1 Introduction
1.1 This Equality Impact Assessment (EQIA) concerns the proposed development of the land at Lewisham Shopping Centre and adjacent land (the ‘Site’), located in the London Borough of Lewisham (LBL). The application seeks permission for the redevelopment of the shopping centre, which is currently in-use.
1.2 The description of the Proposed Development being applied for is:
Hybrid planning application for the comprehensive, phased redevelopment of land at Lewisham Shopping Centre and adjacent land, comprising:
Full planning application (within Phase 1a) comprising the demolition of existing buildings, structures and associated works to provide a mixed-use development including the erection of a Co-Living building (Sui Generis) up to 23 storeys in height (Plot N1), and a residential building (Class C3) up to 15 storeys in height (Plot N2), associated residential ancillary spaces as well as town centre uses (Class E (a, b, c, d, e, f, g (i, ii)); and Sui Generis) together with public open space, public realm, amenity space and landscaping, car and cycle parking, highway works and the formation of new pedestrian and vehicle accesses, existing shopping centre interface works (the ‘Phase 1a Finish Works’), service deck modifications, servicing arrangements, site preparation works, supporting infrastructure works and other associated works.
Outline planning application (all matters reserved) for a comprehensive, phased redevelopment, comprising demolition of existing buildings, structures and associated works to provide a mixed-use development including:
• The following uses:
• Living Uses, comprising residential (Class C3) and student accommodation (Sui Generis);
• Town Centre Uses (Class E (a, b, c, d, e, f, g (i, ii)) and Sui Generis);
• Community and Cultural uses (Class F1; F2; and Sui Generis);
• Public open space, public realm, amenity space and landscaping works;
• Car and cycle parking;
• Highway works;
• Formation of new pedestrian and vehicular accesses, permanent and temporary vehicular access ramps, service deck, servicing arrangements and means of access and circulation within the site;
• Site preparation works;
• Supporting infrastructure works;
• Associated interim works;
• Meanwhile and interim uses and
• Other associated works.”
1.3 The EQIA reviews the Proposed Development and considers the potential effects that may relate to the protected characteristics under the 2010 Equality Act1 . These impacts should be considered when the council is discharging its Public Sector Equality Duty (PSED) under section 149 of the 2010 Equality Act. This EqIA provides information to assist the council in its PSED.
1.4 Equality effects cannot be eliminated. All change affects people differently. The aim of this process is to identify potential equality effects so that they can be avoided or minimised where possible, and residual effects properly considered in the planning balance. Equality considerations feed into the design and implementation, and the report makes recommendations for all parties involved.
1.5 Section 2 of this report provides context by setting out the legislative context, guidance and local policy, and explains the methodology applied in this EqIA, considering both disproportionate and differential effects.
1.6 Section 3 provides baseline information to set the context of the local population – those who live near, work in or visit the site and town centre, and other potentially sensitive local uses. This section considers potential disproportionate effects.
1.7 Section 4 summarises the findings of the consultation, and how they have informed this assessment.
1.8 Section 5 looks at the effects of the proposals, and the potential ways in which these effects may interact with protected characteristics. This section considers potential differential effects.
1.9 Section 6 brings these together to summarise expected effects and considers how the design and development of the proposals and any mitigation, can respond to equality considerations.
1 The Equality Act 2010
2 Equality Assessment Context
Legislative Context
2.1 The 2010 Act requires authorities to have due regard to equality considerations when exercising their functions including decision making on planning applications. These considerations include to:
▪ Eliminate discrimination, harassment, victimisation and any other that is prohibited by or under this Act;
▪ Advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it;
▪ Foster good relations between persons who share a relevant protected characteristic and those that do not share it.
2.2 The objective to advance equality of opportunity includes the need to:
▪ Remove or minimise disadvantages suffered by persons who share a relevant protected characteristic that are connected to that characteristic;
▪ Take steps to meet the needs of persons who share a relevant protected characteristic that are different from the needs of persons who do not share it;
▪ Encourage persons who share a relevant protected characteristic to participate in public life or in any other activity in which participation by such persons is disproportionately low
2.3 The main objective of the PSED is to ensure that public policies and programmes are implemented fairly, especially with regard to the following protected characteristics:
▪ Age;
▪ Disability;
▪ Gender reassignment;
▪ Marriage and civil partnership;
▪ Pregnancy and maternity;
▪ Race;
▪ Religion and belief;
▪ Sex
▪ Sexual orientation
2.4 In the context of planning, the PSED applies to the public authorities in their decision-making on policy and development control. The duty cannot be delegated to the applicant, but information provided in the application can inform the consideration of equality when the authority undertakes its PSED.
Guidance on PSED and Equality Impact Assessment
2.5 The 2010 Act does not specifically require an Equality Impact Assessment to be produced, nor does it define how it should be carried out. The PSED simply requires public bodies to have ‘due regard’ to the requirements of the 2010 Act.
2.6 Guidance for local authorities published by the Government Equalities Office2 confirms that the 2010 does not impose a legal requirement to conduct an Equality Impact Assessment but it emphasises the importance of consciously considering the aims of the PSED in decisionmaking.
2.7 However, many public bodies do choose to prepare Equality Impact Assessments as this enables them to:
▪ Demonstrate due regard for the provision of the Public Sector Equality Duty (PSED);
▪ Identify possible negative effects of decisions on individuals and groups with protected characteristics and plan mitigating action accordingly;
▪ Identify additional opportunities to advance equality within policies, strategies, and services.
Policy
Context
London Policy
2.8 London Plan (2021) Policy GG1 ‘Building strong and inclusive communities’ states that Good Growth is inclusive growth. Part I of this policy states that planning and development should support and promote the creation of an inclusive London to meet the needs of all Londoners, including those with protected characteristics, to ensure all can share in London’s prosperity, culture, community, minimising barriers, challenges and inequalities they face.
Lewisham Policy
2.9 LBS’s Draft Local Plan (2023)3 outlines how the council plan to help the borough “continue to be a welcoming place where the culture of our people, and the unique qualities of local neighbourhoods, is recognised and protected” as highlighted within the council’s vision.
2.10 Strategic objectives referenced in the Draft Local Plan that are of relevance to equality are as follows:
2 Government Equalities Office (2011) Equality Act 2010: Public Sector Equality Duty What Do I Need to Know? A Quick Start Guide for Public Sector Organisations
3 London Borough of Lewisham (2023). Lewisham Local Plan – An Open Lewisham as part of an Open London (Proposed submission document – Regulation 19 stage)
▪ An Open Lewisham as Part of an Open London – sustain and create inclusive neighbourhoods and communities that both reflect and reinforce the diversity and cultural heritage of Lewisham’s people and places and co-ordinating investment in a way that promotes equality of life for everyone and for everyone to enjoy a good quality of life
▪ A thriving local economy that tackles inequalities – strengthening Lewisham’s role in the wider London economy by expanding the local business base, increasing the number and variety of local jobs and business opportunities by making the best use of employment land and providing space suitable for all businesses, and ensuring town and local centres remain the focus for community activity and harness their unique attributes to support growth
▪ Healthy and safe communities – Addressing the wider determinants of physical and mental health and deprivation in an integrated and systematic way to improve the wellbeing of the population and creating environments that encourages and enables people to pursue active and healthy lifestyles irrespective of their age, ability or income,
2.11 A number of Draft Local Plan policies have particular relevance to the aim of reducing inequalities with regards to protected characteristics within the borough, including:
▪ Policy HO3: Genuinely affordable housing
▪ Policy HO4: Housing estate maintenance, renewal and regeneration
▪ Policy HO5: Accommodation for older people
▪ Policy HO6: Supported and specialised accommodation
▪ Policy EC1: A thriving and inclusive local economy
▪ Policy EC4: Low-cost and affordable workspace
▪ Policy EC10: Workplace training and job opportunities
▪ Policy CI1: Safeguarding and securing community infrastructure
2.12 The Lewisham Council Single Equality Framework4 is a strategic tool that is used to assess how the Council promotes equality and fairness through the performance of its functions and the provision of services, setting out what the council has committed to doing to bring equality, diversity and inclusion to the forefront of policy.
2.13 The council’s five main equality objectives are as follows:
▪ To ensure equal opportunities for marginalised and seldom heard communities;
▪ To reduce the number of vulnerable people in the borough by tackling socio-economic inequality;
▪ To improve the quality of life of residents by tackling preventable illnesses and diseases;
4 Lewisham Borough Council, 2020. Single Equality Framework (2020-2024).
▪ To ensure that services are designed and delivered to meet the needs of Lewisham’s diverse population; and
▪ To increase the number of people we support to become active citizens.
Methodology
Approach
2.14 All developments will have a range of impacts, both positive and negative, through their construction and end use. Everyone affected by a development will have some protected characteristics as defined by the 2010 Act, and there will be varying degrees of intersectionality (such as age, race and sex), and people will not all be equally affected. That does not however, necessarily constitute an equality effect.
2.15 To identify which effects are relevant to equality considerations, this EqIA distinguishes equality effects as those that have either a disproportionate or differential effect upon persons who share a relevant protected characteristic compared to persons who do not share it, as explained below:
▪ Disproportionate: there may be a disproportionate equality effect where people with a particular protected characteristic make up a greater proportion of those affected than in the wider population.
▪ Differential: there may be a differential equality effect where people with a protected characteristic are affected differentially to the general population as a result of vulnerabilities or restrictions they face because of that protected characteristic.
2.16 The scale and significance of such impacts cannot always be quantified. Therefore, the consideration of equality effects includes a descriptive analysis of the potential impacts and identifying whether such impacts are adverse or beneficial.
2.17 Equality effects are complex and impacts are difficult to accurately and comprehensively predict. In the context of development, some impacts are inherently more difficult to quantify, or for a planning consent to directly control. For example, some effects may depend on how people respond to a development in the future (e.g. effects of traffic, employment etc), which can only be modelled and forecast, not directly measured in advance. People’s protected characteristics are personal and not always known, and not all of the people who will live near, work in or visit the area in future are already there today. For these reasons, the EqIA can only consider effects that can reasonably be foreseen.
2.18 Any decision taken by a public body may involve a need to consider and balance a range of both positive and negative effects of different types. There may be reasonable mitigation measures that can eliminate or reduce some disproportionate or differential equality effects, but some impacts may not always be avoidable.
2.19 Consideration can be given to whether there are alternative approaches that could alleviate or mitigate the impact of a decision. The PSED is to give due regard to all equality considerations, in accordance with the 2010 Act, and attribute appropriate weight to such considerations. Equality effects should be a consideration in the balance when determining the application, alongside the benefits arising from the Proposed Development.
Scope of Assessment
2.20 The main objective of an EQIA is to provide the local authority with information, with regard to their impact on the protected characteristics identified in the 2010 Equality Act, to inform their decision making.
2.21 There are various ways in which a development could impact individuals and groups with protected characteristics. The consideration of equality impacts can be framed by a series of questions.
Table 2 1 – Assessment Framework
Consideration of impacts
Action Plan
▪ Does it relate to an area where there are known inequalities?
▪ Which groups is the proposal likely to affect?
▪ How significant is its impact?
▪ Identify opportunities for action to be taken to avoid or minimise any negative impacts (Links to Action Plan below)
▪ How did you engage with the affected groups?
▪ What actions can be taken to reduce negative impact?
▪ If the action proposed will not fully mitigate the adverse consequences or if no action is intended explain and justify this.
▪ Can anything further be done to promote equality of opportunity?
▪ Can you undertake further consultation/research if necessary?
2.22 In order to consider the impact of these proposals on equality, a range of information sources have been used including application documentation, baseline analysis (as ser out in the previous section), and discussions with the Applicant and the project team.
2.23 The planning application as a whole provides a significant amount of information and assessment of the potential impacts of the Proposed Development. This EqIA does not seek to repeat the detailed assessment work set out within other planning application documents. It aims to signpost to those aspects of the scheme that have most relevance to the consideration of equality. The assessment of potential equality effects is focused on several key aspects of the scheme, during both the construction and end use drawing on other technical evidence in the application including:
▪ Noise assessment
▪ Air quality assessment
▪ Transport impacts
▪ Access to community facilities
▪ Retail impact
▪ Employment and skills impacts
2.24 Equality impacts are complex and vary by individual, making it difficult to anticipate every possibility. The approach to dealing this constraint is threefold:
a) Baseline assessment of the area, to better understand the local population of residents, businesses, employees and visitors. This can be particularly useful in identifying:
• Sensitive receptors with relevance to protected characteristics
• Population groups who may be disproportionately affected
b) Consultation – both public consultation and surveys, and stakeholder discussions. Consultation responses are analysed to help identify impacts, groups of people, local facilities, or organisations with relevance to protected characteristics.
c) Screening – using the baseline and consultation above, combined with an understanding of the development impacts, and experience of equality impact assessment for development, a framework is used to highlight potential areas of equality impact.
2.25 Table 2 2 sets out the screening framework, highlighting areas of focus. Note this is not an assessment of likely impacts, it is an assessment of which aspects of the scheme the EqIA should review in order to understand whether there may be impacts.
Table 2.2 – Summary of impact screening
Potential Impact
Description of Impact
Decant & relocation
Consultation and Community Engagement
The redevelopment proposals are likely to require the temporary or permanent removal of businesses from the site.
There may be disproportionate or differential impacts with respect to protected characteristics
The 2010 Act’s PSED includes the requirement to have due regard to encourage people with protected characteristics to participate in public life where participation may be disproportionately low.
The consultation and engagement approach will need to aim to be far reaching through the community and where reasonably possible to remove barriers that may prevent people from participating.
Development can cause effects on noise/vibration, air quality and traffic.
Potentially relevant Characteristics
Age, Disability, Race, Sex, Religion or Belief
Age, Race, Sex, Religion or Belief, Disability
Potential actions or mitigation
Engagement with occupiers Decant strategy
Consultation strategy for the proposals, and communication during development.
Amenity During Construction
Access to community uses
Some people may be more sensitive to amenity disruption during the construction period by nature of their protected characteristics.
Some characteristics may be disproportionately represented amongst those in the affected area, including those more likely to be at home during the day, and therefore more exposed to any effects.
Community or other facilities could be affected (eg indirectly by effects on amenity during construction) and may be used disproportionately by people with particular protected characteristics.
Age, Disability, Sex, Pregnancy and Maternity Construction Management Plan, as well as any specific mitigation on noise, air quality and transport.
Design
Retail
Housing
The accessibility of design, including disabled parking, could affect people differentially with respect to their protected characteristics
Change in the town centre may temporarily or permanently change footfall or the retail/services available. This may differentially or disproportionately affect customers or staff/business owners with particular protected characteristics.
The development will increase supply of housing, which may affect people with some protected characteristics disproportionately or differentially.
Age, Race, Religion or Belief, Disability
Age, Disability, Pregnancy and Maternity
Identify sensitive receptors and consider through consultation, EIA and mitigation
Inherent mitigation to be considered through design
Age, Race, Sex Retail surveys / assessment. Management during construction. Design and operation
Age, Race Tenure mix
3 Local Context
3.1 This section of the EqIA provides relevant baseline information in relation to protected characteristics, to understand who may be affected by the proposed development. It informs an understanding of who may be affected disproportionately, on account of their representation locally.
Site Baseline
3.2 The site is in Lewisham Central ward and is also close to Blackheath Ward. The shopping centre is home to a range of occupiers, including national, larger retailers such as Sainsburys, M&S, TK Maxx and JD in addition to smaller independent units.
3.3 Lewisham Shopping Centre is at the heart of Lewisham town centre, which is the largest, most important town centre within the Borough and is a key focal point, serving a diverse catchment of residents
3.4 The centre also benefits from excellent public transport accessibility and is well connected to both Central London and Kent As stated in the Draft Local Plan, the centre is currently undergoing significant transformation aiming to becoming a metropolitan centre
3.5 Within the Shopping Centre, there are a total of 52 leased retail units, including shops and other smaller kiosks. There are also five food and beverage units, and three units temporarily used for community & culture, which include the Bank of Things, Circle Collective, theMigration Museum and the Toy Library.
3.6 In addition to the shopping centre, the Site also includes some of the retail units along the high street. The town centre is home to various occupiers that serve the Black and Asian communities including halal butchers, hairdressers and beauty supply stores.
3.7 Lewisham Street Market (outside the application boundary) is also an integral part of the town centre, selling a range of items including fresh fruit and vegetables, flowers, clothing and other household items. This is also well used by the ethnic minority community in Lewisham and is one of the most attractive features of the town centre. The market has existed since 1906 and one of the few remaining markets that operates for 6 days a week within London. Proposals to renovate and upgrade the market are being prepared by LBL and a planning application (LPA ref. DC/24/136236) was approved for the upgrade works in July 2024
Site Context and Source Data
3.8 For the purposes of this assessment, the Local Area has been defined as Lewisham Central and Blackheath wards Where data is not available at the ward level, we have used a best fit of the Local Area using Mid-Layer Super Output Areas (MSOAs)5 . The demographic profile of
5 The Local Area covers the following MSOAs: E02007008, E02000661, E02000659 and E02007009
the Local Area is presented in the context of the wider local authority (LB Lewisham), a best fit of Lewisham Retail Catchment Area6 and regional (London) population profiles. The site, the town centre and the retail catchment area are shown in Figure 3.1.
3.9 A summary of the wards used to collect data for the Lewisham Retail Catchment Area is presented in Appendix A3
3.10 The majority of the data in this baseline is from the 2021 Census7 which provides the most comprehensive overview of demographic data
3.11 In addition to this local resident population baseline, this chapter also looks at:
▪ Survey data on high street businesses
▪ A survey of businesses within the shopping centre itself
▪ A survey of Shoppers using the centre and the High Street
6 Best fit of the Lewisham Retail Catchment Area using 2011 frozen census wards and 2021 census wards 7 ONS, 2021. Census 2021
Figure 3.1 - Site Context
▪ Baseline information on community facilities relevant to equalities in the local area
Population
3.12 Data from the 2021 Census8 indicates a total resident population of 24,600 within the Local Area. When comparing population statistics for Lewisham as a whole between the 2011 and 2021 Censuses, the population is recorded to have grown by 9% which was higher than the rate of growth at the regional level (8%) but lower than the rate of growth across the Lewisham retail catchment area (13%).
Protected Characteristics
Age
3.13 The 2021 Census reported the Local Area to have a higher working age population (16-74) of 80% when compared to proportions in LB Lewisham, Lewisham Retail Catchment Area and London.
8 Office for National Statistics (2021). Census 2021
3.14 The proportion of elderly individuals residing in the Local Area (4%) was equal to the proportion in Lewisham, but slightly lower than the proportions in the Lewisham Retail Catchment Area and London (both at 5%)
Sex
3.15 According to data from the 2021 Census the proportion of female residents was recorded to be 52% within the Local Area which was equal to the proportion within the Retail Catchment Area, higher than the proportion at the regional level (51%) but lower than the proportion in the LBS (53%).
Marriage and Civil Partnership
3.16 Under the Act, a person has the protected characteristic of marriage and civil partnership if the person is married or is a civil partner.
3.17 In the 2021 Census, 56% of residents over 16 in the Local Area were single (having never married or registered a civil partnership) which is slightly higher than proportions in LB Lewisham (53%), London (46%) and the Lewisham Retail Catchment (52%).
Figure 3.2 - Age Structure (Census 2021)
3.18 The proportion of married individuals in the Local Area was the lowest at 30% when compared to the other spatial scales while the proportion of residents that are in a registered same-sex civil partnership, separated or divorced was broadly in line across all spatial scales.
Figure 3 3 - Marital Status (Census 2021)
Widowed or surviving civil partnership partner
Divorced or civil partnership dissolved
Separated, but still legally married or still legally in a civil partnership
Married or in a registered civil partnership: In a registered civil partnership
Married or in a registered civil partnership: Married
Never married and never registered a civil partnership
Gender Reassignment
3.19 The 2010 Act notes that a person has the protected characteristic of gender reassignment if the person is proposing to undergo, is undergoing, or has undergone a process (or part of a process) for the purpose of reassigning the person’s sex by changing physiological or other attributes of sex.
3.20 To be protected from gender reassignment discrimination, one does not need to have undergone any specific treatment or surgery to change from your birth sex to one’s preferred gender. This is because changing your physiological or other gender attributes is a personal process rather than a medical one. You can be at any stage in the transition process – from proposing to reassign your gender, to undergoing a process to reassigning your gender, or having completed it (as per the Equality and Human Rights Commission).
3.21 A person’s sexual orientation includes their sexual behaviour, sexual attraction and sexual identity. Sexual orientation is a Protected Characteristic to allow individuals to choose how to express their sexual orientation without discrimination. This includes discrimination in the provision of, or access to, goods, facilities and services.
Lewisham Retail Catchment Area London Lewisham Local Area Blackheath Lewisham Central
3.22 The 2021 Census set the question “Is the gender you identify with the same as your sex registered at birth?”9 which suggests that 0.41% of the Local Area’s population currently had a gender identity that was different from the sex that they were registered with at birth, which was lower than proportions in Lewisham (0.42%), Lewisham retail catchment area and London (both at 0.46%).
Figure 3 4 - Gender Identity (Census 2021)
Sexual Orientation
3.23 Discrimination towards sexual orientation is possible in various forms including: discrimination arising from one’s self-perceived sexual identity; one’s perceived sexual orientation (discrimination by perception); or one’s links to other individuals and their sexual orientation (discrimination by association)10
9 ONS, 2021. Sex and gender identity question development for Census 2021 [online]: https://www.ons.gov.uk/census/censustransformationprogramme/questiondevelopment/sexandgenderidentit yquestiondevelopmentforcensus2021
10 As per the Equality and Human Rights Commission Guidance
3.24 According to data from the 2021 Census, the Local Area has a lower proportion of straight individuals when compared to proportions at the borough, retail catchment and regional levels. The proportion of Gay or Lesbian individuals within the Local Area (4.0%) is greater than proportions at the district (3.0%), retail catchment area (3.1%) and regional (2.2%) levels The proportion of individuals that identify as being bisexual was also greater in the Local Area (2.5%) when compared to proportions in Lewisham, Lewisham retail catchment area and London (at 2.3%, 2.0% and 1.5%, respectively).
Race
3.25 Under the Act, Race includes
▪ Colour;
▪ Nationality;
▪ Ethnic or national origins.
3.26 The 2021 Census shows the Local Area (42%) to have a larger proportion of non-white residents when compared to the Lewisham Retail Catchment Area (38%), but a lower proportion of ethnic minority individuals than LB Lewisham (49%) and London (46%) Black individuals account for the largest ethnic minority group in Local Area (19%), with this proportion being greater than proportions for both Lewisham Retail Catchment Area (11%) and London (14%)
Figure 3 5 - Sexual Orientations (Census 2021)
3.27 The proportion of mixed-race individuals was equal across London and the Lewisham Retail Catchment Area both at 6%), which was slightly lower than proportions in the Local Area and Lewisham (at 7% and 8%, respectively).
3.28 When assessing the birth country of local residents, the 2021 Census, 61% of residents in the Local Area were born in the UK, which was lower than the proportions in LB Lewisham (64%) and the Lewisham Retail Catchment Area (65%) but marginally higher than the regional average (59%).
3.29 The proportion of individuals born in Africa ranged between 7-8% across the different spatial scales while the proportion of individuals born within the Middle East was 9% in the Local Area which was higher than the proportion in LB Lewisham and the Lewisham Retail Catchment Area (both at 6%), but lower than the proportion in London (13%) This data is presented in Figure 3.7.
Figure 3.6 - Ethnic Groups (Census 2021)
Religion and Belief
3.30 Under the Act, religion and belief refer to:
• Any religion - and a reference to religion includes a reference to a lack of religion.
• Any religious or philosophical belief - and a reference to belief includes a reference to a lack of belief.
3.31 In the 2021 Census, just over half of the Local Area’s population (52%) identified themselves as being religious, which was lower than proportions at the district, retail catchment and regional levels (at 56%, 55% and 66%, respectively).
3.32 The largest religious group within the Local Area was Christianity, with 41% of the resident population identifying themselves as being Christian in the Local Area, which was equal to the proportion at the regional level (41%), but lower than proportions at the retail catchment area (42%) and the district (44%) levels.
3.33 The proportion of Muslim residents in the Local Area is 6%, which was also lower than proportions across in LB Lewisham, Lewisham Retail Catchment Area and London (at 7%, 7% and 15%, respectively).
Figure 3.7 - Country of Birth (2021 Census)
3.34 There are a total of 16 religious buildings/facilities that fall within 1km of the Site including St John’s Church, Lewisham Methodist Church, Lewisham Islamic Centre and St Margaret’s Church. A detailed list of religious sensitive receptors is set out within the ‘Community Infrastructure’ section of this chapter
Disability
3.35 Under the Act, a person has a disability if they have a physical or mental impairment, and that impairment has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities.
3.36 The 2021 Census asked residents to carry out a self-assessment of their general state of health. Residents were asked whether their health was ‘very good’, ‘good’, ‘fair’, ‘bad’, or ‘very bad’. In the Local Area, 55% of residents reported their health to be “very good” which was higher than proportions across all spatial scales. Despite this, the proportion of residents in the Local Area with “bad” or “very bad” health” was equal to proportions at the district, retail catchment area and regional levels (all at 4%).
Figure 3.8 - Religious Groups (Census 2021)
Figure 3.9 - Self-Reported Health (Census 2021)
3.37 The 2021 Census also collects data on disabilities and the extent to which these disabilities have an impact on people carrying out various day-to-day activities. According to the 2021 Census, 13.1% of the Local Area’s residents were reported to be disabled under the quality act and have their day-to-day activities limited a little or a lot, which was lower than proportions in Lewisham (14.4%), Lewisham Retail Catchment Area (13.9%) and London (13.2%).
Table 3.1 - Long-term health problem or disability (Census 2021)
Long-term health problem or disability, 2021 Census
Disabled under the Equality Act: Dayto-day activities limited a lot
Disabled under the Equality Act: Dayto-day activities limited a little
Not disabled under the Equality Act: Has long term physical or mental health condition but day-to-day activities are not limited
Not disabled under the Equality Act: No long term physical or mental health conditions
3.38 In addition, the Annual Population Survey 2023 estimated the percentage of people to who are “Equality Act Core Disabled” in LB Lewisham to be 19.7% which was lower than proportions in London (19.8%) and England (24.2%)11 Equality Act Core Disabled includes those who have a long-term disability which substantially limits their day-to-day activities. This statistic is self-reported.
3.39 The Blue Badge (Disabled Persons’ Parking) Scheme was introduced in 1971 under Section 21 of the Chronically Sick and Disabled Persons Act 1970 (‘the 1970 Act’). The aim of the scheme is to help people with severe mobility problems caused by visible and non-visible (‘hidden’) disabilities to access goods and services, by allowing them to park close to their destination.
3.40 The scheme is open to eligible people irrespective of whether they are travelling as a driver or as a passenger. Blue Badge Statistics data is currently unavailable at the local ward or local authority level but statistics for 2021 show that 2.7% of the London population holds a Blue
11 ONS, 2023 Annual Population Survey.
Badge, which was the lowest proportion when compared to all other regions in England. As of the 31st March 2021, 247,000 of London’s residents were recorded to hold a blue badge, which was 0.9% higher than the figure recorded in March 202012
Pregnancy and maternity
3.41 There are no detailed statistics on the number of local people who are pregnant at any one time. The ONS publish data on general fertility rates, which is the number live births per 1,000 women of reproductive age, 15 to 44, in a population, per year. The latest available data shows that in 2021, the general fertility rate in LB Lewisham was 52.8, which is close to the rate across London of 52.7.
3.42 Ward level data on general fertility rates is not available so we have used live births per capita as a proxy variable for this indicator. The latest data on live births per capita at the ward level was published in 2019. This dataset suggests that in 2019, there were 0.015 births per capita compared to a marginally lower rates per capita in Lewisham (0.014) and London (0.013).
Cross-cutting themes
3.43 There are two cross-cutting themes which are not protected characteristics, but which can be closely linked to protected characteristics, in some ways through a causal relationship. These are health and employment. For example, race (specifically being from black and other minority ethnic groups) has been linked to poorer health outcomes in the UK, and discrimination against people with any protected characteristic can affect their employment and economic outcomes.
3.44 The links between socio-economic inequality, poor health and Protected Characteristics are complex and causation is, in many cases, not direct or clear. However, there is sufficient spatial overlap between deprived areas and areas with high proportions of people with certain Protected Characteristics, particularly BAME residents, for effects on health and socioeconomic inequality to be relevant to the consideration of differential or disproportionate effects on people with those characteristics. These cross-cutting themes capture some of the intersectional effects of equality, where combinations of protected characteristics can contribute towards disadvantage.
Health
3.45 The Marmot Review (10 Years On) (2020)13 sets out that evidence shows stalling of life expectancy gains and a widening of the gap in health and wider societal inequalities.
3.46 It states that, “Intersections between socioeconomic status, ethnicity and racism intensify inequalities in health for ethnic groups. Some groups, notably individuals identifying as Gypsy
12 ONS, 2020, Blue Badge Scheme Statistics
13 Marmot, M., Allen, J., Boyce, T., Goldblatt, P., Morrison, J. (2020). Health Equity in England: The Marmot Review 10 Years On. Institute of Health Equality.
or Irish Traveller, and to a lesser extent those identifying as Bangladeshi, Pakistani or Irish, stand out as having poor health across a range of indicators”14
3.47 The majority of local air pollution arises from road transport, which disproportionately affect deprived areas, thus widening inequalities. The review also draws a clear link between housing quality and housing affordability and health, particularly noting that 21% of adults in England statethat a housing issue impact their mentalhealth negatively; 1.9 million people report issues with mould, damp or condensation in their homes; increases in costs both across the private and social rental sectors; and homelessness rates having increased by 74% since 2010.
3.48 Office for Health Improvement and Disparities (OHID) data15 shows Blackheath ward to have a higher life expectancy at birth for women (87.3 years) when compared to Lewisham Central, LB Lewisham and London. For males, life expectancy within Lewisham Central (78.0 years) was also lower than life expectancies recorded at the district and national levels (at 79.0 years and 79.5 years, respectively), while Blackheath ward had the highest life expectancy (81.2 years), highlighting the discrepancies in health within the Local Area.
3.10 - Life expectancy (OHID)
expectancy (years)
Life expectancy (males) (2020) Life expectancy (females) (2020)
3.49 When looking at under 75 mortality rates for all causes considered preventable, cardiovascular disease, cancer and respiratory diseases, Lewisham was recorded to have higher mortality rates per 100,000 than both the regional and national levels, highlighting the need for
14 Marmot, M., Allen, J., Boyce, T., Goldblatt, P., Morrison, J. (2020). Health Equity in England: The Marmot Review 10 Years On. Institute of Health Equality. p.23
15 Public Health England, 2021. Local Health. Available at: https://fingertips.phe.org.uk/profile/local-health
Figure
Lewisham Central
Blackheath Lewisham England
healthcare intervention within district area. The highest under 75 mortality rates were recorded to be for all causes considered preventable and cancer, where rates in Lewisham reported to be 158.7 per 100,000 and 131.4 per 100,000, respectively.
Employment and economic activity
3.50 People with some Protected Characteristics are typically disproportionately represented in terms of barriers to accessing work, skills and qualifications, due to issues including racial discrimination, language or cultural factors, family requirements and the need for flexible and/or part-time work. Young people, older people, family carers and ethnic minorities tend to have disproportionate challenges accessing employment because of such issues, and there can be intersectional effects across multiple protected characteristics
3.51 Data from the Census 2021 shows that the Local Area had a higher rate of economic activity (70%) when compared to both LB Lewisham, Lewisham Retail Catchment Area and London (at 67%, 61% and 64%, respectively). The high economic activity rate within the Local Area is driven by an economic activity rate of 73% in Lewisham Central ward.
3.52 The rate of unemployment (as a proportion of the economically active population) was 7.2% within the Local Area, which was greater than rates across London (6.4%) and the Lewisham Retail Catchment Area (6.1%), but slightly lower than the rate in Lewisham (7.3%)
3.53 Claimant count data provides the most recent information on the number of people claiming unemployment-related benefits in a particular spatial area, which includes Jobseekers’
Figure 3 11 - Economic Activity and Unemployment (2021 Census)
Allowance and Universal Credit. The count is calculated for all working age residents aged between 16 and 64 years. This dataset is unable to capture all unemployed individuals as some local residents may not claim these benefits or may be ineligible
3.54 The most recent claimant count data available is for July 2024. This indicates a claimant rate of 5.6% in the Local Area which is lower than rates in both Lewisham (7.0%) and London (6.0%).
Deprivation
3.55 While deprivation and unemployment are not classified as protected characteristics under the 2010 Act, this baseline analysis considers levels of deprivation due to its intersecting nature with different protected characteristics.
3.56 The Government’s Index of Multiple Deprivation (2019)16 combines indicators, including a range of social, economic, and housing factors, to yield a deprivation score for all areas across England (Lower Layer Super Output Areas [LSOAs]). There are seven domains of deprivation that are investigated:
▪ Income deprivation
▪ Employment deprivation
▪ Education, skills, and training deprivation
▪ Health deprivation and disability
▪ Crime
▪ Barriers to housing and services
▪ Living environment deprivation
3.57 All areas are ranked relative to one another according to their level of deprivation. Figure 3.12 shows the relative levels of deprivation surrounding the site – areas shown in red are within the 10% most deprived, areas in orange are within the 10% - 20% most deprived and areas in yellow are within the 20% - 30% most deprived.
3.58 As shown within Figure 3.12, the site boundary falls within a LSOA that is amongst the top 10% - 20% most deprived areas in England. There are also various areas directly to the south of the site that fall amongst the top 10% most deprived areas in England.
3.59 Lewisham has a rank of average score of 49, indicating that this is the 49th highest level of deprivation when compared to the other 317 local authorities in England.
16 Ministry of Housing, Communities & Local Government: The English Indices of Multiple Deprivation 2019
3.60 The deprivation within the LSOA that the site falls within and the other surrounding areas is driven by deprivation relating to crime and living environment, with the LSOA that the site falls within falling amongst the top 10% deprived areas in England.
3 12 - Indices of Multiple Deprivation
High Street Survey
3.61 Lewisham Council undertake an annual independent high streets business survey17, where census level outcomes for ethnicity and a headcount of independent business owners are requested for the defined high street locations which included Lewisham Town Centre, Catford Town Centre, Deptford High Street, New Cross Road, Blackheath, Sydenham, Forest Hill, Crofton Park and Honor Oak.
3.62 The latest survey data suggests that independent businesses continue to be the backbone of Lewisham high street, constituting 63% of the traders along Lewisham High Street.
17 London Borough of Lewisham (LBL), 2023. Lewisham High Streets Survey
Lewisham
Figure
3.63 The cultural diversity and richness of the high street offer within Lewisham is also driven by ethnicities of business owners, with a survey of employees along the high street showing that 74% of the businesses along the high street are owned by Black, Asian or Minority Ethnic individuals. Since the last headcount in 2021, the number in Black, Asian and Minority ethnic ownership in Lewisham Town Centre had reduced by 4%, which contrasted with the collective 5% increase in Black, Asian and Minority ethnic ownership across the 9 high street locations.
3.64 When exploring business-owner characteristics within Lewisham’s high streets, survey data suggests that
▪ the majority of independent high street businesses are well established with over half of the businesses having existed for over five years
▪ employment generation for these businesses is strong with over quarter of surveyed businesses employing between four to six people; and
▪ Lewisham is a highly rated place to do business with 70% of the surveyed businesses agreeing that this is the case
3.65 The applicant undertook a survey of shoppers in 2024 (within the centre itself, and on the High Street), detailed further in the Town Centre Assessment Study report. This included questions relating to protected characteristics, which revealed that:
▪ Shoppers were disproportionately female (65%), although this was less marked in younger age groups (52% amongst 18-34 year olds).
▪ Less than 9% said they had a long term illness or disability that limited their daily activity (a low level of disability relative to the borough or London population)
▪ 8.7% of respondents were aged 65 or older (note that under 18s were not surveyed)
▪ 37% of respondents identified as Black, a high proportion relative to the borough or London.
Shopping Centre occupier survey
3.66 Quod also produced and ran a survey for all current occupiers of the Shopping Centre. The survey included questions on
▪ employment (both full-time and part-time)
▪ whether businesses work with local employment or training providers;
▪ existing relationships with local organisations that provide support for small businesses; and
Lewisham Shopper Survey
Lewisham
▪ whether there were any specific concerns that occupiers wanted to raise as a result of the Proposed Development in relation to protected characteristics or equality.
3.67 The survey was sent to the occupiers on via email, using a list of email with follow-up reminders via email and telephone. Reponses were received from 30% of businesses or organisations occupying space in the shopping centre.
3.68 When assessing the final results, 19% of the occupiers that had responded to the survey reported that they work with local employment or training providers - including the Circle Collective, Lewisham College and Christ the King College.
3.69 Other activities reported by respondents included work with Goldsmiths Synapse (which provides a programme of workshops and business development support for students to explore entrepreneurial tools), Lewisham Local and the Retail Trust, who are responsible for caring and protecting the lives of people working in retail.
3.70 Comments received in relation to protected characteristics as a result of the Proposed Development were as follows:
▪ The importance of accessibility for visitors. The need for free public spaces for individuals with both physical and mental disabilities, while it was also highlighted that individuals with SEND, and young people (14-21) could be better supported within the Local Area with a space to relax and socialise without the pressure of having to purchase something.
▪ The importance of ensuring that the venue remains both accessible and inclusive for all, with key considerations including accessibility for people with disabilities, inclusivity of different age groups (particularly families with children) and ensuring that facilities continue to accommodate diverse cultural and religious needs.
3.71 In addition to this, over 30% of the respondents to the survey reported that they currently employee one or more employees with a substantial or long-term disability.
Community Audit
3.72 Some community infrastructure is disproportionately used by people who share a particular protected characteristic. Therefore activity that may affect those community facilities, such as amenity disruption during construction, could have disproportionate equality effects.
3.73 Figures 3.13 - 3.19 show community infrastructure in the area surrounding the site. These include facilities relevant to age (nurseries, schools, playgrounds, care homes) and religion (places of worship). It also includes facilities such as health centres and community centres, that could have relevance to a wide range of protected characteristics, including age, sex, disability, pregnancy.
3.74 Note that mapping of community infrastructure is indicative, and may not always be complete. The focus has been on those community facilities with a direct relevance to a particular protected characteristic, such as Age or Religion, rather than those that serve the wider
community. Data sources may be fragmented, facilities open or close regularly, and there are also no clear legal definitions of, for example, places of worship, which may be formal or informal. The purpose of the mapping here is to illustrate the overall likely range of neighbouring uses that should be taken into account.
Table 3 2 - Primary and Secondary Schools within 1km of the Site
Figure 3 13 - Primary and Secondary Schools within 1km of the Site
3.15 - Places of Worship within 1km of the Site
Table 3.4 - Places of Worship within 1km of the Site
Figure
Figure 3.18 - Playspaces within 1km of the Site
Table 3.8 - Pubs and Bars within 1km of the Site
Figure
3.75 In addition to the community facilities listed above, there are a number of shops close to the Site that may be relevant to the protected characteristic of race (and potentially also religion in some cases), by the nature of the products or services offered, and their customer base. These including halal butchers, hairdressers, beauty salons, food stalls and clothing shops. Examples include:
• Muskaan Beauty
• Bilal Fish and Meat Centre
• K&K Food Store
• Shaba Hair and Cosmetics
• M.M Quality Halal Meats
• Ameen Butchers and groceries
• Lewisham Food Market (shop)
3.76 This diversity is supported by the Lewisham High Streets Survey as set out in paragraph Error! Reference source not found.
Summary
3.77 Following this baseline analysis, Table 3 10 summarises whether it is considered likely that protected characteristics will potentially be disproportionately affected by the proposals, due to their disproportionate prevalence in the local population.
3.78 Where differential effects are considered to be relevant these are set out through Section 4 where the potential impacts arising from the scheme are discussed in more detail.
Table 3 10: Groups identified in Baseline for Consideration for Potential Disproportionate Effects
Protected Characteristic
Considered for Disproportionate effects?
Age No
Comments
While the area has a high proportion of working-age residents (and fewer children and elderly), the economic data suggests working age is not in itself a
Protected Characteristic
Considered for Disproportionate effects? Comments
group experiencing inequalities and is not considered a likely significant equality effect.
Disability No
Gender reassignment No
Marriage & civil partnership No
Pregnancy and maternity No
Race Yes
Religion or belief No
Sex Yes
Sexual orientation No
The data does not suggest the area has a significantly disproportionate number of people with disability or long-term limiting health
The data does not suggest the area has a significantly disproportionate number of people identifying with a gender different from their sex registered at birth.
The area has a relatively low proportion of people who are married or in a civil partnership. Application of the legislation to this protected characteristic primarily relates to discrimination only.
The data does not suggest a disproportionate number of births in the area.
The baseline data, including surveys, suggests that the local population, businesses in the town centre, and shoppers may have a high proportion of ethnic minorities, particularly Black people, which may result in disproportionate effects in relation to race
The local area is diverse in terms of religion, although broadly in line with Lewisham and London in this respect
The population does not have a particularly disproportionate balance of sexes. However survey data suggests the users of the shopping centre and High Street are disproportionately female.
While the local area has a relatively high proportion of people identifying as gay, lesbian or bisexual, the wider retail
Protected Characteristic
Considered for Disproportionate effects? Comments
Community infrastructure Yes
catchment area has a lower proportion than the borough as a whole.
There are a number of community facilities in the area that may be disproportionately used by people with particular protected characteristics, which need to be considered for equality effects. These include schools, playgrounds, nurseries and care homes (age), places of worship (religion), healthcare and care homes (disability)
3.79 Disproportionate effects are not specific to particular protected characteristics, but are felt generally by the population, which may include a disproportionate representation of particular protected characteristics.
3.80 For that reason, mitigation of harmful disproportionate effects (or enhancement of positive disproportionate effects), is not specific to protected characteristics, but to the scheme effects themselves. For example, if one group is disproportionately affected by noise, then noise mitigation will disproportionately benefit them, even if not specifically targeted at them.
3.81 Note this table considers only disproportionate equality effects. Potential differential equality effects are considered in Section 5.
4 Community Engagement and Consultation
4.1 When considering equality impacts related to estate transformation projects, occupier engagement and community consultation is of particular importance. The PSED requires public bodies to have due regard to encouraging people with protected characteristics to participate in public life. In the context of this project, people’s ability to engage with the development plans, raise any concerns or views and provide feedback on the plans is particularly relevant.
Scope of consultation
4.2 The Applicant has undertaken various rounds of consultation with the existing occupiers and the wider local community over the last four years. Key bodies that were consulted throughout the design process include:
▪ Lewisham Council;
▪ Greater London Authority;
▪ TfL
▪ Metropolitan Police;
▪ Environment Agency;
▪ Historic England;
▪ Greater London Archaeology Advisory Service; and
▪ Quality of Life Foundation
4.3 Through collaboration with Lewisham Council, Landsec were able to consult and engage with a wide range of departments including planning, transport, housing, heritage, landscape, flood risk, energy/sustainability and design review panel.
4.4 As highlighted within the Statement of Community Involvement, Something Collective developed a creative and responsive engagement strategy that reflected and amplified both the Applicant’s and the communities’ aspirations for the Site. As a result of this approach being centred around uncovering unique insights and solution, the proposals have been subject to a significant design evolution .
Summary of consultation
4.5 Prior to Something Collective developing a creative and responsive engagement strategy, Landsec undertook some initial consultation in Summer 2020 over a six week period. During this period, 10,000 newsletters were sent to the local residents and the wider community providing high-level overview of the initial proposals. In addition to this, contact was made with market traders and 115 community groups, while two ‘Virtual Village Halls’ were held.
4.6 The next round of consultation in 2021 included a public exhibition where new proposals were introduced that took concerns around the scale of the proposals, the need for a covered shopping centre experience, increased publicly accessible green space and better connections through the site into account. This round of consultation saw the creation of ‘Common Place’ which encouraged the local community to engage with the proposals as well as in person at consultation exhibition events. Within this round of consultation, 116 feedback forms were received while monthly meetings were held with Lewisham Town Centre Consultation Group and Circle Collective started to engage with young people.
4.7 Within the final round of consultation, the Applicant sought to re-establish the principles of the project to reflect the community feedback received within the initial rounds of consultation.
4.8 Within Stage 1 of this round of consultation, a number of local groups that offer provisions to elderly, youth, NEET (not in employment, education or training) youth, youth from an ethnic minority background, special needs youth and individuals working, living, and using the shopping centre were contacted to provide insights into their respective organisations by taking part in workshops organised by the applicant (e.g. Young Lewisham, Migration Museum, Youth First, The Pensioners Forum, Lewisham Local and BlueprintForAll).
4.9 Other consultation events that took part within Stage 1 of this round of consultation are as follows:
▪ Lewisham People’s Day - a large-scale pop up was held to ask festival-goers about delivering new community social infrastructures in the new Shopping Centre development proposals, in addition to questioning attendees on the need for key facilities such as affordable food spaces, music, spaces for performance, and learning and skills sharing with the Local Area;
▪ Creating A New Community Building Workshops – two interactive workshops with young people from the Circle Collective and with civic & community organisations were held in August and September 2022, to enable the Applicant to understand the needs of underrepresented groups for a new community building;
▪ Lewisham Living Room Pop-up – interactive space set up in the atrium of Lewisham Shopping Centre to provide users of the shopping centre to share memories of people, place and events in Lewisham, as well as aspirations for the future which enabled the Applicant to gain a deeper understanding of Lewisham’s character, identity and what communities wanted to preserve
▪ Design Champion Sessions – a small group of local residents were selected to be the ‘design champions’ to co-create design ideas that are reflective of everyday experiences of the town centre, showcase/test thinking ahead of sharing ideas with the public and to evaluate changes in the project to strengthen final design proposals. The Applicant held sessions with the ‘Design Champions’ on the town centre, movement through the town centre and public realm.
4.10 Key findings after this stage of consultation were as follows:
▪ A greener Lewisham – more nature and greenspaces to soften the hardness of the urban environment of Lewisham Town Centre, increased space for rest and better wellbeing;
▪ A better connected town centre – more attractive and safer routes for cyclists and pedestrians, improved and more disability provision and increased, comfortable seating
▪ A Lewisham rooted in heritage and culture – increased quantity of cultural spaces, art/events that celebrate different cultures and accessible, intergenerational spaces;
▪ A Lewisham which looks out for one another – more lighting, surveillance and active frontages to make people feel more safe and secure, investment in public/social spaces and more spaces for children to play
▪ A Lewisham with everything you need – more local and independent stores, an improved community retail destination feel to Lewisham and a more diverse shopping experience
4.11 Stage 2 of this round of consultation, the engagement approach focused on workshops with the ‘Design Champions’ on meanwhile uses and the emerging vision, and focus groups with specific demographical groups such as young people, women, older people and those with disabilities to evaluated concepts such as public realm, movement and accessibility, and community services. The key considerations at this stage of engagement included participants wanting to see a new shopping centre with greenspaces, better defined access routes through the shopping centre, an improved food and beverage offer in the town centre and more opportunities for culture, entertainment and play in the town centre
4.12 Stage 3 of this round of consultation was characterised by exhibiting the masterplan to the general public to collect wider feedback on the proposals and to gain a deeper understanding of the themes that were important to the community. The first public exhibition detailing the designs and plans for Lewisham Shopping Centre was held in November 2023 at Unit 25. Over 1,200 residents, businesses and other stakeholders attended the exhibition, with 154 feedback forms being received. Session were also held with the ‘Design Champions’ regarding the Northern Square on the event space proposal, seating, design and placement, types of nature/greening set to be introduced and types of water infrastructure.
4.13 Key considerations from this stage of consultation included a replacement model market being reincorporate into the scheme, the introduction of new public spaces to connect the south end of the masterplan (the Southern Quarter), the introduction of a music and community venue in the Southern Quarter and the retention of buildings on the High Street.
4.14 The final stage of engagement built on public feedback on the masterplan proposals by drawing out key elements of interest, presenting updated redevelopment plans, addressing any new concerns or suggestions from residents/stakeholders, strengthening community support and ensuring that the public were fully briefed and informed. Thematic workshops were also held based on feedback received on particular themes following the public exhibition, aiming to gather diverse perspectives and refine ideas that respond to challenges and opportunities identified in the redevelopment of the shopping centre. The workshops were as follows:
▪ A Green Space Like No Other – exploring the design and use of the proposed green spaces, with attendees analysing different types of planting and biodiversity, event spaces, accessibility and spaces for wellbeing and play through table-top exercises;
▪ Reflecting Community Heritage - focused on ways the project can reflect the borough’s diversity in the town centre, through food and retail offer, design in public spaces and community facilities;
▪ A Town Centre for All – focused on ensuring that all communities can benefit from the new facilities, amenities and night-time venues that the Proposed Development is set to provide, exploring the different types of food, retail and community facilities the masterplan could provide
4.15 The second public exhibition relaunched the masterplan from May 2024 to June 2024, including information on the main changes since the last exhibition, new public spaces and connections, and designs of the new music venue after discussions with local group Sister Midnight. In addition to this, the Applicant also ran workshops on designing for neurodiversity and ‘DJ 101 with Sister Midnight’ on Young Women and Gender Diverse people.
4.16 Engagement feedback from this stage of consultation was as follows:
▪ Green Spaces Like No Other – need for good management and maintenance of new public spaces, more detailed plans on shading and seating to make social spaces userfriendly and landscape designs that mitigate against extreme weather conditions
▪ New Residential Buildings – more community-oriented spaces and increased social housing and affordable ground-floor retail spaces
▪ Providing Infrastructure to Meet Local Needs – need for more clarification of managing public spaces and more public facilities such as toilets and drinking fountains
▪ Championing Local Businesses and Culture – need for commitment to supporting local businesses, including financial investments, retail rent caps, and startup funds, with a focus on representing ethnic minorities, and ensuring a portion of the retail spaces are allocated to Lewisham-based businesses
▪ A Town Centre for The Future – dedicated spaces and activities for young people, maintaining public spaces and ensuring they are accessible to all and increased affordable retail, food, and entertainment options that cater to both current and new residents while promoting community ownership and engagement
Impact on Protected Characteristics
4.17 As highlighted above, the Applicant has undertaken various rounds of consultation with the existing occupier andthewider local community which has included a virtual consultation which comprised a description of proposals in key themes, public exhibition events and an information line and email. Full details of the consultation approach are set out within the Statement of Community Involvement.
4.18 The fact that there was a virtual consultation as well as in-person consultation events can help reach groups who may be less likely to attend public events. The virtual consultation process meant that individuals were able to engage at their own leisure, which ensured that individuals with different lifestyles and work patterns were able to engage effectively.
4.19 As well as the virtual consultation, other events and materials distributed through the consultation process included a website, a newsletter, online surveys, emails and phone calls, to maximise reach and ensure people of all ages, levels of literacy and access to the internet/ computers could participate.
4.20 The consultation and engagement approach taken by the Applicant has aimed to be as far reaching through the community and to remove barriers that may prevent people from participating, where reasonably possible.
4.21 Therefore, the approach taken is considered to have a positive impact upon engagement by people protected characterises including Age, Sex, Race, Disability and Religion or Belief.
5 Equality Effects
Scope of Effects
5.1 Section 3 looked at the local context – the local population, businesses, community facilities, and shoppers – which principally determines which protected characteristics may be disproportionately affected by the proposals, due to these characteristics being disproportionately represented in the local area.
5.2 This section looks the effects of the development itself, which also influences which protected characteristics may be differentially affected because of the way that changes resulting from the proposals may interact with those protected characteristics themselves. This can include:
▪ People with restricted mobility, or other disabilities, who may therefore be more sensitive to some changes (this may include a range of protected characteristics, such as Disability, Age, and Pregnancy and Maternity)
▪ People whose lifestyle means they are present at home in the area for more time during the day, and may therefore be more exposed to any effects (data on individuals is not available, but this may correlate with protected characteristics such as Sex, Disability and Age).
▪ Users of community infrastructure serving people with particularly protected characteristics
5.3 Table 2 2 in the methodology section set out the screening of potential effects. Based on a review of the proposed scheme, with the exception of Consultation and Community Engagement (covered in Section 4), the range of potential effects identified to be considered for equality implications are :
• Construction phase, including
o Decant and relocation
o Amenity and disruption during construction
o Access to community facilities
• Completed phase, including
o Design
o Retail
o Housing
o Employment
5.4 An overview of this is set out below, although some details may be determined and assessed later, for example through individual RMAs or as a consequence of mitigation agreed through the S106 process
5.5 This section will contain a summary of the project effects relating to the development, covering the aspects listed in Paragraph 5.3
Construction Phase Effects
Decant and Relocation
5.6 As highlighted within the ES Volume 1, Chapter 5: Demolition and Construction, the indicative phasing is split into three main phases, starting at the north of the Site before undertaking the second phase to the south of the Site. The phasing is as follows:
▪ Phase 1a (Plot N1, N2, Northern Square and Music Venue Refurbishment): Within this phase, 86 – 102 Lewisham High Street will be demolished with the eastern half set to remain as an existing town centre and residential use, and the western side (Riverdale Hall, the Leisure Box and Boots) to be demolished to allow for a construction zone and the service yard for Plot N1. In addition, a new shopping centre entrance will be created at the south of the northern square including a retail entrance, while the existing building at the south of the Site will be refurbished to include music venues and workspaces for creative industries;
▪ Phase 1b (Plot N3 and Northern Square Completion) – The northern core of Lewisham House will be demolished, the main construction works for Plot N3 will commence and a new temporary route through Molesworth Street will be created between Plot N3 and the retained car park.
▪ Phase 2a (Plots S1, S2 and permanent southern ramp) – The southern parts of the multi-storey car park will be reduced to allow for the construction of Plot S1 and a new southern ramp, while the shopping centre’s southern entrance will also close for Phase 2a construction of Plots S1 and S2.
▪ Phase 2b (Part 1)(Plot S3 and temporary entrance to south of shopping centre) –Plot S3 will be constructed and the permanent public area for the east-west route connecting to the high street to Molesworth Street will be built, enabling a temporary entrance to the south of the of the shopping centre
▪ Phase 2b (Part 2) (Plots S4 & completion of Phase 2 public realm) – Plot S4 will be constructed and the Phase 2 public realm works will be completed with the creation of Model Market Square and improvements to the rear of the existing Primark building
▪ Phase 3a (Plots C1, C2 and the Eastern Terrace) – A hoarding line will be placed along the western edge of the existing concourse to ensure that shopping centre continues to operate while the eastern portion of the Site will be demolished. The western portion will operate with the new northern and southern temporary entrance and the existing western entrance. Plots C1, C2.1 and C2.2 will be constructed.
▪ Phase 3b (Plots C3, C4, C5 and Level 02 podium park) – the western part of the shopping centre will be re-built while the new eastern area is in operation, with Buildings C3, C4 and C5 to be constructed from south to north. Permanent entrances will be built
at the north and south ends of the shopping centre. The level 02 podium park will be constructed, followed by the remaining portion of L01 street.
5.7 During the ten-year construction period, decanting and relocation of retail businesses within the shopping centre has the potential to temporarily reduce footfall for some businesses (within the shopping centre, or elsewhere on Lewisham High Street or the market), and cause some shoppers to divert elsewhere. This is not quantifiable at this stage, as it will depend on individual agreements reached with each retailer as the detailed and outline stages progress. As noted in Section 3, because of the nature of the businesses and shoppers, this has potential for disproportionate effects in relation to the protected characteristics of Sex and Race.
5.8 Pharmacies can be particularly important to people with some protected characteristics, (Age, Disability, Pregnancy and Maternity), however, any effects of the decant on the pharmacy in the shopping centre are likely to be minimal given the availability of nearby alternatives, and the fact that an agreement in principle has been made for relocation of Boots within the centre. Other pharmacies within 1km of the Proposed Development include Sheel Pharmacy to the south of the Site, Ladywell Pharmacy to the south-west of the Site and Day Lewis Pharmacy to the north-west of the Site.
5.9 The post office hosted by WH Smith within the centre is closing (unrelated to the proposed development) as WH Smith is not renewing their lease. There are a number of other post offices remaining nearby, and the applicant remains open to the existing franchisee or others interested in operating acounter within the newly redeveloped shopping centre. Notethat since the national closure of Post Office Card Accounts, Post Offices no longer play the same role in the benefits and pensions system, which had been particularly relevant to some protected characteristics.
5.10 There will also be disruption to business owners and employees directly affected by the decant, and in some cases it is possible that these may not be retained in Lewisham. Within the overall churn of the labour market, and the retail lettings sector, many alternatives for employees and business owners are likely to be available. However for those facing barriers to employment (directly or indirectly related to protected characteristics such as Age, Disability or Race), fewer alternatives may be available.
5.11 To mitigate such effects, as highlighted within the indicative phasing plans, the overarching phasing strategy is based around ensuring that the shopping centre is open in some capacity throughout the building process. As the redevelopment progresses, the completion of earlier phases (and the benefits from new retail, improved access and environment, and additional residents on site), may tend to provide a countervailing benefit to retail footfall.
5.12 There is existing vacant floorspace available for relocation, and over time more vacancies will arise as a result of natural churn in occupations, and additional new retail and other commercial space will also become available as each sub-phase completes. This, and the division of the phasing into sub-phases, will increase the opportunity for businesses to relocate within the centre as work progresses. The applicant also proposes to offer free agents’ advice to independent retailers that wish to relocate elsewhere.
Amenity and Disruption during Construction
5.13 Amenity disruption can potentially happen during construction or on completion. The demolition and construction programme is expected to take up to 10 years As set out above, there could be differential or disproportionate effects on people with some particular protected characteristics, in the absence of appropriate mitigation.
5.14 In general, mitigation measures for such effects are not specific to the protected characteristics of those affected, but are instead specific to the effect itself. This means those who might be differentially or disproportionately affected by noise or air quality effects, for example, will also differentially or disproportionately benefit from any mitigation to minimise those effects.
5.15 Technical air, noise and vibration, and transport assessments have been undertaken and presented within the Environmental Statement. In addition, a Health Impact Assessment (HIA) has been prepared to consider any health implications. The results of these assessments are not repeated here, but considerations of how any of these could have a differential or disproportionate effect upon equality, and the measures put in place to minimise or remove any such effects is set out below.
Noise
5.16 The assessment of the noise impacts associated with the construction of the Proposed Development identifies moderate adverse effects – ES Volume 1, Chapter 6: Noise and Vibration. These moderate adverse noise effects may be experienced by residents living at 110–118 Lewisham High Street, Metro Apartments (86-92 and 90-94A Lewisham High Street), 50-70 Lewisham High Street, 161-171 Lewisham High Street and new dwellings within the occupied phases of the masterplan,
5.17 In relation to equality impacts associated with this finding, they could have a differential impact upon residents living in the affected homes who may spend more time at home during the day as a result of their protected characteristics. This could include Age (elderly resident or younger children) or Disability (residents with disabilities that limit their ability to leave the home or disabilities that increase sensitivity to noise).
5.18 Mitigation measures have been proposed in order to reduce or minimise these adverse effects where possible. These measures and best practice means are set out within a site specific Outline Construction Environmental Management Plan (CEMP) that forms part of the Application, and therefore will be material consideration in the decision making process. Some of the measures to mitigate against noise and vibration include using modern and wellmaintained equipment and low impact techniques, in addition to careful material handling and isolating the deconstruction works from sensitive neighbours
5.19 No significant adverse noise effects were identified in relation to the neighbouring or nearby community facilities identified in Section 3.
Air Quality
5.20 Air quality may differentially affect some people with respect to their protected characteristics, which may include Age, Pregnancy and Maternity, and Disability.
5.21 The assessment of the air quality impacts associated with the construction of the Proposed Development highlights that the risk of dust soiling impacts is expected to be high for demolition, construction and trackout, whole the risk of human health impacts are also expected to be high for demolition – ES Volume 1, Chapter 7 : Air Quality.
5.22 The baseline assessment has considered existing residents and local facilities (including sensitive uses from an Equality perspective such at schools), along with the residents of the initial phases of the Proposed Development that would be occupying the first new homes that have been delivered while the later phases are still being constructed.
5.23 Recommended mitigation measures for sites that may be susceptible to adverse dust soiling or human health impacts include good general communication with the local community, site management that ensures that all dust and air quality complaints are recorded and resolved, ensuring that all on-road vehicles comply with the requirements of the London Low Emission Zone and London NRMM standards and avoiding bonfires/burning of waste materials. After mitigation, no adverse air quality effects were identified.
5.24 As outlined within the Outline CEMP, the contractor responsible for the Proposed Development will develop a Code of Construction Practice (CoCP) in relation to construction noise and fugitive dust which will include the types of works to be undertaken, construction techniques being used, site layout/access arrangements, durations of site operations, an inventory of all dust-generating activities and the on-site storage of fuel/chemicals. In addition to this, temporary solid hoardings will be erected along all site boundaries to limit lateral ‘dust’ escape and all vehicle loads entering / departing the site are to be covered and material sprayed with water on all unsealed or exposed areas.
5.25 No significant adverse air quality effects were identified in relation to the neighbouring or nearby community facilities identified in Section 3.
Transport Disruption
5.26 During construction, any temporary or permanent changes to routes to or through the Site may affect some users differently as a result of their protected characteristics, such as those with restricted mobility or adaptability due to age or disability (including sensory impairment, learning disabilities, memory loss or neurodivergence), parents with buggies etc.
5.27 The construction phasing will require some route closures. Closures will rotate around as the construction is phased, including the closure of the northern entrance to the shopping centre in Phase 1A and the closure of the ground floor pedestrian tunnel next to Lewisham House in Phase 1B Alternative routes for vehicle and pedestrian movement will be provided.
5.28 The Construction Logistics Plan (CLP) include details of measures that will be put in place to manage and maintain the site and routes during construction. Measures include the temporary closures and diversions to vehicle routes and footpaths (including a temporary route through Molesworth Street between Plot N3 and the retained car park in Phase 1b), temporary bus stops (to be discussed and consulted on with TfL prior to the Proposed Development), temporary traffic control measures, traffic management procedures for waste disposal vehicles
and off-loading/storage areas. These measures proposed are relevant to some protected characteristics that may be differentially affected by the disruption.
5.29 Where the street is obstructed by activities such as deliveries, partial closures, other hazards, etc suitable signage, ramping etc will be deployed Advance notice will also be helpful where possible. In addition, thesite management team are responsible for keeping the public highway around the construction site clean and free from obstructions. Banksman will be on hand to offer assistance to vulnerable users of the footway.
5.30 The construction phase will also give rise to vehicle movements, When assessing site access and local traffic movements, vehicle access and egress routes have been identified that provide efficient links back to the Transport for London Primary Road Network TfL PRN. In addition to this, deliveries to the Site will be minimised through the adoption of material consolidation centres and a centralised booking system that will reduce impacts on the local road network.
5.31 No significant adverse transport effects were identified in relation to the neighbouring or nearby community facilities identified in Section 3.
Access to Community Facilties
5.32 As set out within the baseline section, some vacant units in the shopping centre are, from time to time, offered on a temporary basis for community uses. Of these, the Migration Museum, Lewisham Toy Library and Circle Collective have been established for some time
5.33 The Migration Museum is a culturally important community facility (relevant to the protected characteristics of Race) that has been given a temporary space within the shopping centre, exploring the movement of people to and from Britain, and how these people have contributed to the wider society The Migration Museum is set to be given a permanent home as part of a mixed-use scheme delivered by Dominus, at 65 Crutched Friars in the City of London, where it will continue to be accessible to a wide audience
5.34 The Lewisham Toy Library (relevant for the protected characteristic of Age) currently offers an affordable and sustainable alternative to buying toys, with children up to the age of 8 able choose from a huge selection of over 4,000 toys and borrow these toys for up to 4 weeks.
5.35 The Circle Collective is a social enterprise that runs a fashion retail store used to give work experience and employment support to young unemployed people. It is relevant to the protected characteristic of Age, but also to wider intersectional characteristics associated with barriers to employment.
5.36 The development aims to retain both the Toy Library and Circle Collective within the shopping centre (if they wish to), and will support them by offering options for relocation within the development.
5.37 The completed development will add two permanent community facilities. Firstly a new cultural arts and music venue to the south of Site. This will open in the early phases of the development helping anchor the evening economy, and will be of particular benefit to young adults. Secondly
a new community building will be created in the open space at the heart of the completed development – options for use of this will be finalised in due course, but community space has potential to benefit people with a range of protected characteristics, including intersectional characteristics.
Operational Phase
Design and Delivery of New Homes
Housing
and Design
5.38 The Proposed Development will deliver 119 homes and 445 co-living homes as part of the Detailed Proposals and up to 1,600 homes and a 661-bed student accommodation as part of the Outline Proposals. These homes would contribute to the delivery of Borough housing targets for LBL.
5.39 The proposals include a wide range of housing types and sizes including 1-, 2- and 3-bedroom apartments, with 46 homes in Building N1 and 11 homes in Building N2 set to come forward as wheelchair accessible, equating to 10% of the accommodation provided in the detailed phase (and meeting Building Regulation requirement M4 (3)(2)(A)). 10% of all homes set to be provided as part of the outline scheme will also be M4(3)(2)(A) compliant, with all other dwellings complying with Building Regulation M4(2). This will support residents through all stages of life enabling a greater level of autonomy into later stages of life and residents with disabilities.
5.40 The Proposed Development will provide transport choices for new residents and visitors. A total of 5 blue badge car parking spaces will be provided within the Detailed Proposals (2 coliving space in Building N1 and 3 residential spaces in Building N2), while 46 long-stay parking spaces will provided as part of the Outline Proposals (1 student space in Buildings S1/S4 and 45 residential spaces across Buildings S3, C1, C2.1, C2.2, C3, C4 and C5)
5.41 In addition to blue badge parking for residents, there will also be provision for commercial uses. The transport assessment details surveys of the town centre car parks (Molesworth Street, Clarendon Rise, and Lewisham Shopping Centre) which showed that occupancy of blue badge disable spaces varied with a peak occupancy briefly reaching up to 21 vehicles This capacity will be retained in the new development with initially 8, and then from Phase 2 a total of 11 dedicated blue badge spaces provided for the commercial uses on site (excluding spaces for residents), which will be at grade on the southern servicing route, together with the existing five at Molesworth Street car park, and six at Clarendon Rise car park, for a total of 22 blue badge spaces serving the town centre. This is in addition to a further ten existing on-street spaces on Molesworth Street and Albion Way, which provide further flexibility and options for disabled users of the town centre
5.42 New housing is an important policy objective to address housing scarcity, and may benefit people with some protected characteristics who may face greater barriers to accessing adequate housing. This may include Age and through intersectional effects of socio-economic deprivation may also affect other protected characteristics such as Race and Disability.
5.43 New homes built to modern accessibility standards will also provide a specifical differential benefit in relation to Age and Disability.
Improved quality and provision of playspace, open space and public realm
5.44 The design and provision of open spaces and public realm can have a number of equality impacts that need to be taken into consideration Some people may feel less safe in poorly designed public open spaces as they tend to have a higher risk (real or perceived) of experiencing harassment/ being a victim of crime as a result of their protected characteristic This may include women, young and older people, people from ethnic minority backgrounds, people from some religions, people identifying as LGBTQ+ or undergoing gender reassignment, and disabled people18 19
5.45 The design of open space and public realm also affects those who have difficulties navigating spaces as a result of a protected characteristic. This can include age (young or old people), pregnancy and maternity, and disability (which can include not only mobility impairments, but also sensory impairments, learning disabilities, memory loss or neurodivergence).
5.46 While there is some existing open space in close proximity to the Site (Cornmill Gardens and Gilmore Estate Open Space), some of these spaces are underused and poorly designed, featuring routes and public realm that are not inviting. The Site does not fall within an area of deficiency for playspace, but the latest Lewisham Open Space Strategy20 suggests that the Site currently falls within an area of deficiency for local, small and pocket parks.
5.47 In addition to this, findings from the Statement of Community Involvement suggest that local residents and stakeholders agreed that Lewisham currently lack well maintained and properly managed green, public open spaces. As a result of this, most respondents to the consultation have a strong desire for an increase quantum of green and open spaces which will provide space for relaxation and improve overall mental health within the area.
5.48 The Proposed Development will significantly improve the overall quality and design of the open space, public realm and playspace within the area surrounding the existing Lewisham Shopping Centre As outlined within the Development Specification, the Proposed Development will provide at least the following open spaces:
▪ The Park (5,255 sqm)
▪ Northern Square (3,360 sqm)
▪ Eastern Terrace (1,970 sqm)
▪ New Model Market (1,300 sqm)
5.49 The Site also encompasses a holistic green approach which references the historic landscape character of the area and creates important links between open space, public realm and existing infrastructure, including Lewisham Gateway, the Sculpture Park, Cornmill Gardens
18 Home Office (2020) Hate Crime, England and Wales 20219/20.
19 UN Women UK (2021) https://www.unwomenuk.org/safe-spaces-now
20 LBL, 2020. Lewisham parks and open spaces strategy (2020-2025)
and Lewisham High Street. New routes through the Site will have public spaces at their intersections, while the multiple levels of landscape will also aid connectivity and active food and beverage-led frontages will ensure that users of these spaces feel safe at all times.
5.50 The centre of the Site will be serviced from the L01 service deck and accessed by a two-way ramp to the south of Molesworth Street, the Northern square will also have both stepped and ramped access to Molesworth Street.
5.51 As highlighted within the Access Statement, all new pedestrian routes throughout the Proposed Development will be in line with good practice from BS8300- 1:2018, with access features including level/gently sloping routes for pedestrians, with gradients between 1:21 and 1:60, footpaths being at least 1800mm wide and 2000mm wide where possible, the provision of resting areas at approximately 50m apart for people with limited mobility and appropriate space for wheelchair users to be integrated in the general seating provision.
5.52 Playspace provision has been designed to meet the needs of various age groups and will be a significant improvement to the existing provision which is of poor quality and not particularly welcoming for children and young people. A total of 189 sqm of playspaces will be provided as part of the Detailed Proposals and up to 4,079 sqm of playspace will be provided as part of the Outline Proposals, in line with the GLA’s Play and Informal Recreation SPG (para 4.31)21 The Proposed Development will therefore increase the overall quantum of playspace on-site, distributing it through the open space and in turn, improving its accessibility.
5.53 Improving the overall quality of the open spaces and the public realm in this area will have a beneficial impact for existing and future residents and visitors. New safe, animated and active routes will benefit those with protected characteristics that make them more vulnerable to crime or fear of crime. New accessible spaces and routes will benefit those with protected characteristics that can make navigating public realm more difficult. And the creation of new playspace will specifically benefit young people.
5.54 In conclusion, the provision of well-designed new public realm and public open space is set to have a positive impact on individuals with protected characteristics, with the accessible multilevel landscape approach ensuring that these individuals feel safe and secure in these spaces, in addition to high-quality active frontages which can have a significant impact on the comfortability, sociability and liveliness of a public space22
Retail
5.55 The baseline evidence presented in Section 3 highlights that shoppers here are disproportionately women, and that small business owners and shoppers are disproportionately from ethnic minorities, particularly Black or Black British. The protected
21 GLA, 2012. Shaping Neighbourhoods: Play and Informal Recreation – Supplementary Planning Guidance (SPG)
22 Heffernan, E., Heffernan, T. & Pan, W. (2014). The relationship between the quality of active frontages and public perceptions of public spaces. Urban Design International, 19 (1), 92-102
characteristics of Sex and Race are therefore potentially affected by changes to retail in the town centre.
5.56 The Town Centre Assessment Study looks at how the changes set to come forward as part of the Proposed Development will affect the town centre (including shops and other businesses within the existing shopping centre, on the High Street or within Lewisham Market). The assessment highlights that Lewisham’s Primary Shopping Area is made upof 48% retail space, 37% services space, 8% vacant space and 7% other space.
5.57 The Proposed Development is set to deliver a comparable level of floorspace for main town centre uses that is currently provided (excluding short term lets and vacancies), with at least 50% of the total floorspace for main town centre uses set to comprise retail (Class E(a)) floorspace.
5.58 The proposals will contribute positively to and maintain the current retail function of Lewisham town centre through the provision of modern retail floorspace appropriate for the changing requirements of the retail sector. In addition, the delivery of opportunities for high street retail, more diverse town centre uses (including the F&B offer) and the more diverse/independent retailers on the southern party of the masterplan around the music venue will serve to support a viable town centre over the long-term.
5.59 The Town Centre Assessment Study suggests that the proposals will not adversely affect the availability of retail uses, with the latest Lewisham Retail Impact Assessment and Town Centre Trends Report (2021) (RIATCTR)23 suggesting that there is an oversupply of comparison retail floorspace within the borough.
5.60 Additionally, the residential element of the proposed development would bring more than 4,000 additional residents to the town centre, increasing footfall.
5.61 Overall, the improved quality and modern nature of the retail space set to come forward as part of the Proposed Development when compared to existing retail units on the Site is likely to have a positive effect in relation to the protected characteristic of Sex and Race.
Employment
5.62 The Proposed Development will create employment through its construction phase and in its end use. ES Volume I, Chapter 15: Socio-economics suggests a total of c.770 FTE on-site jobs will be created during the 10-year construction period. Due to the nature of construction employment, this may fluctuate across the build programme, and could be higher at the peak. When considering the occupations that are likely to be offsite, it is estimated that the scheme could generate a total average of c.1,280 FTE construction jobs.
5.63 The Proposed Development is set to deliver a range of non-residential floorspace, including the provision of flexible retail, commercial, community and cultural spaces. Due to the flexibility of the proposals, the detailed components of the Proposed Development could accommodate
23 Lichfields, 2021. Lewisham Retail Impact Assessment and Town Centre Trends – Final Report
between 145 – 195 jobs (FTE) and the outline components could accommodate between 1,445 to 2,405 jobs (FTE).
5.64 When taking the estimated existing jobs located in floorspace to be demolished into consideration (c. 690 jobs (FTE)), the Proposed Development could result in a net increase of between 900 jobs and 1,910 jobs
5.65 Employment creation has beneficial effects in socio-economic terms, but can have a differential beneficial effect on people with certain protected characteristics. It is important to reiterate that all recruitment for these jobs falls under the 2010 Act, and that discrimination is not permitted.
5.66 Some people with protected characteristics may be disproportionately represented in terms of barriers to accessing work, skills and qualifications. These barriers can result from issues relating to: language; socio-economic or cultural factors; family requirements and the need for flexible and/or part-time work. Relevant protected characteristics include Age (young people, older people), Pregnancy and Maternity, Disability or Race, which can be linked to disproportionate challenges in accessing employment.
5.67 In overall terms, increased employment is beneficial to those who face barriers to employment (those barriers are higher at times of high unemployment, and lower at times of labour market shortages). Retail as a sector has a particularly good record for employment of those entering or re-entering the workforce, including young people, women and ethnic minorities.
5.68 Investment in jobs and skills development and training can further benefit in addressing issues of inequality and deprivation. This can be addressed through an Employment and Skills plan.
6 Conclusions
Summary of potential effects
6.1 The 2010 Act does not specifically require an ‘Equality Impact Assessment’ nor define how it should be conducted. The PSED is to have “due regard” to the requirements of the 2010 Act.
6.2 Guidance24 for local authorities published by the Government Equalities Office clarifies that the 2010 Act does not impose a legal requirement to conduct an Equality Impact Assessment, but it emphasises the importance of consciously considering the aims of the PSED in decision making.
6.3 The PSED cannot be delegated to the applicant, and this report has been provided to support the London Borough of Lewisham and the Greater London Authority in discharging their duty
6.4 The nature of equality effects – often indirect and related to the individual needs of many different people now and in the future – means that assessment cannot be quantitative. The aim of this document, therefore, has been to qualitatively highlight potential effects that LBL and the GLA should take into account when discharging their PSED.
6.5 The overall effects of the development are strongly positive – regenerating the town centre environment, creating new public space and improving connections to and through the town centre, creating new employment opportunities and providing a significant amount of new housing. Different people will experience these benefits differently, in part due to their protected characteristics, and this report highlights likely ways in which this may happen.
6.6 Within this overall strongly positive balance of effects, the negative effects of development are most likely to be temporary effectsthat take place during the construction period. These include disruption from the phased decant of existing occupiers, and the disruption caused by construction noise, dust, or diversion of pedestrian routes. These may affect people differently as a result of their protected characteristics.
6.7 It is not the aim of this document to repeat in detail aspects that are covered elsewhere. Aspects of the application such as design of open space, mitigation of noise and dust etc are properly dealt with in the Environmental Statement, Design and Access Statement and so on.
6.8 Nor should it be expected that every aspect of the development that may affect protected characteristics should be fixed at the application stage – many effects will be determined more by the detail of implementation, and should be considered through control documents, RMAs and S106, as well as through less formal action such as co-operative joint working involving the council, the developer and other parties through the years of implementation. This
24 Government Equalities Office, 2011. Equality Act 2010: Public Sector Equality Duty What do I need to know? A quick start guide for public sector organisations.
document therefore can only act as a signpost to highlight issues to consider as part of the PSED.
6.9 The disproportionate and differential affects identified in this assessment are summarised in Error! Reference source not found.
Table 6 1: Potential equality effects identified
Protected Characteristic Potential equality effects?
Age Yes
Disability Yes
Comments
People with some protected characteristics are potentially more sensitive to the amenity and disruption effects of construction, including noise, dust and disruption to pedestrian routes.
New housing supply is an important contribution towards tackling housing scarcity and affordability, and will particularly benefit those with protected characteristics that correlate with greater exclusion from housing. New housing built to modern standards also increases availability of accessible living space, benefiting those with mobility needs.
Improved pedestrian routes including accessibility and activity/animation of public spaces, will particularly benefit those who may feel more vulnerable to crime or fear of crime as a result of their protected characteristics, as well as those who can experience difficulties in navigating public spaces.
Provision of new playspace, and a new music and arts venue provide benefits to various age groups.
Increased employment (and retail employment in particular), can be particularly beneficial for those who may otherwise face greater exclusion from the workforce as a direct or indirect result of their protected characteristics.
People with some protected characteristics are potentially more sensitive to the amenity and disruption effects of construction, including noise, dust and disruption to pedestrian routes.
Protected Characteristic
Potential equality effects?
Gender reassignment Yes
Marriage & civil partnership No
Pregnancy and maternity Yes
Race Yes
Comments
New housing supply built to modern standards increases availability of accessible living space, benefiting those with mobility needs.
Improved pedestrian routes including accessibility and activity/animation of public spaces, will particularly benefit those who may feel more vulnerable to crime or fear of crime as a result of their protected characteristics, as well as those who can experience difficulties in navigating public spaces.
Increased employment (and retail employment in particular), can be particularly beneficial for those who may otherwise face greater exclusion from the workforce as a direct or indirect result of their protected characteristics.
Improved pedestrian routes including activity/animation of public spaces, will particularly benefit those who may feel more vulnerable to crime or fear of crime as a result of their protected characteristics.
No particularly equality effects have been identified in relation to marriage or civil partnership
People with some protected characteristics are potentially more sensitive to the amenity and disruption effects of construction, including noise, dust and disruption to pedestrian routes.
Improved and accessible pedestrian routes and public spaces will particularly benefit those who can experience difficulties in navigating public spaces as a result of their protected characteristics.
Increased employment (and retail employment in particular), can be particularly beneficial for those who may otherwise face greater exclusion from the workforce as a direct or indirect result of their protected characteristics.
The baseline shows a high proportion of ethnic minority shoppers and business owners, as well as the local population, so anything affecting businesses, visitors or residents will have a disproportionate effect in relation to
Protected Characteristic
Potential equality effects?
Religion or belief Yes
Sex Yes
Sexual orientation Yes
Comments
Race. This includes any disruption during decant and construction, as well as the benefits of improvements to the town centre when complete.
Improved pedestrian routes including activity/animation of public spaces, will particularly benefit those who may feel more vulnerable to crime or fear of crime as a result of their protected characteristics.
New housing supply is an important contribution towards tackling housing scarcity and affordability, and will particularly benefit those with protected characteristics that correlate with greater exclusion from housing.
Increased employment (and retail employment in particular), can be particularly beneficial for those who may otherwise face greater exclusion from the workforce as a direct or indirect result of their protected characteristics.
Improved pedestrian routes including activity/animation of public spaces, will particularly benefit those who may feel more vulnerable to crime or fear of crime as a result of their protected characteristics.
The shopper survey reveals a high proportion of female shoppers, so anything affecting visitors will have a disproportionate effect in relation to Sex. This includes any disruption during decant and construction, as well as the benefits of improvements to the town centre when complete.
Improved pedestrian routes including activity/animation of public spaces, will particularly benefit those who may feel more vulnerable to crime or fear of crime as a result of their protected characteristics.
Increased employment (and retail employment in particular), can be particularly beneficial for those who may otherwise face greater exclusion from the workforce as a direct or indirect result of their protected characteristics.
Improved pedestrian routes including activity/animation of public spaces, will particularly benefit those who may feel
Protected Characteristic
Potential equality effects?
Comments
more vulnerable to crime or fear of crime as a result of their protected characteristics.
Recommendations and Mitigation
6.10 The overall effect of the development, including most equality effects, are strongly positive, and do not require mitigation, and can be secured through the application itself, or subsequent reserved matters and Section 106 agreements. However there may also be measures that could be taken by the applicant, LBL and others to help maximise such positive effects. This could include employment, training and business support initiatives.
6.11 Enhancements are not all necessarily achieved through binding planning commitments – the greatest additional positive effects for equality are likely to come from continued co-operative partnership working between the developer, the council and other parties in the town centre.
6.12 The temporary effects of disruption and relocation during the construction phase have potential for negative equality effects, as set out in this report. It will therefore be important to ensure appropriate mitigation. A particular focus for this should be on:
• The phasing, decanting and relocation strategy
• The construction management and logistics plans
• Noise, vibration and air quality management
• Transport plans
6.13 The details of implementation will be subject to agreement over the course of the S106 and reserved matters, and cannot all be fixed at the point of application. This report highlights issues that should be taken into consideration through these later stages. It should be read alongside other application documents that provide further detail on the proposals, their implementation, and relevant mitigation.
A1 Occupiers within the Shopping Centre
Table A1.1 – List of Current Occupiers within Lewisham Shopping Centre (note this is a snapshot, as occupiers regularly change)
A2 Best fit of Lewisham Retail Catchment Area
2011 Wards
South Norwood
Selhurst
Copers Cope
Clock House
Penge and Cator
Crystal Palace
Knight's Hill
Gipsy Hill
Streatham Wells
Streatham Hill
Telegraph Hill
2021 Wards
2021 Middle Layer Super Output Area
Kidbrooke Village & Sutcliffe Lewisham 008
Kidbrooke Park Lewisham 007
St Martin's (Lambeth) Lewisham 006
Knight's Hill Lewisham 014
Dulwich Village Lewisham 013
Gipsy Hill Lewisham 011
Dulwich Hill Lewisham 010
Champion Hill Lewisham 018
Streatham Hill West & Thornton Lewisham 017
Streatham Hill East Lewisham 016
London Bridge & West Bermondsey Lewisham 015
Sydenham Goose Green Lewisham 022
Bromley Town
Dulwich Wood Lewisham 021
Whitefoot West Dulwich Lewisham 020
Crofton Park Peckham Lewisham 019
Catford South
Streatham Wells Lewisham 026
Evelyn Old Kent Road Lewisham 025
Downham Nunhead & Queen's Road Lewisham 024
Bellingham North Bermondsey Lewisham 023
Thurlow Park Rye Lane Lewisham 030
Brockley Rotherhithe Lewisham 029
Blackheath Peckham Rye Lewisham 028
Greenwich West Surrey Docks Lewisham 027
Blackheath Westcombe South Bermondsey Lewisham 035
Middle Park and Sutcliffe Selhurst Lewisham 034
Kidbrooke with Hornfair
Livesey
Grange
Norbury Park Lewisham 033
Norbury & Pollards Hill Lewisham 031
Crystal Palace & Upper Norwood Southwark 001
Peckham
Blackheath (Lewisham) Merton 019
Nunhead Bellingham (Lewisham) Southwark 008
Upper Norwood
Thornton Heath
Thornton Heath Southwark 007
South Norwood Southwark 006
East Dulwich Deptford Southwark 004
College Crofton Park Southwark 011
Surrey Docks Catford South Southwark 010
South Camberwell Brockley Southwark 015
Village Grove Park Southwark 013
The Lane Forest Hill Southwark 019
Riverside Evelyn Southwark 018
Peckham Rye Downham Southwark 024
South Bermondsey Lewisham Central Southwark 023
Rotherhithe Lee Green Southwark 022
New Cross Ladywell Southwark 028
Lewisham Central Hither Green Southwark 027
Rushey Green Sydenham Southwark 026
Perry Vale Rushey Green Southwark 025
Grove Park Perry Vale Southwark 032
Forest Hill New Cross Gate Southwark 031
Lee Green Bickley & Sundridge Southwark 030
Ladywell Beckenham Town & Copers Cope Southwark 029
Norbury Telegraph Hill
Plaistow and Sundridge Crystal Palace & Anerley
Bromley 004
Bromley 001
South Norwood Clock House Tower Hamlets 023
Bromley Town
Bromley 008
Blackheath Westcombe Bromley 006
Shortlands & Park Langley Southwark 033
Plaistow
Penge & Cator
Greenwich Park
Greenwich Creekside
Charlton Hornfair
Middle Park & Horn Park
Bromley 005
Bromley 013
Tower Hamlets 027
Bromley 012
Bromley 011
Bromley 009
Bromley 020
Bromley 018
Bromley 016
Bromley 015
Lewisham 038
Lewisham 037
Bromley 040
Greenwich 034
Croydon 004
Lewisham 039
Croydon 003
Croydon 045
Croydon 002
Bromley 041
Croydon 001
Southwark 035
Croydon 008
Greenwich 038
Croydon 007
Greenwich 037
Croydon 006
Greenwich 035
Croydon 005
Lewisham 040
Croydon 013
Croydon 011
Croydon 010
Southwark 036
Croydon 009
Greenwich 012
Croydon 020
Croydon 019
Lewisham 041
Croydon 015
Greenwich 019
Greenwich 016
Greenwich 015
Greenwich 014
Greenwich 029
Greenwich 025
Greenwich 022
Greenwich 021
Lambeth 018
Lambeth 014
Lambeth 027
Lambeth 026
Lambeth 025
Lambeth 024
Lambeth 031
Lambeth 030
Lambeth 029
Lambeth 028
Lambeth 034
Lambeth 033
Lambeth 032
Lewisham 005
Lewisham 003
Lewisham 002
Lewisham 001
Lewisham 009