Dear supporter,

Please see a copy of a letter I have sent to Sadiq Khan below. 

Dear Mr Khan,

Given that over 11,256 people have signed the petition ‘Stop TfL closing suburban station car parks’, I would like a detailed reply personally from you please.

I believe there is institutionalised disregard for women, older and disabled persons within TfL. I wish to complain about TfL’s failings in regards to equality, specifically:

1. Any regard to equality in relation to the car park closures came after the decision to close them. This is evidenced by the following:
2. No public consultation on the topic of closing suburban car parks took place.
3. Analysis of 12 Equality Impact Assessments (EqIAs) I obtained from TfL via FOI last year. The analysis shows scant regard has been shown towards women, older people and disabled people. This includes the fact that none of the 12 contain evidence that meaningful consultation with disabled groups took place. For example, the CEO of Inclusion Barnet has stated that they were not made aware of the development by TfL. Read our analysis here: 
4. In relation to your Arnos Grove development, evidence of the poor regard TfL gives to equalities the fact that an EqIA was not included in 169 documents that TfL submitted to Enfield Council in support of its proposed development. In fact it was only provided to the planning authority, Enfield Council, after campaigners pointed out its absence. An FOI proves this. Read our analysis here: 
5. As of 03/11/2021, not one Mayor of London/TfL policy document including the  London Plan (2021) sets out the case for removal of most of London Underground’s suburban station car parks (15 clustered within an area of North West London); the  London Plan (2021) merely talks in general terms about the restriction of car parking generally and it beggars belief that TfL would embark on this policy without properly consulting on and assessing its impacts.
6. In relation to your Cockfosters development, evidence of the poor regard TfL gives to equalities is as follows (in addition to the points 1-4 above, as all the ‘regard’ given to equality issues  postdates the actual decision to close the car park):
   * The 41-page Equality Statement that TfL submitted with the application in July 2021 (more than 2 years after the decision to close the car park was made) gives no consideration whatsoever to women’s safety at night. In fact, the word ‘Night’ does not appear anywhere within the 41 page document.
   * This new ‘beefed up’ 41-page equality statement that TfL has commissioned clearly shows that you’ve heard what campaigners have been saying but you haven’t listened . For example, the document now mentions ‘disabled people who are not Blue Badge’; this is a first, none of your 12 EqIAs that we obtained via FOI mention this and it clearly has only been included because WE raised it with TfL. However, no actual meaningful analysis or consultation in regards to the effects on disabled people who are not Blue Badge holders has occurred. You have simply and quite frankly, cynically, included the phrase in your document.
   * In the table ‘Summary of Effects’ [of the closure of  90% of the 400 space Cockfosters station car park which has a peak utilisation rate of over 90%, according to TfL's own data] women are not mentioned at all (except in relation to pregnancy)! I assume you’ll now mention women in the next equality statement you make for one of these developments, but I’d like to again make the point that simply mentioning something  is meaningless, you actually haven’t given it due regard and the closure breaches the Equality Act 2010. The fact that you left it out of the Cockfosters one when you know what strong opposition you have to the development (almost 3000 individual objections), is indicative of institutionalised disregard for women, older and disabled persons within TfL.
   * The claim within the above mentioned table that “The equality effect upon disabled people who are not Blue Badge, elderly people…are assessed as neutral or potentially minor adverse” is incredulous and there is no evidence for this position provided within the document. Please provide it if it exists. I think it doesn’t exist.
   * Campaigners against the Cockfosters closure have identified around 70 individual objections to the development from disabled and older persons, including my dad who has Parkinson’s, many of them, such as he, who do not hold Blue Badges, who have expressed strongly that there will be major adverse effects on them. I attach a document containing all 71 objections. Would you like me to forward you each email so that you can personally respond to each of them and explain how TfL thinks the effect on them will be “neutral or potentially minor adverse”? These emails are evidence of the importance of the ability to be able to use a car to access London’s transport network by parking at the stations on the lives of the members of the disadvantaged groups that are affected by the inequality of opportunity and the extent of the inequality by permanent closure of the car parks.
7. In summary, TfL made an important policy decision when it decided to close outer London station car parks and, as such, the decision should have been subject to full public consultation. In fact they did not carry out any consultation. Nor did they complete an Equality Impact Assessment relating to the overall policy; in fact, they didn’t even complete Equality Impact Assessments in relation to specific car park closures nor did they carry out proper consultation with car parks users relating to specific car park closures. TfL’s decision to close many of London’s outer London tube station car parks would clearly have far reaching consequences and these would need to be examined under the Equality Act 2010. It embodied an important policy decision and was not simply for TfL’s staff to decide amongst themselves. TfL’s methodology for closing station car parks should have been published and consulted upon. TfL have a duty to have regard to how their policy relating to removing station car parks would affect those with protected characteristics.

Performance of the Public Sector Equality Duty must be an integral part of the decision and not merely the justification for making the decision and there must be enough information to enable the necessary balancing exercise to be carried out. FOIs prove that information that could enable the necessary balancing  exercise was never commissioned/procured/created by TfL and therefore anything presented by your staff in defence of closing the car parks is merely a (poor) justification for the predetermined decision to close the car parks.

TfL is displaying  institutionalised disregard for women, older and disabled persons in its activities. Particularly worrying is the fact that we have shown evidence that they appear to simply add extra words to their equality documents, based on complaints by campaigners, to ‘tick a box’ in regards to fulfilling their duties under the Public Sector Equality Duty. This is meaningless and doesn’t discharge TfL’s Public Sector Equality Duty. TfL has failed in its Public Sector Equality Duty (PSED). It can’t be rectified by simply adding a bit of extra text to a document, that doesn’t show due regard, far from it, in fact that shows utter disrespect -  even contempt -  for the persons affected.

Additionally, regardless of TfL’s failure or otherwise in its PSED, TfL is breaching the Equality Act 2010 in regards to its discriminatory actions against persons protected under the Act. The matter as to whether the PSED is discharged is separate to whether TfL’s actions breach the Equality Act 2010.

Given the volume of people who have signed/continue to sign this petition and the strong representations made specifically about the equality implications of closing the Arnos Grove and Cockfosters station car parks from vast numbers of people, including many protected under the Equality Act 2010, I think campaigners have conducted the full public consultation on behalf of TfL;  the results of the consultation are crystal clear – do not close the suburban station car parks, TfL.

I look forward to your reply.

Yours sincerely,

Kate B