin e.g. people of different ethnic backgrounds including Gypsies and Travellers and Refugees/ Asylum Seekers
Yes No /
- Grounds of gender: Sex, marital status, transgendered people and people with caring responsibilities
Yes No
- Grounds of disability: Physical or sensory impairment, mental disability or learning disability
Yes No / 4. Grounds of faith or belief:
Religion/faith including
people who do not have a
religion
Yes No
- Grounds of sexual orientation: Lesbian,
Yes No /
- Grounds of age: Olderpeople, children andyoung People
Yes No
Consultation conducted
Yes No
Person responsible for arranging the review:
Alice Ng / Person responsible for publishing results of Equality Impact Assessment:
Members of the Policy and Research Team
Person responsible for monitoring:
Members of the Policy and Research Team / Date results due to be published and where:
15th December 2008 Councils Executive
Signed: / Date:
Please note that you must complete this form if you are undertaking a formal Impact Needs/Requirement Assessment. You may also wish to use this form for guidance to undertake an initial assessment, please indicate.
1. What is the service/policy/procedure/project etc to be assessed?The development plan document to be assessed here is Brent’s Core Strategy, the parent document in the Borough’s emerging Local Development Framework (LDF).
2. Briefly describe the aim of the service/policy/procedure/project etc? What needs or duties is it designed to meet? How does it differ from any existing services/ policies etc in this area
Brent is statutorily obliged to prepare a Local Development Framework (LDF)by the Planning and Compulsory Purchase Act 2004. The LDFiscomprised of various local development documents and they will ultimately replace the existing Unitary Development Plan (UDP) when adopted. The LDF development documents collectively will form a holistic planning framework for future developmentsin Brent for the next 15 years.
The Core Strategy is the prime development plan document in the LDF. It sets out a visionfor the future of Brent and sets out a strategy as to how the vision will be delivered through planning and managing developments. It is also the first development plan document being prepared in Brent’s LDF. Two further development plan documents,known as Site Specific Allocations and Development Management Policies, are being prepared also.
The requirement for a new spatial LDF is distinct from theexisting UDP in that it:
- Promotes equality by encouragingearly and widercommunity engagement
- Emphasis on joint working partnerships to achieve share objectives
- Expressively links policies tostrategies and programmes to ensure coherency
- Hasgreater local focusand less of a land- use basedapproach to development
- Contributes more effectively to sustainable development including good design
3. Are the aims consistent with the council’s Comprehensive Equality Policy?
The vision andobjectives in the Core Strategy stem from the borough’s Sustainable Community Strategy and Corporate Strategy, which have integrated Brent’s equality policies, ensuringthe provision of services meet the needs of all sections of the community and minimise exclusion.
4. Is there any evidence to suggest that this could affect some groups of people? Is there an adverse impact around race/gender/disability/faith/sexual orientation/health etc? What are the reasons for this adverse impact?
The plan area covers the entire borough and will have an influence on all residents and communities in Brent. However, there is no evidence suggesting that the Core Strategy causes significant adverse impact. More importantly Brent’s Core Strategy is geared towards reducing discrimination for diverse groups and has recognised the specific demandsof these groups, for example the need for new schools and health facilities, that it set out a specific objective to ensure they will be met.
5. Please describe the evidence you have used to make your judgement. What existing data for example (qualitative or quantitive) have you used to form your judgement? Please supply us with the evidence you used to make you judgement separately (by race, gender and disability etc).
Objectives and policies in the Core Strategy have been developed through studying the deficiencies and needs of the local community arising from new developments in the borough. The needs of different diverse sections of the community such as low income group, gypsy/ traveller communities, disabled people, ethnic minority groups, the elderly, are assessed by analysing survey data and findings from research studies includeCensus data, Housing Needs Assessment 2003, Household Shopping Survey 2003, Housing Development and Education Need Study 2004, Housing and Child Yield Projections and Annual Employment Level.
A full list of evidence informing the Core Strategy can be viewed via .
6. Are there any unmet needs/requirements that can be identified that affect specific groups? (Please refer to provisions of the Disability Discrimination Act and the regulations on sexual orientation and faith, Age regulations/legislation if applicable)
Objectives and policies in the Core Strategy aredeveloped on robust evidence bases. Over-optimised objectives and unrealistic policy options have been scrutinised and amended through a Sustainability Appraisal early in the plan- making process. So far there is no evidence to suggest that identified needs in the Core Strategy are unlikely to be met and that it would adverselyaffect specific groups.
7. Have you consulted externally as part of your assessment? Who have you consulted with? What methods did you use? What have you done with the results i.e. how do you intend to use the information gathered as part of the consultation?
The Core Strategy had undergone four rounds of consultation. To date, the following full publicconsultations have been carried out:
- Aug/ Sept 2008 Pre-submission for Core Strategy
The consultation ended on15th September andofficers are currently in the process of recording and analysing comments. The Council will take on board all comments received and revise the Core Strategyaccordingly for a further round of formal public consultationthe resubmission. All of the comments received will be made available on the Council’s website for viewing prior to the formal submission of Core Strategy.
- Nov/ Dec 2007 - First Submission for Core Strategy
Although the Core Strategy was eventually withdrawn from the Examination early this year, the consultation results at this stage were taken into consideration inrevising the Core Strategy to form thepre-submission version.
- Oct/ Sept 2006 – Preferred Options for Core Strategy
All statutory bodies required by the regulations were consulted. A full range of resident and borough-wide groups and interested parties were also invited to respond by letter. The consultation document was made available at all local libraries and one stop service offices for public inspection. The consultation information was published in two local newspapers as well as the Borough magazine. The findings from the consultation fed into the first submission version of the Core Strategy.
- Oct 2005 - Issues & Options
A series of questionnaire papers on the 12 topic areas weredistributed throughout Brent libraries, local One Stop Shop offices and local area consultative forums for the general public to read and respond to. Additionally, a questionnaire was developed and published in the Brent Magazine which was circulated to approximately 99,000 households, libraries, one stop shops andsports centres in Brent. The Topics for Issues & Options Papers were - A New Plan for a Better Brent ; Strategic Planning Objectives and Priorities ; A Better Townscape By Design ; Environmental Protection ; Planning for More and Better Housing ; Transport ; Employment ; Town Centres and Shopping ; Leisure and Tourism ; Open Space and Biodiversity ; Community Facilities ; Waste. The Issues and Options papers included a monitoring sheet so that respondents could be analysed by gender, age, ethnicity and disability.
A questionnaire was also included in Brent magazine which offered an entry into a prize draw to respondents. The questionnaire was made available alongside an exhibition at Brent Respect Festival.
Views expressed in this consultation,together with evidence and findings from variousstudies have been taken into account and incorporated indrafting the Preferred Options version of the Core Strategy.
In all the rounds of consultation a bespoke consultation system called Limehouse has been used. This enables comments to be made online and for those comments to be made publicly accessible on-line as well.
8. Have you published the results of the consultation, if so where?
All comments received in each round of consultation are recorded and published on the Local Development Framework web page. Please visit the LDF web page to view the comments via this link –
9. Is there a public concern (in the media etc) that this function or policy is being operated in a discriminatory manner?
There hasbeen no adverse media coverage of the draft Core Strategy or the consultation process in the local paper or the national papers. However, objections have been received from different sections of the local community to aspects of the strategy. This is a normal part of the planning process and all objectors will have the opportunity to present their case to an independent inspector when the Core Strategy is subject to public examination.
10. If in your judgement, the proposed service/policy etc does have an adverse impact, can that impact be justified? You need to think about whether the proposed service/policy etc will have a positive or negative effect on the promotion of equality of opportunity, if it will help eliminate discrimination in any way, or encourage or hinder community relations.
The Core Strategy is different to the existing UDP in many ways. In particular it ensures there is a consistency with other local strategies includingthe Council’s equality policy to promote equal opportunities and diversity in employment and service delivery. A wide community engagement early in the preparation of the Core Strategy also means diverse groups have been given more opportunities to express their views in shaping future Brent. More detailed studies helpto develop some finerobjectives and policies in the Core Strategy to meet specific needs and demands in the borough. All of these suggest that the proposed policies in the Core Strategy will have a positive effect on the promotion of equality of opportunity and help eliminate discrimination.
11. If the impact cannot be justified, how do you intend to deal with it?
The effectiveness ofthe Core Strategy,and its performance in meeting the needs of Brent’s local community, will be regularly monitored through the production of an Annual Monitoring Report (AMR). The outcomes in this report should help to justify the need for change of approach in the Core Strategy should adverse impacts be identified.
12. What can be done to improve access to/take up of services?
The Core Strategy will be subject to another round of public consultation before it is resubmitted to Secretary of State for examination andfor Council adoption in 2010. This will continue to use a response form toseek information on gender, ethnicity, age and disability for monitoring purpose. The information is used, in part,to confirm that the consultation process isnot discriminatoryone or another equality group.While hard copies of documents have been and will continue to be provided at local libraries, access to electronic copies of the consultation documents on the Council’s LDF website have been further improved. The planning service also intents to set up a LDF social group on a popular web-based network to further engage targeted groups, in particular young people.
13. What is the justification for taking these measures?
Analysing equality information collected from the monitoring form has providedgood indicationofgroups that may be under-representing in the consultations. Findings from the analysis of equality information in early consultations suggested there had been a low response rate received from age group at age 15 to 24 duringthe early consultation stage in the LDF document making process. (See attachment)
14. Please provide us with separate evidence of how you intend to monitor in the future. Please give the name of the person who will be responsible for this on the front page.
The equality monitoring form will continue be used as a monitoring tool,and information will be analysedby the Policy and Research Team of the Planning Service to identify weaknesses in promoting equality in the consultation process.
The Annual Monitoring Report (AMR) is another key tool to identify the performance of policies in the Core Strategy and its strategic planning framework. The AMR is prepared and published by the Policy and Research Team. Outcomes from AMRs are crucial and help justifying the need for changesof planning framework in the Core Strategy should policies no longer supports promotion of equality.
15. What are your recommendations based on the conclusions and comments of this assessment?
Results from this screening exercise suggest that both the plan making process and the proposed policies in the Core Strategy itself will encourage and promote equality. Further efforts will be made to involve ‘hard to reach’ groups in the plan-making process.
Should you:
- Take any immediate action?
- Develop equality objectives and targets based on the conclusions?
- Carry out further research?
16. If equality objectives and targets need to be developed, please list them here.
N/A
17. What will your resource allocation for action comprise of?
There will be time and staff resource implications to prepare and produce the Annual Monitoring Report, as well as making arrangements for consultation. This will make use of existing staff resources
If you need more space for any of your answers please continue on a separate sheet
Signed by the manager undertaking the assessment:
Full name (in capitals please):Date:11/11/2008
KEN HULLOCK
Service Area and position in the council:
The Planning Service Policy and Research Team
Details of others involved in the assessment - auditing team/peer review:
Alice Ng - Senior Planning Officer
Once you have completed this form, please take a copy and send it to: The Corporate Diversity Team, Room 5 Brent Town Hall, Forty Lane, Wembley, Middlesex HA9 9HD