Local living and 20 minute neighbourhoods - planning guidance: final impact assessment report update

Equalities Impact Assessment (EQIA) – Partial Summary

Title of Proposal

Scottish Government Planning Guidance: Local living and 20 minute neighbourhoods

Purpose and Intended Effect

Summary of aims and desired outcomes of Policy

The Scottish Government Planning Guidance: Local living and 20 minute neighbourhoods supports the delivery of the National Planning Framework (NPF4), adopted by the Scottish Ministers on 13th February 2023.

Directorate: Local Government and Housing Directorate

Division: Planning, Architecture and Regeneration Division

Team: Architecture, Place & Design Innovation team

Executive Summary

The public sector equality duty requires the Scottish Government to assess the impact of applying a proposed new or revised policy or practice. Equality legislation covers the protected characteristics of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion and belief, sex (gender) and sexual orientation.

NPF4 Policy 15 sets out policy principles on local living and 20 minute neighbourhoods. NPF4 forms part of the statutory development plan. The Scottish Government Planning Guidance: Local living and 20 minute neighbourhoods aims to support the implementation of the existing policy framework within NPF4.

The preparation of NPF4 involved extensive consultation and parliamentary scrutiny. A Society and Equalities Impact Assessment, including an EQIA, was undertaken for NPF4 including content on local living and 20 minute neighbourhoods. Additionally, a full public consultation on the draft guidance ran from 27 April to 20 July 2023.

The guidance does not introduce any additional policy requirements or duties and is simply intended to provide additional details and clarifications of existing policy in order to support effective and efficient implementation. The guidance is therefore considered to be covered by the NPF4 EQIA. This report therefore only summarises the key issues to update and supplement the full assessment.

Background

An EQIA aims to consider how a policy may impact, either positively or negatively, on different sectors of the population in different ways.

The Equality Act 2010 harmonised existing equality legislation and includes a public sector duty ('the Duty') which requires public authorities to pay due regard to then need to:

• eliminate discrimination, harassment, victimisation or any other prohibited conduct
• advance equality of opportunity
• foster good relations between different groups – by tackling prejudice and promoting understanding

Stage 1 - Framing

Local living and 20 minute neighbourhoods are included within the policy framework of NPF4, adopted by the Scottish Ministers on 13th February 2023. The concept of local living and 20 minute neighbourhoods is intended to support places where people can meet the majority of their daily needs within a reasonable distance of their home, preferably through active travel modes or by public transport.

NPF4 was the subject of extensive consultation and parliamentary scrutiny and an Integrated Impact Assessment (IIA), involving a number of statutory and non-statutory assessments including EQIA, was prepared for NPF4 and is available on the Transforming Planning website.

The policy intent and outcomes for local living and 20 minute neighbourhoods were included within this assessment process. Therefore, the impact of the policy has already been assessed and this report summarises and updates key content relevant to local living and 20 minute neighbourhoods gathered as part of the previous impact assessment process.

In preparing the Scottish Government Planning Guidance: Local living and 20 minute neighbourhoods, consideration has been given to impacts within the framing already provided by the NPF4 impact assessments, including the EQIA.

Stage 2 – Gather Evidence and Consult

The NPF4 Society and Equalities Impact Assessment, forms the basis for the consideration of equalities impacts of Scottish Government Planning Guidance: Local living and 20 minute neighbourhoods

The preparation of NPF4 involved extensive evidence gathering and consultation.

Between January and April 2020 the Scottish Government held an open call for ideas to hear views on what Scotland should be like in 2050 and the changes needed to get there.

A Position Statement was published in November 2020. This reflected on the information received through the call for ideas engagement programme.

Draft NPF4 was laid in the Scottish Parliament on 10 November 2021 for Parliamentary scrutiny. Alongside Parliament’s consideration of the draft NPF4, the Scottish Government invited comments from all stakeholders. The public consultation was launched on 10 November 2021 and closed on 31 March 2022.

Consultation on draft guidance

A public consultation on the Local living and 20 minute neighbourhood: Draft Planning Guidance ran between 27 April and 20 July 2023 with questions relating to equalities factors included within it. Issues raised include:

• the addressing of the needs of those with protected characteristics within the EQIA, particularly those with disabilities or older people. The consultation called for greater emphasis on the importance of the experience of those with protected characteristics, in navigating local spaces and accessing relevant facilities and services feeding into decision-making and to support inclusion
• that there was disparity between the capacity of communities and the resources available to them to enable communities to drive change, which was not reflected in the guidance
• recommendations that the guidance should be strengthened in relation to the importance of accessible transport and accessible housing to support inclusivity
• that accessibility should be a criterion for determining if a community is a successful place and called for a definition of ‘Inclusive Design’ that advocated for the early involvement of the end user in the design process
• the need to highlight that digital access to services should be available as a choice rather than the only available option and that digital literacy or access to IT equipment should be assumed
• health inequalities could be better referenced, with more mechanistic detail and noted outcomes
• that women often work in low-paid, insecure but local jobs due, for instance, to lack of access to a car or to caring responsibilities and that guidance did not compound the issue
• Some welcomed the inclusion of the EQIA and associated documents, commenting that the Assessment was clear and well-organised and provided a useful focus on equalities. It was also felt to be comprehensive, summarised key aspects relevant to local living from an NPF4 perspective, and gave helpful information

Stage 3 – Assess impact, identify mitigations

Key findings are contained with art A.3. of the Society and Equalities Impact Assessment and relevant issues related to the specifics of the guidance are summarised here.

Age: The importance of considering the age characteristic in the development of places is recognised in the questions which form the Place Standard tool. It provides a simple framework for local people to assess the quality of a place and to help structure conversations about future improvement. It allows people to think about the physical elements of a place (for example its buildings, spaces, and transport links), as well as the social aspects (for example whether people feel they have a say in decision making).

Disability: Disabled people can participate as active citizens in all aspects of daily and public life. Disabled people to benefit from increased availability of affordable and accessible housing to support people to continue to life independent lives. Increased availability of accessible and inclusive transport and services.

Sex: In taking steps to meet the needs of women and men where these are different. Particular issues are noted around the way that women and men use public places, such as access to local employment and community facilities and the safety of users of public spaces. In terms of removing or minimising disadvantages suffered by people due to this protected characteristic, NPF4 policy on local living provides an opportunity to shape places which act as complete, connected and compact neighbourhoods designed in such a way that all people can meet the majority of their daily needs within a reasonable walk, wheel or cycle of their home.

Pregnancy and Maternity: There is considerable evidence of beneficial effects of access to green space for the health of pregnant women. Responses to the NPF4: Call for Ideas noted that places that have not been designed to enable access by those with a variety of access needs become inaccessible, including for disabled women, carers, older women, pregnant women, and mothers of young children. Tackling issues around access to facilities and public spaces may be of particular concern to people with this protected characteristic.

Gender Reassignment: In a survey, less than one third of transgender and non-binary people said there were enough places where they could socialise safely. 54% of trans respondents avoided being open about their gender identity in ‘the park’ for fear of a negative reaction from others. A factor leading to non-binary people and women feeling uncomfortable in parks is the lack of public toilets. 55.4% highlighted that there were no toilets in the park they most frequently visited, and 35.8% of participants indicated that the provision of more toilets would encourage them to visit parks more frequently and for longer periods of time.

Sexual Orientation: It has been suggested that there is a spatial dimension to where the LGBT community lives in Scotland, with a focus of the community in large urban areas. Tackling issues around access and safety in public spaces may be of particular concern to this group of people.

Race: Respondents to the NPF4 Position Statement consultation highlighted the benefits of green space in terms of the wellbeing of communities, and cited evidence that lower income households and Black, Asian and minority ethnic communities are disproportionately impacted by loss of green space. It also went on to say that policy on 20 minute neighbourhoods should ensure diverse needs are taken into account, it was suggested that it will be important not just to focus on people living and working in a particular place but to connect to wider organisations – including those representing Gypsy/Travellers.

Religion or Belief: Responses to the Scottish Household Survey in relation to the national indicator on access to green or blue space, reveals that those responding as having no religion or as Christian were more likely to live within 5 minutes of a greenspace compared to those belonging to another religion. 63.61% of Christians, compared to those from other religions indicated they lived within 5 minutes' walk of their nearest green or blue space. Initial indication are that there is a similar degree of agreement (1/5 to 1/4) across religious groups that they could influence decisions affecting their local area.

Marriage and Civil Partnership. The planning system is not related to this characteristic.

Consultation on draft guidance

The importance of the involvement and consideration of those with protected characteristics, including older people and those with disabilities, in the development of places has been given additional emphasis within the final guidance.

The draft guidance introduced the Local Living Framework, a tool developed to provide a consistent structure to consider how local living is, or can be, supported in a place. The draft guidance also offered ‘Key considerations’ within the main document to support the use of the Local Living Framework and the consideration of local living principles. The ‘Key considerations were expanded upon within an annex to the draft guidance.

Within the final guidance the information previously held in the annex has been refined and combined with the ‘Key considerations’ to illustrate a non-exhaustive set of interrelated place and wellbeing themes to help a holistic consideration of their importance for local living. The ‘Key considerations’ within the final guidance include emphasis on the importance of engaging particular groups including those with disabilities and older people.

The final guidance also notes the relationship between the Local Living Framework the Place Standard tool and the Place and Wellbeing Outcomes^[1] which are inter-related resources structured around the same 14 themes and based on evidence^[2] around how place impacts on health and wellbeing.

The final guidance expresses that the involvement of communities in the shaping of the places where they live, including the location and type of services available and the design of service delivery, is key to the implementation of local living principles.

Throughout the final guidance document and more particularly within Part 3, the importance of considering both qualitative and quantitative data is set out. Ensuring local views are considered alongside mapping, statistics and numbers is likely to allow inequalities issues to be highlighted and considered.

Recommendations and Conclusion

The Scottish Government Planning Guidance: Local living and 20 minute neighbourhoods does not introduce any additional policy requirements or duties and is simply intended to provide additional details and clarifications of existing policy to support effective and efficient implementation of NPF4. The guidance is therefore considered to be covered by the NPF4 EQIA.

In the final guidance, we have aimed to respond to comments on equality issues received through the consultation process, with particular reference to the points raised in the NPF4 EQIA

Sign and Date:

Policy Lead Signature & Date of Sign Off:

Ashley Mullen
13 March 2024

Deputy Director Signature & Date of Sign Off:

Fiona Simpson
13 March 2024