Richmond Council are consulting on a Public Space Protection Order (PSPO) that would criminalise offers of help and prayer outside the BPAS centre on Rosslyn Road.

The most effective way to respond to Richmond’s consultation is through their online portal. Below is an easy reference guide that highlights the most important questions in the consultation, along with justifications and  suggested responses where applicable. These are only suggested responses, and you are free to respond to the consultation however you see fit.

IMPORTANT NOTE: You do not have to answer every question in this consultation (aside from providing your postcode) so where you aren’t sure how to respond to a question, you do not have to comment and can leave the answer blank.

This guide intentionally skips a number of questions (sometimes whole pages) to focus on the main issues raised by the consultation, but you are entirely free to answer whichever questions you are drawn to.

Question 1

Asks in what capacity you are responding. You can tick options that apply to you, but it is not a mandatory question.

Question 2

Asks for your postcode, and is the only mandatory response.

Question 7

Asks whether you agree or disagree with the proposal to implement a buffer zone. As the proposed buffer zone would criminalise prayer, offers of help and any conversations about abortion, we would recommend that you select Disagree.

Question 8

Asks whether you agree or disagree with the boundaries of the proposed buffer zone in the Rosslyn Road area.

We would recommend that you select Disagree on the basis that it completely removes vigil members from the area regardless of what they are doing, which is completely disproportionate.

Feel free to use the text below as a basis for providing additional comments on this question:

Question 9

Asks whether you agree or disagree with a number of proposed prohibitions in the buffer zone. We would recommend responding as follows:

Protesting, namely engaging in any act of approval or disapproval or attempted act of approval or disapproval, with respect to issues related to abortion services, by any means, including, without limitation, graphic, verbal or written means, and including, for the avoidance of doubt, any form of counselling or interaction with residents or BPAS clients on the street

Disagree as these provisions are vague and would criminalise offers of help.

Interfering, or attempting to interfere, whether verbally or physically, with a BPAS client or member of staff

Disagree as again these provisions are vague and broadly drawn. “Attempting to interfere verbally” would criminalise even a simple greeting. There are extensive criminal provisions that would adequately deal with any physical interference, rendering these provisions unnecessary.

Intimidating or harassing, or attempting to intimidate or harass, a BPAS client or a member of staff

Disagree as vigil members have been accused of “harassing” women by offering a leaflet which details the support available to them. From a legal perspective, the wording “attempting to harass” is too vague if criminal sanctions are to be imposed.

Recording or photographing a BPAS client or member of staff of the clinic whilst they are in the buffer zone

Neither agree nor disagree in principle this isn’t problematic as vigil members do not record or photograph individuals entering or leaving the the BPAS centre. However, the neither agree nor disagree option is recommended as this should be dealt with under the existing criminal law and not through a PSPO.

Displaying any text or images relating directly or indirectly to the termination of pregnancy

Disagree as these provisions are vague and would criminalise offers of help.

Question 13

Asks whether you think the proposed prohibitions may have an impact, either positive or negative, on any group of people with a protected characteristic under the Equality Act 2010.

We would recommend that you select Yes.

If a buffer zone was to be brought in, two groups of people with protected characteristics would be negatively affected. Firstly, pregnant women, as they would be denied the right to receive information about support and help available to them if they did not want to have an abortion. Secondly, individuals with religious faith, as they will be prevented from praying for those affected by abortion in any capacity.

Feel free to use the text below as a basis for providing additional comments on this question:

Question 14

Asks whether you have any final comments on the consultation – please add any further thoughts you might have on the imposition of a buffer zone.

You could question whether it is reasonable and proportionate for Richmond to explicitly ban prayer and offers of help and support made by any member of the public – it criminalises otherwise peaceful, legal, reasonable and often charitable activity. You could also raise concerns about the fact that the wording of the buffer zone is almost identical to the one in Ealing, which is currently subject to a legal challenge.

Feel free to use the text below as a basis for providing additional comments on this question:

Once you are happy with your responses, go through to the end of the consultation until you reach the confirmation page that says “Your response has been submitted”.