Application Reference Number: WWO10001 Examining … · 2016-05-05 · 2.7 Above-ground permanent...

Examining Authoritys Second Written Round of Questions and Requests for InformationResponse from Thames Water

Equalities Impact Assessment - 13 January 2014

Doc Ref: APP77

Folder 168 January 2014DCO-DT-APP-ZZZZZ-770000

Thames Tideway Tunnel Thames Water Utilities Limited

Application for Development ConsentApplication Reference Number: WWO10001

DCO-DT-000-ZZZZZ-071600 | January 2013

Equalities Impact Assessment

Full Assessment

Regulation 5(2)(q)

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Equalities Impact Assessment i

Thames Tideway Tunnel

Equalities Impact Assessment

List of contents

Page number

1 Executive summary ......................................................................................... 1

2 Project description ........................................................................................... 5

2.1 Project context ......................................................................................... 5

2.2 The proposed solution ............................................................................. 5

2.3 Planning context ...................................................................................... 6

2.4 Project overview ...................................................................................... 6

2.5 Tunnels .................................................................................................... 7

2.6 Site types ................................................................................................. 7

2.7 Above-ground permanent works .............................................................. 8

3 Introduction ...................................................................................................... 9

3.1 Purpose of this report .............................................................................. 9

3.2 Introduction to equalities .......................................................................... 9

3.3 Equalities impact assessment for the project......................................... 10

3.4 Structure of this document ..................................................................... 10

4 EqIA background ........................................................................................... 13

4.1 Introduction ............................................................................................ 13

4.2 National policy ....................................................................................... 13

4.3 Regional policy ...................................................................................... 14

4.4 Summary ............................................................................................... 16

5 Project approach to equalities ...................................................................... 17

5.1 Introduction ............................................................................................ 17

5.2 Site selection and assessment .............................................................. 17

5.3 Project practices and policies ................................................................ 19

5.4 Approach to consultation ....................................................................... 23

6 Methodology ................................................................................................... 29

6.1 EqIA process ......................................................................................... 29

6.2 Interaction with other assessments ....................................................... 33

6.3 Assumptions and limitations .................................................................. 33

7 Scoping and defining the EqIA ..................................................................... 35

7.1 Introduction ............................................................................................ 35

Equalities Impact Assessment ii

7.2 Scope .................................................................................................... 35

7.3 Defining the assessment area ............................................................... 38

8 EqIA information gathering ........................................................................... 41

8.1 Introduction ............................................................................................ 41

8.2 Project background ................................................................................ 41

8.3 Socio-demographic profiling .................................................................. 43

8.4 Consultation ........................................................................................... 51

9 EqIA and action planning .............................................................................. 55

9.1 Introduction ............................................................................................ 55

9.2 Assessment ........................................................................................... 55

10 EqIA conclusions and review ...................................................................... 157

10.1 Introduction .......................................................................................... 157

10.2 EqIA process ....................................................................................... 157

10.3 EqIA findings ....................................................................................... 157

10.4 Monitoring and review ......................................................................... 160

Glossary ................................................................................................................ 163

Appendices ........................................................................................................... 187

Appendix B : Translation note ............................................................................. 189

Appendix C : EqIA assessment areas ................................................................ 191

Appendix D : Construction patterns ................................................................... 193

Appendix E : Socio-demographic profiling ........................................................ 197

Appendix F : Amenities included in the assessment ........................................ 211

Appendix G : Equalities questionnaire responses ............................................ 213

Appendix H : EqIA consultation .......................................................................... 219

Appendix I : Phase two consultation responses in relation to equalities ....... 239

List of figures

Page number

Figure 6.1 EqIA process ........................................................................................... 30

Figure 7.1 EqIA assessment areas ........................................................................... 40

Equalities Impact Assessment iii

List of tables

Page number

Table 5.1 Equalities issues raised at phase two consultation and Thames Waters response .................................................................................................. 26

Table 7.1 Equalities issues ...................................................................................... 36

Table 8.1 Socio-demographic data sources ............................................................ 43

Table 9.1 EqIA assessment summary: Project-wide impacts .................................. 57

Table 9.2 EqIA assessment summary: Acton Storm Tanks ..................................... 63

Table 9.3 EqIA assessment summary: Hammersmith Pumping Station .................. 65

Table 9.4 EqIA assessment summary: Barn Elms ................................................... 68

Table 9.5 EqIA assessment summary: Putney Bridge Foreshore ........................... 75

Table 9.6 EqIA assessment summary: King Georges Park .................................... 81

Table 9.7 EqIA assessment summary: Dormay Street ............................................ 87

Table 9.8 EqIA assessment summary: Carnwath Road Riverside .......................... 87

Table 9.9 EqIA assessment summary: Falconbrook Pumping Station .................... 97

Table 9.10 EqIA assessment summary: Cremorne Wharf Depot .......................... 103

Table 9.11 EqIA assessment summary: Chelsea Embankment Foreshore ........... 107

Table 9.12 EqIA assessment summary: Kirtling Street .......................................... 108

Table 9.13 EqIA assessment summary: Heathwall Pumping Station .................... 111

Table 9.14 EqIA assessment summary: Albert Embankment Foreshore .............. 114

Table 9.15 EqIA assessment summary: Victoria Embankment Foreshore ............ 117

Table 9.16 EqIA assessment summary: Blackfriars Bridge Foreshore .................. 118

Table 9.17 EqIA assessment summary: Chambers Wharf .................................... 126

Table 9.18 EqIA assessment summary: King Edward Memorial Park Foreshore .. 130

Table 9.19 EqIA assessment summary: Earl Pumping Station .............................. 135

Table 9.20 EqIA assessment summary: Deptford Church Street .......................... 139

Table 9.21 EqIA assessment summary: Greenwich Pumping Station ................... 146

Table 9.22 EqIA assessment summary: Abbey Mills Pumping Station .................. 148

Table 9.23 EqIA assessment summary: Beckton Sewage Treatment Works ........ 149

Table 9.24 EqIA assessment summary: System modification sites ....................... 149

Equalities Impact Assessment iv

List of abbreviations

BME black and minority ethnic

CSO combined sewer overflow

CoCP code of construction practice

DCO development consent order

DDA Disability Discrimination Act 1995

DLA disability living allowance

DO dissolved oxygen

EIA environmental impact assessment

EqIA equalities impact assessment

ES environmental statement

FS foreshore

GLA Greater London Authority

HIA health impact assessment

IPC Infrastructure Planning Commission

IoD index of deprivation

JSA job seekers allowance

LADP landscape and architecture design principles

LGBT lesbian, gay bisexual and transgender

LLTS limiting long term sick

NINo national insurance number

NPS national policy statement

PEIR preliminary environmental impact report

PS pumping station

PSED public sector equality duty

PRoW public right of way

SEIA socio economic impact assessment

SSR site suitability report

STW sewage treatment works

UWWTD urban waste water treatment directive

UWWTR urban waste water treatment regulations

1 Executive summary

Equalities Impact Assessment 1

1 Executive summary

Background

1.1.1 The Equalities Impact Assessment (EqIA) was prepared in support of the application for development consent (the application) for the Thames Tideway Tunnel project (the project). It examines the potential impact of the project on groups of people with protected characteristics. The protected characteristics considered in the EqIA are:

a. age

b. disability

c. gender reassignment

d. marriage and civil partnerships

e. pregnancy and maternity

f. race

g. religion or belief

h. gender

i. sexual orientation

j. shift workers

k. deprivation.

1.1.2 The EqIA was developed in accordance with the requirements of the National Policy Statement for Waste Water (the NPS) and consideration of the Equality Act 2010 (the 2010 Act). It also had regard to relevant national and regional policies that sustain the objectives and ambitions embedded in the project, of improving the natural environment and water quality, Londons environment and economy.

1.1.3 It is noted that shift workers and deprivation equalities groups are not considered under the Equalities Act 2010, but have been included in this assessment based on the socio-demographic profile of the study area in line with the requirements of the NPS.

EqIA approach and methodology

1.1.4 The assessment evolved throughout the pre-application phase of the project and sought to ensure that equalities groups were considered throughout each stage of the project, from site selection and assessment to public consultation and through development of suitable mitigation and strategies.

1.1.5 The methodology was developed through examination of relevant policies and guidance. A best practice review of other EqIAs was also undertaken, including the NPS EqIA, other national infrastructure projects as well as equalities policies and EqIAs from the relevant local authorities.

1 Executive summary


1.1.6 The methodology was based on two stages; an initial EqIA and a full EqIA. Thames Water1 carried out an initial EqIA in January 2012, which identified a range of potential impacts on equalities groups that might arise as a result of the proposed project. Consequently a full EqIA (the EqIA) was undertaken. The EqIA explores the range and magnitude of potential impacts on equalities groups and sets out any appropriate mitigation and monitoring measures.

1.1.7 The EqIA examined the potential impact of the project on equalities groups surrounding the sites, along the route of the main tunnel. It identified representation, and in some cases concentrations, of the equalities groups considered within the assessment area (within 250m of each proposed worksite).

1.1.8 The EqIA identified a range of equalities issues relevant to the project, which were categorised under the following themes:

a. accessibility (physical accessibility of services, places and information)

b. environment (changes to the living environment)

c. safety (actual or perceived safety, security and severance)

d. infrastructure (local environmental impacts or changes including public realm or landscaping)

e. transport (transport services, parking and public rights of way)

f. deprivation (impact on those whose life choices are already limited due to limited/low incomes and/or deprivation).

1.1.9 The EqIA took into account outputs from a number of technical assessments undertaken by Thames Water as part of the Environmental Statement (including noise, transport and socio-economic impact assessments). The EqIA specifically considered the impact of the project on equalities groups in order to ensure that the interests of these groups were appropriately represented.

Scoping and information gathering

1.1.10 The scope of the EqIA was defined by way of setting out the likely equalities impacts that may arise as a result of the project. This process involved defining the geographical areas that are likely to be affected by the proposed works.

1.1.11 The EqIA took into account the site selection process and considered the proposals for construction and operation at each site, in order to understand the level of effect and potential impacts on equalities groups as a result of the project.

1.1.12 A review of the socio-demographic profile of each site was undertaken in order to understand the composition of the population around the proposed sites.

1 Thames Water Utilities Ltd (TWUL). The Draft Development Consent Order (DCO) contains an ability for TWUL

to transfer powers to an Infrastructure Provider (as defined in article 2(1) of the DCO) and/or, with the consent of the Secretary of State, another body

1 Executive summary


1.1.13 The findings from all phases of consultation were used to inform the identifcation of equalities issues for the EqIA. This included responses to the equalities questionaire and the EqIA consultation undertaken with the relevant local authorities.

EqIA and action planning

1.1.14 The proposed construction and operational phases of the project were assessed for impacts on equalities groups. The assessment included a consideration of the potential project-wide impacts and likely site-specific impacts where the impact is considered to be significant. The assessment indicated that there would be both positive and negative impacts as a result of the project.

1.1.15 The EqIA established that the majority of impacts would be experienced during the construction phase, due to the type and scope of works required. It was found that the impacts would vary by site and were categorised as follows:

a. construction noise and vibration

b. land take for construction

c. pedestrian diversions

d. movement of construction vehicles

e. changes to parking provision

f. increased water rates

g. creation of employment.

1.1.16 For the operational phase, the assessment identified a range of benefits for equalities groups, including:

a. improvements to public realm

b. creation of new open spaces

c. creation of employment.

1.1.17 Thames Water has sought to minimise, mitigate and eliminate the potential impacts on equalities groups, through appropriate design solutions and various measures and processes including project-wide and site-specific design principles, and environmental mitigation measures. These were developed in response to the technical assessments undertaken as part of the environmental impact assessment, and in accordance with measures embedded within the Code of Construction Practice (CoCP), and other initiatives and strategies such as the Skills and Employment Strategy.

Updates to the EqIA

1.1.18 The EqIA has been updated in the light of the more timely and accurate Census 2011 datasets. The original socio-demographic profiling around each site has been updated along with data for each Local authority affected and the comparable data for England and Greater London. The Appendices have not been updated because these are not affected by the

1 Executive summary


census updates, except for Tables D1 and D2 in Appendix D. These are now included as Tables 8.2 and 8.3.

1.1.19 The key changes identified from the 2011 census data were as follows:

a. With the exception of City of London, all boroughs have seen a one to three per cent reduction in the proportions of older people (over 65 years).

b. With the exception of Ealing, Hammersmith and Fulham, Richmond upon Thames, Wandsworth and Westminster, all other boroughs have seen a reduction in the proportion of young children (under 16 years).

c. All boroughs have seen an increase in the proportions of Black Asian Minority Ethnic groups, with the largest increases in Westminster (14 per cent), Lewisham (12 per cent) and Greenwich (15 per cent).

d. All boroughs have seen a reduction (six to ten per cent) in the proportions of those classified as having long-term health problems or disability.

1.1.20 The findings at borough level were generally replicated across the more detailed site analysis review, which examined the socio-demographic profile of residents within a 250m boundary of each site.

1.1.21 The reductions in the proportions of the protected characteristics mentioned above are a positive improvement on the application assessment as a lower proportion of residents from these groups are likely to be affected.

1.1.22 The increases in the proportion of Black and Asian Minority Ethnic groups in a number of boroughs were expected and discussions were had with several boroughs on how best to engage with these communities during the pre-application consultation periods. Future consultation, communication and community liaison during the construction phase will also take into account the higher proportion of Black and Asian Minority Ethnic groups within the boroughs affected and around each site.

1.1.23 Following the application for development consent, we have continued to develop and refine our mitigation for reducing impacts at all our sites. The detail of this on-going work is set out in the Summary of Further On-Site Mitigation Measures and Revisions to Compensation Policies (Doc Ref: APP67) to be submitted to the ExA on 13 January 2014. The measures outlined in this document would further minimise disproportionate impacts on equalities groups.

1.1.24 The review and updates to Census datasets demonstrates that there are no significant changes to the overall equalities assessment and thus the original findings remain unaltered.

2 Project description



2.1 Project context

2.1.1 At present, untreated sewage mixed with rainwater (combined sewage) regularly overflows into the River Thames from Londons Victorian sewerage system via combined sewer overflows (CSOs).

2.1.2 Combined sewage discharges must be reduced in order to comply with relevant wastewater legislation. The primary objective of the proposed Thames Tideway Tunnel project (the project) is to control discharges from CSOs in order to meet the requirements of the European Unions Urban Waste Water Treatment Directive (91/271/EEC) (UWWTD) and the related United Kingdom (UK) Urban Waste Water Treatment Regulations. Other European Union and UK legislation also forms part of the legal framework within which the project is to be designed and delivered. The Water Framework Directive, and the regulations that transpose it into UK law, set out various environmental objectives to be achieved in relation to surface water quality.

2.1.3 Solutions to the problem of wastewater discharges into the tidal reaches of the River Thames have been under examination for more than ten years. The project has been determined to be the most technologically-sound and cost-effective means of controlling CSO discharges and satisfying regulatory requirements. This has been confirmed by independent studies and by Thames Water.

2.2 The proposed solution

2.2.1 The project would control CSO discharges by intercepting and diverting combined sewage flows into a new storage2 and transfer tunnel. The tunnel would run from Acton Storm Tanks in west London to Abbey Mills Pumping Station in the east, where it would connect to the Lee Tunnel, which would transfer the flows to Beckton Sewage Treatment Works for treatment.

2.2.2 The new infrastructure would protect the tidal Thames from increasing pollution for at least the next 100 years. The current assumption is that construction would commence in 2016 and be completed by 2023.

2.2.3 The project forms part of the wider London Tideway Improvements scheme, which includes the Lee Tunnel project and improvements at Mogden, Crossness, Longreach and Riverside Sewage Treatment Works, and a major capacity extension at Beckton Sewage Treatment Works to treat flows collected by the Thames Tideway and Lee tunnels.

2 The main tunnel would capture and store combined sewage from the unsatisfactory CSOs along its route and transfer it to Beckton Sewage Treatment Works



2.3 Planning context

2.3.1 The National Policy Statement for Waste Water, which was designated on 26 March 2012, clearly states that the need for the project has been demonstrated. It concludes that detailed investigations have confirmed the case for a Thames Tunnel3 as the preferred solution (para. 2.6.33).

2.3.2 On 22 June 2012, the Secretary of State made the Infrastructure Planning (Waste Water Transfer and Storage) Order 2012 pursuant to Section14(3) of the Planning Act 2008 (as amended by the Localism Act 2011) (the 2008 Act). This order created a new category of Nationally Significant Infrastructure Projects (NSIPs) into which the project falls. Following the making of the order, the project formally became an NSIP to which the procedures under the 2008 Act apply.

2.3.3 The Planning Inspectorate is responsible for examining applications for NSIPs, which are granted in the form of Development Consent Orders. The Secretary of State4 has assumed responsibility under the 2008 Act for deciding such applications and will judge the application for development consent for the project primarily on the basis of the policies in the National Policy Statement for Waste Water.

2.3.4 Promoters of applications for development consent must undertake pre-application public consultation and publicity and have regard to feedback prior to submission of the application. The planning team has therefore carried out extensive consultation and publicity in accordance with the relevant statutory requirements.

2.4 Project overview

2.4.1 The project comprises two principal elements:

a. tunnels:

i the main tunnel

ii connection tunnels.

b. sites:

i main tunnel sites

ii CSO sites

iii system modification sites

iv Beckton Sewage Treatment Works.

3 The project changed its name from the Thames Tunnel project to the Thames Tideway Tunnel project in July

2012. 4 In this case, the Secretaries of State for the Department for Communities and Local Government and the

Department for Environment, Food and Rural Affairs will act as joint decision maker.



2.5 Tunnels

Main tunnel

2.5.1 The main tunnel would capture and store combined sewage from the unsatisfactory CSOs along its route and transfer it to Beckton Sewage Treatment Works.

2.5.2 The horizontal alignment of the main tunnel would generally follow the River Thames, where possible and practical, in order to:

a. ensure the most efficient route to connect the CSOs located on both banks of the river

b. enable river transport during construction to supply and remove materials, where practicable and economic

c. minimise the number of structures the tunnel would pass beneath in order to reduce the number of third parties affected.

2.5.3 The main tunnel route would take the shortest line from Acton Storm Tanks to the River Thames and stay beneath the river from west London to Rotherhithe. It would then divert from beneath the River Thames to the northeast via the Limehouse Cut and terminate at Abbey Mills Pumping Station, where it would connect to the Lee Tunnel.

2.5.4 The main tunnel would be approximately 25km long with an approximate internal diameter of 6.5m in the west increasing to 7.2m through central and east London. The approximate depth of the tunnel would be between 30m in west London and 65m in the east in order to provide sufficient clearance to existing tunnels and facilities under the city and meet the hydraulic requirements.

Connection tunnels

2.5.5 Two long connection tunnels would be required in order to connect five remote CSOs to the main tunnel. The tunnels are known as:

a. the Frogmore connection tunnel (approximately 3m internal diameter and approximately 1.1km long), which would be situated in the London Borough of Wandsworth

b. the Greenwich connection tunnel (approximately 5m internal diameter and approximately 4.6km long), which would pass through the London boroughs of Southwark and Lewisham and the Royal Borough of Greenwich.

2.5.6 A series of shorter connection tunnels would also be necessary to connect various CSOs that are close to the proposed main tunnel route.

2.6 Site types

2.6.1 The Environment Agency has identified 34 unsatisfactory CSOs that the project needs to address. CSO control studies and design development have established that 14 of these CSOs could be controlled indirectly, which reduces the number of worksites required.



2.6.2 The multidisciplinary team carried out a detailed site selection process, having regard to engineering, planning, environment, socio-economic, community and property constraints. Twenty-four worksites were selected in total, which can be categorised by function as follows:

a. Five main tunnel sites: These sites would be used to construct the main tunnel and can be further classified as drive sites and/or reception sites. Shafts would be excavated to the appropriate depth and the tunnel boring machines would start at drive shafts and be removed via reception shafts. A shaft may serve as both a drive and a reception shaft.

b. Sixteen CSO sites: These sites would be used to construct the CSO drop shafts and interception structures and to drive or receive connection tunnels.

c. Two system modification sites: These sites would be used to control CSOs locally rather than connecting them to the main tunnel.

d. Beckton Sewage Treatment Works: This site would be used to lift the combined sewage flows from the main tunnel system and transfer them for treatment. This site also requires a siphon tunnel to bypass the pumping mechanism when the tunnel system is full.

2.7 Above-ground permanent works

2.7.1 Some permanent above-ground infrastructure would be required, which would vary according to the type of site. This infrastructure might include:

a. air management facilities including ventilation structures and ventilation columns

b. a kiosk structure to house electrical and control equipment

c. a means of access

d. areas of hardstanding adjacent to shafts and structures to enable periodic inspection and maintenance.

2.7.2 Maintenance visits would be required approximately every three to six months for above-ground equipment inspections and every ten years for tunnel system and shaft inspections.

2.7.3 Construction sites would be restored on completion of the works by means of levelling, in-filling, landscaping and making good.

3 Introduction


3 Introduction

3.1 Purpose of this report

3.1.1 The EqIA was prepared in support of the application for the project. The project is a Nationally Significant Infrastructure Project (NSIP) designated under the Planning Act 2008 (the 2008 Act). Under the requirements of the 2008 Act, applications for wastewater NSIPs are to be considered in accordance with the relevant national policy statement.

3.1.2 The NPS, which was designated on 26 March 2012, sets out government policy for the provision of major wastewater infrastructure. It is used by the decision maker5 as the primary basis for deciding applications for development consent for wastewater developments, that fall within the definition of NSIPs as defined by the 2008 Act.

The NPS (para. 4.15.6) states that: The applicant should undertake and include in their application an equalities impact assessment for construction, operation and decommissioning phases. This will require an Initial Equalities Impact Assessment (EqIA) to identify potential adverse, differential or positive impact on equalities groups, and whether these are direct or indirect. If significant impacts are identified at the screening stage, a full Equalities Impact Assessment should be undertaken.

3.1.3 Thames Water undertook an initial EqIA in January 2012, which established the need for further assessment. Accordingly, a full EqIA was conducted in order to satisfy the requirements of the NPS and to support the application.

3.2 Introduction to equalities

3.2.1 The purpose of the EqIA was to ensure that the project would not discriminate against any individual or community and to promote equality for all where possible. Thames Water developed the EqIA in order to have a positive effect on the development of the project and to support the policy objectives of the NPS for the creation of a "strong, healthy and just society (para. 2.2.3).

3.2.2 EqIAs seek to ensure that equalities are placed at the centre of policy development and review, as well as service delivery. EqIAs are required to fulfil the statutory duties of public bodies by ensuring that equalities are promoted in accordance with the 2010 Act. The 2010 Act identifies a number of protected characteristics for consideration within EqIAs as follows:

a. age

b. disability

5 In this case, the Secretaries of State for the Department for Communities and Local Government and the

Department for Environment, Food and Rural Affairs will act as joint decision maker.

3 Introduction


c. gender reassignment

d. marriage and civil partnership

e. pregnancy and maternity

f. race

g. religion or belief

h. sex

i. sexual orientation.

3.2.3 In this report, the protected characteristics are referred to as equalities groups.

3.2.4 Although the 2010 Act advises consideration of the above equalities groups within an EqIA, other groups may also be examined, depending on the specific demographic and socio-economic composition of the area and the policy, strategy or scheme under assessment.

3.2.5 An EqIA should be used to inform all stages of scheme development including design, construction and operation, to ensure positive outcomes are maximised and adverse impacts on equalities groups are either avoided or minimised and where feasible mitigated.

3.2.6 In addition to promoting equality, an effective EqIA assists in achieving a more cohesive relationship and increased transparency between scheme designers and users. It ensures that equalities are at the heart of scheme development, contributing to better safety, security and health, as well as promoting greater equality of opportunity and assisting in improving quality of life for residents and communities.

3.3 Equalities impact assessment for the project

3.3.1 Consideration of equalities was important in the development of the project. It informed the selection of sites and the approach to the construction and operation of the project. The EqIA was an interactive process and developed throughout the pre-application phase. It sought to ensure that the needs of all the equalities groups were considered in the way the project was designed . Further information on the purpose and role of the EqIA in the development of the project is set out in Section 5.

3.4 Structure of this document

3.4.1 This document is structured as follows:

a. Section 4 EqIA background: This section provides an overview of the key policy documents that shaped the EqIA.

b. Section 5 Project approach to equalities: This section describes how equalities were considered at each stage of the projects development.

c. Section 6 Methodology: This section describes the methodology followed for the EqIA.

3 Introduction


d. Section 7 Scoping and defining the EqIA: This section outlines the background to the identification of geographical areas likely to be affected by the project in equalities terms.

e. Section 8 EqIA information gathering: This section details the literature examined in the EqIA and discusses the data sources used for the assessment.

f. Section 9 EqIA assessment and action planning: This section presents the site-specific EqIAs for each of the 24 sites.

g. Section 10 EqIA conclusions and review: This section presents the overall conclusions of the assessment and discusses the monitoring of equalities impacts.

3 Introduction


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4 EqIA background


4 EqIA background

4.1 Introduction

4.1.1 In preparing the EqIA and throughout the development of the project, the requirements of the NPS were considered alongside a number of other national and regional policy documents. These documents sustained the objectives and aspirations embedded in the EqIA and were used to inform and guide planning and development of the Thames Tideway Tunnel project. This section provides an overview of the key policy documents utilised in the EqIA.

4.2 National policy

National Policy Statement for Waste Water

4.2.1 The NPS, sets out government policy for the provision of major wastewater infrastructure, and provides the framework for examining and considering NSIP applications for development consent.

4.2.2 The NPS was subject to an EqIA which is one of a series of documents that also includes the Appraisal of Sustainability: National Policy Statement for Waste Water6 (AoS Report), which has an equality objective to encourage equality and sustainable communities.

4.2.3 The equality topic within the AoS Report states the NPS aims to mitigate the potential effects of large scale waste water infrastructure development upon different sections of society (including the more disadvantaged).

4.2.4 The AoS Report stipulates the need for developers of NSIPs to undertake an EqIA. This process consists of two phases; an initial EqIA to determine any potential adverse or differential impacts of the scheme and a full EqIA if necessary.

4.2.5 The NPS states that EqIAs for NSIP applications for development consent should identify which impacts would have an adverse, differential or positive impact on particular equalities groups including:

a. a description of the existing demographics of the area surrounding the development in order to show whether a disproportionate number of a particular equalities group will be affected by the generic impacts e.g. air emissions, other emissions, flood risk, noise, visual impacts, land use etc. (para. 4.15.8)

b. a description of the potential equalities impacts on people who live, work or own businesses in the surrounding area who may be displaced as a result of the development (para. 4.15.9)

c. a description of the indirect equalities impacts of a loss of goods or services as a result of displacement (para. 4.15.9).

6 http://archive.defra.gov.uk/corporate/consult/waste-water/101116-wastewaterpolicy-condoc-annex3b.pdf

4 EqIA background


4.2.6 The EqIA undertaken for the project has been prepared in accordance with this guidance and equalities considered throughout each phase of the proposed project.

Equality Act 2010

4.2.7 The Equality Act 2010 brings together a number of previously separate Acts and regulations, including those pertaining to race and disability. The 2010 Act extends the equalities groups for consideration to encompass age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.

4.2.8 The Public Sector Equality Duty (PSED) established under the 2010 Act, identifies the need for organisations and service providers to publish data and assess the equalities impact of a scheme or policy. On that basis, EqIAs should be included in planning and development applications and Thames Water has adhered to the PSED.

4.2.9 The 2010 Act was taken into account in developing the approach to the EqIA and in identifying equalities issues (Section 7) and groups for consideration in the assessment.

4.3 Regional policy

Equal Life Chances for All

4.3.1 The Equal Life Chances for All (April 2009) paper from the Greater London Authority (GLA) adopted a new definition of equality, which promotes equal and real freedom, and the opportunity to live in a way that people value and choose. It states that: an equal society recognises peoples different needs, situations and goals and removes the barriers that limit what people can do and be.

4.3.2 As a result, the Mayor of London encouraged London partners to deliver clear equality outcomes including:

a. ensure the capitals diverse communities, particularly the most vulnerable and disadvantaged, benefit from Londons success

b. ensure we communicate and engage with all of Londons communities so we understand and respond to the different needs of all Londoners.

4.3.3 In order to achieve these outcomes, Thames Water considered a number of measurable and desirable outcomes in developing the EqIA, including:

a. support deprived communities and vulnerable people and promote community cohesion which includes:

i inclusive engagement with excluded communities

ii increase the percentage of Londoners who see Londons diversity as a positive aspect of living in the capital

b. increase the levels of employment of excluded groups

c. spread equality through business and procurement

4 EqIA background


d. better quality of life and health

e. accessible affordable and safer transport, including:

i safer travel in London

ii safer travel at night, particularly for women

f. people feel safer whenever they are in London, including objectives to:

i increase reporting of hate crimes

ii increase the percentage of people who feel safe whenever and wherever they are in London.

4.3.4 In February 2012, a revised Equal Life Chances Measures Framework was developed to align the GLAs approach with the 2010 Act. A series of measurable objectives were also published, in order to achieve the outcomes listed above.

4.3.5 The Equal Life Chances for All policy was considered in the formation of the EqIA, particularly in developing equalities issues for consideration in the assessment (Section 7) and associated mitigation measures. Compliance with the Mayor of Londons strategy on equality was also sought in the development of the EqIA.

The London Plan

4.3.6 The London Plan is the overall strategic plan for London. It sets out an integrated economic, environmental, transport and social framework for the development of London over the next 20 to 25 years. The plan contains a number of policies utilised within the project and the EqIA, including:

a. Policy 3.1 Ensuring Equal Life Chances for All: aims to tackle inequality across London and states that social infrastructure should be protected and enhanced in planning decisions. Schemes that do not meet this objective would be resisted.

b. Policy 3.16 Protection and enhancement of social infrastructure: aims to meet the needs of a growing and diverse population by protecting social infrastructure and making it accessible to all sections of the community (including disabled and older people).

c. Policy 7.1 Building Londons Neighbourhoods and Communities: stipulates that: Development should enable people to live healthy, active lives; should maximize the opportunity for community diversity, inclusion and cohesion; and should contribute to peoples sense of place, safety and security.

d. Policy 7.2 An inclusive environment: seeks to achieve the highest standards of accessible and inclusive design in order to ensure that facilities can be accessed and used safely, easily and with dignity by all regardless of disability, age, gender, ethnicity or economic circumstances.

4 EqIA background


4.3.7 The EqIA had regard to The London Plan in identifying equalities issues for consideration in the assessment and associated mitigation measures, to ensure compliance with the London development framework.

Other guidance

4.3.8 In addition to the above policies, Thames Water referred to a number of other data sources in developing the EqIA, including:

a. local government guidance on the 2010 Act and EqIAs7

b. Equalities and Human Rights Commission guidance on the PSED8

c. examination of EqIAs for NSIPs to identify best practice

d. equalities procedures or EqIAs from each of the relevant local authorities to gather information on the equalities groups considered and approaches followed in the areas where the project is proposed.

4.4 Summary

4.4.1 The development of the EqIA had regard to the requirements of the NPS as well as a number of other policies and strategies. These highlighted issues for consideration as part of the assessment and included the need to consider the most vulnerable and disadvantaged communities, maintain and enhance social infrastructure, provide an inclusive and accessible environment, maintain and improve safety, as well as enhance neighbourhoods and communities.

4.4.2 Identification and consideration of these issues, coupled with the overarching aim of ensuring equality for all, illustrate Thames Waters commitment to ensuring that equalities groups would not be unfairly disadvantaged as a result of the proposed project. The enhancement of services, environments and facilities for local residents and communities would be undertaken where possible.

7 http://www.idea.gov.uk/idk/core/page.do?pageId=5145524 and

http://www.idea.gov.uk/idk/core/page.do?pageId=8017247 8 http://www.equalityhumanrights.com/advice-and-guidance/public-sector-equality-duty/

http://www.idea.gov.uk/idk/core/page.do?pageId=5145524http://www.idea.gov.uk/idk/core/page.do?pageId=8017247http://www.equalityhumanrights.com/advice-and-guidance/public-sector-equality-duty/

5 Project approach to equalities



5.1 Introduction

5.1.1 This section describes how equalities formed a key consideration throughout the development of the project, including site selection and assessment, public consultation and communication, design and construction practices and policies.

5.2 Site selection and assessment

5.2.1 The potential for the proposed sites to disproportionately impact on equalities groups were considered and assessed, initially at a high level during the site selection process.

5.2.2 The multidisciplinary site selection process involved representatives of the engineering, planning, environment, community and property disciplines. The disciplines assessed the potential sites in increasing levels of detail, progressing through three separate stages of site selection. to the final list of 24 proposed sites.

5.2.3 The disciplines employed technical knowledge and professional judgement to evaluate sites, based on relevant information available at the time of the short listing. While all five disciplines were relevant to the EqIA, the most pertinent assessments regarding consideration of equalities were:

a. Environment assessments which addressed:

i transport

ii built heritage and townscape

iii air quality

iv noise.

b. Socio-economic and community assessments which addressed:

i proximity to sensitive receptors

ii social considerations

iii health considerations

iv equality considerations.

5.2.4 Equalities groups and the potential for proposed worksites to disproportionately impact on disadvantaged groups were considered at the three separate stages of the site selection process; long list to draft shortlist, draft shortlist to final shortlist and the final shortlist to the site suitability reports.



Draft shortlist

5.2.5 The draft shortlist assessment (undertaken as part of the initial site selection process) included identification of the existing or designated use of potential sites and neighbouring land uses. Thames Water recorded the presence of residential properties and community facilities such as places of worship, health and educational facilities, public open space and recreation and leisure facilities.

5.2.6 For this initial high-level assessment, the presence of these types of facilities on or near the proposed sites was used as an initial guide to determine the likely impact on sections of the local community. This was then used to determine whether or not a site should pass to the next level of assessment.

Final shortlist

5.2.7 Equalities impacts were specifically included as one of five criteria considered within the community disciplines final shortlist assessment, as follows:

a. proximity to sensitive receptors: the potential for the use of a site to impact on sensitive receptors

b. social considerations: the potential for the use of a site to impact on community cohesion9

c. economic considerations: the potential for the use of a site to impact on the local economy

d. health considerations: the potential for the use of a site to impact on the health and well-being of the local community

e. equalities considerations: the potential for the use of a site to disproportionately impact on any equalities group.

5.2.8 Evaluation of the equalities considerations focussed specifically on the potential for the use of a site to impact on facilities intended for women, young people, older people, disabled people, ethnic minorities, faith groups, and lesbian, gay, bi-sexual and transgender people. Facilities related to residential care or counselling were also identified.

5.2.9 Where facilities intended for any of the above groups were present (adjacent to or opposite a proposed site), this consideration was taken into account in the overall assessment of the potential sites. The sites were then classified as least suitable/least desirable, possible or most suitable/most desirable from a community impacts perspective.

Site suitability reports

5.2.10 Within the site suitability reports, the five disciplines assessed the shortlisted sites in further detail. The community assessment included a high-level review of the socio-economic indicators in the area surrounding the proposed sites.

9 The notion of community cohesion was derived from the vision of the Institute of Community Cohesion

(http://www.cohesioninstitute.org.uk/AboutUs/OurAims)



5.2.11 This review was based on Census 2001 data and designed to provide an overview of the socio-economic composition of the area surrounding the proposed sites. Understanding an areas composition enabled the community discipline to further determine where the use of a site could disproportionately impact on specific sectors of the local community, including equalities groups. The results of this review were then considered in the assessment of the sites overall suitability.

Community audit

5.2.12 Prior to the start of phase one consultation, Thames Water undertook a community audit in order to identify community groups and facilities in the area surrounding the proposed sites. The community audits identified community organisations based near or operating in the vicinity of the proposed worksites. This identified potentially interested parties who would not otherwise appear on statutory consultee lists to involve in the consultation. This included the following:

a. local strategic partnership

b. BAME groups

c. faith groups

d. local interest groups

e. residents associations

f. regeneration partnerships

g. education institutions

h. other potentially relevant groups and services.

5.2.13 The community audits were updated throughout the pre-application process to ensure any changes were appropriately captured.

5.2.14 While the audit did not specifically consider potential impacts on equalities groups, it helped to further identify community groups and facilities in the vicinity of the sites. This deepened the community disciplines understanding of the potential for the use of a site to impact on the local community, including disadvantaged groups.

5.3 Project practices and policies

Sustainability Statement

5.3.1 A Sustainability Statement was prepared for the application. It explains how Thames Water has taken into account, and will continue to work towards, a range of social, economic and environmental objectives. Furthermore, it highlights how the main tunnel presents significant opportunities to enhance water quality within the tidal Thames and deliver long-term legacy benefits for Londons environment and communities, as part of the London Tideway Improvements. The statement also indicates that such benefits would only be realised through significant construction work, during which has the potential to cause disruption to local communities, and impact on equalities groups could occur.



5.3.2 In recognition of this, Thames Water identified a series of objectives in the Sustainability Statement, one of which was to encourage equality and sustainable communities. The Sustainability Statement draws on various project documents, including the EqIA, to demonstrate how this objective would be achieved.

5.3.3 A number of other objectives set out in the Sustainability Statement that relate to the EqIA, include:

a. Ensuring the health and safety and support the well-being of the communities in which the project operates.

b. Promoting a strong and stable economy (through the creation of jobs during construction and the legacy effect of the project as detailed in the strategic and economic case report10).

c. Minimising significant adverse effects relating to air quality, odour, noise and vibration and lighting from the construction and operation of the Thames Tideway Tunnel.

d. Minimise waste arisings and its impact on the environment and communities, and promote re-use, recovery, recycling and beneficial use.

5.3.4 The Sustainability Statement demonstrates how impacts relating to equalities and sustainable communities are addressed by means of a range of activities focused on developing skills (particularly in the most affected local authorities), securing economic activity through local recruitment and promoting health by improving access to amenity.

Code of Construction Practice

5.3.5 The Code of Construction Practice (CoCP) sets out mitigation and control measures for application throughout the proposed construction period in order to:

a. adhere to the environmental standards and procedures for managing and mitigating the impact of site activities during construction

b. maintain satisfactory levels of environmental protection

c. limit disturbance from construction activities and assure stakeholders that all construction impacts would be managed appropriately.

5.3.6 The mitigation and control measures include construction management and practices, and embedded design solutions to minimise or eliminate significant effects arising from construction.

5.3.7 The CoCP sets out working practices for all aspects of construction, from site operations to the management of potential environmental effects. Equalities groups, as outlined in Section 3.2, are critical to a number of these practices, namely:

a. communications and community/stakeholder liaison

10

http://www.thamestunnelconsultation.co.uk/doclib/02-creating-a-river-thames-fit-for-our-future/?came_from=411, Summary: http://www.thamestunnelconsultation.co.uk/doclib/02-creating-a-river-thames-fit-for-our-future/?came_from=411

http://www.thamestunnelconsultation.co.uk/doclib/02-creating-a-river-thames-fit-for-our-future/?came_from=411http://www.thamestunnelconsultation.co.uk/doclib/02-creating-a-river-thames-fit-for-our-future/?came_from=411http://www.thamestunnelconsultation.co.uk/doclib/02-creating-a-river-thames-fit-for-our-future/?came_from=411http://www.thamestunnelconsultation.co.uk/doclib/02-creating-a-river-thames-fit-for-our-future/?came_from=411



b. general site operations

c. public access, the highway and river transport

d. noise and vibration

e. third-party infrastructure.

5.3.8 The CoCP consists of two separate volumes: Part A: General requirements, and Part B: Site specific requirements, which details site-specific construction practices in view of the local circumstances. The CoCP was developed in consultation with relevant consultees, including local planning authorities.

5.3.9 Following the application for development consent, we have continued to develop and refine our mitigation for reducing impacts at all our sites. A number of additional on-site mitigation measures have been developed which will be secured through the CoCP. The Summary of Further On-Site Mitigation Measures and Revisions to Compensation Policies (Doc Ref: APP67) provides an overview of the additional mitigation proposed.

Design principles

5.3.10 The design principles for the Thames Tideway Tunnel project were developed to ensure a consistent approach to the design of the permanent structures and spaces. The principles that apply to the permanent structures and the operational phase are set out in the Design Principles document, which is submitted as part of the DCO application.

5.3.11 The design principles seek to ensure that site designs are high quality, provide value and respect each sites individual location and setting. In addition to maintaining safety, functional, environmental and access requirements, the principles seek to ensure that any new open spaces created would positively enhance the environment and create a lasting legacy.

5.3.12 The principles incorporate a series of high-level design objectives that have regard to equalities, including:

a. respecting and contributing positively to each sites individual context and surroundings

b. reducing the impacts of operations on local communities, the environment and third party interests as much as possible

c. listening to and working with stakeholders, being open to new ideas and identifying areas of mutual interest with others

d. ensuring that the principles of sustainability are integral to designs by incorporating environmental solutions and environmental mitigation

e. where opportunities arise, we shall seek to create new, high quality, public spaces and enhance habitats and biodiversity

f. providing safe sites for operations staff and (where relevant) the public that are accessible to all

g. reinstating and extending the Thames Path where practicable.



5.3.13 More specifically, a number of the generic (project-wide) design principles ensured equal access for all, including:

a. Landscape design principles to ensure that public realm is designed for safety and accessibility, including:

i keeping gradients as shallow as possible

ii providing a step-free alternative to any external stairs wherever possible

iii where external stairs are provided, a step-free alternative shall also be provided flights would also be uniform in order to avoid confusion

iv designing stairs to help visually-impaired people appreciate the extent of the stair and identify individual treads

v ensuring that stairs are accessible to disabled people and wide enough to accommodate walking aids, such as frames

vi providing walkways of adequate width to enable two wheelchair users, mobility scooters or double buggies to pass comfortably

vii maintaining clear lines of sight throughout pedestrian environments in order to maximise accessibility, reduce visual confusion, and reduce dependence on signage and auditory information

viii selecting materials for safety and accessibility. Footway surfaces would be firm, level and slip-resistant. Where paving is provided, larger sets/slabs would be used where practicable to minimise the risk of trapping wheels or other walking aids.

b. Lighting strategies including:

i avoiding dark patches and high light/dark contrasts that can impair visibility

ii reducing the risk of accidents and helping to prevent crime and the fear of crime.

5.3.14 The Design Principles document also sets out a series of site-specific contextual principles for each of the 24 sites that are unique to each site or which elaborate further on the generic principles.

Skills and Employment Strategy

5.3.15 Objective 3 of the Strategy relates to the promotion of opportunities for local people and disadvantaged groups and requires Contractors to use reasonable endeavours to maximise the diversity of their workforce. To improve employment opportunities for disabled people, key tunnel drive site offices should be compliant with Disability and Discrimination Act (DDA) requirements, as a minimum in ground floor areas (paragraph 9.4.22).



5.4 Approach to consultation

5.4.1 Public consultation and engagement has played a vital role in the development of the project. The overriding aim of the public consultation process was to ensure that all interested or potentially affected parties had the chance to understand and influence Thames Waters proposals.

5.4.2 Thames Waters Community consultation strategy11 and Statement of Community Consultation12 (SoCC) were published in 2010. These documents outlined Thames Waters intention to consult the public, communities, land owners, local authorities and stakeholders on its proposals. Thames Water also sought to adhere to government guidance and ensure an equal and accessible process.

5.4.3 The consultation approach included:

a. Publicity, comprising:

i Regional and local press: the SOCC was published in the London Evening Standard free newspaper and exhibition dates were publicised in local newspapers.

ii Letters and leaflets: a letter providing details of public exhibitions in the vicinity, plus detailed leaflets on the background of the project and a language translation sheet (with information on the language line service) were distributed to community consultees, land owners, statutory consultees and local authorities.

iii Notices and leaflets: site notices (containing a map, a description of the proposals and information on the language line) and project leaflets (on the background of the project, details of public exhibitions in the vicinity and a language translation sheet) were distributed to all properties within 250m of each site in advance of local exhibitions.

iv Website: a dedicated consultation website was created to provide information on the project and to obtain feedback. Paper feedback forms were also made available on the website.

b. Public meetings were held and briefings given to local authorities and community representatives to facilitate a shared understanding of the project and to ensure representatives had suitable information to pass to members of their community as required.

c. Technical and non-technical written information was made available online, at public exhibitions, local libraries, town halls and on request, to maximise accessibility. This included information on the processes undertaken to develop the project, site information papers and various project topics such as build, odour, air quality and construction.

d. Public exhibitions were held by the project team (as relevant during the stages of consultation and interim engagement) in the vicinity of each site over a period of three consecutive days and evenings, to

11

http://www.thamestunnelconsultation.co.uk/doclib/community-consultation-strategy-2/?came_from=411 12

http://www.thamestunnelconsultation.co.uk/doclib/statement-of-community-consultation-2/?came_from=411

http://www.thamestunnelconsultation.co.uk/doclib/community-consultation-strategy-2/?came_from=411http://www.thamestunnelconsultation.co.uk/doclib/statement-of-community-consultation-2/?came_from=411



allow interested parties to ask Thames Water questions on the project and seek assistance with interpreting materials or completing feedback forms.

e. Responses were provided to requests for information including written queries and phone calls.

5.4.4 Thames Waters approach to consultation was developed through liaison with local authorities across Greater London to identify the best approach to community engagement within each local authority.

5.4.5 Thames Water considered equalities groups at each stage of consultation. The methods employed to promote equality in this process included:

a. Using accessible venues for public exhibitions to enable access for all. The locations were based on physical access to the building, proximity to the relevant site, proximity to local transport routes, availability of toilets, health and safety compliance, level access and security.

b. Providing advertisements and written materials in a range of media to maximise access to information. This included displaying information and advertisements around the sites, posting written information/advertisements in regional and local newspapers, providing materials online, and distributing materials to households, businesses, landowners and stakeholders.

c. Providing an equalities questionnaire with consultation materials in order to monitor representation of equalities groups.

d. Providing details of translation services with publicity and printed materials (via Language Line) to enable access to information in a variety of languages (where agreed with the local authority). For example, translation services were offered on site notices, multi-language forms were included in letter drops and materials were provided for inclusion in local East London papers (information on the approach to translation at phase two consultation is provided in Appendix B).

e. Providing written information in large print, Braille or audio format on request, in order to ensure accessibility for all equalities groups (ie. disabled groups).

f. Using interpreters at exhibitions to ensure that those whose first language is not English could participate in the consultation13.

5.4.6 Further information on Thames Waters consultation process is provided in the Final report on consultation.

13

Provision of translations of project materials and use of interpreters at exhibition venues was implemented according to Guidance for Local Authorities on Translation of Publications (http://www.communities.gov.uk/publications/communities/translationguidance). Language Line and additional translators were used as the Guidance for Local Authorities on Translation for Publications explicitly states that the automatic translation of documents into different languages can undermine the importance of English as a way of enabling all citizens to communicate and relate to each other. It states that automatic translation should be rejected in favour of a more selective approach.

http://www.communities.gov.uk/publications/communities/translationguidance



Equalities issues raised regarding consultation

An application for judicial review was proposed by a resident in relation to the use of the Kings Stairs Gardens, which included equalities related concerns on the consultation process, following the end of phase one consultation, details of which are set out below. No other significant equalities issues were highlighted at phase one or targeted consultation. During phase two consultation, a number of issues were raised at public exhibitions, in written and verbal form in relation to equalities and how they relate to the consultation process. Table 5.1 sets out the issues raised and Thames Waters response.

Proposed application for judicial review

5.4.7 Following a letter received from a resident near Kings Stairs Gardens, the preferred main tunnel site at the phase one pre-application consultation stage, a letter before claim was submitted to Thames Water advising of the details for a proposed claim for judicial review against Thames Water. The grounds for this proposed claim concerning the pre-application consultation process included an alleged non-compliance with equalities duties in respect of section 49A of the Disability Discrimination Act 1995 and section 76A of the Sex Discrimination Act 1975. The alleged non-compliance was not specified except for the following example provided in the letter before claim:

5.4.8 no equality impact assessment has been provided as part of this consultation exercise, nor any other information to suggest that the equality duties have been applied to Thames Waters decision making up to this point. If this is correct, the decision-making process and consultation up to this point has not been lawful.

5.4.9 Thames Water responded to the letter before claim and set out the reasons why it did not agree that there were any grounds for a judicial review. The residents legal representative confirms in writing that a review of the phase one consultation (pre-application) was not appropriate subject to further consultation on the Chambers Wharf and Kings Stairs Gardens sites. No further claims were made following the subsequent interim engagement held in relation to the Chambers Wharf site as a possible alternative to Kings Stairs Gardens or the subsequent phase two consultation. However, concerns remained in relation to Thames Waters disability and gender duties in this consultation. Thames Water suggested that this would be addressed by an equalities impact assessment that would consider potential impacts on disabled people (including the mobility impaired) and women (including the impact on children and their parents). This assessment considered both of these categories of equality groups in relation to the proposed Chambers Wharf site as required by the NPS (paras. 4.15.6, 4.15.7 and 4.15.9).

5 P

roje

ct a

pp

roa

ch

to e

qu

alit

ies

Equalit

ies Im

pact A

ssessm

ent

26

Tab

le 5

.1 E

qu

ali

tie

s is

su

es r

ais

ed

at

ph

ase

tw

o c

on

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ltati

on

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hem

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mm

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5.4

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Tow

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lets

C

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of

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Tra

nsla

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serv

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Lack o

f appro

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tra

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sourc

es (

paper/

tele

pho

ne

-based a

nd

inte

rpre

ters

at

exhib

itio

ns)

and lack

of

consultation

with M

uslim

faith

gro

ups in T

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lets

.

Prior

to c

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ur

appro

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phase o

f consu

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n w

ith t

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directly a

ffecte

d local

auth

orities. T

his

inclu

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. T

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appro

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consu

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inclu

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to t

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or

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tra

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Regard

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e p

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as

consid

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n a

ccepta

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pote

ntia

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irectly a

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d local

auth

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In a

dditio

n to t

he S

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we

pub

lish

ed p

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ases in loca

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5.4

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Lond

on

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wis

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Lack o

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litie

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assessm

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It d

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that

an E

qu

alit

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lysis

Assessm

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AA

) has

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tw

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nd w

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ll our

activitie

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com

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with t

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qu

alit

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0,

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to e

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ent

of

all

mem

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ty,

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f ag

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reassig

nm

ent,

5 P

roje

ct a

pp

roa

ch

to e

qu

alit

ies

Equalit

ies Im

pact A

ssessm

ent

27

R

esp

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t T

hem

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e

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ate

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at ph

ase

two

consulta

tio

n

consulta

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AA

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involv

es s

yste

matically

ana

lysin

g a

pro

pose

d o

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olic

y o

r str

ate

gy t

o ide

ntify

wha

t eff

ect, o

r lik

ely

eff

ect, w

ill f

ollo

w f

rom

the

imple

menta

tion o

f th

e p

olic

y f

or

diffe

rent gro

ups in t

he c

om

munity.

The a

ssessm

ent seeks to e

nsure

, as

far

as p

ossib

le, th

at a

ny n

egative

conseque

nces f

or

a p

art

icula

r gro

up

or

secto

r of

the c

om

munity a

re

elim

inate

d, m

inim

ised o

r co

unte

r-bala

nced b

y o

ther

measure

s. T

he

council

consid

ers

that

an E

AA

should

be

un

dert

aken f

or

this

pro

ject.

marr

iage a

nd c

ivil

part

ners

hip

, ra

ce, re

ligio

n o

r b

elie

f, s

ex, and s

exu

al

orienta

tion.

We h

ave u

nde

rtake

n this

EqIA

in o

rder

to ide

ntify

pote

ntial

advers

e, d

iffe

rential or

positiv

e im

pacts

on e

qua

litie

s g

roups,

as p

art

of

our

DC

O a

pp

lica

tio

n,

in a

ccord

ance w

ith t

he N

PS

. W

e c

are

fully

consid

ere

d o

ur

appro

ach to c

onsultation f

ollo

win

g t

he a

dvic

e in

DC

LG

Guid

ance for

Loca

l A

uth

orities o

n T

ransla

tion f

or

Pu

blic

ations. A

ccord

ingly

a tra

nsla

tio

n leaflet

was inclu

de

d w

ith t

he a

ppro

xim

ate

172,1

62 c

onsultation letters

th

at

were

sent ou

t at th

e s

tart

of

phase t

wo c

onsultation a

nd a

te

lepho

ne lan

gu

age

line w

as m

ade a

va

ilable

to

pro

vid

e a

ssis

tance w

here

requ

ired. In

add

itio

n,

in a

gre

em

ent

with local auth

orities, la

ngua

ge info

rmation w

as inclu

de

d o

n

site n

otices. W

e b

elie

ve

the

refo

re that o

ur

ap

pro

ach w

as c

onsis

tent

with

equa

litie

s leg

isla

tion.

5.4

.12

Lond

on

Boro

ugh o

f T

ow

er

Ham

lets

Letter

dro

ps

At p

hase o

ne c

onsultation

a n

um

ber

of

peop

le local to

Kin

g E

dw

ard

M

em

orial P

ark

and w

ithin

the

consulta

tio

n b

oun

dary

com

mente

d

that th

ey h

ad n

ot re

ce

ived a

le

tter.

T

he c

ouncil

ca

nno

t ju

dg

e h

ow

successfu

l th

is e

lem

ent of

the p

hase

two c

onsu

ltatio

n h

as b

ee

n.

We s

ought to

notify

the

pu

blic

of

the

consultation in g

ood t

ime a

nd in

accord

ance w

ith s

tatu

tory

requ

irem

ents

and g

overn

ment gu

idance

concern

ing p

re-a

pp

licatio

n c

onsulta

tio

n.

Prior

to c

om

mencin

g p

hase t

wo

consulta

tio

n, 1

29,5

15 le

tters

were

sent

out

acro

ss th

e c

onsulta

tio

n a

rea

, w

hic

h inclu

de

d r

esid

ents

within

at

least

250m

of

the b

oundary

of

each

site

and w

ith

in a

bro

ad c

orr

idor

alo

ng t

he r

oute

of

the m

ain

tunn

el. T

he

boun

dary

was a

pp

lied f

lexib

ly a

ccord

ing t

o th

e s

cale

and n

atu

re o

f th

e

pro

pose

d w

ork

s, and t

ook a

ccount

of

the c

hara

cte

ristics o

f th

e s

urr

ound

ing

are

a. T

he letter

set

out

wh

at exhib

itio

ns w

ere

bein

g h

eld

, w

here

an

d w

hen.

We a

lso d

eliv

ere

d le

aflets

settin

g o

ut d

eta

ils o

f our

exhib

itio

ns t

o a

ll le

tterb

oxes c

lose

to t

he e

xh

ibitio

n v

en

ues, so t

hat

occupie

rs w

ere

aw

are

of

our

pro

posals

and w

here

to

obta

in f

urt

her

info

rmation o

n o

ur

pro

posa

ls.

5.4

.13

Lond

on

Boro

ugh o

f T

ow

er

Ham

lets

Tra

nsla

tion

serv

ices

Pro

vis

ion o

f tr

ansla

tion w

as v

ery

poor.

Inte

rpre

tation s

hould

be o

ffere

d a

nd

advert

ise

d a

t dro

p-i

n s

essio

ns. T

he

two m

ain

com

munity lang

uages in

Tow

er

Ham

lets

are

Ben

ga

li and

See r

esponse in p

ara

. 5.4

.10.

5 P

roje

ct a

pp

roa

ch

to e

qu

alit

ies

Equalit

ies Im

pact A

ssessm

ent

28

R

esp

on

den

t T

hem

e

Su

mm

ary

of

issu

e

Th

am

es W

ate

r re

sp

on

se

Som

ali.

It

wou

ld b

e p

rude

nt

to

pro

vid

e t

he d

istr

ibutio

n lette

r in

th

ese

lan

gua

ges a

lso.

5.4

.14

Lond

on

Boro

ugh o

f T

ow

er

Ham

lets

Lang

uag

e

barr

iers

for

the B

en

ga

li com

munity

There

are

man

y r

esid

ents

fro

m the

Ben

ga

li com

munity w

ho a

re u

nable

to

contr

ibute

due t

o lang

ua

ge

barr

iers

; th

is a

rea

ma

y h

ave b

een

sele

cte

d a

s a

n e

asy targ

et.

We h

ave n

ot se

lecte

d th

is s

ite d

ue t

o a

perc

eiv

ed ina

bili

ty o

f lo

ca

l re

sid

ents

to

en

gag

e w

ith t

he p

rocess. W

e a

re c

om

mitte

d to u

nd

ert

akin

g a

n inclu

siv

e

consulta

tio

n. T

o th

is e

nd

, w

e t

ook s

teps to e

nsure

that

peop

le w

hose f

irst

lan

gua

ge is n

ot

En

glis

h w

ere

fully

able

to p

art

icip

ate

.

At th

e s

tart

of

ph

ase t

wo c

onsulta

tio

n w

e p

ublis

hed

our

SoC

C in

the

Lo

ndo

n

Evenin

g S

tandard

. T

he S

oC

C s

et o

ut o

ur

ap

pro

ach t

o c

onsultation inclu

din

g

the f

act th

at

a lan

gua

ge lin

e s

erv

ice

was a

va

ilab

le. W

e c

onsid

er

that o

ur

appro

ach w

as c

onsis

tent

with e

qua

litie

Application Reference Number: WWO10001 Examining … · 2016-05-05 · 2.7 Above-ground permanent...

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