Integrated Impact Assessment Form (IIA) from June 2013

This form replaces the previous Integrated Impact Assessment form used by LBC. The key aim of an impact assessment is to ensure that all Council policies, plans and strategies support the corporate mission statement that

‘The needs of ’s people will be first in everything we do’.

1. Why do I need to do an IIA? The aim of this impact assessment process is to:  Ensure adherence to the legal duties contained within the Equality Act 2010 and associated Public Sector Duty to analyse the impact of decisions to be undertaken by Council.  Ensure the Council has due regard to equality taking a proportionate and timely approach to analysing the impact on citizens  Minimise duplication of initial impact assessments with regards to Environment and Health and maximise consideration of other key Council priorities of Inclusion and Community Cohesion  Ensure that the Council has been able to consider the social, health, environmental and economic impacts in its decision making in a single document and, where necessary enable the production of a comprehensive action plan to mitigate any potential negative impacts identified

2. When do I need to do an IIA?

An IIA must be started at the beginning of any project, policy or strategy, and cannot be finalised until such time as all consultations, as required, are undertaken.

 The Impact Table will help you to make early consideration of the potential impacts of your proposal and should be used from the point at which preliminary report is taken to Corporate Leadership and Management Team (CLMT) where appropriate. By using this table at your earliest point in the project, potential impacts can be highlighted and it will also be clear whether you need to carry out a full IIA.

 If you complete this table and all impacts identified are neutral, i.e. there is no noticeable impact on characteristics and priorities listed and you are fully confident of this, please contact the SJU by email setting out how you have reached this judgement as it is unlikely you will need to carry out a full IIA.

 An IIA must at all times identify those who will be affected by the decision, policy or strategy.

 At a time of economic austerity IIA authors are minded to consider the whole range of decisions, both locally and nationally when analysing the impact on citizens

 Your first early draft is to be sent to the Social Justice Unit for comments and guidance

 Once consultation has ended, the IIA must be updated with results of the consultation and returned to Executive, where required, for further consideration and approval – at this stage it will be signed off as completed by the Social Justice Unit

If at anytime you need further guidance please contact the Social Justice Unit. For your convenience, please see links at the end of this document to key Corporate and Partnership documents that may help you complete this IIA.

1 IIA from June 2013

Tracker 2 No: Lead Officer Name: Chimeme Egbutah Proposal Title: 2014-2021 Playing Pitch Strategy Advanced Health Improvement Specialist Public Health services Date of IIA: 10.03.2014

Updated after consultation (Policy Group) - Date: 19th March 2014

Early draft Seen by:1 .Sandra Legate Equality and Diversity Policy Manager 25th March 2014......

Finalised IIA Signed and seen by SJU : Name: Sandra Legate Date: 11th August 2014

Please include the names of all other If there is any potential impact on staffing please contributors and stakeholders involved in the include the name/s of the trade union preparing of this proposal who have been representative/s involved in the preparation of this consulted with and agreed this assessment. assessment or any supporting evidence of request (Please note the IIA must not be carried out to participate: by one person): Husnara Malik Karen Fletcher Chimeme Egbutah

Please provide an outline of your proposal:

Following an Audit Assessment of Playing Pitches in Luton, the Playing Pitch Strategy (PPS) has been undertaken to provide a strategic framework for the Town on the improvement and maintenance of existing outdoor sports and ancillary facilities.

The strategy has a timescale from 2014-2021 and has a proposed action plan that includes a prioritisation list of sites that are to be improved.

The strategy aims to feed into the wider Sports vision for Luton.

Information supporting the proposal (who, what, where, how2)

1 Please send an early draft of your IIA to the SJU to ensure all impacts are being considered at the appropriate time 2 Breakdown of present users by ethnicity, age, gender, disability, religion/belief, sexuality (if recorded)

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Who: The strategy is aimed at all residents in Luton and includes children and communities who may access school sites. What: The strategy is one of the key documents feeding into Luton’s Sports Vision. It aims to improve and to maximise investment into outdoor sports facilities. Also, to increase access to all outdoor facilities and in particular educational facilities. It is underpinned by a number of key strategies including, Sport England Strategy, NPPF and ECB Champion Strategic Plan Where: The strategy gives a list of proposed priority sites. Sites have been classified into Strategic sites, key Centres and Club and education sites (local sites). There are four Borough wide priorities, which have been deemed by key stakeholders to have the greatest impact in terms of improving sporting participation. These are:  (lower) – Luton Central  Common (Luton Regional and Lothair Road Recreation Grounds)  How: The proposed priorities will be delivered over a 10 year period and have been ranked according to cost and timescales. These rankings have been set by Sport Englands estimated facility costs.3

IMPACT TABLE The purpose of this table is to consider the potential impact of your propound sal against the Equality Act 2010 ‘protected characteristics’ and the Council’s Social, Environmental and Economic priorities.

Once you have completed this process you should have a clearer picture of any potential significant impacts4, positive, negative or neutral, on the community and/or staff as a result of your proposal. The rest of the questions on this form will help you clarify impacts and identify an appropriate action plan.

Protected Groups Citizens/Community Staff (for HR related issues) Positive Negative Neutral Positive Negative Neutral Race x Gender x Disability x Sexual Orientation x Age x Religion/Belief x Gender Reassignment x Pregnancy/Maternity x

Also, show areas in the town with the biggest and lowest needs. Greater emphasis is required at the start of the IIA on the service, how it is delivered now and how the new service will be delivered

3 Sport England Facilities Cost. Forth Quarter 2013. Found here: http://www.sportengland.org/media/198443/facility- costs-4q13.pdf 4 “Significant impact” means that the proposal is likely to have a noticeable effect on specific section(s) of the community greater than on the general community at large.

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Marriage/Civil Partnership (HR issues only) Care Responsibilities5 (HR issues only)

Social & Health6 Impact on community cohesion x

Impact on tackling poverty x Impact on health and wellbeing x Environment Impact on the quality of the natural x and built environment Impact on the low carbon agenda x Impact on the waste hierarchy x Economic/Business Impact on Luton’s economy and/or x businesses Impact on jobs x Impact on skills x

Please answer the following questions

1. Research and Consultation 1.1 Have you made use of existing recent research, evidence and/or consultation to inform your proposal? Please insert links to documents as appropriate.

1.2 Have you carried out any specific consultation with people likely to be affected by the proposal? (if yes, please insert details, links to documents as appropriate).

Guidance Notes: If you have not yet undertaken any consultation you may wish to speak to the Consultation Team first as a lack of sufficient consultation could place the Council at risk of legal challenge.

Click here Luton Observatory Click here for LBC Consultation Portal For local demographics and information To access available relevant research already carried out

1.1.Insert any links to references including 1.2. Consultation – insert any links to websites below consultation documents

5 This is a Luton specific priority added to the 9 protected characteristics covered under the Equality Act and takes into account discrimination by association. 6 Full definitions can be found in section 3

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As part of the PPS Needs Assessment: Located in Further consultation will take place once the strategy Labour Group room has been ratified by council’s democratic process. Active People Survey informed the assessment.

For advice and support from Consultation Team click here

1.3 Have you carried out any specific consultation with citizens/staff likely to be affected by the proposal? If yes, please insert details, links to documents, as appropriate above. Please show clearly who you consulted with, when you consulted and the outcomes from the consultation. Mitigations from consultation should be clearly shown in Action Plan at end of document.

Some consultation has been conducted with key stakeholders in order to develop the strategy. Key stakeholders have been Sport England, Parks, LBC commissioning, Planning, Capital Assets, Football Association, Rugby league, Cricket Academy. However, it is envisaged that now the strategy has been written in draft, further consultation with key stakeholders in greater depth will be undertaken this includes schools and colleges.

It is hoped that consultation with school groups who work with ethnic minorities, girls and women and disability will also be consulted.

2. Impacts Identified 2.1 Where you have identified a positive* impact, for communities or staff, please outline how these can be enhanced and maintained against each group identified. Specific actions to be detailed in action plan below. *By positive impact we mean, is there likely to be a noticeable improvement experienced by people sharing a characteristic? Increasing physical activity for Luton residents will have a positive impact on:  Health and improve health outcomes  Improve community cohesion and  Increase community cohesion and participation

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For advice & support from the Social Justice Unit click here

2.2 Where you have identified a negative* impact please explain the nature of this impact and why you feel the proposal may be negative. Outline what the consequences will be against each group identified. You will need to identify whether mitigation is available, what it is and how it could be implemented. Specific actions to be detailed in action plan below. *By negative impact we mean is there likely to be a noticeable detrimental effect on people sharing a characteristic?

Whilst the needs assessment highlights the demographic requirements and specific issues relating to sub- populations in Luton. This includes BME groups and female sports participation.

Luton’s Vision for sport identified the need to improve physical activity in Luton and noted the differences in activity levels between different demographic groups, for examples: • 64% of females were inactive compared to 48.9% of males • 65.3% of people from socio-economic groups NS-SEC 5-8 were inactive compared to 44.1% from NS-SEC 1- 2. • 76.5% of people with a limiting disability or illness are inactive compared to 52.7% of those without Luton’s sports strategy also noted that disabled adults were less than half as likely participate in sports compared to people with no disability.

The Vision specifies that Luton Borough Council should focus on increasing participation levels in sports generally, with specific interventions aimed at: • Older people (aged 55+) • Younger people (aged 16-34) • Disabled people • Women and girls

In addition the Vision aims to reduce excess weight in children aged 4-5 years and 10-11 years of age.

Despite the assessment previous to the PPS highlighting the poor uptake of sports and organised participation from BME groups and people with disabilities, the strategy itself has limited detail regarding how improved access in specific groups will be achieved. Therefore, currently it is not possible to state that the strategy will have a positive impact on gender equity or access for those with a disability or all black and minority groups in Luton.

Update 11/08/14 (AD): Partnership funding has been secured for both disability access to sport and for a programme of additional of sports activities for women and girls.

In terms of disability access to sport, the Disability Resource Centre (DRC) in conjunction with the County Sports Partnership, Team Beds and Luton has secured almost £360K from Sport England to create more sustainable opportunities for disabled people to take part in sport in .

This award is one of 44 projects across England which will collectively inject £8 million into disability sport. Branded under the banner ‘No Limits’, the project aims to develop a network of multi-sport and sport-specific clubs across the county over the next three years. Working with a range of key delivery partners across the county, the project aims to create a strong and consistent message that focus on No Limits to an individual’s capacity to be involved, No Limits

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to an individual’s aspiration to succeed and No Limits to regular sports participation!

It should be also noted that several new disability sports programmes have been set up in 2014 including Disability Tennis and a Disability Dive programme.

Whilst in terms of female access to sport and leisure, Active Luton recently secured £220K from Sport England to run a three year women only programme. The programme The sports trust is among 36 projects to receive a share of £5.9 million of funding to support grassroots sport activity across the country.

The ‘Active Women’ programme encourages women aged 16 years and over to increase their sport and physical activity levels for fun, social, recreational or competitive purposes.

There are a number of community-based programmes taking place across Luton providing local women the opportunity to participate in a variety of sports and fitness programmes. The new funding will allow the project to grow and offer more regular sessions over the next year.

Activities will be during the day, in the evening and at weekends so that everyone has the opportunity to participate. As well as the physical activities, the programme also provides links into coaching and mentoring to help develop local female leaders, mentors and coaches who can then encourage others to take part.

A key partner in the project is the University of Bedfordshire who will be providing activities for female students and integrating them into community-based activity as role models.

It needs to be stated that the strategy does to some extent consider the need to improve access for females: for instance the Play Pitch Needs Assessment, which informed the strategy, stated the need to improve access to female changing facilities, and the play pitch strategy does prioritise Increasing “the provision of changing rooms and clubhouses that can sustain concurrent adult and junior male and female activity at clubs”i, but otherwise there is limited discussion of how access for females will be improved.

There is also only limited discussion regarding disabled access for the facilities, in the form of a quality statement “Good quality refers to facilities that have, for example, good grass cover, an even surface, are free from vandalism, litter etc, have access for disabled people”. There was also a lack of information regarding how disability access would be achieved and monitored, or regarding disabled changing facilities and access for disabled spectators.

The needs assessment notes that the Asians, Black and Minority groups have a higher level of ‘intent’ to participate in sports. The PPS does not address this issue – although Aim 3 speaks of maximising access to all outdoor facilities and in particular educational facilities.

Community Cohesion The PPS offers improved access to sports pitches and thus improved access to sport team participation which improves community cohesion7. This was not specifically identified in the strategy, although, this could offer opportunities

7 Sport England. Building Communities. Developing strong, sustainable and cohesive communities through sport. Found here: http://www.sportengland.org/media/91527/building-communities.pdf

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2.3 Where you have identified a neutral* impact for any group, please explain why you have made this judgement. You need to be confident that you have provided a sufficient explanation to justify this judgement. *By neutral impact we mean that there will be no noticeable impact on people sharing a characteristic Example statement:

There is no evidence currently available to suggest that the PPS will have a noticeable impact, either positive or negative, on the groups identified above namely (please insert as appropriate): Religion/belief; pregnancy and gender re-assignment. Although, there is no clear evidence – it is possible where issues of improving quality exists and facilities provision may have a positive impact on religion/belief for Muslim women.

For advice & support from the Social Justice Unit click here For advice and support from the Public Health team click here

3. Social & Health Impacts If you have identified an impact on community cohesion8’, tackling poverty9 or health and wellbeing10, please describe here what this may be and who or where you believe could be affected, Please also ensure that you consider any possible impacts on Looked After Children.

Guidance Notes: Please use this section to describe the social and health impacts and detail any specific actions or mitigations in the action plan below.

Sports participation in Luton is currently less than the national average. As stated in above, currently females are more likely to be inactive compared to males, people in lower economic groups are more likely to be inactive compared to those in higher socio-economic groups, and those with a disability are more likely to be inactive compared to those without. Therefore, it is important to ensure that the play pitch strategy is aligned with the Sports strategy for Luton and specifically outlines how it will work towards improving access to physical activity for females, older residents and those with a disability, currently this is not clear in the strategy.

It has been well documented that exercise and sports participation can improve mental and general health outcomes1112. The health outcomes for Luton based on the strategy could be beneficial to participants and users of

8 is the proposal likely to have a noticeable effect on relations within and between specific section(s) of the community, neighbourhoods or areas. 9 is the proposal likely to have a noticeable effect on households that are vulnerable to exclusion, e.g. due to poverty, low income and/or in areas of high deprivation 10 Is the proposal likely to have a positive or negative impact on health inequalities, the physical or mental health and wellbeing of an individual or group, or on access to health and wellbeing services?

11 Cochran Review. Exercise for Depression. Cooney GM et al (2013). John Wiley and Sons Ltd

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pitches, however in regards to reducing health inequalities, the strategy does not mention (specifically) how the priorities will improve inequalities or improve health outcomes in disadvantaged areas.

The PPS clearly identifies strategic priority sites, all of which are currently not in areas of deprivation or lower life expectancy. It is however, recognised the strategy highlights a range of local (and accessible) local centres for improvement and the increase in cricket and football pitches to meet future demands.

The strategy lacks the wider contextual setting clearly given in the needs assessment and Vision. Whilst Luton’s Sport Vision recognises and confidently links to relevant strategies including the Health & Wellbeing Strategy, this is not reflected in the PPS.

12 Sport England. Healthier Communities. Improving health and reducing health inequalities through sport. Shaping Places through Sport. Found here: http://www.sportengland.org/media/91477/healthier-communities.pdf

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For advice and support from the Strategy & Sustainability Team click here

4. Impacts on the natural & built environment Environment Impacts If you have identified any impacts related to the built and natural environment13, low carbon14 and waste minimisation please describe here what this may be and who or where you believe could be affected (please see footnote below)

Is the proposal likely to impact on the waste hierarchy which includes issues shown in the table below:

Waste Hierarchy

For advice and support on Economic Development click here

5. Economic Impacts If you have identified any impacts related to Luton’s economy and businesses 15, creating jobs16 or improving skill levels 17, please describe here what this may be and who or where you believe could be affected (– please see footnote below)

Guidance Notes: Please use this section to describe the social impacts and detail any specific actions or mitigations in the action plan below.

13 Is the proposal likely to Impact on the built and natural environment covers issues such as heritage, parks and open space, cleanliness, design, biodiversity and pollution. 14 Is the proposal likely to impact on low carbon includes issues such as use of energy, fuel and transport. 15 Is the proposal likely to impact on Luton’s economy and businesses for example by creating an opportunity to trade with the Council, support new business opportunities? 16 Is the proposal likely to impact on the creation of new jobs in the local economy? This will also link to health and well- being and the reduction of poverty in the social box. 17 There are significant skills gaps in Luton’s economy. Is the proposal likely to create opportunities for up skilling the workforce or to create apprenticeships?

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Please detail all actions that will be taken to enhance and maintain positive impacts and to mitigate any negative impacts relating to this proposal in the table below:

Action Deadline Responsible Intended Outcome Date Completed/ Officer Ongoing

Ensure that further June H Malik/K Improved and inclusive consultation on the PPS 2014 Fletcher strategy demonstrating the includes marginalised ‘golden thread’ of themes on groups including people improving access, improving with disabilities, BME health and wellbeing and groups and Women sports providing an equitable groups service for vulnerable groups Explore the opportunity to April 2014 H Malik/K Improved and inclusive include contextual Fletcher/Lisa strategy demonstrating the information gained from the Roe ‘golden thread’ of themes on needs assessment e.g. improving access, improving how to include health and wellbeing and marginalised groups, providing an equitable improve inequalities within service for vulnerable the town through improving groups access and activity Explore the addition of an April 2014 C. Egbutah/S. Improved and inclusive extra objective under ‘Aim Legate strategy demonstrating the 3’ to include key groups ‘golden thread’ of themes on and improving access sport improving access, improving facilities health and wellbeing and providing an equitable service for vulnerable groups Include reference to Health April 2014 C. Egbutah Ensures PPS has an and Wellbeing Strategy outcome on improving health and wellbeing. Ensure that the PPS is TBC H Malik/K Improved and inclusive aligned with Luton’s overall Fletcher strategy demonstrating the 2013 Sports Vision by ‘golden thread’ of themes on partnership working to improving access, improving support specific groups health and wellbeing and including people with providing an equitable disabilities, BME groups service for vulnerable and Women sports groups groups

A review of the action plan will be prompted 6 months after the date of completion of this IIA

Key Contacts:

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Husnara Malik – Project Manager Karen Fletcher – Commissioning Officer Sandra Legate – Equalities Manager Chimeme Egbutah – Advanced Health Specialist Emma Waters - Practitioner

Next Steps

 All Executive Reports, where relevant, must have an IIA attached

 All report authors must complete the IIA section of Executive Reports (equalities, cohesion, inclusion, health, economic, business and environment)

 All reports are to be forwarded to the Social Justice Unit, Public Health and Strategy & Sustainability Unit for sign off in time for Executive deadline

 On the rare occasion that the Social Justice Unit are unable to sign off the report, e.g. recommendations are in breach of legislation, a statement will be submitted by Social Justice Unit Manager or Equality and Diversity Policy Manager

Completed and signed IIA’s will be published on the internet once the democratic process is complete

Corporate Plan http://intranet/SupportServices/Document%20library/Corporate%20plan%2011th%20July%202011.doc

Equality Charter http://intranet/SupportServices/socialjustice/Document%20library/Equality%20charter.pdf

Social Justice Framework http://www.luton.gov.uk/Community_and_living/Lists/LutonDocuments/PDF/Social%20Justice/Social% 20Justice%20Framework%202012%20-2026.pdf

Family Poverty Strategy http://www.lutonforum.org/Forum/Documents/Family-Poverty-Strategy-Final-October2011_001.pdf

Joint Strategic Needs Assessment (JSNA) http://www.luton.gov.uk/Council_government_and_democracy/Lists/LutonDocuments/PDF/Consultatio n/Reports/Final%20JSNA%202011.pdf

Community Involvement Strategy http://www.lutonforum.org/Forum/Documents/CISfinaljune2010.pdf

i LUTON BOROUGH COUNCIL PLAYING PITCH STRATEGY FINAL ASSESSMENT REPORT DECEMBER 2013

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