-
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
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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
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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
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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
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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
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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.
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1 Executive summary
Equalities Impact Assessment 2
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
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1 Executive summary
Equalities Impact Assessment 3
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
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1 Executive summary
Equalities Impact Assessment 4
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.
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2 Project description
Equalities Impact Assessment 5
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
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2 Project description
Equalities Impact Assessment 6
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.
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2 Project description
Equalities Impact Assessment 7
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.
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2 Project description
Equalities Impact Assessment 8
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.
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3 Introduction
Equalities Impact Assessment 9
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.
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3 Introduction
Equalities Impact Assessment 10
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.
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3 Introduction
Equalities Impact Assessment 11
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.
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3 Introduction
Equalities Impact Assessment 12
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4 EqIA background
Equalities Impact Assessment 13
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
Equalities Impact Assessment 14
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
Equalities Impact Assessment 15
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
Equalities Impact Assessment 16
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
Equalities Impact Assessment 17
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.
-
5 Project approach to equalities
Equalities Impact Assessment 18
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 Project approach to equalities
Equalities Impact Assessment 19
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 Project approach to equalities
Equalities Impact Assessment 20
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
-
5 Project approach to equalities
Equalities Impact Assessment 21
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 Project approach to equalities
Equalities Impact Assessment 22
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 Project approach to equalities
Equalities Impact Assessment 23
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
-
5 Project approach to equalities
Equalities Impact Assessment 24
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
-
5 Project approach to equalities
Equalities Impact Assessment 25
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
su
ltati
on
an
d T
ham
es
Wa
ter
s r
es
po
nse
R
esp
on
den
t T
hem
e
Su
mm
ary
of
issu
e
Th
am
es W
ate
r re
sp
on
se
5.4
.10
Tow
er
Ham
lets
C
ouncil
of
Mosques
Tra
nsla
tion
serv
ices
Lack o
f appro
priate
tra
nsla
tion
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
ow
er
Ham
lets
.
Prior
to c
om
mencin
g p
hase
tw
o c
onsu
lta
tio
n,
we a
gre
ed o
ur
appro
ach to
this
phase o
f consu
ltatio
n w
ith t
he p
ote
ntially
directly a
ffecte
d local
auth
orities. T
his
inclu
ded r
evie
win
g o
ur
ap
pro
ach t
o e
ngag
ing w
ith h
ard
-to-
reach g
rou
ps. A
s p
art
of
this
pro
cess, w
e c
onta
cte
d c
om
munity g
roups p
rior
to c
om
mencin
g c
onsultatio
n. T
hese g
rou
ps a
re lis
ted in A
ppen
dix
I o
f th
e
Main
rep
ort
on
ph
ase tw
o c
onsultation
.
With r
egard
to
those
for
wh
om
Englis
h is n
ot th
eir f
irst la
ngu
age
, at
the s
tart
of
phase t
wo c
onsu
ltatio
n w
e p
ublis
hed
our
SoC
C in t
he L
ond
on
Even
ing
Sta
ndard
. T
he S
oC
C s
et o
ut our
appro
ach to
consu
lta
tion
inclu
din
g the
fact
that
a lang
uag
e lin
e s
erv
ice
was a
vaila
ble
. W
e c
onsid
er
that o
ur
ap
pro
ach
was c
onsis
ten
t w
ith e
qu
alit
ies leg
isla
tio
n.
We s
ent
a tota
l of
12
9,5
15 letters
to t
he s
urr
ou
nd
ing
co
mm
unity n
otify
ing
peop
le o
f th
e c
onsu
lta
tion a
nd p
ublic
isin
g t
he lan
gua
ge
lin
e b
y m
eans o
f a
transla
tio
n leaflet. W
e a
lso p
lace
d s
ite
notices w
ith o
ptions f
or
transla
tion
serv
ices a
round e
ach o
f ou
r pre
ferr
ed s
ites. O
n t
he b
ack o
f our
litera
ture
w
e inclu
ded a
para
gra
ph a
skin
g p
eop
le t
o c
onta
ct us if
the
y w
ante
d
info
rmation in a
diffe
rent fo
rmat and a
dvis
ing t
hat
we p
rovid
ed a
tra
nsla
tio
n
serv
ice t
hro
ug
h th
e lan
gua
ge lin
e. In
form
ation r
eg
ard
ing th
e a
va
ilabili
ty o
f th
e lan
gua
ge lin
e w
as a
lso p
rovid
ed o
n o
ur
website. W
e there
fore
co
nsid
er
that
we a
deq
uate
ly p
ublic
ised th
e a
va
ilabili
ty o
f our
tra
nsla
tion s
erv
ices.
Regard
ing th
e p
rovis
ion o
f tr
ansla
ted m
ate
rial, th
e lang
uage
lin
e w
as
consid
ere
d a
n a
ccepta
ble
measure
by the
pote
ntia
lly d
irectly a
ffecte
d local
auth
orities.
In a
dditio
n to t
he S
oC
C,
we
pub
lish
ed p
ress r
ele
ases in loca
l n
on
-Eng
lish
lan
gua
ge p
ap
ers
specific
ally
for
the L
on
don B
oro
ug
h o
f T
ow
er
Ham
lets
. F
urt
her
info
rmation w
as a
lso p
rovid
ed in loca
l n
ew
spa
pers
. W
e a
lso o
ffere
d
to m
eet and d
iscuss p
roposals
with a
ny in
div
idu
als
duri
ng a
Sa
ve
KE
MP
gro
up e
vent;
ho
wever
no
follo
w-u
p m
eetin
gs w
ere
re
qu
este
d.
5.4
.11
Lond
on
Boro
ugh o
f Le
wis
ham
Lack o
f equa
litie
s
assessm
ent
It d
oes n
ot
app
ear
that
an E
qu
alit
y
Ana
lysis
Assessm
ent (E
AA
) has
been
un
dert
aken a
t phase
tw
o
We h
ave u
ndert
aken a
nd w
ill c
ontinu
e to
un
dert
ake a
ll our
activitie
s in
com
plia
nce
with t
he E
qu
alit
y A
ct
201
0,
in o
rder
to e
nsu
re e
qu
al tr
eatm
ent
of
all
mem
bers
of socie
ty,
irre
spective o
f ag
e, d
isab
ility
, g
ender
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
on
den
t T
hem
e
Su
mm
ary
of
issu
e
Th
am
es W
ate
r re
sp
on
se
at ph
ase
two
consulta
tio
n
consulta
tio
n. T
he E
AA
pro
cess
involv
es s
yste
matically
ana
lysin
g a
pro
pose
d o
r exis
tin
g p
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