DD2048 Integrated Impact Assessments – London Environment Strategy

1.1 The Greater London Authority Act 1999 (the “Act”) requires the Mayor to produce a London Environment Strategy (LES) which must contain the following: biodiversity, municipal waste management, climate change mitigation and energy, adaptation to climate change, air quality and ambient noise.

1.2 The Mayor has indicated that he would like a newly-created LES to be drafted and adopted as soon as possible. As part of the preparation of this strategy, under both European and national legislation, the Mayor is required to undertake a number of Impact Assessments to review policy options and assess the impact of proposed strategies. Previously these assessments were independent of one another, which led to duplication of efforts and a lack of ‘coherent thinking’ around the mayoral strategies. More recently an Integrated Impact Assessment process has been proposed that combines these assessments and enables all of the mayoral strategies to work from the same baseline information.

1.3 The Mayor has legal duties to consider the following:
• Economic development and wealth creation (GLA Act 1999, as amended);
• Social development (GLA Act 1999, as amended);
• Protection and Improvement of the environment (European Directive 201/42/EC on SEA;, The Environmental Assessment of Plans and Programmes Regulations 2004, GLA Act 1999, as amended);
• Health inequality and promoting Londoners’ health (GLA Act 1999, as amended);
• Community safety (Crime and Disorder Act 1998, Police and Justice Act 2006); and
• Equality of opportunity, elimination of discrimination and the promotion of good community relations (GLA Act 1999, as amended, Equality Act 2010).

1.4 In addition, the Integrated Impact Assessment (IIA) for the LES is required to cover assessment of:
• Strategic Environmental Assessment (SEA) required in accordance with European Directive 2001/42/EC;
• Equalities Impact Assessment (EqIA) in line with GLA guidance ensuring that due regard is given to equality considerations is accordance with the requirements of the Equality Act (2010) in particular the public sector equality duty;
• Health Impact Assessment (HIA) incorporated into the IIA will ensure that the Mayor’s duty pursuant to section 30 of the Act to promote the reduction of health inequalities and have regard to the effects of his strategies on reducing health inequalities is met;
• Community Safety Impact Assessment (CSIA) in line with the Mayor’s duty pursuant to Section 17 of the Crime and Disorder Act 1998 to do all that reasonably can be done to prevent crime and disorder and for all his strategies to have due regard to the likely effect on crime; and
• Climate change and consequences.

1.5 Broadly the IIA process follows the following structure:

1.6 Approval is sought to seek tenders through a TfL Health & Safety and Environmental Services Framework (Ref: PSF-91312) to appoint a specialist consultants to contribute to the preparation of the IIAs for the London Environment Strategy and to assist with stages 2.1 – 2.3 (as above) for the LES
Transport for London (TfL) commercial team are providing assistance on this procurement and have advised the above Framework is suitable to use in this instance.

There are three distinct phases of work that we are intending to procure from the consultant(s). These are explained briefly below.

London Environment Strategy IIA development and assessment and produce the IIA report and statement

2.1 Objective: For this phase the consultant will be expected to:
• Assess the questions proposed in the scoping report for testing the draft LES against the agreed IIA objectives; [£15,000]
• test the proposed strategy and policy options against the IIA objectives that have already been identified; [£15,000] and
• undertake a detailed appraisal of the draft policies and produce an IIA report and statement. [£40,000]
2.2 Outcome: We expect the consultants to produce a written review of the policy appraisal that will confirm a preferred approach and ensure that the strategy appropriately and robustly meets or contributes to the objectives of the IIA. Full details of the requirement for this phase are provided in Annex 1.

3.1 The Integrated Impact Assessment includes an Equalities Impact Assessment which will evaluate the likely potential impacts, both positive and negative, of the Environment Strategy on those with protected characteristics (age, disability, gender, gender reassignment, pregnancy and maternity, race, religion or belief, sexual orientation).

a) key risks
4.1 If, post the public consultation on the LES, the draft strategy policies need to be amended to such an extent that there is a need for an additional IIA then the project could take up to two months longer to be completed.

b) links to Mayoral strategies and priorities

4.2 The IIA is a requirement for the preparation of the Mayor’s LES.

4.3 The Scoping Report for the IIA for the London Plan was used to form the basis of the Scoping Report for the LES. An internal GLA steering group was set up with the purpose of developing a framework which is to be applied to the IIAs for each strategy, including the LES. The framework includes a common set of IIA objectives to be used for the assessment stage of the IIAs for each strategy. The guide questions which sit underneath each of the IIA objectives will be relevant and specific for the individual strategies. The Mayor’s Transport Strategy (MTS) has already been tested against the IIA objectives and the outcomes of this testing will be used to inform the process for the other strategies.

c) impact assessments and consultations

4.4 The IIA incorporates all the relevant impact assessments and will be consulted on alongside the strategy. We have been advised by Natural England that the LES does not require a Habitats and Regulations Assessment (HRA).

5.1 Approval is sought for the expenditure of up to £70,000 and the award of the consultancy contract for the undertaking of the Integrated Impact Assessment of the Mayor’s London Environment Strategy, as outlined in this report.

5.2 The budgetary requirement for the Integrated Impact Assessments (IIA) has been set out under section 2.1 and will be met from the Statutory Strategies GM.0109.003 budget within the Governance Directorate. All appropriate budget adjustments will be made.

5.3 Any changes to the project, including budget implications will be subject to the Authority’s decision-making process.

5.4 The Statutory Strategies Unit within the Governance Directorate will be responsible for managing the proposed contract and ensuring that all expenditure complies with the Authority’s Financial Regulations and Contracts & Funding Code.

6.1 The Mayor under the Greater London Act (1999) shall prepare and publish a LES. In preparing or reviewing the strategy, the Mayor shall have regard to;
• the principal purpose of the GLA;
• the effect on the proposed strategy on the health of persons in Greater London;
• health inequalities between persons living in Greater London;
• achievement of sustainable development in the UK,
• equality of opportunity for all people
• climate change and its consequences;
• ensuring the policy is consistent with national policy and other GLA strategies;
• resources available to implement the strategy; and
• desirability of promoting and encouraging the use of the River Tames in the provision of passenger transport services.

6.2 The decisions requested of the Director falls within the GLA’s statutory powers to do such things considered to further or which are facilitative of, conductive or incidental to the promotion of economic development and wealth creation, social development or the promotion of the improvement of the environment in Greater London; and in formulating the proposals in respect of which a decision is sought officers have complied with the Authority’s related statutory duties (as outlined in 6.1) as well as consult with appropriate bodies.

6.3 Officers have indicated at paragraph 1.6 of this report that the;
• framework under which it is proposed that the services required are to be “call-off” are in accordance with relevant procurement law; and
• the services required have been procured fully in accordance with the requirements of that framework.

6.4 Officers must ensure that appropriate “call-off” documentation is put in place and executed by the successful bidder(s) and the GLA before the commencement of the services.