Submission to Council Executive meeting, 5.30pm, Thursday 13^th January 2021.

From Diane Roworth, York Sight Loss Council , and Reverse the Ban, re-open York to Blue Badge Holders, and registered blind person.

Agenda item 8 – closing off the largest area of any city centre in Europe, to disabled people

Flawed Equality Impact Assessment Annexe C

The Councils understanding of the purpose and use of an EIA is incomplete and as such, misleading.

An EIA should highlight issues affecting people with a protected characteristic, and alert officers and members to try to find alternative solutions (mitigations) to remove or minimise that impact.

City of York Councils EIA;s, and in particular this one, do not perform this function, and mislead those reading them into thinking that all that can be done to fulfil their responsibilities under the Equality Act, has been done.

By way of example, as far as I know, no EIA has identified that a system of staffed barriers, CCTV’s and/or number plate recognition systems would enable blude badge holders to retain their ability to enter the foot streets, whilst providing secure HVM.

This also applies to North Yorkshire Police.

Comments on This Equality Impact Assessment

Proposal

1.3 – stakeholders – this includes people with protected characteristics who will be discriminated against if this proposal is not modified

1.4 What results/outcomes do we want to achieve? What is missing here is ‘a safe and secure city centre, which is truly accessible to all and contributes to our City Centre Vision by accommodating the needs of blue badge holders.

2.1 What sources of data, evidence and consultation feedback do we have to help us understand the impact of the proposals on Equality and Human Rights

There is no evidence that information received from the consultation exercises mentioned has made any difference to the decisions Executive have made. Information is always noted – but there is no evidence that any amendments, or solutions to take account of the impact, have ever been developed.

If all the evidence were published in 1 space, it would clearly show that there is little reason to exclude blue badge holders for example:-

Collision data – 16 accidents in 10 years – does not support exclusion.

Surveys of traffic and blue badge parking – when and where were these done? How have they been shared with disabled people and Council Executive members. When North Yorkshire Police think that there are over 7,000 blue badge holders in the city when there are only 4,000 – this brings into question the basis on which decisions have been made.

3.1 Gaps in information – a gap which has never been discussed is – what would need to be in place to allow blue badge holders to retain their ability to enter and park in the city centre. This gap remains, because the Council Executive do not want blue badge holders in the city and are determined to keep them out.

Medium and long term impact on stakeholders. The city becomes known as an exclusion zone for disabled people, it cannot include severely disabled people in its festivals, it portrays the medical model of disability to the outside world, rather than the social model of disability,

4.1 Likely Impact on people with a protected characteristic.

Age and Disability It is misleading to say that there is a very high positive impact by excluding blue badge holders. The number of blue badge holders entering the city centre on a daily basis is small and safety has been demonstrated as not being an issue due to the low number of accidents, and could, be further increased by a slower speed limit.

St Sampson Centre will be inaccessible to many people who cannot use Dial and Ride. Also, for those that can, it is only available at designated times and in designated areas and has to be booked well in advance. A person cannot use it at times of their choosing.

SOME blind and partially sighted may benefit from a car free area, however, there are many who will no longer be able to take a taxi into the centre and will therefore be excluded from it.

Impact on Human Rights This ignores the excellent information provided to the City Council by its own Human Rights board, and the Human Rights City Network. Article 2 is the only article identified, whereas Human Rights articles

Non discrimination and participation and inclusion are another 2 articles which are highly relevant, and the Human Rights Board can further inform Executive if you are willing to listen to them.

Step 5 – there are no suggestions here, such as researching options that do allow blue badge holders to enter the city centre.

Step 6 – No major changes. This identifies the officer’s reluctance to take seriously the Equalities Act and Human Rights Act and also demonstrates that consultation exercises undertaken by the Council have been in name only. No alternatives have ever been presented, which demonstrates why this EIA and others demonstrate the Councils lack of understanding of their Equality duty, and failure to discharge is appropriately.

I ask that you defer the decision on this permanent barrier system and seek proposals that include ways of allowing blue badge holders to enter.