Equalities Impact Assessment – Beach Chalet Letting Policy

Aim of Policy / Scope of Service: This impact assessment is in relation to the beach chalet letting policy and the proposal to bring indefinite tenancies to an end. Beach chalets are situated in various locations along the seafront – Hove, Madeira Drive, Ovingdean, Rottingdean and Saltdean.  The chalets are all council owned and any resident of the city is eligible to rent one. In 2011 the beach chalet letting policy changed to a 2-tier system whereby new tenancies were granted for a fixed term of 5 years and existing tenants remained on a tenancy with no fixed end date. A further change was introduced that new chalet tenants should be residents of the city. This is the first EIA undertaken on the council’s beach chalet letting policy and follows a recent in principle decision at the Tourism, Equalities, Communities & Culture Committee to bring all indefinite tenancies to an end over an eight year period.  It will be reviewed whenever there are any proposed changes to the policy. This EIA is intended to cover existing tenants, those on the waiting list and any potential new tenants. We recognise that we have a duty to ensure that our policies prevent discrimination and promote positive community relations and equality.
Different Groups included in scope	Potential Impact on this group	Existing data/information inc. relevant legislation	Data/Information required	Potential actions to minimise negative impact and maximise positive impacts
Existing chalet tenants on indefinite tenancies	The policy change means that indefinite tenancies are being bought to an end and tenants will be required to enter into a new 8 year fixed-term agreement after which they will be required to leave.	· Annual proof of residency/address · Email and contact details · Bank details for direct debit · Equality data from recent survey · No other data is requested	No further data required	Whilst it is noted that the existing tenancy agreements allow the council to terminate the tenancy subject to a notice period, there is likely to have been an expectation among tenants that they would be able to keep their chalets for the rest of their lives. The Seafront Team directly engage with all tenants and therefore have a degree of awareness of whether tenants have protected characteristics (whilst noting that some protected characteristics may not be obvious or visual). However, the Council has limited monitoring data in relation to the tenants. All indefinite tenancies have been in place for at least 10 years and it is therefore reasonable to assume that tenants on indefinite tenancies may be older residents and that therefore this policy change will negatively impact on this group. This older group may also be more likely to be disabled. The Council will mitigate the negative impact on these residents by reducing the licence fee and by offering 8-year tenancies to replace the indefinite tenancies to allow tenants plenty of time to prepare and adjust to the change. Whilst there is a potential negative impact on older and disabled residents, this impact is being mitigated as much as possible and the positive policy objectives from a fairness and equalities objective outweigh the negative aspects of this policy change. From an equalities perspective, being able to reopen the waiting list as more chalets become available, is likely to result in a more diverse range of people being able to secure a tenancy. The Council will promote this positive outcome by working with communities once there are places available on the waiting list to consider how to make all communities aware of the opportunity. For example the current vast majority of beach chalet users are White and therefore this would give an opportunity to start to address this imbalance. The change will make the beach chalets accessible to more residents. The Council will also take steps in the future to collect equalities data from tenants so that it can monitor the impact of its policies.
Residents on the waiting lists and those who would like to be on a waiting list	The change in policy will mean that in the short and medium term, the current waiting lists will reduce, the waiting lists are re-opened and more residents can have the opportunity of a 5 year chalet tenancy. Due to high demand for chalets there are waiting lists. The waiting lists are currently closed. When a chalet becomes available it is let to the resident at the top of the waiting list for each chalet location.	· Email and contact details · Proof of residency, bank details and photo ID is required when a tenancy agreement is signed. · Equality data from recent survey		The policy is changing to make the beach chalets accessible to more residents. The proposal also removes the 2-tier system by bringing every chalet tenant onto a fixed-term tenancy which is fairer than the existing policy although there will still be disparity with some tenants on an 8 year and some on a 5 year fixed tenancy.

What consultation has been used or undertaken?	Date	Methods Used	Findings
Beach Chalet Letting Policy review	September 2020	Survey on the online consultation portal Equality data to better understand the demographic profile of the community was included in the survey.	There were 790 responses to the survey. 65% of those who responded to the consultation were in favour of changes being made to phase out indefinite agreements and make all agreements fixed-term. 30% of those who responded disagreed with making changes to indefinite agreements. The consultation reiterated what is known from the long waiting lists, that beach chalets are a very popular much sought-after amenity.

Agreed Actions	Timescale	Lead Officer	Review date
· To bring to an end indefinite tenancies where the tenant is a resident of the city and grant new 8 year fixed term tenancies to this group	Recommendations to TECC Committee June 2021	Seafront Estates Surveyor	Whenever there is a change to the beach chalet letting policy.

Departmental Management Team: Toni Manuel – Seafront Development Manager     Date:  03/06/21

Assistant Director:    Donna Chisholm                                                                                  Date: 07/06/21

Corporate Equalities and Inclusion Team            Krishna Kaur                                          Date: 08/06/21