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Richmond Consultation

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 (see here for a link to an easy reference guide to a consultation submission) however if it is more convenient for you, we have prepared a one-click email submission below that can be sent to Richmond Council.  

You can review the pre-populated responses, make any amendments you see fit, and click “send” at the bottom of the page to submit the response to the Council.

IMPORTANT NOTE: These are only suggested responses – you are free to respond to the consultation however you see fit. You can amend all answers contained in this submission – these submissions are yours and you are fully responsible for your responses.

The Richmond consultation document is available here. This submission intentionally skips a number of questions to focus on what we believe to be the main issues raised by the consultation, but you are entirely free to respond to the consultation in full and answer whichever questions you are drawn to.

2) What is your postcode? (required)

7) Do 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”.

AgreeNeither agree nor disagreeDisagreeDon't know

8) Do 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.

AgreeNeither agree nor disagreeDisagreeDon't know

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

9) Do you agree or disagree with each of the following proposed prohibitions in the buffer zone?

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 extremely vague and would criminalise offers of help.

AgreeNeither agree nor disagreeDisagreeDon't know

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

AgreeNeither agree nor disagreeDisagreeDon't know

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.

AgreeNeither agree nor disagreeDisagreeDon't know

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.

AgreeNeither agree nor disagreeDisagreeDon't know

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

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

AgreeNeither agree nor disagreeDisagreeDon't know

13) Do 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?

YesNoDon't know

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:

14) If you have any final comments regarding this consultation, please use the space below:

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:

I agree to Be Here For Me using this response anonymously as part of their Be Here For Me campaign to prevent censorship outside abortion clinics.

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By submitting this form, I agree to you forwarding the above message, my name, postcode and email address to the London Borough of Richmond upon Thames in response to their public consultation on a Public Spaces Protection Order for the Rosslyn Road area. I understand my data may be retained for monitoring purposes. See our Privacy policy here.