Here are some thoughts for consideration,

                                                           A Planning Stage DAS merely describes how the development (site) is accessed by pedestrians, motorists and cyclists etc and takes no account (or very little account) of the accessibility of the inside of the buildings which is covered by Building Control; primarily under Part M – Access & Use.

What is lacking at planning stage is a distinct requirement that a development MUST be fully accessible and adhere to the principles of inclusive design and that developers MUST properly address inclusive access at an early stage and that this WILL be robustly enforced at building regulations stage.

Problem is that most building control bodies do not fully understand Part M and make their own interpretation of the requirements, often to the detriment of inclusive access. I can give examples...

Also designers still consider access as an optional extra, an add-on, and therefore fail to address the issues at the design stage. This often leads to compromises being made at building regulations stage, making access to the development less than it should be and often less than adequate.

It is vital if DASs are to be removed from the legislation that at least an Access Statement of some sort (without the design element) is required to commit developers and designers to full compliance with the relevant parts of the building regulations, building bulletins (in schools) and other design requirements & standards to ensure equality of opportunity for disabled people, older people and children.

It is vital that building control bodies and approved inspectors follow Part M to the letter.

It is vital that Part M in Wales is reviewed to remove anomalies and misleading or out of date requirements and recommendations and add any new improvements or developments.

It is vital that building control bodies and approved inspectors are told by Welsh Government that Part M is not an optional extra, that “reasonable” in this context means reasonable access for disabled and older people and children and NOT reasonable for the developer.

                            Yours sincerely,

                                          Henry Langen.

                        (Chair Pembrokeshire Access Group) 

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