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Meeting: |
Executive |
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Meeting date: |
12/10/2023 |
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Report of: |
James Gilchrist - Director of Environment, Transport and Planning / James Gilchrist |
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Portfolio of: |
Cllr. P. Kilbane – Deputy Leader and Economy & Transport |
Decision Report: Consideration of changes to the City Centre Traffic Regulation order (Footstreets)
Subject of Report
1. In November 2021 the Council’s Executive made the decision to permanently remove the exemption which had allowed Blue Badge holders vehicular access to Blake Street, Lendal, St. Helen’s Square, Goodramgate (between Deangate and King’s Square), Church Street, King's Square and Colliergate.
2. The lived experience in a post-COVID19 world has evidenced the significant impact on disabled people. In response, a coalition of charities, associations, action groups and other organisations have worked together to campaign for a reversal of the ban on Blue Badge holders’ access to York’s pedestrian streets.
3. The York Labour Group’s Pledge and Policy List pledges to “reverse the Blue Badge ban”.
4. This report is in response to the Labour Group Pledge and sets out options of how that can be delivered in the context of the New Council Plan, Counter Terrorism Policing advice, the impacts, and the next steps to inform a decision to permit Blue Badge access be made.
5. This report considers the recent consultation responses to the proposed principles that Members will take into consideration to decide the basis on which Blue Badge access can be permitted in the pedestrianised streets.
6. It sets out options of how blue badge access may be permitted and the way this changes the risks and the mitigations that can be considered.
7. The report sets out targeted engagement and workshops to ensure the pedestrianised streets are as accessible as possible for the option chosen.
Benefits and Challenges
8. This decision is challenging as it requires the Executive to balance the security advice from the Counter Terrorism Police, public safety, and the rights of all users of the pedestrianised streets (footstreets) (including users with protected characteristics under the Equality Act 2010) against the rights of Blue Badge holders requiring vehicular access to the footstreets (a protected group under the Equality Act 2010).
9. This report does not seek to put those interests and those of other groups in conflict but rather to help the Executive establish the policy context for how that balance is struck.
10. This report invites the Executive to consider the requirements for public space, which are exacerbated in York by the constraints of narrow footpaths and pedestrianised streets. The fundamental issue is one of balancing the human rights and equalities impacts against the security advice. However, the Executive should be aware there are additional impacts for instance on pavement cafes.
Policy Basis for Decision
11. The 10-year plan sets a vision that everyone can benefit from and take pride in the city with the Council Plan setting a priority that the council will set the conditions for a healthier, fairer, more affordable, more sustainable, and more accessible place where everyone can feel valued.
12. This vision sets a clear policy that an accessible place is a priority for the Executive. The Executive has set out Four Core Commitments in the Council Plan which are those outcomes they believe will most support the delivery of their vision. One of which is:
“Equalities and Human Rights - Equality of opportunity - We will create opportunities for all, providing equal opportunity and balancing the human rights of everyone to ensure residents and visitors alike can benefit from the city and its strengths. We will stand up to hate and work hard to champion our communities”.
13. Previous reports have identified the impact on Blue Badge holders of restricting access and parking of their vehicles in the city centre. Reports advised decision makers of the need to weigh up the negative impact in terms of equalities and human rights for a group with a protected characteristic in the context of a wider human right of the general public to health and safety and protection of life, reflected in the Counter Terrorism Policing advice.
14. In deciding, the Executive are again asked to weigh up and consider the balance and consider the impact of any decision on Equalities and Human Rights issues, whilst recognising that this decision is made under a different policy context particularly one of the Executive’s four core commitments.
15. The draft Terrorism (Protection of Premises) Bill, https://www.gov.uk/government/publications/terrorism-protection-of-premises-draft-bill-overarching-document also known as ‘Martyn’s Law’ in tribute to Martyn Hett, who was killed alongside 21 others in the Manchester Arena terrorist attack in 2017, will ensure that security preparedness is delivered consistently across the UK, ensuring better protection of the public.
16. The bill was developed with security partners, business, and victims’ groups, including Figen Murray (Martyn’s mother) and the Martyn’s Law Campaign Team, and Survivors Against Terror. If enacted, the proposed new legislation will require venues and public spaces to take steps to improve public safety.
17. This will also likely see the introduction of legislation and/or guidance to strengthen the current legislation placing duties upon public authorities in relation to predictably crowded places.
18. Under the Equality Act 2010, the Council must in the exercise of its functions have due regard to the need to eliminate discrimination, harassment, victimisation and any other prohibited conduct; advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it and foster good relations between persons who share a relevant protected characteristic and persons who do not share it and foster good relations between persons who share a relevant protected characteristic and persons who do not share it. This is referred to as the Public Sector Equality Duty. The protected characteristics in the Equality Act 2010 are age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex and sexual orientation. The duty is to have “due regard”, it is not to achieve a specific outcome.
19.
The Human Rights Act 1998 states that it is unlawful for a public
authority to act in a way which is incompatible with a right or
freedom under the European Convention on Human Rights. The
provisions of Article 8 (right to respect for private and family
life) and Article 14 (protection from discrimination) contained in
Schedule 1 of the Human Rights Act 1998 have been considered and
taken into account. These rights can lawfully be interfered with
where the interference is proportionate, necessary, and has a
legitimate aim. For example, where it is necessary in the interests
of other concerns including public safety and health or where it is
necessary in the wider public interest, and it is
proportionate.
20. The Executive are asked to consider both the right to life and the protection from discrimination. Neither of these duties take precedence and the Executive will need to make a decision proportionately, having regard to all impacts, to reach a balanced decision including the Council’s responsibilities under the Public Sector Equalities Duty.
Financial Strategy Implications
21. It is estimated that to permit Blue Badge access will increase costs to the Council by £200,000 per annum, this covers the additional cost of staffing and monitoring at the access points.
22. These additional costs cannot be covered from within existing budgets and therefore, should the Executive commit to this recommendation, additional budgets would need to be identified. For a full financial year budget, the Executive can commit to the additional budget being a priority growth commitment in the 2024/25 budget.
23. Should the decision be made to implement the access from January 2024 there will be additional costs of £50k in the financial year. Whilst the Place Directorate is forecasting an underspend in 2023/24 (£1.2m reported to September Executive) and therefore could meet these costs in year, there is a significant forecast overspend across the council in year. Executive agreed a plan to mitigate spending in the financial year at its meeting in September and Members should consider the financial impact when making its decision.
Recommendation and Reasons
25. Recommendations: The Executive are asked to:
a) Consider the revised policy position of a new council plan, and how this changes decision making.
b) Consider the updated Our City Centre Strategy (to be considered at the same meeting)
c) Consider the advice of Counter Terrorism Policing contained within Annexes A and B attached to this report. At Economy, Place, Access and Transport Scrutiny Committee on the 26th of September, Counter Terrorism Policing Northeast confirmed their advice contained within Annex B remained their advice. The Executive have had a private briefing by Counter Terrorism Policing before making this decision and the information provided should also be considered.
d) Consider the responses to the consultation on the principles for restoring Blue Badge access to Blake Street, Lendal, St. Helen’s Square, Goodramgate (between Deangate and King’s Square), Church Street, King Square, and Colliergate during pedestrianised hours, contained with Annex C attached to this report.
e) Consider the positive impact of restoring Blue Badge access for disabled people.
f) Consider the impacts of increased risk of accidents between pedestrians and vehicles linked to additional vehicles within the pedestrianised streets, (including the potential negative impacts on some groups with protected characteristics under the Equality Act 2010) and the technical and practical challenges in administering an access regime.
g) Decide to pursue either:
· Option 1 - revert to two separate phases of HVM. This would allow the highest risk area focusing on Parliament Street to be emergency/blue light vehicle access only, Blue Badge access could then be permitted to the outer area as it existed immediately prior to the COVID19 Pandemic as this area was defined as a lower risk area by the original risk assessment.
NB – Option 1 is NOT recommended for the reasons set out in this report.
OR
· Option 2 - As detailed in the report and not permit Blue Badge holders access to Blake Street, Lendal, St. Helen’s Square, Goodramgate (between Deangate and King’s Square), Church Street, Kings’ Square and Colliergate;
OR
· Option 3 - The Hostile Vehicle Mitigation Measures will continue to operate but the Executive determine that Blue Badge access will be permitted to Blake Street, Lendal, St. Helen’s Square, Goodramgate (between Deangate and King’s Square), Church Street, Kings’ Square and Colliergate through the Hostile Vehicle Mitigation Measures during pedestrianised hours as shown in Annex H to this report from January 2024. To start the process and consultation of developing an Anti-Terrorism Traffic Regulation Order and recognise some events may mean access is restricted for the event.
h) Agree that any additional ongoing costs, currently estimated at £200k, will need to be classed as priority growth as part of the 2024/25 budget process.
Reason(s): Executive are required to consider if the option to restore Blue Badge access is reasonable and proportionate having fully considered the Equalities Impact Assessment. Executive therefore need to weigh up the equalities and human rights benefits to Blue Badge holders of restoring access and if the proposed mitigation of introducing an Anti-Terrorism Traffic Regulation Order balances the wider public interest, including the right to life, the duty to protect life, and the potential negative impact that additional vehicular traffic in the pedestrianised area could have on some groups with protected characteristics under the Equality Act 2010.
Background
26. The York Protect and Prepare Group was established in 2017 following a number of terrorist attacks that had taken place during that year. The group is multi-agency, involving all blue light services, Counter Terrorism Police, Relevant Council Services, Make It York, York BID and representation from across the business, leisure and tourism sector. The group has a detailed action plan comprised of six strategic priorities each with a range of detailed actions designed to mitigate the risks to the city associated with a potential terrorist attack and prepare key stakeholders to be able to cope in the event of an attack taking place. These priorities include the consideration and installation of both temporary and permanent HVM measures to increase security for events and areas within the city which attract large crowds and pose the greatest risk from attack. Alongside physical protective measures, the action plan also includes a suite of tactical activity (both overt and covert) training and support to those with responsibility for public safety. York has previously been cited by Government as best practice in terms of its Protect and Prepare Group.
27. The decision taken by the Executive in November 2021 was the culmination of a series of decisions made by the previous Executive. Therefore, in terms of reviewing the decision it is important to consider all the advice and rationale behind those previous decisions. The key points are summarised below with a link to the detailed reports for a full history.
a. In February 2018, the Executive considered the first report which alerted the Executive to the risks around terrorism, particularly for those areas of the city with high numbers of people. Areas where people congregate, and predictably crowded places are defined as targets. The report recognised that the existing vehicular access controls were not an absolute control and relied on people being law abiding, the inference being that terrorists were not law abiding. Executive therefore instigated a scheme of engineering measures to give effect to the traffic regulation orders and a review of who could access the pedestrian area. The report recognised the potential impact on Blue Badge holders and requested engagement with disabled people’s organisations.
b. In September 2018, the Executive considered a report which proposed a phased approach to security measures within the city centre pedestrianised zone. The Council having received advice from the Counter Terrorism Unit and the Centre for the Protection for National Infrastructure appointed industry experts to risk assess the streets that posed the greatest risk from a Hostile Vehicle Attack, this was attached as an annex. The report was accompanied by a letter from the Police urging action as they considered the lack of suitable vehicle mitigation measures in York an unacceptable risk for the city. It identified Article 2 of the European Convention of Human Rights (also described as The Right to Life) and how it places a positive duty on the state (i.e., public bodies) to protect life. A scheme was proposed to protect the priority one area including Parliament Street, High Ousegate, Spurriergate, Coney Street, Daveygate, Finkle Street, Church Street and Jubbergate. This was identified as a first phase, taking an onion skin approach, with future phases of protection to a much wider area identified as priority/phase 2. The report recognised that some people would be disadvantaged as a consequence of making the city safer by reducing the risk of attack, but presented means to mitigate these impacts. The Executive approved an Experimental Traffic Regulation Order adding St Sampson Square to the phase 1 / priority 1 area see map at Annex D attached to this report.
c. At Executive in August 2019, the Executive considered a further report. This updated on the engagement with disabled people and disabled people’s organisations and made the Experimental Traffic Regulation Order permanent removing the access from St Sampson Square. The My City Centre Project was commissioned by Executive.
d. In
February 2020, the Executive approved the anticipated revenue and
capital allocations for the Hostile Vehicle Mitigation measures and
authorised a procurement process to progress the phase 1/priority 1
area.
https://democracy.york.gov.uk/documents/g11116/Public%20reports%20pack%20Thursday%2013-Feb-2020%2017.30%20Executive.pdf?T=10
e. In response to the COVID19 Pandemic and the requirement to queue outside shops, the exemption which allowed Blue Badge holders to park on some pedestrianised streets outside the phase 1/priority area was temporarily removed. In June 2020 the Executive approved a One Year Transport and Place Plan as part of its COVID19 Recovery and Renewal Strategy. The Executive decided to extend the removal of Blue Badge access in footstreets as part of the economic recovery to create increased public spaces that can be used by local businesses to adapt their operating models with outdoor seating. In response, some areas for Blue Badge parking were provided on the outskirts of the pedestrian area and linked to shop mobility and a temporary shuttle service. A temporary extension to footstreet hours later into the evening during COVID19 was also extended through the recovery phase.
f. In November 2020 whilst the pandemic restrictions continued, a decision was taken by Executive to extend the arrangements which excluded Blue Badge access until September 2021 and also to initiate the process of making these changes permanent. This allowed the Hostile Vehicle Mitigation Measures project to be brought forward in a single stage/phase see map at Annex D attached to this report. The Executive commissioned a Strategic Review of City Centre Access and Council Car Parking. https://democracy.york.gov.uk/documents/g12407/Public%20reports%20pack%20Thursday%2026-Nov-2020%2017.30%20Executive.pdf?T=10
g. In June 2021, the Executive Member for Transport approved a number of further changes to add additional Blue Badge parking bays to the city centre outside the footstreets zone, following engagement with disabled people and disabled people’s organisations. They also approved the formal advertising of the proposed Traffic Regulation Order, to remove the exemptions on vehicles with a Blue Badge from permitted access to Blake Street, Castlegate, Church Street, Colliergate, Goodramgate (between Deangate and King’s Square), King’s Square, St Helen’s Square, Lendal. https://democracy.york.gov.uk/documents/g12726/Public%20reports%20pack%20Tuesday%2022-Jun-2021%2010.00%20Decision%20Session%20-%20Executive%20Member%20for%20Transport.pdf?T=10
28. The Executive considered a number of linked reports in November 2021; My City Centre Strategic Vision - Adoption of Vision and Next Steps, Strategic Reviews of City Centre Access and Council Car Parking and finally the report on Consideration of Changes to the City Centre Traffic Regulation Order.
29. These documents and annexes can be found in full https://democracy.york.gov.uk/documents/g12797/Public%20reports%20pack%20Thursday%2018-Nov-2021%2017.30%20Executive.pdf?T=10
but rather than repeat all the information here the key points are summarised below:
a) My City Centre Strategic Vision – Adoption of Vision and Next Steps
The Executive adopted the My City Centre Strategic Vision as a guide to investment in the city centre, to inform policy decision and as a material consideration in planning. The report outlined how the My City Centre project has been shaped through extensive public and stakeholder consultation. Eight individual themes emerged:
i. Family Friendly City Centre - putting families at the heart of a reimagined city centre.
ii. Events Experiences & Investment in Public Spaces - focus new investment on improving existing city spaces and improving the market offers in the city.
iii. An Attractive City Offer at All Times – creating an early evening economy and encourage new home workers to visit the city after work and build on the popularity of outdoor café culture that has developed during the pandemic and post restrictions.
iv. Making Tourism Work for York - Acknowledging the huge benefits that tourism brings in supporting our economy and sustaining our city centre, harness the positive benefits for our residents and communities and reduce, offset and mitigate any negative impacts.
v. Embracing Our Riversides – making the rivers part of everyday life in the city, opening up new access routes and riverside environments and exploring their use as transport corridors, whilst also focusing on river safety.
vi. City Centre Community which is Welcoming for All - create new city living and ensure the facilities and services that our city centre communities need to thrive exist.
vii. Thriving Businesses and No Empty Buildings - support businesses in the centre, allow them to grow and adapt, whilst also promoting more temporary uses and making better use of vacant buildings.
viii. Celebrating Heritage and Making Modern History - balancing the heritage environment with the needs of a successful 21st century city that supports the modern lifestyles of our communities.
b) Strategic Review of City Centre Access Executive approved several separate documents and action plans. Within the annexes were a number of reports including the Martin Higgett report which can all be found at: https://democracy.york.gov.uk/mgAi.aspx?ID=60464#mgDocuments
i. Approved the Strategic Review of City Centre Access and an Action Plan to improve access, including the creation of an Access Officer post, improving toilet facilities, further Blue Badge parking, investment in Dial a Ride and Shop Mobility. This has since been reviewed and updates on progress provided to several scrutiny committees (include as an Annex E to this report).
ii. Approved the Strategic Review of Council Car Parking which established the criteria by which Car Parks should be evaluated and scored and produced an associated Action Plan, which covered a range of issues such as improving the management information available about usage, working with disabled people and disabled people’s organisations to identify what makes a good car park and diversifying the park and ride sites, most of which is either delivered or in progress.
c) Consideration of Changes to the City Centre Traffic Regulation Order
In the context of the My City Centre Vision previously approved on the agenda and the approved action plans as part of the Strategic Review of City Centre Access to further improve access to the city centre. Executive:
i. considered the responses to the statutory consultation on the removal of Blue Badge exemptions permitting access to footstreets during pedestrianised hours;
ii. considered the impact of the proposals on Blue Badge holders and the disabled community, as identified through the statutory consultation and the wider engagement work the council has undertaken. Some of this community made clear that removal of the exemption will remove their ability to access the footstreets which was set out and considered within the Equalities Impact Assessment (“EIA”);
iii. made the decision to remove the exemption which allowed vehicles displaying a Blue Badge to access Blake Street, Church Street, Colliergate, Goodramgate between Deangate and Church Street, King’s Square, Lendal, St Andrewgate between its junction with King’s Square and a point 50 metres northeast and St Helen’s Square during the pedestrian hours;
iv. made the decision to not proceed with a permanent change to remove Blue Badge access to Castlegate, as it was not in the hostile vehicle mitigation zone and therefore not affected by the Counter Terrorism Policing advice;
v. approved the implementation of the additional Blue Badge parking that formed part of the statutory consultation, with the exception of the two bays on St Andrewgate nearest to its junction with Bartle Garth (recognising the consultation relating to St Andrewgate);and
vi. decided to commence a statutory consultation on a permanent change to footstreet hours to be 10:30 am to 7:00pm. To give effect to the My City Centre Vision which has an aspiration for long term footstreet hours that run until 7:00pm.
30. Based upon those decisions, the bollards that will secure the city centre from a hostile vehicle attack have now begun to be installed. The Council have ordered the bespoke equipment and is in contract with an installer. Where these have been installed it will remove the requirement for most temporary measures this Christmas.
31. In July 2022, Executive decided that they would postpone any decision to undertake the statutory traffic regulation order consultation on a permanent change in footstreet hours to 7:00 pm until new pavement café guidance could be developed. https://democracy.york.gov.uk/documents/g13288/Public%20reports%20pack%20Thursday%2028-Jul-2022%2017.30%20Executive.pdf?T=10
32. In November 2022, Executive considered a report on the deregulated approach to Pavement Café Licenses https://democracy.york.gov.uk/documents/g13292/Public%20reports%20pack%20Tuesday%2022-Nov-2022%2017.30%20Executive.pdf?T=10
33. Pavement cafes were initially a response to COVID19 under emergency government legislation as part of immediate economic support and the “Eat out to help out” scheme. Government has since announced that a deregulated approach would become permanent change. As the City had returned to more normal post COVID19, the impact that emergency pavement cafes had on specific access issues became more apparent. The report recognised that pavement cafes are here to stay in some form in the future but are no longer part of an emergency response. Therefore, new guidance and conditions around when and where cafes are acceptable was developed with an external access consultant with the input of disabled residents.
34. Recognising the impact that current temporary arrangements have had on residents and visitors, particularly on people with health conditions or impairments, Executive decided that café licences issued under the fast-track approach would only be allowed on footways if 1.5m width remains for people to get past (with the exception of pedestrianised streets with level access between the footway and the carriageway).
35. This had a significant impact in the city centre where many of the pedestrianised streets do not have room for a pavement café, emergency access and a clear footway of 1.5 metres so the number of pavement cafes reduced.
Summary of Position to date
The Counter Terrorism Policing advice is contained within Annexes A and B attached to this report.
36.
The original hostile vehicle mitigation scheme foresaw a first
phase secure zone, focused on Parliament Street, with very little
impact on Blue Badge holders except for the removal of access to St
Sampson Square, which was well used by Blue Badge holders.
37. A second phase of hostile vehicle mitigation was envisaged at a future date to protect a larger area around the first phase, this could have been operated in a more flexible way without necessarily impacting on Blue Badge access, except for events with specific risks, as the initial risk assessment identified this area as a lower risk.
38. The Executive acknowledged/accepted the Counter Terrorism Policing advice that only Emergency Blue Light Vehicles should be allowed in the protected area.
39. In response to COVID19, Blue Badge access was removed to allow room for queuing on street and later to support pavement cafes as part of economic recovery. The café culture, extended early evening economy aspiration, and car free City Centre became part of the My City Centre Vision and Executive determined that it should be a permanent change. Therefore phases 1 and 2 of the City Centre Security Project were merged into a single phase.
40.
As the city moved into a post covid world the real-life impact of
pavement cafes in the City’s narrow streets, with aging
highway infrastructure, has been considered by Members who have
determined that their impact is too great on disabled residents in
many locations, so the local rules on pavement cafes evolved and
the number of cafes has reduced.
41.
The new Council Plan sets out Four Core Commitments in the Council
Plan which are those outcomes they believe will most support the
delivery of their vision. One of which is
“Equalities and Human Rights.
42. The City Centre Vision has been reviewed in light of the new Council and the new Council Plan needs to be applied in reviewing this decision.
43.
The advice in November 2021 was that the impact would be so extreme
that disabled people would have difficulty in accessing or could
not access the footstreets, this is the lived experience.
44. In response, a coalition of charities, associations, action groups and other organisations have worked together to reverse the ban on Blue Badge holders’ access to York’s pedestrian streets.
45. In October 2022 a Reverse the Ban Post Card Campaign was submitted to the council. This can be summarised as follows:
· 2,734 cards received,
· 2,074 were residents,
· 660 were visitors including people who work in York or visit York regularly from the surrounding areas and tourists
· 677 responses contained additional written comments of which
o 231 of which reference to the rights of disabled people under the Human Rights Act / disability discrimination,
o 141 sight personal experiences including how the change has affected them emotionally,
o 86 references to no longer being able to get into the city centre,
o 15 references to political parties,
o 4 references to terrorist activities,
Consultation Analysis
46. To inform this decision Executive have requested an initial consultation on the principles of permitting Blue Badge access within the Hostile Vehicle Mitigation measures.
47. This report considers those consultation responses, outlines options for considering how Blue Badge access could be reinstated and the evaluation of the impacts of such a decision.
48. A report of the consultation is contained within Annex C attached to this report. In summary the total number of responses was 3,126 with approximately 500 paper copies received.
49. The principles and levels of support are as follows:
· Principle 1 - Return to previous access – This principle aims, subject to full consultation, to revert to the Blue Badge accessibility measures that were in place before the emergency COVID measures and the Council’s decision of November 2021 to make them permanent.
83% Agree, 12% Disagree, 5% Don’t know
Total responses = 2867
· Principle 2 - City centre events – Some events, as prior to the November 2021 decision, may require Blue Badge access to be suspended at times (for example during the Christmas Markets).
61% Agree, 32% Disagree, 7% Don’t know,
Total responses = 2870
· Principle 3 - Recognising Security Risks – In light of any security risk intelligence, the Police will have the power to lock down all access to the City Centre under an Anti-Terrorism Traffic Regulation Order, a counter-terrorism measure under the Civil Contingencies Act 2004.
88% Agree, 7% Disagree, 5% Don’t know
Total responses = 2866
· Principle 4 - Finding solutions – the Council Executive agrees to restore Blue Badge access through the new hostile vehicle barriers, then the council will work with Blue Badge holders on the detailed ways to achieve this
90% Agree, 5% Disagree, 4% Don’t know
Total responses = 2858
· Principle 5 - Longer term improvements – The Council is committed to considering and implementing longer-term improvements to accessibility in the city, taking into consideration the needs and opinions of the community on an ongoing basis, including in the development of its Transport Strategy
89% Agree, 4% Disagree, 7% Don’t know
Total responses = 2861
50. There were 1223 detailed comments many of which contain personal data, but 188 provided a personal experience because of the restrictions, 125 provide suggestions on how things can be improved. (access and general ideas), 93 commented on the consultation (81 negative).
51. Due to the way the comments were provided using freetext we could identify he following groups:
Unknown = 754 (unable to identify)
Disabled = 319
Elderly = 12
Business = 7
Family = 2
52. Comments for disagreeing with Principle 1 came from businesses, people who felt the streets would become unsafe and those who either thought the whole of the city centre would be opening up and not enough information to be able to make a decision
53. Although the majority agreed with principle 2 (and the requirement for restrictions for come city centre events) there were more comments against this principle than there were for it.
54. Most responses were in favour of principle 3, however there was concern that the ATTRO could be used to close the city centre whenever the council decided it wanted to.
55. A small number of comments were around deliberately delaying tactics to give the council time to find excuses to change its mind on the commitment to reverse the ban.
56. The biggest message of all was – just get on with it and stop delaying by wasting money on unnecessary consultations.
57. This shows strong support for the principles but only 61% supported the principle “Some events, as prior to the November 2021 decision, may require Blue Badge access to be suspended at times (for example during the Christmas Markets).” and 32% did not support this principle.
58. Officers recognise the lower levels of support for Principle 2: City centre events, that some events, as prior to the November 2021 decision, may require Blue Badge access to be suspended at times (for example during the Christmas Markets). In response clientofficers from will open discussions with Make It York to explore how future Christmas Markets may be able to be organised and be designed to permit Blue Badge access.
59. An Economy, Place and Transport Scrutiny Committee considered the options outlined in this report and heard from key stakeholders. Scrutiny made the following resolutions:
i. That the Committee would recommend, based on the information available to the Scrutiny Committee, that the Executive do not support Option B within the report;
ii. That the Scrutiny Committee would recommend to the Executive that the primary focus on any decision in relation to the Consideration of changes to the City Centre Traffic Regulation Order (Footstreets) report, to be considered by the Executive on 12 October 2023, be made in relation to the security of the city centre weighted against the access requirements of individuals;
iii. That the Committee would request that the Executive engage with Make it York, about whether there were alternative arrangements which could be put in place to run the city’s Christmas market. With a focus for alternative arrangements to enable blue badge access
iv. That the Committee would request that officers include the following within the Consideration of changes to the City Centre Traffic Regulation Order (Footstreets) report:
a) Reference to both the Martin Higgitt report and the report produced by the University of York;
b) Reference to the number of signatures to the Reverse the Ban petition;
c) Further detailed information regarding the financial impact of different options presented within the report, including the impact on York’s economy by the loss of any spending from blue badge holders;
d) Any relevant information available to the Council regarding decisions made and or considered in relation to access to the footstreets from 2011;
e) Whether the Care Act 2014 had been considered in determining the options presented in the report;
v. That the Committee would request that officers engage with the Counter Terrorism Police and any other relevant bodies to explore any further briefings to Councillors regarding the risk of terrorist attacks and the role of hostile vehicle measures in preventing or limiting the impact of said attacks.
60. Advice has been received from the Monitoring Officer, that whilst members are welcome to read the academic submission it cannot purport to provide legal advice, since that is reserved to the Monitoring Officer and Legal Services Team, and it cannot be taken as overriding the advice provided by security services.
61. The Monitoring Officer has advised that Members are entitled to take decisions which fall within the range of reasonable options open to them. The decision taken in 2021 was one such decision, as it was within the range of options available based on the information and advice presented to the decision-maker; however, that does not mean that no other decisions are possible, and a new decision-maker may consider the same, or the same and additional, information and advice and come to a different decision. Both of those decisions would be lawful.
62. Whilst Section 1(1) of the Care Act 2014 imposes a general duty on a local authority, when exercising a function under Part 1 of the Care Act 2014 in the case of an individual, to “promote that individual’s well-being”, one might argue that in the context of installing Hostile Vehicle Mitigation (“HVM”) measures and restricting vehicular access to/parking of vehicles in the city centre, the Council is not exercising a function under Part 1 of the Care Act 2014, and therefore the general duty set out in Section 1(1) is not relevant, and instead the relevant legal duties to be taken into account might just be those set out in HRA 1998 and the EA 2010 as referred to elsewhere in this report.
63. That being said, statutory guidance on the Care Act 2014 has stated that the general wellbeing principle applies equally to those who do not have eligible needs but come into contact with the system in some other way (for example, via an assessment that does not lead to ongoing care and support) as it does to those who go on to receive care and support, and have an ongoing relationship with the local authority. The general duty to promote wellbeing should therefore inform the delivery of universal services which are provided to all people in the local population, as well as being considered when meeting eligible needs.
64. Although technically the general duty to promote wellbeing applies specifically when the local authority performs an activity or task, or makes a decision, in relation to a person under the Care Act 2014, based on the statutory guidance it arguably should also be considered by the Council when it undertakes broader, strategic functions, such as planning, which are not in relation to one individual. As such, wellbeing should be seen as the common theme around which care and support is built at local and national level.
Further guidance can be found at: https://www.gov.uk/government/publications/care-act-statutory-guidance/care-and-support-statutory-guidance#general-responsibilities-and-universal-services
· Is there a better workable solution that a staffed presence, e.g. the advanced booking system used on the M6 Toll Road
· How are blue badge holders picked up from within the footstreets.
· If Blue Badge access is permitted during pedestrianised hours, this will still mean parking for 3 hours max on double yellow lines where parking doesn't cause an obstruction. Option to create some Blue Badge bays to enable parking for longer periods and to provide bays suitable for adapted vehicles.
· With Blue Badge access is there still a requirement for the city centre bus shuttle
· Keeping the way the city centre and the Hostile Vehicle Measures work under review.
· How should other mobility aid such a cycles acting as a mobility aid be managed
Options Analysis and
Evidential Basis
66. The new Council Plan, is a new policy environment with four core commitments that underpin everything the council does. It is clear that in considering this decision the equality of opportunity commitment is important. This has led to a review of the City Centre Vision. This changing policy framework needs to be considered when making this decision.
67. Recognising the decision that have gone before, and in order to consider options to reinstate Blue Badge access to pedestrianised streets, the following options have been considered, some have been discounted and are not recommended.
68.
Option 1 (NOT RECOMMENDED) – revert to two separate
phases of Hostile Vehicle Mitigation. This would allow the
highest risk area focusing on Parliament Street to be
emergency/blue light vehicle access only, Blue Badge access could
then be permitted to the outer area as it existed immediately prior
to the COVID19 Pandemic as this area was defined as a lower risk
area by the original risk assessment.
69. To determine if this is a credible option a refreshed risk assessment would need to be undertaken. It is also not an immediate resolution to restoring Blue Badge access to the pedestrianised streets as it existed before the emergency measures in response to COVID19, as it would take significant time to implement. The other issue is that this option would have significant capital costs of approximately £2,000,000. It would also introduce further construction works in the city centre, which like any construction causes disruption to residents and businesses.
Option 1 therefore is NOT recommended.
70. Option 2 – This option is to make no change to the way Blue Badge access into the pedestrianised area operates. This would provide maximum mitigation to the security risks in accordance with the previous advice from Counter Terrorism Policing that any additional motor vehicles in a pedestrianised area poses a risk. However, it continues to disadvantage many disabled people. Any decision must consider the balance of rights and risks, and subsequent decisions of the Council as described above and the expectations of the revised Our City Centre vision if approved earlier on the agenda for this meeting.
71. Option 3 – is to continue to operate the hostile mitigation measures and allow Blue Badge access into the secure zone so that Blue Badge access will be permitted to Blake Street, Lendal, St. Helen’s Square, Goodramgate (between Deangate and King’s Square), Church Street, Kings’ Square and Colliergate. This conflicts with the advice of the Counter Terrorism Policing Teams, but is a balance the Council needs to make. The risk is that vehicles within the secure zone can be commandeered and used as a weapon anywhere within the secure zone by those determined to do so. There is also the intrinsic risk of having any vehicles in an area where there is a public expectation of no vehicles, this does however mirror the risk prior to COVID19. Previous accident data is contained within Annex F of this report.
72.
This risk could be reduced with the introduction of a An
Anti-Terrorism Traffic Regulation Order (ATTRO)an ATTRO to give the
police powers to remove Blue Badge access for events or specific
risks. An ATTRO is a counter terrorism measure pursuant to the
provisions of the Civil Contingencies Act 2004. Members may recall
that a temporary ATTRO was put in place for the Maundy Thursday
visit of the now King. This allows traffic orders to be put in
place by the Traffic Authority for the purpose of: 'avoiding or
reducing, the likelihood of, danger connected with
terrorism’; or 'preventing or reducing damage connected with
terrorism’.
73. These orders can only be made on the recommendation of the Chief Officer of Police and are subject to prior statutory consultation. An ATTRO could be put in place on a permanent basis which covers the whole City Centre including the Minster area, but only enacted in response to specific circumstances or elevated threat levels. The contingent nature of the ATTRO means that it would only be utilised as an operational response where the Police believe that this would be a proportionate counter terrorism response to the needs of an event, incident or to intelligence received.
74. The ATTRO would only be brought into use as an operational tool under the direction of the Police, where the responsible officer has sound reasons on the basis of a security assessment or tactical intelligence of a likelihood of danger or risk of harm due to terrorism. Having a permanent ATTRO would mean that the Police could rely on the order being generally available as an operational tool but on a contingency basis that could be “activated” at any time in accordance with the Schedule to the ATTRO which reflects the statutory requirements for making such an order.
75. The mechanism and robustness of the system for permitting Blue Badge holders is a key component of Members considerations of reconsidering Blue Badge access through the secure Hostile Vehicle Mitigation measures and this needs further work and co-design with Blue Badge holders. The access arrangements are not for specific cars but for Blue Badge holders in any vehicle they are travelling in, which means the system needs to be able to admit any vehicle carrying a Blue Badge holder. Therefore, discussions with the Blue Badge holders as to whether restrictions of vehicle types would be appropriate, i.e., under 3.5 tonnes, will be needed. Blue badges are not issued nationally but by local councils for residents in their area so cross checking a Blue Badge which has not been issued in York remotely is not easy. A Blue Badge is very small and not easily picked up by CCTV and would often need to be removed from the vehicle as the windscreen can cause reflection and the badge needs to be checked against the person who it has been provided to. Automatic Number Plate Recognition is not an option as, as noted above, Blue Badges are provided to the person not a vehicle and can be used in taxis etc, so reconciling that a number plate provided into a booking system actually was being provided by a Blue Badge holder is impossible. The most obvious solution that provides maximum accessibility and minimal inconvenience to Blue Badge holders is a security guard at two entry points who can liaise with the control room to open the bollards once the Blue Badge has been verified. However, this is likely to come with some significant revenue costs detailed in the finance section.
76. Counter Terrorism Policing have confirmed at the scrutiny last month that the advice contained with Annex B of this report remains their current advice. The Executive have been briefed in private by Counter Terrorism Policing.
77. There is an increased risk of no intent accidents between pedestrians and vehicles if more vehicles are in the pedestrianised streets (footstreets). Previous accident data is contained with Annex F. This risk could be mitigated by reinstating the exclusion of Blue Badge holders for the busiest events such as the Christmas markets, or reviewing the layout of streets with Blue Badge access.
78. Should members choose Option 3, the existing traffic regulation order does not need to be consulted upon to permit Blue Badge access. The current Traffic Regulation Order states:
“A Vehicle proceeding upon the direction or with the permission of a police constable in uniform or a traffic warden or proceeding with the permission of the Council's Head of Transport or a person authorised to grant such permission on behalf of the Council's Head of Transport.”
79. Should the Executive choose Option 3, the Head of Transport or appropriate officer can authorise those that staff the future barriers to grant permission to access and egress the pedestrian area without a change to the Traffic Regulation Order.
80. Should the Blue Badge holders be permitted access, there will be a further impact on pavement cafes. Whilst this is not material to balancing the security advice and balancing the equalities and human rights issues members need to take their decision in full knowledge of the impacts of that decision. Details of this impact are contained with Annex I of this report.
Organisational
Impact and Implications
81. When Executive made the decision in November 2021, they weighed up the security advice with the impact on Blue Badge holders. It was, and remains, a difficult decision.
82. The previous Executive favoured fulfilling the full security advice. By excluding all Blue Badge holders Executive were made aware that the impact on disabled people would be so extreme that they would have difficulty in accessing and that some disabled people would not be able to access the pedestrianised streets (footstreets) at all.
83. When considering the circumstances as they exist today, including subsequent decisions and assuming the approval of the Our city Vision on this agenda, Executive need to accept that in order to permit Blue Badge access it has not been possible to find a way to deliver the full Counter Terrorism Policing Advice.
84. When considering the options, the Executive are required by law to consider if the options to restore Blue Badge access are reasonable and proportionate, having fully considered the Equalities Impact Assessment. This is attached as Annex G to this report.
85. The Executive therefore need to weigh up (inter-alia) the following issues:
· consider the advice from counter terrorism policing and the right to life and duty to protect life,
· consider the equalities and human rights benefits to Blue Badge holders of restoring access,
· consider any extra equalities and human rights benefits by heeding the counter terrorism policing advice,
· consider the proposed mitigation of Blue Badge access being restricted during the busies events and the introducing an Anti-Terrorism Traffic Regulation Order for the events and circumstances of highest risk.
· consider any revisions the Executive may have approved to the Our City Centre Vision
· consider the above in the context of the new Council Plan
· consider changes to the uses of pedestrianised streets since the previous decision to exclude Blue Badge holders was made (based upon subsequent Executive Decisions regarding Pavement Cafes and pedestrianised hours) and therefore reconsider the risk profile,
· consider the impact on businesses who will be impacted and may have their pavement café licence removed or reduced,
· Financial
Depending on the option chosen there will be different financial implications. Should the operation continue as planned there will be no additional costs. Should Members allow access into the inner area there will need to be staffed points at locations to be determined. The cost during pedestrianised hours (10:30-17:00) would be c £43,000 per person per location per year. It is considered that at a minimum there would need to be approximately four times resource to cover the points at Goodramgate and Blake Street therefore a cost of £172,000. There are also additional costs at the CCTV room as demands for exiting the zones will increase. It is estimated that this will increase costs to £200,000 per annum.
The cost could be mitigated by reducing the number of access points, but this would impact upon the access that could be achieved and is therefore not presented as an option.
These costs cannot be contained within existing budgets and therefore, should the Executive commit to this recommendation, additional budgets would need to be identified. For a full financial year budget, the Executive can commit to the additional budget being a priority growth commitment in the 2024/25 budget.
For the part year it is estimated that the costs will start to be incurred from January 2024 and therefore additional costs will be in the region of £50,000. The Place Directorate is forecast to underspend in year and therefore the costs can be contained within the Directorate budget however there remains a significant council overspend that needs to be reduced.
· Human Resources Depending on the option agreed by the Executive and whether HVM points require staffing, HR implications and staffing options will be considered following HR policies and procedures.
· Legal
The Council, as Highway Authority and Local Traffic Authority is responsible for making Traffic Regulation Orders (TRO). The Council has a statutory duty to secure the expeditious, convenient and safe movement of vehicular and other traffic (having regard to the effect on amenities).
Any amendment to an existing Traffic Regulation Order will need to be effected in accordance with the relevant statutory procedures including the requirement for formal consultation and advertisement in the local press. Where objections are received, there is a duty on the Council to ensure that these objections are duly considered.
An Anti-Terrorism Traffic Regulation Order (ATTRO) is a counter terrorism measure pursuant to the provisions of the Civil Contingencies Act 2004. This allows traffic orders to be put in place by the Traffic Authority under S.6, 22C and 22D of the Road Traffic Regulation Act 1984, for the purpose of avoiding or reducing, the likelihood of, danger connected with terrorism; or preventing or reducing damage connected with terrorism. An ATTRO can only be made by the Council on the recommendation of the Chief Constable of Police. The implementation of an ATTRO will follow the same statutory procedure as a Traffic Regulation Order under The Local Authorities’ Traffic Orders (Procedure) (England and Wales) 1996.
The Council must comply with the Public Sector Equality Duty as set out in Section 149 of the Equality Act 2010. This means in relation to making a decision, the decision-maker must firstly understand their obligations under the PSED. This is a duty to have due regard to the need to:
1. eliminate discrimination, harassment, victimisation and any other conduct that is prohibited by or under the Equalities Act 2010.
2. advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it; and
3. foster good relations between persons who share a relevant protected characteristic and persons who do not share it.
Technical guidance provided by the Equality and Human Rights Commission assists public bodies in discharging the duty in practice and this is expressly brought to Members’ attention. https://www.equalityhumanrights.com/en/publication-download/technical-guidance-public-sector-equality-duty-england)
Secondly the decision maker must have sufficient relevant information and demonstrably take this information fully into account throughout the decision-making process.
The concept of due regard requires that there has been proper and conscientious focus on what the duty requires at 1-3 above. If that is done, a court cannot interfere with the decision simply because it would have given greater weight to the equality implications of than the decision maker did. However, the decision maker must be clear precisely what the equality implications are when they put them in the balance. A public body can lawfully conclude that other considerations outweigh the equality ones. This could include security concerns or available resources provided that the weight given to those countervailing factors is not irrational.
Thirdly, the courts have established that the potential impact of a decision on people with different protected characteristics is a mandatory relevant consideration. The manner of assessing that impact is discretionary. Often an Equality Impact Assessment is an appropriate tool but is not the only available tool. It is the quality of the assessment whether that is presented in an EIA or some other evaluative report which is important.
· Procurement – Each option presented hold different levels of procurement implications. The implications are as follows:
Option 1: Any additional work to be carried out within the city centre, subject to funding must be procured via a compliant, open, transparent, and fair process in accordance with the Council’s Contract Procedure Rules and where applicable, the Public Contract Regulations 2015. Further advice regarding the procurement process and development of procurement strategies must be sought from the Commercial Procurement team.
Option 2: There are no procurement implications should the council proceed with Option 2.
Option 3: Whilst there are no direct procurement implications with Option 3, should the Council decide to procure the additional staff rather than recruit, procurement will apply. If any services are required, this must be procured via a compliant, open, transparent, and fair process in accordance with the Council’s Contract Procedure Rules and where applicable, the Public Contract Regulations 2015. The Council may explore varying existing security contracts to include the additional security guard requirement, however, this will be subject to the Public Contract Regulations and subject to the safe harbour provisions under Regulation 72. A full procurement exercise may need to be carried out should the Commercial Procurement team and Legal Services team deem the variation unjustifiable and a high risk. Further advice regarding the procurement process and development of procurement strategies must be sought from the Commercial Procurement team.
· Environment and Climate
The climate impacts are negligible from the options. The report and options define how the city centre environment is managed.
· Affordability
There is not expected to be additional impacts from this report on low-income groups.
· Equalities and Human Rights,
As per the previous sections of this report, the Council recognises, and needs to take into account its PSED under Section 149 of the EA 2010 (to have due regard to the need to eliminate discrimination, harassment, victimisation and any other prohibited conduct; advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it and foster good relations between persons who share a relevant protected characteristic and persons who do not share it in the exercise of a public authority’s functions).
A full EIA can be found in Annex G attached to this report.
· Data Protection and Privacy
Data protection impact assessments (“DPIAs”) are an essential part of our accountability obligations and is a legal requirement for any type of processing under UK GDPR. Failure to carry out a DPIA when required may leave the council open to enforcement action, including monetary penalties or fines. DPIAs helps us to assess and demonstrate how we comply with all of our data protection obligations. It does not have to eradicate all risks but should help to minimise and determine whether the level of risk is acceptable in the circumstances, considering the benefits of what the council wants to achieve. As there is no personal data, special categories of personal data or criminal offence data being processed to inform the Consideration of changes to the City Centre Traffic Regulation order (Footstreets), there is no requirement to complete a DPIA This is evidenced by completion of DPIA screening questions. However, there will need to be consideration and completion of DPIAs where required, within delivery of the plan.
· Communications
Those impacts will not immediately be removed through a different decision alone. A carefully constructed approach to stakeholder engagement in the ongoing work to deliver any change required following consultation on principles will be essential to the effective delivery of an accessible city centre, as well as regaining the goodwill and trust of affected communities and campaigners. Support for the engagement approach, and accompany public and media reactions work will be required from the communications service.
· Economy
In the 2-years since the ‘My City Centre’ Vision was
adopted, York city centre has continued to recover strongly from
the impact of the COVID19 pandemic alongside an evolving context of
regulatory change for accessibility and business activity. In
this period, the city has also adopted three significant 10-year
strategies, including a new Economic Strategy. To reflect the
current environment and align to the city strategies, a separate
report on this Executive agenda is proposing that the city centre
vision is updated and re-launched as the “Our City Centre
Vision”, with a stronger focus on accessibility, residents,
climate resilience and carbon reduction.
Some of the options outlined in this report have potential to
impact on existing pavement licenses for up to 19 businesses.
Removal of, or changes to, the availability of outside seating
areas will inevitably run the risk of direct commercial impact for
these specific businesses.
With one in five of all households including people with disabilities, the Purple Pound – that is to say, the money that those households spend – represents a significant proportion of the UK economy. Disability charity Purple (https://wearepurple.org.uk/the-purple-pound-infographic/)
have estimated the total value of the Purple Pound to be close to £300bn per annum for the UK, and using their methodology suggests that its value to York is £820m per annum. Around 10% of consumer spend in York happens in the city centre, so for the area under consideration in this report, the value of the Purple Pound is approximately £80m per annum, with around £16m of that coming from households which include a Blue Badge holder.
Risks and
Mitigations
· The security advice is that the installation of Hostile Vehicle Mitigation Measures are a significant improvement in the security of the city centre.
· The security advice is that their preference is for only blue light vehicles to be permitted into the secure zone. Should Executive permit blue badge access through the Hostile Vehicle Mitigation Measures it adds a level of risk.
· In addition to the security risk permitting blue badge holders into the secure zone does generally raise the risk of an accident between a vehicle and pedestrian.
· However ,the risk is something that the security services can only advise on, the judgement call is for the Council to determine where its appetite for risk lies against the impacts of such restrictions and whether the mitigations are proportionate.
· The mitigations proposed are the introduction of Anti Terrorism Traffic Regulation order to respond to intelligence regarding specific terror risks in York. To mitigate the accident risk, it is proposed to restrict access for the busiest events e.g., the Christmas Markets.
Wards Impacted
86. Disabled people live in all wards.
Contact details
For further information please contact the authors of this Decision Report.
Author
|
Name: |
James Gilchrist |
|
Job Title: |
Director of Environment, Transport and Planning |
|
Service Area: |
Place Directorate |
|
Telephone: |
01904 552547 |
|
Report approved: |
Yes |
|
Date: |
03/10/2023 |
Background
papers
All relevant background papers must be listed.
Technical guidance provided by the Equality and Human Rights Commission assists public bodies in discharging the duty in practice and this is expressly brought to Members’ attention. https://www.equalityhumanrights.com/en/publication-download/technical-guidance-public-sector-equality-duty-england)
Executive - February 2018 - City Transport Access Measures
Executive - September 2018 – City Centre Access and Priority 1 Proposals
Executive - August 2019 - My City Centre Project https://democracy.york.gov.uk/documents/g11108/Public%20reports%20pack%20Thursday%2029-Aug-2019%2017.30%20Executive.pdf?T=10
Executive - August 2019 - City Centre Access Experimental Traffic Order Conclusion and Phase 1 Proposals https://democracy.york.gov.uk/documents/g11108/Public%20reports%20pack%20Thursday%2029-Aug-2019%2017.30%20Executive.pdf?T=10
Executive - February 2020 - City Centre Access – Phase 1 Proposals (Update)
Executive – June 2020 - City of York Council Recovery and Renewal Strategy
Executive - November 2020 - City of York Council Recovery and Renewal Strategy - November Update
Executive - November 2020 - The Future of the Extended City Centre Footstreets
Executive Member for Transport – June 2022 - Footstreets Traffic Regulation Order Proposals
Executive - November 2021 - My City Centre Strategic Vision - Adoption of Vision and Next Steps
Executive - November 2021 - Strategic Reviews of City Centre Access and Council Car Parking
Executive - November 2021 - Consideration of Changes to the City Centre Traffic Regulation Order.
Executive - July 2022 - City Centre Access Action Plan Update
Executive - November 2022 - Pavement Café Licence Update https://democracy.york.gov.uk/documents/g13292/Public%20reports%20pack%20Tuesday%2022-Nov-2022%2017.30%20Executive.pdf?T=10
Terrorism (Protection of Premises) – Draft Bill
.
Annexes
Annex A – Original Police Advice
Annex B – Advice from Counter Terrorism Policing Northeast for November 2021 Executive
Annex C – Restoring Blue Badge Principles Access Results
Annex D – Map showing Phase 1/Priority 1 Area and later decision to deliver larger area in a single stage/phase
Annex F – Historical Accident Data in York Footstreets
Annex G – Equalities Impact Assessment
Annex H – Map showing Option 3
Annex I – Pavement Café Impacts