Written submission from the Hull Access Improvement Group (DBE0173)

The Hull Access Improvement Group (HAIG) is a group formed in 1981 to campaign in an honest, reasonable and intelligent manner to ensure that the built environment is an inclusive environment, accessible to everyone no matter what physical or mental challenges their lives have brought them. We liaise with Hull City Council's Access Officer with whom we meet on a monthly basis and usually make advisory comments on planning applications or proposed major works. Our membership is mainly composed of experts by experience with one or two with relevant professional qualifications. We are independent and self-funded. We are mindful of the full spectrum of disability and do not focus on a particular condition to the detriment of others.

Definitions

Built environment

We will, of course, abide by the Committee's ruling to omit public transport from our evidence regarding the built environment. This is in the quiet confidence that the Committee is fully aware of how important an adequate transport system is and how it forms an integral part of a successful accessible built environment.

Accessible/accessibility

We also use the social model of disability.

Submissions

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

1. The current supply of accessible homes is inadequate. A short time spent on a property search in any area proves this point. As does the amount of public and private monies spent on adapting properties.

2. The supply of accessible commercial premises is also inadequate and accessible premises can be rendered inadequate by lack of understanding by the building’s managers, it is amazingly common to find what should be an accessible WC used as a store room, my favourite was a 7 foot tall potted palm in the wheelchair transfer space! And retail spaces whose goods are stacked in front of shelving, making a wheelchair accessible shop suitable for the slim and agile only.

3. The Government may well be taking current and future needs for accessible homes into account but the changes to the manner of administering planning and in particular building regulation may sabotage any good intention for future housing supply. Also the existence of M4(1) as a housing standard does not auger well for the future of housing in general, and provides a massive loophole in building regulations.

4. It would be sensible if the minimum standard for housing was M4(2), there are of course reasons, mainly topographical, where this is impossible, but surely a dwelling that can be altered to the changing needs of its occupants with the minimum of cost and disturbance is a more practical option than what is the norm at present.

5. We feel it would not be possible for us to provide a “One size fits all.” solution to increasing the accessibility of existing housing stock en mass; however, it does give weight to the case for including accessibility in minimum standards and thereby reducing if not eliminating many problems in the future.

6. Our opinion is that a simpler method to ‘encourage’ developers to go beyond minimum standards of accessibility is to set a desirable standard of accessibility as the minimum. What possible reason can there be for not achieving more than the bare minimum standard in new build properties?

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

Planning applications

1. As a group we have looked at planning applications for over 30 years. We have, it must be stressed, seen a lot of improvements over the years. Applicants are now well aware that they do need to provide access and facilities for disabled people.

2. The quality of the provisions for access and facilities vary depending on the skills and priorities of the architect, the commitment of the developer and money available.

3. When it comes to access; the success, or not, of the provision, is in the detail, not simply that a ramp is indicated at the front of building, but that they can actually fit it when they come to construct it. Not all authorities spend the necessary time making sure that a proposal will work.

4. Our experiences have taught us that these important details should not be left for later, as they sometimes are, even through to building regulations, where they are beyond review. The planning system is, rightly, open to public consultation and should include details related to access even those which are later checked by building inspectors.

5. Ramps are part of an elevation, as are doors, what they look like, their width and height within an elevation should all be part of the detail that planners agree before approval, however, on site things change, a ramp may or may not materialise because of unexpected ground conditions etc. And the front door which looks as it did on the plan - opens from the opposite side so there is not the 300 mm return that makes it possible for a wheelchair user to open a door for themselves. Details. Details that change accessible into inaccessible.

6. Planning approvals and conditions could be dealt with in one of two ways, either:

7. Agree the details of access and facilities for disabled people before a planning application is granted

or

8. Grant a planning application with conditions related to providing suitable mechanisms of access and facilities for disabled people.

9. Both have their positive and negative points, as an access group of volunteers we can only meet once a month, so it is important that if our comments are to be used in planning conditions that there is sufficient time for the architect to amend plans and the planners meet an arbitrarily timed decision target. This is not always possible which makes the second option preferable.

10.          We also suspect that many applicants do not give access sufficient early consideration because they know that if they do not provide the details then a condition will be put in an approval. This situation has not been helped by the reduction in the requirement of access statements

11.          The access statements were rarely taken seriously by some authorities and even less by architects. An access statement should have been a full statement of how the building or public space should work for people with any kind of impairment. Instead the planning statement contained little or no information and was not helpful because it was not required to relate to the inside of the building

12.          We have found that some planners have a better understanding of access, inclusion and equality than others. It is still disappointing that many do not appear to care or to have been educated about equality during their planning degree. We have seen new developments in neighbouring authorities where clearly no one has had any idea about the practicalities and dignity of accessibility.

Building Regulations

13.          The inside of the building, is of course, as important as the outside, if not more so for people with disabilities. And yet the public cannot see building regulation applications, cannot make comment on the facilities or accessibility of the proposals. There is no way of challenging a Building Control decision at any stage. This is wrong. This is irrational and does not lead to good access and facilities.

14.          A Building Control authority’s decisions have a tremendous impact on the lives of disabled people. Our Government is trying to get disabled people into employment but the number of accessible workspaces is limited. ADM does not have a size requirement prior to the provision of mechanical vertical circulation. This leads to buildings without accessible first floors, reducing employment prospects or availability of social venues.

15.          Hull has virtually no accessible city centre restaurants because the majority are on the first floor of mixed use buildings. This is a fault of the present system; because planning have no legal reason to refuse a restaurant but also Building Control for not insisting on mechanical vertical access as a standard requisite. Building Control authorities, both LA and private, have set arbitrary limits, based on the internal use as shown on a plan without thought that anyone with a disability is a potential user of that building. Developers always justify the non-provision due to cost, their penny pinching costs disabled people opportunities of gainful employment and causes social isolation which is a major factor in mental ill health.

16.          Part M is advisory only and many authorities will negotiate provision, why some areas are less accessible than they could be. Hull City Council has a specialist Access Officer, so our area fares better than many. Overall the competition in the housing market has not helped accessibility as some developers are willing to go around inspectors until they get one to approve their proposals. Some major companies even have their own building regulation inspectors, adding concerns of partiality to an already opaque system.

Design and management in the public realm

1. How well, or if at all the needs of any group of disadvantaged people are met is heavily dependent on their Local Authority, how dependent that authority is on Central Government for funding, and the combination of personal attitudes, intelligence, and compassion of the elected members and officers that administer that particular Local Authority. And of course the funds available and how wisely those funds are administered.

2. When an authority is in receipt of Central Government funding, it has to consider everyone’s needs and consultations take place, and sometimes needs are noted, and sometimes they are not. Which brings us to Shared Space.

3. The only people I have ever met who think Shared Space is a good idea are the people peddling the idea. Sadly with some success. I will merely add a list of the groups of people who will have difficulty using a Shared Space safely. This is the usual recommendation for pedestrians: “Make eye contact with the car driver so they stop. Then it will be safe to cross to the other side.”

4. People with any degree of sight loss,

Guide dogs,

Wheelchair users,

Users of mobility scooters,

People of short stature,

Children,

People accompanying small children,

People with dementia,

People with mobile phones,

People under the influence of alcohol,

People under the influence of illegal substances,

5. Shared Space is indicative of the “Fashion Trends” which afflict the granting of large sums of money for public realm projects, iconic statutes of CorTen Steel are very popular, the latest trend appears to be for pavement fountains. These do not produce public open space that is accessible, or pleasant to be in, they must be terrifying for those who have only long term memory left. After all, water shooting out of the pavement used to mean a burst water main. Well designed, accessible toilets are regrettably not “Bang on trend.” nor are old fashioned shopping streets like that ‘dementia village’ in the Netherlands.

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

1. The role of designers, architects, and built environment specialists is key to ensuring the accessibility and inclusiveness of the built environment, as are planners, building inspectors and planning committees. Given the patchiness of excellence it seems apparent that training is required throughout the industry and engaging fully qualified access consultants maybe an excellent interim measure or continuing solution.

Local involvement in decision-making.

1. The Hull Access Improvement Group (HAIG) read and comment on planning applications as a major part of their involvement in improving access for disabled people, for many years the plans in applications were accessible. They were printed at an acceptable scale for all members of our group, or any member of the public, to see. Unfortunately, in a bid to save money, councils provide only A4 plans, or on line; neither are suitable, or big enough to see, or get an overall picture of a development. In fact we believe that it must have an effect on the planner’s ability to properly assess details of plans and make sufficiently informed decisions.

2. They do not think it is a reasonable adjustment to make them larger.

In addition people now have to make appointments to see applications. This does not have an effect on us but it will have an effect on the involvement of any other disabled people. The person is unlikely to see the planning officer dealing with the application, a loss to both parties and detrimental to encouraging public involvement.

3. Our local authority has an Access Officer who gives guidance to planners and building inspectors, he also liaises with organisations and groups of disabled people to ensure they have as much input as possible into local decision making.

4. Also our city has a Street Charter, in fact the first in the country, an initiative of the RNIB, a form of contract between the City Council and its residents to enable rapid response to ensure streets are free of clutter and clean, something which makes life pleasant for everyone and removes hazards for the visually impaired. A-boards for instance, are not too much of a nuisance if you can see them and avoid them, but they are painful and confidence sapping, trip hazards if you can’t.

Conclusion

We think that local authorities are more likely to improve the accessibility of the built environment if they all take notice of what is being said to them by disabled people. We are certain the built environment would improve if all developers understood that Building Regulations generally, ADM, and BS 8300 were not in place to deprive them of profit, and we wish that architects would use their talents to design beautiful accessible buildings instead of creating artistic excuses for meanly sized entrances and stepped exits.

October 2016