Memorandum from the Royal National Institute
of the Blind (RNIB) (DDB 122)
ADDITIONAL CLAUSE FOR THE DRAFT DISABILITY
DISCRIMINATION BILL (FEBRUARY 2004): COUNCILLORS AND MEMBERS OF
THE GREATER LONDON AUTHORITY
1. COMMENTS ON
SECTION 5B
1.1 RNIB has concerns around the provisions
in clause 15B (4). We are concerned that the provision in 15B(4),
allowing for the introduction of regulations that state when less
favourable treatment which relates to a person's disability can
or cannot be justified, may lead to the justification of less
favourable treatment in cases where this would not be desirable
or appropriate because the threshold used ("material and
substantial" (Section 3A (3)) is a low one. We would urge
the Joint Committee to gain assurances that the regulations will
not be used to lower this threshold any further.
2. COMMENTS ON
SECTION 15C
2.1 We are concerned that the reasonable
adjustment provisions within 15C do not contain provisions requiring
auxiliary aids and services to be provided where they would enable
or facilitate the official business of councillors. This duty
is vital in securing the access needs of disabled councillors
in cases such as;
— A blind or partially sighted councillor
who needs written information in an accessible format such as
tape or large print.
— A councillor who is hard of hearing
and requires a BSL interpreter or a palantypist.
2.2 Without such vital provision we are
concerned that the new clause will fail to assist disabled councillors
who have additional communication needs.
2.3 We would therefore like to see the wording
of 15C amended so that it makes adequate provision for auxiliary
aids and services that enable and facilitate the access of disabled
councillors when performing official business.
March 2004
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