Published: 12 June 2023
Consultation
This Draft Equality Impact Assessment (EQIA) Report has been prepared primarily for the purposes of consultation. All comments are welcome and will be accepted in any format, with the consultation period lasting for a period of 14 weeks from 12 June 2023 to midnight on 17 September 2023.
During this consultation period, face-to-face meetings will be offered and held with local community groups, Elected Members of Belfast City Council, Ulster Scots and Irish stakeholder groups and the public. The council will make its Migrant Forum, Disability Advisory Panel, and Sign Language Users’ Forum and Shared City Partnership aware of the consultation and will offer engagement sessions upon request.
Submit all comments to:
Olympia Signage EQIA, Equality and Diversity Unit, Belfast City Council, Belfast City Hall BT1 5GS
Telephone: 028 9027 0511
Freephone: 080 0085 5412
Textphone 028 9027 0405
Email: [email protected]
If there is any information in this report which is not clear, or if you require further information, contact the Equality and Diversity Officer on the above number. All relevant documents can be accessed at: Olympia signage: consultation on Draft Equality Impact Assessment | Your say Belfast (link opens in new window).
Access to information
As part of our commitment to promoting equality of opportunity and good relations, we want to ensure that everyone is able to access the documents we produce. We would therefore be happy to provide any of the information in this document in alternative formats on request. If you have any queries about this document, and its availability in alternative formats (including Braille, disk and audio cassette and in minority languages to meet the needs of those who are not fluent in English) then contact:the Equality and Diversity Unit, Belfast City Council, Belfast City Hall BT1 5GS.
Direct Line: 028 9027 0511
Freephone: 080 0085 5412
Text phone: 028 9027 0405
Email: [email protected]
Deadline for comments: Midnight on 17 September 2023
Contents
- Background
- Section 75
- Purpose of the EQIA
- About the Language Strategy 2018-23
- About Naming and Signage in the City-wide Leisure Centres
- About Naming and Signage in Olympia Leisure Centre
- Definition of the aims of the policy
- Analysis of available data and research
- Legal position
- Central government strategies
- Advice from language agencies
- Policies of other councils in Northern Ireland.
- Language legislation in the UK and Republic of Ireland
- Demand for minority languages.
- Other Council policies and decisions.
- Advice from Equality Commission NI
- Academic research.
- Feedback from pre-consultation on Language Strategy.
- Feedback from consultation on City-wide leisure centre naming and signage.
- Census data by DEA and ward (religion, ethnicity, national identity, language)
- Assessment of impacts
- Consideration of measures to mitigate
- Consultation
- Further steps
1. Background
This Equality Impact Assessment (EQIA) relates to the proposal of Belfast City Council (‘the Council’) to erect bilingual external naming and internal directional signage in Olympia Leisure Centre and follows from an earlier consultation on naming and signage as carried out in four City-wide leisure centres (Andersonstown, Lisnasharragh, Olympia and Templemore) from 5 November 2019 to 10 January 2020.
Following that consultation, the Strategic Policy & Resources Committee initially agreed to erect bilingual signage In Olympia leisure Centre but Elected Members subsequently agreed that a decision relating to signage at Olympia Leisure Centre required further consideration.
As part of that further consideration, in February 2022 the Council agreed to proceed with an EQIA on the proposal to erect bilingual external naming and internal directional signage at Olympia Leisure Centre.
Section 75
This EQIA is being carried out in accordance with Belfast City Council’s (the Council’s) statutory duties under Section 75 and Schedule 9 of the Northern Ireland Act 1998. Section 75 requires the Council, in carrying out its functions in Northern Ireland, to have due regard to the need to promote equality of opportunity:
- between persons of different religious belief, political opinion, racial group, age, marital status or sexual orientation;
- between men and women generally;
- between persons with a disability and persons without; and
- between persons with dependants and persons without.
Without prejudice to these obligations, the Council is also required to have regard to the desirability of promoting good relations between persons of different religious beliefs, political opinion or racial group.
Schedule 9 of the Northern Ireland Act sets out the detailed procedure for the implementation of these duties, including the conduct of screening exercises and EQIAs of policies.
When undertaking an EQIA, the Council closely follows the guidance issued by the Equality Commission for Northern Ireland in 2004. This guidance recommends that there should be seven steps in the EQIA process [Footnote 1]:
- Step 1: Definition of the aims of the policy
- Step 2: Consideration of available data and research
- Step 3: Assessment of impact
- Step 4: Consideration of measures to mitigate
- Step 5: Formal consultation
- Step 6: Decision and publication of the results of the EQIA
- Step 7: Monitoring for adverse impact
This Draft EQIA Consultation Report sets out the findings of the first four steps of the EQIA process. Following the period of consultation, any feedback obtained will be reflected on by the Council and incorporated into a Final EQIA Decision Report
2. Purpose of the EQIA
An EQIA is a thorough and systematic analysis of a policy to determine the extent of differential impact upon the groups within the nine equality categories and whether that impact is adverse. If it is decided that the policy has an adverse impact on groups within one or more of the nine equality categories, the Council must consider measures which may mitigate the adverse impact and alternative ways of delivering policy aims which have a less adverse impact on groups within each of the relevant equality categories.
In order to determine whether the policy is likely to have any adverse impact, it is necessary to consider the people affected by the policy, their needs and experiences and the equality categories to which they belong.
About the Language Strategy 2018-2023
Further to its original Language Policy (2006), in 2018 the Council adopted a Language Strategy 2018 - 2023. In keeping with the Council’s long-term vision for the city, as set out in the Belfast Agenda, the strategy aspires to create a place where linguistic diversity is celebrated and respected, and where those who live, work and visit Belfast can expect to access what Belfast has to offer, using forms of language with which they are familiar and comfortable. The aims of the strategy are to:
- address language and communication challenges and opportunities within the Belfast Agenda outcomes;
- establish a transparent set of principles for promoting, protecting and enhancing the linguistic diversity of the city;
- increase the profile of different languages along with awareness and understanding of associated cultures, heritage and traditions;
- engage with language communities to address language barriers and promote equality of opportunity through the development and integration of different languages into mainstream civic life;
- enhance good relations within the city through the promotion of linguistic diversity and to celebrate the significance of language in the history and culture of the City;
- address staff training and capacity building needs in relation to the role linguistic diversity has in the workplace and in the delivery of services;
- work in partnership to promote linguistic diversity across the City, to move toward our shared vision of inclusive growth, where no one is left behind.
In adopting this strategy, the Council was mindful of various legal positions including Counsel’s opinion and international and domestic legal obligations and standards. It was also informed by demands for minority languages and feedback from wide ranging consultation.
Based on this information, an approach was adopted that included the development of an overarching Language Strategy, which articulated the Council’s commitment to supporting minority languages while allowing the different needs of speakers of Irish, Ulster-Scots and other minority languages to be addressed appropriately and effectively.
The Language Strategy was subject to a formal consultation period which ran from 23 May 2017 to 18 July 2017. A Section 75 screening process accompanied the consultation and the Strategy was duly ‘screened out’ that is no need for a further EQIA).
Consultation is currently underway for the Council’s Language Strategy Review – Draft Action Plan 2022 – 2025.
About External Naming and Internal Directional Signage in the Council’s City-wide Leisure Centres (Andersonstown, Lisnasharragh, Templemore and Olympia)
Under this strategy, between November 2019 and January 2020, public consultation was undertaken to consider external naming and internal directional signage in four of the Council’s City-wide leisure centres, namely Andersonstown, Lisnasharragh, Templemore and Olympia.
Strategic Planning and Resources (SP&R) Committee, at its meeting on 24 January, 2020, granted approval to erect bilingual external naming and internal directional signage in Andersonstown Leisure Centre.
At a subsequent meeting of the Committee on 24 September 2021, and further to due consideration of the findings contained within the consultation report, the Committee agreed:
- to erect bilingual external naming and internal directional signage at Olympia Leisure Centre, with a report on the detail and appearance of that signage to be submitted to a future meeting;
- that a report on linguistic accessibility at Lisnasharragh and Templemore Leisure Centres be submitted to a future meeting;
- that a multi-lingual welcome sign be erected in the entrance and reception area of all leisure centres.
About External Naming and Internal Directional Signage in Olympia Leisure Centre
While the consultation on signage and naming in the four centres had been able to provide a clear steer to the Council with regard to three of the leisure centres (Andersonstown, Lisnasharragh and Templemore), the consultation in relation to Olympia was less conclusive. In the words of the Consultation Report (pp. 41-42):
‘The case of Olympia Leisure Centre is potentially more problematic, and the consultation may be less well placed to help inform this decision. While the two communities expressed diametrically opposed views as to whether English Only or English and Irish signage and naming were appropriate in this and other centres, there was little by way of direct feedback from the community local to Olympia during the consultation, other than that the needs of new communities should be given due consideration in terms of accessibility in particular.’
‘It was noted by one respondent that the local area is now culturally very diverse, and that users of the centre come from a variety of new communities, as well as from across the city. It was suggested that bilingual signage may be additionally confusing to those whose first language is not English. Furthermore, the centre has been open for over two years and the existing signage is now well established, and the costs of replacement and rebranding are likely to be considerable. In addition, from a practical point of view, it is not clear if there is an Irish translation of Olympia, and therefore how Irish would be accommodated in the external naming.’
Subsequent to the closure of the public consultation, further submissions from local groups and individuals were received, including a petition signed by 571 local residents for the adoption of monolingual signage. An addendum to the original Consultation Report concluded:
‘While the meeting, and associated representations, do fall outside the agreed period of consultation, it would be difficult to set aside these submissions and perhaps in particular given the time constraints within which the consultation was originally carried out.’
The sentiments expressed by those present indicated strong local support for English only signage, along with concern that good community relations could potentially be damaged if bilingual signage was to be installed. In the words of the consultation report:
‘Such a decision may also require the Council to review its Section 75 screening outcome, as the potential for major adverse impact on good relations, and possibly also equality of opportunity, cannot be ignored.’
‘The Council’s Language Strategy makes explicit a commitment to adopt the use of Irish and Ulster-Scots in signs, and in particular where, ‘it will be seen primarily by users of Irish and Ulster Scots.’ While this commitment is not specific on this point, it could be inferred that the imposition of bilingual signage, contrary to significant, expressed views of local residents, does not fall within the current scope of the strategy.’
Further to a presentation and consideration of the consultation report on naming and signage in the four centres, at a meeting of SP&R Committee on 24 September 2021, it was decided, ‘to erect bilingual external naming and internal directional signage at Olympia Leisure Centre, with a report on the detail and appearance of that signage to be submitted to a future meeting.’
This decision was subsequently ‘called in’ by the required number of elected members on both procedural and community impact grounds. Under Section 41 of the Local Government Act (NI) 2014 the Council is required to reconsider a Committee decision if 15 per cent (nine Members) present a requisition on either:
- That the decision was not arrived at after a proper consideration of the relevant facts and issues (Procedural Grounds); or
- That the decision would disproportionately affect adversely any section of the inhabitants of the district (Community Impact).
Subsequent legal opinion found that only the Community Impact element had merit. It also recommended that the Council should, in any reconsideration of the decision, bear in mind its duties under Section 75 of the Northern Ireland Act 1998 and its Equality Scheme.
The decision of 24 September 2021 was then included on the agenda for the next available meeting of the Council on 10 January 2022 at which time it was referred back to SP&R Committee for further consideration.
At the meeting of SP&R Committee on 21 January 2022 it was agreed to proceed with an EQIA on the erection of bilingual external naming and internal directional signage at Olympia Leisure Centre, a decision that was ratified by full Council on 1 February 2022 and confirmed by the Interim City Solicitor at a further meeting of SP&R Committee on 24 March 2023, and it is this decision that forms the basis of the current EQIA.
3. Definition of the aims of the proposal
The proposal falls under the Council’s Language Strategy, which was first adopted in 2018 and has since been reviewed on a regular basis. Prior to this date, the Council’s existing policy on Linguistic Diversity had been subject to a public consultation in 2017 and further to this consultation the Council had agreed to rebrand the policy as a Language Strategy.
This Strategy has at its core the need to embrace diversity in the Council’s ambition for Belfast to be a welcoming and inclusive city for all. The opening of the Council’s new City-wide leisure centres was seen as providing a unique opportunity to live the principles of diversity as contained in the Language Strategy.
Based on principles of equality and linguistic diversity, the Council had agreed at that time the following:
- to engage in a city-wide consultation in respect of bilingual and multilingual naming and the type of signage to be used in the centres designed to have a city-wide catchment, as guided by local consultation. The process referred to will commence after agreement of a framework for the consultation, which will be brought to the Strategic Policy and Resources Committee on 25 October 2019, with that Committee having delegated authority to approve the framework referred to. Agreement on the framework to be reached at that meeting;
- to apply the Council policy on bilingual naming of local facilities in respect of Brook Leisure Centre and to agree to the principle of the installation of bilingual signage, subject to review at the close of the consultation period;
- notwithstanding that the city-wide consultation process would not have closed, to grant delegated authority to the Strategic Policy and Resources Committee permitting it to authorise the bilingual and such other signage to be procured and installed for the opening of Andersonstown Leisure Centre (the Strategic Policy and Resources Committee to meet no later than week commencing 26 January, 2020). In taking this decision, it was agreed that the Committee would consider the consultation response received up to the date of that meeting;
- to draw on consultation responses in reviewing and informing decisions in respect of bilingual and multilingual naming and signage in each City-wide centre, taking onto account the language needs of all citizens.
In developing the Language Strategy, the Council was mindful of various legal positions including Counsel’s opinion and international and domestic legal obligations and standards. The Strategy contains an overarching Language Framework which allows for the development of three separate policies on:
- Irish Language
- Ulster-Scots Language
- Other Languages (including sign languages)
Following a Special Council meeting on Friday 11 October 2019, the Council agreed to the installation of multilingual welcome signs in all its leisure centres with immediate effect and also to carry out a public consultation regarding bilingual or multilingual signage in four leisure centres.
The Council then consulted on the proposals as drawn up in line with its Language Strategy regarding external naming and internal directional signage at the four City-wide leisure centres which were being delivered as part of the Council’s £105m Leisure Transformation Programme (Andersonstown, Lisnasharragh, Olympia and Templemore).
It was also proposed at that time that internal directional signage should include pictorial signage to enhance accessibility, for example, to members of new communities and people with a disability. The Council proceeded mindful of the location and history of each centre, along with the needs of members of new communities and disabled people.
Working within the context of these linguistic frameworks, the proposal’s aim is:
- In line with the aims of the Language Strategy 2018 – 23, to commit to supporting minority languages while allowing the different needs of speakers of Irish, Ulster-Scots and other minority language, including sign language, to be addressed effectively. In particular, to roll out the Council’s Language Strategy by providing appropriate external naming and internal directional signage in Olympia Leisure Centre.
4. Analysis of available data and research
(i) Legal position
(a) Counsel’s opinion
In relation to the Language Strategy itself, in January 2013 the Council sought the opinion of Mr Richard Gordon QC, widely recognised as a leading counsel on constitutional, administrative, public and civil liberties law. Mr Gordon was asked to advise:
- whether the Council is in any legal conflict with the provisions of the European Charter and whether the current policies in relation to the use of Irish meet with the spirit and requirements of the Charter;
- whether the current language policies are open to legitimate criticism.
Mr Gordon advised that there would be potential for judicial review in relation to allegations of the Council’s non-compliance with the European Charter and recommended that the Council should – as a minimum – have in place a clear strategy which can be shown to be implemented for facilitation of the Irish language so as to meet all the requirements of Article 10 of the European Charter. He suggested that the Council should reformulate the Language Policy in a comprehensive and easily accessible form and should attempt to itemise in the clearest terms what is being done to implement the policy.
(b) High Court ruling
In December 2014, the High Court ruled on an application for judicial review by Eileen Reid of a decision taken by Belfast City Council to refuse to erect an additional street name plate in Irish at Ballymurphy Drive, Belfast. The application was made on five grounds, one of which was that the Council’s street naming policy was inconsistent with its commitment to act in accordance with the European Charter. The ruling stated that, as a general proposition, international treaties or agreements which have not been incorporated into national law are not enforceable and went on to say:
‘a public authority … cannot be obliged to treat itself as bound to act in compliance with international obligation. Even where it does so it is clear from the authorities that the courts will adopt a very light touch review which will not extend to ruling on the meaning or effect of the International Treaty.’
(c) International and domestic legal obligations, charters and standards
European Charter for Regional or Minority Languages
The European Charter for Regional or Minority Languages is an international convention designed to protect and promote regional and minority languages.
The UK has an obligation not to create barriers regarding the use of a minority language. Article 7(4) of the Charter provides that, ‘In determining their policy with regard to regional or minority languages, the Parties shall take into consideration the needs and wishes expressed by the groups which use such languages’.
In Northern Ireland, Part II of the European Charter applies to Irish and Ulster-Scots and Part III to Irish only.
Part II places a general duty on the state to facilitate and encourage the use of regional or minority languages in speech and writing, in public and private life but does not place any obligations directly on district councils.
Part III of the Charter extends to public services under public control. In Article 10, it states that services need to be able to be provided in the specified language and users of the language need to be able to submit requests for services in this language. Article 10 makes it clear that public authorities should have a capacity for translation and interpretation, allow or encourage the use of traditional forms of placenames and family names, draft documents in the specified language, facilitate oral and written applications in this language, facilitate the use of the language in debates and allow people to submit requests in the language.
The UK ratified the European Charter in March 2001, but it has not been incorporated into domestic law. At present there is no Language Act in place in Northern Ireland (unlike the position in Scotland and Wales) although policies have been formulated by central government
UN Special Rapporteur on minority issues
Guidance from the UN Special Rapporteur on minority issues issued in 2017 [Footnote 2] was also taken into consideration by the Council when revising this policy. The guidance notes that, ‘Bilingual or multilingual signs used by public authorities demonstrate inclusiveness, and that various population groups share a locality in harmony and mutual respect’.
Framework Convention for the Protection of National Minorities
The Framework Convention for the Protection of National Minorities is a multilateral treaty of the Council of Europe aimed at protecting the rights of minorities within Europe. The United Kingdom is a signatory nation to the Framework.
It does not place any directly enforceable obligation on local councils but includes a number of provisions in relation to minority languages.
Article 11 requires the state to facilitate the display of traditional local names, street names and other topographical indications in the minority language where there is a sufficient demand and in areas traditionally inhabited by substantial numbers of persons belonging to a national minority.
The Fifth Report on the United Kingdom by the Advisory Committee on the Framework Convention for the Protection of National Minorities (May 2023) addressed the issue of bilingual signage in Northern Ireland. This report placed an emphasis on the need for bilingual signage as a marker of shared territory.
New Decade, New Approach 2020
The NI Executive’s New Decade, New Approach strategy sets out a number of proposals in relation to rights, language and identity. These include:
- establishing an Office of Identity and Cultural Expression ‘to celebrate and support all aspects of Northern Ireland's rich cultural and linguistic heritage’;
- appointing a Commissioner ‘to recognise, support, protect and enhance the development of the Irish language in Northern Ireland’;
- appointing a Commissioner ‘to enhance and develop the language, arts and literature associated with the Ulster Scots and Ulster British tradition’;
- officially recognising both Irish and Ulster-Scots languages in Northern Ireland;
- allowing any person to conduct their business in Irish or Ulster-Scots before the Assembly or any of its committees
While the document sets out proposals that are broadly in line with previous advice and guidance, at this time it does not provide specific guidance for local government other than:
‘The guidance will ask the Commissioner, as a first priority, to focus on developing best practice standards that facilitate interaction between Irish language users and public bodies, including but not limited to making information or forms available in Irish where required, enabling widely used public websites to have an Irish Language translation available, and ensuring that public bodies reply in Irish where practical to correspondence in Irish. Public bodies will each continue to make their own decisions on other matters to do with the Irish language.’
Northern Ireland (St Andrews Agreement) Act 2006
This Act places a duty on the NI Executive to adopt a strategy for the enhancement and protection of the Irish language.
Belfast (Good Friday) Agreement 1998
Strand Three of the Belfast Agreement contains a series of commitments in respect of economic, cultural and social issues, including a general provision relating to minority languages:
‘All participants recognise the importance of respect, understanding and tolerance in relation to linguistic diversity, including in Northern Ireland, the Irish language, Ulster-Scots and the languages of the various ethnic communities, all of which are part of the cultural wealth of the island of Ireland.’
(d) Judicial Review Application Conradh Na Gaeilge March 2017
The High Court found that the Executive Committee of the NI Assembly had failed to comply with obligations flowing from the NI Act 1998 requiring it to adopt a strategy in respect of the Irish language and that consideration was not sufficient to discharge the duty arising under the Act.
(e) Fair Employment and Treatment (NI) Order 1998
The Equality Commission’s remit in this area stems from their duties under the Fair Employment and Treatment (NI) Order 1998 (‘FETO’) ‘to promote equality of opportunity, affirmative action and to work for the elimination of religious and political discrimination’. The Commission’s advice includes the following:
‘[FETO] makes discrimination on the grounds of religious belief and political opinion unlawful, both in the workplace and in the provision of goods, facilities and services. Also, in the workplace, it bans ‘harassment’ on these grounds. In addition to the issue of discrimination and harassment, employers also have legal obligations which require them to promote fair participation in employment and associated responsibilities to promote a good and harmonious workplace.’
‘In the field of employment, the Fair Employment Code of Practice provides general guidance for employers on these matters. The Code has been cited with approval by the Fair Employment Tribunal when upholding complaints against employers in numerous discrimination cases. A small number of these concerned the display of flags and emblems.’
‘The relatively new statutory definition of harassment under FETO (first enacted in 2003), has not yet been explicitly considered by the Tribunal in any case dealing specifically with ‘flags and emblems’ issues, and including signage. However, the case law that preceded 2003 can, with a reasonable degree of confidence, be used to predict how the Tribunal would approach these questions if raised today.’
‘In relation to fair employment obligations on the provision of goods, facilities and services, it is also not clear to what extent FETO impinges on the issue, as there has not been any case law to date in respect of these provisions in relation to the display of flags and emblems, including signage. Furthermore the coverage of the statutory provisions differs from those which apply to employment-related matters.’
ECNI Guidance on Promoting a Good and Harmonious Working Environment
In October 2009, the Equality Commission issued guidance on promoting a good and harmonious working environment. This guidance states that:
‘A good and harmonious working environment is one where all workers are treated with dignity and respect and where no worker is subjected to harassment by conduct that is related to religious belief or political opinion….This of course does not mean that working environments must always be devoid of anything that happens to be more closely associated with one or other of the two main communities in Northern Ireland….In other words an ‘harmonious’ working environment does not necessarily mean a ‘neutral’ one.’
The guidance includes the following advice on the issue of workplace displays or emblems, which could extend to signage:
‘The Commission recommends that where an employer is seeking to provide or maintain fair participation, or to ensure that all services and facilities are widely utilised by all sections of the community, there is sensitivity concerning displays wholly or mainly associated with one section of the community.’
(ii) Central government strategies
Structural changes within central government have resulted in this work being taken forward by the Department for Communities (DfC).
(a) Irish Language Strategy
In January 2015, the Department of Culture, Arts and Leisure (DCAL) published a Strategy to Enhance and Protect the Development of the Irish Language over the period 2015-2035 (Straitéis le Forbairt na Gaeilge a Fheabhsú agus a Chosaint).
The key aims of the Strategy are to:
- support quality and sustainable acquisition and learning of the Irish language;
- enhance and protect the status and visibility of the Irish language;
- deliver quality and sustainable Irish language networks and communities; and
- promote the Irish language in a way that will contribute towards building a strong and shared community.
In relation to the delivery of public services, the Strategy envisages that public authorities will facilitate the use of Irish both orally and in writing and will produce and adhere to a Code of Courtesy that meets the needs of those who wish to conduct their business through Irish. The Strategy notes that language awareness and language training programmes need to be provided so that a higher proportion of public service staff can effectively deliver services in Irish to customers who seek them.
Local councils will be expected to:
- adopt Irish language policies and plans and appoint Irish language officers;
- initiate or expand facilities for the use of Irish in their council and committee meetings;
- increase the visibility of the Irish language by publicising the availability of their Irish language services;
- provide an Irish or bilingual version of publications, official documents and forms in line with the approach of the Strategy and the European Charter for Regional or Minority Languages;
- facilitate the proper preservation and signposting of Irish place-names and the naming of new housing developments; and
- encourage tourism and cultural initiatives through Irish.
Under New Decade New Approach there was a further commitment to an Irish Language Strategy to be taken forward by DfC. This led to the publication in 2022 of an Expert Advisory Panel Recommendation Report which placed an emphasis on the need for Irish and English bilingual signage to be available throughout public buildings in Northern Ireland.
(b) Consultation on proposed Irish Language legislation
In accordance with the Strategy, DfC continues to work towards introducing legislation to secure legislative protection of the Irish language and issued a consultation document in February 2015 setting out the provisions that might appear in an Irish Language Act. Some of the key proposals are summarised below:
- Irish will be defined as an Official Language in Northern Ireland in such a way as to guarantee services through Irish on a par with those available through English;
- There will be provision to create the position of an Irish Language Commissioner whose functions would include approving language schemes and providing advice to the public and public bodies;
- the Irish Language Commissioner would have the power to instruct public bodies to draft language schemes;
- public bodies, including district councils, will have a statutory duty:
- to ensure that correspondence sent to them in Irish is replied to in Irish without undue delay;
- to ensure that when information is provided to the public, the communication is in Irish and English;
- to publish simultaneously in Irish and English documents setting out public policy proposals, annual reports, audited accounts or financial statements etc.;
- to agree language schemes with the Irish Language Commissioner and to implement the commitments of such statutory schemes; and
- to undertake public consultation exercises to assist in the preparation of language schemes.
Further to this work, in February 2022 DfC produced an Expert Advisory Panel Recommendation Report that sets out in some detail the goals, aims, objectives, action areas and recommendations attaching to the Irish Language Strategy [Footnote 3]. This includes recommendations specifically in relation to the provision of public services, both centrally and through local government.
(c) Ulster-Scots Strategy
In January 2015 DCAL also published a Strategy to Enhance and Develop the Ulster-Scots Language, Heritage and Culture over the period 2015-2035 (Roadin furtae Brïng Forrits an Graith tha Ulstèr-Scotch Leid, Heirskip an Cultùr).
The Strategy has four key aims:
- promote and safeguard the status of, and respect for, the Ulster-Scots language, heritage and culture;
- build up the sustainability, capacity and infrastructure of the Ulster-Scots community; and
- foster an inclusive, wider understanding of the Ulster-Scots language, heritage and culture in a way that will contribute towards building a strong and shared community.
In relation to public services, the Strategy indicates that Departments, councils and public bodies need to:
- facilitate and encourage the use of Ulster-Scots in public life;
- increase awareness and visibility of the Ulster-Scots services they provide;
- encourage the promotion of Ulster-Scots cultural and heritage tourism initiatives;
- ensure that respect for Ulster-Scots within the context of cultural diversity is an element of their commitment to good relations;
- facilitate the proper preservation and signposting of Ulster-Scots place names.
The Strategy also says that awareness training for relevant staff needs to be a good practice requirement.
(iii) Advice from language agencies
(a) Guidance from Foras na Gaeilge
In March 2015 Foras na Gaeilge (the statutory body charged with the promotion of the Irish language) published a Guidance Document: Irish Language Services in the New Councils. Foras na Gaeilge has been assisting councils to develop their service provision in Irish since 2006, principally through the Irish Language Officers’ Scheme.
Under this Scheme, joint funding for a three-year period is provided towards the salary of an Irish Language Officer, provided that a Council Action Plan is prepared in collaboration with Foras na Gaeilge. The most recent scheme ran from 2013-2016. Foras na Gaeilge has advised that a review of the Scheme has been initiated to take account of the changed environment following local government reorganisation.
Foras na Gaeilge recommends that each council should include the Irish language in their Community Plans, adopt a strong Irish Language Policy and adopt a strategy for the development of Irish both within the council and in the community. They suggest that development of a strategic approach should be based on:
- consultation with local Irish speaking communities to gather information on which Irish language services would be beneficial to them and which they would be most likely to use; and
- an audit of the Irish language skills of existing staff.
The Guidance Document sets out examples of good practice in terms of support for minority languages and offers practical advice on ways to support and promote the Irish language including the provision of signage; these are set out as a ‘menu’ ranging from the simplest actions to a more comprehensive approach.
(b) Guidance from the Ulster-Scots Agency
The Ulster-Scots Agency has highlighted that it is essential that, when public authorities are undertaking actions to promote Ulster-Scots, they reflect the situation of the language, in accordance with the European Charter. The Ulster- Scots Agency has adopted the Fishman Model for reversing language shift, which sets out an eight-stage process for language development. The Model states that efforts should be concentrated on the earlier stages of restoration until they have been consolidated before proceeding to the later stages. The stages are:
- acquisition of the language by adults, who in effect act as language apprentices (recommended where most of the remaining speakers of the language are elderly and socially isolated from other speakers of the language);
- create a socially integrated population of active speakers (or users) of the language (at this stage it is usually best to concentrate mainly on the spoken language rather than the written language);
- in localities where there are a reasonable number of people habitually using the language, encourage the informal use of the language among people of all age groups and within families and bolster its daily use through the establishment of local neighbourhood institutions in which the language is encouraged, protected and (in certain contexts at least) used exclusively;
- in areas where oral competence in the language has been achieved in all age groups encourage literacy in the language but in a way that does not depend upon assistance from (or goodwill of) the state education system;
- where the state permits it, and where numbers warrant, encourage the use of the language in compulsory state education;
- where the above stages have been achieved and consolidated, encourage the use of the language in the workplace (lower worksphere);
- where the above stages have been achieved and consolidated encourage the use of the language in local government services and mass media;
- where the above stages have been achieved and consolidated encourage use of the language in higher education, government, etc.
(iv) Policies of other councils in Northern Ireland
Before local government reform, the majority of the 26 legacy councils in NI had policies relating to either the Irish language or linguistic diversity generally. However, at this time only four of the ten NI councils (excluding Belfast) have formally adopted policies addressing these issues.
Fermanagh and Omagh District Council
Fermanagh and Omagh District Council has adopted an overarching Linguistic Diversity Policy which embraces all language forms but affords particular status to Irish in accord with Part III of the European Charter. To date, the Linguistic Diversity Policy is reflected in its branding strategy: English and Irish are included on council stationery, vehicles and external signage with the exception of Strule Arts Centre and Enniskillen’s Ardhowen Theatre, where Ulster Scots is also included.
Derry City and Strabane District Council
Derry City and Strabane District Council adopted a policy for the Irish language and a separate policy for Ulster-Scots in September 2014. It should be noted that Derry and Strabane District Council have trilingual English, Irish and Ulster Scots signage throughout their buildings.
Newry, Mourne and Down District Council
Newry, Mourne and Down District Council agreed its Bilingual Language Policy in 2015, establishing the Council's commitment to facilitate and encourage the promotion and use of both the Irish language and English language in the Council area. While procedures have been agreed, the Council has not as yet finalised an action plan to implement the commitments. Newry, Mourne and Down District Council have bilingual Irish and English signage throughout their buildings.
Mid Ulster District Council
The Mid Ulster District Council Irish Language Policy is based on the requirements of Parts II and III of the European Charter for Regional or Minority Languages, thereby implementing a range of positive actions to promote, enhance and protect the Irish language while encouraging its use in speech and writing in private and public life. Mid Ulster District Council buildings have bilingual Irish and English signage.
(v) Language Legislation in the UK and Republic of Ireland
(a) Wales
The Welsh Language Act 1993 established the principle that, in the conduct of public business and the administration of justice in Wales, the Welsh and English Languages should be treated on the basis of equality. Public bodies, including local councils, are required to prepare a Welsh Language Scheme to outline the Welsh language services they will provide and state how and when those Welsh services will be available.
The Welsh Language (Wales) Measure 2011 replaced many of the provisions of the Act and established official status for the Welsh language in Wales. The Measure created a new legislative framework to impose a duty on public authorities to comply with standards relating to the Welsh language, with these standards replacing existing Welsh Language Schemes over time. The purpose of introducing standards was to provide greater clarity to public authorities regarding their duties and to Welsh speakers about the services they could expect to receive in Welsh. Standards will also ensure greater consistency of Welsh language services and improve their quality. The Measure also required public authorities to use the Welsh language in a reasonable and proportionate manner.
Local councils in Wales have had Welsh Language Schemes in place for a number of years. Typically, these cover three specific areas:
- dealing with the Welsh speaking public (including correspondence, meetings and by telephone);
- the Council’s public image (including corporate identity, signs, publications, forms, advertising, news releases, exhibitions, surveys, public notices and recruitment advertisements);
- staffing issues (including recruitment, language training and vocational training).
(b) Scotland
The Gaelic Language (Scotland) Act 2005 established the status of the Gaelic language as an official language of Scotland, commanding equal respect with the English language. It also established Bòrd na Gàidhlig as a public body with responsibility for preparing a National Plan for Gaelic every five years. The Bòrd has powers to require public authorities, including local councils, to draft and implement a Gaelic Language Plan. Each individual plan must take into account the National Plan and the extent to which Gaelic is used within, and in relation to, the work and services of the public authority.
The Bòrd has identified four core areas of service delivery that it wishes public authorities to address when preparing Gaelic Language Plans. These are:
- Identity (including corporate identity and signage);
- Communication (including reception, telephone, mail and e mail, forms, public meetings and complaints procedures);
- Publications (including public relations and media, printed material, websites and exhibitions);
- Staffing (including training, language learning, recruitment and advertising).
(c) Republic of Ireland
The Irish Constitution establishes that the Irish language is to be regarded as the first official language, while the Official Languages Act 2003 provided the public with the right to conduct business with the state solely through Irish. The Act requires the preparation by public authorities of Irish Language Schemes, specifying which services will be provided exclusively in Irish, exclusively in English and through the medium of both languages. Each scheme must set out the measures that the public authority will adopt to ensure that any services that are not currently provided in Irish will be so provided over a period of time. In developing its scheme, the public authority may take into account the underlying level of demand for specific services in the Irish language and the resources and capacity to develop or access the necessary language capability.
(vi) Demand for minority languages
(a) Census
The 2021 Census included information on the main languages spoken by residents of Belfast and knowledge of Irish and Ulster-Scots, and the School Census 2014-15 provides information on the number of schools in the Belfast City Council area providing teaching through the medium of Irish. The figures (which relate to the Council’s extended boundary) show that:
- 15.5 per cent of the Belfast population (aged 3+) have some ability in Irish, compared with 12.5 per cent of the population of Northern Ireland as a whole;
- over 18,000 people in Belfast speak, read, write and understand Irish; just under 3,000 pupils receive education through the medium of Irish in the Council area;
- 7.3 per cent of the Belfast population (aged 3+) have some ability in Ulster-Scots, compared with 10.4 per cent of the population of Northern Ireland as a whole;
- 2,753 people in Belfast speak Ulster-Scots on a daily basis;
- 5. 7 per cent of people in Belfast are deaf or have partial hearing loss;
- 2.6 per cent of Belfast households contain at least one person who does not have English as a main language and in 3.9 per cent of Belfast households, no-one has English as a main language;
- the most commonly spoken languages in Belfast (excluding English and Irish) are Polish, Arabic and Chinese (NISRA have indicated that all Chinese languages are grouped together for the purposes of the 2021 Census).
Table 1 below provides information on the number of pupils receiving education through the medium of Irish. The data is drawn from the School Census 2014-15.
Table 1: Schools and pupils taught in the medium of language
|
Number of establishments |
No. of pupils 2014-15 |
---|---|---|
Naíscoileanna (Nursery and Pre-School Units) |
13 |
442 |
Gaelscoileanna (Primary Schools Units) |
9 |
1,194 |
Gaeloideachas Dara Leibhéil (Secondary Stream) |
1 |
580 |
Youth club provision |
7 |
760 |
Total |
30 |
2,976 |
In addition, there are also currently 16 secondary schools teaching Irish within the Council area.
(b) 2013-14 Continuous Household Survey (Northern Ireland data)
Data relevant to the Irish Language
Knowledge of Irish
In the 2013-14 Continuous Household Survey, 14.9 per cent of the population had some knowledge of Irish (that is, can understand, speak, read or write Irish). This was an increase on the 13.1 per cent of the population who had some knowledge or Irish in 2011-12.
Understand Irish
More than one in ten (12.2 per cent) of the population could understand Irish. One out of every hundred (0.6 per cent) people in Northern Ireland could understand complicated spoken sentences, so could understand programmes in Irish on the radio or television. A further two out of hundred (2.4 per cent) people could undertake a conversation in Irish conducted at a simple level so, for example, could understand directions given in the street. An additional three out of hundred (3.2 per cent) of the population could understand simple spoken sentences or passages, e.g. ‘It’s half past three’, while a further 6.0 per cent could understand single spoken words or simple phrases, e.g. ‘Hello’ or ‘How are you?’.
Speak Irish
One in ten (9.8 per cent) of the population could speak Irish. Two out of a hundred people (1.7 per cent) could carry on a complicated conversation in Irish, e.g. talking about any subject, or carry on an everyday conversation, e.g. could describe their day. Four out of hundred (3.6 per cent) could use simple sentences in Irish, e.g. ‘Can I have a cup of tea?’, while a further 4.2 per cent could use single words or simple phrases, e.g. ‘Hello’ or ‘How are you?’.
Read Irish
More than one out of twenty adults (7.3 per cent) could read Irish. One out of a hundred people (0.5 per cent) could read and understand complicated passages, so could read a book or newspaper written in Irish. A further two out of a hundred (1.6 per cent) could read and understand difficult sentences and less complicated passages, so could read a letter or email written in Irish. An additional three out of every hundred (3.1 per cent) of the population could read and understand simple sentences or passages, so could read a postcard written in Irish. A further 2.2 per cent could read and understand single words or simple phrases, e.g. ‘Entrance’ or ‘No smoking’.
Write Irish
One in twenty adults (5.4 per cent) could write Irish. One out of a hundred people (0.3 per cent) could write complicated passages, e.g. could translate part of a book or report into Irish, or write difficult sentences and moderately difficult passages, e.g. could write a letter or email in Irish. An additional two out of a hundred (2.1 per cent) of the population could write simple sentences or passages, so could write a postcard in Irish, while a further 1.9 per cent could write single words or phrases, e.g. ‘Hello’ or ‘How are you?’.
Use of Irish
Four out of a hundred people (3.5 per cent) use Irish at home, conversing with family or housemates, either on a daily basis or occasionally. A similar proportion (4.1 per cent) use Irish socially, either on a daily basis or occasionally, conversing with friends or acquaintances.
Knowledge of Ulster-Scots
In 2013-14, 16.4 per cent of the population had some knowledge of Ulster-Scots, that is, can understand, speak, read or write Ulster-Scots. This is similar to the 15.1 per cent of the population who had some knowledge of Ulster-Scots in 2011-12.
Understand Ulster-Scots
More than one in seven (14.6 per cent) of the population could understand Ulster-Scots. Two out of a hundred (1.6 per cent) people in Northern Ireland could understand complicated spoken sentences, so could understand programmes in Ulster-Scots on the radio or television. A further four out of every hundred (4.5 per cent) people could understand a conversation in Ulster-Scots conducted at a simple level so, for example, could understand directions given in the street. An additional five out of every hundred (4.8 per cent) of the population could understand simple spoken sentences or passages, e.g. ‘It’s half past three’, while a further 3.8 per cent could understand single spoken words or simple phrases, e.g. ‘Hello’ or ‘How are you?’.
Speak Ulster-Scots
More than one in twenty (5.6 per cent) of the population could speak Ulster-Scots. One out of a hundred people (0.6 per cent) could carry on a complicated conversation in Ulster-Scots, e.g. talking about any subject, while 1.5 per cent could carry on an everyday conversation, e.g. could describe their day. Two out of a hundred (1.9 per cent) could use simple sentences in Ulster-Scots, e.g. ‘Could I have a cup of tea?’, while a further 1.6 per cent could use single words or simple phrases, e.g. ‘Hello’ or ‘How are you?’.
Read Ulster-Scots
Just under one out of twenty adults (4.3 per cent) could read Ulster-Scots. One out of a hundred people (0.8 per cent) could read and understand complicated passages, so could read a book or newspaper written in Ulster-Scots. A further one out of a hundred (1.2per cent) could read and understand difficult sentences and less complicated passages, so could read a letter or email written in Ulster-Scots. An additional one out of every hundred (1.5 per cent) of the population could read and understand simple sentences or passages, so could read a postcard written in
Ulster-Scots. A further 0.9 per cent could read and understand single words or simple phrases, e.g. ‘Entrance’ or ‘No smoking’.
Write Ulster-Scots
One in every hundred adults (1.4 per cent) could write Ulster-Scots.
Use of Ulster-Scots
Six out of every hundred people (6.0 per cent) use Ulster-Scots at home, conversing with family or housemates, either on a daily basis or occasionally. A similar proportion (6.5 per cent) use Ulster-Scots socially, either on a daily basis or occasionally, conversing with friends or acquaintances.
(vii) Other Council policies and decisions
The Council’s Language Strategy was formally adopted in April 2018. However, the Council also has in place other policies and has made a number of ad hoc decisions which have a bearing on the proposal in relation to signage. The following paragraphs summarise the decisions made.
Street naming power
The Council has a statutory discretionary power under Article 11 of the Local Government (Miscellaneous Provisions) (NI) Order 1995 to erect nameplates expressing street names in English and any other language. When exercising this power, the Council must have regard to any views on the matter expressed by the occupiers of premises in that street. The Council adopted a revised Dual Language Street Signs Policy in October 2022. This provides that an application for a dual language sign may be made by an occupier(s) of the street, an elected Member for the District Electoral Area or a developer. The Council will carry out a survey of the street and if 15 per cent of the occupiers of the street are in favour of the sign, a report will be brought to the relevant committee to consider the application.
As outlined above under ‘High Court Ruling’ under in December 2014, the High Court ruled on an application for judicial review by Eileen Reid of a decision taken by Belfast City Council to refuse to erect an additional street name plate in Irish at Ballymurphy Drive, Belfast. The Court ruled that the Council’s policy and process were not unlawful and the application failed.
As stated above, a revised policy has now been adopted by Belfast City Council in relation to the erection of dual language street signage.
Signage
- On 7 December 1999 the Parks & Amenities Sub-Committee agreed that a welcome sign in English and Irish should be installed at the entrance of Falls Park.
- On 18 May 2012 the Strategic Policy & Resources Committee agreed that hoardings and signs relating to the delivery of the Investment Programme projects in the Gaeltacht Quarter should be bi-lingual (English and Irish).
- On 7 September 2012 the Strategic Policy & Resources Committee agreed that the Nollaig Shona sign (donated by An Cultúrlann) be erected again at the East entrance to the City Hall.
- On 18 August 2017, the Strategic Policy & Resources Committee agreed that in addition to the Nollaig Shona sign on one end column of City Hall, a ‘Blythe Yuletide’ sign would be erected at the other end column City Hall for the Christmas period.
- It should be noted that the Council agreed a draft policy on dual language (English and Irish) signage in 2006 but decided that signage should be in English only, with the exception of multi-lingual welcome signs where there is appropriate demand.
- On 17 June 2022, the Strategic Policy & Resources Committee agreed that English and Irish bilingual signage should be installed at Belfast City Cemetery.
- On 23 September 2022, at a meeting of the Council’s Strategic Policy and Resources Committee it was agreed to erect bilingual English and Irish signage at Páirc Nua Chollann, a new Council facility on the Stewartstown Road.
Equality Scheme
The Council’s Revised Equality Scheme (approved in 2021), which sets out the Council’s arrangements for complying with the equality duties under Section 75 of the Northern Ireland Act 1998, includes a commitment to providing information in alternative formats on request, where reasonably practicable. The Scheme states that alternative formats may include Easy Read, Braille, audio formats (CD, mp3 or DAISY), large print or minority languages to meet the needs of those for whom English is not their first language.
(viii) Advice from the Equality Commission for Northern Ireland
Response by the Equality Commission for Northern Ireland to the Consultation by the Department of Culture, Arts and Leisure on a Strategy for protecting and enhancing the development of the Irish Language, November 2012
‘Para. 12: The Commission considers that the use of any language should be a neutral act and that the speaking of Irish or its more general use in the community should not diminish the entitlements of those whose right to their British identity is guaranteed in the Good Friday Agreement. Similarly, the Commission considers that the wider use of Ulster Scots should not in any way diminish the entitlements of those whose right to their Irish identity is similarly guaranteed. The speaking of any language in Northern Ireland should not be perceived as a threat to any individual or group, nor should it be intended in such a manner.’
Following discussion at the Joint Diversity Group, 18 October 2013, an enquiry was made to the Equality Commission for Northern Ireland (ECNI) regarding Newry & Mourne Council’s Language Policy.
ECNI responded:
‘We have commented that Newry & Mourne has a clear policy in place to promote the Irish Language and the Commission has provided advice, when requested, in relation to the implementation of the policy. In general we consider the language rights issue to be more a human rights issue than an equality issue although there is an intersection with employment and good relations aspects’.
ECNI also summarised their response to Committee of Experts on the European Charter for Regional and Minority Languages:
‘Our response had made the point that the notion that providing equality or protection for one group limits their availability for another is both unfounded in itself and acts to the detriment of all who seek to live in a society that is fair and equitable and should be avoided in the drafting of public policy.’
Response by the Equality Commission for Northern Ireland to the Consultation by the Department of Culture, Arts and Leisure on Proposals for an Irish Language Bill, May 2015
‘Para. 3: On the relatively few occasions that language issues have been brought to our attention, it has come about because they were raised in the context of Section 75 of the Northern Ireland Act 1998 and/or the provisions of the anti-discrimination legislation, specifically the Race Relations (NI) Order 1997 and the Fair Employment and Treatment (NI) Order 1998. The Commission’s advice to public authorities has been specific to the context presented by the public authority. It has referenced our position on minority languages (as set out below), the public authority’s compliance with its Equality Scheme commitments and the Commission’s guidance, as well as the provisions of the relevant anti-discrimination legislation, if appropriate.’
‘Para. 11: An important aspect of language policy is the interrelationship between individuals or groups that speak different languages. Any duty placed on public authorities should ensure that the development of provisions to protect and promote the language is viewed within the context of the duty to have due regard to the need to promote equality of opportunity and to have regard to the desirability of promoting good relations within the provision of public services. Public authorities should consider aspects of mutual understanding, co-operation, communication and partnership between different ‘language communities’, including engagement with relevant communities to seek to explore and take reasonable account of concerns or perceptions about the promotion of minority languages.’
(ix) Academic research
Language, Politics and Identity in Ireland: a Historical Overview – Tony Crowley
Crowley provides insight into the significance of linguistic diversity, placed at the heart of the Good Friday/Belfast Agreement (1998), which brought about new constitutional arrangements between the Republic of Ireland and the United Kingdom, and a new structure of governance within Northern Ireland. The text of the concord included the following general declaration:
‘All participants recognise the importance of respect, understanding and tolerance in relation to linguistic diversity, including in Northern Ireland, the Irish language, Ulster-Scots and the languages of the various ethnic minorities, all of which are part of the cultural wealth of the island of Ireland.’ (Belfast Agreement 1998: 19)
Crowley observes, ‘In the context of a document that outlined the contours of a major historical settlement, this is a striking statement about the significance of language(s) in Ireland which indicates the continuing social and political status of ‘the language question(s)’ in Irish history’.
(x) Feedback from pre-consultation on Language Strategy
Various meetings were held with representative groups in drawing up the Language Strategy 2018 - 23. The list below is a combination of key factors identified at such meetings.
Irish language sector
Various practical suggestions to build on currently available services were made, including:
- Information on services currently available for Irish speakers could be provided on the council’s website together with a link from the homepage to Irish language and culture sector websites; key council documents could also be provided in Irish on the website;
- There could be better promotion of the availability of tours of the city hall in Irish and an increase in the number of such tours available; consideration could also be given to making tours of other venues available in Irish;
- Greater access to council venues and facilities for Irish language and culture events could be facilitated and opportunities to present joint heritage exhibitions could be pursued;
- Initiatives should be implemented to raise awareness among council staff of the current language policy and the practical issues around translation; staff could also be made more aware of the work of the Irish language sector in Belfast;
- The possibility of appointing an Irish language officer could be considered.
Ulster-Scots sector
The sector representatives indicated that Irish and Ulster-Scots were at different stages of development and the use of the Ulster-Scots language was not received in Belfast in the same way as in other parts of Northern Ireland. There was an underlying prejudice with the use of Ulster-Scots and there was a need for wider cultural engagement with Ulster-Scots heritage as well as language and for celebration of the culture in a more open way.
The sector representatives wished to see a focus on the cultural and heritage aspects of the language rather than promote the need for translation services. They welcomed the Council’s commitment to support Ulster-Scots traditions and cultural activities in practical ways; however, they were concerned that the promotion of any language might be seen to be political and lead to division.
New communities
The sector representatives suggested that:
- the Council’s Welcome Pack should be more widely publicised and an electronic link to the Welcome Pack could be included in a regular electronic update circulated to appropriate organisations;
- Council staff should be made more aware of the Big Word interpreting service and trained in how to use it;
- a leaflet could be made available to Council staff so that they can assist service users to identify the language translation required;
- the Council could support initiatives to promote the heritage and traditions associated with different languages spoken in Belfast.
People with sensory or learning disabilities
The sector representatives suggested that:
- our website is clear and provides technology for people who are blind and partially sighted
- the Council needs to think about how we make our information accessible to everyone
- as civic leader we need to lead others by example, in having menus in braille and large print
- there are so many Council services that people don’t always understand that there are things there which are of interest – how does Council link with groups for people with disabilities
- hearing loops should be included in the new exhibition
- signed tours of City Hall could be offered and promoted
(xi) Feedback from consultation on City-wide leisure centre signage
Following a Special Council meeting on Friday 11 October 2019, the Council agreed to commission a public consultation regarding the installation of bilingual and multilingual signage in four new or recently refurbished City-wide leisure centres (Andersonstown, Lisnasharragh, Olympia and Templemore). This signage and naming decision represents one element of the outworking of Council’s Language Strategy 2018-2023, a strategy that aspires to make Belfast a place where linguistic diversity is celebrated and respected, and which complements the broader vision of the Belfast Agenda.
It was agreed that the consultation would employ both quantitative and qualitative methods to ensure widespread and meaningful engagement. These methods included the following:
- public and staff engagement events which were held in the local areas of each of the four leisure centres: (Andersonstown, Lisnasharragh, Olympia and Templemore); additional public meetings were held for both Templemore and Andersonstown due to the short notice of the first set of public meetings;
- Belfast City Council staff and GLL staff had the opportunity to complete an online survey or face-to-face engagement;
- an online questionnaire survey was made available for the public, along with hard copies for those who were unable to access the material electronically;
- face-to-face engagement with disabled communities (including the Council’s Disability Advisory Panel); representatives of the Irish Language and Ulster Scots communities; the Council’s Equality Consultative Forum; and the Council’s Migrant Forum;
- further engagement with the external consultant for individuals or representatives was available by arrangement.
All relevant consultation materials were published on Belfast City Council’s website and through other appropriate social media channels.
The consultation opened on 5 November 2019 and closed on 10 January 2020.
There was a substantial response to the consultation process from across all communities. Responses included:
- 3,393 completed response forms, submitted by members of the public by post or email;
- eight completed staff questionnaires, submitted anonymously by post or email;
- two written submissions (from Joanne Bunting MLA and the Northern Ireland Human Rights Commission);
- one photocopied summary response sheet with name and addresses included (n = 262 ).
In addition, a total of 127 members of the public attended one of the 12 scheduled public meetings (this included afternoon and evening sessions at each location, with two sets of meetings held at both Templemore and Andersonstown due to the short notice of the meetings held in these locations in the first week of the consultation), and 30 sector representatives attended at least one of the five scheduled meetings.
Only nine members of staff attended one of the six scheduled meetings at the four leisure centres, and no staff attended the drop-in session.
This represents a grand total of 3,822 responses.
The profile of questionnaire respondents (n = 3393) tended to be characterised by an over-representation of men (56.3 per cent), those from the west of the city (35.5 per cent), those whose national identity was Irish (47.9 per cent) and those who self-identified as Catholic (48.9 per cent), in comparison with 21.4 per cent who identified as British and 28.8 per cent Protestant. It was also noteworthy that of those aged under 18 years who completed the survey (n = 320), 90.3 per cent were self-identified as Catholic.
In terms of written comments, the significant level of emotion revealed in many written responses was noteworthy. A number of comments focused on practical considerations, and including the expense attached to additional signage, or the priority of making buildings easily accessible to all users. In this regard, bilingual signage was seen by some as potentially confusing. Others argued that a focus on only a single issue, such as bilingualism, could be to the detriment of considerations such as the communication needs of those with a disability, those with literacy problems, or those from new communities.
Comments relating specifically to the use of either bilingual or monolingual signs varied widely in scope and focus but in very general terms, these could be broadly grouped into one of two camps.
On the one hand there were those who celebrated linguistic diversity, the promotion of minority languages and the benefits of bilingualism, arguing that naming and signage in languages along with English would enhance the cultural vitality of the city. In particular, the promotion of Irish was highlighted as a positive and progressive way forward, and in general saw no threat attached to this approach. While many did not couch comments in terms of rights, others saw the promotion of minority languages as a fundamental right that was being ignored. Others argued that greater use of Irish would be an indication of a welcoming and inclusive environment for all, including those who chose to communicate and educate primarily in Irish.
On the other hand there were those who may not have objected to the Irish language per se but who felt that, at the present time, the use of the language had been politicised and in their view now posed a threat to their culture and heritage. It was argued that this feeling had grown as the relative sizes of the two communities had shifted over recent times within Belfast. English was often described as sufficient, as it was seen to represent the main language of the UK. A smaller number voiced a concern that the imposition of Irish in areas where it may not be welcome had the potential to damage community relations and would be resisted by local communities.
Regarding the series of public meetings, the atmosphere that characterised these events varied dramatically. At many, the level of attendance was disappointing, and the questions that were asked were often no more than seeking information or clarification. These smaller meetings did raise a number of interesting issues however, for example, whether words such as Olympia could be translated into other languages, and the extent to which detail on internal signage could be presented bilingually without losing clarity. A further discussion point was why local solutions were being sought for ‘City-wide’ leisure centres as this appeared to be a contradiction in terms.
The atmosphere at larger meetings was far more confrontational. There was a considerable level of emotion at these meetings, and a deep suspicion among participants as to the true purpose of the exercise, and the Council’s long-term objectives. During these events it was often difficult to maintain order or follow an agenda, as many participants’ contributions were fuelled by considerable levels of anger and frustration at the Council, and this was seen as an opportunity to vent that anger. In particular, the consultation exercise was characterised as a conspiracy to impose language forms on local facilities against the will of that community.
There was widespread agreement on three matters, namely that:
(i) internal directional signage should be pictorial to enhance accessibility;
(ii) there should be consistency in language between internal directional signage and external signage; and in principle and subject to appropriate consultation, the Council should consider adopting bilingual and multilingual naming and signage at all of its leisure centres in future.
The majority of those who expressed an opinion stated a preference for English and Irish external naming signage at each of the four centres (overall, 61.4 per cent), with this preference being most pronounced at Andersonstown Leisure Centre (66.9 per cent).
However, this headline figure does not take into account the deep divisions of opinion across the sample and in particular in terms of preferences by national identity and community background.
Of those who self-identified as Catholic, four out of five respondents (80.1 per cent) advocated external naming signage in English and Irish across all four centres, and this figure rose to 88.7 per cent in the case of Andersonstown. In stark contrast, 85.4 per cent of those who described themselves as Protestant indicated a preference for English only naming and signage for Lisnasharragh, Olympia and Templemore Leisure Centres, although this figure fell somewhat to 73.7 per cent for Andersonstown.
These statistics were confirmed by views expressed in public meetings and by sector representatives, where events were generally characterised not by debate or difference in opinion but by consistent and unswerving unanimity of view. The level of emotion attaching to these views was often noteworthy. To summarise briefly, on the one hand there were those who celebrated linguistic diversity, the promotion of minority languages and the benefits of bilingualism, arguing that naming and signage in languages along with English would enhance the cultural vitality of the city. On the other hand there were those who may not have objected to the Irish language per se but who felt that, at the present time, the use of the language had been politicised and in their view now posed a threat to their culture and heritage.
Despite the survey inviting separate views on external naming signage for each of the four leisure centres, the overwhelming majority of respondents (86.1 per cent) chose instead to give the same response for all four centres.
While no strict protocols exist in relation to how consultation can be used to inform decision-making by public authorities, the experience of Section 75 has provided some useful guidance on the weight to be attached. For example, Schedule 9 of the Northern Ireland Act 1998 requires that, in making any decision with respect to a policy, a public authority shall take into account any EQIA and consultation carried out in relation to the policy (para. 9.2).
Although there is no strict definition of what ‘taking into account’ entails, the Equality Commission guidance on how decisions should be recorded makes it clear that a public authority must be able to record the decision-making process (as well as the decision) and that the decision must be justified [Footnote 4].
The guidance also advises that all available information should be combined in the decision; this includes the information gathered during the research phase, the results of the consultation and the analysis of alternative options. It is hoped that this information has been brought together in this report in order to place the Council is in a position to take account of all pertinent issues when making a decision.
In any consultation, the number of people expressing a preference for a particular option cannot be ignored but must also be considered in the context of all other relevant concerns, including the strength and depth of feeling expressed by all respondents. It was to be expected that those who took the time and trouble to respond to the consultation would be those with strong opinions on the subject and they have made their views very clear. In relation to Section 75 consultations, the Equality Commission has made explicit in the past that an ‘EQIA should not be considered as a referendum whereby the views of consultees from a majority are counted as votes to decide the outcome.’ Instead, all available quantitative and qualitative data should be interrogated in order to help reach a decision that aspires to be fair, reasonable and proportionate.
On this occasion there would appear to be no specific legal requirement acting on the Council to adopt a particular approach to naming and signage. The most recent guidance (New Decade, New Approach, see p.14 above) does not provide great clarity but instead implies that public authorities will have a degree of autonomy in deciding which language formats are deemed appropriate.
While the consultation did not provoke many responses in relation to Section 75 considerations and including the draft equality screening report the adverse impacts that may attach to any decision on naming and signage cannot be ignored. These adverse impacts were alluded to by a number of respondents who suggested either that good relations generally may be damaged by the imposition of a Council decision on a local facility or that a centre may be less welcoming to members of certain communities depending on the languages on display. At this time these concerns are only conjecture and have yet to be tested but should be borne in mind nevertheless.
With this in mind, the decision must also be married with the Council’s Good Relations Strategy, and including a commitment to the development of shared spaces across the city.
The consultation revealed considerable support for only one form of bilingual signage, English and Irish, most especially among members of the Catholic community who identify as Irish. This enthusiasm is not matched by those from the Protestant community who identify as British and the contrast in views could not be more stark.
The following tables provide a summary of preferences for each leisure centre.
The first table indicates that an overall majority would prefer to see a combination of English and Irish on all external naming signage. This is especially the case for Andersonstown Leisure Centre where around two-thirds of respondents (66.9 per cent) preferred this option, with the other centres averaging around 60 per cent. Around a quarter of those surveyed stated a preference for English only signage.
Q.1 Which of the following languages would you like to see on external naming signage for; (tick one for each leisure centre as follows):
Table 2: External naming preferences: Overall sample by centre
Andersonstown LC |
No. of responses |
Per cent of responses |
|
---|---|---|---|
1 |
English Only |
778 |
22.9 |
2 |
English and Irish |
2270 |
66.9 |
3 |
English and Ulster-Scots |
25 |
0.7 |
4 |
English, Irish and Ulster-Scots |
213 |
6.3 |
5 |
No preference |
90 |
2.7 |
|
TOTAL |
3393 |
100 |
Lisnasharragh LC |
No. of responses |
Per cent of responses |
|
---|---|---|---|
1 |
English Only |
901 |
26.6 |
2 |
English and Irish |
2028 |
59.8 |
3 |
English and Ulster-Scots |
54 |
1.6 |
4 |
English, Irish and Ulster-Scots |
278 |
8.2 |
5 |
No preference |
97 |
2.9 |
|
TOTAL |
3393 |
100 |
Olympia LC |
No. of responses |
Per cent of total responses |
|
---|---|---|---|
1 |
English Only |
877 |
25.8 |
2 |
English and Irish |
2035 |
60.0 |
3 |
English and Ulster-Scots |
39 |
1.1 |
4 |
English, Irish and Ulster-Scots |
314 |
9.3 |
5 |
No preference |
87 |
2.6 |
|
TOTAL |
3393 |
100 |
Templemore LC |
No. of responses |
Per cent of total responses |
|
---|---|---|---|
1 |
English Only |
907 |
26.7 |
2 |
English and Irish |
2001 |
59.0 |
3 |
English and Ulster-Scots |
60 |
1.8 |
4 |
English, Irish and Ulster-Scots |
290 |
8.5 |
5 |
No preference |
101 |
3.0 |
|
TOTAL |
3393 |
100 |
Differences in patterns of response between the two main communities were stark (see Table 3 below). Among those who self-declared as Catholic, 80.1 per cent showed a preference for external signage in English and Irish, and this figure rose to 88.7 per cent in the case of Andersonstown. Among those self-declared as Protestant, 85.4 per cent supported English only signage for Lisnasharragh, Olympia and Templemore, although this figure dropped to 73.7 per cent for Andersonstown. Around half of those who stated neither religion showed support for English and Irish, rising to 60.4 per cent for Andersonstown.
Table 3: External naming preference by community background [Footnote 5] by centre
Andersonstown LC |
Protestant |
Catholic |
Neither |
||||
---|---|---|---|---|---|---|---|
No. |
Per cent |
No. |
Per cent |
No. |
Per cent |
||
1 |
English Only |
571 |
73.7 |
20 |
1.5 |
162 |
27.0 |
2 |
English and Irish |
72 |
9.3 |
1165 |
88.7 |
362 |
60.4 |
3 |
English and Ulster-Scots |
11 |
1.4 |
5 |
0.4 |
8 |
1.3 |
4 |
English, Irish and Ulster-Scots |
41 |
5.3 |
114 |
8.7 |
56 |
9.3 |
5 |
No preference |
75 |
9.7 |
4 |
0.3 |
10 |
1.7 |
6 |
Not answered |
5 |
0.6 |
5 |
0.4 |
1 |
0.2 |
|
TOTAL |
775 |
100 |
1313 |
100 |
599 |
100 |
Lisnasharragh LC |
Protestant |
Catholic |
Neither |
||||
No. |
per cent |
No. |
per cent |
No. |
per cent |
||
1 |
English Only |
671 |
86.6 |
24 |
1.8 |
178 |
29.7 |
2 |
English and Irish |
32 |
4.1 |
1021 |
77.8 |
309 |
51.6 |
3 |
English and Ulster-Scots |
35 |
4.5 |
10 |
0.8 |
9 |
1.5 |
4 |
English, Irish and Ulster-Scots |
28 |
3.6 |
170 |
13.0 |
77 |
12.9 |
5 |
No preference |
5 |
0.7 |
65 |
5.0 |
23 |
3.8 |
6 |
Not answered |
4 |
0.5 |
23 |
1.8 |
3 |
0.5 |
|
TOTAL |
775 |
100 |
1313 |
100 |
599 |
100 |
Olympia LC |
Protestant |
Catholic |
Neither |
||||
---|---|---|---|---|---|---|---|
No. |
per cent |
No. |
per cent |
No. |
per cent |
||
1 |
English Only |
652 |
84.1 |
24 |
1.8 |
173 |
28.9 |
2 |
English and Irish |
33 |
4.3 |
1022 |
77.8 |
314 |
52.4 |
3 |
English and Ulster-Scots |
23 |
3.0 |
7 |
0.5 |
8 |
1.3 |
4 |
English, Irish and Ulster-Scots |
30 |
3.9 |
197 |
15.0 |
83 |
13.9 |
5 |
No preference |
28 |
3.6 |
42 |
3.2 |
17 |
2.8 |
6 |
Not answered |
9 |
1.2 |
21 |
1.6 |
4 |
0.7 |
|
TOTAL |
775 |
100 |
1313 |
100 |
599 |
100 |
Templemore LC |
Protestant |
Catholic |
Neither |
||||
---|---|---|---|---|---|---|---|
No. |
per cent |
No. |
per cent |
No. |
per cent |
||
1 |
English Only |
670 |
86.5 |
27 |
2.1 |
173 |
30.2 |
2 |
English and Irish |
31 |
40 |
10000 |
76.2 |
308 |
51.1 |
3 |
English and Ulster-Scots |
36 |
4.7 |
16 |
1.2 |
8 |
1.3 |
4 |
English, Irish and Ulster-Scots |
24 |
3.1 |
181 |
13.8 |
81 |
13.5 |
5 |
No preference |
9 |
1.2 |
66 |
5.0 |
21 |
3.5 |
6 |
Not answered |
5 |
0.7 |
23 |
1.8 |
2 |
0.3 |
|
TOTAL |
775 |
100 |
1313 |
100 |
599 |
100 |
Differences between those who identified as either Irish or British were significant and broadly parallel the findings for community background. For those who stated their national identity as British, around 90 per cent preferred English only external signage for Lisnasharragh, Olympia and Templemore, although this figure dropping slightly for Andersonstown (78 per cent). In contrast, 90 per cent of those who self-identified as Irish showed preference for English and Irish signage in Andersonstown, with around 78 per cent choosing this option for the other three centres.
Table 4: External naming preferences by national identity by centre
Andersonstown LC |
British |
Irish |
NI |
Other |
|||||
---|---|---|---|---|---|---|---|---|---|
No. |
per cent |
No. |
per cent |
No. |
per cent |
No. |
per cent |
||
1 |
English Only |
566 |
78.0 |
14 |
0.9 |
166 |
22.7 |
10 |
3.2 |
2 |
English and Irish |
44 |
6.1 |
1455 |
89.6 |
92 |
47.7 |
21 |
95.2 |
3 |
English and Ulster-Scots |
13 |
1.8 |
5 |
0.3 |
6 |
0.0 |
0 |
0.1 |
4 |
English, Irish and U-Scots |
29 |
4.0 |
141 |
8.7 |
31 |
22.7 |
10 |
0.3 |
5 |
No preference |
69 |
9.5 |
4 |
0.3 |
12 |
6.8 |
3 |
0.3 |
6 |
Not answered |
5 |
0.7 |
5 |
0.3 |
1 |
0.0 |
0 |
0.9 |
|
TOTAL |
726 |
100 |
1624 |
100 |
308 |
100 |
44 |
100 |
Lisnasharragh LC |
British |
Irish |
NI |
Other |
|||||
---|---|---|---|---|---|---|---|---|---|
No. |
per cent |
No. |
per cent |
No. |
per cent |
No. |
per cent |
||
1 |
English Only |
650 |
89.5 |
20 |
1.2 |
195 |
63.3 |
10 |
22.7 |
2 |
English and Irish |
17 |
2.3 |
1274 |
78.5 |
66 |
21.4 |
19 |
43.2 |
3 |
English and Ulster-Scots |
35 |
4.8 |
10 |
0.6 |
9 |
2.9 |
0 |
0.0 |
4 |
English, Irish and U-Scots |
17 |
2.3 |
218 |
13.4 |
30 |
9.7 |
10 |
22.7 |
5 |
No preference |
4 |
0.6 |
77 |
4.7 |
6 |
2.0 |
5 |
11.4 |
6 |
Not answered |
3 |
0.4 |
25 |
1.5 |
2 |
0.7 |
0 |
0.0 |
|
TOTAL |
726 |
100 |
1624 |
100 |
308 |
100 |
44 |
100 |
Olympia LC |
British |
Irish |
NI |
Other |
|||||
---|---|---|---|---|---|---|---|---|---|
No. |
per cent |
No. |
per cent |
No. |
per cent |
No. |
per cent |
||
1 |
English Only |
636 |
87.6 |
18 |
1.1 |
187 |
60.7 |
10 |
22.7 |
2 |
English and Irish |
17 |
2.3 |
1280 |
78.8 |
67 |
21.8 |
19 |
43.2 |
3 |
English and Ulster-Scots |
22 |
3.0 |
8 |
0.5 |
8 |
2.6 |
0 |
0.0 |
4 |
English, Irish and U-Scots |
18 |
2.5 |
248 |
15.3 |
32 |
10.4 |
12 |
27.3 |
5 |
No preference |
24 |
3.3 |
48 |
3.0 |
12 |
3.9 |
3 |
6.8 |
6 |
Not answered |
9 |
1.2 |
22 |
1.4 |
2 |
0.7 |
0 |
0.0 |
|
TOTAL |
726 |
100 |
1624 |
100 |
308 |
100 |
44 |
100 |
Templemore LC |
British |
Irish |
NI |
Other |
|||||
---|---|---|---|---|---|---|---|---|---|
No. |
per cent |
No. |
per cent |
No. |
per cent |
No. |
per cent |
||
1 |
English Only |
651 |
90.0 |
25 |
1.5 |
195 |
63.3 |
10 |
22.7 |
2 |
English and Irish |
16 |
2.2 |
1254 |
77.2 |
60 |
19.5 |
19 |
43.2 |
3 |
English and Ulster-Scots |
34 |
4.7 |
15 |
0.9 |
10 |
3.3 |
1 |
2.27 |
4 |
English, Irish and U-Scots |
15 |
2.1 |
231 |
14.2 |
32 |
10.4 |
9 |
20.5 |
5 |
No preference |
5 |
0.7 |
75 |
4.6 |
10 |
3.3 |
5 |
11.4 |
6 |
Not answered |
5 |
0.7 |
24 |
1.5 |
1 |
0.3 |
0 |
0.0 |
|
TOTAL |
726 |
100 |
1624 |
100 |
308 |
100 |
44 |
100 |
Despite these stark differences in opinion between communities, both the questionnaire results and the qualitative data did indicate a willingness to accept that bilingual signs would be more acceptable in some centres than others. For example, while there was considerable local opposition to bilingual signage in Templemore and Lisnasharragh Leisure Centres, these same respondents often expressed a view, either verbally or in writing, that what was decided as appropriate for Andersonstown was of little concern to them, so long as the decision did not have an impact on their local facility.
In this respect a decision to erect external bilingual naming and internal directional signage in Andersonstown Leisure Centre did not run counter to the findings of the consultation, albeit that concerns were raised by various sector representatives that a local, as opposed to ‘City-wide’ solution could serve to ‘ghettoise’ or ‘linguistically balkanise’ the language.
However, local consultation revealed that a similar decision would have been regarded as an unwanted imposition by those who live close to Lisnasharragh and Templemore Leisure Centres, and would be likely to be met with considerable local opposition. Instead, the preferred option was clearly English Only signage in these centres.
The case of Olympia Leisure Centre was potentially more problematic, and the consultation was less well placed to help inform this decision. While the two communities expressed diametrically opposed views as to whether English only or English and Irish signage and naming were appropriate in this and other centres, there was little by way of direct feedback from the community local to Olympia during the consultation.
It was noted by one respondent that the local area is now culturally very diverse, and that users of the centre come from a variety of new communities, as well as from across the city. It was suggested that bilingual signage may be additionally confusing to those whose first language is not English. Furthermore, the centre has been open for over two years and the existing signage was well established, and the costs of replacement and rebranding were likely to be considerable. In addition, from a practical point of view, it is not clear if there is an Irish translation of Olympia, and therefore how Irish would be accommodated in the external naming.
Written comments and face-to-face exchanges brought to light a number of other practical considerations regarding naming and signage, which it was argued should be borne in mind in any future proposal, including:
- Cost: The cost involved in installing new signage in new centres may be less than changing existing signage.
- Translation: Names of centres may be more or less amenable to translation
- Wordage: A protocol may be required to determine the level to which bilingual signage should be applied (e.g. titles or subheadings).
Addendum: Olympia Consultation
Further to the end of the public consultation, an independent consultation report was prepared summarising the key findings and presenting conclusions to be drawn from the consultation process. The report highlighted the widespread engagement with a range of stakeholders, both locally and city-wide, but also acknowledged the paucity of local response with regard to Olympia Leisure Centre. (Two public consultation events were held at Olympia on 18 November 2019, at which a total of two members of the public attended.)
The report also recognised the special circumstances of Olympia in relation to the issue of naming and signage, as summarised in the final two bullet points of the report:
5.21 The case of Olympia Leisure Centre is potentially more problematic, and the consultation may be less well placed to help inform this decision. While the two communities expressed diametrically opposed views as to whether English Only or English and Irish signage and naming were appropriate in this and other centres, there was little by way of direct feedback from the community local to Olympia during the consultation, other than that the needs of new communities should be given due consideration in terms of accessibility in particular.
5.22 It was noted by one respondent that the local area is now culturally very diverse, and that users of the centre come from a variety of new communities, as well as from across the city. It was suggested that bilingual signage may be additionally confusing to those whose first language is not English. Furthermore, the centre has been open for over two years and the existing signage is now well established, and the costs of replacement and rebranding are likely to be considerable. In addition, from a practical point of view, it is not clear if there is an Irish translation of Olympia, and therefore how Irish would be accommodated in the external naming.
During the consultation period, Olympia did not tend to feature prominently as a topic, although at the meeting with the Council’s Equality Consultative Forum (10.12.19), it was noted that, ‘Olympia Leisure Centre was the closest to Coláiste Feirste, the largest Irish-medium secondary school anywhere in Ireland. It was felt by some that it would be a shame if the Irish language was not reflected in the signage here while others argued that the community around Olympia would not want this.’ (Independent Consultation Report, p.33).
Further to the presentation of the consultation report to SP&R Committee on 24 January 2020, on 12 February 2012 a meeting was convened in City Hall by DUP Councillor Tracy Kelly. This was primarily to voice concerns regarding the possible naming of Olympia, as well as the lack of local input into the decision-making process to date. The meeting was attended by representatives of communities local to Olympia (that is, Blackstaff and Windsor), together with DUP elected members and staff officers.
At the meeting it was argued that details of the original consultation had failed to reach representatives of local communities in time, and hence the ability of those communities to air their concerns had been lost.
Those representatives present at the meeting unanimously agreed that naming and signage in Olympia should be in English only, and expressed grave concerns as to the potential damage to good relations, locally and city-wide, should bilingual signage be imposed against what were described as the wishes of local residents.
It was also acknowledged that the local community adjacent to Olympia was now extremely diverse and included many new communities from e.g. Poland, Romania and Somalia, with different language needs that moved well beyond a consideration of English, Irish or Ulster-Scots .
A petition outlining concerns had been circulated by word of mouth and via social media, and has attracted 571 signatures.
During the meeting, concerns that a decision to include bilingual signage had already been made were allayed by Council officers, along with a commitment to bring forward the views expressed at the meeting to appropriate decision-making bodies within the Council.
Conclusions
While the meeting, and associated representations, fell outside the agreed period of consultation, it was not considered helpful or inclusive to set aside these submissions and perhaps in particular given the time constraints within which the consultation was originally carried out.
The sentiments expressed by those present indicated strong local support for English only signage, along with concern that good community relations could potentially be damaged if bilingual signage was to be installed.
Such a decision may also require the Council to reflect on its obligations under Section 75, as the potential for major adverse impact on good relations, and possibly also equality of opportunity grounds, cannot be ignored.
(xii) Census data by DEA and ward (religion, ethnicity, national identity, language)
Data from the 2011 Census provides a profile of the adjacent wards (Blackstaff and Musgrave) and District Electoral Areas (Botanic and Balmoral) by ethnic origin, religious belief, national identity and language use. Although this information is now somewhat dated (local 2021 census breakdowns are not yet publicly available), it may still be broadly indicative of the demographic profile of each area. In summary, Olympia is located in an area that can be characterised as ‘mixed’ with only one area, Blackstaff ward, being predominantly of one community (71.5 per cent Protestant). Returns from the latest local government elections (May 2023) confirm this impression with elected members from four parties accounting for the five seats in Balmoral, and five different parties for the five seats contested In Botanic DEA.
Table 5: Local Demographic Profile
Ethnic Origin |
Council Area |
Northern Ireland |
||||
---|---|---|---|---|---|---|
|
District Electoral Area |
Ward |
||||
|
Botanic |
Balmoral |
Musgrave |
Blackstaff |
Windsor |
|
White* |
91.5 per cent |
95.6 per cent |
95.2 per cent |
96.7 per cent |
89.0 per cent |
98.3 per cent |
Other |
8.5 per cent |
4.4 per cent |
4.8 per cent |
3.3 per cent |
11.0 per cent |
1.7 per cent |
*Note: Includes Irish Travellers |
Religious Belief |
Council Area |
Northern Ireland |
||||
---|---|---|---|---|---|---|
|
District Electoral Area |
Ward |
||||
|
Botanic |
Balmoral |
Musgrave |
Blackstaff |
Windsor |
|
Roman Catholic |
45.5 per cent |
43.4 per cent |
60.6 per cent |
15.0 per cent |
41.6 per cent |
45.1 per cent |
Protestant |
38.6 per cent |
47.8 per cent |
32.9 per cent |
71.5 per cent |
40.7 per cent |
48.4 per cent |
Other or ND* |
17.9 per cent |
8.8 per cent |
6.5 per cent |
13.5 per cent |
17.7 per cent |
6.5 per cent |
*Note: ND = not determined. |
National Identity |
Council Area |
Northern Ireland |
||||
---|---|---|---|---|---|---|
|
District Electoral Area |
Ward |
||||
|
Botanic |
Balmoral |
Musgrave |
Blackstaff |
Windsor |
|
British |
38.4 per cent |
48.7 per cent |
34.4 per cent |
63.2 per cent |
36.5 per cent |
48.4 per cent |
Irish |
33.5 per cent |
32.0 per cent |
42.9 per cent |
10.1 per cent |
31.5 per cent |
28.4 per cent |
Northern Irish |
29.2 per cent |
29.3 per cent |
28.1 per cent |
26.5 per cent |
32.2 per cent |
29.4 per cent |
* Note: Respondents could indicate more than one identity. |
Language |
Council Area |
Northern Ireland |
||||
---|---|---|---|---|---|---|
|
District Electoral Area |
Ward |
||||
|
Botanic |
Balmoral |
Musgrave |
Blackstaff |
Windsor |
|
Irish* |
15.6 per cent |
12.0 per cent |
18.6 per cent |
3.6 per cent |
14.6 per cent |
12.4 per cent |
Ulster Scots* |
6.7 per cent |
6.7 per cent |
5.4 per cent |
8.1 per cent |
7.5 per cent |
10.4 per cent |
English not first |
9.7 per cent |
3.2 per cent |
4.2 per cent |
9.4 per cent |
12.2 per cent |
4.6 per cent |
* Note: Indicates some knowledge of the language (Population aged 3+ yrs.) |
District Electoral Areas and wards
- Castle
- Chichester Park
- Oldpark
- New Lodge
- Court
- Black Mountain
- Ballymurphy
- Beechmount
- Andersonstown
- Collin
- Stewartstown
- Balmoral
- Botanic
- Lisnasharragh
- Cregagh
- Orangefield
- Ormiston
- Sandown
- Titanic
- Beersbridge
- Woodstock
- Ballymacarrett
- Connswater
5. Assessment of impacts
In accordance with the EQIA process, having gathered information on the proposal and those affected by it, the Council must then assess whether there is likely to be a differential impact on groups within one or more of the Section 75 categories if the proposal is adopted before determining the extent of that differential impact and whether the impact is likely to be adverse.
The proposal under consideration is to erect bilingual external naming and internal directional signage within Olympia Leisure Centre, and is further to a decision reached by the Council’s SP&R Committee on 24 September 2021. As agreed at SP&R Committee on 21 January 2022, a final decision has since been held in abeyance until the conclusion of the EQIA.
While the findings from the previous public consultation on naming and signage in four City-wide leisure centres (including Olympia) in 2019 and 2020 remain valid to some degree, and have helped to inform the current EQIA, it must also be recognised that this information was gathered over three years ago, and political times have undoubtedly changed in the meanwhile. Furthermore, the previous public consultation focused on four centres and was not carried out as an integral part of the EQIA process while on this occasion exclusive attention falls on Olympia and within the parameters of an EQIA. In combination, data from previous surveys alongside fresh data from the present EQIA should provide the Council with a solid foundation for reaching a decision on the proposal in question.
The previous public consultation in 2019-20 generated little interest in Olympia per se during the consultation period itself, However, further to an additional agreed period of consultation, strong local support was forthcoming for English only signage, with concerns raised that bilingual signage could heighten local community tensions and may serve to provoke a hostile response from certain elements within these communities.
The present EQIA will afford a contemporary opportunity to gauge local and city-wide opinion, and to test the potential of the proposal to adversely impact on the promotion of good relations and equality of opportunity at this time and mindful of changing political circumstances in the city.
While the installation of bilingual external naming and internal directional signage would continue to fall comfortably within the scope of the Council’s Language Strategy, as well as relevant local, national and international minority language charters and guidance, the proposal also has the potential to raise concerns with regard to the promotion of a good and harmonious environment for those who work in the Centre (that is, GLL staff) as well as those who visit or use the Centre.
While many who speak Irish would contest that its use is non-contentious and apolitical, there are those, predominantly from Protestant, Unionist and Loyalist communities, who would argue that the Irish language has been overtly politicised within the context of Northern Ireland.
Aside from this important dimension of good relations, previous consultation has identified that the Centre is used by members of new communities who reside in the locality, and their needs and experiences should also not be ignored in any future determination. For example, bilingual signage may be potentially confusing for those who may not have English as a first language.
Hence, the proposal may have the potential to adversely impact people with regard to religious belief, political opinion and race or ethnic origin but the precise extent of this impact is yet to be determined. In this way, the EQIA process, and in particular the current public consultation and stakeholder engagement, can help consider further the tangible and contemporary impacts of the policy in terms of: (i) encouraging or discouraging participation in sport and leisure in the Centre; (ii) the promotion of a good and harmonious working environment, and, more generally: (iii) the promotion of equality of opportunity and good relations among all employees, users and potential users of the Centre, as well as more widely across the City.
Equality of opportunity
The EQIA process is intended to anticipate barriers to participation or failings in service provision (that is, the promotion of equality of opportunity), and to assist public authorities in mitigating these adverse impacts as well as complying with the law. [Footnote 6]
One of the key indicators of adverse impact, as identified by the Equality Commission, can be lower participation rates or uptake by one or more group.
The proposal for bilingual naming and signage may give rise to a potential adverse impact for:
- users and potential users, and in particular those from a Protestant, Unionist, or Loyalist background;
- individuals from different ethnic origins who may want to visit the Centre.
In theory, it could be argued that there may be the potential for bilingual signage to introduce a ‘chill factor’ for those from particular communities which may in turn discourage access to or use of the Centre. However, to date there is no hard evidence to substantiate this assertion, but this possibility should not be ignored in any future monitoring of the proposal.
Further, there may be the potential for the use of bilingual signage to cause a degree of uncertainty or confusion for those who do not have English as a first language or those with literacy issues, perhaps linked to a disability. At the present time there has been no indication that this has raised significant concerns but it is a matter that the Council should also commit to keeping under review.
Good relations
More generally, the proposal may have an adverse impact on those residents, visitors and employees from a Protestant, Unionist or Loyalist community background, as well as those of different ethnic origins, in terms of an expectation that the Council will have regard to the desirability of promoting good relations through its policies. This would include the naming of facilities.
The evidence that is available to date, and including the previous round of public consultation in 2019-20, does indicate that the proposal for bilingual naming and signage has the potential to have an adverse impact on good relations on grounds of religious belief, political opinion, and also perhaps race or ethnic origin.
Previous consultations on related matters, and including the introduction of dual language signage in leisure centres, have suggested that there may be the potential for those who do not support languages other than English to see dual language signage as potentially challenging to their sense of identity. These concerns appear to be most notable, and emotive, when decisions are seen to impact on local areas or facilities and against the perceived wishes of those communities.
With this in mind, there are safeguards in place within the Council to ensure that any decision on the proposal takes on board the views of both the local community and city-wide residents, and is fair, reasonable and proportionate within the present-day context of local circumstances.
Conclusions
The EQIA on this proposal is now being made available for public consultation as Step 5 in the EQIA process.
The historical evidence that is available to date, and prior to this current period of consultation, suggests that the proposed changes may have the potential for an adverse impact but the extent of that impact is yet to be fully determined.
6. Consideration of measures to mitigate
This proposal and the accompanying assessment of impacts are now being presented for consultation. The EQIA process requires that, if it is decided that the proposal has an adverse impact on those within one or more of the nine equality categories, then a series of mitigations or alternatives should be put forward for consideration, and an assessment of the possible impact of these alternatives undertaken.
The Council must then consider the adoption of measures that may mitigate the adverse impact and alternative ways of delivering policy aims which have a less adverse impact on those within the relevant equality category or which better promote equality of opportunity and good relations.
The Equality Commission Guidance on this section advises that the Council should give consideration to options and measures that may mitigate any adverse impact, and to alternative policies that may better achieve the promotion of equality of opportunity. The guidance states:
‘The consideration of mitigating measures and alternative policies is at the heart of the EQIA process. Different options must be developed which reflect different ways of delivering the policy aims. The consideration of these measures is intertwined with the consideration of alternative policies. Mitigation can take the form of lessening the severity of the adverse impact.’
‘Ways of delivering policy aims that have a less adverse effect on the relevant equality category, or which better promote equality of opportunity for the relevant equality category, must in particular be considered. Consideration must be given to whether separate implementation strategies are necessary for the policy to be effective for the relevant group.’
While the consultation may confirm that no mitigations are required, it is imperative that alternative options are made available for consideration as part of the consultation process. This would include monolingual naming and signage, or consideration of alternative types of signage.
Equally, in reaching a decision on appropriate external naming, the Council may have to accommodate the fact that the name Olympia itself is not amenable to translation into Irish or may consider those external locations where bilingual signage is appropriate.
The Council has decided to seek views on the proposal for bilingual naming and signage at Olympia Leisure Centre, along with mitigating options, through public consultation. The Council will collate and analyse all comments received and this feedback will be used to inform emerging mitigating measures or alternative policies if appropriate.
In reaching a decision, the Council commits to remaining open to feedback and is committed to responding in a positive manner to views expressed through the consultation process.
Conclusions
At this time, and prior to feedback obtained from the public consultation on the EQIA, it is not felt that mitigating measures need to be specified over and above a consideration of alternative language forms. Instead, the Council will reflect on feedback, including a consideration of these alternative options, and will continue to remain mindful of the need to accommodate sensitivities around this issue and ensure that all steps are taken to minimise potential adverse impacts in the future, whether currently seen or unseen.
7. Consultation
Belfast City Council is committed to consultation which is timely, open and inclusive and conducted in accordance with the Equality Commission’s Guiding Principles. The consultation process in respect of this EQIA will last for a period of 14 weeks from 12 June 2023 to midnight on 17 September 2023.
All Equality Scheme consultees will be notified of the availability of this EQIA report and invited to comment.
A press release will be prepared and issued to various media outlets to make the public aware of the EQIA.
Information about the EQIA can be found at yoursay.belfastcity.gov.uk/olympia-signage-eqia (link opens in new window) and through other appropriate social media channels.
An online questionnaire survey will be made available for the public and Council staff, along with hard copies for those who are unable to access the material electronically;
Comments will be welcomed from any individual with an interest in the proposals, in whatever format is chosen.
Further engagement with the external consultant for individuals or representatives can be arranged on request.
Face-to-face engagement with representatives of the Irish Language and Ulster Scots communities.
The council will make its Migrant Forum, Disability Advisory Panel and Sign Language Users’ Forum aware of the consultation and will offer engagement sessions upon request;
The Council will arrange and facilitate two public consultation events to be held on Wednesday 14 June from 3pm to 4pm and 7pm to 8pm at Olympia. You can register for these on our YourSay platform.
There will also be online consultation events on Tuesday 13 June from 10am to 11am and on Wednesday 23 August from 12 noon to 1pm and 7pm to 8pm. You can register for these on our YourSay platform.
All consultation documents can be made available in hard copy, email and alternative formats on request and can be accessed at yoursay.belfastcity.gov.uk/olympia-signage-eqia (link opens in new window).
As much background information as possible has been included within this report. If there is any information which has not been provided, the Council will make every effort to do so on request. If any consultee has difficulty accessing the background information the Council will consider providing summaries in other formats or explaining issues on a face-to-face basis.
All comments and queries regarding this report should be addressed to:
Olympia Signage EQIA,
Equality and Diversity Unit,
Belfast City Council,
Belfast City Hall BT1 5GS
Telephone: 028 9027 0511
Freephone: 080 0085 5412
Textphone 028 9027 0405
Email: [email protected]
8. Further steps
At the end of the consultation period, the Draft EQIA report will be revised to take account of all comments received from consultees. An EQIA Final Decision Report will then be submitted to Council to assist Elected Members in reaching a decision in respect of the proposal. The Council’s decisions will be incorporated into an EQIA Final Decision Report which will set out the consideration given to the impact of alternative policies and mitigating actions. This will complete Step 6 of the EQIA process.
The EQIA Final Decision Report will be made available at Olympia signage: consultation on Draft Equality Impact Assessment | Your say Belfast (link opens in new window). In addition, Equality Scheme consultees and those who responded to the consultation will be notified of the availability of the report.
A system will be established to monitor the impact of the Council’s decision in order to find out the effect on the relevant Section 75 groups. Full details of the monitoring system will be included in the EQIA Final Decision Report.
The results of ongoing monitoring will be reviewed on an annual basis and included in the annual review on progress to the Equality Commission. This review will be published on Olympia signage: consultation on Draft Equality Impact Assessment | Your say Belfast (link opens in new window). This will complete Step 7 of the EQIA process.
Appendix 1: Belfast’s population by Section 75 category
Section 75 category |
Details of evidence, information and engagement |
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Religious belief |
According to the 2021 Census, 48.7 per cent (45.7 per cent) of the usual residents of Belfast were from a Catholic community background compared with 36.4 per cent (43.4 per cent) from a Protestant or other Christian related background, with 3.3 per cent (1.5 per cent) Other and 11.6 per cent (9.3 per cent) None. (Figures in brackets refer to NI as a whole.) The Continuous Household Survey 2013-14 data showed that:
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Political opinion |
Local government elections on 18 May 2023. The results of the election to Belfast City Council are shown below.
Results for the two District Electoral Areas adjoining Olympia (Balmoral and Botanic), were:
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Racial group |
Country of birth statistics taken from the last census in 2021, show that 8.6 per cent of all usual Belfast residents were born outside the UK and Ireland. The Census showed that the most commonly spoken languages in Belfast (excluding English and Irish) are Polish, Arabic and Chinese |
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Age |
The age profile of Belfast is slightly younger compared to that of the wider region. 18.0 per cent are aged under 15 (slightly lower than the Northern Ireland average of 19.2 per cent), 37.1 per cent are aged 15-39 (compared with 31.2 per cent), 30.1 per cent aged 40-64 (32.4 per cent for NI), and 14.7 per cent 65 and over (17.2 per cent). The Continuous Household Survey 2013-14 data showed that:
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Marital status |
According to the 2021 Census, around one third (33.2 per cent) of all usual residents in Belfast (aged 16+) are married or in a civil partnership – a relatively low proportion when compared with the Northern Ireland average (45.8 per cent). Belfast has a higher percentage (49.8 per cent) of residents who are single when compared with the Northern Ireland average (38.1 per cent). There is also a higher than average proportion of people in Belfast who are separated, divorced or widowed (17.0 per cent to 16.2 per cent NI average).Belfast also has 720 residents who are in a registered same-sex civil partnership, around a quarter of all such partnerships in Northern Ireland (2742). The Continuous Household Survey 2013-14 data showed that for those who are married or cohabiting, the proportion who had some knowledge of Ulster-Scots increased from 15.9 per cent in 2011-12 to 19.1 per cent in 2013-14. 2013-14 data showed that adults who are married or cohabiting or widowed (19.1 per cent and 19.0 per cent respectively) are more likely to have knowledge of Ulster-Scots than those who are single (11.2 per cent). |
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Sexual orientation |
According to the 2021 Census, 31,600 people aged 16 and over (2.1 per cent) identified as LGB+ ('lesbian, gay, bisexual or other sexual orientation'), 1.364 million people (90.0 per cent) identified as 'straight or heterosexual' and 119,000 (7.9 per cent) either did not answer the question or ticked 'prefer not to say'. A higher proportion (4.1 per cent of adults) in Belfast identified as LGB+, Several UK and NI based studies have attempted to quantify the number of people who identify as LGB. Estimates for LGB population range from 0.3-10 per cent using different sources. A commonly used estimate of LGB people in the UK, accepted by Stonewall UK, is approximately 5-7 per cent of the population. |
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Men and women generally |
Belfast has a slightly higher proportion of women (51.3 per cent) of all residents), in comparison with Northern Ireland as a whole (50.8 per cent). The Continuous Household Survey 2013-14 data showed that the proportion of males who have knowledge of Ulster-Scots increased from 16.2 in 2011-12 to 19.9 per cent in 2013-14. 2013-14 data showed that men (19.9 per cent) are more likely to have knowledge of Ulster-Scots than women (13.5 per cent). |
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Disability |
2021 Census figures show that over one quarter (26 per cent) of Belfast residents have a long-term health problem or disability which affects their day-to-day activities. This is a slightly higher proportion than the Northern Ireland average (24.3 per cent). Over one-third of Belfast residents reported that they had a long-term condition (defined as a condition which has lasted, or is expected to last, at least 12 months). The most common conditions were mobility or dexterity, pain or discomfort, shortness of breath or difficulty breathing, and emotional, psychological or mental health condition. Deafness and hard of hearing The table below provides information on people with deafness (or partial hearing loss), blindness (or partial sight loss) and other communication difficulty. The Northern Ireland Census does not provide information on users of sign language or readers of Braille, but DCAL estimates that approximately 5,000 people in Northern Ireland use sign language as the preferred means of communication, with 3,500 using BSL and 1,500 using ISL.
DCAL set up a Sign Language Partnership Group in 2005 which produced best practice guidance on providing public services to Deaf people who use British Sign Language (BSL) or Irish Sign Language (ISL). Speaking in the Assembly on 1 December 2015, the Minister for Culture, Arts and Leisure said that the Partnership Group had contributed much to improving the lives of sign language users and their families but that she was convinced of the need to do much more. She indicated that the Deaf community had made it clear that they want legislation to safeguard their rights as a cultural and linguistic minority. The Minster said that she would take initial steps to address this issue before responsibility transfers to the Department of Communities in 2016. A draft Sign Language Framework was opened for public consultation from 15 March 2016 to 4 July 2016, the consultation report has not, to date, been published. |
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Dependants |
According to the 2021 Census, 40.1 per cent of households in Belfast included no dependent children, in comparison with 44.9 per cent of households across Northern Ireland. The Belfast City Council Residents Survey 2014, reported that 32.3 per cent of the population have dependants or caring responsibilities. The 2011 Census shows that 28.58 per cent of households in Belfast include dependent children, compared with the Northern Ireland average of 33.86 per cent. The Continuous Household Survey 2013-14 data showed that a higher proportion of adults who do not have dependents (17.8 per cent) have knowledge of Ulster-Scots than those who have dependents (14.7 per cent). |
Footnotes
[Footnote 1] Practical Guidance on Equality Impact Assessment, ECNI 2004
[Footnote 2] https://www.ohchr.org/Documents/Issues/Minorities/SR/LanguageRightsLinguisticMinorities_EN.pdf (link opens in new window)
[Footnote 3] Language Rights of Linguistic Minorities: A Practical Guide for Implementation (link opens in new window)
[Footnote 4] Practical Guidance on Equality Impact Assessment, ECNI 2004, p.45
[Footnote 5] Excluding those who did not answer this question (n = 706)
[Footnote 6] Practical Guidance on Equality Impact Assessment, Equality Commission for NI, 2004 (p.22)