Cleaner Air for Scotland 2: equalities impact assessment

Stage 1: Framing

In this EQIA we look at published evidence available and gathered so far under the protected characteristics as listed within the Equality Act 2010: Age, Disability, Sex, Pregnancy and Maternity, Gender Reassignment, Marriage and Civil Partnership Sexual Orientation, Race and Religion or Belief.

The scope of this EQIA is extended beyond the list of protected characteristics to include wider socio-economic considerations and considers people living in poverty and/or in low income households, and those living in remote rural areas and island communities. As the scope of this assessment has been extended to include these impacts, partial/not required assessments and rationale for separate Fair Scotland Duty and Children's Rights and Wellbeing impact assessments have been completed. A separate Island Communities Impact Assessment may also be required.

A full list of protected characteristics, together with an analysis of the available evidence is provided in Table 2 of this EQIA.

Qualitative information has been gathered from the independent review steering group report, along with comments on the recommendations received via an online survey held at the end of 2019.

A one day Cleaner Air for Scotland workshop was held in September 2019 with air quality officers from Local Authorities. The aim of the workshop was to get their views on the review recommendations, particularly the 10 high level recommendation on which the new strategy will be shaped.

Evidence has also been gathered from a review of literature around public attitudes and behaviour relating to air quality^[6]. The review was commissioned by Scottish Government and was undertaken by the University of the West of England (UWE). The report highlighted the need to engage effectively with communities, particularly those in deprived areas during the design and implementation of pro-environmental policies, to minimise negative impacts.

Consideration has been given as far as possible to potential impact based on the evidence gathered leading up to the formal consultation. Specifically, this EQIA considers impacts on equalities groups based on the three tests it is required to address:

• Does this policy eliminate discrimination for each of the nine protected characteristics? If not is the discrimination justifiable? Can it be mitigated?
• Does this policy advance equality of opportunity between people who share a protected characteristic and those who do not?
• Does this policy foster good community relations between people who share a protected characteristic and those who do not?

Initial reflections from the evidence gathering and engagement to date indicate that the strategy, may potentially have positive impacts on some people, including those with protected characteristics, due to measures to reduce air pollution and improve air quality. The initial indications of the main positive impacts are Age, Disability and Pregnancy and Maternity as summarised below:

Protected Characteristic: Age

Poor air quality can have an effect on human health^[7], and evidence from international research indicates disproportionate impact on the elderly and on the young^[8]. The objective of CAFS 2 to is to implement measures to help achieve compliance with air quality objectives and reduce preventable air pollution. This will improve air quality for Scotland's population, including children and older people.

Protected Characteristic: Disability

A disability can arise from a wide range of impairments which can be organ specific, including respiratory conditions, such as asthma and cardiovascular diseases. These conditions can be exacerbated by poor air quality. Therefore measures contained within the CAFS 2 strategy, which aim to reduce emissions and improve air quality, will positively impact disabled people living with conditions exacerbated by poor air quality.

Protected Characteristic: Pregnancy and Maternity

Pregnancy and early childhood are critical times for the formation and maturation of body systems, and the time during which the most rapid changes take place. Factors that adversely affect human development, including air pollution, can have both immediate and long-lasting effects on a person's health, and some health impacts may only emerge later in life^[9].

Socio-economic considerations

The scope of this EQIA is extended beyond the list of protected characteristics to include wider socio-economic considerations and considers people living in poverty and/or in low income households, and those living in remote rural areas and island communities. Initial reflections from the evidence gathering and engagement to date indicate that the strategy may impact on those living in remote/rural and island communities as well as low income families. These impacts may occur due to measures to tackle emissions from domestic combustion and policies to encourage a shift to more sustainable transport modes.

The UWE literature review showed that for those living in rural areas and in lower socioeconomic households, reducing private vehicle ownership/use is a challenge as there is a (perceived) reliance on the car to manage complex needs (e.g. work, family, caring, health concerns). In the most deprived areas, this is compounded by a fear of crime, as well as a lack of infrastructure, which restricts perceived abilities to use active travel modes. As the policies in CAFS 2 aim to encourage a shift towards more sustainable transport modes, focus on engagement with these communities will be critical to mitigate any disproportionate impacts.

There may also be an impact on remote/rural or island communities arising from measures contained within the strategy to tackle emissions from domestic combustion. Particularly controlling the supply of the most polluting fuels. This may disproportionately impact remote/rural and island communities due to the potentially higher proportion of households relying on solid fuels as a primary heat source in these areas.

Further evidence is sought via the consultation on CAFS 2 to inform this impact assessment. It should also be noted that it is not the CAFS 2 strategy itself that will cause the impact but the regulations which follow on. Any such regulations will be required to undergo further equalities assessments.

Further evidence gathering will be conducted as part of the consultation on CAFS 2. This will include specific questions on to assess the impact of the measures on people with one or more of the protected characteristics. We will also seek and consider further views from relevant stakeholders as part of this EQIA in due course.