Equality Impact Assessment report
Full Equality Impact Assessment Report
Date to Challenge
Title Highway Maintenance Policy Changes
Principal Highways Engineer
Executive Director, Housing, Regeneration and Environment / Divisional
Director Public Realm
To advise the Equalities Panel of the full Impact of the proposed changes
Purpose of report
to the Highway Maintenance Policy
Consultation with corporate boards/officers/departments
Name Date sent
London Borough of Lambeth
Full Equality Impact Assessment Template
POLICY: Highways Maintenance
The council has legal requirements to pay due regard to equality before and during policy decision
making. Due regard comprise two linked elements: proportionality and relevance. The initial screening
for relevance of this policy is summarised below. Given the high relevance of this policy to equality a full
assessment is deemed proportionate.
1.1 Stage 1 summary
Policy High – needs very detailed and thorough process with significant external challenge. Full
relevance assessment required
to Medium – needs reasonably robust process with some degree of external challenge. Full
Low – needs a degree of rigor to confirm that it is in line with statutory duties but external
challenge. Full assessment not required
Relevance Race Gender & Disability Age Sexual Faith or Social
identified Transgender Orientation Belief Factors
High/ Low Low Medium Medium Low Low Medium
The completed stage 1 screening template is attached as appendix 1.
1.2 This full assessment builds on the stage 1 initial screening and provides the following:
the aims and intention of the policy;
equality evidence collected;
results of consultation and involvement;
the impacts revealed; and
justification of decisions made.
1.3 Policy aims and intention
Why is the policy needed? Who is the policy aimed at? What is the intended outcome?
The policy changes are required due to the result of the Comprehensive Spending Review and its
resultant affect on public finances. A need to reduce the Councils revenue budgets across the board
has meant that services have been squeezed to the point where policy changes have had to be made in
order for the Authority to make the necessary savings to continue to provide a range of services to
residents and businesses of Lambeth.
The policy change is aimed at all users of the public highway network.
The intended outcome of the policy is to save £200K per annum on responsive maintenance defects –
namely potholes, trip hazards and carriageway defects.
2. Stage 2 – Sound, consistent equality data collection and analysis
Evidence based policy making often requires both consultation and involvement of representative groups.
EIAs should draw on this to ensure involvement and consultation approaches include communities and
groups covered by the public sector duties and wider equality groups. This section sets out how equality
information has been mapped, collected and analysed to better understand the likely impact of the policy on
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2.1 Collecting and using data to identify the impact
What does available In your response please identify:
data / consultation Any further evidence captured or insight gained since stage 1.
about the access and Equalities profile of service users/staff and beneficiaries - - race, gender,
other outcomes of the transgender, disability, age, sexual orientation, faith or belief equality or
proposed policy for socio economic groups.
different equalities Evidence of complaints on the grounds of discrimination, if any.
A significant amount of benchmarking has been undertaken to assess Lambeth’s position relative to
other central London Boroughs. It was found that the policy changes would sit Lambeth firmly in the
middle, or ‘average’ in terms of its response to highway defects.
It is wholly recognised that different equality groups need to be recognised in the decision making
process. For this reason, the Highways Department will work closely with Risk and Insurances on
establishing trends and any issues related to highway defects affecting vulnerable groups.
There have been no complaints received in regarding discriminatory practices relating to the Highways
2.2 Positive involvement and consultation
What do stakeholders In your response please set out:
think about the policy?
The potential barriers to participation for the different equality groups.
How you have consulted with key stakeholders in the process of
developing the policy to obtain their views on the policy
How feedback and challenge from informed groups and individuals will be
used to ensure that the final policy is robust, addresses identified need
and promotes equality of opportunity.
No formal consultation has been undertaken on the policy changes. However a number of press releases
have been issued advising Lambeth Residents about a reduction in the Highways Maintenance services.
The Local Authority, acting as the Highway Authority for Lambeth’s roads has a statutory duty to maintain
the network by providing a safe highway for the use of the public and be consistent with the national Code
of Practice for Highway Maintenance “Well Maintained Highways”. There is no highway law which states
that consultation needs to take place when undertaking maintenance duties, however it is recognised that
residents should be advised in some form. Work has begun on updating the Lambeth Website information
on highway maintenance.
No feedback on the reduction has been received thus far.
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2.3 Gaps in information
What gaps in In your response please identify:
information have you Areas where more information is required and action taken or will be
identified? taken to obtain this data
Longer term measures to be taken to provide strengthen data.
There are gaps in data currently issued to highways from the Risk and Insurance department.
Information on claimant circumstances and precise location has been identified as the key gaps in
ensuring that the Council provides all groups with a fair service. It is envisaged that the information that
will be obtained will assist Highways Officers to shape the Highway Policy document which is a working
document expected to be amended annually.
Longer term measures include:
The use (potentially) of GIS mapping of claim related data to identify areas of concern.
Complete overhaul of the Highways Road Hierarchy – for instance where roads / footways are in the
proximity to those within the vulnerable groups – ie schools and elderly people homes.
3. Stage 3 – Assessing impact
It is essential to consider not just the intended consequences of the policy but also any unintended
consequence and barriers that might prevent it being effective for certain community groups. Where a policy
is found to have either positive or negative impact on a particular group it will need to be revised or justified
within the permits of the law. This section sets out how equality information has been analysed and the likely
3.1 Testing for negative impact
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From evidence In your response please set out:
analysed could the
Take up of service by each equality group
policy have differential,
disproportionate or If differential or disproportionate impact amount to adverse how is this
adverse impact on justified on grounds of promoting equality of opportunity or another
different equality legitimate reason?
groups? If differential or disproportionate impact amount to unlawful indirect or
direct discrimination how is this justifiable under legislation?
Differential Impact – adverse
On a very simplistic level, defects that are currently repaired will not be repaired. Defects
will be on the ground that are outside of our current intervention levels and for longer
periods of time.
There are approximately 29,200 people of working age who are disabled in Lambeth. This is 14.9%
of the working age population, in line with London (15.3%) and slightly lower than England
(18.0%). In 2001 there were 22,466 residents aged 16-64 years with a long term limiting illness
in Lambeth, approximately 12% of the working age population and in August 2008 11,645 people in
Lambeth were in receipt of Disability Living Allowance. In June 2009 there were 815 children
under the age of 19 years with disabilities on the voluntary ICOUNT register; 43% of whom have
Autistic Spectrum Disorder (ASD), showing an increase of nearly 12% over the last five years.
Just over a quarter of Lambeth’s school children (27%) are recorded at some time in their
school career as having Special Educational Needs.
There is a (and always has been) a risk that disabled persons will encounter a highway defect
on the footway. However, to mitigate this, the Council will retain its commitment to
inspecting main walking routes on a monthly basis and treating all defects at the same 20mm
intervention. Side roads will present a risk to the disabled – notably those with walking
impediments and there will be a risk to the Council that insurance claims will increase as a
result of this.
The Highway Maintenance Policy will be treated as a working document – any claims received from
residents will help shape the way in which the policy is formed and re-formed in the future.
Differential Impact - adverse
Some of the most common complainants about highway maintenance are from the elderly, or parents
of young children.
As stated above there is always a risk that these vulnerable groups will inevitably encounter a highway
defect and that mitigating circumstances have been made to at least reduce this risk, but it would be
impossible to eliminate the risk altogether under any conditions.
Religion and belief
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Lambeth has very diverse socio economic demography – no greater example if this can be illustrated
by the oxymoronic comparison of its southern section of Streatham and West Norwood to its northern
tip, the Waterloo Area.
By introducing these changes to the Highway Maintenance Policy, the Council is at risk of placing its
residents of the more deprived areas of Lambeth in an adverse financial situation. Damages to
vehicles may be more likely to occur should the changes go ahead, placing much more financial
hardship on residents to make repairs as a result of encountering carriageway defects. Some work
has been done to identify if the Council would be putting its residents in an unfair position by
benchmarking highway policies with other Boroughs. The results of which are at the end of this report.
In assessing the benchmark results, the impact of the policy change has been assessed as a medium
on the basis that Lambeth will be managing an ‘average’ maintenance service.
3.2 Additional factors which may influence impact
What custom and In your response please identify:
practice in service For example management arrangements, accessibility issues,
provision or allocation communications methods and equality monitoring processes.
relates to this policy
A significant capital investment has been identified for the full resurfacing and full reconstruction of
roads and footways respectively. This has allows the service to balance out resident need by mitigating
the need to repair defects on a road for instance for the obvious reason that it has been newly laid. This
will have a positive influence on how equalities groups affected are impacted. It is common practice to
reconstruct footways in worse deprived areas and roads that are within proximity to schools.
3.3 Equality impact summary
Potential impact identified – High (H), Medium (M), Low(L)
Potential impact Race Gender Disability Age Sexuality Faith or Socio-
identified Orientation Belief economic
Opportunity for a
L L M M L L M
Risk of differential/
Disproportionate/ L L M M L L M
4. Addressing adverse impact and promoting equality
This section sets out specifics actions taken or to be taken to deal with any adverse impact. There are four
possible outcomes and more than one may apply to a single policy:
Low impact: - no major change. The EIA demonstrates the policy is robust and there are no
potential for discrimination or adverse impact. Opportunities to promote equality have been taken.
Medium/high impact: adjust the policy. The EIA identified potential problems or missed
opportunities. Adjust the policy to remove barriers or better promote equality.
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Medium/high impact: continue the policy. The EIA identifies the potential for adverse impact or
missed opportunities to promote equality. Clearly set out the justifications for continuing with it. For the
most important relevant polices, compelling reasons will be needed.
Unlawful discrimination: stop and remove the policy. The policy shows actual or potential
unlawful discrimination. It must be stooped and removed or changed.
4.1 Removing barriers in policy development
What are the main conclusions and Please identify:
the key changes that have been made Changes/adjustments made to address the impact identified.
or practical measures put in place to
address disproportionate/differential Measures that will require wider decisions
impact (adverse/positive) on equality What do you think are the main issues that could hinder the
groups or to address potential effective implementation of equality / diversity within this
unlawful discrimination, if any policy area?
The ways in which services are delivered or communicated
and whether there are alternative measures that would have
a more positive effect
Outcome 3 Identified –
The savings have to be achieved. No changes can be made unless SLB level decision is made to shift
The main issue that affects the implementation of equality / diversity is that there is little to no funding
available to continue with the Highway Maintenance service in its current form.
Increasing the budget is the obvious recourse to positively effecting vulnerable groups. Other areas already
mentioned include increasing the Capital Investment in the Boroughs road network.
Furthermore – keeping the Highway Maintenance Policy agile will allow the Council to meet the needs of
vulnerable groups through detailed investigation into 3rd party claim data.
4.2 Promoting equality of opportunity
What changes have been made or In your response please identify:
practical measures put in place to For example, changes in communication methods, language
promote equality of opportunity? support, disability measures, changes in eligibility criteria,
amended programmes, outreach methods, shared targets with
other departments, etc.
Factors that can hinder the implementation of the suggested
measures such as financial resources, competencies,
managerial support, commitment etc.
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Stage 5 – Implementation and review
At this stage an action plan should be developed to address any additional concerns or issues related to
equality in the proposed policy. The plan should include arrangements for monitoring, evaluation and review
of the policy and should be integrated into the appropriate Service of Business Plan. The results of the EIA
and action plan will need to be published. Once the new or revised policy has been implemented, it must be
monitored and periodically reviewed to ensure that it has the intended impact and is still appropriate.
Actions Required Timeframe Budget Lead Officer Relevant PI
EIA publishing date: __________________________ Policy review date: ______________________
Full assessment sign-off
Name Signature Date
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