EqIA - 'Be Seen' Energy Monitoring

Key information

Publication type: London Plan Guidance

Publication status: Draft

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1. Equality Impact Assessment (EqIA) for London Plan Guidance

London Plan Guidance:

‘Be Seen’ energy monitoring guidance – draft for consultation

October 2020

Please provide an outline of the guidance, who it is aimed at and any key issues to be aware of.

Draft London Plan Policy SI 2 Minimising greenhouse gas emissions sets out the ‘be seen’ requirement for all major development proposals to monitor and report on their actual operational energy performance. The ‘be seen’ policy will help in understanding the performance gap (i.e. the gap between the predicted energy use at design stage and actual energy use in operation) and identify ways of closing it while ensuring compliance with London’s net zero-carbon target.

The document explains the process that needs to be followed to comply with the post construction monitoring requirement of draft London Plan Policy SI 2 i.e. the ‘be seen’ element of the energy hierarchy. It is aimed at those involved in the planning, design, construction, delivery and operation of new major development.

It sets out what each responsible party needs to do to comply with the policy from the inception stage of a development to full occupancy. It provides information on the ‘be seen’ monitoring portal and explains how and when to report to the GLA.

Which of the Public Sector Equality Duty aims are relevant to the guidance and the impacts identified?

2) Advance equality of opportunity between people who share a protected characteristic and those who do not, in particular having due regard to the need to:

b) Take steps to meet the needs of people with certain protected characteristics where these are different from the needs of other people.

1.1 Assessment

List aspects of the guidance that might affect particular groups

Guidance key aspects, chapter headings, theme etc	Particular group that could be affected
In-use stage: process and requirements	Women, BAME, low-income, disabled, younger people.

* it should be noted that the general policy requirement and principles are already required through the London Plan. This London Plan Guidance is providing further detail on how the policies should be implemented, and therefore further amplifying the effects

Equality impacts, mitigating actions and justification (where applicable)

Group	Potential impact description What positive and negative impacts have been identified (known and potential) for particular groups? Refer to evidence (including engagement).	Relevant PSED aim (1, 2a, b or c, and/or 3)	Actions identified and/or justification For negative impacts, set out mitigating actions to minimise or eliminate negative impacts and any action plan. If negative impacts cannot be mitigated, provide objective justification. For positive impacts, consider how these could be maximised.
Age	Positive The guidance focuses on gathering information on the energy performance for buildings. Ultimately the aim is to help close the performance gap and ensure buildings meet policy requirements. In the medium-long term the guidance will provide a source of data to inform future policy which can help to ensure that energy use and associated bills are as expected and affordable for occupiers. This may be positive for younger households who are more likely to be fuel poor – however given the focus of the guidance is on gathering information no measurable impact can be attributed from the guidance itself. Equalities impacts will continue to be reviewed as part of the development of any future policy connected to the information gathered through implementation of the guidance.	2b	The guidance encourages the identification of remediation measures to improve energy performance where buildings are not performing as expected. The data provided through implementation of the guidance will inform further action that can be taken in future policy
Age	Negative No anticipated impacts
Disability	Positive The guidance focuses on gathering information on the energy performance for buildings. Ultimately the aim is to help close the performance gap and ensure buildings meet policy requirements. In the medium-long term the guidance will provide a source of data to inform future policy which can help to ensure that energy use and associated bills are as expected and affordable for occupiers. This may be positive for households with disabled people who often experience higher energy costs, however given the focus of the guidance is on gathering information no measurable impact can be attributed from the guidance. Equalities impacts will continue to be reviewed as part of the development of any future policy connected to the information gathered through implementation of the guidance.	2b	The guidance encourages the identification of remediation measures to improve energy performance where buildings are not performing as expected. The data provided through implementation of the guidance will inform further action that can be taken in future policy
Disability	Negative No anticipated impacts
Gender reassignment	Positive No anticipated impacts
Gender reassignment	Negative No anticipated impacts
Marriage and civil partnership	Positive No anticipated impacts
Marriage and civil partnership	Negative No anticipated impacts
Pregnancy and maternity	Positive No anticipated impacts
Pregnancy and maternity	Negative No anticipated impacts
Race or Ethnicity	Positive The guidance focuses on gathering information on the energy performance for buildings. Ultimately the aim is to help close the performance gap and ensure buildings meet policy requirements. In the medium-long term the guidance will provide a source of data to inform future policy which can help to ensure that energy use and associated bills are as expected and affordable for occupiers. This may be positive for BAME households who are more likely to be fuel poor – however given the focus of the guidance is on gathering information no measurable impact can be attributed at this stage. Equalities impacts will continue to be reviewed as part of the development of any future policy connected to the information gathered through implementation of the guidance.	2b	The guidance encourages the identification of remediation measures to improve energy performance where buildings are not performing as expected. The data provided through implementation of the guidance will inform further action that can be taken in future policy
Race or Ethnicity	Negative No anticipated impacts
Religion or belief	Positive No anticipated impacts
Religion or belief	Negative No anticipated impacts
Sex	Positive The guidance focuses on gathering information on the energy performance for buildings. Ultimately the aim is to help close the performance gap and ensure buildings meet policy requirements. In the medium-long term the guidance will provide a source of data to inform future policy which can help to ensure that energy use and associated bills are as expected and affordable for occupiers. This may be positive for women who make up the majority of single-parent households and are more likely to be in part-time or lower-paid work. However, given the focus of the guidance is on gathering information no measurable impact can be attributed from the guidance. Equalities impacts will continue to be reviewed as part of the development of any future policy connected to the information gathered through implementation of the guidance.	2b	The guidance encourages the identification of remediation measures to improve energy performance where buildings are not performing as expected. The data provided through implementation of the guidance will inform further action that can be taken in future policy
Sex	Negative No anticipated impacts
Sexual orientation	Positive No anticipated impacts
Sexual orientation	Negative No anticipated impacts
People on low incomes	Positive The guidance focuses on gathering information on the energy performance for buildings. Ultimately the aim is to help close the performance gap and ensure buildings meet policy requirements. The 2019 CCC report estimates closing the energy use performance gap in new homes could save between £70 and £260 in energy bills per household per year. In the medium-long term the guidance will provide a source of data to inform future policy which can help to ensure that energy use and associated bills are as expected and affordable for occupiers. This may be positive for people on low incomes, however given the focus of the guidance is on gathering information no measurable impact can be attributed from the guidance. Equalities impacts will continue to be reviewed as part of the development of any future policy connected to the information gathered through implementation of the guidance.	2b	The guidance encourages the identification of remediation measures to improve energy performance where buildings are not performing as expected. The data provided through implementation of the guidance will inform further action that can be taken in future policy
People on low incomes	Negative No anticipated impacts.

Overview of equality impacts

Using your findings from the table above, summarise the impacts for each group in the table below using the scoring listed above.

	Age	Disability	Gender reassignment	Marriage and civil partnership	Pregnancy and maternity	Race	Religion and belief	Sex	Sexual Orientation	People on low incomes
Be Seen	No anticipated impacts	No anticipated impacts	No anticipated impacts	No anticipated impacts	No anticipated impacts	No anticipated impacts	No anticipated impacts	No anticipated impacts	No anticipated impacts	No anticipated impacts

Amendments to the guidance

(only for review to the EqIA in the future)

Change	Reason for change
What changes have you made to the guidance as a result of this EqIA?	Why have these changes been made?

Recommendation

Based your assessment, please indicate which course of action you are recommending to decision makers.

Outcome Number	Description	Mark with an X
Outcome One	No major change to the guidance is required This EqIA has not identified any potential for discrimination or negative impact, and all opportunities to advance equality have been taken.	x
Outcome Two	Adjustments to the guidance are required to remove barriers identified by the EqIA or better advance equality.
Outcome Three	Justify and continue with the guidance despite having identified some potential for negative impacts or missed opportunities to advance equality.
Outcome Four	Stop, rethink or abandon when the EqIA shows actual or potential unlawful discrimination

Monitoring

Monitoring will take place through the London Plan Annual Monitoring Report and wider monitoring of the Mayor’s other strategies as well as part of reviewing the London Plan.

1.2 Appendix A: Evidence Reference and Content

London Plan IIA (including EqIA) and Addendums

Evidence

Age

Equality, diversity and inclusion evidence base for London
A household is defined as being fuel poor if it has higher than typical energy costs and the household’s income would fall below the poverty line if it paid for these costs (60 per cent of median equivalised household income).

Younger households are more likely to be fuel poor, including those households with children aged 16 or under (16-21 per cent depending on the age of youngest child), and those households where the oldest member is aged 16-24 (22 per cent). Income is likely to be an important factor driving fuel poverty in younger households as they tend to have lower incomes

In addition, lower-income households often experience a ‘poverty premium’ in energy, whereby those living below the poverty line pay more buying fuel than other households.

Disability

A household is defined as being fuel poor if it has higher than typical energy costs and the household’s income would fall below the poverty line if it paid for these costs (60 per cent of median equivalised household income).

Thirty-nine per cent of households in England living in fuel poverty include a disabled person. A third of disabled adults say their impairment or condition has a significant impact on their energy costs. Disabled people with limited mobility, for example, might have to use more heating to keep warm, whilst people using assistive technology or electrical equipment such as powered wheelchairs will use additional electricity to charge these items.

Gender reassignment