Date of meeting: 18 January 2022

A period of not more than fifteen minutes shall be allowed at each ordinary meeting of the Council for the hearing of deputations from members of the public. Each deputation may be heard for a maximum of five minutes following which one Member of the Council, nominated by the Mayor, may speak in response. It shall then be moved by the Mayor and voted on without discussion that the spokesperson for the deputation be thanked for attending and its subject matter noted.

Notification of one Deputation has been received. The spokesperson is entitled to speak for 5 minutes.

(1) Play area refurbishments

A significant £3 million investment in the infrastructure of 45 play areas addresses urgent need to replace, upgrade and maintain facilities (Open Spaces, 2017). We welcome investment in play areas as an essential resource for early years learning and leisure activity, activities by rights guaranteed to all children and young people (CYPs) (UN Convention on Rights of the Child Articles [UNCRC] 28 & 31). However, the process of consultation regarding these refurbishments is exclusionary, unequal and fails democratic process (Appendix 1). It fails to meet engagement requirements to involve ‘residents, park users and other interested parties’, risking widening health inequalities and poor physical and mental health outcomes for CYPs. We call to uphold Brighton & Hove’s values as a city that welcomes residents’ input and collective caring for its assets; values health and wellbeing of all residents; and is committed to reducing health inequalities. Processes should uphold city codes of practice on consultation (where spending exceeds £500,000) to avoid wastage. We call to uphold Council’s own standards for consultation and assure the integrity of play areas as essential, accessible resources for all children and families.

Refurbishments of this scale, with implications for a whole generation’s physical and mental health, requires effective consultation with a diverse appropriate range of stakeholders of all ages, abilities and locations across the city. This has demonstrable not happened with a ‘patchy-touch’ approach relying on ‘Friends of’ groups in select areas (Appendix 2). Office Reports have not been forthcoming. A special educational needs and disabilities (SEND) working group established by requirement for ETS approval has been unable to significantly affect specifications or design. Requests for information about implementation of ‘inclusive design’ have been denied with only illustrations offered on social media provided. Feedback from residents and councillors of insufficient provision for older children, with fears for antisocial behaviour in absence of leisure alternatives, has not resulted in amendments to designs, resulting in inequalities in provision for older children and impacting the security of all residents. CYPs’ rights to ‘express their views, feelings and wishes in all matters affecting them, and to have their views considered and taken seriously’ have been denied (UNCRC 12). CYPs have not been meaningfully consulted even ‘light touch’, with the only major online consultation formatted inaccessible to CYPs and no engagement with Youth Council. Reliance on ‘Friends of’ parks groups widens inequalities which have been identified as needing diversification (Groundwork UK, 2021). The process excludes established stakeholders that serve CYPs effectively (community fora, parent-carer groups, specialist schools and childcare facilities, Youth Council) where CYPs and carers concentrate their time and resources, contributing to democratic exclusion. Children and families with SEND have been especially failed by the current process.

As well as upholding the city’s own standards, consultation should meet UNICEF (2020) criteria for designing child-friendly spaces particularly those lacking: strategic orientation, collaboration, efficacy review and Participation and identification. We aim for communities to be engaged and funding best spent for areas with lasting play appeal within the challenges of managing maintenance. Communities should feel listened to as ‘expert users of play areas’. We call for 6 corrections (Appendix 3): (1) Pause, Reflection and Change to consultation to address identified failures using range of time allocated to refurbishments. (2) Pause refurbishment programme while above is undertaken. (3) Comprehensive and equitable consultation with an appropriate range of stakeholders and communication of consultation outcomes. (4) Stronger utilisation of existing feedback mechanisms such as SEND groups and use of portal mechanisms (5) Creation of an Advisory Team of key stakeholders including community leaders, health and wellbeing advisors, SEND representatives, the city’s Youth Council and experts by experience (6) development of a strategy to effectively communicate with residents including CYPs with or without SEND, about changes to their essential services.

Supported by:

Lisa Creagh

Neil Man

Dr Rebecca Graber (Lead Spokesperson)

Philippa Hodge

Dr Bruno De Oliveira

Kate Bloc

APPENDIX 1: FAILURES OF DEMOCRATIC PROCESS

Spends of more than £500,000 require consultation, yet an Office Report has not been forthcoming.
Requests from citizens and councillors for details of, and feedback from, those consultations have occurred have revealed a ‘light touch’ approach in a mere handful of play areas disproportionate to spend. The process’s reliance on early ‘pop-up’ consultations fails to mitigate challenges to engagement in early stages of the pandemic.
Reliance on ‘Friends of…’ park groups exemplifies a ‘patchy touch’ approach dependent on prior organisation, neglecting other readily-accessible community stakeholders such as community groups, specialist schools and childcare facilities.
A SEND working group established by requirement for ETS approval has been unable to have feedback significantly affect specifications or design. Requests for design briefs and contractor specifications and draft/final designs for each park throughout phases of the tender process have been denied. Terms of reference for the group have not been agreed and designs set forth as final with meaningful consultation therefore non-existent or negligible.
Requests for information about how ‘inclusive design’ approaches have been implemented have been denied with only those illustrations offered on social media provided.
Requests for alterations to opportunities to feed in have been met with responses of insufficient time, despite the 5-year, phased approach of the refurbishments

APPENDIX 2: IMPLICATIONS FOR INEQUALITIES, HEALTH AND WELLBEING

Communities with ‘social capital’ to organise can use time, resources and power to advocate for improvements to their communities while those without, go without (Putnam, 2000).
‘Friends of’ groups need diversification and to ‘support young people to get their voice heard as park users’ (Groundwork UK, 2021).
Representatives from the SEND community have not been able to effectively feed into designs nor into formulation of future designs, being instead told that designs have been ordered and final. The needs of a vulnerable and diverse range of children, and indeed of adults with SEND who routinely use play areas, have been omitted from democratic consultation process. Reliance on ‘Friends of’ groups exacerbates this exclusion by, for example, failing to consult specialist schools near grounds of play areas.

APPENDIX 3: WHAT IS NEEDED FOR ACCEPTABLE CONSULTATION

Consultation should be demonstrated to be democratic, able to effect significant changes to design, utilise appropriate methodologies to engage CYPs and SEND families (with coproduction of these as necessary), and make use, wherever feasible, of existing organisations supporting CYPs, and should reflect the full time-scale of planned refurbishments. Tools supporting the consultation (such as online surveys) should be fit for purpose for use with hard-to-reach communities and individuals, such as families in low-income neighborhoods, CYPs and SEND families.
To convene an Advisory Team of key stakeholders (including community leaders, health and wellbeing advisors, SEND representatives, the city’s Youth Council and experts by experience) to agree a set of universal principles overarching all scheme designs, using coproduction as necessary and drawing on established guidance in designing child-friendly spaces (UNICEF, 2020). Principles should be available for the public to view. Principles might include: opportunities for interaction, designability, sustainability, inclusivity, accessibility, risky play, sensory diversity, sociability, all-age play, nature.
Designs should incorporate the agreed principles and be available for the public to view in a fair, timely and accessible manner to permit play park users, including CYPs and SEND families, to be able to contribute on specific design proposals for their own community’s play area. Sight of drafts with opportunity to provide some feedback at pre-order stage is a reasonable minimum that has been asked for, yet denied. Social media dissemination of final illustrations as the ‘first look’ is insufficient.
Efficacy reviews of play areas should be undertaken to understand CYP’s engagement with implemented designs especially but not only where there is substantive citizen feedback on disappointment with play areas (e.g., Victoria Park, Hove Park).
Narrative explanation throughout the process of how the agreed concept of ‘inclusive design’ has been applied to designs with proactive implementation of feedback about issues of inclusive design in practice.