Promoting Equality within the Estates Strategy

Report: 4
Date: 2 June 2011
By: Director of Resources on behalf of the Commissioner

Summary

This report provides provides an outline of how equality and diversity are incorporated into the implementation of the MPA/MPS Estate Strategy 2010-2014.

A. Recommendation

That members

1. Note the recent publication of the MPA/MPS Estates Strategy.
2. Note the approach being taken to ensure that equality and diversity is taken into account in the delivery of the Estates Strategy.

B. Supporting information

Overview of the MPA/MPS Estates Strategy 2010-2014 and its aims.

1. The MPA/MPS Estate Strategy sets out the overall vision and objectives of the Estate and the supporting property services. The Strategy supports and is supported by a number of complementary strategies and plans including Corporate Social Responsibility, Corporate Real Estate, Town Planning and Residential. It is also flexible enough to respond to changing operational needs through the various corporate re-alignment programmes. For example, the outcomes of the consultations on Public Access and Safer Neighbourhoods may affect policing services which may impact on the Estate. The Vision includes the statement that the Estate:

“supports inclusion and recognises the diversity of the communities we service”

In addition a number of the key objectives directly support equality and diversity:

• Provide accommodation that meets statutory and regulatory requirements in terms of health and safety and accessibility
• Offer an efficient working environment for officers and staff supporting high Performance
• Promote sustainable and environmentally friendly provision and use of property

2. The criteria we adopt for assessing potential change to the estate also reflects equality and diversity. Building condition and suitability are two of the criteria used to assess the retention, refurbishment or disposal of a property.

3. The provision of new custody and patrol bases and the resultant disposal of buildings no longer fit for purpose have already provided improved quality of estate which supports equality and diversity issues for the public and MPS employees.

4. The Corporate Real Estate Plan is driving further change to the estate which moves us closer to a leaner and more fit for purpose estate. In planning and reviewing the changes, Diversity and Equality are two of the issues constantly under consideration. In the Estates Strategy we set out a number of criteria used to guide our decision making. One of these criteria is “building and location suitability” which thus includes a range of equality and diversity matters. Examples of our recent changes include:

• A more fit for purpose custody facility in London Borough of Waltham Forest which is fully compliant. The opening has allowed us to exit an inferior building
• The move of a number of TP Staff from Canon Row to Empress State building. The former is an old less accessible building. The latter is a much more modern easily accessible property with a better range of amenities for all staff
• Two good example of improvement to Front Counter facilities are Kirkland House, Harrow and Fishmongers Arms, Haringey. In the both bases the service moved from older less accessible buildings into modern purpose built fully compliant front counters integrated with Safer Neighbourhoods Bases

How equality and diversity are are incorporated into decision making processes, particularly when:

Making alterations to properties to improve access;

5. We undertake changes to the existing estate a well as providing new buildings which generally result in the release of older, less accessible buildings.

Modifications to the existing estate

6. We have an ongoing programme of work to upgrade the estate, however, between 2003 and 2006 there was a particularly concerted effort to make as many public facing buildings DDA compliant. 58 of the 137 front counter locations were fully refurbished to the then DDA standards. The coverage per Borough was as equitable as possible.

7. At the same time most remaining locations had access audit and maintenance/minor works undertaken. These improvements were carried out without a wholesale refurbishment or upgrade to general standards. Induction loops, tactile paving, colour and contracts to steps, handrail work etc was all done as a gradual process. This means that many non-refurbished properties are fully accessible to the majority of disabled people. We consider that of the 137, 92 locations are either fully compliant or accessible to the majority of disabled people.

New buildings

8. The recent roll-out of Safer Neighbourhood bases has been delivered under the ethos that a property is not suitable for our use unless it could provide full Disability Discrimination Act 1995 (DDA) compliance in public areas and meet all accessibility needs. Furthermore and parallel with public needs, there is also a drive to understand the requirements of our own personnel so that we can provide properties that have appropriate levels of accessibility. The Disability Discrimination Act 1995 has now been replaced by the Equality Act 2010.

In particular, the following check-list has been applied to projects.

• Identify the precise nature and end use of the spaces within the demise
• Identify the areas of public / staff access
• Understand the occupational split of the staff: i.e. operational only, operational and administration / volunteers and the level of provision required for each user type.
• Identify the DDA requirements to accommodate the staff members i.e., no unique facilities on inaccessible floors, distances to sanitary facilities etc.
• Identify potential scope for future alterations to make provision of changing staff needs or future building use. e.g. a lift may not be required at the outset however, identifying a location and/or installing the infrastructure at the base build stage may be a reasonable measure to accommodate change and flexibility.
• Understand and communicate the spatial requirements imposed by improvements for new property acquisitions or the impact and potential loss of accommodation within an existing property following improvements
• Assess the structural feasibility to adapt the property to accommodate appropriate access and internal circulation
• Ensure access and circulation requirements are clearly identified within the brief.
• Include statutory and other standards within the brief which are to be complied with during the design process
• Assess the access to the site, on to the site and into the property.
• Consideration should be given to the potential routes used by the users and visitors when arriving via different methods of transport i.e. personal car, walking, public transport etc
• Assess the feasibility to adapt the approach to the building from the site boundary to the building. Note: if a ramp is required, provision must also be made for a stepped approach
• Assess the feasibility to adapt the existing structure to achieve the required widths for access.
• If site restrictions do not permit the construction of a permanent ramped approach, management process must be justified within the access statement to ensure statutory compliance
• Assess the nature and frequency of public access.
• Consider the type of access control. Audio, Video. Consider the mounting heights for both standing and seated users. Audio devices may require the inclusion of hearing loop technology
• Does the nature and frequency of public access warrant automatic opening doors. If not, can the installation be designed to allow a system to be easily retrofitted if the use changes.
• Provide appropriate warning signage to automatic doors and consider the design of anti finger trap hinges, obstruction detection and other safety features.
• Designs should provide adequate disabled circulation within all areas and this should be demonstrated on the drawings and within the access statement.
• Consideration should be given within the design of the finishes to partially sighted visitors. The scale, layout and contrasting nature of wall, floor, ceiling and door finishes should clearly define the spaces and circulation routes within.
• All areas should provide clear door and corridor widths as required under building regulations.
• The facilities intended for public use within properties should make provision for disabled users i.e. counter heights, induction loops etc.
• All deviations from the normal provision under the DDA or Part M, due to operational reasons should be described and justified within the access statement.
• Carry out an independent access audit on completion

On Procurement;

9. The MPS works in partnership with the GLA Central Responsible Procurement team to support the Mayor’s vision for London to be an exemplary, sustainable, world city.

Through engagement with the supply chain the MPS aims to;

• Improve standards of living and opportunities for sustainable employment for all Londoners
• Open up opportunities for London businesses and work with the business community to promote equal life chances for all
• Promote greater environment sustainability and make London a better place to live and work.

10. This is also covered in the April 2011 paper ‘Equality and Diversity Implications of Responsible Procurement’ which was presented to Equality and Diversity Sub-Committee - 14 April 2011.

Potential benefits to the community when disposing of property;

11. Once a property has been scheduled for disposal the statutory duty of the Authority is to seek best consideration for the asset. However, in doing so the property is marketed to a wide audience allowing local organisations including community groups to submit proposals. Recent examples of sales to such organisations include: a private day nursery, Harrow school and a new Islamic school.

12. In addition to the core estate the MPA/MPS are reducing the size of the residential estate. By processing sales through auction and private treaty we have managed to reach a diverse range of purchasers.

Deciding to relocate services;

13. Equality Impact Assessments (which address Equality and Diversity issues) are required as part of the process within all change projects whether they have a property implication or not. The Diversity and Citizen Focus Directorate (DCFD) works alongside all MPS Change Programmes. This provides a rigorous and comprehensive approach to ensuring that equality issues are considered and addressed through the development of programme and projects. The process supports programmes to achieve their vision by ensuring that opportunities for increasing confidence and satisfaction across all communities are identified and progressed, and any adverse impacts on communities are identified and mitigated. For example DCFD are represented at the monthly Corporate Real Estate Change Leaders meeting at which progress within the programme and future changes are considered.

Providing a visible presence to all of London’s communities.

14. To best serve our communities and in conjunction with DPA, Property Services recognised the need for a set of corporate branding guidelines governing the manner in which our buildings are presented to the public. A survey of the presentation of our buildings with public access highlighted inconsistencies in our approach to signage. It became evident that moving forward, a branding strategy was required to provide standardisation pan-London, increase visibility to ensure an awareness of our presence and thus, create a set of products that could prove instantly recognisable to all members of the community in a 21st century streetscape.

15. After developing a proposed ‘signage toolkit’, Property Services undertook direct consultation with a diverse cross-section of London’s community (then known as the Safer London Panel - managed by the MPA). This engagement took the form of telephone interviews, online surveys and face-to-face focus groups to ensure we were able to capture the views of a broad range of people. The consultation was intended to capture the views of members of the public on:

• The new signage – its design and usefulness;
• Whether the new signage is an improvement on the old signage;
• Whether the new signage increases their understanding of the services offered at the station or office;
• Whether the new signage will make passers-by more aware of station location and what impact increased visibility has on public perceptions.

16. A key theme that arose was the need for appropriate illumination particularly during hours of darkness (if open); however other benefits of the proposed signage toolkit were seen as ‘reassurance’, ‘recognisable’, ‘deterrence’ and ‘access to help’.

17. Taking into consideration the views of the Safer London Panel, Property Services undertook a number of pilot branding sites using the ‘signage toolkit’ from which we developed corporate branding guidelines. These are currently in use for new projects moving forward and most recently have been deployed in the roll-out of Safer Neighbourhood premises.

18. The signage products that are in use under our corporate branding guidelines consist of illuminated identity signs, illuminated external poster-cases LCD screens displaying relevant information such as opening hours and a ‘thin-blue-line’ LED strip amongst others. All of which intend to raise the profile of our buildings and provided an increased, standardised level of branding that helps us to recognisable and increase our presence in the communities we serve.

Consultations and community engagement conducted

19. Territorial Policing (TP), by way of example, has recently carried out a consultation exercise across the 32 boroughs in relation to Safer Neighbourhoods. The MPS SN review protects the founding principles of Safer Neighbourhoods, yet allows for good practice around deployment of resources to improve problem solving delivery to be formalised in central policy. An Initial Impact Assessment has been undertaken which considers any possible changes to locations, the impact changes would make on communities, and the needs of SN staff which may occur as a result of the outcome of the SN review.

20. The TP Development Public Access project has recently begun a public review of the ways in which the public can access the Met's services which ranges from calls and online contact to face-to-face meetings. The review will also look at the role that police station front counters play. The review started on 11 April 2011 and concludes on 27 May 2011. The Public Access project is subject to an EIA in line with the TP Development approach for EIAs.

21. TP Borough Commanders are required to undertake a period of local engagement activity with key stakeholders and the local community in relation to changes to the public facing estate in their Borough in support of the MPS Corporate Real Estate Plan. These changes have recently been subject of an individual EIA, in addition to the overall EIA for the CRE plan.

Any disability audits and related risk assessments

22. Property Services holds Access Audits of properties that have required an audit construction projects since 2000 comply with Approved Document M of the Building Regulations which provides Access to and Within a Building, as part of this Access Statements are submitted to Building Control for all new build construction projects. In addition, an ongoing building audit carried out by Atkins addresses some DDA and Access issues.

The identified lead for equality and diversity in delivery of the estates strategy

23. The responsibility for Equality and Diversity in relation to the estate is delegated from the Director of Property Services to Assistant Director (AD) level within the Facilities Management team. The AD attends the MPS Equalities and Diversity Board and reports back on issues which require PSD actions.

Any specific Estates Equality Strategy to tackle identified equality issues

24. In 2004 in preparation for the DDA Part 3 (access to goods and services) becoming law (earlier sections of the act relating to employment had been in existence since 1995) Property Services carried out a front office refurbishment programme (aimed at making two sites per borough fully compliant). All sites with front offices at the time had access audits carried out and minor works were done to many that fell outside the two per borough to make the best of the facilities we had at those sites. All new locations have to be built in accordance with building regulations and as such will be compliant with approved document M and in doing so be accessible. The DDA has been incorporated into the Equalities Act so it is Equalities Act we now need to comply with.

Estates Communication Strategy to inform the public of its work;

25. Through our consultation for new policing facilities across London we adopt a comprehensive consultation, communication and engagement strategy to ensure that all stakeholders are communicated with the same messages about any new scheme. We try to ensure that groups who may be interested in or affected by the scheme as well as local residents and other key audiences are communicated to at the same time and in a way that is easily accessible for them.

26. Through the consultation and communication process we try to ensure that no stakeholder receives less favourable treatment on the grounds of his or her race, nationality, ethnic origin, religion, religious or philosophical belief, sex, marital status, sexual orientation, disability or age. This applies to all phases of communication / consultation and in particular:

27. The promotion and advertisement of consultations – we ensure that this is done in a number of ways to ensure that everyone is able to find the information about the consultation. This includes online, in the local media, at meetings, in person and via tailored letters.

28. The locations of consultation events – we ensure are in DDA compliant locations as well as being well advertised and close to the location of the proposed new development so that local residents and those most affected by the development of the site are able to access the public exhibition.

29. Staffing all public exhibitions – we ensure that all public exhibitions are staffed by professional members of the team to ensure that they can answer any questions which may be asked about policing in the local area even if they are not directly related to the development.

30. Displaying information – for those unable to attend consultation events we try and make the materials available in other places for members of the public and other stakeholders to access. This can be online, in front offices of local police stations or they can be presented at community group meetings to try and reach as wide an audience as possible.

31. The feedback mechanisms – we ensure that stakeholders and members of the public can provide comments on a proposed scheme in a number of ways usually including phone, email and in writing, as well as in person at the exhibitions.

Any performance framework that is in place to manage compliance with Estates Equality and/or Communication strategies

32. For all new build and alterations, compliance with the Building Regulations ensures quality of Access. Ongoing holistic building audits ensure ongoing compliance.

How MPS staff associations have been involved in the MPA/MPS Estates Strategy 2010-2014 (any Equality/Communication Strategies)

33. Over 2010/11 Property Services has held regular meetings with Union and Staff Association representatives to share Corporate Real Estate (CRE) plans. Meetings are held bi-monthly and provide a key vehicle for engaging staff and learning of their experience as delivery of CRE plans gathers pace.

34. Union and Staff association representatives have played a key role in developing a CRE Frequently Asked Questions function on the CRE intranet pages as well as raising local issues on behalf of members for resolution.

35. Union members are also kept up to speed with CRE developments through regular meetings they have with the Developing Resource Management Programme Manager, as CRE sits within this portfolio of work.

36. Separate meetings with Unions and Staff Associations are also held as part of the Delivery of Property Services review that is now entering implementation phase.

Any relevant Equality Impact Assessments (EIAs)

37. The business case for Corporate Real Estate 2011/12 was recently approved by MPS Management Board. A programme level EIA was considered as part of this approval. The EIA is attached for reference which shows that while high level assumptions can be made about the potential impact of CRE, the impact on staff, stakeholders and communities needs to be assessed on a case by case basis, for each building that the MPS intends to exit and release under CRE.

38. In 2010/11 equalities implications of CRE accommodation moves were managed locally, however the CRE Governance Board has requested that this approach changes for 2011/12 to ensure there is central oversight of the CRE equalities implications and consistent format for capturing them. Production of EIAs at building level is therefore an area for development within CRE processes and for this reason is logged in the CRE risk register.

39. The MPA Finance and Resources Committee gave approval in principle to 2011/12 CRE plans in December 2010. Property Services are working with HR and affected business groups to prepare EIAs for each building in scope for 2011/12. The process for how building specific EIAs are to be produced is set out in the programme level CRE EIA. No relocation project will take place until the EIA implications have been assessed and 28 days notice given to affected staff, as is good industry practice.

40. For public facing buildings included in 2011/12 plans, the Finance and Resources Committee specified that stakeholder engagement must take place with the findings reported to the MPA before final approval to release can be given. Good progress is being made here, with front counter transfer papers recently approved for Surbiton and Wallington front counters (both in preparation for full station closure). EIA implications are clearly considered in the front counter transfer papers and supporting EIAs, which are now being produced to support all front counter transfers.

Other Considerations

41. Where police officers/staff have any disability or access/egress issues a PEEP (Personal Emergency Evacuation Plan) is prepared and these are managed on a local basis. Any issues identified are feedback to Property Services who will assess if any alterations to the property are required. In the case of visitors it is the responsibility of the visitor’s host to undertake a risk assessment and agree a PEEP.

42. We also link in with the Equality Standard for Police Service and Property Services provide regular reports through to the Diversity Forum.

43. As well as the internet/web we use a range of other means of communicating the accessibility of our services. These include posters inside and outside police stations, the single non-emergency telephone number, SN surgeries and ward meetings; and posters in libraries and town halls. We also use local and London-wide media including regular editorial and pull-outs in local papers.

C. Other organisational & community implications

Equality and Diversity Impact

1. Whilst the overall strategies incorporate holistic Equality impact assessments, specific cases of building disposal or other estate changes including the relocation of personnel must include relevant analysis of the individuals and services impacted by any change to ensure that no group is disproportionately affected. Cumulative impact on groups and communities should also be considered in line with the Equality Act 2010.

Consideration of MET Forward

2. The development of the Estates Strategy took into account Met Forward and Met Forward is cross referenced in the Strategy document.

Financial Implications

3. The costs associated with ensuring that equality and diversity is considered as part of the Estates Strategy are covered within existing MPS wide budgets as approved within the 2011/14 Business Plan. The costs associated with developing and maintaining controls to manage equality and diversity are also contained within existing approved budgets. Any funding required over and above these existing budgets will be subject to the normal MPA/MPS approval and planning processes.

Legal Implications

4. There are no direct legal implications arising from this report which is presented for information only.

Environmental Implications

5. Effect on sustainable development:

6. Energy Use and carbon emissions:

The proposed change to the Estate should result in fewer buildings and these will be equipped with modern, efficient Mechanical and Electrical installations and insulated to current building regulation standards. Opportunities to install renewable energy technologies will be investigated.

7. Water consumption:

Modern equipment and plant, including water efficient devices together with potential re-use of ‘grey’ water, will be used where appropriate.

8. Use of materials / resources:

Construction and fit-out activities will require the use of materials and resources. All projects will seek to, within economic bounds, maximise the use of recycled material and sustainable resources in line with best practice / regulation.

9. Procurement will adhere to Property Services Directorate design guidelines on environmental management covering construction and operational use, and specifications for responsible procurement. This will ensure, for example, that ICT equipment is energy efficient.

10. More broadly, besides efficiency gains through facilities and equipment, there are considerable opportunities to effect behavioural change among staff by providing awareness training regarding resource management, particularly in regard to the use of energy, waste, water, products and materials.

11. The MPS wishes to promote the use of sustainable travel options such as public transport, walking and cycling and therefore assesses the provision of commuter parking and takes into account Public Transport Accessibility Levels (PTAL) when choosing alternative locations. However, these decisions need to be balanced by the accessibility needs of MPS employees and the community and this requirement will be assessed through the completion of building level EIA’s.

Risk Implications

12. Existing estate offers a mix of accommodation; maintenance of some areas is costly and funding is limited. Infrastructure in some areas is antiquated and resilience can not be guaranteed. The Estates strategy seeks to improve the estate in order to reduce risks.

13. The size of the site gives challenges with resilience and security; reducing the size of the estate will enable more effective management/control.

D. Background papers

• Estates Strategy 2010-14
• Corporate Social Responsibility Strategy 2010-13
• Equality and Diversity Implications of Responsible Procurement -14 April 2011

E. Contact details

Report author: Jane Bond, Director of Property Services, MPS

For information contact:

MPA general: 020 7202 0202
Media enquiries: 020 7202 0217/18

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