Paving The Way for inclusive streetspace: our manifesto for ‘EQIAs in Action’
We want to see a complete overhaul of the engagement and consultation model, and a ‘rebranding’ of EQIAs.
An Equality and Impact Assessment (EQIA) is a document that allows someone who has decided to do something, such as a local council deciding to put in a new bus stop, to look at the impact that what they are proposing will have on people. It should identify the pros and cons for different people (for example, a bus stop might increase access to a bus route, but the stop may block a dropped kerb). The onus is then on the service provider to mitigate against negative impacts.
Sometimes, not all negative impacts can be eliminated, but the service, or scheme, goes ahead anyway. This is how it works, and that’s ok – there is rarely a perfect solution. But this is, by and large, a process that citizens aren’t included in and don’t really understand.
Our recent Pave The Way report identified fundamental problems with the ways decisions are made and communicated to the local residents they affect. 3 in 4 of our participants expressed frustration at the way Low Traffic Neighbourhoods and other streetspace schemes had been communicated to them. An issue that came up time and time again in our interviews was the lack of consultation: disabled residents felt that they had no say in the changes being made.
So what’s going wrong?
From conversations we have been having over the past year with various service providers and local authorities, it seems there is a disconnect between what an EQIA is meant to do, and how they are actually being done in practice.
Currently, EQIAs are often being seen by authorities as an obligatory piece of paperwork, and are often being treated as a tick-box exercise. In actual fact, the document itself (“an EQIA”) is not compulsory at all.
What is compulsory under Section 149 of the Equality Act, known as the Public Sector Equality Duty, is for public bodies to have done their due diligence, and put due regard into eliminating unlawful discrimination and promoting equal opportunities for disabled people.
It’s an active process – a verb not a noun. A public body must have thought about how their policy might impact on disabled people, must have asked and listened to those groups who may be affected, and planned for how to mitigate these impacts.
As we have seen confirmed in the High Court ruling on the Streetspace for London plan, which found that the needs of disabled Londoners were “not considered”, and described parts of the EQIA as “perfunctory or non-existent”, failure to meaningfully carry out these processes can have legal ramifications, in addition to forfeiting the trust and support of disabled residents.
What needs to change? Our vision of co-production
What we know is that an EQIA needs to be the result of a considered and inclusive consultation; this would result in EQIA’s that fairly and openly set out all the impacts. A consultation process should therefore be an ‘EQIA in Action’, a way to actively seek out, listen to, and understand the impact of your service, scheme or idea, on all the people it will affect.
For too long EQIA’s have been completed by internal members of staff without the direct input of external communities with lived experience, a heavy weight of responsibility for those individuals and a lost opportunity for knowledge sharing. This is not fair on anyone and needs to change. A meaningful consultation cannot be undertaken from a desk by one person with little to no understanding of the realities of disabled people.
A good consultancy process should tell you things you don’t already know, from the people you need to hear it from. It is not acceptable to bring people on board at a late stage to confirm a decision that has already been made, instead EQIAs must start out as a blank canvas – learning from the conversations with people with lived experience and adapting accordingly.
An EQIA is a chance to do better, to be innovative, to pave the way in designing and delivering world-class transport and journey initiatives that include and improve for all.
We are working with an increasing number of partners to revitalise the consultancy and EQIA process and we ask all transport providers and operators to do the same.
All travel should be accessible travel but the opportunities to achieve this aim are being lost through fear, complacency and a lack of accountability. It’s an exhausting process for everyone.
Let’s change it.
What should happen now? Our key suggestions:
Transport for All call for our model of consultation, ‘EQIAs in Action’ to be trialled and implemented across the transport sector. This model frames EQIAs as a process of:
- Seeking out the viewpoints of disabled residents using a range of accessible channels
- Asking, listening, and understanding concerns and ideas about the issues (this may involve guided walks, focus groups, etc)
- Learning: a commitment to witnessing the lived experience – walk on the streets or take a train with your residents
- Co-producing solutions with disabled people and organisations with expertise
- Paying disabled experts for this expertise
The EQIA in Action is a not a tick-box exercise that can be done after the decisions have been made and the plans have been drawn up – it should involve disabled experts from the outset.
We ask that, for any new scheme, the authority or provider must submit proof that they have undertaken this EQIA in Action process. This proof must be included in any criteria for accessing funding.
In addition, Local Authorities and transport bodies need to improve the accessibility of their communications with disabled people. It is not sufficient to open up an online portal to collect feedback and wait for disabled people to engage, work needs to be done to engage disabled people in an accessible way:
- Accessible communication: Government, Local Authorities and Transport for London need to communicate the LTN changes to local residents clearly and thoroughly. Information about the schemes must be jargon-free and easy to understand, and must acknowledge and address disabled residents’ concerns. All communications must be available in a range of accessible formats – at a minimum to include:
- For printed communications: large print versions
- For online communications: Text-only word documents or static HTML (accessible to screen-readers)
- EasyRead versions
- British Sign Language translation
- Bridging the digital divide: We are aware that consultations are increasingly moving online. In a recent Government white paper on planning, it is stated “we are moving away from notices on lampposts to an interactive and accessible map-based online system”. With disabled people disproportionally represented in the portion of adult internet non-users, it is vital that steps be taken to reach those who do not have internet access.
- Accessible feedback collection: When councils are seeking feedback online, they must use tools that are screen-reader/keyboard-user friendly and accessible, and must endeavour to collect feedback in different ways to accommodate disabled people where appropriate. We would like to see the accessibility of the Commonplace website improved, and in the short-term where commonplace is used as the primary means, extra work should be done to collect feedback from those who cannot use this service (particularly screen reader and keyboard users).
- Transport User Groups: We recommend that all local authorities commit to setting up and consulting a paid group of disabled residents to shape and inform their planning.