Renfrewshire Council

Renfrewshire Local Development Plan Housing Land Supply EQIA

Introduction

This Equalities and Human Rights Assessment has been undertaken alongside and informed the preparation of the Update to the Renfrewshire Local Development Plan Housing Land Supply Supplementary Guidance.

The purpose of the Assessment is to ensure that the Housing Land Supply Supplementary Guidance (Update 2017) utilises the opportunities to promote equality and human rights and does not result in discrimination.

Equality is about making sure that people are treated fairly. It  is not about treating everyone in the same way. It recognises that people's needs can be different and are able to be met in different ways. The Renfrewshire Local Development Plan Housing Land Supply Supplementary Guidance (Update) 2017 has been prepared with the aim of ensuring that everyone is treated fairly and given an equal chance.

Equality Impact Assessment Process

The Equality Impact Assessment is a two part process which involves initial screening and then if required a full Equality Impact Assessment will be undertaken. A full assessment is required if the initial screening identifies that any of the equality groups would be negatively affected by the policy or if the impact is assessed as being of high significance.

The Equality Act 2010 protects people on the basis of their protected characteristics. The Equality Act aims to ensure that when a plan or strategy is being prepared, planning authorities consider potential consequences on particular groups. It covers nine protected characteristics and the protected characteristic groups, they are as follows:

  • Age
  • Disability
  • Gender
  • Gender reassignment
  • Race
  • Religion and belief
  • Pregnancy and maternity
  • Marriage and civil partnership
  • Sexual Orientation.

This Equality and Human Rights Impact Assessment has considered potential impacts from the preparation of the Housing Land Supply Supplementary Guidance on particular groups.

The Assessment, which was undertaken as a parallel process to the preparation of Housing Land Supply Supplementary Guidance (Update) 2017 has made sure that as far as possible, any negative impacts are minimised and where possible eliminated.

Renfrewshire Local Development Plan

The current Renfrewshire Local Development Plan was adopted in 2014 and sets out the Council's spatial strategy to guide the future use of land in Renfrewshire. An Equality Impact Assessment was undertaken when preparing the Renfrewshire Local Development Plan Main Issues Report in 2011. An Equality Impact Assessment was also undertaken for the publication of the Proposed Renfrewshire Local Development Plan in January 2013.

Subsequent Equality Impact Assessments have been undertaken for individual documents that have been prepared to implement the Renfrewshire Local Development Plan. This Equality Impact Assessment updates the assessment that was undertaken for the Housing Land Supply Supplementary Guidance in 2015.

Human Rights Assessment

Whilst it is not a requirement to carry out a Human Rights Impact Assessment, human rights issues have been considered alongside equalities as the objectives of both are often complimentary.

Human rights extend the concept of fairness of treatment, dignity and respect beyond the sphere of protected characteristics to include individual rights.

Many areas of human rights cannot be influenced through the development plan process and it is considered that the Housing Land Supply Supplementary Guidance (Update) 2017 does not impinge on any of these rights.

Contents of the Housing Land Supply Supplementary Guidance (Update) 2017

Name of the document

Housing Land Supply Supplementary Guidance (Update) 2017

Responsible Department

Development Plans and Housing Strategy Team

Responsible Officer

Kevin Dalrymple (Development Plans and Housing Strategy Team Leader)

Date of Impact Assessment

January - March 2017

Who will be the beneficiaries of the document

People with an interest or involved in the preparation of the Renfrewshire Local Development Plan which include residents and businesses across Renfrewshire, as well as stakeholders, community groups, key agencies, the development industry, Renfrewshire Council and individuals.

Aims of the document

The Renfrewshire Housing Land Supply Supplementary Guidance sets out a framework that Renfrewshire Council will use to assess planning applications for housing on sites not allocated for residential development in the Adopted Renfrewshire Local Development Plan 2014, in circumstances where the 5 year effective land supply is not being maintained.

The role of Supplementary Guidance is simply to provide further information and detail in respect of Policy P2 - Housing Land Supply, a policy that is already set out in the adopted Renfrewshire Local Development Plan 2014 which was subject to an Equality Impact Assessment that was undertaken in January 2013.

In the current Adopted Renfrewshire Housing Land Supply Supplementary Guidance (December 2015) the shortfall in private sector effective housing land was identified as 755 private sector units. Following monitoring and review of the housing land supply through the Renfrewshire Housing Land Audit 2016, this shortfall has been reduced to 230 private sector units and the Supplementary Guidance has been updated to reflect this change.

Part 1: Equality Impact Assessment - Screening

1. Officer and Department responsible for completing the Assessment

Kevin Dalrymple, Development and Housing Services

2. Name of policy, strategy or project

Erskine Town Centre StrategyHousing Land Supply Supplementary Guidance (Update) 2017

3. What is the main purpose or aims of the policy, strategy or project

The preparation of the Housing Land Supply Supplementary Guidance was a requirement of the Scottish Government Reporter to the Examination of the Renfrewshire Local Development Plan and was adopted and published in 2015.

The Housing Land Supply Supplementary Guidance has been updated by changing the figure and table on Page 3 of the document to reflect the current housing shortfall. There is no change to the detailed framework, criteria and considerations in the Supplementary Guidance, they remain as exists.

The Scottish Government Reporter to the Examination of the Renfrewshire Local Development Plan concluded that Renfrewshire had a shortfall in its housing land supply. To address this, the Reporter recommended that the Council prepare Supplementary Guidance, within 1 year of the adoption of the Local Development Plan, which would include a detailed framework to guide the release of additional housing land. The Reporter considered that an agreed framework set out in the Renfrewshire Housing Land Supply Supplementary Guidance would allow the Council to grant planning permission for housing proposals that complied with that Supplementary Guidance framework as well as all other policies in the Renfrewshire Local Development Plan. To ensure that the Council complies with the recommendations of the Scottish Government Reporter, Housing Land Supply Supplementary Guidance was prepared to provide a framework to Policy P2 - Housing Land Supply in the Renfrewshire Local Development Plan.

The Renfrewshire Housing Land Supply Supplementary Guidance sets out a framework that Renfrewshire Council will use to assess planning applications for housing on sites not allocated for residential development in the Adopted Renfrewshire Local Development Plan 2014, in circumstances where the 5 year effective land supply is not being maintained.

The role of the Housing Land Supply Supplementary Guidance is to provide further information and detail in respect of a policy that is already set out in the Renfrewshire Local Development Plan which was subject to an Equality Impact Assessment.

In the current Adopted Renfrewshire Housing Land Supply Supplementary Guidance (December 2015) the shortfall in private sector effective housing land supply was identified as 755 private sector units. Following monitoring and review of the housing land supply through the Renfrewshire Housing Land Audit 2016, this shortfall has been reduced to 230 private sector units. The Supplementary Guidance has been updated to reflect this change. The reduction in the housing shortfall is due to the increase in housing completions at Dargavel Bishopton, the approval of housing at the former BASF site on Hawkhead Road along with higher completions from many of the existing housing sites on brownfield land. This confirms that the Council's strategy focused on the development of previously used sites, concentrating on existing built-up areas and key redevelopment sites is successfully being delivered.

4. Who will be the beneficiaries of the policy/ strategy/ project?

The Housing Land Supply Supplementary Guidance (Update) 2017 provides a policy framework that supplements the existing Renfrewshire Local Development Plan and New Development Supplementary Guidance to ensure that there is a range of housing sites in the right locations to meet the housing land requirements within Renfrewshire.

Given the existing policy framework set out in the Renfrewshire Local Development Plan and the New Development Supplementary Guidance, the focus will be for new housing developments to support strong communities and places. Developments will require to provide a mix of physical, economic, social and environmental enhancements to communities and places. Housing sites will also require to augment communities and importantly, be in sustainable locations.

It is considered that given the aims and objectives of the adopted Renfrewshire Local Development Plan, the New Development Supplementary Guidance and the Housing Land Supply Supplementary Guidance Update 2017, that the beneficiaries should be all residents that either currently reside or would like to reside in Renfrewshire which included all of those people covered by the Protected Characteristic Groups.

5. Has the policy/ strategy/ project been explained to those it might affect directly or indirectly?

The Housing Land Supply Supplementary Guidance was first put before Renfrewshire Council's Planning and Property Policy Board on the 12 May 2015. A Board Report accompanied the draft Housing Land Supply Supplementary Guidance which provided an explanation to the requirement for the Housing Land Supply Supplementary Guidance.

The 2015 Housing Land Supply Supplementary Guidance was subject to an external consultation period for six weeks where people were able to comment on the document. This was an important part of the process where stakeholders are able to influence the document.

Everyone that made comment on the Renfrewshire Local Development Plan was contacted by email or by letter and signposted to where a copy of the draft Housing Land Supply Supplementary Guidance could be viewed online, at the Council offices or in every library in Renfrewshire. A Statutory advert was placed in both papers that circulate the Renfrewshire area. A notice was also published on the Tell Me Scotland website.

As well as all of those that commented on the Renfrewshire Local Development Plan, correspondence was sent to various bodies and groups which represent those identified as Protected Characteristic Groups.

Following the six week period of consultation all comments received on the draft Housing Land Supply Supplementary Guidance were considered in the production of the final Housing Land Supply Supplementary Guidance (2015).

A report on the consultation along with a finalised version of the Housing Land Supply Supplementary Guidance was prepared and was put before Renfrewshire Council's Planning and Property Policy Board on 10 November 2015. The finalised supplementary guidance along with a table summarising all of the representations, setting out how Renfrewshire Council considered these comments, was submitted to the Scottish Ministers. The Scottish Ministers made some minor suggested amendments and Renfrewshire Council accepted these minor amendments, finalised the document, adopted and published the supplementary guidance in December 2015.

The Housing Land Supply Supplementary Guidance (Update) 2017 was put before Renfrewshire Council's Planning and Property Policy Board on the 14 March 2017 and again a Board Report accompanied this document.

A 6 week period of consultation will be undertaken on the 2017 update to provide an opportunity for comments. Following this consultation a finalised version of the Supplementary Guidance along with a summary of the representations made during the consultation period was presented to the Board for consideration.

The finalised Supplementary Guidance then requires to be sent to the Scottish Government along with a statement setting out the comments received through consultation and an explanation of how these were taken into account. Thereafter, unless directed by the Scottish Government, the Supplementary Guidance will then be considered as being the Adopted Council policy

6. Have you consulted on the policy?

Yes, there have been internal and external discussions undertaken whilst preparing the document.

7. Impact on Equality Target Group

The policy/strategy/project could have a positive impact on any of the equality target groups or contributes to promoting equality, equal opportunities and improving relations with equality target groups.

The policy/strategy/project could have a negative impact on any equality target groups. If the impact is high a full EIA should be completed.

Race - low positive impact

No specific impact - the impact of the policy framework to ensure that there is a range of sites for housing in the right places to meet the overall housing land requirements within Renfrewshire will apply irrespective of race.

Sex - neutral impact

The policy framework will impact equally on males and females. The framework will ensure that there is a range and choice of housing sites, housing tenures in various locations across Renfrewshire.

Disability - low positive impact

Renfrewshire Housing Land Supply Supplementary Guidance will have a positive impact on the disability equality target group. The Supplementary Guidance provides the framework to ensure developments happen in the most suitable sustainable locations. This should ensure that there is accessibility to new developments both by sustainable accessible modes of transport and through accessible design of proposed developments.

Religion - neutral impact

No specific impact, the policy framework will apply irrespective of faith or belief.

Sexual orientation - neutral impact

No specific impact, the policy framework will apply irrespective of sexual orientation.

Age - low positive impact

Renfrewshire Housing Land Supply Supplementary Guidance will have a positive impact on the age equality target group. Proposed development sites will be in a sustainable location. This should ensure that there is accessibility to new developments by public transport which should benefit both younger and older members of society as well as families.

This policy framework will also provide for a supply of housing

Gender reassignment - neutral impact

No specific impact, the policy framework will apply irrespective of gender re-assignment.

Marriage and civil partnership - neutral impact

No specific impact, the policy framework will apply irrespective of relationship status.

Pregnancy and maternity - neutral impact

No specific impact, the policy framework will apply irrespective of pregnancy/ maternity.

8. How this policy benefits the equality target groups identified in Section 7

Renfrewshire Housing Land Supply Supplementary Guidance (Update) 2017 is designed to ensure that any new residential developments are located in sustainable locations. This will benefit all Protected Characteristic Groups through improved accessibility and quality of place.

9. If there is a negative impact on any of the equality target groups, is the impact intended or legal?

No negative impacts identified

10. What actions could be taken to amend the policy/strategy/project to minimise any impact identified?

No negative impacts have been identified

11. If there is no evidence that the policy/strategy/project promotes equality, equal opportunities or improves relations within equality target groups, what amendments could be made to achieve this?

Not Applicable

12. How will the policy/strategy/project be implemented including any necessary training?

Training and understanding of how to use this document will be given to Council Staff as well as Councillors.

Conclusion

In general terms the Housing Land Supply Supplementary Guidance (Update) 2017 is likely to have a positive impact on the Protected Characteristic Groups given that additional housing will aim to provide a range and choice of housing in different locations and communities across Renfrewshire. There is no requirement for a full Equality Impact Assessment on this updated Supplementary Guidance.

New housing proposals will require to be assessed against the Renfrewshire Local Development Plan and the New Development Supplementary Guidance, both of which were subject to an Equality Impact Assessment.

Renfrewshire Local Development Plan and associated Supplementary Guidance is an integrated planning framework by which all aspects of development proposals require to be fully considered when assessing and determining individual planning applications.

The Renfrewshire Local Development will be reviewed and replaced every five years. This 2017 Update is the first Update to the Housing Land Supply Supplementary Guidance.

Updating the Guidance enables the policy framework to reflect changing circumstances along with new opportunities as well as constant review and monitoring of the impact of the policy framework.