The Equality Act 2010 (the Act) replaces the previous anti-discrimination laws with a single Act

Equality Impact Analysis Template

Equality Impact Analysis (EqIA) (or Equality Impact Assessment) aims to make services and public policy better for all service-users and staff and supports value for money by getting council services right first time.

We use EqIAs to enable us to consider all relevant information from an Equality requirements perspective when procuring or restructuring a service, or introducing a new policy or strategy. This analysis of impacts is then reflected in the relevant action plan to get the best outcomes for the Council, its staff and service-users[1].

EqIAs are used to analyse and assess how the Council’s work might impact differently on different groups of people[2]. EqIAs help the Council to make good decisions for its service-users, staff and residents and provide evidence that those decision conform with the Council’s obligations under the Equality Act 2010[3].

This template sets out the steps you need to take to complete an EqIA for your project. Guidance for sections is in the end-notes. If you have any questions about your EqIA and/or how to complete this form, please use the contact details at the end of this form.

Title of Project/Service/Policy[4]

Eastbourne Town Centre Movement & Access Package – Phase 2A

Directorate

Communities, Economy & Transport

Team/Department[5]

Strategic Economic Infrastructure Team

Provide a comprehensive description of your Project (Service/Policy, etc.) including its Purpose and Scope[6]

This project is specifically focused on a key Eastbourne town centre corridor between the junction of Cornfield Road and Terminus Road (known locally as ‘Bankers Corner’), extending along Terminus Road to Langney Road and Bolton Road.

The scheme consists of a complementary package of improvements, building on the already completed Phase 1 improvements which covered the section of Terminus Road between Station roundabout and Bankers Corner, Cornfield Road and Gildredge Road. Phase 2a will create a pedestrianised area at the eastern end of the primary retail corridor in Eastbourne Town Centre (Bolton Road/Langney Road) and a high-quality urban environment on the middle section of Terminus Road. This includes new pedestrianisation and opening up to two-way traffic configuration at the lower end of Bolton and Langney Road. Vehicular traffic (apart from emergency vehicles) will not be permitted to access Terminus Road between the hours of 10am to 6pm through the use of removable bollards at Bolton Road and Langney Road.

The objectives of the scheme are to:

· Deliver improvements which support and complement changes made in Phase 1 Eastbourne Town Centre Improvement Scheme;

· Improve pedestrian safety and accessibility by reallocating road space in the section of Terminus Road between Bolton Road and Langney Road to pedestrians;

· The use of Terminus Road to create a ‘spine route’ through the primary retail area of Eastbourne Town Centre to the seafront;

· Support local development and businesses along Terminus Road;

· Coordinate the design of street furniture, street lighting and signage which will be finished to a high standard in the town centre: and,

· Improve the public realm within Eastbourne Town Centre.

The development of the scheme aims to support and increase access to the town centre for all service users, by balancing the needs of local businesses, disabled users, cyclists and delivering a scheme within the funding available and to the highways design standards such transport and public realm schemes are required to meet .

Consultation and engagement with groups representing disabled people’s experiences has been used to inform a number of changes, some of which are outlined below.

Initial assessment of whether your project requires an EqIA

When answering these questions, please keep in mind all legally protected equality characteristics (sex/gender, gender reassignment, religion or belief, age, disability, ethnicity/race, sexual orientation, marriage/civil partnership, pregnancy and maternity) of the people actually or potentially receiving and benefiting from the services or the policy.

In particular consider whether there are any potential equality related barriers that people may experience when getting to know about, accessing or receiving the service or the policy to be introduced or changed.

Discuss the results of your Equality assessment with the Equality Lead for your department and agree whether improvements or changes need to be made to any aspect of your Project.

	Question	Yes	No	Don’t Know
1	Is there evidence of different needs, experiences, issues or priorities on the basis of the equality characteristics (listed below) in relation to the service or policy/strategy area?	X
2	Are there any proposed changes in the service/policy that may affect how services are run and/or used or the ways the policy will impact different groups?	X
3	Are there any proposed changes in the service/policy that may affect service-users/staff/residents directly?	X
4	Is there potential for, or evidence that, the service/policy may adversely affect inclusiveness or harm good relations between different groups of people?	X
5	Is there any potential for, or evidence that any part of the service/aspects of the policy could have a direct or indirect discriminatory effect on service-users/staff/residents ?		X
6	Is there any stakeholder (Council staff, residents, trade unions, service-users, VCSE organisations) concerned about actual, potential, or perceived discrimination/unequal treatment in the service or the Policy on the basis of the equality characteristics set out above that may lead to taking legal action against the Council?	X
7	Is there any evidence or indication of higher or lower uptake of the service by, or the impact of the policy on, people who share the equality characteristics set out above?		X

If you have answered “YES” or “DON’T KNOW” to any of the questions above, then the completion of an EqIA is necessary.

The need for an EqIA will depend on:

· How many questions you have answered “yes”, or “don’t know” to;

· The likelihood of the Council facing legal action in relation to the effects of service or the policy may have on groups sharing protected characteristics; and

· The likelihood of adverse publicity and reputational damage for the Council.

Low risk

Medium risk

High risk

1. Update on previous EqIAs and outcomes of previous actions (if applicable)[7]

What actions did you plan last time?

(List them from the previous EqIA)

What improved as a result?

What outcomes have these actions achieved?

What further actions do you need to take? (add these to the Action Plan below)

The previous EQIA was undertaken as part of the public consultation in 2019.

The actions were:

· Proceed to development of detailed design, but with continued consultation with key stakeholder groups, including Eastbourne disability groups.

The detailed design has been refined following feedback from stakeholder groups and lessons learnt from Phase 1.

Continued engagement was carried out with representatives from local disability groups, business, transport and walking and cycling groups. Microsoft Teams stakeholder meetings were carried out in September and October 2020 and February 2021 and ESCC continued correspondence with key stakeholders and attended site visits. ESCC also commissioned an additional accessibility audit on the preferred design option before submitting for approval. This has ensured that where feasible mitigating actions have been incorporated into the detailed design whilst keeping in line with the key business case objectives of the scheme.

ESCC and Eastbourne Borough Council officers have been actively working with key stakeholder focus groups including local disability groups in Eastbourne on the development of the scheme proposals from early stakeholder engagement and business case development in 2018, public consultation in 2019, and through the detailed design process to provide updates and seek comments on the Phase 2a proposals.

The detailed design will go through a Stage 2 Road Safety Audit, Lead Member for Transport and Environment approval and Traffic Regulation Order advertisement process.

The EqIA will be further updated ahead of construction of the scheme.

2. Review of information, equality analysis and potential actions

Consider the actual or potential impact of your project (service, or policy) against each of the equality characteristics.

Protected characteristics groups under the Equality Act 2010	What do you know[8]? Summary of data about your service-users and/or staff	What do people tell you[9]? Summary of service-user and/or staff feedback	What does this mean[10]? Impacts identified from data and feedback (actual and potential)	What can you do[11]? All potential actions to: · advance equality of opportunity, · eliminate discrimination, and · foster good relations
Age[12]	The dataset shows the resident population by broad age groups in June 2020. ESiF (eastsussexinfigures.org.uk) From the above, Eastbourne has a higher proportion of older people (65+) and a lower proportion of younger people (0-15). When compared to the East Sussex average, the proportions are generally similar, although it is marginally higher for younger people and less for older people. There is no information available on visitors. Eastbourne town centre is described in Eastbourne Borough Council’s (EBC’s) Local Plan as having a younger age profile than other neighbourhoods. However, the role of Terminus Road as a hub for transport into the town centre means that the area is visited by a wide range of people, including people commuting to work, shoppers, tourists and people visiting for entertainment purposes. Young (16-29) and older people (65+) are potentially more sensitive to the changes proposed for Terminus Road, Bolton Road and Langney Road because of the impact on taxi services, safety and footways. Younger (0-15) and working age group (16-64) who are likely to cycle are affected by the proposals due to the pedestrianisation of the area and preventing cycling through Terminus Road. Fear of crime can deter people from going out and detract from their enjoyment of the town centre. Older people (65+) in particular are potentially sensitive to changes that make the area more prone to anti-social behaviour, whether the effect on crime is real or perceived. Young people (16-29) and working age group (16-64) can also be discouraged to travel at night.	ESCC has engaged at all formative stages of scheme development, from business case stage, to preliminary design, public consultation, and detailed design stage. § Public and stakeholder feedback arising from the public consultation carried out in 2019 indicates that 63% of respondents support or strongly support the scheme proposals. The majority of respondents felt that the plans would achieve the scheme objectives and were positive about how they would improve the town centre. The most common concerns related to the provision for cyclists, disabled access parking, potential construction times and legacy issues arising from the newly completed Phase 1 – Eastbourne Town Centre Improvement Scheme. § Feedback from key stakeholder focus groups indicates that pedestrianisation will improve the town centre for residents and visitors of all ages and encourage more people to patronise businesses due to an attractive town centre. This in turn will support the local economy. However, concerns have been raised by disability groups, about the impact of reducing the number of accessible parking bays and taxi drop-off points close to the town centre. § As part of the public consultation in 2019 a workshop event to discuss and explore young people’s attitudes toward Eastbourne Town Centre was held. Workshop participants felt the area was lacking in public facilities such as good lighting, covered shelter areas or water fountains but they did agree that the proposals addressed these concerns. § The proposal to not permit cycling throughout the extent of the scheme has been raised as a key concern by local cycle groups. Disability groups have expressed concerns at the potential for cycling in pedestrianised areas, especially for people with sensory impairment and/or limited mobility, and the potential conflicts this generates. § Increase in number of seats and rationalised seat locations is required for people of all ages particularly older people. Following an access assessment on the preferred detailed design, it was noted that bench seats should incorporate various seat heights with back and arm supports provided.	§ Pedestrianisation will generally be beneficial to all age groups, enhance well-being and provide support for businesses in the local area. § Not permitting cycling through the extent of the Phase 2a scheme has the potential act as a barrier for those who prefer to cycle within the town centre. § Improving seating within Eastbourne town centre will have a positive impact for all people of all age groups particularly older people with limited mobility or health conditions. § Enhanced street lighting will potentially reduce safety concerns for people who wish to visit the town centre in the evening. In addition, better installation of power supplies will have the potential to encourage more young people to events in the town centre.	As standard practice, the scheme design will be audited by our Road Safety Team to ensure that all reasonable measures to maximise safety are taken. § The pedestrianised area will be enforced by removable bollards at the entrance points on Bolton Road and Langney Road during the day (10am to 6pm). This will ensure that no vehicles other than emergency vehicles requiring access are permitted. § The no cycling within the scheme extent will be enforced by a legal traffic regulation order with appropriate signage. However, cycle parking will be provided at the entrance points to the scheme so that cyclists of all ages do not feel excluded. The considered placement of cycle parking should provide a safe and secure location that will encourage cyclists to dismount and park their bicycles. However, compliance cannot be guaranteed so measures will be taken to make restrictions clear though the legal traffic regulation order. § Alternative cycle routes from Eastbourne station to the sea front have been developed and are being consulted upon as part of a separate scheme. § Variation of seat height and provision of back and arm supports has been included in the design as a direct result of the feedback received. § The provision of enhanced street lighting for safety and public realm will make the town centre more attractive. § Research and engagement with local stakeholders highlight the importance of ensuring that this Phase 2a scheme and future public realm improvement schemes are inclusive.
	Disability[13]	This dataset shows the percentage of people that have a limiting long-term illness or disability from 2011 Census: Source: 2011 Census, Office for National Statistics In 2011 Eastbourne had a slightly higher proportion of the population with a limiting illness than East Sussex or England & Wales as a whole. The number of those whose day to day activities are limited a little are significantly higher the England & Wales average. The following dataset shows the projected number of people with limited long-term illness (LLTI), calculated by multiplying age and sex specific rates of LLTI by the latest dwelling-led population projections calculated by East Sussex County Council using the POPGROUP model in April 2021: The data shows that from 2019 to 2034 the projected number of people in Eastbourne with limited long term illness will increase by 4,060. The projected number of people with disabilities, in 2034 is 22,289, an increase of 3,710 since 2019. Source: East Sussex County Council, Research and Information Team, April 2021 ESiF (eastsussexinfigures.org.uk) Eastbourne is projected to have a marginally higher proportion of the population with a limiting long-term illness or disability than East Sussex or England and Wales as a whole. The projected number of people with disabilities is expected to increase. There is no information available on visitors.	ESCC officers have attended meetings with members of local disability groups, including attendance at site visits, as the detailed design has progressed. The following summarises points raised by local disability groups, as well as points raised by an independent access auditor commissioned by ESCC, as priorities to be addressed: § Need for materials to tonally contrast against the background they are seen against – e.g. experience of navigating the proposed feature banding along Terminus Road has the potential to create an illusion of steps/trenches for those with visual impairments and hidden disabilities and will not meet with Light Reflect Value standards § BS8300 Design of an accessible and inclusive built environment. Buildings - code of practice 2018 to be applied. § Consideration for making the carriageway the same colour as the footway. This reduces the number of colours used. It also has the benefit of encouraging pedestrians to wander freely slowing down any vehicles that are in the road. § Accessible parking bays should conform to the BS8300 width of 3.6m § Alternative accessible parking provision close to the town centre should be found to offset the loss of 9 disabled parking bays within the Phase 2a scheme area, including when construction starts. § The need to consider impacts arising from the expansion of eligibility criteria for blue badge parking § Taxi drop off points near to the town centre need to be retained for those who do not have access to a vehicle or cannot use public transport § Need for a range of accessible seating designs § Dropped kerbs with tactile paving should be provided within on-street parking bays. § Temporary accessible parking bays need to be provided during construction § Distance from the disabled bays to the Beacon Shopping Centre has increased § Ensure location of street furniture is considered and variable seat heights are provided. § Cycling is prohibited throughout the scheme area and this is enforced through appropriate signing § Ensure that all methods of communicating the scheme proposals including when construction begins, reach the town centre and wider communities in accessible formats . .	Feedback from local disability groups and an independent access auditor has identified the following potential impacts resulting from the design proposals which have been assessed and considered by ESCC officers and the Phase 2a design team: § The contrasting bands that run horizontally across the pedestrian routes along Terminus Road could have an impact for blind and partially sighted people and those with cognitive impairments. § Not reducing visual clutter and/or ensuring there is consistency in where street furniture is placed at site approaches on Terminus/Cornfield Road and Bolton Road potentially impacts blind and partially sighted people and those with cognitive impairments. § Not providing a range of seating designs which include different seat heights, with and without back and arm rests would have an impact on the scheme’s accessibility. § It is anticipated that with the projected increase in people in Eastbourne living with limited long-term illness and with disabilities by 2034, the demand for accessible parking spaces in the town centre may increase (factoring in too, the national expansion of blue bade parking eligibility criteria to include hidden disabilities), so reducing the number and availability of accessible parking spaces will impact those who rely on being able to park close to the town centre to access local amenities.	By addressing the features deemed to be of particular priority by local disability groups and recommendations made by the access auditor, where possible and reasonable to do so, improvements have been made to the final detailed design which should lead to greater accessibility without impacting on the character of the scheme. § The detailed design team have reviewed each comment and recommendation from the access auditor, assessed from a technical feasibility perspective, and have incorporated feedback and recommendations where practicable whilst also adhering to the required highway scheme design standards. § The design has been amended to ensure that the street furniture contrasts sufficiently with the paving materials. § The chosen material for the feature breaker band has been chosen to have a low contrast to the materials it passes through in accordance with the accessibility audit requirements. The feature banding breaks down the linearity of the street and promotes more driver caution to create a pedestrian orientated environment. The bands break up the otherwise straight aesthetic view often associated with a road. This is in line with general design approaches of changing the character of roads to “streets” in public realm schemes. § The use of concrete blocks in the vehicular central area of the scheme will address the potential for damage caused by heavy goods vehicle use. The two grey tones that were selected for the concrete blocks are very close to the colour tones used in Phase 1, and similar to the light grey in the selected footway area granite paving palette. The greys were selected considering oil spills and tyre tracks because lighter colours may stain more easily. Although it would be best to encourage 'wandering' into the middle area, it will be good to have a slight visual difference for vulnerable users as the area can be used by vehicles from 6pm to 10am. § The use of tactile paving between the pedestrian (granite) and vehicular (concrete) areas has been discounted by the design team owing to an increased potential for sending conflicting messages to pedestrians that they are not allowed to enter the vehicular space. Delivery vehicles will only be allowed during designated hours (6pm – 10am) and their speed is expected to be low due to the confined space. Appropriate signing will be in place as per the traffic regulation order. § The current distance from the nearest parking bays on Terminus Road to the Beacon shopping centre is approximately 28m. From Bolton Road to the shopping centre is approximately 100m and from Langney Road to the shopping centre is approximately 103m.The increase in distance has been necessitated due to the principal objective of the project to pedestrianise Terminus Road including converting Bolton Road and Langney Road to two way, blocking it off with bollards during the day with the provision of turning heads for drivers. The turning heads in both Bolton Road and Langney Road dictate where the nearest disabled bay should be positioned. § For the remaining parking on Bolton Road and Langney Road within the scheme extent, it is important to note the retention of accessible parking bays and taxi bays has been prioritised over other road users, by removing all pay and display parking and significantly reducing the number of loading bays to 1 on Bolton Road and 1 on Langney Road. § The length of the accessible parking bays on Bolton Road will be unchanged (26.4m), which is 4 x 6.6m bays. The accessible parking bays are moving from the east side (currently 46m = 7 x 6.6m bays) of Langney Road to the west side which reduces the number of bays to 33m (5x 6.6m bays) due to the need for 1 loading bay. In addition to the accessible parking and loading bays, the supply of taxi bays has been recognised as essential in continuing to provide access to the town centre for those with mobility impairments, who do not own a vehicle, or cannot use public transport. § To further compensate for the loss of accessible parking,15.6m length (2 x 6.6m) bays have been identified on Lismore Road (due to the doctors surgery closing) and will be included in a Traffic Regulation Order (TRO) for the scheme. The project team has also carried out a site visit with members of local disability groups to identify additional areas for parking in the town centre close to the Phase 2a scheme area. Suitable alternative sites, both on road and surface access off road parking areas,have been found nearer to the shopping centre and will be incorporated under the necessary TRO process. There is a desire by ESCC to advance equality of opportunity and eliminate discrimination by ensuring that there will be no net loss of accessible parking bays because of the Phase 2a scheme. § 3.2m wide disabled bays on Bolton Road, 2.9m wide disabled bays and 3.1m wide disabled bays on Lismore Road are provided which is over and above the minimum 2.7m as per design standard: Traffic Signs Regulations and General Directions 2016. To make the scheme work, two-way access to Bolton and Langney Roads is required due to the removal of the through route which limits the available carriageway space for parking. While acknowledging this is below the recommendation in BS8300, that guidance is predominantly applied to new built environments that aren't constrained by existing buildings, utilities and footways, and that BS8300 standards should only be applied where practicable. In this instance, by providing 3.6m wide bays, the scheme would no longer be viable. The bays that are provided achieve the minimum requirement of 2.7m for accessible parking bays. § Introducing dropped kerbs to the existing accessible parking bays is deemed unfeasible in the design because it introduces a number of additional issues including changes to footway levels, footway gradients (making them steeper which may cause a hazard for visually impaired and older people), drainage, services and existing street furniture levels. This is due to the proposed parking bays being located within the existing constrained highway, where the intention is to leave the existing horizontal layout. The back of footway levels are also fixed due to shop frontages and the existing accessible parking bays have a kerb upstand. In addition, providing the layout recommended by BS8300 will significantly reduce the number of spaces available. § It should be noted that the reasoning behind not adopting the widening of parking bays and installation of dropped kerbs was explained to the access consultant, which was accepted, and these responses were presented to local disability groups during the February 2021 detailed design engagement workshop. § The location of street furniture has been optimised – such as cycle stands moved to near entry points into the scheme area, well distributed seating that will be at suitable varying heights and closer to accessible parking bays. Planters will be 75cm above ground and easily detectable to avoid acting as an obstacle for people with visual impairments. § Brochures to explain the operation of the new town centre to be prepared and circulated once detailed design is complete and approved and ongoing engagement with stakeholder groups to continue once construction commences. § Research and engagement with local stakeholders highlight the importance of ensuring that public realm schemes such as Phase 2a are inclusive, i.e. considers the needs of those with both physical and hidden disabilities.
Gender reassignment[14]	Data is not currently available on the number of people in the county or Eastbourne who identify with a different gender to that which they were born with, who might describe themselves as trans, transgender, transsexual or gender non-binary. Nationally it is estimated that 1% of the population is trans. Community safety is an important priority for everyone, but we are aware that some women and transgender people may feel particularly vulnerable to crime and anti-social behavior.	No feedback received.	It is not considered that people sharing this protected characteristic will experience disproportionate, negative, neutral or positive impact by the scheme.	It is not considered that trans people with this protected characteristic will experience disproportionate, negative, neutral or positive impact by the scheme. The intention of the scheme is to make the town centre feel safer and more accessible for everyone. Street lighting throughout the scheme will be upgraded. CCTV is also present throughout the town centre. Additionally, the project is being designed to encourage members of the public to an area, assisting the creation of a pleasant public realm and civic spaces and discouraging anti-social behaviour.
Pregnancy and maternity[15]	The data below shows the number of live births by age of mother in 2019. There is no information available on Eastbourne visitors. ESiF (eastsussexinfigures.org.uk)	No feedback received.	It is expected that pedestrianisation of the Town Centre will make it safer, attractive, and accessible for people sharing this protected characteristic.	It is expected that pedestrianisation of the Town Centre will make it safer, attractive, and accessible for people sharing this protected characteristic. The intention of the scheme is to make the town centre feel safer and more accessible for everyone.
Race/ethnicity[16] Including migrants, refugees and asylum seekers	The data below shows the percentage of the population by ethnic groups from the 2011 Census. ESiF (eastsussexinfigures.org.uk) East Sussex and Eastbourne have a more predominantly white population than the South-East and National averages. There is no information available on Eastbourne visitors.	No feedback received.	Language may be a barrier to access and so the design will need to consider clear wayfinding for all users.	Wayfinding signage (fingerposts and totem signs) is included in the scheme and any information distributed by the project will be available in different languages and formats on request. The intention of the scheme is to make the town centre feel safer and more accessible for everyone. Street lighting throughout the scheme will be upgraded. CCTV is also present throughout the town centre. Additionally, the project is being designed to encourage members of the public to an area, assisting the creation of a pleasant public realm and civic spaces and discouraging anti-social behaviour.
Religion or belief[17]	The data below shows the percentage of the population by religion from the 2011 Census. There is no information available on Eastbourne visitors. ESiF (eastsussexinfigures.org.uk)	No feedback received.	It is not considered that this protected characteristic will experience disproportionate, negative, neutral or positive impact by the scheme.	It is not considered that this protected characteristic will experience disproportionate, negative, neutral or positive impact by the scheme.
Sex/Gender[18]	The data below shows the resident population by gender in June 2019. There is no information available on Eastbourne visitors. ESiF (eastsussexinfigures.org.uk) The percentage of women (51.4%) is slightly higher in Eastbourne than the national average and consequently the number of men (48.6%) is slightly lower. There is no information available on Eastbourne visitors. Community safety is an important priority for everyone, but we are aware that some women and transgender people may feel particularly vulnerable to crime and anti-social behavior.	No feedback received.	The project will benefit people of all genders equally.	The project will benefit people of all genders equally. Street lighting throughout the scheme will be upgraded. The intention of the scheme is to make the town centre feel safer and more accessible for everyone. Street lighting throughout the scheme will be upgraded. CCTV is also present throughout the town centre. Additionally, the project is being designed to encourage members of the public to an area, assisting the creation of a pleasant public realm and civic spaces and discouraging anti-social behaviour.
Sexual orientation[19]	The data below shows the estimate of the percentage of the population by sexual orientation in 2017. There is no information available on Eastbourne visitors. ESiF (eastsussexinfigures.org.uk) Source: ESCC and IpsosMORI, 2017 Community Survey	No feedback received.	It is not considered that this protected characteristic will experience disproportionate, negative, neutral or positive impact by the scheme.	It is not considered that this protected characteristic will experience disproportionate, negative, neutral or positive impact by the scheme. The intention of the scheme is to make the town centre feel safer and more accessible for everyone. Street lighting throughout the scheme will be upgraded. CCTV is also present throughout the town centre. Additionally, the project is being designed to encourage members of the public to an area, assisting the creation of a pleasant public realm and civic spaces and discouraging anti-social behaviour.
Marriage and civil partnership[20]	This dataset shows the number of people aged 16 and over and the percentage by marital status from 2011 Census. ESiF (eastsussexinfigures.org.uk)	No feedback received.	It is not considered that this protected characteristic will experience disproportionate, negative, neutral or positive impact by the scheme.	It is not considered that this protected characteristic will experience disproportionate, negative, neutral or positive impact by the scheme.
Impacts on community cohesion[21]	No data available.	No feedback received.	It is not considered that this protected characteristic will experience disproportionate, negative, neutral or positive impact by the scheme.	It is not considered that this protected characteristic will experience disproportionate, negative, neutral or positive impact by the scheme.

Protected characteristics

groups under the Equality Act 2010

What do you know[8]?

Summary of data about your service-users and/or staff

What do people tell you[9]?

Summary of service-user and/or staff feedback

What does this mean[10]?

Impacts identified from data and feedback (actual and potential)

What can you do[11]?

All potential actions to:

· advance equality of opportunity,

· eliminate discrimination, and

· foster good relations

Age[12]

The dataset shows the resident population by broad age groups in June 2020.

ESiF (eastsussexinfigures.org.uk)

From the above, Eastbourne has a higher proportion of older people (65+) and a lower proportion of younger people (0-15). When compared to the East Sussex average, the proportions are generally similar, although it is marginally higher for younger people and less for older people. There is no information available on visitors.

Eastbourne town centre is described in Eastbourne Borough Council’s (EBC’s) Local Plan as having a younger age profile than other neighbourhoods. However, the role of Terminus Road as a hub for transport into the town centre means that the area is visited by a wide range of people, including people commuting to work, shoppers, tourists and people visiting for entertainment purposes.

Young (16-29) and older people (65+) are potentially more sensitive to the changes proposed for Terminus Road, Bolton Road and Langney Road because of the impact on taxi services, safety and footways.

Younger (0-15) and working age group (16-64) who are likely to cycle are affected by the proposals due to the pedestrianisation of the area and preventing cycling through Terminus Road.

Fear of crime can deter people from going out and detract from their enjoyment of the town centre. Older people (65+) in particular are potentially sensitive to changes that make the area more prone to anti-social behaviour, whether the effect on crime is real or perceived. Young people (16-29) and working age group (16-64) can also be discouraged to travel at night.

ESCC has engaged at all formative stages of scheme development, from business case stage, to preliminary design, public consultation, and detailed design stage.

§ Public and stakeholder feedback arising from the public consultation carried out in 2019 indicates that 63% of respondents support or strongly support the scheme proposals. The majority of respondents felt that the plans would achieve the scheme objectives and were positive about how they would improve the town centre. The most common concerns related to the provision for cyclists, disabled access parking, potential construction times and legacy issues arising from the newly completed Phase 1 – Eastbourne Town Centre Improvement Scheme.

§ Feedback from key stakeholder focus groups indicates that pedestrianisation will improve the town centre for residents and visitors of all ages and encourage more people to patronise businesses due to an attractive town centre. This in turn will support the local economy. However, concerns have been raised by disability groups, about the impact of reducing the number of accessible parking bays and taxi drop-off points close to the town centre.

§ As part of the public consultation in 2019 a workshop event to discuss and explore young people’s attitudes toward Eastbourne Town Centre was held. Workshop participants felt the area was lacking in public facilities such as good lighting, covered shelter areas or water fountains but they did agree that the proposals addressed these concerns.

§ The proposal to not permit cycling throughout the extent of the scheme has been raised as a key concern by local cycle groups. Disability groups have expressed concerns at the potential for cycling in pedestrianised areas, especially for people with sensory impairment and/or limited mobility, and the potential conflicts this generates.

§ Increase in number of seats and rationalised seat locations is required for people of all ages particularly older people. Following an access assessment on the preferred detailed design, it was noted that bench seats should incorporate various seat heights with back and arm supports provided.

§ Pedestrianisation will generally be beneficial to all age groups, enhance well-being and provide support for businesses in the local area.

§ Not permitting cycling through the extent of the Phase 2a scheme has the potential act as a barrier for those who prefer to cycle within the town centre.

§ Improving seating within Eastbourne town centre will have a positive impact for all people of all age groups particularly older people with limited mobility or health conditions.

§ Enhanced street lighting will potentially reduce safety concerns for people who wish to visit the town centre in the evening. In addition, better installation of power supplies will have the potential to encourage more young people to events in the town centre.

As standard practice, the scheme design will be audited by our Road Safety Team to ensure that all reasonable measures to maximise safety are taken.

§ The pedestrianised area will be enforced by removable bollards at the entrance points on Bolton Road and Langney Road during the day (10am to 6pm). This will ensure that no vehicles other than emergency vehicles requiring access are permitted.

§ The no cycling within the scheme extent will be enforced by a legal traffic regulation order with appropriate signage. However, cycle parking will be provided at the entrance points to the scheme so that cyclists of all ages do not feel excluded. The considered placement of cycle parking should provide a safe and secure location that will encourage cyclists to dismount and park their bicycles. However, compliance cannot be guaranteed so measures will be taken to make restrictions clear though the legal traffic regulation order.

§ Alternative cycle routes from Eastbourne station to the sea front have been developed and are being consulted upon as part of a separate scheme.

§ Variation of seat height and provision of back and arm supports has been included in the design as a direct result of the feedback received.

§ The provision of enhanced street lighting for safety and public realm will make the town centre more attractive.

§ Research and engagement with local stakeholders highlight the importance of ensuring that this Phase 2a scheme and future public realm improvement schemes are inclusive.

Disability[13]

This dataset shows the percentage of people that have a limiting long-term illness or disability from 2011 Census:

Source: 2011 Census, Office for National Statistics

In 2011 Eastbourne had a slightly higher proportion of the population with a limiting illness than East Sussex or England & Wales as a whole. The number of those whose day to day activities are limited a little are significantly higher the England & Wales average.

The following dataset shows the projected number of people with limited long-term illness (LLTI), calculated by multiplying age and sex specific rates of LLTI by the latest dwelling-led population projections calculated by East Sussex County Council using the POPGROUP model in April 2021:

The data shows that from 2019 to 2034 the projected number of people in Eastbourne with limited long term illness will increase by 4,060.

The projected number of people with disabilities, in 2034 is 22,289, an increase of 3,710 since 2019.

Source: East Sussex County Council, Research and Information Team, April 2021

ESiF (eastsussexinfigures.org.uk)

Eastbourne is projected to have a marginally higher proportion of the population with a limiting long-term illness or disability than East Sussex or England and Wales as a whole. The projected number of people with disabilities is expected to increase. There is no information available on visitors.

ESCC officers have attended meetings with members of local disability groups, including attendance at site visits, as the detailed design has progressed. The following summarises points raised by local disability groups, as well as points raised by an independent access auditor commissioned by ESCC, as priorities to be addressed:

§ Need for materials to tonally contrast against the background they are seen against – e.g. experience of navigating the proposed feature banding along Terminus Road has the potential to create an illusion of steps/trenches for those with visual impairments and hidden disabilities and will not meet with Light Reflect Value standards

§ BS8300 Design of an accessible and inclusive built environment. Buildings - code of practice 2018 to be applied.

§ Consideration for making the carriageway the same colour as the footway. This reduces the number of colours used. It also has the benefit of encouraging pedestrians to wander freely slowing down any vehicles that are in the road.

§ Accessible parking bays should conform to the BS8300 width of 3.6m

§ Alternative accessible parking provision close to the town centre should be found to offset the loss of 9 disabled parking bays within the Phase 2a scheme area, including when construction starts.

§ The need to consider impacts arising from the expansion of eligibility criteria for blue badge parking

§ Taxi drop off points near to the town centre need to be retained for those who do not have access to a vehicle or cannot use public transport

§ Need for a range of accessible seating designs

§ Dropped kerbs with tactile paving should be provided within on-street parking bays.

§ Temporary accessible parking bays need to be provided during construction

§ Distance from the disabled bays to the Beacon Shopping Centre has increased

§ Ensure location of street furniture is considered and variable seat heights are provided.

§ Cycling is prohibited throughout the scheme area and this is enforced through appropriate signing

§ Ensure that all methods of communicating the scheme proposals including when construction begins, reach the town centre and wider communities in accessible formats

Feedback from local disability groups and an independent access auditor has identified the following potential impacts resulting from the design proposals which have been assessed and considered by ESCC officers and the Phase 2a design team:

§ The contrasting bands that run horizontally across the pedestrian routes along Terminus Road could have an impact for blind and partially sighted people and those with cognitive impairments.

§ Not reducing visual clutter and/or ensuring there is consistency in where street furniture is placed at site approaches on Terminus/Cornfield Road and Bolton Road potentially impacts blind and partially sighted people and those with cognitive impairments.

§ Not providing a range of seating designs which include different seat heights, with and without back and arm rests would have an impact on the scheme’s accessibility.

§ It is anticipated that with the projected increase in people in Eastbourne living with limited long-term illness and with disabilities by 2034, the demand for accessible parking spaces in the town centre may increase (factoring in too, the national expansion of blue bade parking eligibility criteria to include hidden disabilities), so reducing the number and availability of accessible parking spaces will impact those who rely on being able to park close to the town centre to access local amenities.

By addressing the features deemed to be of particular priority by local disability groups and recommendations made by the access auditor, where possible and reasonable to do so, improvements have been made to the final detailed design which should lead to greater accessibility without impacting on the character of the scheme.

§ The detailed design team have reviewed each comment and recommendation from the access auditor, assessed from a technical feasibility perspective, and have incorporated feedback and recommendations where practicable whilst also adhering to the required highway scheme design standards.

§ The design has been amended to ensure that the street furniture contrasts sufficiently with the paving materials.

§ The chosen material for the feature breaker band has been chosen to have a low contrast to the materials it passes through in accordance with the accessibility audit requirements. The feature banding breaks down the linearity of the street and promotes more driver caution to create a pedestrian orientated environment. The bands break up the otherwise straight aesthetic view often associated with a road. This is in line with general design approaches of changing the character of roads to “streets” in public realm schemes.

§ The use of concrete blocks in the vehicular central area of the scheme will address the potential for damage caused by heavy goods vehicle use. The two grey tones that were selected for the concrete blocks are very close to the colour tones used in Phase 1, and similar to the light grey in the selected footway area granite paving palette. The greys were selected considering oil spills and tyre tracks because lighter colours may stain more easily. Although it would be best to encourage 'wandering' into the middle area, it will be good to have a slight visual difference for vulnerable users as the area can be used by vehicles from 6pm to 10am.

§ The use of tactile paving between the pedestrian (granite) and vehicular (concrete) areas has been discounted by the design team owing to an increased potential for sending conflicting messages to pedestrians that they are not allowed to enter the vehicular space. Delivery vehicles will only be allowed during designated hours (6pm – 10am) and their speed is expected to be low due to the confined space. Appropriate signing will be in place as per the traffic regulation order.

§ The current distance from the nearest parking bays on Terminus Road to the Beacon shopping centre is approximately 28m. From Bolton Road to the shopping centre is approximately 100m and from Langney Road to the shopping centre is approximately 103m.The increase in distance has been necessitated due to the principal objective of the project to pedestrianise Terminus Road including converting Bolton Road and Langney Road to two way, blocking it off with bollards during the day with the provision of turning heads for drivers. The turning heads in both Bolton Road and Langney Road dictate where the nearest disabled bay should be positioned.

§ For the remaining parking on Bolton Road and Langney Road within the scheme extent, it is important to note the retention of accessible parking bays and taxi bays has been prioritised over other road users, by removing all pay and display parking and significantly reducing the number of loading bays to 1 on Bolton Road and 1 on Langney Road.

§ The length of the accessible parking bays on Bolton Road will be unchanged (26.4m), which is 4 x 6.6m bays. The accessible parking bays are moving from the east side (currently 46m = 7 x 6.6m bays) of Langney Road to the west side which reduces the number of bays to 33m (5x 6.6m bays) due to the need for 1 loading bay. In addition to the accessible parking and loading bays, the supply of taxi bays has been recognised as essential in continuing to provide access to the town centre for those with mobility impairments, who do not own a vehicle, or cannot use public transport.

§ To further compensate for the loss of accessible parking,15.6m length (2 x 6.6m) bays have been identified on Lismore Road (due to the doctors surgery closing) and will be included in a Traffic Regulation Order (TRO) for the scheme. The project team has also carried out a site visit with members of local disability groups to identify additional areas for parking in the town centre close to the Phase 2a scheme area. Suitable alternative sites, both on road and surface access off road parking areas,have been found nearer to the shopping centre and will be incorporated under the necessary TRO process. There is a desire by ESCC to advance equality of opportunity and eliminate discrimination by ensuring that there will be no net loss of accessible parking bays because of the Phase 2a scheme.

§ 3.2m wide disabled bays on Bolton Road, 2.9m wide disabled bays and 3.1m wide disabled bays on Lismore Road are provided which is over and above the minimum 2.7m as per design standard: Traffic Signs Regulations and General Directions 2016. To make the scheme work, two-way access to Bolton and Langney Roads is required due to the removal of the through route which limits the available carriageway space for parking. While acknowledging this is below the recommendation in BS8300, that guidance is predominantly applied to new built environments that aren't constrained by existing buildings, utilities and footways, and that BS8300 standards should only be applied where practicable. In this instance, by providing 3.6m wide bays, the scheme would no longer be viable. The bays that are provided achieve the minimum requirement of 2.7m for accessible parking bays.

§ Introducing dropped kerbs to the existing accessible parking bays is deemed unfeasible in the design because it introduces a number of additional issues including changes to footway levels, footway gradients (making them steeper which may cause a hazard for visually impaired and older people), drainage, services and existing street furniture levels. This is due to the proposed parking bays being located within the existing constrained highway, where the intention is to leave the existing horizontal layout. The back of footway levels are also fixed due to shop frontages and the existing accessible parking bays have a kerb upstand. In addition, providing the layout recommended by BS8300 will significantly reduce the number of spaces available.

§ It should be noted that the reasoning behind not adopting the widening of parking bays and installation of dropped kerbs was explained to the access consultant, which was accepted, and these responses were presented to local disability groups during the February 2021 detailed design engagement workshop.

§ The location of street furniture has been optimised – such as cycle stands moved to near entry points into the scheme area, well distributed seating that will be at suitable varying heights and closer to accessible parking bays. Planters will be 75cm above ground and easily detectable to avoid acting as an obstacle for people with visual impairments.

§ Brochures to explain the operation of the new town centre to be prepared and circulated once detailed design is complete and approved and ongoing engagement with stakeholder groups to continue once construction commences.

§ Research and engagement with local stakeholders highlight the importance of ensuring that public realm schemes such as Phase 2a are inclusive, i.e. considers the needs of those with both physical and hidden disabilities.

Gender reassignment[14]

Data is not currently available on the number of people in the county or Eastbourne who identify with a different gender to that which they were born with, who might describe themselves as trans, transgender, transsexual or gender non-binary. Nationally it is estimated that 1% of the population is trans.

Community safety is an important priority for everyone, but we are aware that some women and transgender people may feel particularly vulnerable to crime and anti-social behavior.

No feedback received.

It is not considered that people sharing this protected characteristic will experience disproportionate, negative, neutral or positive impact by the scheme.

It is not considered that trans people with this protected characteristic will experience disproportionate, negative, neutral or positive impact by the scheme. The intention of the scheme is to make the town centre feel safer and more accessible for everyone. Street lighting throughout the scheme will be upgraded. CCTV is also present throughout the town centre. Additionally, the project is being designed to encourage members of the public to an area, assisting the creation of a pleasant public realm and civic spaces and discouraging anti-social behaviour.

Pregnancy and maternity[15]

The data below shows the number of live births by age of mother in 2019. There is no information available on Eastbourne visitors.

ESiF (eastsussexinfigures.org.uk)

No feedback received.

It is expected that pedestrianisation of the Town Centre will make it safer, attractive, and accessible for people sharing this protected characteristic.

It is expected that pedestrianisation of the Town Centre will make it safer, attractive, and accessible for people sharing this protected characteristic. The intention of the scheme is to make the town centre feel safer and more accessible for everyone.

Race/ethnicity[16]

Including migrants, refugees and asylum seekers

The data below shows the percentage of the population by ethnic groups from the 2011 Census.

ESiF (eastsussexinfigures.org.uk)

East Sussex and Eastbourne have a more predominantly white population than the South-East and National averages. There is no information available on Eastbourne visitors.

No feedback received.

Language may be a barrier to access and so the design will need to consider clear wayfinding for all users.

Wayfinding signage (fingerposts and totem signs) is included in the scheme and any information distributed by the project will be available in different languages and formats on request. The intention of the scheme is to make the town centre feel safer and more accessible for everyone. Street lighting throughout the scheme will be upgraded. CCTV is also present throughout the town centre. Additionally, the project is being designed to encourage members of the public to an area, assisting the creation of a pleasant public realm and civic spaces and discouraging anti-social behaviour.

Religion or belief[17]

The data below shows the percentage of the population by religion from the 2011 Census. There is no information available on Eastbourne visitors.

ESiF (eastsussexinfigures.org.uk)

No feedback received.

It is not considered that this protected characteristic will experience disproportionate, negative, neutral or positive impact by the scheme.

Sex/Gender[18]

The data below shows the resident population by gender in June 2019. There is no information available on Eastbourne visitors.

ESiF (eastsussexinfigures.org.uk)

The percentage of women (51.4%) is slightly higher in Eastbourne than the national average and consequently the number of men (48.6%) is slightly lower. There is no information available on Eastbourne visitors.

Community safety is an important priority for everyone, but we are aware that some women and transgender people may feel particularly vulnerable to crime and anti-social behavior.

No feedback received.

The project will benefit people of all genders equally.

The project will benefit people of all genders equally. Street lighting throughout the scheme will be upgraded. The intention of the scheme is to make the town centre feel safer and more accessible for everyone. Street lighting throughout the scheme will be upgraded. CCTV is also present throughout the town centre. Additionally, the project is being designed to encourage members of the public to an area, assisting the creation of a pleasant public realm and civic spaces and discouraging anti-social behaviour.

Sexual orientation[19]

The data below shows the estimate of the percentage of the population by sexual orientation in 2017. There is no information available on Eastbourne visitors.

ESiF (eastsussexinfigures.org.uk)

Source: ESCC and IpsosMORI, 2017 Community Survey

No feedback received.

It is not considered that this protected characteristic will experience disproportionate, negative, neutral or positive impact by the scheme.

It is not considered that this protected characteristic will experience disproportionate, negative, neutral or positive impact by the scheme. The intention of the scheme is to make the town centre feel safer and more accessible for everyone. Street lighting throughout the scheme will be upgraded. CCTV is also present throughout the town centre. Additionally, the project is being designed to encourage members of the public to an area, assisting the creation of a pleasant public realm and civic spaces and discouraging anti-social behaviour.

Marriage and civil partnership[20]

This dataset shows the number of people aged 16 and over and the percentage by marital status from 2011 Census.

ESiF (eastsussexinfigures.org.uk)

No feedback received.

It is not considered that this protected characteristic will experience disproportionate, negative, neutral or positive impact by the scheme.

Impacts on community cohesion[21]

No data available.

No feedback received.

It is not considered that this protected characteristic will experience disproportionate, negative, neutral or positive impact by the scheme.

Additional categories (identified locally as potentially causing / worsening inequality)
Characteristic	What do you know[22]?	What do people tell you[23]?	What does this mean[24]?	What can you do[25]?
Rurality[26]	No data available.	No feedback received.	Issues relating to carers are addressed in the section above on disability. Parking, access and safety issues and actions for disabled people and carers are identified above.	Not relevant to this proposal.
Carers	No data available.	No feedback received.	See section on disability above for actions.	See section on disability above for actions.
Other groups that may be differently affected (including but not only: homeless people, substance users, care leavers – see end note)[27]	There are no other groups which have been identified which are likely to experience disproportionate, negative, neutral or positive impact.	N/A	N/A	N/A
Assessment of overall impacts and any further recommendations[28] - include assessment of cumulative impacts (where a change in one service/policy/project may have an impact on another)
On balance, the benefits of the scheme far outweigh any negative impacts. The ongoing engagement with the stakeholder groups representing the experiences of disabled people and the significant dialogue and changes to the detailed design demonstrate the positive action measures that ESCC has undertaken for those with protected characteristics who suffer detrimental or substantial disadvantage.

3. List detailed data and/or community feedback that informed your EqIA

Source and type of data (e.g. research, or direct engagement (interviews), responses to questionnaires, etc.)	Date	Gaps in data	Actions to fill these gaps: who else do you need to engage with? (add these to the Action Plan below, with a timeframe)
Preliminary Design – initial optioneering and design development	January, February & May 2018. November 2018, March and October 2019	Detailed Design	Continued consultations with disability groups.
Public consultation	November / December 2019	Detailed design	Continued consultation with disability groups
Detailed Design Lessons Learnt Virtual Meeting with ESCC	July 2020	Comments incorporated within the emerging design where practicable and fits within the scheme objectives and business case.	Continued consultations with disability groups.
1st Detailed Design Virtual Stakeholder Meeting	September 2020	Comments incorporated within the emerging design where practicable and fits within the scheme objectives and business case.	Continued consultations with disability groups.
2^nd Detailed Design Virtual Stakeholder Meeting	October 2020	Comments incorporated within the emerging design where practicable and fits within the scheme objectives and business case.	Continued consultations with disability groups.
Accessibility Audit	December 2020	Comments incorporated within the emerging design where practicable and fits within the scheme objectives and business case.	Continued consultations with disability groups.
3^rd Detailed Design Virtual Stakeholder Meeting	February 2021	Comments incorporated within the emerging design where practicable and fits within the scheme objectives and business case.	Continued consultations with disability groups.
Site Meeting	June 2021	Comments relating to locations for relocated accessible blue badge parking incorporated within the emerging design	Continued engagement with disability groups ahead of advertisement of Traffic Regulation Order

4. Prioritised Action Plan[29]

Impact identified and group(s) affected	Action planned	Expected outcome	Measure of success	Timeframe
NB: These actions must now be transferred to service or business plans and monitored to ensure they achieve the outcomes identified.
To ensure that the scheme is safe. All users.	Road Safety Audit	Stage 2 Road Safety Audit Report	Production of designers’ responses and incorporating agreed recommendations into the final detailed design.	July 2021
To obtain approval of the scheme. All users.	Lead Member Meeting	Lead Member Approval.	The scheme approved to go ahead and progress to construction	July 2021
To advertise and agree TRO’s which will enforce the pedestrianised area. All users.	TRO Process	Agreement of TRO’s.	TRO’s agreed with no objections/objections resolved.	July to November 2021
All users.	Approval for Construction	Construction of scheme.	Construction of the scheme in accordance with agreed (safety and access audited) design.	March 2022 – March 2023
All users.	EQIA reviewed	Updated to ensure compliant	All potential actions to advance equality of opportunity, eliminate discrimination, and foster good relations have been addressed.	February - March 2022 (prior to construction)
All users.	Post Construction Review including dialogue with local people and businesses.	Comments received.	No significant issues.	April 2023
(Add more rows as needed)

EqIA sign-off: (for the EqIA to be final an email must be sent from the relevant people agreeing it, or this section must be signed)

Staff member completing Equality Impact Analysis: Date:

Directorate Management Team rep or Head of Service: Date:

Equality lead: Date:

Guidance end-notes

[1] The following principles, drawn from case law, explain what we must do to fulfil our duties under the Equality Act:

· Knowledge: everyone working for the Council must be aware of the Council’s duties under the Equality Act 2010 and ensure they comply with them appropriately in their daily work.

· Timeliness: the duty applies at the time of considering policy options and/or before a final decision is taken – not afterwards.

· Real Consideration: the duty must be an integral, rigorous part of your decision-making process and influence the process.

· Sufficient Information: you must assess what information you have and what is further needed to give proper consideration.

· No delegation: the Council is responsible for ensuring that any contracted services, which are provided on its behalf need also to comply with the same legal obligations under the Equality Act of 2010. You need, therefore, to ensure that the relevant contracts make these obligations clear to the supplier. It is a duty that cannot be delegated.

· Review: the equality duty is a continuing duty. It applies when a policy or service is developed/agreed, and when it is implemented and reviewed.

· Proper Record Keeping: to prove that the Council has fulfilled its legal obligations under the Equality Act you must keep records of the process you follow and the impacts identified.

NB: Filling out this EqIA in itself does not meet the requirements of the Council’s equality duty. All the requirements above must be fulfilled, or the EqIA (and any decision based on it) may be open to challenge. An EqIA therefore can provide evidence that the Council has taken practical steps comply with its equality duty and provide a record that to demonstrate that it has done so.

[2]Our duties in the Equality Act 2010

As a public sector organisation, we have a legal duty (under the Equality Act 2010) to show that we have identified and considered the actual and potential impact of our activities on people who share any of the legally ‘protected characteristics’ (age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, sexual orientation, and marriage and civil partnership).

This applies to policies, services (including commissioned services), and our employees. The level of detail of this consideration will depend on the nature of your project, who it might affect, those groups’ vulnerability, and the seriousness of any potential impacts it might have. We use this EqIA template to gather information and assess the impact of our project in these areas.

The following are the duties in the Act. You must give ‘due regard’ (pay conscious attention) to the need to:

avoid, reduce, minimise or eliminate any negative impact (if you identify unlawful discrimination, including victimisation and harassment, you must stop the action and take advice immediately).
promote equality of opportunity. This means the need to:

- Remove or minimise disadvantages suffered by equality groups

- Take steps to meet the needs of equality groups

- Encourage equality groups to participate in public life or any other activity where participation is disproportionately low

- Consider if there is a need to treat disabled people differently, including more favourable treatment where necessary

foster good relations between people who share a protected characteristic and those who do not. This means:

- Tackle prejudice

- Promote understanding

[3] EqIAs are always proportionate to:

The nature of the service, or scope of the policy/strategy
The resources involved
The number of people affected
The size of the likely impact
The vulnerability of the people affected

The greater the potential adverse impact of the proposed service or policy on a protected group (e.g. disabled people), the more thorough and demanding our process must be so that we comply with the Equality Act of 2010.

[4] Title of EqIA: This should clearly explain what service / policy / strategy / change you are assessing

[5] Team/Department: Main team responsible for the policy, practice, service or function being assessed

[6] Focus of EqIA: A member of the public should have a good understanding of the policy or service and any proposals after reading this section. Please use plain English and write any acronyms in full first time - eg: ‘Equality Impact Analysis (EqIA)’

This section should explain what you are assessing:

What are the main aims or purpose of the service, policy, strategy, practice, or function?
Who implements, carries out or delivers the service, policy, strategy, practice, or function? Please state where this is more than one person/team/body and where other organisations deliver under procurement or partnership arrangements.
How does it fit with other services?
Who is affected by the service, policy, strategy, practice, or function, or by how it is delivered? Who are the external and internal service-users, groups, or communities?
What outcomes do you want to achieve, why and for whom? Eg: what do you want to provide, what changes, or improvements, are required and what should the benefits be?
What do existing or previous reviews of the service, policy, strategy, practice, or function indicate to you?
What is the reason for the proposal, or change (financial, service scope, legal requirements, etc)? The Equality Act requires us to make these clear.

[7] Previous actions: If there is no previous EqIA, or this assessment is for a new service, then simply write ‘not applicable’.

[8] Data: Make sure you have enough information to inform your EqIA.

· What data relevant to the impact on protected groups of the policy/decision/service is available?[8]

· What further evidence is needed and how can you get it? (Eg: further research or engagement with the affected groups).

· What do you already know about needs, access and outcomes? Focus on each of the protected characteristics in turn. Eg: who uses the service? Who doesn’t and why? Are there differences in outcomes? Why?

· Have there been any important demographic changes or trends locally? What might they mean for the service or function?

· Does data/monitoring show that any policies or practices create particular problems or difficulties for any groups?

· Do any equality objectives already exist? What is current performance like against them?

· Is the service having a positive or negative effect on particular people in the community, or particular groups / communities?

[9] Engagement: You must engage appropriately with those likely to be affected to fulfil the Council’s duties under the Equality Act.

· What do people tell you about the services, the policy or the strategy?

· Are there patterns or differences in what people from different groups tell you?

· What information or data will you need from communities?

· How should people be consulted? Consider:

(a) consult when proposals are still at a formative stage;

(b) explain what is proposed and why, to allow intelligent consideration and response;

(d) make sure what people tell you is properly considered in the final decision.

· Try to consult in ways that ensure all different perspectives can be captured and considered.

· Identify any gaps in who has been consulted and identify ways to address this.

[10] Your EqIA must get to grips fully and properly with actual and potential impacts.

· The Council’s obligations under the Equality Act of 2010 do not stop you taking decisions, or introducing well needed changes; however, they require that you take decisions and make changes conscientiously and deliberately confront the anticipated impacts on people.

· Be realistic: don’t exaggerate speculative risks and negative impacts.

· Be detailed and specific so decision-makers have a concrete sense of potential effects. Instead of “the policy is likely to disadvantage older women”, say how many or what percentage are likely to be affected, how, and to what extent.

· Questions to ask when assessing impacts depend on the context. Examples:

o Are one or more protected groups affected differently and/or disadvantaged? How, and to what extent?

o Is there evidence of higher/lower uptake among different groups? Which, and to what extent?

o If there are likely to be different impacts on different groups, is that consistent with the overall objective?

o If there is negative differential impact, how can you minimise that while taking into account your overall aims

o Do the effects amount to unlawful discrimination? If so, the plan must be modified.

o Does the proposal advance equality of opportunity and/or foster good relations? If not, could it?

[11] Consider all three aims of the Act: removing barriers, and also identifying positive actions to be taken.

· Where you have identified impacts you must state what actions will be taken to remove, reduce or avoid any negative impacts and maximise any positive impacts or advance equality of opportunity.

· Be specific and detailed and explain how far these actions are expected to address the negative impacts.

· If mitigating measures are contemplated, explain clearly what the measures are, and the extent to which they can be expected to reduce / remove the adverse effects identified.

· An EqIA which has attempted to airbrush the facts is an EqIA that is vulnerable to challenge.

[12] Age: People of all ages

[13] Disability: A person is disabled if they have a physical or mental impairment which has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities. The definition includes: sensory impairments, impairments with fluctuating or recurring effects, progressive, organ specific, developmental, learning difficulties, mental health conditions and mental illnesses, produced by injury to the body or brain. Persons with cancer, multiple sclerosis or HIV infection are all now deemed to be disabled persons from the point of diagnosis. Carers of disabled people are protected within the Act by association.

[14] Gender Reassignment: In the Act a transgender person is someone who proposes to, starts or has completed a process to change his or her gender. A person does not need to be under medical supervision to be protected

[15] Pregnancy and Maternity: Protection is during pregnancy and any statutory maternity leave to which the woman is entitled.

[16] Race/Ethnicity: This includes ethnic or national origins, colour or nationality, and includes refugees and migrants, and Gypsies and Travellers. Refugees and migrants means people whose intention is to stay in the UK for at least twelve months (excluding visitors, short term students or tourists). This definition includes asylum seekers; voluntary and involuntary migrants; people who are undocumented; and the children of migrants, even if they were born in the UK.

[17] Religion and Belief: Religion includes any religion with a clear structure and belief system. Belief means any religious or philosophical belief. The Act also covers lack of religion or belief.

[18] Sex/Gender: Both men and women are covered under the Act.

[19] Sexual Orientation: The Act protects bisexual, gay, heterosexual and lesbian people

[20] Marriage and Civil Partnership: Only in relation to due regard to the need to eliminate discrimination.

[21] Community Cohesion: potential impacts on how well people from different communities get on together. The council has a legal duty to foster good relations between groups of people who share different protected characteristics. Some actions or policies may have impacts – or perceived impacts – on how groups see one another or in terms of how the council’s resources are seen to be allocated. There may also be opportunities to positively impact on good relations between groups.

[22] Data: Make sure you have enough information to inform your EqIA.

· What data relevant to the impact on protected groups of the policy/decision/service is available?[22]

· What further evidence is needed and how can you get it? (Eg: further research or engagement with the affected groups).

· Have there been any important demographic changes or trends locally? What might they mean for the service or function?

· Does data/monitoring show that any policies or practices create particular problems or difficulties for any groups?

· Do any equality objectives already exist? What is current performance like against them?

· Is the service having a positive or negative effect on particular people in the community, or particular groups or communities?

[23] Engagement: You must engage appropriately with those likely to be affected to fulfil the Council’s duties under the Equality Act .

· What do people tell you about the services, the policy or the strategy?

· Are there patterns or differences in what people from different groups tell you?

· What information or data will you need from communities?

· How should people be consulted? Consider:

(a) consult when proposals are still at a formative stage;

(b) explain what is proposed and why, to allow intelligent consideration and response;

(d) make sure what people tell you is properly considered in the final decision.

· Try to consult in ways that ensure all different perspectives can be captured and considered.

· Identify any gaps in who has been consulted and identify ways to address this.

[24] Your EqIA must get to grips fully and properly with actual and potential impacts.

· The Council’s obligations under the Equality Act of 2010 do not stop you taking decisions, or introducing well needed changes; however, they require that take decisions and make changes conscientiously and deliberately confront the anticipated impacts on people.

· Be realistic: don’t exaggerate speculative risks and negative impacts.

· Questions to ask when assessing impacts depend on the context. Examples:

o Are one or more protected groups affected differently and/or disadvantaged? How, and to what extent?

o Is there evidence of higher/lower uptake among different groups? Which, and to what extent?

o If there are likely to be different impacts on different groups, is that consistent with the overall objective?

o If there is negative differential impact, how can you minimise that while taking into account your overall aims

o Do the effects amount to unlawful discrimination? If so the plan must be modified.

o Does the proposal advance equality of opportunity and/or foster good relations? If not, could it?

[25] Consider all three aims of the Act: removing barriers, and also identifying positive actions to be taken.

· Where you have identified impacts you must state what actions will be taken to remove, reduce or avoid any negative impacts and maximise any positive impacts or advance equality of opportunity.

· Be specific and detailed and explain how far these actions are expected to address the negative impacts.

· If mitigating measures are contemplated, explain clearly what the measures are, and the extent to which they can be expected to reduce / remove the adverse effects identified.

· An EqIA which has attempted to airbrush the facts is an EqIA that is vulnerable to challenge.

[26] Rurality: deprivation is experienced differently between people living in rural and urban areas. In rural areas issues can include isolation, access to services (eg: GPs, pharmacies, libraries, schools), low income / part-time work, infrequent public transport, high transport costs, lack of affordable housing and higher fuel costs. Deprivation can also be more dispersed and less visible.

[27] Other groups that may be differently affected: this may vary by services, but examples include: homeless people, substance misusers, people experiencing domestic/sexual violence, looked after children or care leavers, current or former armed forces personnel (or their families), people on the Autistic spectrum etc.

[28] Assessment of overall impacts and any further recommendations

Make a frank and realistic assessment of the overall extent to which the negative impacts can be reduced or avoided by the mitigating measures. Explain what positive impacts will result from the actions and how you can make the most of these.
Countervailing considerations: These may include the reasons behind the formulation of the policy, the benefits it is expected to deliver, budget reductions, the need to avert a graver crisis by introducing a policy now and not later, and so on. The weight of these factors in favour of implementing the policy must then be measured against the weight of any evidence as to the potential negative equality impacts of the policy.
Are there any further recommendations? Is further engagement needed? Is more research or monitoring needed? Does there need to be a change in the proposal itself?

[29] Action Planning: The Council’s obligation under the Equality Act of 2010 is an ongoing duty: policies must be kept under review, continuing to give ‘due regard’ to the duty. If an assessment of a broad proposal leads to more specific proposals, then further equality assessment and consultation are needed.