Hounslow's Streetspace

2023 updates

See latest Streetspace scheme review below:

Chief Officer Decision See report on Staveley Road & Burlington Lane Experimental Schemes - Final Review 

EQUALITIES ANALYSIS FORM

Equality Analysis should be undertaken before a decision is made when adopting or reviewing policies/procedures or for savings proposals/ restructures and transformations where it is likely to affect equalities groups or engage the Public sector Equality Duty under section 149 of the Equality Act 2010 –See Appendix below).

(Note: If Equality is considered to have little or no effect on equality groups or if it is unlikely to engage equality duty then you do not need to complete this form. Even where the proposal is relevant to the equality duty but the effects is remote or peripheral to the substance of the Equality duty then do not complete this form, just use the standard equalities text in your main report, see web page for standard text.)

Your Equality Analysis  needs to demonstrate  that due regard has been given to the equalities  protected characteristics and the equalities duties and that this policy/ procedure/ proposal is not in breach of the equality duties. The aim is to support members make informed decisions about the policy/savings proposal balanced against any likely adverse effects. You must advice members about what actions are proposed to mitigate any adverse effect identified by affected stakeholders  during your consultation  or from your data analysis.

Due regard has to be given to:

➢   ensure that your decisions impact in a fair way: where there is evidence that particular equalities groups will be negatively affected by a decision, action should be taken to address this.

➢   make your decisions based on evidence and more transparent : Equality Analysis provides a clear and structured way to collect, assess and put forward relevant evidence and is much more open and transparent.

➢   provide a platform for partnership working: Equality Analysis offers an opportunity for organisations to work in partnership to consider the effect on members of their shared communities and how they might best collaborate and co-ordinate financial decisions.

➢   enable decision makers to asses whether  the decision might amount to unlawful discrimination and/or might effect on the promotion of equality of opportunity and/or might effect on the promotion of good relations, and if so the extent and nature of those effects.

Directorate / Section Name of the proposal / policy to assess: Date of analysis Person responsible for the analysis (include name of author if different)
Environment, Culture and Customer Services / Traffic and Transport Streetspace Previous version: 6th October Mark Frost
    Previous version: 12th May 2021

Author: Gareth Jones

Person Responsible: Paul Traynor

    Previous version: 27 August 2021 Jefferson Nwokeoma
    Previous version: 23 September 2021 Jefferson Nwokeoma
    Previous version: 12 November 2021 Jefferson Nwokeoma
    This version: 19 April 2023 Jefferson Nwokeoma
1. Briefly describe the policy / proposal - its aim and expected outcomes

The Covid-19 pandemic has radically altered how we use our transport network.  Local trips, often made on foot or by bike, have noticeably increased.  Public transport use has fallen dramatically due to concerns about virus transmission and increased take up of remote working.  While car trips significantly decreased during the lockdown period, these are now returning to pre Covid-19 levels.  In many locations it is now necessary to rethink how we allocate space on our highway and ensure that sufficient room is available for people to carry on moving around and accessing services on foot and by bike.  This will help to prioritise sustainable travel modes for those short journeys, for people who are able, and in turn ensure road capacity is freed up for essential car journeys.  The Streetspace programme responds to these challenges and opportunities. It introduced a range of measures that sought to prioritise walking and cycling, reduce cut-through driving, while allowing for social distancing. 

Experimental traffic orders were used to progress these schemes on a trial basis, for a minimum period of 6 months. Hounslow Council was required by government to review the network and implement projects that create more space and improve safety for those walking and cycling and reduce car use where possible. The government stipulated that these changes needed to be made ‘as swiftly as possible’, which it further clarified to mean ‘within weeks. (Government statutory guidance issued in May 2020 in response to Covid-19 pandemic). The measures do not seek in any way to adversely impact blue badge holders or those with disabilities.

Whilst equalities considerations must be assessed for all schemes, it is the case that the experimental order process allows for feedback to be taken on the lived experience of the change from all road users (including those with protected characteristics).  This experience can then be fed back to the council to allow for the equalities impact to be updated ahead of any final decisions being taken on the measure. 

2. Who is the policy/ proposal going to effect and in what way?

Please use evidence to support your analysis. Use separate sheets if necessary.

All those that live, work or travel through the areas of the borough with Streetspace projects, all of whom will have the equality characteristic, but the impact is not likely to be solely on grounds of equality. Nonetheless, the council recognises that the elderly, disabled, and pregnant women are less likely to change their mode of travel to walking and cycling. 

3. When will the decision be taken?

  • The future of measures introduced in 2020 have now been determined in May and August 2021
  • New measures introduced in the summer/autumn of 2021 will be due for a review in the spring of 2022.   
  • A decision on the trial measures (approved in autumn of 2021 and implemented in January 2022) was taken by Hounslow’s Cabinet on 18 April 2023. The decision was to conclude the trial and make the measures permanent. 

4. Are there concerns that the decision  could affect the following:- Please explain or attach evidence of your answers to these questions

 

 

 

(i) Age

Y

 

The council has carefully considered the impact of this proposal on each of the equalities characteristics. This has been done taking account of the consultation responses. An initial assessment identified some impact on grounds of equality. There is likely to be some impact for some residents and motorists who traditionally travelled through certain areas of the borough to access other streets, and the council recognises that those with a disability, some of whom may be more reliant on car journeys, may have to change some of their journeys. For example, some of the road closure trials closed a road to all vehicles, while certain parking suspension trials could impact those with mobility impairments being able to access services. However, new disabled parking provision has been included to mitigate this impact, and quieter streets - which have wider benefits to the community with regards to improved safety and increased active travel - are expected to result in shorter journey times for those who are more reliant on private car journeys.

The changes to the times for the Staveley Road restriction will help to reduce the volume of motorised vehicles on said road and within the South Chiswick area, which will make crossing roads easier, having a positive impact on the elderly, the disabled and women in pregnancy/maternity. Reduction in traffic is expected to have a positive impact in local air quality. 

Conversely, the reduced operational hours for the Hartington/Cavendish Road and Strand on the Green restrictions could increase the volume of motorised vehicles using both roads outside those times (between 7pm and 8am), which could potentially make crossing roads relatively difficult, having a negative impact on the elderly, the disabled and women in pregnancy/maternity. However, this is expected to be have a minimal impact as the level of traffic passing through these roads is expected to reduce outside the restricted hours. And, as the proposed changes aim to promote active travel, particularly for short trips, the net impact of these changes across the local network is expected to be positive. 

Transport for London’s document, Travel in  London: Understanding our diverse communities (2015) outlines the barriers faced by London’s communities with regards to access to transport. This document contains a range of statistics for those with a disability, with regards to transport in the capital:

- Fourteen per cent of Londoners consider themselves to have a disability that impacts their day-to-day activities ‘a lot’ or ‘a little’.

- The most commonly used types of transport by disabled Londoners are

walking (78 per cent walk at least once a week), the bus (56 per cent) and car as a passenger (47 per cent)

-    Disabled Londoners cite accessibility-

related issues (44 per cent), cost (21 per cent) and comfort (20 per cent) as key barriers to travel.

-    Eighty-five per cent of disabled

Londoners say they never use a bike to get around London, a slightly smaller proportion than among non-disabled Londoners (82 per cent).

Due to experimental orders being utilised to introduce these schemes, consultation has run alongside the measures being in place. The measures have been installed from spring 2020 onwards, with consultation commencing for a scheme once the project is live.

Feedback from residents, businesses,  and other stakeholders has been vital during this time to help understand the impact of the proposals and whether they will remain in place, as evidenced by the August 2021 Chief Officer Decision report: “Covid-19 Transport

Response – Interim Review of Streetspace Phases 1 & 2a reviews”. The scheme consultation summaries that form appendices to these reports each include a section on feedback received that may be relevant from an equalities standpoint. 

In terms of access, specific reference was made by some disabled respondents to health care facilities. For Turnham Green Terrace, a number of respondents shared their concern about using public transport during the pandemic. It is noted that for this scheme, some respondents who may ordinarily have been able to switch certain journeys to public transport were not able to do so during the pandemic and would have faced a longer journey time to make their usual trips by car.

The potential impact of the decision to make permanent the Burlington Lane and Staveley Road restrictions is noted and addressed on page 9 of this report. 

(ii) Disability

Y

 

(iii) Gender Reassignment

 

N

(iv) Marriage and Civil Partnership

 

N

(v) Race

 

N

(vi) Religion or Belief

 

N

(vii) Sex

 

N

(viii) Pregnancy and Maternity

  Y

 

(ix) Sexual Orientation

 

N

(x) fostering good relations and community cohesion

 

N

(xi) Human rights

Public Authorities have a duty under the Human Rights Act 1998 (HRA) not to act incompatibly with rights under the European

Convention for the Protection of Fundamental Rights and Freedoms Because of the close relationship between human rights and equality, it is good practice for those exercising public functions to consider equality and human rights together when analysing for effect on policies and proposals. (See list below for the Human Rights Articles)

 

N

5. Which equalities duties will be engaged by this proposal and will require due regard to be given before a decision is made? (See summary of equalities duties below)

 

The Council has to give due regard to its Equalities Duties, in particular with respect to general duties arising pursuant to the Equality Act 2010, section 149. Having due regard to the need to advance equality involves, in particular, the need to remove or minimise disadvantages suffered by persons who share a relevant characteristic that are connected to that characteristic.

6. Are there any relevant groups or stakeholders who you can approach to explore their views on the policy/proposal? You must consult/involve those who will be affected by the decision. YES/NO

 

Please list the relevant groups and how the views of these groups will be obtained. Or state the reason why you have not approached groups/users affected by your proposal

The Streetspace measures were not expected to significantly affect any group because of an equality characteristic. However, consultation continued through the trial periods to fully understand the impact of the schemes.  

 

At the end of the consultation period, while it was evident that there was a  significant level of opposition to the schemes, this was not related to any group of an equality characteristic. The consultation responses was considered ahead of the interim and final reviews, and the Chief Officer Decision of August 2021. 

The new measures introduced through the Chief Officer Decision of August 2021 on Staveley Road and Burlington Lane, both in Chiswick, will be subject to further equalities assessment once the trials commence. The Council will engage with the cemetery on Staveley Road, and Chiswick School, to better understand the effect of the restrictions on their visitors and services. The associated six-month consultation period will enable the Council to receive feedback from the public as to the effect of the scheme. Where specific issues arise, dedicated engagement with representative groups will be carried out, feedback will be collated and considered and this EQIA will be updated prior to any final decisions being taken. 

7. Please explain in detail the views of the relevant groups who have been consulted on the issues involved and the dates when this happened.

(please use a separate sheet if necessary)

Consultation has run concurrently with the trials, as documented in the August 2021 Chief Office Decision relating to the Interim reviews. The Consultation Analysis appendices that also accompany the report each include an Equalities section detailing relevant feedback received via the consultations.

8. Taking into account the views of these

groups, and the available evidence, please

clearly state the risks associated with the decision, weighed against the benefits of the decision. Will the effects be high, medium or low?

 

High – Effect is likely to be high if the savings proposal has significant relevance to the substance of the equality duty. So consider size and scale of effect of policy/savings proposal or service restructure on staff, users/residents  and other affected stakeholders. The effects can also be high if there is a potential for challenge of breach of equalities duties from affected stakeholders who have a protected equality characteristic (see overview of legal duties below).

 

Medium – If your proposal is not assessed as high or low then it is likely to be medium risk. Due regard given to the equality duties must be commensurate with the impact of the policy/proposal or decision.

There is little evidence assessed with relevance to the provisions of the Equality

Act which identifies that there may be some impact on equalities groups.

Therefore, the impact of the Streetspace programme is seen as low; except for Turnham Green Terrace, for which it was medium. This scheme was significantly amended in May 2021. 

 

 

9. What are the main conclusions and key actions/

recommendations of this equality analysis? Set out what actions you can take to mitigate any findings of adverse effects. Set out fully the actions you propose in the Action Plan below.

(You can use the information in sections 10 and11 below to inform the main report to members under the section on ‘Equalities and Human Rights Implications’. You do not need to attach this form with your Executive Report

By adding the conclusions and the key actions and recommendations to the main report you do not need to separately publish this form

The Council has considered the relevance of the proposal to the provisions of the Equality Act 2010 and the Human Rights Act 1998 and concluded that there is a disproportionate impact on two protected characteristic s – age and disability

- for the Turnham Green Terrace scheme. However, as the scheme was largely reversed under the Chief Officer Decision of May 2021, the Equalities Duties will no longer be engaged for this scheme. An extract from said report states the following “It is recommended that the experimental access restrictions, which have been suspended since 19th October 2020, are now formally abandoned and that the road remains open for all vehicles. It is also recommended the experimental parking restrictions are removed with the exception of the new disabled and loading bays which are proposed to be retained through a new experimental traffic order. Following the implementation of a new experimental order, a 6-month consultation period, it is recommended that the council commission a third party to engage with the affected businesses to determine whether there is support for a community led public realm improvement.”

The new experimental measures introduced under the Chief Officer Decision of August 2021 will be subject to equalities-related considerations and will continue to be reviewed, and this EQIA report updated, throughout the trial period. The equalities impact of the two trials at the Chiswick School ‘School Street’ on Staveley Road and Burlington Lane, both in Chiswick, will be considered before a determination is made to amend, reverse, or make the schemes permanent. 

Following the Overview and Scrutiny Committee’s recommendations of 11 April 2023, which included the retention of the experimental measures at Burlington Lane and Staveley Road, it was recognized that residents who were reliant on visits from carers and district nurses could be adversely affected by the access restrictions. This could result in slightly longer journey times for carers and nurses travelling from the A316 to Grove Park during the operational hours of the restrictions.

In view of the foregoing, Cabinet approved the following: 

  1. Access exemptions for all carers, irrespective of whether they hold residential parking permits or not, noting that those who require residential parking permits would have to apply in the usual way.
  2. Align the Council’s approach to exemptions for carers and district nurses.
  3. Review the permitting for district nurses and address it through the Council’s upcoming Parking Strategy. 

These measures should grant unfettered access to carers and nurses. 

 

 Signed (completing officer) _Jefferson Nwokeoma   

 

Equalities Analysis Action Plan

Where the equality analysis indicates a potential negative impact, consideration should be given to means of reducing or mitigating the negative effects. At this stage an Action Plan should be developed to address any concerns/issues raised in your analysis. You should also consider arrangements for reviewing the actual effect of the proposals annually once they have been implemented if appropriate.

The plan should be adopted as Equality Objectives and integrated in your Service or Business Plan.

If relevant, please list below any recommendations for action that you plan to take as a result of this equality analysis. To be completed post trial/consultation  on each scheme as appropriate.

Issue

Action Required

Lead Officcerer

Timescale

Resource Implications

Comments

 

 

 

 

 

 

 

Appendix 1

Is the policy/savings proposal/restructure/transformation decision likely to breach equalities duties below? If the proposal/policy  is notremote or peripheral to the substance of the duties set out below then an Equality Analysis is relevant.

Overview of Equality Act 2010 General Public Sector Equalities duties

Equality Act 2010 - Section149, Part 11, Public Sector Equality Duty

(1) A public authority must, in the exercise of its functions, have due regard to the need to-

(a) Eliminate discrimination, harassment, victimisation and eliminate any other conduct that is prohibited by or under the Act;

(b) Advance equality of opportunity between persons who share a relevant protected characteristic and person who do not share it;

(c) Foster good relations between persons who share a relevant protected characteristic and persons who do not share it;

 

(2) A person who is not a public authority but who exercises public functions must, in the exercises of those functions, have due regard to the matters mentioned in subsection1 above.

(3) Having due regard to the need to advance equality of opportunity between persons who share a relevant protected character istic and persons who do not share it involves having due regard, in particular, to the need to-

a)  remove or minimise disadvantages suffered by persons who share a relevant characteristic that are connected to that characteristic;

b)  take steps to meet the needs of persons who share a relevant protected characteristic that are different from the needs of persons who do not share it;

c)  encourage persons who share a relevant protected characteristic to participate in public life or in any other activity in which participation by such persons is disproportionately  low.

 

(4)  The steps involved in meeting the needs of disabled persons that are different from the needs of persons who are not  disabled

include, in particular, steps to take account of disabled persons’ disabilities.

 

(5) Having due regard to the need to foster good relations between person who share a relevant protected characteristic and persons who do not share it involves having due regard, in particular, to the need to:

a)  Tackle prejudice, and

b)  Promote understanding.

 

(6)  Compliance with the duties in this section may involve treating some persons more favourably than other; but that is not to be taken as permitting conduct that would otherwise be prohibited by or under this Act.

 

(7) The relevant protected characteristics are:a)     Age;

b)     Disability;

c)     Gender reassignment;

d)     Pregnancy and maternity;

e)     Race;

f)     Religion or belief;

g)     Sex;

h)     Sexual orientation.

 

Equality Act 2010 - Section 20, Part 2 - Duty to make adjustments for disabled people

(1) Where a provision, criterion or practice of a public body puts a disabled person at a substantial disadvantage in relation to a relevant matter in comparison with persons who are not disabled, to take such steps as it is reasonable to have to take to av oid the disadvantage.

(2) Where a physical feature puts a disabled person at a substantial disadvantage in relation matter in comparison with persons w ho are not disabled, to take such steps as it is reasonable to have to take to avoid the disadvantage.

(3) Where a disabled person would, but for the provision of an auxiliary aid, be put at a substantial disadvantage in relation to a relevant matter in comparison with persons who are not disabled, to take such steps as it is reasonable to have to take to provide the auxiliary aid.

Under Section 39, Part 5 of the Equality Act 2010, Employers must not discriminate against or victimise an employee:

  • as to the terms of employment;
  • in the way they make access to opportunities for promotion, transfer or training or for receiving any other benefit, facility or service;
  • by dismissing the employee; or subjecting them to any other detriment;
  • Employers must ensure that they do not deny workers access to benefits because of a protected characteristic.
  • Where denying access to a benefit or offering it on less favourable terms the employer must be able to objectively justify the rule or practice as a proportionate means of achieving a legitimate aim.

 

Sections 64 and 65 relate to equal pay between men and women.

  • These equal pay provisions apply to all contractual terms including wages and salaries, non-discretionary bonuses, holiday pay, sick pay, overtime, shift payments, and occupational pension benefits, and to non-monetary terms such as leave entitlements or access to benefits.
  • Other sex discrimination provisions apply to non-contractual pay and benefits such as purely discretionary bonuses, promotions, transfers and training and offers of employment or appointments to office.

 

Appendix 2

Human Rights Act 1998 which came into force in 2000

Does your proposal breach any of these Articles

Article 2 - Right to Life

Article 3 - Protection from torture and inhuman or degrading treatment or punishment

Article 4 - Protection from slavery and forced or compulsory labour

Article 5 - The right to liberty and security of person

Article 6 - The right to a fair trial

Article 7 - Protection from retrospective criminal offences

Article 8 - The protection of private and family life Article 9 - Freedom of thought, conscience and religion Article 10 - Freedom of expression

Article 11 - Freedom of association and assembly

Article 12 - The right to marry and found a family

Article 14 - Freedom from discrimination

 

For more information contact: Celia Golden

Equality and Human Rights

Borough Solicitors

Corporate Services

0208 583 2530 celia.golden@hounslow.gov.uk

 

Revised January 2013

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