Draft Energy Supplementary Planning Document

Energy SPD Equalities Impact Assessment

SECTION 1 -Context & Background

1.1

Please tick one of the following options:

This EIA is being carried out on:

☐New policy / strategy

☐New service

☐Review of policy / strategy

☐Review of service

☐Commissioning

☒Other project (please give details)Supplementary Planning Document for Energy

1.2

In summary, what is the background to this EIA?

The Energy Supplementary Planning Document (SPD) adds further details to the Local Plan which was adopted on 6th December 2017 and for which EIA was undertaken. SPDs do not introduce new policy, but provide further detail and guidance to enable the delivery of adopted policies.

Providing further guidance on building standards as they relate to carbon reduction and climate change over the Plan period to 2031 is a key commitment set out in Policy EM2 (Building Standards) of the adopted Coventry Local Plan. The aim of this SPD is to provide technical guidance on energy standards and requirements to improve the environmental sustainability of new development in the city.

The additional guidance provided within the SPD aims to provide clear information for applicants about policy requirements and expectations, clearly set out what detail the council expects developers to provide to assist the decision - making process and to encourage developers to promote excellence and best practice in sustainable development.

1.3

Who are the main stakeholders involved? Who will be affected?

Developers of proposed schemes which require planning applications, local communities including people who will live or work in the proposed developments, other stakeholders including those developing technologies to address climate change and those organisation involved in dealing with matters of climate change and sustainability.

1.4 Who will be responsible for implementing the findings of this EIA?

Coventry City Council Planning Policy Service

SECTION 2 - Consideration of Impact

Refer to guidance note for more detailed advice on completing this section.

In order to ensure that we do not discriminate in the way our activities are designed, developed and delivered, we must look at our duty to:

    • Eliminate discrimination, harassment, victimisation and any other conflict that is prohibited by the Equality Act 2010
    • Advance equality of opportunity between two persons who share a relevant protected characteristic and those who do not
    • Foster good relations between persons who share a relevant protected characteristic and those who do not

2.1 Baseline data and information

Please include a summary of data analysis below, using both your own service level management information and also drawing comparisons with local data where necessary (go to https://www.coventry.gov.uk/factsaboutcoventry)

The Local Plan was formulated using detailed evidence and information including the Building Regulations and Building for Life standards. The Local Plan was independently examined by a Planning Inspector to ensure that its policies were robust and formulated using appropriate evidence before it could be found sound and capable of adoption. Further detail on the Local Plan and the evidence base can be found here https://www.coventry.gov.uk/localplan

The additional guidance provided within the SPD aims to provide clear information for applicants about policy requirements and expectations, clearly set out what detail the council expects developers to provide to assist the decision - making process and to encourage developers to promote excellence and best practice in sustainable development

2.2 On the basis of evidence, complete the table below to show what the potential impact is for each of the protected groups.

  • Positive impact (P),
  • Negative impact (N)
  • Both positive and negative impacts (PN)
  • No impact (NI)
  • Insufficient data (ID)

*Any impact on the Council workforce should be included under question 2.6 - not below

Protected

Characteristic

Impact type

P, N, PN, NI or ID

Nature of impact and any mitigations required

Age 0-18

P

More efficient use of energy contributes to reduction in carbon emissions and addressing the impacts of climate change. The SPD is legally only allowed to provide further guidance to adopted policy, and is only able to encourage developers to follow its recommendations in terms of good practice so it is not possible to quality what the direct impact will be on this group. 19.5% of Coventry City Council residents are aged 15 and under and children and young people stand to gain the most benefit from the policies dealing with the implementation of sustainable energy practices over the long term.

Age 19-64

P

More efficient use of energy contributes to reduction in carbon emissions and addressing the impacts of climate change. The SPD is legally only allowed to provide further guidance to adopted policy, and is only able to encourage developers to follow its recommendations in terms of good practice so it is not possible to quality what the direct impact will be on this group. Coventry has a higher than average number of residents of working age (67% compared to 61.7% for the West Midlands and 62.4% for England) however so it stands to reason that a significant portion of the population will positively benefit from the implementation of policies which encourage sustainable energy practices. This is especially pertinent for those households currently identified as being in fuel poverty: 2019 figures show that at 18.8% overall this is significantly above the regional average of 17.5 % and 13.4% for England.

Age 65+

P

13.5% of Coventry's population are aged 65+ (compared to 18.6% and 18.4% for the West Midlands and England respectively). As above, all sectors of the population will benefit from more sustainable energy practices although because of the scope of the SPD it is not possible to quantify this. See above regarding comments on fuel poverty which also applies here.

Disability

ID

Whilst individuals and households are likely to benefit from more sustainable energy practices the scope of the SPD is limited and it is not possible to quantify direct impacts with regard to this protected characteristic.

Gender reassignment

ID

Whilst individuals and households are likely to benefit from more sustainable energy practices the scope of the SPD is limited and it is not possible to quantify direct impacts with regard to this protected characteristic.

Marriage and Civil Partnership

ID

Whilst individuals and households are likely to benefit from more sustainable energy practices the scope of the SPD is limited and it is not possible to quantify direct impacts with regard to this protected characteristic.

Pregnancy and maternity

ID

Whilst individuals and households are likely to benefit from more sustainable energy practices the scope of the SPD is limited and it is not possible to quantify direct impacts with regard to this protected characteristic.

Race (Including: colour, nationality, citizenship ethnic or national origins)

ID

Whilst individuals and households are likely to benefit from more sustainable energy practices the scope of the SPD is limited and it is not possible to quantify direct impacts with regard to this protected characteristic.

Religion and belief

ID

Whilst individuals and households are likely to benefit from more sustainable energy practices the scope of the SPD is limited and it is not possible to quantify direct impacts with regard to this protected characteristic.

Sex

ID

Whilst individuals and households are likely to benefit from more sustainable energy practices the scope of the SPD is limited and it is not possible to quantify direct impacts with regard to this protected characteristic.

Sexual orientation

ID

Whilst individuals and households are likely to benefit from more sustainable energy practices the scope of the SPD is limited and it is not possible to quantify direct impacts with regard to this protected characteristic.

HEALTH INEQUALITIES

2.3

Health inequalities (HI) are unjust differences in health and wellbeing between different groups of people which arise because of the conditions in which we are born, grow, live, work and age. These conditions influence our opportunities for good health, and result in stark differences in how long we live and how many years we live in good health.  

Many issues can have an impact: income, unemployment, work conditions, education and skills, our living situation, individual characteristics and experiences, such as age, gender, disability and ethnicity

A wide range of services can make a difference to reducing health inequalities. Whether you work with children and young people, design roads or infrastructure, support people into employment or deal with welfare benefits – policy decisions and strategies can help to reduce health inequalities

Please answer the questions below to help identify if the area of work will have any impact on health inequalities, positive or negative.

If you need assistance in completing this section please contact: Hannah Watts  (hannah.watts@coventry.gov.uk) in Public Health for more information. More details and worked examples can be found at https://coventrycc.sharepoint.com/Info/Pages/What-is-an-Equality-Impact-Assessment-(EIA).aspx

Question

Issues to consider

 

2.3a What HIs exist in relation to your work / plan / strategy

·   Explore existing data sources on the distribution of health across different population groups (examples of where to find data to be included in support materials)

·   Consider protected characteristics and different dimensions of HI such as socio-economic status or geographical deprivation

 

Response:

The Energy SPD supplements the policies of the adopted Local Plan which was subject to Health Impact Assessment. The Health and Wellbeing chapter of the plan, which includes Policy HW1, requires Health Impact Assessments for particular types and scale of development where there could be significant impacts. See https://www.coventry.gov.uk/localplan This was supplemented by a Health Impact Assessment SPD which provided further detail and guidance including that in relation to climate change. See https://www.coventry.gov.uk/downloads/file/28900/health_impact_assessment_spd

2.3b How might your work affect HI (positively or negatively).

How might your work address the needs of different groups that share protected characteristics

Consider and answer below:

·   Think about whether outcomes vary across groups and who benefits the most and least, for example, the outcome for a woman on a low income may be different to the outcome for a woman a high income

·   Consider what the unintended consequences of your work might be

 

Response:

a.     Potential outcomes including impact based on socio-economic status or geographical deprivation

The Health Impact Assessment SPD referred to above states (pages 18 / 19):  

‘There is a clear link between climate change and health. Coventry is a Marmot City and the Marmot Review is clear that local areas should prioritise policies and interventions that ‘reduce health inequalities and mitigate climate change’ because of the likelihood that people with the poorest health would be hit hardest by the impacts of climate change.

The planning system is at the forefront of both trying to reduce carbon emissions and to adapt urban environments to cope with higher temperatures, more uncertain rainfall, and more extreme weather events and their impacts such as flooding. Poorly designed homes can lead to fuel poverty in winter and overheating in summer, contributing to excess winter and summer deaths. Developments that

take advantage of sunlight, tree planting and accessible green/brown roofs have the potential to contribute towards the mental wellbeing of residents, as well as their physical wellbeing.

Proposed developments can exacerbate the impacts of climate change by failing to consider relevant influences such as location, materials, designs or technologies that could help to reduce energy consumption or reduce the environmental impact

of energy generation.

Proposed developments can help to reduce greenhouse gas emissions by requiring lower energy use in buildings and transport, and by encouraging renewable energy sources’.

The Energy SPD provides further guidance on how to practically address these matters.

 

b.     Potential outcomes impact on specific socially excluded or vulnerable groups eg. people experiencing homelessness, prison leavers, young people leaving care, members of the armed forces community.

Please see above: the environmental impact of energy generation affects all groups.

2.4

Next steps - What specific actions will you take to address the potential equality impacts and health inequalities identified above?

This was considered through the Local Plan (the 'parent document'), this document provides the detail to ensure the Local Plan policies can be delivered effectively

2.5

How will you monitor and evaluate the effect of this work?

The Local Plan already includes monitoring indicators.

2.6 Will there be any potential impacts on Council staff from protected groups?

No

You should only include the following data if this area of work will potentially have an impact on Council staff. This can be obtained from: lucille.buckley@coventry.gov.uk

Headcount:

Sex: Age:

Female

 

Male

 

16-24

 

25-34

 

35-44

 

45-54

 

55-64

 

65+

 

Disability:

Disabled

 

Not Disabled

 

Prefer not to state

 

Unknown

 

Ethnicity: Religion:

Any other

 

Buddhist

 

Christian

 

Hindu

 

Jewish

 

Muslim

 

No religion

 

Sikh

 

Prefer not to state

 

Unknown

 

White

 

Black, Asian, Minority Ethnic

 

Prefer not to state

 

Unknown

 

Sexual Orientation:

Heterosexual

 

LGBT+

 

Prefer not to state

 

Unknown

 

3.0 Completion Statement

As the appropriate Head of Service for this area, I confirm that the potential equality impact is as follows:

No impact has been identified for one or more protected groups ☒

Positive impact has been identified for one or more protected groups ☐

Negative impact has been identified for one or more protected groups ☐

Both positive and negative impact has been identified for one or more protected groups ☐

4.0 Approval

Signed: Head of Service:

David Butler

Date:02/09/2021

Name of Director:

Andrew Walster

Date sent to Director: 02/09/2021

Name of Lead Elected Member:

Councillor David Welsh

Date sent to Councillor: 02/09/2021

Email completed EIA to equality@coventry.gov.uk