EqIA- Public London Charter

Encouraging spaces to be open, accessible and inclusive

• BAME people
• Disabled people
• Younger people

• Disabled people
• Older people
• Pregnant women and mothers

• Older people
• Disabled people
• LGBTQ+ people

• Transgender people
• Men
• BAME people

Positive

The Charter encourages increased access to areas of public spaces (part of the wider public realm). It also aims to make such spaces more inclusive. This could potentially make parts of the public realm and the external environment more welcoming and increase people’s likelihood to use active travel modes, which could in turn help to reduce inequalities in physical and mental health and wellbeing as the policy will help to bring forward safe, welcoming, secure and inclusive places and spaces. This is likely to have a positive impact for groups who may be more likely to experience barriers to access or inclusion- including older people, as well as groups at greater risk of poor mental health which includes young women and people aged 35-44.

1, 2b, 2c, 3

+2

Negative

Having parts of or entire public spaces closed off either temporarily or permanently for restricted use e.g. ticketed events could have a negative impact on people and groups for whom the nature of London’s built environment can either support or form barriers to participating in city life. This is particularly relevant to older people and those with pushchairs, who may face barriers in accessing many services and buildings because of how buildings, spaces and places are designed and managed.

Encouraging public spaces to be as open as possible with activities allowed as a default such as cycling and skating could have a negative impact on older people as some people within that group may have limited mobility and move at a slower pace and feel less safe if people are moving at faster speeds through the public space.

2a, 2b

Mitigation: The Charter allows for ‘safe cycling’ to keep spaces safe and mitigate potential impacts between cyclists and other users in a space. If a space is deemed inappropriate for specific activities, the charter allows for site-specific regulations to be applied to a space, informed by consultation with relevant stakeholders.

+1

Positive

Increasing Londoners’ access to areas of public realm and the requirement for areas of public realm to be inclusive, could potentially make the external environment more welcoming. The Charter is likely to have a positive impact for groups such as disabled people, as well as groups at greater risk of poor mental health including disabled adults. People in these groups may be more likely to experience physical and other potential barriers to access or inclusion such as costs associated with entry and use of a space.

1, 2a, 2b, 2c, 3

+2

Negative

Balancing the consideration of commercial events against the wider public use of a public space for certain periods of time could have a negative impact for some groups. Spaces being used for commercial events could cause an obstruction, or additional travelling distances which could be problematic for some disabled people for whom travel distances are critical, blind and partially sighted people who may have difficulties navigating around ‘events’, or people with certain neurodiverse conditions who may have difficulties navigating the changes in the route/ environment. Disabled people are more likely to be on lower incomes or unemployed than non-disabled people. This may mean access to free events is even more important for this group.

Encouraging public spaces to be as open as possible with activities allowed as a default such as cycling and skating could have a negative impact on disabled people, as some people within that group may have limited sight and/or mobility. This may mean that they move at a slower pace and feel less safe if people are moving at faster speeds through the public space.

1, 2a, 2b, 2c

Mitigation: Successful public spaces need resources for stewardship, maintenance, community involvement, security or enlivenment. Events can help to promote use of public space, with commercial elements and sponsorship used to help meet running costs. It is important that these are in line with the ethos of public space and do not compromise the principle of accessibility to the space.

Mitigation: Requiring that events held in public spaces do not compromise the principle of accessibility to the space and are offered free where possible could help to ensure that events are more inclusive for all Londoners, including groups who may be on lower incomes or unemployed and have fewer opportunity to attend paid/ticketed events.

Mitigation: The Charter allows for ‘safe cycling’ in order to keep spaces safe and mitigate potential impacts between cyclists and other users in a space. If a space is deemed inappropriate for specific activities the charter allows for site specific regulations to be applied to a space, informed by consultation with relevant stakeholders.

+2

+1

+1

Positive

Creating public space in London that is safer, more welcoming, and more consistently regulated is likely to have a positive impact for groups who are at higher risk of violent crime and who experience higher rates of fear of crime. For example, people who share the protected characteristic of gender reassignment are more likely to be victims of crime than some other members of the population and are more likely to avoid activities and even certain streets due to a fear of being harassed or identified as transgender. The Charter may, therefore, result in a positive impact for these groups, creating a safe secure environment that people have confidence accessing and using.

1, 2a, 2b, 2c

Enhancement opportunity: Through the principle ‘Good Stewardship’ the Charter will help to ensure that new public space in London is safer and more welcoming. It clarifies that stewardship of public spaces should be informal day-to-day and considerate of all users. However, to ensure that public space is safe and secure for all users, enforcement of any restrictions on the use of the public space should be appropriate and reasonable and carried out by staff who have been appropriately trained.

+2

Negative

Not all spaces that will be covered by the Charter will be open and accessible 24/7. For example, sometimes part of a public space if not an entire space may be closed off temporarily for ticketed events to be held, or have restricted opening hours due to access arrangements. These restrictions to access and use could have a negative impact on some groups for whom access to and the ability to spend time and dwell in a public space could be particularly important. For example, homeless people that may have to leave hostels or other temporary accommodation during the daytime, with evidence finding that transgender people are particularly vulnerable to homelessness.

2a, 2b, 2c

Mitigation: Requiring that public spaces clearly identify their opening hours will make it easier for people to work out how they can spend time in a space, e.g. if they need to move on/leave the space at a certain time.

+1

Positive

No anticipated impacts

Negative

No anticipated impacts

Positive

Encouraging public space to be more open, accessible and inclusive is likely to mean that more people are likely to congregate in a given area and spend time in these spaces. This could more opportunities for Londoners to connect and open up opportunities for social interaction in spaces which feel safe to all users during the day time and night. This is likely to have a positive impact on people who share the protected characteristic of pregnancy and maternity.

1, 2a, 2c

+1

Negative

Encouraging public spaces to be as open as possible with activities allowed as a default such as cycling and skating could have a negative impact on pregnancy and maternity as people within that group may move at a slower pace and be more vulnerable to people moving at faster speeds.

Balancing the consideration of commercial events against the wider public use of a public space for certain periods of time could have a negative impact on pregnant women or mothers with young children. For example, spaces being used for commercial events could cause an obstruction or additional travelling distances which could be problematic for people who may have more difficulty navigating around barriers/obstructions such as pregnant women or mothers with young children in pushchairs.

1, 2a, 2b, 2c

Mitigation: Announcing and publicising any closures affecting a space well in advance and an accessible format will help ensure everyone can to be notified and can plan for the potential disruption. This Charter requirement is likely to be helpful for people who may have difficulties navigating around ‘events’ such as mothers and people with young children in pushchairs.

+1

Positive

Evidence at a national level finds that those places with a higher proportion of BAME residents also tend to have fewer green spaces. Areas that have almost no BAME residents have six times as many parks than those where more than 40 per cent of the population are BAME. The first principle in the Charter ‘Public Welcome’ seeks to ensure that public space in London achieves the highest levels of access and inclusion for all people. Encouraging public space to be more open, accessible and inclusive is likely to have a positive impact for BAME Londoners as it aims to provide more opportunity for access to green spaces across London.

1, 2b, 2c, 3

+1

Negative

No anticipated impacts

+2

Positive

Encouraging consistency of management and regulation in public spaces can potentially help to create safe and inclusive spaces, which is likely to have a positive impact for groups who may be more likely to be at greater risk of violent crime, such as religious minorities.

1, 2b, 2c, 3

+1

Negative

No anticipated impacts

Positive

Creating public space in London that are safer, more welcoming, and more consistently regulated is likely to have a positive impact for groups who are at higher risk of violent crime such as men. [To be finalised with reference to additional evidence on impacts on women].

1, 2b, 2c, 3

Enhancement opportunity: Through the principle ‘Good Stewardship’ the Charter will help to ensure that new public space in London is safer and more welcoming. It clarifies that stewardship of public spaces should be informal day-to-day and considerate of all users. However, to ensure that public space is safe and secure for all users, it is clear that enforcement of any restrictions on the use of the public space should be appropriate and reasonable, and carried out by staff who have been appropriately trained.

+2

Negative

No anticipated impacts

Positive

Creating public spaces (as part of the wider public realm) in London that feel safe to all users during the day time and night is likely to be beneficial for certain protected characteristic groups who are more likely to experience fear of crime such as LGBTQ+ people.

1, 2b, 2c, 3

Enhancement opportunity: The Charter requires that applicants to consider how to ensure that the space will provide a safe environment during the day as well as at night. Addressing safety concerns upfront will ensure that they can be resolved or mitigated at the planning application stage, rather than leaving it to the owners or managers of a space to implement measures in a reactive manner.

A number of the Charter principles specifically address the issue of safety and how safe management of public space is to be achieved including:

‘Public Welcome
The public space should be managed to be welcoming to all people. It should be kept clean, well maintained and appropriately lit…

Unrestricted Use
The public space should only have rules restricting the behaviour of the public that are essential for safe management of the space at different times of day and night.

Good Stewardship
The public space should be managed on behalf of all Londoners. Day-to-day supervision should be informal, with both supervision and maintenance carried out in a manner which is considerate of all users.’

+1

Negative

If spaces are closed off at certain times either due to restricted opening hours or temporarily for events, it could have a negative impact for some groups for whom access to and the ability to spend time and dwell in a space could be particularly important. For example, homeless people that may have to leave hostels or other temporary accommodation during the daytime, with evidence finding that LGBT young people are more likely to find themselves homeless than their non-LGBT peers, comprising up to 24% of the youth homeless population.

2a, 2b, 2c

Mitigation: Requiring that opening hours are clearly identified in public spaces will make it easier for people to work out how they can spend time in a space. For example, if they will need to move on/leave the space at a certain time. By also encouraging a more informal approach to stewardship the Charter will help to ensure that spaces are more welcoming to spend time in. Security guards working in a space will be required to undergo appropriate training, which could include sensitivity around the impacts that LGBTQ+ people may face in the public realm.

+1

Positive

Encouraging public space to be more open, accessible and inclusive may increase opportunities for informal play for children. This may have a positive impact for people on low incomes as 28 per cent of children living in poverty in London are materially deprived, with no access to a range of items and experiences typical in childhood.

2a, 2b

+2

Negative

No anticipated impacts.

Public London Charter

+2

+2

+1

No anticipated impacts

+1

+2

+1

+2

+1

+1

What changes have you made to the guidance as a result of this EqIA?

Why have these changes been made?

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

Adjustments to the guidance are required to remove barriers identified by the EqIA or better advance equality.

Justify and continue with the guidance despite having identified some potential for negative impacts or missed opportunities to advance equality.

Stop, rethink or abandon when the EqIA shows actual or potential unlawful discrimination

Equality, diversity and inclusion evidence base for London GLA Intelligence June 2019
The GLA projects that, in 2019, over a fifth of London’s population are under 16 (1.9 million). Over two-thirds, or 6.2 million, are working age (aged between 16 and 64), and less than one in eight are 65 or over (1.1 million). Despite being the smallest age group in London’s population, the number of Londoners aged 65 or over is projected to increase by 86 per cent between 2019 and 2050, faster than younger age groups. Therefore, there will be a growing need for infrastructure that supports an ageing population, including accessible transport and housing, as well as more inclusive employment practices.
Outside of the home, the nature of London’s built environment can support or form barriers to participating in city life. This is particularly relevant to older people and those with children in pushchairs, who face barriers in accessing many services and buildings because of how buildings, spaces and places are designed and managed.
Children in London are less likely than children in other parts of England to make visits to the natural environment, with 62 per cent making at least one visit a week, and 15 per cent never visit, versus 70 per cent and 12 per cent respectively at an England level. Data at a national level also reveals that some groups of children are less likely to engage with the natural environment, including children who are BAME, 56 per cent of whom make at least one visit a week compared to 74 per cent of children who are not from BAME backgrounds. Also, children whose parents are from a lower social class, with a gap in weekly visits of 12 percentage points between the highest social grade (77 per cent) and the lowest (65 per cent).
37 per cent of London’s children are living in relative poverty. Evidence at a UK level suggests that Bangladeshi and Pakistani children are at a greater risk of poverty than children in other ethnic groups. Children living in lone parent households, rented housing, households where nobody is in work or where someone is disabled are at a greater risk of poverty. Twenty-eight per cent of children living in poverty in London are materially deprived, with no access to a range of items and experiences typical in childhood.

Is Britain Fairer? Key facts and findings on children, Equality and Human Rights Commission 2015
The percentage of children and young people who were obese was 28% in England, 34.4% in Wales, and 30.6% in Scotland, in 2012.
In England, 19.8% of children were living in substandard accommodation in 2011/13, compared with 30.9% in 2007/09, and the percentage of children and young people living in overcrowded accommodation fell slightly from 11.5% in 2008/09 to 11.3% in 2012/13. In Scotland, the percentage of households with children living in accommodation that did not meet the Scottish Housing Quality Standard fell from 60.2% in 2008 to 43.5% in 2013. However, there was an increase in the percentage of households with children living in overcrowded accommodation between 2008 and 2013, from 4.5% to 8.2%. There were no data available for Wales.

Making London Child Friendly - Designing Places and Streets for Children and Young People, Greater London Authority January 2020

Children, particularly teenagers, are a complicated presence in public space – often stereotyped as proponents of antisocial behaviour, whilst also imposed with mobility restrictions due to perceived dangers of public space. In London, young people’s perceptions of safety in their area decrease with age. A study conducted by ZCD Architects found knife crime, strangers and adults’ negative perceptions to be the most prominent factors for reluctance to go outside. Built environment interventions and policy should therefore aim to fulfil a child’s right to safety, both actual and perceived.

Girls, particularly teenage girls, are more likely to have restrictions placed on their mobility freedoms. Research in different housing typologies in London found that boys are more likely to play out, visit a park and ride a bicycle alone, and have fewer concerns over safety in public spaces. Design, planning and policy must understand these social and gendered issues when considering how built environment interventions will be experienced and impact on opportunities for mobility.

Designing for independent mobility needs to create safe and accessible routes between the home and the school, as well as connections to the other places that children and young people use. ‘Third places’ are places used away from home and school, such as parks, recreation facilities, libraries and other forms of social infrastructure. These informal spaces, where important social interactions occur, hold a key functional and symbolic role.

Equality, diversity and inclusion evidence base for London GLA Intelligence June 2019
There are 1.3 million disabled adults in London, defined according to the Equality Act 2010 as having a physical or mental impairment that has a 'substantial' and 'long-term' negative effect on their ability to do normal daily activities. Disability is closely related to age: 13 per cent of the working-age population are disabled versus 28 per cent of people aged 65 or over.
Disabled and older Londoners face barriers in accessing London’s built environment, as a result of street design and clutter, a lack of dedicated parking, and a few accessible and specialised public toilets. Older Londoners are at risk of social isolation due to physical barriers preventing them from experiencing the city in full.

Being disabled in Britain: a journey less equal, Equality and Human Rights Commission 2017
UK data from 2014/15 shows that 30% of working-age adults in families where at least one member is disabled were living in households with below 60% of contemporary median income after housing costs, compared with 18% for those living in families with no disabled members. Across Great Britain, 59% of families with children, that were in income poverty and that contained a disabled person, lived in material deprivation in 2014/15, compared with an average material deprivation rate of 20%.

“Who put that there!” The barriers to blind and partially sighted people getting out and about, The Royal National Institute for the Blind (RNIB), 2015
Ninety-five per cent of blind and partially sighted people have collided with an obstacle in their local neighbourhood over three months. The most common obstacles collided with are: – cars parked on pavements (70 per cent) – bins of all kinds (64 per cent) – permanent and temporary street furniture (59 per cent and 55 per cent) – advertising boards (49 per cent).
Over half of blind and partially sighted people reported that recent building developments in their area had made it either a little harder or much harder, for them to get about. Many couldn’t avoid using these areas, but 40 per cent were either using the area less or avoiding it altogether. Two-thirds had not been consulted about these changes to their neighbourhoods. Few local authorities provided evidence of robust consultation policies for planning and highway disruptions.
There is a failure to provide accessible information about building and street developments. This means that blind and partially sighted people are unaware of changes being proposed, and are denied the right to object or ask for disability access to be considered.

Is Britain Fairer? Key facts and findings on transgender people Equality and Human Rights Commission 2015
A UK survey of transgender people carried out in 2012 indicates that respondents avoided some activities due to a fear of being harassed or identified as transgender. Many said they avoided public toilets and gyms, and around a quarter said they avoided clothing shops, leisure facilities, clubs or social groups, public transport, travelling abroad, restaurants or bars. Those with ‘clear and constant gender identities’ as men avoided many more situations than those with ‘clear and constant identities’ as women. This was particularly the case with public toilets, with 77% of transgender men avoiding them.

LGBT in Britain- Trans report, Stonewall 2018
Trans people experience high levels of discrimination and poor treatment because of their gender identity and often change their behaviour because of it. This ranges from verbal abuse and intimidation in the street and other public spaces like toilets, to being discriminated against in shops, cafés, restaurants, bars and nightclubs. Trans people also face discrimination when using public services and when looking for a house to rent or buy.
More than two in five trans people (44 per cent) avoid certain streets altogether because they don’t feel safe there as an LGBT person

Causes and motivations of hate crime Research report 102 Equality and Human Rights Commission July 2016
There is no single type of hate crime. Research shows that some of the most common types of hate crime involve: 1. Incidents that occur during an ongoing local conflict (for example, between neighbours) that has escalated over time; 2. Incidents that form part of a targeted campaign of abuse directed against certain individuals within a neighbourhood; or 3. Incidents that occur in public spaces and are perpetrated by individuals who feel somehow aggrieved by the victim – sometimes occurring during commercial transactions or on public transport.
A large research study recently conducted in England (The Leicester Hate Crime Project) estimated that 49% of hate crimes are committed by perpetrators who are unknown to their victim (Chakraborti et al., 2014). The authors reported that incidents commonly occurred in public spaces including streets, parks and city centres, as well as in and around public transport infrastructures (Chakraborti et al., 2014, p. 31). Yeung and Duncan (2016) reported that there has been a 37% increase in the number of race hate crimes reported to British Transport Police over the past five years.

Equality, diversity and inclusion evidence base for London GLA Intelligence June 2019
GLA projections estimate that, in 2019, 57 per cent of Londoners have a white British, white Irish or other white ethnicity, with the remaining 43 per cent having a black, Asian or minority ethnicity (BAME).
Availability of green space is lower in more deprived areas and areas with a higher proportion of BAME residents, with children in London less likely to visit the natural environment than children elsewhere in England.
LGBT, black and mixed ethnicity Londoners have a less positive attitude towards the police. Younger Londoners feel less well informed about local police activities than other groups.

Stop and think A critical review of the use of stop and search powers in England and Wales, Equality and Human Rights Commission July 2010
Across England and Wales there were 22 stops and searches per 1,000 people in 2007/08. Breaking this down for the different ethnic groups reveals significantly different rates. The black population had the highest rate of stop and search at 129 per 1,000. The rate for Asian people was 40 per 1,000, and it was 17 per 1,000 for white people.
A major influence on the England and Wales figures is the high stop and search rate in London, which in 2007/08 was 60 per 1,000 people. In 2001 the London area was also home to around three-fifths of the black population aged 10 and over in England and Wales, which means that its relatively low disproportionality ratio (4.1) in fact has a big impact on this group’s experience of stop and search nationwide. The large numbers of excess stops and searches conducted on ethnic minority people in London, 104,000 for the black population and 19,000 for the Asian population, are the result of large minority populations and high stop and search rates rather than exceptionally high disproportionality ratios.

Is Britain Fairer? Key facts and findings on women and men Equality and Human Rights Commission 2015
In England, more men reported being the victim of violent crime (3.2%) than women (2.1%) in 2012/13.

Equality, diversity and inclusion evidence base for London GLA Intelligence June 2019
The report states that 2 per cent of adult Londoners identify as gay or lesbian, higher than the UK rate of 1.3 per cent. A further 0.6 per cent identify as bisexual and 0.6 per cent as other sexual identities. A recent survey of the UK’s LGBT population found that 40 per cent had experienced an incident such as verbal harassment or physical violence because they were LGBT and that they had lower levels of life satisfaction than the general UK population.
LGBT, black and mixed ethnicity Londoners have a less positive attitude towards the police.
Note: Statistics about the size of the LGB population vary considerably and there is no single widely accepted measure. The 2017 GP Patient Survey found that 5.4% of London residents surveyed identified as Lesbian, Gay, Bisexual or ‘Other’ compared to a national rate of 3.3%. Figures from the 2017 Annual Population Survey provide lower estimates for London and England (3.2% and 2.6%) (Brent Equality Profile, page 12).

LGBT youth homelessness: A UK national scoping of cause, prevalence response and outcome. The Albert Kennedy Trust, 2015
Focuses on LGBT youth homelessness, covering prevalence, causes, and top 5 issues presented by homeless LGBT young people.
- LGBT young people are more likely to find themselves homeless than their non-LGBT peers, comprising up to 24% of the youth homeless population.
- Whilst homeless they are significantly more likely to experience targeted violence, sexual exploitation, substance misuse, and physical and mental health problems than other homeless youth.

Is England Fairer? The state of equality and human rights 2016 Equality and Human Rights Commission 1 March 2016
In 2015, the Home Office reported a 22% rise in police recorded sexual orientation hate crimes between 2013/14 and 2014/15. For 38 out of 44 police forces, sexual orientation hate crime was the second most commonly recorded hate crime.

Equality, diversity and inclusion evidence base for London GLA Intelligence June 2019
Availability of green space is lower in more deprived areas and areas with a higher proportion of BAME residents, with children in London less likely to visit the natural environment than children elsewhere in England.

Thirty-seven per cent of London’s children are living in relative poverty. Evidence at a UK level suggests that Bangladeshi and Pakistani children are at a greater risk of poverty than children in other ethnic groups. Children living in lone-parent households, rented housing, households where nobody is in work or where someone is disabled are at a greater risk of poverty. Twenty-eight per cent of children living in poverty in London are materially deprived, with no access to a range of items and experiences typical in childhood.
At year 5, children living in the most deprived areas are 15 percentage points more likely to be overweight or obese than children in the least deprived areas.

List the protected groups that have been engaged through the informal engagement - Please refer to the engagement table 2 below.

If groups are identified in the assessment who have not been previously engaged, briefly set out how they will be targeted through the formal engagement (i.e either a specific focus group meeting or invitation to community webinar event) and timeframes.

Already engaged:

• Disabled people
• Age (Older people, Younger people)

Through engagement events people who identify with other groups may have been engaged with, but not in a targeted way.

Future engagement:
Targeted engagement sessions during formal consultation:

• Disabled people
• Pregnancy and maternity
• Age (Older people and Young people)
• BAME people
• People on low incomes

Inclusive design and access panel (IDaAP) meeting
12 June 2019
City Hall

Disabled people
Older people

Opportunity to engage with this group of users at an early stage of the project and get some feedback from them about their priorities and what they would like to see in a Charter.
The following points were raised at the meeting:

• The Panel made a submission for the draft LP which included points addressing shared space, management and maintenance, access for disabled people.

General panel comments:

• Specific references to accessibility and disabled people needed so doesn’t get missed
• Use definition of inclusive which emphasises disabled people.
• Requirements of disabled people/ people with a range of impairments need to be considered
• All people should be able to comfortably use areas, people aren’t all the same
• There should be user involvement too, disabled people should be involved later once there is a draft to look at too.
• Check for other best practice examples, the Olympic park etc.
• Need to consider very different requirements of people with mental health issues and neurodiverse conditions in how spaces are managed
• The charter needs to be more people/ user focussed rather than legal/ ownership based
• Public spaces include: cathedrals, royal parks, canal towpaths, it needs to work across a wide range of areas/ define carefully what is covered.

LSE Seen and Heard
Brent Youth Council
5th September 2019?
LSE

Blueprint Collective presented preliminary ideas for a multi-media Youth Charter (Brent Council) + initial ideas for a series of policy recommendations based on the findings from their workshops,

GLA presented on the Public London Charter and sought feedback

• Seen and heard projects – Blueprint collective has been working on putting together a vision and plan for a public space – representing young people/ a space for young people.
• Development of a charter (as part of the seen and heard project).
• Attended a conference at the GLA where a number of Charter’s were presented – picked up that none of the charters were very engaging.

Some policy recommendations that the youth group came up with:

Engagement

• Young adults want to get involved in shaping their physical environments

Design

• mapped out how people travel out the borough and where they go, to start seeing patterns
• Young adults look for privacy but equally visual safety

Infrastructure

• LSE starting to make their own google map of Privately Owned public spaces.
• Designing for young adults must translate into management that allows for congregation and dwell time in the space.
• Include young adults in the long term programming of these spaces.
• Investment in the public realm should extend beyond the red line of the development (in the context of the rise of large scale redevelopment projects particularly in context of high social and economic inequality).