Equality Impact Assessment Record - Guidance on Safer Public Places
Title of policy/ practice/ strategy/ legislation etc.
Coronavirus (COVID-19): Safer Public Spaces for Scotland Urban Centres and Green Spaces
Cabinet Secretary for Communities and Local Government
Officials involved in the EQIA
Architecture and Place
Directorate: Division: Team
DLGC: Planning and Architecture: Architecture and Place
Is this new policy or revision to an existing policy?
New guidance adapted from MHCLG guidance
The screening of the policy shows that any people using urban centres and green spaces can potentially be affected (directly or indirectly) and so an EQIA is required.
The guidance provides information and examples of interventions with the aim of keeping people safe in urban centres and green spaces and supporting physical distancing during the coronavirus pandemic, and as lockdown eases.
It is intended primarily for owners and operators of public places including, but not limited to, local authorities, town centre managers, landowners, and commercial landlords.
In order to support physical distancing, and to reduce the chance of transmission of the coronavirus (COVID-19), changes are required in terms of both the management and physical layout of many urban and green spaces.
The safer places guidance focuses primarily upon areas of high footfall and provides a framework for identifying issues.
Who will it affect?
The guidance can potentially impact upon all people who pass through or use urban centres and green spaces.
What might prevent the desired outcomes being achieved?
The guidance provides information and examples of interventions that may be undertaken, but it does not impose any legal obligations.
It depends on the goodwill and co-operation of both owners and operators and the users of their spaces.
Lack of resources to carry out measures.
Stage 1: Framing
Results of framing exercise
The provision of temporary interventions aimed at supporting physical distancing introduces elements of unfamiliarity into the built environment. The framing exercise identified concerns about the extent to which people with disabilities, older people and people with prams and buggies might be affected by any temporary measures and interventions.
In adapting and building upon the guidance prepared by the Ministry of Housing, Communities and Local Government (MHCLG), particular attention has been paid to any gaps therein with regard to addressing the needs of disabled people and elderly people.
A Health Impact Scoping of the MHCLG guidance has been completed by members of the Public Health Scotland System Recovery: Environments and Spaces Group which set out populations and health determinants likely to be affected by the guidance.
This noted that a range of users will be affected including pedestrians, cyclists, wheelchair users, parents with buggies or prams and car users. The use of space could be for a number of reasons including travel, exercise and play/recreation.
An opportunity has also been taken to consider ways in which advice on interventions can also support long term benefits for health across Scotland’s population. Consequently, an Active Travel section has been introduced, which aims to support wider behavioural change with related benefits in this regard.
The underlying intention throughout the guidance is for it to act for the benefit of all users of public space in Scotland. A key issue within the guidance was therefore to make it clear to owners and operators of public spaces that taking an inclusive approach to any required interventions is essential, and that it is important to consider the needs of all street users, including people who have difficulty walking, wheelchair users, and people with cognitive impairments, including dementia, blind and deaf people.
Extent/Level of EQIA required
The Scottish document is based upon guidance first produced by the Ministry of Housing, Communities and Local Government (MHCLG). In adapting this for Scotland, the opportunity was taken to pro-actively address any potential impacts upon equality issues that had not been covered in the original guidance.
An accelerated timescale due to the exceptional urgency of the need for this guidance during the pandemic precluded the hosting of framing workshops but, within the timeframe available, every effort was made to include those key issues raised by consultees that were directly applicable and to capture the principles and intentions put to us throughout.
The guidance will shortly be updated as Scotland moves forward in relation to its route map through and out of the crisis. As we do so, the opportunity will be taken to revisit comments made to us and to review any potential impact upon protected characteristics of our progress through the route map.
However, as each individual intervention will be specific to an area with unique characteristics, each individual project will require a EQIA to consider any implications for people with one or more of the protected characteristics.
Stage 2: Data and evidence gathering, involvement and consultation
Include here the results of your evidence gathering (including framing exercise), including qualitative and quantitative data and the source of that information, whether national statistics, surveys or consultations with relevant equality groups.
|Characteristic|| Evidence gathered and
Strength/quality of evidence
|Source||Data gaps identified and action taken|
|Age|| The prevalence of disability rises with age. Around 6% of children are disabled, compared to 16% of working age adults and 45% of adults over State Pension age. (UK data).
Children and young people in family groups may require additional space.
| Family Resources Survey 2010/11
|Disability||There is strong evidence that people with reduced mobility, blind and visually impaired, hearing impaired and people with cognitive impairments may be affected by this policy.|| Mobility and Access Committee document: https://www.transport.gov.scot/media/47546/temporary-street-measures-during-the-coronavirus-crisis.pdf
Scottish Parliament Petition – PE01595 – supporting documents.
Interim outputs from Inclusive Design research (not yet published)
|Sex||There is evidence that women feel less safe in public spaces.||https://www.engender.org.uk/content/publications/Engender-response-to-the-Scottish-Government-consultation-on-Scotlands-National-Transport-Strategy.pdf|
|Pregnancy and maternity|| Pregnant women may find standing difficult and require facilities to sit down.
People with prams and pushchairs may require accessible pavements (dropped kerbs) and more space to maintain physical distancing.
| Health Impact Scoping Paper:
|Gender reassignment||No evidence of any issue that would be particular to interventions as result of the policy.|
|Sexual orientation||No evidence of any issue that would be particular to interventions as result of the policy.|
|Race||No evidence of any issue that would be particular to interventions as result of the policy.|
|Religion or belief||No evidence of any issues that would be particular to interventions as result of the policy.|
|Marriage and civil partnership||No evidence of any issues that would be particular to interventions as result of the policy.|
Stage 3: Assessing the impacts and identifying opportunities to promote equality
The guidance recognises and emphasises that people who have impaired mobility, and those who are visually or cognitive impaired may be disproportionately affected in their ability to navigate public places unless owners and operators are alert to their needs.
An overarching issue impacting upon decisions around the use and management of public space during, and coming out of, the pandemic, is that more space is required for people walking, wheeling and cycling, including while queuing. The needs of children, young people and their families are also considered, for example space for people with prams and buggies.
Stage 4: Decision making and monitoring
Identifying and establishing any required mitigating action
Have positive or negative impacts been identified for any of the equality groups?
The guidance is intended to have a positive impact on equality groups, potentially disadvantaged by both physical and operational responses to the need for physical distancing in public places due to the pandemic.
Is the policy directly or indirectly discriminatory under the Equality Act 2010?
If the policy is indirectly discriminatory, how is it justified under the relevant legislation?
If not justified, what mitigating action will be undertaken?
Describing how Equality Impact analysis has shaped the policy making process
The views of Disability Equality Scotland, the Mobility and Access Committee for Scotland (MACS) and the Royal National Institute of Blind People (RNIB) were sought, and the guidance sets out a range of measures that are required in order to help support the needs of disabled people and older people. Some of the key considerations include:-
- establishing a pedestrian corridor that is free of obstacles and allows for physical distancing (though remaining aware of the continued need for seating for older people) with access to dropped kerbs and tactile paving provided where required;
- providing space for regular, safe, formal and informal road crossing points;
- ensuring that any additional signage or markings provide colour and tonal contrast to enable accessibility;
- providing seating to meet the needs of disabled people and older people, who may not be able to stand for long, in the provision for queuing;
- emphasising to place owners that not all disabilities are visible and to give thought to this;
- segregating pedestrians from cyclists to reduce potential conflict between street users. This is particularly important for visually impaired people; and
- maintaining access to parking for disabled people when considering changes to parking arrangements and street layouts
Links to sources of accessible communication of information relating to changes in transport and infrastructure will be added to forthcoming updated guidance.
There may be additional costs for the implementation of this policy, which will be met by local authorities and land owners under their equality duties. Additional funding has been allocated for interventions by Transport Scotland.
The guidance for Scotland includes information on meeting the needs of disabled people and the importance of an EQIA on each intervention.
Monitoring and Review
The guidance will be updated as Scotland moves through the Route Map. Any feedback will be considered and the guidance updated on a regular basis.
Stage 5 - Authorisation of EQIA
Please confirm that:
This Equality Impact Assessment has informed the development of this policy:
- Opportunities to promote equality in respect of age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex and sexual orientation have been considered, i.e.:
- Eliminating unlawful discrimination, harassment, victimisation;
- Removing or minimising any barriers and/or disadvantages;
- Taking steps which assist with promoting equality and meeting people’s different needs;
- Encouraging participation (e.g. in public life)
- Fostering good relations, tackling prejudice and promoting understanding.
If the Marriage and Civil Partnership protected characteristic applies to this policy, the Equality Impact Assessment has also assessed against the duty to eliminate unlawful discrimination, harassment and victimisation in respect of this protected characteristic:
I am satisfied with the equality impact assessment that has been undertaken for Safer Public Places and give my authorisation for the results of this assessment to be published on the Scottish Government’s website.
Name: John McNairney
Position: Chief Planner
Authorisation date: 5 August 2020