Equality screening

Equality Screening Template

Purpose Built Managed Student Accommodation (PBMSA) in Belfast, Supplementary Planning Guidance (SPG)

February 2016

The Council has a statutory duty to screen. This includes our strategies, plans, policies, legislative developments; and new ways of working such as the introduction, change or end of an existing service, grant funding arrangement or facility. This screening template is designed to help departments consider the likely equality impacts of their proposed decisions on different groups of customers, service users, staff and visitors.

Before carrying out an equality screening exercise it is important that you have received the necessary training first. To find out about the training needed or any other queries on screening, contact the Equality and Diversity Officers (job-share) Stella Gilmartin or Lorraine Dennis on extension 6026/7 or by email equality@belfastcity.gov.uk

The accompanying Screening Guidance note provides straightforward advice on how to carry out equality screening exercises. Detailed information about the Section 75 equality duties and what they mean in practice is available on the Equality Commission’s website [Footnote 1].

The screening template has 4 sections to complete. These are:

• Section A - provides details about the policy / decision that is being screened
• Section B – gives information on the consultation process, supporting evidence gathered and has 4 key questions outlining the likely impacts on all equality groups.
• Section C - has 4 key questions in relation to obligations under the Disability Discrimination Order
• Section D - is the formal record of the screening decision.

Section A

Details about the policy / decision to be screened

1. Title of policy / decision to be screened:-
Purpose Built Managed Student Accommodation (PBMSA) in Belfast, Supplementary Planning Guidance (SPG)

2. Brief description of policy / decision to be screened:-
(Explain - Is this a new, revised or existing policy? Are there financial / legislative / procurement implications?)

The SPG has been prepared to provide additional advice and guidance in relation to PBMSA developments in Belfast. It supports and clarifies existing policies, most notably the Houses in Multiple Occupation (HMOs) Subject Plan for Belfast, the Belfast Metropolitan Area Plan (BMAP), the Strategic Planning Policy Statement (SPPS) for NI and PPS7 Quality Residential Environments. It sets out supplementary guidance in relation to six planning issues, including:

1. Location: The development should be at a location which is easily accessible to university/college campuses by sustainable transport modes.
2. Quality Design: The layout, design and facilities provided within a development should be of high standards.
3. Scale and Impact: The development should be designed in a way that does not conflict with adjacent properties or the general amenity of the surrounding area.
4. Management: The development has appropriate management in place to create a positive and safe living environment for students whilst minimising any potential negative impacts from occupants.
5. Need: The development meets an identified need for the type of accommodation proposed. This should help secure a supply of accommodation in response to evidence of need.
6. Planning Agreements: Planning Agreements, and related developer contributions, may be required in relation to PBMSA where what is secured cannot be adequately addressed by the imposition of conditions alone.

3. Aims and objectives of the policy / decision to be screened:-
(What is the policy trying to achieve?)

To provide additional advice and guidance for use by developers, the public and by planning officers in the assessment of planning applications for PBMSA developments.

4. On whom will the policy / decision impact?

Consider the internal and external impacts (both actual or potential) and explain:-

For use by the public, developers and their agents when preparing planning applications for PBMSA in Belfast. Will also form a material consideration, to be referenced by development management staff when assessing planning applications for PBMSA developments.

5. Are there linkages to other Agencies/ Departments?

Polices supplemented by the SPG were originally prepared by the Department for Environment’s Planning Service prior to the transfer of planning to the Council on 1 April 2015.

Section B

Information on the consultation process, supporting evidence gathered and has 4 key questions outlining the likely impacts for equality and good relations

6. Outline consultation process planned or achieved

A public consultation period will run for 12 weeks from 7 March 2016 until 30 May 2016. This will be conducted in line with corporate consultation policy and Statement of Community Involvement.

7. Available evidence

What evidence / information (both qualitative and quantitative) have you gathered to inform this policy? Set out all evidence below to help inform your screening assessment. It is important to record information gathered from a variety of sources such as: monitoring information; complaints; research surveys; consultation exercises from other public authorities.

As outlined above, the SPG does not introduce any new policy, but instead supports and clarifies existing policies, most notably the HMOs Subject Plan for Belfast, the Belfast Metropolitan Area Plan (BMAP), the Strategic Planning Policy Statement (SPPS) for NI and Planning Policy Statement (PPS) 7: Quality Residential Environments. The principle evidence used to inform this equality screening exercise is therefore any equality screening and/or Equality Impact Assessments (EqIA) conducted in relation to these existing policy documents. The implications of these exercises are summarized briefly below.

HMOs Subject Plan

A full EqIA for the HMOs Subject Plan was published in December 2008. On the basis of an earlier screening exercise, the assessment concluded that the following Section 75 groups were affected by certain policy groupings and should be the subject of the fuller EqIA:

• Racial Group; and
• Age

However, from a review of the EqIA, most of the issues identified relation to HMOs policies as opposed to the PBMSA-specific policy, HMO7. As PBMSA is distinct from HMOs, the EqIA considerations for HMOs are not relevant when considering guidance specifically in relation to PBMSA. In relation to the Policy HMO7, the assessment concluded:

• There will be a positive impact on people from different religious groups or of different political opinion as provision of such accommodation will encourage higher standards of student accommodation and provide choice outside of residential areas where HMOs are concentrated.
• There will be a positive impact on people of different age and racial minorities. Belfast is underrepresented in terms of purpose built student accommodation. This policy encourages such development hence providing more opportunity and choice for students and freeing up HMO accommodation for other sections of community such as migrant workers.

See Appendix A for further information.

BMAP

A full EqIA on BMAP was published alongside final Policy in September 2014. Whilst the majority of the high level, strategic policies contained within the EqIA are of no direct relevance to the PBMSA SPG, a number of relevant conclusions are recorded in relation to:

• Housing Policies HOU3 and HOU4 – Sufficient flexibility exists to meet specific identified needs through design and house type. There is no evidence to suggest that the locational range of people with disabilities is inconsistent with the spread of opportunity for housing.
• Urban Environment Policies – Will have a positive impact on people of different religions and political opinions as distribution of zonings correlates with population distributions.
• Open Space, Sport & Outdoor Recreation – There is a potentially negative impact on young people and disabled people if these facilities are not accessible via public transport provision.

SPPS

A final Equality Screening report was published with final SPPS in September 2015. Again, as a high level strategic policy statement, there are no policies of direct relevance to the PBMSA SPG. However, the screening report notes that the SPPS, and the planning system generally, is for securing the orderly and consistent development of land in Northern Ireland under a reformed two-tier planning system.” It therefore concludes that “it will be applied uniformly across all section 75 categories without prejudice” and, as such, “will not positively or negatively discriminate towards any” Section 75 Group. It is, in fact, “expected to equally benefit all Section 75 categories”.

Other Relevant Planning Policies

Although not the principal policies of relevance to the provision of PBMSA, there are also a range of other regional policy documents and guidance that are referred to within the SPG. Each of these documents have also been prepared to by public bodies in accordance with any statutory obligations in relation to Equality Impact at the time of writing.

The Equality Screening for the SPPS highlights similarities between the SPPS and the existing suite of PPSs, noting that as high level, strategic policies there are no likely adverse impacts anticipated on equality of opportunity as the PPS, as with the SPPS, “will be applied uniformly across all section 75 categories.” 

These other relevant policy documents are listed below, alongside any relevant learning from their respective equality assessment considerations:

• Regional Development Strategy 2035 (March 2012) – This high level strategic policy was subjected to a full EqIA, which is available on the Department for Regional Development’s (DRD) website. It concludes that “the implementation of the Strategic Guidance would provide benefits across all equality categories”, with “no negative effects on any category”.
• PPS7: Quality Residential Environments (June 2001) – There is no EqIA or Equality Screening Assessment publicly available in relation to this PPS.
• PPS8: Open Space, Sport and Outdoor Recreation (February 2004) – PPS8 was subject to an Equality Impact Screening exercise with the outcome indicating that “the PPS is unlikely to have any significant adverse implications for equality of opportunity or community relations.”
• PPS12: Housing in Settlements (June 2005) – The PPS notes that it has been prepared in accordance with DRD’s statutory obligations under Section 75 of the Northern Ireland Act 1998. This relies upon the original EqIA undertaken in relation to the first RDS (September 2001).
• Creating Places (May 2000) – This regional Supplementary Planning Guidance was prepared to support the published policies contained within PPS7 (see above). There is no EqIA or Equality Screening Assessment publicly available in relation to this guidance.
• Living Places (September 2014) – This provides strategic guidance to supplement a range of existing regional policy documents, including the SPPS (see above) and PPSs. There is no EqIA or Equality Screening Assessment publicly available in relation to this guidance.

8. What is the likely impact (indicate if the policy impact is positive or negative) on equality of opportunity for those affected by this policy, for each of the Section 75 equality categories? What is the level of impact?

9.  Are there opportunities to better promote equality of opportunity for people within the Section 75 equalities categories? 

10. To what extent is the policy likely to impact (positive or negatively) on good relations between people of different religious belief, political opinion or racial group? What is the level of impact? 

11.Are there opportunities to better promote good relations between people of different religious belief, political opinion or racial group? 

Section C

Belfast City Council also has legislative obligations to meet under the Disability Discrimination Order and Questions 12-13 relate to these two areas.

Consideration of Disability Duties

12. Does this proposed policy / decision provide an opportunity for the Council to better promote positive attitudes towards disabled people? 

Explain your assessment in full 

There is therefore an opportunity for the SPG to actively promote compliance with these requirements by highlighting the need for rooms within PBMSA development to be suitable for students with disabilities.

13. Does this proposed policy / decision provide an opportunity to actively increase the participation by disabled people in public life?

Explain your assessment in full

The PBMSA SPG will have no effect on participation by disabled people in public life.

14. Monitoring Arrangements

Section 75 places a requirement the Council to have equality monitoring arrangements in place in order to assess the impact of policies and services etc; and to help identify barriers to fair participation and to better promote equality of opportunity. Outline what data you will collect in the future in order to monitor the impact of this policy / decision on equality, good relations and disability duties.

Section D Formal Record of Screening Decision

Title of Proposed Policy / Decision being screened

Purpose Built Managed Student Accommodation (PBMSA) in Belfast, Supplementary Planning Guidance (SPG)

I can confirm that the proposed policy / decision has been screened for –

• equality of opportunity and good relations
• disabilities duties

On the basis of the answers to the screening questions, I recommend that this policy / decision is:

*Screened Out – No EQIA necessary (no impacts)
Provide a brief note here to explain how this decision was reached:

As the PBMSA SPG supports and clarifies existing policies, there are no additional negative impacts associated with publication of this document. There are a number of potential minor positive impacts for some Section 75 groups associated with the provision of high quality PBMSA in the right locations and an opportunity to better promote positive attitudes to people with disabilities by highlighting the need for rooms within PBMSA development to be suitable for students with disabilities.

Formal Record of Screening Decision 

Screening assessment completed by (Officer level) -

Name: Martyn Smithson
Date: 22/02/2016
Department : Planning and Place

Screening decision approved by -
Name: Dermot O’Kane
Date: 22/02/2016
Department : Planning and Place

Appendix A

Appendix A: Extracts from Equality Impact Assessment for the HMOs Subject Plan for Belfast, December 2008

Positive: +
Negative: - 
Neutral: 0

Footnotes

[Footnote 1] http://www.equalityni.org/archive/pdf/S75GuideforPublicAuthoritiesApril2010.pdf