Written submission from Mr Alan Morey (DBE0133)

I have over 27 years’ experience of working in the highway design and transport planning industry, with a special interest in accessibility with regards to transport.

I am a Fellow of the Institute of Highway Engineers, Member of the Chartered Institute of Logistics and Transport (where I am a member of their access and inclusion forum), Member of the Chartered Institute of Highways and Transportation, and Member of the Access Association.

I have also undertaken research into transport accessibility as part of my studies at the ‘Transport Research Group’ at the University of Southampton.

I am disabled myself and am currently chair of Gosport Access Group and Disability Forum. A separate submission has been made on behalf of GAGDF, using feedback from group members – this response is separate from GAGDF’s response.

I have responded to each of the points in turn.

Government policy on and current provision of accessible properties (including homes and commercial premises)

• How adequate is the supply of accessible properties (including homes and commercial premises)?
  Generally I specialise in highways and transport matters rather than buildings.
  However, physical access into / within buildings is only one part of the story – many premises are remote or not able to be accessed easily from local amenities, transport links, even including sheds, bins, etc.
• To what extent is the Government taking current and future needs for accessible homes into account in its policies on increasing housing supply?
• How effective are the planning and building regulations systems in ensuring the provision of new accessible / lifetime homes?
• What can be done to increase the accessibility of existing housing stock to support independent living?
• Could financial or other mechanisms be used to encourage developers to go beyond minimum standards of accessibility?
  We need to ‘normalise’ building for accessibility, not make it an extra hurdle or ‘add-on’ to current regulations.

The effectiveness of UK legislation, policies and standards on accessibility in the built environment

• How well do Part M of the Building Regulations and Approved Document M perform in providing reasonable levels of accessibility in the built environment and what could be done to improve performance?
  Part M is fine for buildings themselves. However, it does not cover open areas and places which are neither residential nor commercial ‘buildings’ and do not have the same level of building control scrutiny placed upon them.
• Is there sufficient compliance with building regulations and requests for reasonable adjustment? If not, what more could be done to increase compliance?
  The attitude / knowledge of front-line staff in customer-facing roles varies greatly and has a great impact on accessibility for customers. High staff turnover in the retail and council contractor sectors and poor levels of staff training exacerbate this.
  The Equality Act 2010 does not make it easy for customers to make formal complaints on grounds of accessibility, with the result that the vast majority are put off from doing so.
• Do current standards regarding accessibility in the built environment take account of the full range of disability and impairment needs? (For example, are the needs of people with dementia, the visually impaired, those with mental health issues and older people given sufficient consideration? If not, what more could be done to increase inclusivity?)
  Part M (and BS 8300) are technical specification standards / guidance that are, easily understood by engineers and architects. They are mainly concerned with physical accessibility and occasionally sensory issues.
  In addition, they are rightly focused on designing for people in wheelchairs, are totally blind or have other severe physical issues, even though these people account for only a relatively small proportion of disabled people.
  Such ‘physical’ design standards have limited benefit for those who have more ‘moderate’ disabilities, or have a combination of multiple disabilities (as often happens with the elderly), or have more ‘hidden’ disabilities (such as mental health problems, cognitive issues, dementia, even deafness).
  I could argue that by focusing on large-ticket physical accessibility we have stopped people from paying attention to other, more common issues.
• What is the role of reasonable adjustments in delivering accessibility?
  These are possibly more important than technical specifications, for the reasons such as people suffering from moderate, multiple, hidden or non-physical impairments trying to get by.
  They are particularly pertinent when dealing with front-line staff in shops, etc, or when dealing with older, unconverted buildings.
  I also reiterate my point about the Equality Act 2010 being ineffective.

Design and management of the public realm

• Are the needs of all groups given adequate consideration in the design of streets, highways, parks and publicly accessible open spaces and in the provision of services such as public toilets?
  I chair a local access group. We often have engineers and architects come and tell us about what they are going to do on new projects, but they do not actually ask for (nor take account of) our views.
  Standards vary: Many places that are open to the public are not actually publicly-owned or maintained. This often means that they do not necessarily share the same standards of design, accessibility, maintenance, facilities provision or enforcement of operational regulations. Such spaces can include parks, shopping centres, private streets (e.g. MoD areas, development areas such as London Docklands, Gunwharf Quays in Portsmouth), Hospital exterior environments, supermarket car parks, transport hubs.
  Because much development takes place on individual sites and is often undertaken by private developers, there is a disconnect / lack of coherent strategy, which can affect overall accessibility.
  As a designer, many of the complaints I receive are the result of the unintended consequences of multiple development schemes not being planned or implemented correctly – leading to inaccessible areas in between.
  Maintenance and management is also a big issue, especially the condition of footway surfaces, crossings and toilets (many ‘accessible toilets’ and disabled parking bays are used for storage, etc.)
  A good example of an inconsistent approach is in the use of tactile paving. Although meant as a tactile language for the visually-impaired, we often find the incorrect type installed, or installed incorrectly. Landscape architects will often vary the styles used in order to fit in with their ‘pet scheme’, citing that the tactile paving guidance is “only guidance”.
  Highway engineers will avoid putting in what is appropriate (in accessibility terms) if it conflicts with another feature which is too expensive / difficult to move.
  It is clear that many engineers, planners and architects do not understand how their decisions affect the different users – and are often unaware how common certain disabilities are.
  Another example would be the provision of disabled parking in a supermarket car park. Some people will have their own ‘personal mobility device (wheelchair, scooter, etc.) and will need extra space around the parking bay – but do not need to be near to the entrance of the shop, whereas the ambulant disabled will not need that extra space but do need to be close to the entrance. Many designers and providers do not understand the difference or the ramifications amongst the different user groups.
  There are many aspects of the public realm where multiple agencies are involved. For example, bus stops, parking provision and enforcement, etc, dealing with obstructions. These are the problems faced by people every day, yet nobody seems to want to take ownership or responsibility.
  ‘Manual for Streets’ tried to give flexibility to designers. MfS2 goes even further, but is not mandatory. However, neither document prioritises accessibility.
• To what extent do shared space schemes in roads and highways cause barriers for disabled people and how can these be resolved?
  Many visually-impaired people are so frightened by the concept of shared space that they will often try to avoid the area – or will only use it if they have sighted accompaniment. Attempts by landscape architects to ameliorate this often lead to inconsistent, incoherent or unreadable environments.
  In theory, those with more physical disabilities should find shared space easier to use, but in practice the shared areas often fill up with obstacles which make the areas less accessible.
  In fact, both ‘official’ and unofficial’ obstacles in the street are common and are amongst the biggest problems faced by disabled users.
  Inconsistent motifs implemented by landscape architects can confuse the issue and make the street incoherent to those with cognitive impairments.
• What opportunities are there for delivering greater accessibility and inclusivity alongside more age-friendly towns and cities, including liaison with the NHS?
  Improved accessibility can reduce dependence / increase or prolong independence for individuals – thus reducing the burden on the NHS and Adult Social Services.
  In theory, the best opportunities arise when new developments are planned. But these ‘opportunities’ are often ‘lost’ (for reasons discussed elsewhere in this document).
  Building in inclusivity and accessibility from the start is cheaper than attempting to retrofit accessibility.
  User-training can also be useful (e.g. the work of the Brandon Trust in Bristol), but is most closely associated with public transport (not in the remit of this inquiry).

The role of designers, architects and built environment specialists in ensuring accessibility and inclusivity

• To what extent is the need for accessibility taken into account in the design of buildings and public spaces? What can the professionals who are responsible for the creation, maintenance and retrofitting of our built environment do to ensure that buildings and public spaces are as accessible and inclusive as possible?
  Accessibility is often considered an issue for detailed design, not strategic planning. However, many of the problems encountered could have been pre-empted at the planning stage (e.g. sufficient land made available for ramps, etc.)
  We professionals need to understand who they are designing for and why. We know that they have to do it, but often do not have the tools to do so. Guidance (such as ‘Inclusive Mobility’) are quite old and is only guidance.
  By way of contrast, the access group I chair often takes part in consultations and advisory panels for heritage projects, such as museum refurbishments and exhibitions. This is because accessibility is locked in as a condition of Heritage Lottery Funding (which is often the source of grants etc.). Because of this, there are more examples of good access in the museum / heritage sector than elsewhere in the ‘public realm’ and public buildings.
  There is no such mandatory condition re: accessibility for either public funding or planning consent on transport and development projects.
  Therefore I would recommend better liaison between representatives of disability groups and the people doing the planning, design and funding of these projects.
  It is possible that design professionals look at an area and decide that it will never be fully accessible and therefore do not make any attempt to improve the situation. However, sometimes it must be accepted that a scheme may never meet Part M standards (or equivalent), but could easily have some ‘quick wins’ that would benefit a significant number of users.
• How well is inclusive design built into training for built environment specialists such as planners, designers, architects and building inspectors? Is there sufficient continuing professional development on inclusive design for such specialists? What tools and techniques are needed to infuse inclusive design into education and training programmes?
  Accessibility is now built into many undergraduate and postgraduate courses. However, the quality varies from college to college.
  For example, UCL / Imperial College have an excellent accessibility programme for their students.
  A more serious hurdle is in educating those who are already in their professional career.
  The professional institutions have a role to play in educating older and more experienced engineers and architects in accessibility – perhaps in a similar fashion to that in which knowledge about environmental issues has been spread over the past decade or so.
  An even bigger obstacle is in imparting the importance of accessibility to those making the strategic decisions (elected members, project managers, etc.)
  Perhaps the professionals and strategists may not need to know the detailed ‘ins and outs’ themselves, but they should be aware that these issues exist and that they should have the sense to employ specialists and to allocate time and resources for access.
  I have mentioned ‘Design Reference Groups’ already (in the context of heritage projects). It is not a ‘given’ that these will automatically work – so there needs to be education in how to consult and how to work effectively with advisory panels in order to get something useful out of them.
  Professional social media platforms such as LinkedIn are also good for sharing information and best practice amongst peers and professionals.
• How can changes to the way we create and adapt our built environment, such as building information modelling and modern methods of construction, contribute to making environments more accessible and inclusive?
  BIM is a useful tool. But it is only a tool; the real challenge is in educating those who plan, design, run, manage and maintain our environments in how to use those tools effectively.
  There are plenty of examples of good design practice, but the issue is sharing the information (including useful data) amongst those who need to know about it.
  There are examples of technology having a positive impact: some of the modern lighting systems available can make a big difference to accessibility and well-being (especially for those with sensory or cognitive impairments) – even though it is not often advertised as such.

Local involvement in decision-making

• How effectively are communities able to engage with the process of decision making that shapes the accessibility of the built environment? Are there any barriers to effective public engagement and if so, how might these be addressed?
  There is also an assumption at the outline planning stage that ‘accessibility is a detailed design issue, sufficiently covered by the various regulations and standards (such as Part M) so as to not need consideration at strategic stage of development’. This is incorrect.
  Design Reference Groups (such as the one which advises Transport for Greater Manchester) can work, if run and managed properly. The biggest difficulty is in putting such a group together and getting the right people to work effectively together.
• Could local authorities do more through licensing, planning and/or enforcement to increase the accessibility of the built environment?
  The design and planning of parking provision often has a knock on effect on accessibility. Parking on pavements, in bus stops and across pedestrian crossing points are major obstacles for disabled people..
  Parking policies need to be reasonable and, most importantly realistically enforceable, as do policies on ‘A’ boards, street furniture, vegetation clearance and cleansing.
  Local highway authorities need to undertake better scrutiny of infrastructure built by developers before adopting these into the public highway.
  More objective scrutiny of verge crossings and dropped kerbs needs to take place in the context of where and how they will be used, especially with regards to gradients, etc.
  
  Although public transport is not part of the remit of this inquiry, the accessibility of transport is often dictated by the built environment in which it operates. For instance, the siting and construction of bus stops on the footway, the approaches to railway stations, pick-up and drop-off points for taxis (both hackney cab and minicab) and parking provision (and parking regulations enforcement). These matters also have a bearing at strategic planning level.

October 2016