EqIA - Good Quality Homes for all Londoners

Module A

Positive: Age, Disability, Pregnancy and Maternity, Race, Sex, Sexual orientation, People on low incomes

Negative: Age, Disability, Pregnancy and Maternity, Race, Religion or belief, Sex, People on low incomes

Positive: Disability

Negative: Disability

Positive: Age, Disability, Gender reassignment, Pregnancy and Maternity, Race, Religion or belief, Sex, Sexual orientation, People on low incomes

Negative: Age, Disability, Sex, Race

NA. Document contains best practice examples based on guidance set out in Modules A – C

Positive

Overshadowing and overheating are key design considerations, which could benefit groups that are less likely to spend time outdoors, such as older people who are more likely to have a disability.

2b

The positive impacts of this guidance can be maximised by encouraging applicants to produce ‘pioneering’ Circular Economy Statements, which go beyond standard practice and the minimum requirements for Statements set out in the guidance. The guidance outlines how applicants can pursue this status, which will be encouraged through the development management process.

+2

Emphasis on considering air pollution as part of site characteristics, and reducing air pollution through sufficient well-designed mitigation measures with consideration for uses by groups particularly affected (e.g. avoiding children’s play areas being located in areas of high pollution). This could benefit young and older people, who are more likely to be negatively affected by poor air quality.

Flood risk is reduced as developers should prioritise areas least likely to flood. This could particularly benefit young and older people who are particularly vulnerable in the event of a flood, as they are less likely to be able to escape independently. Whilst not encouraged by the guidance, development within a flood zone or over a certain size requires a full flood risk assessment. If approved an evacuation strategy must be provided.

Emphasis on connectivity, accessible walking routes, step-free changes, and sufficient infrastructure provision (particularly for larger sites e.g. bus and rail, services and facilities). This is likely to benefit young and older people through supportive travel by means of walking, cycling and using public transport where possible.

Incremental densification of small sites is encouraged by London Plan policy - which has been subject to an EqIA - in existing residential areas, taking into account PTAL and/or distance from a rail station. This will support access to local services, benefitting particularly people who are less mobile, such as older people who are more likely to be affected by disability.

Considering how issues intersect (e.g. walking routes in areas of lower air and noise pollution) guidance is likely to benefit protected groups by encouraging active travel where possible. It may also positively impact children and older people by reducing their exposure to poor air quality, which research shows these groups are particularly vulnerable to.

Emphasis on connectivity alongside density is likely to encourage active means of travel where possible by reducing overcrowding, a commonly cited barrier to greater public transport use cited by young people and older people Transport for London (2019).

Improving digital infrastructure provision could positively impact older people, who are less likely to be online, and young people from low income households or who are in larger families, who may have more limited digital access. It is also likely to support people to work from home, including working parents alleviating potential issues around childcare.

Play space emphasised to meet the needs of children and young people, including ensuring access to the same spaces across tenures.

Encouraging the promotion of higher density developments in areas that are well connected e.g. to services and infrastructure may help to provide more opportunities for Londoners to actively participate in the city’s life, decision making and communities which could represent a positive impact for groups who are at higher risk of social isolation including older people and people aged 20-24.

Housing types

B - House: Private amenity space may be more appropriate for families with children, including young people with Autism.

C – Cluster: Communal outdoor space opportunities could help to meet the needs of children and older people, by ensuring access to outdoor space and reducing isolation.

D – Terraces: Private gardens or courtyards likely to benefit children and older people.

E – Linear blocks: Lower floors may be more suitable for families with children due to access to outdoor space and if there is no lift access (in exceptional circumstances in blocks with 4 storey’s or less). Upper floors likely to be suitable for older people if provided with lift access.

Negative

Access to waste and recycling facilities for people with disabilities may be more difficult if the development doesn’t have lift access.

Where in exceptional circumstances private outdoor space cannot be provided, additional internal living space may instead be provided equivalent to the private open space requirement, added to the minimum GIA and the minimum combined living area of the dwelling. Justification will need to be made as to why external private outside space cannot be provided.

Housing types

E – Linear blocks: Limited private direct rear gardens access could mean this type of housing is less suitable to families with children, particularly families with children with disabilities where there is no lift access (in exceptional circumstances in blocks with 4 storey’s or less).

Lack of direct access to a garden for families is believed to be mitigated by the provision of communal outdoor space, which should be provided close to the development and accessible by children and families from different tenures. Communal outdoor space can bring positive impacts for families with children, by encouraging opportunities to meet and for children to play together. Smaller on-site communal spaces might be less likely to be used by older people however, potentially due to noise and lack of space. The guidance in Module C also requires that all dwellings should be provided with adequate private outside space however in the form of a garden, terrace, balcony or glazed winter garden. This applies to all forms of tenure. Where this cannot be provided, justification must be provided, and additional living space included.

Providing direct access to a garden for families with children is likely to positively impact on their health. The provision of communal outdoor space and private outside space such as balconies ensures that smaller households, which may include older people, still have access to outdoor space and the health benefits associated.

The cost of including lifts in linear blocks of 4 storeys or less could negatively impact on the viability of the development, as the costs may be too high for occupants. Furthermore, lift access is provided to upper levels in linear blocks of 4 storeys or more, and alternative housing types, such as towers, will always include lift provision. Building above 4 storeys may not be suitable to the site characteristics, however it ensures that housing is provided which meets the needs of people without physical disabilities. Including linear blocks that are 4 storeys or less without lift access helps to ensure viability of the scheme and meet the housing needs of people without a physical disability. Alternative housing types which are accessible are also included to ensure that the needs of people with physical disabilities are met.

F – Villa blocks: Without lift access, families with small children and/or children with disabilities, and older people on upper floors may be negatively affected

1, 2a, 2b, 2c, 3

The cost of including lift access in villa blocks could make the scheme unviable. Alternative types of housing, which are accessible, is included in the guidance to ensure that needs of older people, who are more likely to be disabled, are met. Including housing types without lift access means that housing is developed to meet the needs of younger people and families, who are less likely to have a disability.

-1

Positive

The further guidance on Design and access statements, which are a statutory requirement for certain development, should maximise opportunities for access and inclusion.

1, 2a, 2b, 2c, 3

The positive impacts of this guidance can be maximised by encouraging applicants to produce ‘pioneering’ Circular Economy Statements, which go beyond standard practice and the minimum requirements for Statements set out in the guidance. The guidance outlines how applicants can pursue this status, which will be encouraged through the development management process.

+2

The positive impacts of this guidance can be maximised by encouraging applicants to produce ‘pioneering’ Circular Economy Statements, which go beyond standard practice and the minimum requirements for Statements set out in the guidance. The guidance outlines how applicants can pursue this status, which will be encouraged through the development management process.

Taller buildings less appropriate for narrower street widths. This could help to reduce overcrowding, encourage active travel by people with disabilities and reduce isolation.

Ensuring inclusive public access to heritage asset viewing locations as required by the London View Management Framework. Heritage assets can provide landmarks that aid navigation, which can support people with wayfinding.

The importance of reducing resident exposure to air pollution is highlighted (e.g. using air quality data to inform residential type and location, engaging with air quality experts, developing mitigations such as increasing distances between buildings and busy roads, considering throughout development and the impact of multiple developments), which should positively impact people with disabilities who are more likely to be affected.

Ways to reduce noise pollution are suggested, which are likely to benefit people with disabilities, for example Autistic people who are more likely to be sensitive to noise.

Minimising the negative impacts from construction and demolition could positively impact people with a visual impairment, who are particularly affected by changing routes and street clutter.

2a, 2b, 2c, 3

Prioritising areas least likely to flood and including mitigation (e.g. locating vulnerable users or people on upper floors) is likely to positively benefit people with disabilities.

Addressing flood risk, urban heat and poor air quality through well-designed green infrastructure could positive impact children and young people, older people and people with disabilities, who are more vulnerable to these issues.

Requiring a delivery schedule for phased developments including details on how accessibility will be enhanced is likely to positively impact people with disabilities, as it ensures access and inclusion issues are considered early on and supports implementation.

The guidance supports clearly legible and easily accessible entrances, which is likely to positively impact disabled people.

Encouraging noise analysis for mixed use developments is likely to positive impact disabled people, particularly Autistic people, by helping to minimise noise pollution.

Housing types

B – House: This type may be more appropriate for people with disabilities, including Autistic people, due to direct access from the street and access to private amenity space.

C – Cluster: Opportunities for communal outdoor space could benefit people with disabilities in terms of ease of access and facilitating social interactions.

D – Terraces: Access to private gardens or courtyards and disabled persons parking could mean that this type is more suitable for disabled people.

E – Linear blocks: Lower floors may be more suitable for people with mobility impairments. Suitable for wheelchair accessible houses when planned with lift access. Ground floor more suitable for people with disabilities and Autistic people, if separate entrances can be provided.

G – Tower: Wheelchair accessible units suitable throughout due to lift access.

Module B – frontage line of new developments should not negatively impact street scene or create street canyons / result in poorer air quality. This could positively impact disabled people in terms of supporting accessible streets, and protect air quality, which some disabled groups, for example people with asthma, may be particularly affected by.

Negative

Car parking may be needed by people with disabilities and carers.

Mixed-use development in well-connected areas should be car-free (with the exception of disabled persons parking). Car parking standards are specified within the London Plan which take into account the needs of people with disabilities.

In line with London Plan policies, Module C requires that large-scale redevelopment areas (i.e. Opportunity Areas) should consider how local air quality can be improved as part of an air quality positive approach. All other development should be at least Air Quality Neutral. Air Quality Assessments should be submitted with all major developments.

Equality considerations are considered as part of a scheme's development, for example through Inclusive Design Statements and Equality Impact Assessments. Cumulative equality impact assessments which may be conducted by local authorities should also help to identity difficulties from multiple tall buildings and their impact on parking for disabled people and carers. The London Plan also includes parking requirements for schemes, which recognises the needs of disabled people.

Building in flood risk areas is not promoted in the guidance. If a development was being considered in a flood risk area, a flood risk assessment would need to be conducted. If a scheme was permitted, it would need to have an evacuation strategy, which included the needs of disabled people. As highlighted in Module C, where development in areas at risk from flooding is permitted, homes should make space for water and aim for development to be set back from the banks of watercourses and be designed to incorporate flood resistance and resilience measures.

Minor schemes not needing infrastructure assessments could mean less consideration is given to the public realm including public transport, which would support disabled people.

Use of soft landscaping to minimise noise could introduce barriers to people with a visual impairment.

Alternative smaller housing types are also provided (e.g. houses and terraces) which may be suited to the needs of Autistic people. Communal space may help to foster good relations between different groups. It also helps to ensure that housing targets are met. Ground floor units may have direct access to properties also, although these are more likely to be family sized, and so would more likely benefit families and people with Autism.

Housing types

C – Cluster: Stacked maisonettes – without level access, this housing type may be less suitable to people with disabilities, particularly if they cannot be adapted to make them accessible in the future, thus increasing the chance that a person developing a disability would need to move.

Whilst this may not be the most suitable development for people with disabilities the broad range of other delivery types is designed to mitigate. Terraces are also an efficient way of providing larger homes and so help to meet the needs families. Access to upper floors e.g. via stairlifts, could be made possible through future adaptations to the property. Providing lift access could make the scheme unviable as the costs could be too high to pass to occupants.

The guidance does not recommend building in flood risk areas. However, if permitted following a full flood risk assessment, providing residential accommodation at upper levels could help minimise negative impacts on occupants. Module C specifies that development permitted in areas at risk of flooding should be set back from the banks of watercourses and be designed to incorporate flood resistance and resilience measures. Whilst accommodation at upper levels without lift access may not be suitable for people with disabilities, adaptations could potentially be made to make the property accessible. Alternative housing types also offer level access helping to ensure that the needs of disabled people are met.

E – Linear blocks Level access is not guaranteed, for example, for blocks that are 4 storeys or less. This may negatively impact people with disabilities as it may limit choice, as accommodation on upper floors may not be accessible. It may make it difficult for disabled people to occupy units on upper levels and/or to visit their neighbours on upper floors. It may make it harder for disabled people to visit people living on upper levels also - this could include friends, family and/or professionals from organisations. It may mean that a property cannot be adapted to meet the needs of people with a disability, and people may need to move if they develop a disability in the future.

Maisonettes encouraged at ground floor to provide family units where required. However, this may negatively impact on the availability of accommodation for disabled people, who may require smaller household units.

Development proposals should ensure that communal refuse, recycling and food waste containers, communal bin enclosures and refuse stores are easily accessible to and usable by all residents including children and disabled people, and located on a hard, level surface.

Module C specifies that development proposals should demonstrate that they achieve the highest standards of fire safety, identify unobstructed outside space for fire appliances which is also appropriate for use as an evacuation assembly point, and provide suitable and convenient means of escape and an associated evacuation strategy for all building users.

In line with London Plan policy, schemes are required to have evacuation strategies, which consider the needs of disabled people and how they would evacuate in the event of a fire. The highest standards of fire safety should be embedded in developments from the earliest possible stage. For major applications, applicants must submit a fire statement to demonstrate that the requirements of Policy D12 have been considered as an integral part of their proposals. Applicants must demonstrate within the Fire Statement that the means of escape for all building users has been considered and planned into the scheme from the outset. It is essential that all building users have been considered and planned for within the design of the means of escape and evacuation strategy.

There are a number of evacuation strategies that applicants could incorporate. The strategy must make provision for everyone, including people who require level access, disabled people with a range of impairments (including mobility, sensory and cognitive impairments), and people who do not have a good understanding of English.

F - Villa blocks: Limited access to street frontages and open public spaces from dwellings could make this housing type less suitable for people with disabilities. Also, if upper levels are planned without lift access, this housing type may be less suitable for people with physical impairments and it may mean people are more likely to have to move if they develop a physical impairment.

If planned without lift access, access to waste and recycling facilities and means of evacuation may be more difficult.

Evacuation means for all occupants should be included in evacuation strategy and Fire Statements. Development proposals should demonstrate that they achieve the highest standards of fire safety, identify unobstructed outside space for fire appliances which is also appropriate for use as an evacuation assembly point, and provide suitable and convenient means of escape and an associated evacuation strategy for all building users.
Noise insulation is included in standards, which may mitigate this.

Module B

Access may be more restricted for small sites, such as back land developments, depending on site specific considerations.

Developments that bookend a street or on a corner could have a frontage line that steps out in front of adjacent buildings, which could impact on accessibility for people with disabilities e.g. people with a visual impairment and wheelchair users.

Distances between buildings can be reduced in certain circumstances, which could reduce space for disabled parking.

As suggested by the London Plan, conversions could be exempt from M4(2) (e.g. see example 4.1.1. or when houses are converted to maisonettes).

2a, 2b, 2c

Occupant could still ensure accessibility requirements at a later date

0

Positive

No anticipated impacts

Negative

No anticipated impacts

Positive

No anticipated impacts

Negative

No anticipated impacts

Positive

Emphasis on access to open space and reducing air pollution are likely to positively impact people who are pregnant and people with small children.

2a, 2b, 2c

+2

Research by Transport for London (2019) highlights that parents of young children face barriers to accessing public transport in London including overcrowding. Ensuring that the scale of development relates to existing or future infrastructure capacity will help to mitigate the impacts of a growing population on the public transport network. Managing future levels of crowding by improving transport capacity and connectivity should have a beneficial impact on those who share the protected characteristic of pregnancy and maternity by helping make public transport journeys more comfortable.

Housing types

B (House), C (Cluster) and D (Terraces) are likely to be suitable for people with small children due to access to private amenity or communal outdoor space or courtyards.

E – Linear blocks: Lower floors may be more suitable for people with small children due to ease of access (especially when planned with lifts).

Negative

E – Linear blocks: The lack of private garden space could mean that this housing type is less suitable to people with children.

Upper floors without lift access are likely to be less suitable to people with small children / prams.

2a, 2b, 2c

Developments are expected to be planned for so that 90% meets M4(2) accessible and adaptable requirements and 10% meets M4(3) wheelchair accessible. In unusual circumstances, in housing types of 4 storeys or less, lift access may make the scheme unviable. It is felt that the provision of housing in these exceptional cases outweighs the negative impact of not providing lift access. Alternative housing types that meet the needs of people who are pregnant or on parental leave through level access.

0 / -1

Positive

Just under a third (30%) of Bangladeshi households and15% of Black African households are classified as overcrowded, compared to only 2% of white British households (English Housing Survey 2018). Encouraging more housing delivery is of benefit to groups that are more likely to live in sub-standard or overcrowded housing.

2a, 2b

The positive impacts of this guidance can be maximised by encouraging applicants to produce ‘pioneering’ Circular Economy Statements, which go beyond standard practice and the minimum requirements for Statements set out in the guidance. The guidance outlines how applicants can pursue this status, which will be encouraged through the development management process.

+2

Encouraging enhancements to walking areas, promoting cycling, access to open space and reducing air and noise pollution, improving connectivity and infrastructure provision are likely to positively impact on BAME groups. For example, research by Sport England (2020) shows lower participation in sport amongst BAME communities. Research by the Institute of Fiscal Studies (2020) shows that Black people are more likely to be overweight than White people, while both Asian and Black populations have been found to have a higher risk of diabetes and heart disease. Enhancements to walking areas and improving connectivity and infrastructure provision could encourage active travel amongst BAME groups and positively impact on health.

Protecting heritage and cultural views could positively impact on the protected characteristic of race, by potentially ensuring that buildings of cultural significance to people from minority backgrounds are preserved.

Providing affordable housing is a key consideration. Affordable housing should be outlined in delivery schedules, where delivery will be phased, which may help to secure affordable housing. This is likely to positively impact BAME groups who are more likely to be living in poverty.

Family size and the needs of households including multiple generations are included in housing need assessments and London Plan policy H10, which focuses on housing size mix.

Housing types

B (House), C (Cluster) and D (Terraces) are likely to be suitable due to the provision of private amenity space, communal outdoor space and private gardens or courtyards.

Negative

E Villa blocks: Limited access to street frontages and open public spaces from dwellings could potentially negatively impact on families.

Extent to which the housing types meet the needs of Gypsies and Travellers.

2b

0

Positive

Buildings worthy of retention and their uses considered as part of site assessments, and heritage assets and protecting cultural views – this could include limit negative impacts on buildings used by people of particular religions or beliefs.

2a, 2b, 2c

+1

Housing types

B (House), C (Cluster) and D (Terraces) are likely to be suitable for people of particular religions or beliefs due to the provision of private amenity space, communal outdoor space and private gardens or courtyards. This could support people who have a religion or a belief to practice their religion or belief with others, for example through community gatherings. However, access to communal outdoor space and private outdoor space is a key consideration in Module C, across all housing types and other policies of the Plan encourage associated infrastructure development to meet wider community need in any case.

Housing size is also considered through housing needs assessments and London Plan policy H10.

Negative

No anticipated impacts

Positive

Evaluation of social infrastructure provision could positively impact women, as women tend to provide more informal care and rely more on social infrastructure provision.

2a, 2b, 2c

+2

Negative

E Villa blocks: Limited access to street frontages and open public spaces from dwellings may negatively impact people with small children. 90% of lone parents are women and so women may be more likely to be affected.

Without lift access people with prams could find it difficult to access.

2a, 2b, 2c

90% of development should be M4(2) and 10% M4(3). Level access is expected to be provided. Where this is not possible in unusual circumstances due to the cost of lift access affecting the financial viability of the scheme, the provision of housing is argued to outweigh the possible negative impact.

0 / -1

Positive

Assessing physical site characteristics includes identifying existing buildings worthy of retention and their uses and heritage assets, which could include significant buildings to LGBT+ communities.

2a, 2b, 2c, 3

+2

Providing affordable housing is a key consideration. Affordable housing should be outlined in delivery schedules, where delivery will be phased, which may help to secure affordable housing. This is likely to positively impact LGBT young people who are more likely to be homeless than non-LGBT peers, due to increased likelihood of familial rejection.

Negative

No anticipated impacts

Positive

Evaluating infrastructure capacity could improve energy efficiency and reduce fuel poverty.

2a

+2

Providing affordable housing is a key consideration. Affordable housing should be outlined in delivery schedules, where delivery will be phased, which may help to secure affordable housing. This could particularly benefit BAME young LGBT people who are on low incomes, due to their increased risk of living in poverty and of being homeless.

Improving connectivity to social and transport infrastructure can improve access to jobs and services, which may positively impact people on low incomes.

Housing types

E (Linear blocks), F (Villa blocks) and in some cases G (Towers) offer opportunities to generate larger amounts of new affordable housing.

Lower rise may also be more appropriate than towers in lower value locations to maximise the affordable housing offer.

Negative

Improving connectivity to social and transport infrastructure can impact on the value of land and depending on local circumstances this could inflate the cost of accommodation in some areas, particularly impacting private renters on lower incomes such as older retired people, some disabled people, or students.

D – Terraces: Opportunities to generate affordable housing are reduced due to lower densities/ homes more likely to come forward through minor development.

G –Tower: Taller buildings do not always result a higher percentage of affordable homes within a development, due to higher development costs. This may be more evident in lower value locations.

The London Plan aims to achieve 50% affordable housing which includes consideration of different types of housing. Taller buildings are still likely to provide a higher number of affordable homes when compared to other housing types.

-1

Positive

In line with London Plan policy SI1, development should be designed to reduce resident’s exposure to air pollution, and to meet the needs of older people and families with young children.

2a, 2b, 2c

+1

All open space should be designed to be safe, accessible and inclusive, avoiding features which could enhance the fear of crime.

Shelter from the wind is likely to encourage social activity outside for children and older people.

For developments where 10 or more children and young people are expected to live, development proposals should make appropriate play and informal recreation provision in accordance with London Plan Policy S4. Children’s play space should be designed to be stimulating and incorporate greenery, be overlooked to enable passive surveillance, be accessible to all tenures and be safely accessed from the street by children and young people independently. Play space should be carefully integrated into a scheme, which is likely to benefit children and young people.

Play space and communal areas should be located in areas with low air pollution. This should positively impact children and older people, who are more vulnerable to poor air quality.

Where family units are prov ided on the upper floors, it is important to ensure appropriate private open space is provided with adequate outlook, orientation, and privacy. This is likely to positively impact on families with children.

Development proposals should demonstrate how they have been designed to meet the needs of a diverse population, including older people and families with young children in terms of site arrangements.

Negative

Locating footpaths and cycleways next to trafficked streets could increase exposure young and older people’s exposure to air pollution.

The potential increased exposure to poorer air quality is argued to be justified by increasing safety and security for pedestrians and cyclists. The benefit of increased safety through surveillance is likely to positively impact young and older people, reduce fear of crime and isolation. Air quality assessments are required as part of large developments. Reducing air pollution is a key feature of good quality design, highlighted throughout Modules A, B and C. Furthermore, the Mayor's Health Street approach and modal shift to 80% of journeys to be made by walking, cycling and public transport should over time improve air quality at street level.

Provision of mobility scooter parking could help older people to maintain their independence and reduce social isolation.

2a, 2b, 2c

Disabled car parking is included which should help to ensure that the needs of people with disabilities and carers are met. Mobility scooter storage could be added to developments as part of good quality design.

-1

Positive

Development proposals should ensure access and inclusion in terms of inclusive design. They should demonstrate how they meet the needs of disabled people and the provision of accessible housing, entrances, disabled persons car parking and access to public transport networks. This is likely to positively impact disabled people in terms of increasing accessible housing, supporting access to facilities and services and reducing social isolation.

1, 2a, 2b, 2c

+2

Wheelchair user dwellings should meet the design requirements set out in Approved Document M volume 1, M4(3).

Minimum space required for private outside space should meet building regulation accessibility standards (90% must be M4(2) accessible and adaptable and 10% must be M4(3) wheelchair accessible).

Developments should minimise noise pollution to sound sensitive rooms and reduce resident’s exposure to air pollution. This could support people with a disability, particularly Autistic people who are more likely to be sensitive to noise. It is also likely to reduce any negative impact of noise pollution on health.

Level changes on sites can be exploited while still ensuring that accessible housing is provided, and the highest standards of access and inclusion are met throughout the site.

All open space should be designed to be safe, accessible and inclusive, avoiding features which could enhance the fear of crime.

Creative approaches should be developed for play equipment which is accessible and inclusive for a range of users, including people with a range of impairments. This is likely to benefit people with disabilities, including children, including having a positive impact on health.

Wheelchair user dwellings should generally be provided for all tenures of housing to maximise choice for wheelchair users. However, wheelchair users disproportionately require affordable housing and so at least 10% of affordable homes should comprise wheelchair user dwellings with a mix of dwelling types to cater for a broad range of household sizes, ages of residents and varying family needs.

All other dwellings to which Part M volume 1 of the Building Regulations apply should be ‘accessible and adaptable’. The guidance reiterates the importance of accessible housing for disabled people.

The approach to all entrances, should be level or gently sloping. All main entrances should be illuminated and have level access. This should benefit people with disabilities, including wheelchair users, people with sensory impairments, people living with dementia and people with invisible disabilities, as well as older people who are more likely to be at risk of falls.

Communal cycle stores should include accessible stand types and have step-free access. This is likely to positively impact people with disabilities by promoting access to cycling and encouraging exercise, which is likely to have positive health benefits.

Shared approach routes, including the vertical circulation in the common parts of a block of flats, and communal areas between dwellings of different categories (i.e. M4 (2) and M4 (3)) should meet the highest numbered category of dwelling to ensure that people can visit their neighbours with ease. This is likely to positively impact disabled occupants in terms of reducing social isolation. It will also support people with disabilities to visit occupants, both friends and family of occupants and professionals from organisations.

Architects are encouraged to indicate in Design and Access Statements how dwelling types facilitate flexible use so that changes in circumstances and lifestyle can be accommodated without residents having to move to a new home. This is likely to positively impact residents with disabilities by increasing their choice of accommodation and supporting them to stay in their own homes for longer, should they wish to.

The guidance aims to reduce the negative impacts of noise, which could positively impact people with disabilities, including Autistic people. It could also help support people’s mental health. Residents should be able to get to public transport, shop for food, relax in a park or have access to food and beverage facilities within comfortable walking distance of their home. This should positively benefit people with physical disabilities who may find it harder to travel further independently and without access to a car.

Communal areas should be located in areas with low air pollution. This should positively impact people with disabilities, who are more vulnerable to poor air quality.

Overheating strategy should take into account external noise, which may positively impact disabled people by reducing noise disruption.

Emergency means of escape should be designed to incorporate safe and dignified emergency evacuation for all building users.

Negative

Communal spaces and courtyards if not planned sensitively and with the input of people with lived experience of disabilities may not be accessible for disabled people.

Designing to encourage social interaction may positively impact residents, including older people, who are more likely to be affected by social isolation. It could also help to foster good relations between groups with a protected characteristic, and in doing so, reduce prejudices. Private entrances are provided for some types of accommodation, ensuring that the needs of Autistic people are met.

Provision of mobility scooter parking could support independence and reduce social isolation.

Open-plan living, dining and kitchen spaces are often considered to be the market preference, however with more people working from home due to Covid-19, families and people with disabilities may find it hard to work from home successfully in open-plan environments. but there are times when it is preferable to achieve a degree of separation, at least between the living space and the work area of the kitchen.

2a, 2b

The guidance highlights that at times it may be preferable to achieve a degree of separation, at least between the living space and the work area of the kitchen. The guidance also notes that homes in which living, dining and kitchen functions are combined in a single space can make it difficult for family members to pursue different activities at the same time without disturbing each other. Even very large rooms will not be flexible when there is an insufficient area of external wall with windows to allow for sub-division.

0

Positive

All open space should be designed to be safe, accessible and inclusive, avoiding features which could enhance the fear of crime.

2a, 2b, 2c, 3

+2

Negative

No anticipated impacts

Positive

No anticipated impacts

Negative

No anticipated impacts

Positive

Development proposals should demonstrate how they have been designed to meet the needs of families with young children and access to outdoor space and play space is a key consideration. For developments where 10 or more children and young people are expected to live, development proposals should make appropriate play and informal recreation provision in accordance with London Plan Policy S4. This is likely to positively impact parents of small children, including positively impacting on physical and mental health.

2b, 2c, 3

+2

Where family units are provided on the upper floors, it is important to ensure appropriate private open space is provided with adequate outlook, orientation, and privacy. This is likely to positively impact on families with children.

Negative

No anticipated impacts

Positive

Development proposals should demonstrate how they have been designed to meet the needs of families with young children.

2b, 2c, 3

+2

All open space should be designed to be safe, accessible and inclusive, avoiding features which could enhance the fear of crime.

Provision of communal spaces, where possible, that are of value to the existing or future community such as well-located open green spaces or community rooms that enable a variety of activities, can help to foster active participation in social life.

Development proposals should demonstrate that meaningful engagement has taken place with existing communities from the early design stage in order to help define specific community needs and aid with any integration of new communities.

Fire Statements include ensuring that people who speak little or no English are planned for in terms of evacuation.

Homes for larger families should cater for activities involving family members and visitors and should have sufficient social spaces e.g. homes with 3+ bedrooms should have two social spaces, both with external windows.

Where housing is being designed to suit specific cultural requirements, designers might (depending on said cultural requirements) find a preference for the kitchen to be separated from the living and dining spaces. Different methods of cooking may require larger kitchens with additional ventilation or features.

Narrow living rooms are discouraged. It is recommended that the width of the principal sitting space is at least 3.2m for dwellings with four or more occupants, and at least 2.8m in dwellings for those with fewer than four occupants.

Negative

Housing types without lift access (e.g. linear blocks with 4 storey’s or less) may be difficult to access for families with small children

2b, 2c

It is expected that all new build developments will include level access and meet targets of 90% accessible and adaptable (M4(2)) and 10% wheelchair accessible (M4(3)). In exceptional and unusual cases, developments that are 4 storeys or less or stacked maisonettes, or buildings above shops may be exempt, if providing level access would make the scheme unviable. Providing alternative housing types ensures that accessible housing is provided. Building in exceptional circumstances without level access would still benefit non-disabled people, including other protected groups, and can help to ensure that affordable housing is provided benefiting low income groups.

-1

Positive

All open space should be designed to be safe, accessible and inclusive, avoiding features which could enhance the fear of crime.

+2

Provision of communal spaces, where possible, that are of value to the existing or future community such as well-located open green spaces or community rooms that enable a variety of activities, can help to foster active participation in social life.

Where housing is being designed to suit specific cultural requirements, designers might (depending on said cultural requirements) find a preference for the kitchen to be separated from the living and dining spaces. Different methods of cooking may require larger kitchens with additional ventilation or features.

Narrow living rooms are discouraged. It is recommended that the width of the principal sitting space is at least 3.2m for dwellings with four or more occupants, and at least 2.8m in dwellings for those with fewer than four occupants.

Negative

Housing types without lift access (e.g. linear blocks with 4 storey’s or less) may be difficult to access for families with small children, which may affect people of particular religions more as research indicates that they may be more likely to have higher numbers of dependent children.

It is expected that all new build developments will include level access and meet targets of 90% accessible and adaptable (M4(2)) and 10% wheelchair accessible (M4(3)). In exceptional and unusual cases, developments that are 4 storeys or less or stacked maisonettes, or buildings above shops may be exempt, if providing level access would make the scheme unviable. Providing alternative housing types ensures that accessible housing is provided. Building in exceptional circumstances without level access would still benefit non-disabled people, including other protected groups, and can help to ensure that affordable housing is provided benefiting low income groups.

-1

Positive

All open space should be designed to be safe, accessible and inclusive, avoiding features which could enhance the fear of crime.

2a, 2b, 2c, 3

+2

Negative

Housing types without lift access (e.g. linear blocks with 4 storey’s or less) may be difficult to access for families with small children.

2b, 2c

It is expected that all new build developments will include level access and meet targets of 90% accessible and adaptable (M4(2)) and 10% wheelchair accessible (M4(3)). In exceptional and unusual cases, developments that are 4 storeys or less or stacked maisonettes, or buildings above shops may be exempt, if providing level access would make the scheme unviable. Providing alternative housing types ensures that accessible housing is provided. Building in exceptional circumstances without level access would still benefit non-disabled people, including other protected groups, and can help to ensure that affordable housing is provided benefiting low income groups.

-1

Positive

All open space should be designed to be safe, accessible and inclusive, avoiding features which could enhance the fear of crime.

2a, 2b, 2c, 3

+2

Negative

No anticipated impacts

Positive

Development proposals should demonstrate that housing of different types and tenures have been fully integrated, and that the quality of architecture and materials is consistent across all tenures. Affordable homes should have the same external appearance as private market homes.

1, 2a, 2b, 3

+2

In some higher-density schemes, separate provision of entrance and circulation spaces for different tenures may be permitted to support the viability of the scheme. However, the size and legibility of all residential entrances should be designed such that equal weight is given to the quality and accessibility of residential entrance lobbies and their visual presence from the public realm.

Residents of all homes in a residential tower should have access to all communal amenity and play space that serves the building.

There should be equitable access to on-site cycle parking and any car parking spaces for different tenures based on the proportion of affordable homes within the scheme.

Developments such as gated communities that might compromise objectives to secure a more socially inclusive city should be resisted.

This guidance requires that all dwellings should be provided with adequate private outside space in the form of a garden, terrace, balcony or glazed winter garden. This applies to all forms of tenure, including affordable rent. This ensure that low income residents have access to private outside space, which is likely to positive impact on their health.

Costed plans should set out how management arrangements will work in mixed-tenure schemes, and how residents’ views will be taken into account in delivering affordable services. This should help to ensure that the needs of low-income residents are taken into account.

Negative

No anticipated impacts.

Module A and B

+1

0

n/a

No anticipated impacts

+1

+1

+1

+1

+2

+2

What changes have you made to the guidance as a result of this EqIA?

Why have these changes been made?

No major change to the guidance is required

This EqIA has not identified any potential for discrimination or negative impact, and all opportunities to advance equality have been taken.

x

Adjustments to the guidance are required to remove barriers identified by the EqIA or better advance equality.

Justify and continue with the guidance despite having identified some potential for negative impacts or missed opportunities to advance equality.

Stop, rethink or abandon when the EqIA shows actual or potential unlawful discrimination

London boroughs have a relatively young population. The median age of Londoners was 35, compared to a national average of 40.

32% of Londoners are under the age of 25 and 11% are aged 65 or over (ONS 2011).

Older Londoners (aged 65 or over) are more likely to be women (London Travel Demand Survey 2016/17).The GLA projects that, in 2019, over a fifth of London’s population are under 16 (1.9 million). Over two-thirds, or 6.2 million, are working age (aged between 16 and 64), and less than one in eight are 65 or over (1.1 million). Despite being the smallest age group in London’s population, the number of Londoners aged 65 or over is projected to increase by 86 per cent between 2019 and 2050, faster than younger age groups (GLA City Intelligence Unit 2018).

16% of working age Londoners aged 16 to 64 were disabled between 2015 to 2017 (ONS 2017). This is slightly younger than the national average for Great Britain of 20%, reflecting London’s younger population.

There are 1.3 million disabled adults in London, defined according to the Equality Act 2010 as having a physical or mental impairment that has a 'substantial' and 'long-term' negative effect on their ability to do normal daily activities (ONS 2019).

14% of Londoners consider themselves to have a disability that effects their day-to-day activities ‘a lot’ or ‘a little’ (ONS 2011).

Disability is closely related to age: 13% of the working age population are disabled versus 28% of people aged 65 or over (ONS 2019).

56% of disabled Londoners are women, compared with 50% of non-disabled Londoners
Disabled people are also are more likely to be on a low income (61% of disabled people are also on low income). 34% per cent of disabled Londoners have a household income of less than £10,000 compared with 10% of non-disabled Londoners (London Travel Demand Survey 2016/17)

84% of disabled Londoners report that their disability limits their ability to travel.

55% of disabled Londoners state that their disability affects their mobility, 22% have a serious long-term illness and 10% have a mental health condition.

Many disabled people experience multiple impairments.

According to GP records, approximately 2 per cent of London’s population, or around 175,000 people, have a learning disability (Public Health England in GLA 2019).

EHRC (2018) The housing experiences of disabled people in Britain
Key factors for successful independent living for disabled people include accessibility features such as adapted kitchens and bathrooms; a feeling of safety and security and being in a good location with access to shops, transport and public services.

Lack of availability of accessible housing across all tenures.

Living in unsuitable accommodation can cause deterioration in mental wellbeing.

Appropriate housing is often either unavailable or unaffordable.

Disabled people in the private and social rented sectors were more likely to have experienced poor housing than disabled homeowners. Although homeowners overall had more choice and control over their housing, many had experienced considerable difficulty purchasing accessible homes, particularly within an affordable price range

LSE (2016) No Place Like an Accessible Home Quality of life and opportunity for disabled people with accessible housing needs

At least 1.8 million households (one in twelve of all households) in England have an identified need for accessible housing, of whom 580,000 (one third) are working age.

0.7 million households (around one in thirty of all households) have more significant needs corresponding roughly to Building Regs 2/3.

Real need estimated to be higher, as English Housing Survey does not include figures for disabled children.

DCLG (2016) English Housing Survey Adaptations and Accessibility Report, 2014-15

There were around 814,000 (4%) households with a wheelchair user in England in 2014. Around 521,000 (64%) of these households included someone who only required a wheelchair outside the home while 210,000 (26%) of these households contained someone who used a wheelchair all the time. The remaining 84,000 (10%) households had someone who just used their wheelchair when indoors. Among all households with a wheelchair user, 84% (685,000) lived in a home that did not have full visitability including the 19% (158,000) who lived in a home that lacked any of the four features (level access to the entrance, a flush threshold, sufficiently wide doorways and circulation space, and a toilet at entrance level). One visitability feature was most commonly present for these households (32%).

Terraced (41%) and semi-detached (34%) houses were far more likely to have none of the four accessibility features than detached houses (9%) or flats (10%).

The majority of homes lacking full visitability could be adapted to provide all four features. It was more difficult for terraced houses and older properties to be made fully visitable Terraced houses were the most likely dwelling type to be not feasible to be made fully visitable (50%) compared with flats (27%), and other houses (semidetached, 15% and detached, 14%).

In 2014-15, one in ten households (10%) which included a person with a long-term limiting disability requiring adaptations wanted to, or were trying to, move somewhere more suitable for their needs. Nearly half of the households (47%) that wanted to move somewhere more suitable contained a person with a long-term disability aged under 55.

In 2014, almost two thirds (64%) of homes had a toilet at entrance level but the presence of the other three visitable features were less common, especially level access, which was present in just 18% of homes. Of the other accessibility features assessed by the English Housing Survey, the most common in 2014 were the absence of any trip steps (75%) and the presence of a room at entrance level that could be converted into a bedroom (56%). Less common were the presence of a bathroom at entrance level (39%), and straight stairs (for the installation of a stair lift) with a sufficiently wide landing to allow wheelchair access (24%). Just a fifth had a wheelchair accessible toilet at entrance level (20%).

Although a quarter of newer homes built since 1990 (24%) could be made compliant with minor works only, a similar proportion (25%) of these homes were not feasible to make fully visitable. This latter finding can be partly explained by the dwelling type profile of newer homes, namely the relatively high proportion of flats that have been built; where these are not fully visitable, it is often impractical to extend or redesign these homes.

Improving the accessibility of terraced homes would be the most challenging, with half (50%) of these homes simply not feasible to make fully visitable in 2014. This is partly because smaller and mid-terraced homes do not easily allow for any moderate or major adaptations, such as the rearrangement of internal space or building extensions to take place. There are similar issues with extensions to upper floor or basement flats and so 27% of flats were not feasible to make visitable. Over half of semi-detached (58%) and detached homes (60%) could be made fully visitable through a moderate level of work but 15% and 14% respectively were not feasible to make them to compliant.

There are no current data sources on gender identity in London or the UK as a whole. Research carried out in 2012 on the acceptability of gender identity questions in surveys provided an indicative estimate that 1% of the UK population identify as trans (EHRC, 2012). The Government Equalities Office tentatively estimated that around 0.3- 0.8% of the UK population in 2018 were transgender (approximately 200 000 to 500 000 people).

In 2015, 5% of partnerships formed in London were same sex marriages or civil partnerships.
39.8% of adults aged 16 and over in 2011 in London were married, and 0.4% were in a same sex civil partnership. The national respective figures were 46.6% and 0.2%.

58% of live births were born to mothers who were born outside the UK, compared to a national average of 28% (ONS, 2017).

Pregnant women and people on maternity and paternity leave using buggies are more likely to require level access to buildings. Housing types without level access, such as linear blocks that are 4 storeys or less without lift access, may be more difficult to access.
Pregnant women may also be negatively affected by overcrowding on public transport.

Race

Black, Asian and minority ethnic (BAME) Londoners make up 40% of London’s population (ONS 2011). BAME Londoners are more likely to be younger and on lower incomes. For instance, 44% of people on low incomes in London are also BAME (London Travel Demand Survey 2016/17). Cost of travel is more often mentioned as a barrier to public transport use by BAME Londoners (51%). BAME Londoners are more likely to live in households with an average annual income below £20,000 (33% BAME compared with 25% white) [11].

Most Londoners have English as their main language (78%). However, 4% do not speak English well (ONS 2011).

Research by Sport England (2020) shows that people from Asian, Black and Chinese backgrounds are far more likely to be physically inactive than those who are White.
Research by the Institute of Fiscal Studies 2020 shows that Black people are more likely to be overweight than White people, while both Asian and Black populations have been found to have a higher risk of diabetes and heart disease.

Furthermore, just under a third of Bangladeshi households are classified as overcrowded, as are 15% of black African households, according to the English Housing Survey (2018). Only 2% of white British households are classified as overcrowded.

18.9% of Black households were made up of a single parent with dependent children, the highest percentage out of all ethnic groups for this type of household; the lowest percentage was found among Asian households, at 5.7% (Census 2011).

The 2011 Census shows that the representation of religion and beliefs of Londoners has changed over the past 10 years. There has been a decline in the proportion of Londoners considering themselves to be Christian (58% to 48%). There has also been an increase in the proportion who do not identify with any religion (16% to 21%).

Religion varies considerably between ethnic groups:

While 28% of white and 27% of mixed Londoners report they have no religion, only 7% of Black and 8% of Asian Londoners report this.

More than half of Black (68%) and white (57%) Londoners report that they are Christian. Asian Londoners and Londoners who have selected ‘other’ to describe their ethnic group are most likely to be Muslims (36% of Asian Londoners and 50% of Londoners selecting ‘other’ ethnic group are Muslims).

Research by the Equality and Human Rights Commission highlights that in England, there was a higher percentage of Christians who were recorded as overweight or obese (66.6%), compared with people with no religion (55%). The percentage of religious minorities recorded as overweight or obese was 56.4% in 2012.

Half of Londoners are women (51%) (ONS 2011).

In 2019, the GLA projected that 4.55 million Londoners were female and 4.55 million were male (GLA Intelligence Unit 2018). Women face particular issues around gender-based violence and low pay. As the majority of lone parents (90%) are women, recent reforms to welfare that have affected lone parents have had a disproportionate impact on women. 18.9% of Black households and 16.2% of Mixed households were made up of a single parent with dependent children, the highest percentage out of all ethnic groups for this type of household; the lowest percentage was found among Asian households, at 5.7% followed by White households at 6.7% (Census 2011).

Women sharing other characteristics women often face additional challenges, such as higher gender pay gaps among older and BAME women (All-Party Parliamentary Group on Sex Equality 2018). Young women report issues around financial pressures and mental health issues (Young Women’s Trust 2017). Men face issues around lower educational attainment and are at higher risk of suicide (EHRC 2018).

Londoners living in a lower income household (less than £20,000 per year) are more likely to be women (London Travel Demand Survey 2016/17).

Women in London are more likely to be older (ONS 2011).

Men are more likely than women to be working full-time.

Women more likely to be unemployed than men and are more likely to work part-time.

Women are more likely than men to be travelling with buggies. This could mean that women are more likely to be affected by lack of level access.

Statistics about the size of the LGB population vary considerably and there is no single widely accepted measure. The 2017 GP Patient Survey found that 5.4% of Londoners identified as Lesbian, Gay, Bisexual or ‘Other’ compared to the national rate of 3.3%. Figures from the 2017 Annual Population Survey provide lower estimates for London and England (3.2% and 2.6%).
LGB Londoners are significantly more likely than heterosexual Londoners to have experienced incidents of unwanted sexual behaviour or hate crime.

LGBT young people are more likely to find themselves homeless than their non-LGBT peers, comprising up to 24% of the youth homeless population.

No gaps have been identified at this stage. Additional data that could inform the EqIA may include the number of disabled people by household size, for example that held by Local Planning Authorities in relation to social housing.

List the protected groups that have been engaged through the informal engagement - Please refer to the engagement table 2 below.

If groups are identified in the assessment who have not been previously engaged, briefly set out how they will be targeted through the formal engagement (i.e. either a specific focus group meeting or invitation to community webinar event) and timeframes.

Already engaged:

The guidance has been developed by a broad network of built environment and planning professionals, including Mayor’s Design Advocates.

Young Londoners working with the Stephen Lawrence Trust have had their say on the role that housing has in shaping our neighbourhoods and boroughs.

Urban Design London have provided a platform for borough officers to offer their expertise.

Future engagement:

Engagement with community groups as part of the formal consultation on the guidance.

Aug 2018

Young

GLA workshop facilitated by Mae Architects and the Stephen Laurence Charitable Trust engaging young Londoners on the key quality of life indicators and priorities from their perspective.