Equalities Impact Assessment (EQIA) – Partial Summary
Title of Policy
Local Living and 20 Minute Neighbourhoods draft guidance
Summary of aims and desired outcomes of Policy
The draft local living and 20 minute neighbourhoods guidance supports the delivery of the National Planning Framework (NPF4), adopted by the Scottish Ministers on 13th February.
Directorate: Division: team
Local Government and Housing Directorate
Planning, Architecture and Regeneration Division
Architecture, Place & Design Innovation team
The public sector equality duty requires the Scottish Government to assess the impact of applying a proposed new or revised policy or practice. Equality legislation covers the protected characteristics of: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion and belief, sex (gender) and sexual orientation.
NPF4 Policy 15 sets out policy principles on local living and 20 minute neighbourhoods. NPF4 forms part of the statutory development plan. The draft local living and 20 minute neighbourhood guidance aims to support the implementation of the existing policy framework within NPF4.
The preparation of NPF4 involved extensive consultation and parliamentary scrutiny. A Society and Equalities Impact Assessment, including an EQIA, was undertaken for NPF4 including content on Local Living and 20 minute neighbourhoods.
The draft guidance does not introduce any additional policy requirements or duties and is simply intended to provide additional details and clarifications of existing policy in order to support effective and efficient implementation. The draft guidance is therefore considered to be covered by the NPF4 EQIA. This report therefore only summarises the key issues to update and supplement the full assessment.
An EQIA aims to consider how a policy may impact, either positively or negatively, on different sectors of the population in different ways.
The Equality Act 2010 harmonised existing equality legislation and includes a public sector duty ('the Duty') which requires public authorities to pay due regard to then need to:
- Eliminate discrimination, harassment, victimisation or any other prohibited conduct;
- Advance equality of opportunity; and
- Foster good relations between different groups – by tackling prejudice and promoting understanding.
Stage 1 - Framing
Local living and 20 minute neighbourhoods are included within the policy framework of NPF4, adopted by the Scottish Ministers on 13th February. The concept of local living and 20 minute neighbourhoods is intended to support places where people can meet the majority of their daily needs within a reasonable distance of their home, preferably through active travel modes or by public transport.
NPF4 was the subject of extensive consultation and parliamentary scrutiny and an Integrated Impact Assessment (IIA), involving a number of statutory and non-statutory assessments including EQIA, was prepared for NPF4 and is available on the Transforming Planning website.
The policy intent and outcomes for local living and 20 minute neighbourhoods were included within this assessment process. Therefore, the impact of the policy has already been assessed and this report summarises and updates key content relevant to local living and 20 minute neighbourhoods gathered as part of the previous impact assessment process.
In preparing the Local living and 20 minute neighbourhood draft guidance, consideration has been given to impacts within the framing already provided by the NPF4 impact assessments, including the EQIA.
Stage 2 – Gather Evidence and Consult
The NPF4 Society and Equalities Impact Assessment, forms the basis for the consideration of equalities impacts of the draft local living and 20 minute neighbourhoods guidance.
The preparation of NPF4 involved extensive evidence gathering and consultation.
Between January and April 2020 the Scottish Government held an open call for ideas to hear views on what Scotland should be like in 2050 and the changes needed to get there.
A Position Statement was published in November 2020. This reflected on the information received through the call for ideas engagement programme.
Draft NPF4 was laid in the Scottish Parliament on 10 November 2021 for Parliamentary scrutiny. Alongside Parliament's consideration of the draft NPF4, the Scottish Government invited comments from all stakeholders. The public consultation was launched on 10 November 2021 and closed on 31 March 2022.
In addition, a public consultation will be undertaken for the draft local living and 20 minute neighbourhood guidance and questions relating to equalities factors will be included within it.
Stage 3 – Assess impact, identify mitigations
Key findings are contained with art A.3. of the Society and Equalities Impact Assessment and relevant issues are summarised here.
Age: The importance of considering the age characteristic in the development of places is recognised in the questions which form the Place Standard tool. It provides a simple framework for local people to assess the quality of a place and to help structure conversations about future improvement. It allows people to think about the physical elements of a place (for example its buildings, spaces, and transport links), as well as the social aspects (for example whether people feel they have a say in decision making).
Disability: Disabled people can participate as active citizens in all aspects of daily and public life. Disabled people to benefit from increased availability of affordable and accessible housing to support people to continue to life independent lives. Increased availability of accessible and inclusive transport and services.
Sex: In taking steps to meet the needs of women and men where these are different, particular issues are noted around the way that women and men use public places, such as access to local employment and community facilities and the safety of users of public spaces. In terms of removing or minimising disadvantages suffered by people due to this protected characteristic, NPF4 policy on local living provides an opportunity to shape places which act as complete, connected and compact neighbourhoods designed in such a way that all people can meet the majority of their daily needs within a reasonable walk, wheel or cycle of their home.
Pregnancy and Maternity: There is considerable evidence of beneficial effects of access to green space for the health of pregnant women. Responses to the NPF4: Call for Ideas noted that places that have not been designed to enable access by those with a variety of access needs become inaccessible, including for disabled women, carers, older women, pregnant women, and mothers of young children. Tackling issues around access to facilities and public spaces may be of particular concern to people with this protected characteristic.
Gender Reassignment: In a survey, less than one third of transgender and non-binary people said there were enough places where they could socialise safely. 54% of trans respondents avoided being open about their gender identity in 'the park' for fear of a negative reaction from others. A factor leading to non-binary people and women feeling uncomfortable in parks is the lack of public toilets. 55.4% highlighted that there were no toilets in the park they most frequently visited, and 35.8% of participants indicated that the provision of more toilets would encourage them to visit parks more frequently and for longer periods of time.
Sexual Orientation: It has been suggested that there is a spatial dimension to where the LGBT community lives in Scotland, with a focus of the community in large urban areas. Tackling issues around access and safety in public spaces may be of particular concern to this group of people.
Race. Respondents to the NPF4 Position Statement consultation highlighted the benefits of green space in terms of the wellbeing of communities, and cited evidence that lower income households and Black, Asian and minority ethnic communities are disproportionately impacted by loss of green space. It also went on to say that policy on 20 minute neighbourhoods should ensure diverse needs are taken into account, it was suggested that it will be important not just to focus on people living and working in a particular place but to connect to wider organisations – including those representing Gypsy/Travellers.
Religion or Belief: Responses to the Scottish Household Survey in relation to the national indicator on access to green or blue space, reveals that those responding as having no religion or as Christian were more likely to live within 5 minutes of a greenspace compared to those belonging to another religion. 63.61% of Christians, compared to those from other religions indicated they lived within 5 minutes' walk of their nearest green or blue space. Initial indication are that there is a similar degree of agreement (1/5 to 1/4) across religious groups that they could influence decisions affecting their local area.
Marriage and Civil Partnership. The planning system is not related to this characteristic.
Recommendations and Conclusion
The draft guidance does not introduce any additional policy requirements or duties and is simply intended to provide additional details and clarifications of existing policy in order to support effective and efficient implementation. The draft guidance is therefore considered to be covered by the NPF4 EQIA.
In developing the final guidance we will respond to comments on equality issues received through the consultation process, with particular reference to the points raised in the NPF4 EQIA.
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