I did the consultation last night. I'm not sure how much time everyone had to read the Impact Assessments or whether you made a comment about them. I was losing the will to live by the time I waded through to that point so perhaps others were too.
I commented that the one on children was inadequate as it did not consider the effect on other children affected by a transgender child in their class, dorm room, sports, etc.
The Equalities Impact Assessment was shocking. It only considered the impact on trans identified people but also said:
Some women’s groups may have concerns that simplifying the process for obtaining legal gender recognition, and recognising non-binary people, could have a negative impact on equality for women, on work to improve the representation of women in public life and on the safety of women.
However, the Scottish Government remains committed to action in areas such as:
■ tackling the pay gap between men and women;
■ tackling gender based violence and violence against women;
■ encouraging girls and women into certain professions such as engineering and technology;
■ increasing the representation of women on boards and in public life more generally.
Given the commitment to this continued action, we have ticked the “none” box.
My response was:
This is a breathtaking failure to assess the impact of the proposed legislation on the ability of the Scottish Government to take any action to achieve these goals and an out of hand rejection of the legitimate concerns raised by women's groups without any consideration of the issues raised. To be an effective impact assessment, the report would need to consider whether the changes would have the negative impacts raised by women's groups and whether there are steps the Scottish Government can take to address those impacts. As a result, there has been no assessment of the impact of the legislation in these areas.
If you have completed the consultation but not answered the question on the Impact Assessments, please do go back and make some comment. They are totally inadequate and this needs to be pointed out. As I said, I was out of steam by that point so if anyone else has a suggestion for another point on the impact assessments, please add.