Equality Impact Assessment - K+20 Kingston Town Centre Area Action Plan

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Contents

K+20 Kingston Town Centre Action Plan EQIA

1. Introduction
2. Background information
3. Policies in the Kingston Town Centre Area Action Plan (AAP)
4. Monitoring results
5. Consultation
6. Action points
7. Publication arrangements
8. Document review

1.0    Introduction

1.1
The purpose of an Equality Impact Assessment (EQIA) is to improve the work of the Council by making sure it does not discriminate and that, where possible, promotes equality and fulfils the duty under the Race Relations Act (as amended) 2000 and the Disability Discrimination Act 2005.  An EQIA focuses on systematically assessing and recording the likely equality impact of a service, policy or project.  There is a focus on assessing the impact on any group of people, in particular the equality target groups.  This involves anticipating the consequences of policies and projects on these groups and making sure that, as far as possible, any negative consequences are eliminated or minimised and opportunities for promoting equality are maximised.  This report is a Final Assessment of the policies contained in the Kingston Town Centre Area Action Plan (KTC AAP) Submission Version.  The emphasis of this EQIA is on whether the policies have an actual or potential adverse impact on the groups and if so what measures are proposed to remove or reduce it.

1.2
In line with its legal responsibilities the Council has considered the likely impact of the AAP on the following target equality groups:

• Gender
• Race - Black and Minority ethnic communities
• Disabled people with impairments of all types i.e. those with visual and hearing impairments, with physical and learning disabilities and mental health problems.

1.3
However, it is important to note that the Equality Act 2006 outlaws discrimination on the grounds of sexual orientation, religion or belief and age, in addition to gender, race and disability. In addition, the Act provides for the establishment of a Commission for Equality and Human Rights, which will replace the Equal Opportunities Commission, Commission for Race Equality and the Disability Rights Commission. The Commission, to be established in October 2007, will seek to promote diversity and equality for all by reducing inequality, eliminating discrimination and strengthen relations between diverse members of the community.

1.4
Key issues in any EQIA on the AAP are assessing whether effective consultation with the target equality groups has been undertaken, whether they have been effectively involved in policy formulation, whether policies will meet their needs in an inclusive way and what monitoring arrangements have been put in place for gathering information on the effect of its policies and practices on these groups of people. At the same time it must be recognised that the AAP only promotes spatial policies and is therefore limited in what it can achieve in terms of addressing inequality issues.

Stage 1 – Screening for relevance for carrying out a full EQIA

2.0    Background Information guiding preparation of AAP Policies

2.1
The area bounded by the Kingston town centre AAP has an increasing resident population – 1400 new homes have been completed since 1995 from a low base of around 400 homes. According to the 2001 Census information, a high proportion of the borough’s single person households reside in its town centres, including Kingston, and typically a significant proportion of Kingston town centre residents are single, well-qualified, professional people in the 25 - 44 age range. Owing to good rail and bus links, car ownership levels are low when compared with the rest of the borough, with high proportions travelling to work on the train.

2.2
In broad terms, Kingston reflects many of the national social trends although figures are not specifically available for the AAP area. The following headline points are sourced from a number of background documents including the 2001 Census, The Director of Public Health Annual Report 2005 and the Council’s Affordable Housing SPD.

• Black and minority ethnic groups form a relatively low, but increasing proportion (up from 7.9% in 1991 to 15.5% in 2001) of Kingston’s population breakdown with the Indian population forming the largest ethnic minority group (up from 2% to 3.6% over the same period) with Koreans making up around 2.6%.
• It also has a low proportion of lone parent households (5% of the 61,426 borough’s households, compared to 6.5% in England and Wales, although the number of single parent households is increasing rapidly in line with national trends).
• Since 1991, the percentage of elderly residents in Kingston living alone has decreased from 6.4% to 5.6% in contrast to relatively little change across England and Wales during this period, although Grove Ward in which the town centre is located stands out as having greater proportion (9.1%) compared to other areas in the borough. Social isolation is an issue that tends to be associated with older people prompting the need for promoting social interaction such as improving access to leisure
• The cost of housing in and around the borough is high and there is a severe shortage in the availability of affordable housing. At the end of May 2005, the Council’s housing register contained more than 5,000 households in need of accommodation, including over 700 homeless households in temporary accommodation provided by the Council
• Unemployment, although not a major issue in the borough is nevertheless an important determinant of inequalities, including in terms of people’s health and well-being. Roughly similar levels of people commute out of the borough to work as commute in. Since 2001, the unemployment rate in the Borough dropped further to 2.2% in 2002, since when it has remained relatively stable and below the national rate of 3.2%. However, between 1991 and 2001 there was a nearly 40% increase in the number of people reporting long-term illness or disability preventing them from working. Whilst there have been some positive actions from employers etc, aided by the passing of  the DDA and other national anti-discrimination policies, disabled people still face barriers that limit their ability to compete in the jobs market, particularly those with mental health problems. The Government’s strategy ‘Health, Work and Wellbeing also places emphasis on creating healthy working environments to avoid work-related health problems.
• Increases in the numbers of people living in housing without basic amenities were noted between 1991 and 2001, i.e. from 2.5% to 8% which may be explained by the increasing numbers of students sharing sub standard accommodation. This indicates a need for more quality housing but there is also a need to ensure that they are built to sustainable standards with appropriate levels of insulation to reduce heating costs for those on low incomes.
• Although Kingston is typically perceived as an affluent and prosperous borough, it does have pockets of deprivation and disadvantaged communities across the borough, notably in wards around Kingston town centre.
• There has been an 11% rise in the nos. of pupils educated in Kingston over the last 10 years, particularly from those wishing to stay on into 6^th form, such that it has one of the highest ‘staying on’ rates in the country. Education plays an important role in addressing inequalities in terms of maximising job prospects, income levels, social skills and housing etc. and the borough’s schools consistently achieve standards well above the national average. The early years of childhood is recognised as a life stage where action to tackle inequalities is especially important and likely to have significant beneficial impact and every 3 & 4-year old child in the borough is offered a free nursery place,
• Transport accessibility and choices or lack/adequacy of it impacts on health (including mental health), social inclusion and ability to access services. Traffic levels also contribute to levels of air pollution which have an effect on health, particularly the more vulnerable groups such as children and the elderly. Traffic restraint measures, improving access to public transport, promoting land use policies which minimise distances between homes, employment and services and making streets safer all help contribute to reducing inequalities for those with impaired mobility for whatever reason, be it physical or socio-economic.
• Crime or the perception of crime can be a cause of social exclusion and women and older people in particular tend to worry more about becoming victims of crime. Although Kingston is one of the safest London boroughs there was an 18% increase in reported crime between 2001 and 2004, including a significant increase in violence against person crimes, with offences heavily concentrated in Grove Ward which covers the town centre. There is also an increasing number and proportion of ethnic minorities becoming the victims of crime – over 300 racist incidents are recorded each year with one of the highest concentrations of incidents occurring in and around Kingston town centre.
• Accurate statistics relating to the borough’s disability profile are not available but it is estimated that 20% of the population have a disability.  
• Life expectancy for men in Kingston is the second highest in SW London with men living on average for 77.8years and women for 81.4years.   

2.3
The AAP also considered this information in the context of Kingston town centre’s role as a metropolitan centre attracting large numbers of shoppers, workers and visitors by day and night from a large catchment area outside the borough’s boundaries as well as Kingston University’s increasing attraction for growing numbers of local, international and postgraduate students.

2.4
It takes account that one of the key objectives in the Councils Corporate Policy Programme is to ‘be a Council which celebrates diversity and practices equality in everything we do, in providing or commissioning services, and as an employer.’

2.5
When the UDP underwent initial EQIA screening in May 2005, it identified that the transport, housing and community policies had a high impact on the equality target groups and the residents of Kingston generally and it was decided to proceed with a full EQIA.  Its findings were pertinent to the preparation of the KTCAAP.

2.6
Notwithstanding, the policies contained in the KTCAAP have taken account of external documents, including research, consultations and good practice guidance as well as council written reports which included evidence of consultation with Kingston’s equality target groups together with the findings of consultation at each stage of the preparation of the AAP.  Therefore, the policies are developed from a sound evidence base.

3.0    Policies in the Kingston Town Centre Area Action Plan (AAP)

3.1
The Kingston Town Centre Area Action Plan is part of the Council’s Local Development Framework for the borough, as set out in the Local Development Scheme and has been prepared in accordance with the Town and Country Planning Act 1990 and the Planning and Compulsory Purchase Act 2004 and accords with the requirements of the Council’s Statement of Community Involvement. It also takes account of national and London wide planning policies, including the Mayor’s London Plan 2004 and related strategies, local planning policies set out in the Council’s UDP (including its policies on affordable housing and car parking standards for employment generating uses that were modified following the Secretary of State’s intervention prior to the Plan’s adoption in August 2005) and other borough strategies, including the Community Plan 2004 and Local Implementation Plan (Transport) 2005, as well as specially commissioned K+20 studies on Retail, Offices, Parking, Cycle Parking, the Old Town Conservation Area, Flood Risk and Archaeology.

3.2
It sets out the planning policy for Kingston town centre over the period to 2020 and on adoption will form part of the statutory development plan for the borough, superseding all the UDP policies for the town centre, including the 3 strategic policies. At the same time it will continue to be read in the context of general, relevant ‘saved’ UDP policies until such time as they are superseded by the Core Strategy and Development Control Policies. Key UDP objectives for land use planning, which are also relevant to this AAP are:

• Encouraging new development to be sustainable
• Encouraging strong sustainable communities
• Safeguarding and enhancing the existing environment for future generations
• Practising equal opportunities

3.3
The Council’s Executive endorsed the proposal to prepare the strategy for the town centre behind the new plan, known as K+20, in November 2002. It has been the subject of high level public and stakeholder involvement throughout the various stages of its preparation starting in June 2003 with the launch of the strategy when a Community/Stakeholder Event was held to identify key issues affecting the future development and well-being of the town centre. Consultation on these key issues was undertaken in 2004, followed by consultation on Preferred Options in June 2005 with stakeholder consultation on an initial draft of the AAP in Spring, 2006. The Plan has been modified at each of the various stages in the statutory process in response to all the views expressed by stakeholders, residents, elected members, commercial concerns and a wide range of other organisations with an interest in the future of the town centre and Executive endorsed the Submission Version in April 2007.

3.4
A full account of the consultation process at each of the stages is documented in the Report on Consultation which accompanies the Plan. (Between 320 individuals and organisations etc., including disabled and equality groups were consulted at the earliest stage of consultation rising to around 370 at the Preferred Options stage. A borough-wide householder questionnaire was also undertaken which elicited around 2,500 responses).

3.5
The AAP follows the approach promoted by government guidance. This includes taking into account the KTC AAP Sustainability Appraisal which (like the Report on Consultation) accompanies the Plan and identifies the likely social, economic and environmental effects of policies and proposals in the Plan, including the need for sustainable development to protect the quality of life and ensure access for all. The review of the relevant plans, programmes and sustainability objectives in the preparation of the SA highlighted 24 sustainability development themes that needed to be taken into account when preparing the AAP. The sustainability objectives of relevance to the EQIA included:

• To reduce poverty and social exclusion
• To reduce anti-social behaviour
• To improve accessibility to essential services and facilities
• To provide the opportunity for everyone to live in a decent home
• To encourage a sense of community identity and welfare
• To contribute towards health improvements of the borough population
• To allow development that sustains and enhances the vitality and viability of the town centre
• To encourage sustained economic growth with a diverse employment base
• To make efficient use of land and infrastructure
• To maximise energy efficiency and reduce the use of non-renewable resources

3.6
These then translated into sustainability themes set out in Table 3 of the SA including:

• Ensure that local communities have access to a range of local services
• Make further provision for affordable housing to meet identified need
• Promote higher density residential and mixed-use development where appropriate to meet the housing needs of the local community
• Ensure the most efficient use of land by supporting urban regeneration and balancing competing demands within the context of sustainable development
• Improve the general health and well-being of the population
• Promote sustainable modes of transport and reduce the need to travel
• Address issues of poverty and localised deprivation
• Reduce crime and anti-social behaviour
• Maintain an adequate supply of open space
• Promote renewable energy
• Improve air quality and reduce air, noise and light pollution
• Improve education and employment opportunities

3.7
The findings of the sustainability appraisal together with the results of consultation on the Preferred Options and associated SA Report resulted in certain amendments and refinements being made to the Plan. The SA identified amongst its key issues and problems (Table 4) that there are gaps in the baseline data regarding accessibility to essential facilities and services, including healthcare, leisure opportunities and open space. It identifies that this has implications for ensuring access for all and social inclusion, catering for the needs of disabled people through appropriate transport services and access to facilities – This is an action point for EQIA report.

3.8
The AAP seeks to build upon Kingston’s strengths (including its attractive character, high quality shopping etc facilities and to enhance these attractions and its role as a successful metropolitan centre) and address its weaknesses (including its peak time congestion and parking issues with a range of access and parking improvements and managing the night time economy by providing a broader range of visitor attractions, especially in the early evenings).

3.9
It seeks, through a public/private/agency partnership approach, to promote and manage change for the benefit of the whole community, providing a sustainable and enhanced range of town centre services, new homes (including affordable housing, together with managed student accommodation), more job opportunities and improved transport, access and connectivity (a new bus station, improvements to Kingston Station, new and improved car parks, improved walking and cycling routes and a potential permanent Park & Ride facility)  in a high quality physical environment with well designed buildings and spaces that is safe, clean and easily accessible to all.

3.10
Part I of the Plan sets the wider strategic and local policy context, identifies the town centre’s characteristics and key issues and describes its vision and objectives.  Part 2 sets out more detailed local policies that have been developed within this broad framework to provide more detailed guidance for proposed new developments.  Part 2 policies and what they set out to achieve are presented on a topic basis. These are carried through in Part 3 to specific guidance for sites (proposal sites) and character areas where development opportunities exist or for which the Council has specific proposals.  Part 4 sets out the Implementation and Monitoring Framework in respect of each of the 24 Policies, 20 Proposal Sites and Historic Core, Riverside South and High Street Character Areas.

3.11
The following specialist studies were commissioned to provide a sound evidence base to guide the AAP policies and proposals and to a greater or lesser extent cover equality issues:

• Retail Studies 2003 and 2006
• Parking Study 2003 and Parking Strategy 2005
• Old Town Conservation Area Studies 2003 – 2005
• Transport Assessment 2004 - 2006
• Secure Cycle Parking Study and Strategy 2004
• Park & Ride Study 2003 and Integrated Transport Study 2006
• Office Survey 2005
• Strategic Flood Risk Assessment and Management Study 2006
• Archaeology Overview 2006
• Hotel Feasibility Study 2007

In addition, the AAP has taken into account the following documents:

The Housing Needs Survey 2001 which highlights that:

• An estimated 1.7% of all households living in the borough are in housing need, with owner-occupiers least likely to be in need and Council and Housing Association households most likely to be in housing need. In addition, lone parent households, those living to the north of the borough, Black and Asian households and households containing a member with special needs noticeably likely to be in need. [This excludes student households who would be unlikely to be housed in social rented accommodation if they were to approach the Council].
• There is an estimated annual need for 1,812 affordable homes for the following 5-year period (117 to reduce the backlog + a newly arising need for 1,695 resulting from household formation, existing households currently living in the borough and in-migrant households).
• There is a need for more one-bedroom accommodation (582 shortfall/annum) but also for four-bedroom accommodation where the shortfall relative to supply is greatest such that only 5% of need would be met

The Council’s Affordable Housing SPD (adopted February 2006) the purpose of which is to help deliver good quality affordable housing of the right type, size and tenure through the planning process, notably seeking appropriate proportions and types of affordable housing commensurate with the scale and location of new development through its Plan policies. It refers to the Mayor’s London Plan which sets a target that 50% of additional housing in London should be affordable.  It also requires that all affordable housing be built to Lifetime Homes Standard, so that it is easily adaptable to changing needs or disability, and that 10% is built to wheelchair standard, in accordance with London Plan policy 3A.5.

The Council’s Access for All SPD (adopted July 2005) which highlights the most important principles in designing inclusive buildings which meet the needs of all users equally, regardless of disability, age, gender or ethnic background and is a material consideration in the determination of planning applications. It refers in its introduction to the expected 40% increase in the number of disabled people over the next 30 years, due in large part to an expected increase in the number of older people as disability often results from the ageing process (even though older people may not think of themselves as disabled).

The Council’s SPG on Sustainable Construction (adopted February 2004). This points out the responsibilities of ensuring that we hand future generations a healthy sustainable borough which treasures and improves the quality of its built and natural environment making it a good place in which to live and work and offers guidance on energy saving techniques. From an EQIA point of view the latter is of relevance for example to those on low incomes (and evidence suggests that disproportionate numbers from the target groups fall into this category) for whom the cost of heating etc impacts on the quality of their lives.

The Council’s Shopfront Design Guidance SPD (adopted 2005) which is intended to help retailers and commercial operators occupying ground floor shop units and their designers, improve the quality of their design, including in terms on making them accessible for disabled people including wheelchair users and visually impaired people when altering or replacing shopfronts and signage.

The Council’s ‘After Dark Strategy’ which seeks to make the evening economy much more accessible and welcoming to all, i.e. regardless of age, gender, disability and ethnic background

EQIA issues

3.12
Issues that are considered relevant to an EQIA are access for the equality target groups to:

• A full range of job opportunities
• A full range of housing, including affordable, student and wheelchair accessible housing
• Transport; including ensuring through good design that proposals for a new bus station and improvements to Kingston Station and town centre car parks etc (and the spaces around and access routes to them) are inclusive and thus do not e.g. disadvantage disabled persons in any way
• Town centre services including community uses, with more opportunities for faith groups such as the Quakers (who are affected by town centre redevelopment proposals contained in the Plan), to relocate or establish themselves in the town centre
• The evening economy - by providing a broader range of uses of interest to all age groups and social/economic/cultural backgrounds and managing it in such a way that it is safer, cleaner and generally more attractive and welcoming for all
• An improved built environment that meets their physical access needs
• The riverside

3.13
The AAP policies are intended, inter alia, to:

• Promote equality of opportunity between the equality target groups and other people
• Eliminate unlawful discrimination through good design
• Encourage participation by all groups in the community in public life
• Address the needs of disabled people in a positive and pro-active way

Improving Equal Access Opportunities to Town Centre Employment

3.14
Retaining a diverse town centre economy (retail which dominates with providing nearly half the jobs, private offices, public sector administration, entertainment and leisure, higher and further education) is considered key to maintaining a range of job opportunities and offering equal access opportunities – Key objectives 1 and 2. Significant positive effects for equality target groups will be a reduction in poverty and social exclusion through improving access to education and training.

• The 2003 Retail Studies concluded Kingston town centre had to enhance its retail offer by providing a greater range and more choice of outlets of all sizes to remain attractive and compete effectively in the retail hierarchy. Policies K1- K3 promote proposals for significant retail development for comparison goods (up to 50,000sqm (gross) additional floorspace by 2016).
• The AAP acknowledges Kingston’s weak position as an office centre with poor quality office stock and comparatively poor rail services and connections, leading to low demand and office rents. Policy K4 seeks to address this by promoting provision of new and upgraded offices as part of mixed use developments, including small business space to attract and support the growing number of creative, knowledge and information businesses. PS10 is identified as a potential site and, by virtue of its proximity to Kingston Station, would be a convenient location for disabled and other workers using the rail network. (Kingston Station was made wheelchair accessible during 2008)
• Policy K4 also seeks to play an active role with partner organisations in identifying and addressing skill and training needs for town centre businesses – A feasibility study for a Creative Industries Centre in 2005 identified a mismatch in local workforce skills and town centre business needs and through the Local Area Agreement, the Council is seeking to provide training to improve retail skills in partnership with Kingston College’s Centre of Vocational Excellence in Learning. This offers the opportunity to promote equality and to meet the needs of and encourage greater participation by the equality target groups in the job market
• Both Kingston University and Kingston College have an increasingly important role in the local economy providing education, training, employment etc and Policy K8 acknowledges the need to support this growth in a way that is of benefit to the wider community
• The range of entertainment and leisure attractions has increased significantly since 2001 but Policy K6 seeks to further promote, enhance and diversify the town centre’s attractions and has identified a need for the development of a quality full service hotel.  The town centre is well placed to promote tourism, including in the context of the 2012 Olympics which provides an important opportunity to provide a range of facilities away from Central London with all the advantages this brings to the local community not only in terms of access to a greater range of job opportunities but also leisure etc facilities
• The Plan also addresses through Policy K5 the need for improving facilities for public administration, the police and court services, which provide a range of services as well as a significant number of jobs

Improving Equal Access Opportunities to Housing

3.15
As with the transport policies, the AAP housing policies are set against ‘saved’ housing policies in the UDP which concentrate on:

• facilitating sufficient housing as part of mixed-use development to contribute towards regional and London-wide requirements and local housing needs, whilst resisting overdevelopment and ‘town cramming’ and development otherwise likely to detract from the character of the area
• facilitating the provision of different types of housing in appropriate locations in the town centre to serve people’s different needs
• encouraging a good standard of design and amenity for residents

These aims have no adverse impact on equality, diversity and race.

The policies concentrate on the physical aspects of providing the housing, while taking the social implications into consideration, i.e. contributing to meeting local housing need and reducing social exclusion. They seek to deliver ‘affordable’ housing for those who cannot afford local open market prices, to cater for the special needs of people requiring e.g. wheelchair accessible housing and to provide opportunities in appropriate locations for the provision of managed student accommodation.

• Policy K7 of the AAP identifies the scope for more housing (around 1,000 additional units) to help meet local housing needs and the need for more affordable, family and student housing as part of mixed-use developments.
• The Policy states that new housing should meet Lifetime Home (or subsequent) standards and at least 10% of new housing should be designed to be wheelchair accessible or easily adaptable for residents who are wheelchair users in order to promote social inclusion and accord with the London Plan (Policy 3A.5) and the Council’s Supplementary Planning Advice Note – Lifetime Homes and Wheelchair Housing (December 2007). Identifying more opportunities to provide managed student accommodation not only provides the opportunity to ensure inclusion of appropriate levels of suitable disabled accommodation but frees up locally available family housing for the wider community that is currently rented out to students.
• At the same time the Policy takes into account concerns about increasing densities, lack of amenity space, the need to provide new housing in locations where it will be compatible with other uses and provide a suitable residential environment and the need to increase supporting facilities such as GP surgeries and schools

Improving Equal Access Opportunities to Transport

3.16
The AAP transport policies are set in the context of the UDP transport chapter which outlines the Council’s land use and traffic management policies for ensuring that travel in the borough develops in a sustainable way which contributes to the social, economic and environmental well-being of all sections of the community.  The UDP, through the transport chapter recognises that land use and transport policies and decisions have major impacts on each other and need to complement each other.  The plan policies promote positive integration by, inter alia, promoting high density development, especially for major traffic generators, as much as possible in town centres where they are accessible by public transport, walking and cycling.

3.17
Weaknesses in transport (accessibility, infrastructure etc) were identified in early stakeholder engagement as a significant local issue. As part of improving equality of transport accessibility, the Plan promotes policies which seek to make it more accessible by different modes of transport and cater for multi-purpose trips, though it cautions that its powers are limited as it does not control the rail or bus networks or parts of the road network and it therefore needs to work in partnership to achieve improvements. It also seeks a balance between the need to keep traffic flowing with opportunities to give greater priority to pedestrians, public transport, cyclists and disabled people, including blue badge holders.

3.18
Specifically, the policies seek to:

• Reduce congestion at peak periods and make better use of existing parking capacity and reduce queuing by redistributing the balance of attractions in the town centre i.e. proposing that vacant underused land in the south and east (Ashdown Road sites) provides new retail and parking facilities to attract visitors (Policy K15). Policy K15 also seeks to reduce vehicle access in some parts of the town centre e.g. around Fife Road to give greater priority to, and improve the quality of the environment for, pedestrians, cyclists, public transport users and people with disabilities
• Improve rail services and Kingston Station (Policy K16).
• Improve public transport from the west and south-west parts of the town centre’s catchment area (Policy K16).
• Improve bus facilities i.e. a new bus station to enable the removal of buses from Eden Street together with an improved waiting environment and an improved Fairfield bus station
• The Plan would like to deliver permanent Park & Ride facilities as this would improve access to the town centre. However, potential sites are outside the borough and studies have indicated they would be difficult to deliver and may be long-term (Policy K19).
• Improve provision for taxis, community transport (which helps those unable to drive or use conventional public transport and thus makes a vital contribution to social inclusion) and the Shopmobility Scheme providing improved mobility and access for older and disabled people (including the relocation and expansion to more accessible ground level sites). (Policy K19)
• Through its roles as a highway authority and car park operator the Council will ensure generous and convenient on and off-street parking for blue badge holders (Policy K20). This addresses a shortcoming identified in the UDP EQIA i.e. that the UDP was not very forthcoming on the issue of the provision of disabled parking bays
• Minicab booking facilities to enable the pre-booking of minicabs late at night have been provided in the town centre. These help reduce the negative consequences of the late night economy, notably anti-social behaviour (or at least the perception of it), by helping e.g. to get women home safely at night, so they can participate more fully. Other transport initiatives to improve the late night public transport system to disperse visitors more quickly and reduce late night noise and disturbance and crime are being pursued through partnership arrangements as part of the after dark strategy which complements the Plan e.g. more late night trains and cross GLA/Surrey bus services and better information (Policy K19).

3.19
Improvements in Equal Access Opportunities to Community Uses and Town Centre Infrastructure

• The Plan notes the contribution the various Faith, Community and Voluntary Sector groups make to the town centre’s vitality and diversity and Policy K6 promotes their need for improved facilities so they can reinforce their role in meeting local needs and delivering public services. The SA identifies the loss of local community pubs and halls as an issue affecting the provision of facilities for local communities and this will need to be monitored
• The Plan is limited in its proposals for new health facilities to a new GP surgery on the Lock ‘n Store site in Skerne Road owing to lack of data. This is referred to again at para. 5.4 of this document.
• Provision of a new library within the relief road would be a significant benefit for providing improved access to essential services and facilities – it will be easily reached by public transport and more readily accessible by people in the local communities, including the equality target groups, as well as a valuable asset for students and lecturers at the University and College.
• One of the potential negative consequences of the proposed scale of new town centre retail and housing development, i.e. from an EQIA perspective, is that if not appropriately addressed at the right time, there may be a time lag in providing essential town centre infrastructure such as school places and GP surgeries, which is likely to have a disproportionate impact on the equality target groups. Policy K23 seeks contributions in appropriate cases towards public infrastructure including improvements to facilities and the environment and the provision of affordable housing.

3.20
Improving Equal Access Opportunities to the Evening Economy

• In early engagement on the AAP with the community and stakeholders, 34% of respondents perceived the town centre to be unsafe at night, 16% considered the evening economy caters for teenagers/binge drinkers and 12% responded that there are too many nightclubs/theme pubs. These factors deter many people from coming to Kingston town centre at night. Key Objective 7 of the Plan seeks to provide a clean, safe, friendly, well managed and well maintained town centre at night as well as during the day. It seeks to do this through Policy K21 and the Council’s After Dark Strategy when adopted later in 2007. This will promote a number of initiatives aimed at tackling the town centre’s negative night-time image and broadening the range and increasing the attractiveness of evening activities, especially in the early evening, in order to make it more socially inclusive for people of all age groups, interests and backgrounds. It is expected that the opening of the theatre and provision of a quality hotel will in part help address this.
• Further analysis of data is required to identify what proportion of the above percentages of respondents fall within the equality target groups to confirm whether there are equality issues that need to be investigated and more specifically addressed i.e. reasons behind why specific groups may be more disadvantaged than others.

3.21
Improving Access Opportunities through Improved Urban Design and Environmental Quality

• It is a key objective of the AAP to provide a high quality environment with well designed buildings and spaces. The Plan identifies the need to improve the quality of the public realm, including access to, and the use and enjoyment of, the town centre’s riverside facilities. It notes that at Issues stage, community and stakeholder engagement identified the need for a cleaner, tidier environment with more green areas, trees and places to sit as priorities for environmental improvements. Policy K9 requires, inter alia, that all new development should be designed to be accessible and inclusive and to reduce opportunities for crime with new landmarks in key locations to reinforce identity and improve legibility. The Plan considers it important that the town centre is permeable and well connected so that people can access attractions and spaces easily on foot or by wheelchair and developments need to create spaces and routes that are accessible and open at all times. Replacement of the Eden Walk car park, for example, on the south-east edge of the town centre will consolidate the pedestrian core by removing car penetration thereby making it easier for disabled people to move around it. However, it is noted that any shortage of blue badge parking close to shops and other destinations hits certain disabled people very hard and prevents them from accessing the town centre. Some of this negative effect can be mitigated by the development of the Shopmobility service.
• Policy K10 identifies the need to implement a rolling programme of improvements to streets and public spaces using materials that are both durable and easy to maintain, which is important for those with physical disabilities. Similarly, it seeks to improve the quality of the pedestrian environment, ensuring that all routes are clear, legible, well lit, safe and convenient and to improve the environment of the relief road and crossings as well as approaches to bus stops, Kingston Station and car parks. A-boards are singled out for mention and a strategy is being developed that enhances the pedestrian environment, seeking a balance between the need to remove them where they present obstructions which disabled people find difficult to negotiate around and meeting the needs of the business community. The need for improved signage generally is also identified. Policy K10 also seeks to protect and enhance the Old Town Conservation Area, including protecting public access to the undercroft to the John Lewis building to view the Old Bridge remains.
• Design and Access Statements are now required to be submitted with the majority of planning applications at each stage of the development process and assessed by the Disability Equality and Access Officer to ensure they incorporate the principles of inclusive design.

Improving Access Opportunities to The Riverside

3.22
A key objective of the AAP is to promote and enhance use of the river and the riverside. This includes improving riverside access, facilities, services and information in order to enhance its potential for sport, recreation, leisure and educational activities and tourism and provide a welcoming, attractive and positive experience for all. Policy K13 refers to the possible use of S106 legal agreements in connection with major development proposals to secure improved facilities, which could include e.g. support facilities such as jetties, landing stages and slipways which would help improve access to the river for disabled people.

Flood Risk Management

3.23
Kingston town centre falls mainly in the Environment Agency’s Flood Zones 2 (Medium Probability) and 3 (High Risk). As such the AAP Policy K24 makes it clear that development proposals will need to include flood mitigation measures as an integral part of the design process to minimise any negative effects e.g. limiting ground floor uses in high risk areas to commercial uses, ensuring ‘dry’ (raised) access routes are provided for safe evacuation in times of flood, ensuring access to basement areas is above a certain minimum level, ensuring development does not increase flood risk to adjoining properties and where appropriate include Sustainable Urban Drainage Systems to reduce surface water runoff rates. These measures are of benefit to all groups in the community but particularly those with physical disabilities who are at greater risk where speed and safety is important in the event of evacuation.

Implementation and Monitoring Framework

3.24
The AAP sets out an indicative programme for the delivery of the main elements of the Plan’s Vision during the period up to 2020 and a range of funding sources and land ownership arrangements by each of the 8 key objectives and their related policies (where possible with targets) together with associated action for each of the 20 Proposal sites. Delivery of the Vision will require considerable resources and depends on the Council playing a central role and continuing to work in partnership with a range of stakeholders in the public, private and community/voluntary sectors, including equality target groups as well as residents and other local groups. The Council has employed the services of consultant Price Waterhouse Coopers to advise it on the most appropriate way to deliver the Vision.

3.25
Various initiatives have commenced and some have been implemented in the town centre e.g. late night minicab kiosks, by public, private and community/voluntary organisations. During 2008 Kingston Station became fully wheelchair accessible with the installation of full passenger lifts to all platforms, funded by the Department for Transport’s Access for All programme. The Council’s Executive has also approved the allocation of £200,000 from S106 contributions for town centre access improvements to Kingston Station by SW Trains, expected to be undertaken in 2008/09.

3.26
The property developer has a key role to play in delivering retail-led mixed development projects in the town centre with ownership of a quarter of the 20 proposal sites in the AAP boundary, including the site for the new bus station and another for community use.

3.27
The Council proposes to regularly review and monitor how the different policy objectives, including initiatives directed at equality target groups are being delivered and, as and when necessary, to discuss with its partners, alternative delivery mechanisms if these initiatives are not being achieved in the desired way or in the desired timescales. The key to successful delivery is considered to be flexibility and the Council recognises the need for ongoing consultation and review throughout the process of implementing the AAP proposals and this will include the equality target groups, including via the recently-formed Kingston Disabled and Older People’s Forum and BME Forum. It proposes to prepare a Communications Plan to disseminate regular information on the progress and delivery of the AAP. It will be important as part of this exercise to ensure that the appropriate information is passed onto relevant target groups in a way that will allow them to have easy access to it.

4.0    Monitoring results

4.1
Unlike earlier UDP consultation exercises, the AAP process undertook ethnicity and equality monitoring as part of its consultation process.   A borough-wide householder questionnaire elicited responses from 2,495 residents of whom:

• 42% were male, 55% were women,
• 82% were White British; 2% White Irish and 5% White Other. 5% did not respond. The remaining 6% of responses were from ethnic minority groups
• 15% were disabled. Of these:
  • 17% had a hearing impairment
  • 9% had a visual impairment
  • 4% had mental health difficulties
  • 52% had physical disabilities
  • just over 1% had a learning disability

4.2
The Census and the Director of Health’s Annual Reports provides information on population changes in the borough, changes in ethnicity and social class, health aspects of employment, housing, education, transport and crime over the past 10 years together with trends in health and mortality which will be useful in monitoring the effectiveness of a number of relevant policies over the Plan period.  

4.3
Information from the Council’s Housing Dept., Census data, housing completions and performance London-wide data indicate that the borough is ahead of the London Plan strategic target for 1997-2016 of 6710 homes. However, the Housing Needs Survey 2001 has estimated that around 14.5% of borough households are living in unsuitable housing (almost one-third of Council tenants, almost a quarter of private tenants and 16% of Housing Association tenants) with Black and Asian households and also special needs households found to be significantly more likely to be living in unsuitable housing than other households – the figures are set out in the UDP (Housing) EQIA. Kingston University has also advised that despite operating a 10 mile exclusion zone, it has a current shortfall in the region of 1,600 bedspaces to meet first year student needs and this is projected to grow to around 2,500 in the next few years.

4.4
The AAP cannot deliver housing for specific BME groups but it can seek to deliver appropriate levels, sizes and type of affordable, as well as market, housing, and identify appropriate sites for student housing to reduce the current shortfalls. The AAP housing policies will be used in conjunction with ‘saved’ UDP Policy H9 and the Affordable Housing SPD to deliver affordable housing through new development. The UDP EQIA identified that the lack of larger family units discriminated against women and young families and those with disabled children due to the high proportion of flats being built with no private outdoor space and little community amenity space. The Council recognises that the AAP area lends itself most readily to non-family housing but this does not rule out provision of good quality family accommodation e.g. at ground level with access to a private garden or communal amenity space.

4.5
The Supplementary Planning Advice Note on Lifetime Homes and Wheelchair Housing provides developers with guidance on the 16 Lifetime Homes criteria and applications are assessed on their compliance. This is resulting in new homes being more accessible and adaptable to meet the access requirements for disabled and older people.

4.6
The intention to undertake continuing consultation during the implementation of the Plan will enable the Council to monitor equality target group satisfaction levels and to modify its AAP proposals etc as appropriate.

5.0    Stage 2 - Consultation

5.1
The SA has helped ensure that equality issues are generally well covered in the Plan but the EQIA has identified that there are some weaknesses regarding these issues which need to be addressed as ‘Action Points’. To some extent these will duplicate action points listed under the UDP EQIA to be addressed when the LDF Core Strategy DPD is being prepared. These include the following:

Transport - parking provision for disabled people close to destination and the need for revised and further guidance regarding implementation

Housing including:

• the delivery of affordable housing
• Undertaking a New Housing Needs Survey, ensuring that equality target groups are consulted and that wheelchair housing need requirements are examined more fully to understand the scale of need. As part of this exercise, it is recommended that further monitoring information should be gathered on the disability profile and gender profile of Council housing and lettings waiting lists.

Community Services, including:

• gathering more information on the use of community services by equality target groups and determining how accessible its community facilities in Kingston are, such as the library, Kingston College;
• assessing what scope there is for ‘dual use’ of e.g. education facilities for other purposes including religious teachings in evenings and weekends; strengthening internal relationships with other Council services to ensure well informed policies are developed for the Core Strategy DPD and Development Control Policies DPD including on community facilities and equality issues;
• better liaison with the PCT to determine specific need in relation to location of/access to primary health care facilities especially in the context of black and minority ethnic groups who according to national evidence experience greater problems in accessing appropriate health services
• maintenance of the Kingston Disabled and Older People’s Forum and the BME Forum, as these offer an ideal opportunity to contact hard to reach groups.

5.2
The AAP policies are not considered to have detrimental impact in terms of race, gender or disability and where appropriate have sought so far as possible to address the issues identified as action points under the UDP EQIA. The Council has been very mindful when preparing the AAP of the need to embrace all aspects of equalities legislation and guidance. In overall terms, the strategies and policies in the AAP are considered to have a positive, or at worst neutral, impact in terms of race, gender, disability, age, religion and belief or sexual orientation for the reasons set out in this report.

5.3
Unlike the UDP, the AAP process has undergone ethnicity and equality monitoring at all its consultation stages and has consulted equality target groups in accordance with the Statement of Community Involvement. Data is also now routinely collected as part of consultation exercises undertaken by other Council services. In addition a number of Member Working Group meetings were set up under the auspices of the former Transport & Infrastructure Overview Panel to assess the impact of development by Kingston University on the town centre. Following on from this, a KU Liaison Committee led by the Leader of the Council, was set up to maintain closer working links with the University and this has helped inform the Plan. A Member Working Group was similarly set up to formulate an After Dark Strategy and evidence was heard from various stakeholders, including transport groups and local residents, which confirmed the presently narrow appeal and accessibility of the night time economy to many groups and discussed measures to improve this.

5.4
It is considered that the AAP may be weak on access to community facilities, including health facilities, by the equality target groups. The UDP EQIA identified the fact that little data is currently available from the PCT concerning the needs of these groups and that they plan for much shorter timescales (usually 3 years) than local plan documents which plan for development over at least 10 years, or in the case of the AAP 15 - 20 years. However, closer working links are now being developed with the PCT, including through planned workshop events, with the intention of building up a bigger strategic evidence base and working more collaboratively in terms of e.g. public consultation. This will help to achieve a better alignment between planning and health to address any current existing and potential shortcomings. It is hoped that more information will be available in time to guide the LDF Core Strategy. The PCT is in the process of formulating a Strategy, albeit only for the next 3 years, which will review how they use their estate, where the health priorities lay and how they propose to address these.

6.0 Action Points

6.1
It is not proposed to repeat the UDP EQIA action points (summarised above) of relevance to the AAP, e.g. better liaison with the PCT which is crucial to identifying the full extent of need for, and delivery of, more accessible facilities to contribute to health improvements.

6.2
As with the UDP, preparation of the AAP commenced before there was a statutory requirement to prepare EQIAs, although (unlike the UDP) it did include questions on gender, race and disability as part of the public consultation feedback monitoring process. However, it has become clear that further analysis of the data collected from the public consultation stages would be beneficial in terms of identifying what proportion of respondents fall within the equality target groups to identify if there is an EQIA issue to address and, if a particular equality target group is over-/under-represented in responses to specific questions, to investigate the reasons behind this and to review policies and practices as appropriate to mitigate or redress this.

6.3
There is also considered to be a general need to ensure that action points are monitored and reviewed on an appropriately regular basis to assess whether the actions are having the desired effect. For example, one of the sustainability themes of the Plan (picked up in the SA) is to promote higher density residential and mixed-use development where appropriate to meet the housing needs of the local community (para 3.6 of this report). This will need to be closely monitored to ensure that it is not at the expense of the equality target groups that e.g. for disability or family reasons need larger flats or houses, including with amenity space. There is a need to investigate the best ways of measuring the success or otherwise of policies in delivering improvements for the equality target groups be it as part of the annual monitoring report on the Plan or as part of a separate exercise targeting the equality groups on a topic or issue basis and undertaking user satisfaction surveys. The SA (Table 5) sets out useful indicators for measuring the sustainability objectives of the Plan, a number of which are common to EQIA objectives and help provide a monitoring framework

6.4
There will also be a need (ref. para 3.27 of this report) to ensure that the appropriate monitoring information is passed onto relevant equality target groups in a way that will allow them to have easy access to it.

7.0 Publishing Arrangements

7.1
This report will be available to view on and download from RBK's website (www.kingston.gov.uk) under the Equality pages. The report can also be viewed at Environmental Services reception, in Guildhall II. The Council provides an interpretation and translation service to assist people who are unable to access information for reasons of disability or language.

Document Review

The following documents are of relevance to the AAP policies:

1. The London Plan: Spatial Development Strategy for Greater London, GLA
2. Planning Policy Guidance note 13: Transport (PPG13)
3. Diversity and Equality in Planning – Good Practice Guide, ODPM, January 2005
4. Accessible London Supplementary Planning Guidance, GLA 2004
5. Planning and Access for Disabled People, ODPM, 2003
6. The Mayor’s Transport Strategy, GLA, 2004
7. Equality Impact Assessments for Local Implementation Plans, Transport for London, June 2004
8. RBK, Local Implementation Plan, 2005
9. Promoting Gender Equality in Transport, Equal Opportunities Commission, 2005
10. Meeting Part M and Designing Lifetime Homes, Joseph Rowntree Foundation 1999
11. RBK Housing Needs Survey 2001
12. Residents Services Overview Panel, report of the 21^st July 2005 – Cross-cutting services for disabled people: outcome of scrutiny
13. Planning Policy Statement 3: Housing (PPS3)
14. Wheelchair Housing Design Guide 2006 (BRE Press)  
15. The Housing Corporation, Race Equality Scheme 2005
16. London Household Survey 2002
17. The Director of Health Annual Report 2005
18. Census 2001
19. UDP EQIA
20. RBK Affordable Housing SPD (adopted February 2006)
21. RBK Access for All SPD (adopted July 2005)
22. RBK Sustainable Construction SPG adopted February 2004.
23. RBK Shopfront Design Guidance SPD (adopted 2005)
24. RBK Draft ‘After Dark Strategy’ (March 2007)
25. Sustainability Appraisal of the Submission Version KTC AAP Dec 2006
26. Retail Studies 2003 and 2006
27. Parking Study 2003 and Parking Strategy 2005
28. Old Town Conservation Area Studies 2003 – 2005
29. Transport Assessment 2004 - 2006
30. Secure Cycle Parking Study and Strategy 2004
31. Park & Ride Study 2003 and Integrated Transport Study 2006
32. Office Survey 2005
33. Strategic Flood Risk Assessment and Management Study 2006
34. Archaeology Overview 2006
35. Hotel Feasibility Study 2007
36. RBK Supplementary Planning Advice: Design and Access Statements (2008)
37. RBK Supplementary Planning Advice Note on Lifetime Homes and Wheelchair Housing (2007)

Name:       Karen Perry
Service:    Planning Policy
Date:         2007, revised September 2008