6. Summary of consultation responses

The Equality Commission’s Guide to the Statutory Duties makes it clear that a formal consultation exercise should be included as a critical stage in an EQIA, immediately before decision making. Consultation should focus on the actual impact of the existing policy and the likely impact of proposed and alternative policies. Consultation should be inclusive, afford a fair opportunity to communicate pertinent information and enable consultees to give advice and opinion on the policy so that the public authority may reach a more informed decision. However, the Equality Commission has also made it clear 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.[5] [5] Practical Guidance on Equality Impact Assessment, Equality Commission for NU, 2004 (p.36)

The consultation process on this EQIA covered a 14-week period from 21 February 2022 to 13 May 2022 and 16 June 2022 and 1 July 2022. [JS1] During the consultation period the draft EQIA report was available on the Council’s website together with questionnaires for staff and the public designed to facilitate the type of responses referred to above. A public advertisement was placed in the local press, and there were two public meetings. The Council’s Equality Scheme consultees were notified of the availability of the report and invited to comment. Elected Members were made aware of the draft EQIA report and consultation questionnaires on the Council’s website, invited to submit written responses and attend an online consultation event.

Responses to the online consultation events

The following section summarises online consultation events that were carried out during the 14-week public consultation.

Public meetings

Two online consultation events were arranged and widely advertised. No attendance was recorded.

Staff meetings

Two online consultation events were arranged. No attendance was recorded.

Equality Forum

Six Equality Forum members attended. One respondent questioned if everyone would feel welcome and “included”. One attendee had no objection to the Union flag flying 365 days a year, but she was concerned that it may be viewed as “overkill”. A note of the meeting is attached in Appendix 12.

Youth Forum

The Youth Forum members were invited to attend an online consultation event. They opted for a closed session with a recorded version of the presentation.

Elected Members

Eighteen elected Members attended. Respondents raised questions regarding the administrative arrangements of the EQIA report. The queries concerned the submission date of the final EQIA report to council and if community groups had been contacted.

An extension to the consultation deadline of two weeks as the report had been circulated over the Easter holidays and election period was requested and agreed.

A note of the meeting is attached in Appendix 13.

Responses from the general public

There were 562 responses received to an online survey targeted at the general public.[6] Five hundred and fifty-one responses were received from individuals and two were received from organisations (nine returns did not include responses to this question). [6] Unless otherwise stated, n=562

Demographic breakdown of responses

Geographic spread

Respondents were asked to provide the first four digits of their postcode. The map and table below show the geographic spread of respondents.

Postcode Percentage Number

BT35 0.7% 4

BT44 6.2% 35

BT46 0.2% 1

BT47 4.3% 24

BT49 14.8% 83

BT51 13.2% 74

BT52 15.8% 89

BT53 20.6% 116

BT54 5.2% 29

BT55 7.5% 42

BT56 2.8% 16

BT57 2.1% 12

No response 6.6% 37

Community background

44.7 per cent of respondents identified as from a Protestant community background. 24.0 per cent identified as from a Roman Catholic community background.

Community background Number Percentage

Roman Catholic 135 24.0%

Protestant 251 44.7%

Other Christian 32 5.7%
(Including Christian related)

Other Faith or non-Christian 3 0.5%
community background

No religion 79 14.1%

Prefer not to say/no response 62 11.0%

National identity

42 per cent of respondents identified as British. 26 per cent identified as Northern Irish. 24.4 per cent identified as Irish.

National identity Number Percentage

British 236 42.0%

Irish 137 24.4%

Northern Irish 146 26.0%

English 3 0.5%

Scottish 4 0.7%

Welsh 1 0.2%

Other 16 2.8%

No response 19 3.4%

Ethnic group

96.3 per cent of respondents (519) identified as white. 1.7 per cent (9) identified as from another ethnic group.[7] [7] n=539

Age

The following graph and table provide a breakdown of responses by age band.

Age band Number Percentage

Under 16 3 0.5%

16-24 26 4.6%

25-34 97 17.3%

35-44 155 27.6%

45-54 121 21.5%

55-64 94 16.7%

Over 65 57 10.1%

No response 9 1.6%

Gender identity

The majority of respondents (62.1 per cent) identified as male.

Gender identity Number Percentage

Male 349 62.1%

Female 186 33.1%

Prefer not to 25 4.4%
say/nil response

In some other way 2 0.4%

Responses in relation to the policy

The following section considers responses to the current and proposed policy on flying the Union flag.

It should be noted that the responses indicate some confusion as to the nature of the current and proposed policy. For example, some respondents were broadly favourable of the flying of the Union flag but went on to object to the proposed policy on the grounds that it makes provision for designated days only (the proposed policy makes provision for flying the Union flag 365-days a year on listed Council buildings).


General attitude to flying the Union flag

Respondents were asked to indicate how they feel in general about the flying of the Union flag on Council buildings using a scale of 1 to 10 where 1 meant “very uncomfortable” and 10 meant “very comfortable”.

The average rating was 6.2 out of 10.

Attitude Number Percentage

1 (very uncomfortable) 195 34.7%

2 13 2.3%

3 12 2.1%

4 7 1.2%

5 12 2.1%

6 1 0.2%

7 4 0.7%

8 3 0.5%

9 11 2.0%

10 (very comfortable) 304 54.1%

Taking the average response by religious category, people from Protestant and other faith or non-Christian backgrounds feel most comfortable with the flying of the Union Flag. People from a Roman Catholic community background or no religion feel least comfortable on average.

Community background Number Average rating
of responses

Roman Catholic 135 2.7

Protestant 251 9.0

Other Christian 32 6.7
(Including Christian related)

Other Faith or non-Christian 3 10
community background

No religion 79 4.2

Prefer not to say 46 4.8

Respondents were also offered the opportunity to explain why they felt that way. Four hundred and eight-four responses were received. The sentiment of each comment was analysed and coded as follows.

Sentiment Number Percentage

Positive expression 258 65.0%
of nationality/culture

Sectarian/divisive 99 12.0%

Not representative 57 8.1%
of nationality/culture

Prefer no flags/neutral space 59 10.9%

No opinion 3 0.8%

Other 38 3.1%

Comments in favour of flying the Union flag included:

  • “Council buildings are government buildings and therefore should fly the Union Flag 365 days a year.”
  • “Across europe its common for national flag to be flown on goverment buildings.”
  • “Because I have grown up with the union flag flying, it doesn't cause me any offence in the slightest, it is the flag of our country. The same way when I holiday in the Republic of Ireland the flag of their country doesn't cause me any offence or scare me”
  • “Because it is the national flag of the UK, of which NI are central”
  • “We are part of the UK it is our National Flag. We should be proud to fly it.”
  • “It is the flag of our country”
  • “Because it is the flag of our nation, which local people fought and died for and still do, it’s a bit of respect”
  • “Remember those who fought for our country”

Comments not in favour of flying the Union flag included:

  • “It recognises one identity only and effectively marks territory. In that sense it is intimidatory and exclusionary. I would feel unwelcome and less likely to access council services.”
  • “The Union Flag has been politised by loyalists and is used to mark territory abd goad nationalists and then it is left to deteriorate to rags.”
  • “British and Irish flags are divisive”
  • “Flags in NI are political statements. Council and civic buildings should be seen as politically neutral.”
  • “Cause it doesn’t represent the mixed cultures of NI”
  • “Doesn't show equality to all residents”
  • “I would feel intimidated and unwelcome to shop in the local area”
  • “An entertainment venue should be inclusive and welcoming”

Frequency of flying the Union flag on Council buildings

Half of respondents (51.2 per cent) felt the flag should fly 365-days a year. Nearly a third (30.1 per cent) felt it should never fly.

Frequency Number Percentage

Always (365 days) 288 51.2%

On working days 15 2.7%
(260 days) and designated
flag days (15 days)

On specific designated 65 11.6%
days (15 days)

It should depend on 25 4.4%
the location

No never 169 30.1%

People from Protestant and other non-Christian faiths were most likely to agree that the Union Flag should be flown 365-days a year. People from a Roman Catholic community background and no religion were most likely to agree that it should never be flown.

Frequency Roman Catholic Protestant Other Christian Other Faith or No religion Prefer
(Including non-Christian not to say
Christian community
related) background

No. % No. % No. % No. % No. % No. %

Always (365 days) 14 10.4% 209 83.3% 17 53.1% 3 100.0% 22 27.8% 9 50.0%

On working days
(260 days) and 0 0.0% 10 4.0% 1 3.1% 0 0.0% 2 2.5% 2 11.1%
designated flag
days (15 days)

On specific designated
days (15 days) 33 24.4% 11 4.4% 4 12.5% 0 0.0% 9 11.4% 1 5.6%

It should depend on
the location 9 6.7% 2 0.8% 3 9.4% 0 0.0% 6 7.6% 1 5.6%

No never 79 58.5% 19 7.6% 7 21.9% 0 0.0% 40 50.6% 5 27.8%

Current policy on flying the Union flag

Respondents were asked to consider how much they agreed with the current policy on flying the Union flag.

Agree with current policy Number Percentage

Strongly agree 83 14.8%

Agree 59 10.5%

Neutral 70 12.5%

Disagree 133 23.7%

Strongly disagree 214 38.1%

No response 3 0.5%

25.3 per cent agree or strongly agree with the current policy, and 61.7 per cent disagree or strongly disagree with it.

Those who disagreed included respondents who felt that there should be a consistent approach to flying the flag 365 days a year across all Council buildings and those who felt there should be a consistent no-flags policy across all Council buildings.[8] [8] n=396

68.1 per cent also agreed that the current policy should be changed, while 28.6 disagreed.

Should the current Number Percentage
policy be changed?

Yes 383 68.1%

No 161 28.6%

No response 18 3.2%

82.4 per cent of people from a Roman Catholic background agree that the current policy should be changed compared with 63.8 per cent of people from a Protestant community background.

Community Current policy Current policy
​background should be changed should not be changed

Number % Number %

Roman Catholic 108 82.4% 23 17.6%

Protestant 155 63.8% 88 36.2%

Other Christian
(Including Christian 22 71.0% 9 29.0%
related)

Other Faith or
non-Christian 1 33.3% 2 66.7%
community
background

No religion 54 72.0% 21 28.0%

Prefer not to
say/no response 43 71.8% 18 28.2%

Proposed policy on flying the Union flag

Respondents were asked to consider how much they agree with the proposed policy on flying the Union flag. 43.6 per cent agreed or strongly agreed and 47.3 per cent disagreed or strongly disagreed.

Number Percentage

Strongly agree 207 36.8%

Agree 38 6.8%

Neutral 43 7.7%

Disagree 50 8.9%

Strongly disagree 216 38.4%

No response 8 1.4%

People from Protestant and other faith community backgrounds were most likely to agree with the proposed policy, and people from a Roman Catholic background and no religion were most likely to disagree.

Roman Catholic Protestant Other Christian Other faith No religion Prefer not to say
/no response

No. % No. % No. % No. % No. % No. %

Agree/strongly agree 12 9.2% 175 70.3% 13 41.9% 3 100% 20 25.6% 22 35.5%

Neutral 8 6.1% 17 6.8% 4 12.9% 0 0.0% 8 10.3% 6 9.7%

Disagree/strongly
disagree 111 84.7% 57 22.9% 14 45.2% 0 0.0% 50 64.1% 34 54.8%

Respondents were also asked to comment on the proposed policy on the flying of the Union flag. While the majority of respondents[9] used the opportunity to reinforce previously stated support or opposition to the flying of the Union flag, a number of respondents proposed alternative measures including:

  • “Only needs to be flown for Head of State’s official birthday”
  • “if Union flag is flown, then Irish flag should be flown alongside”
  • “We need our own flag and only our flag to fly. We don't require an English flag. Scotland and Wales don't fly the English flag. We are just being lazy.”
  • “To include ‘all’ Council properties”
  • “To fly in all depots yards and building.”
  • “This policy if adopted needs to be revisited to include Ballycastle to comply with published guidance.”
  • “All 4 civic buildings should be included. Town Halls could fly it on special days to mark them as special”

[9] n=354

Preferred arrangement by location

Respondents were then asked to consider each of the Council buildings named in the proposed policy and indicate how many days they would prefer the Union flag to fly, if any.

Preferred option Coleraine Portrush Ballymoney Roe Valley Cloonavin, Riada House, Limavady
​ Town Hall Town Hall Town Hall Arts Centre Coleraine Ballymoney Council Office

No. % No. % No. % No. % No. % No. % No. %

365 days 285 50.7% 285 50.7% 285 50.7% 284 50.5% 285 50.7% 284 50.5% 283 50.4%

No flag 184 32.7% 184 32.7% 184 32.7% 184 32.7% 184 32.7% 184 32.7% 183 32.6%

Designated
days 70 12.5% 70 12.5% 69 12.3% 70 12.5% 69 12.3% 70 12.5% 67 11.9%
(circa 15 days)

Working days
(260) & 16 2.8% 16 2.8% 15 2.7% 16 2.8% 16 2.8% 16 2.8% 16 2.8%
designated days*

No response 7 1.2% 7 1.2% 8 1.4% 8 1.4% 7 1.2% 7 1.2% 13 2.3%

On average across all buildings, 50.6 per cent preferred flying the flag 365-days a year. 32.7 per cent preferred no flag days. Variances between locations are not statistically significant.

Responses in relation to the draft EQIA

23.8 per cent of respondents agreed with the assessment of impacts in the EQIA, and 18.7 per cent disagreed

Agreement with EQIA Number Percentage

Strongly agree 66 11.7%

Agree 68 12.1%

Neutral 264 47.0%

Disagree 36 6.4%

Strongly disagree 69 12.3%

No response 59 10.5%

Among comments received asking respondents to explain why they disagree with the assessment of impacts;[10] identify any other issues that should be included in the EQIA;[11] and any further relevant data or research;[12] the majority of respondents took the opportunity to restate their previous policy position. Other comments included:

  • “To say that the flying of the Union Flag on Council buildings could create a ‘chill factor’ is outrageous! […] May all Councils be reminded to not cause hurt towards the majority of people in Northern Ireland. Remember the removal of the flag from Belfast City Hall in 2012? It caused deep hurt for the majority of people in Northern Ireland.”
  • “Disproportionate weight and consideration has been given to the ‘Chill Factor’ element, especially when compared to statistical data. And there is little/none weight given or indeed statistical data provided for the discomfort felt when the Union Flag is NOT flown.”
  • “They're more concerned about offending those who don't want the Union Flag flown, they have ignored the discomfort felt by those of us who want the Union Flag flown.”
  • “The union flag currently flies at the council offices in Coleraine and it has not prevented either elected representatives or the public from entering the building. Likewise no council employee has indicated that they were not willing to come to work because it was flying. I therefore do not believe it will be a bar to people entering and doing business within council premises.”
  • “the impact assessment sets out the worst state scenario and assumes that all people who are of a certain religion will be impacted by the flying of the countries flag on council buildings will be adversly affected. Many within Northern Ireland now see themselves as Northern Irish and British and are in favour of maintaing the Union for various reasons. Pride in where they were born, economic ties , benefits of belonging to a strong economic partner, the NHS etc. I do not believe that the flying of the countries flag will deter anyone from entering the above mentoned buildings as it has not done so in the past where the flag has been flown, in Coleraine or Ballymoney.”
  • “Why has the policy discriminated against Council Admin Centre - (Ballycastle Council Offices). So the policy is discriminatory and fail Section 75. “
  • “Unrealistic and biased towards pro union members of the community“
  • “The adverse impact on staff and sections of inhabitants of the council area may be understated. 41% of staff stated that they feel offended by the flying of this flag at their place of work. The Council must robustly affirm as a corporate entity its commitment to creating a neutral work environment for staff and for members of the public who, as stated, may as a result not fully participate or benefit from council services as a dirct result of flying this flag.”
  • “Other options apart from just one flag or no flag should have been given, both flags should have been an option as well as an alternative for example a council flag.”
  • “A civic flag would have been a good option”
  • “Give the Irish community some sort of recognition, it's not much to ask“
  • “Irish Language research which states it is not political but the language of Ireland. Is there some linkage as the flag represents Northern Ireland too.”
  • “The non-flying of any other flags within the council administered area. Paramilitary emblems and flags should be disallowed in public spaces.“
  • “Flags flying in towns, for example Irish flags flying in ballycastle should be removed, along with any other flags”
  • “We must try and maintain as neutral an environment as is possible. Consider these locations as proposed for the flying of the tricolour and this will facilitate an understanding of how this flag is perceived by those who have no allegiance to it.”
  • “You should consider the ethnic minorities represented in the borough and consider flying the flags they represent, and also consider the impact on flying the British flag for them, e.g for Caribbean's the British flag is a mark of the commonwealth and often offensive as it represents slavery and how Britain took many Africans from their homeland and made them slaves in the Caribbean.”
  • “Reasons people oppose the flying of the flag, for clarity”
  • “Overall, Scoffield QC found that ‘The striking of such a balance’ as is set down for central government buildings in the Flags Regulations ‘seems to me to be a laudable aim’. Furthermore, it ‘is likely to be legally “safer” than the present policy and very unlikely to give rise to a successful discrimination and less at risk of a successful legal challenge’.”
  • “I am extremely uncomfortable with the religious / sectarian nature of the report. I think religions such as Protestant and Catholic should be removed and replaced by political / cultural identity i.e. National, Unionist, Republican, Loyalist, Neutral. So few people these days are actually religious. But plenty of people have strong beliefs on cultural identity and the use of tribal flags.”

A number of respondents stated that they had not seen or been able to find the EQIA. One respondent felt that the survey was poorly advertised and the survey questions and form were confusing.

[10] n=86
[11] n=116
[12] n=67

Responses from Causeway Coast and Glens Borough Council Staff

There were 177 responses from staff during the public consultation on the draft EQIA.[13] Of these, 169 were submitted on behalf of individuals and 3 on behalf of organisations (the remainder did not provide a response to the question).

[13] Unless otherwise stated, n=177

Demographic breakdown of responses
Geographic spread

Respondents were asked to provide the first four digits of their postcode. The map and table below show the geographic spread of respondents.

Postcode Number Percentage

BT35 1 0.6%

BT44 7 4.0%

BT47 7 4.0%

BT49 24 13.6%

BT51 25 14.1%

BT52 16 9.0%

BT53 27 15.3%

BT54 8 4.5%

BT55 8 4.5%

BT56 10 5.6%

BT57 5 2.8%

No response 39 22.0%

Community background

The following chart and table provide a breakdown by community background.

Religion Number Percentage

Roman Catholic 57 32.2%

Protestant 63 35.6%

Other Christian
(Including Christian 3 1.7%
related)

Other Faith or
non-Christian 2 1.1%
community background

No religion 25 14.1%

Prefer not to
say/nil response 27 15.3%

National identity

35.6 per cent of respondents identified as British; 28.2 per cent as Irish; and 27.1 per cent as Northern Irish.

National identity Number Percentage

British 63 35.6%

Irish 50 28.2%

Northern Irish 48 27.1%

Scottish 2 1.1%

Other 4 2.3%

No response 10 5.6%