Feedback from EIA Report for the EP

The feedback that was received for the Equalities Impact Report in relation to the Enhanced Partnership was very useful. This addendum is addressing the issues and comments that we will take on board as we move forward in implementing the Enhanced Partnership. However, some of the risk and vulnerabilities that were highlighted for groups with protected characteristics are not relevant to the measures in the Enhanced Partnership.

To that end this document serves to highlight potential areas of concern in our ongoing conversations with Bus Operators, in our general operations and as we implement the EP.


Suggested Data Sources for Future Reference


·         Joint Strategic Needs Assessments  

·         Local Insight

·         Bank of England

·         Assert Brighton and Hove

·         Mind Brighton & Hove

·         Possibility People

·         Mind Out

·         Black and Minority Ethnic Communities in Brighton & Hove (


·         Brighton & Hove Council Staff

·         Complaints received about services from people with protected characteristics or on their behalf if they are not able to advocate for themselves.


Questions and issues raised during the EIA Review

Vulnerable people not using buses due to fear of Covid
Central government has not made masks mandatory or issued any further guidance around using public transport and mitigating the risk of Covid. Brighton and Hove Public Transport would then not be able to provide guidance to vulnerable people with regards to their safety with regards to Covid when using the bus.

BAME people not feeling safe in the city after dark
This statement makes it unclear as to whether it is after dark on buses that BAME people don’t feel safe or if it is the streets themselves which would not be in the remit of the EP.

It can be a barrier for people for whom English is not their first language to navigate the bus network system

It was suggested that a printed timetable be made in different languages. This can be considered, but anything within the EP will only be approved by the DfT if in compliance with suggested priorities. We have put in measures to simplify fares and will include simplifying the information that is available but cannot commit to any measures at this point in terms of printing timetables in different languages.


Other issues raised with regards to possible barriers to using the bus network

·         Religion not feeling safe on the bus transport services if there are identifiable visual markers that give an indication of a person’s religion

·         Risk of pregnancy discrimination with regards to someone who is pregnant but who identifies as Trans binary or Gender Neutral

·         Risk of sexual harassment on buses

·         Risks to people who are intersectional i.e. who possess multiple protected characteristics

·         Risk of hate crimes to all groups with protected characteristics which include physical violence, verbal assault and slurs and microaggressions

·         People from all groups who may suffer from mental illness

The EP would not deal directly with the risks mentioned above. The Bus Operators have policies, information and training to identify and assist any person who is a victim of a hate crime.

Hate crime #NoHateHere - Brighton & Hove Buses

They have their own Equality, Diversity and Inclusivity policies in place which includes training and awareness for their drivers. This would also include providing help to vulnerable passengers. As they are a commercial operation we wouldn’t be able to design and implement their policies. However, the Brighton and Hove Public Transport Team have a good working relationship with local Bus Operators. We will take on board all the comments and feedback that has been given to ensure that our conversations ensure that the bus network services are accessible to all members of the public.