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Consultations
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SDEF
The Scottish Disability Equality
Forum works for social inclusion in Scotland through the removal of barriers
and the promotion of equal access for people affected by disability.
It is a membership organisation, representing individuals with any type of
impairment, disability organisations and groups who share its values. It
aims to ensure the voices of people affected by disability are heard and
heeded.
SDEF promotes access in its widest sense: access to the built and natural
environment and access to the same opportunities as are enjoyed by other
people in our community.
It takes a broad
definition of access, within which it focuses on access to the environment
and access to information and mechanisms promoting two-way communications.
It campaigns to improve access in these areas and seeks to become a free
source of high quality information on them.
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Planning Bill Consultation Response
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SDEF welcomes the opportunity for disabled people to be consulted on as part of the planning process and has considered the following.
Development Plans
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Consultation Process
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Consultation should take account of the needs of people with different disabilities and activities held as part of the consultation process should take account of support needs, with documentation being made available in different formats eg. large print format, Braille, audio and in plain English, for example. Methods used to consult could include email, e panels, interactive websites, questionnaire, local access groups, one-to-one interviews and voice only consultation via tape or CD. Consultation should not rely on one method of communication but on various processes.
It may be that previous consultation documentation was available in alternative formats but the internet and hard copy via Royal Mail seems to have been the preferred method.� Given the mandatory requirements in the DDA 2005 for Public Bodies this would no longer be good enough as every reasonable action must be taken to consult with as many disabled people as possible reaching out to all thus covering as diverse range of abilities as possible.
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Consideration should be given to local conditions when setting up focus groups and meetings, for example, access to reliable transport to and from the meeting. Additionally, assumptions should not be made about suitable times for meetings as those held later in the day may impact upon a person’s care plan or be unsuitable because they suffer from a condition that induces fatigue.
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The more diverse the method of consultation the more likely it is to involve a more diverse number of people with different viewpoints.
Consultation activities must be advertised through organizations that represent those with disabilities at local and national level. Care should be taken to ensure that details are passed on to local access panels. They should be advertised through the press in the same way as public enquiries and hearings and be posted on the appropriate websites.
Some SDEF members are of the opinion that disabled people should be paid for the advice they give.� However, it is important to consider the value and quality of that advice and �who is providing it. There could be a graded scale of payment costs that would regulate payments to disabled for the advice they give in relation to their experience and/or qualifications.
Access Statements
Access statements should include the following:
��������� How the consultation process has been undertaken.
��������� The number of disabled people consulted and whether they have been consulted as individuals or representatives of organisations
��������� The results of the consultation
��������� Any and all contradictions between what the developer/architect is suggesting that may go against the outcome of the consultation and the reasons for deviating from the results of the consultation.
��������� Access approach
��������� Proximity of Parking and/or vehicular access (if appropriate)
��������� The minimum standard used to comply with the Building Regulations
��������� How best practice is to be met over and above the minimum requirements of the British Standards.
��������� The methodology uses to evaluate the access requirements.
��������� Although the access statement should contain issues that are relevant to building standards and not planning, the access statement must be submitted at both the planning and building warrant stages of submission.
This list in not exhaustive but could form the basis of an access statement. Care must be taken that access statements are not drawn up with good intentions but then disregarded at a later stage. National, local and major developments should all be required to include access statements.
There needs to be an express commitment by the Scottish Executive in the legislation or the guidelines to the legislation on the content and usage of access statements. Whereas access statements are important what must be the overriding commitment is what will actually be carried out to meet not only the minimum British Standards but where ‘Best Practice’ is not only used but is going beyond the minimum requirements of the British Standards.
Current good practice is contained in the British Standards Institute (2001) BS8300: Design of� Buildings and their approaches to meet the needs of disabled people - Code of Practice. BS8300 is a useful reference for anyone considering the needs of disabled people when designing new buildings or altered existing buildings.
BS8300 is not relevant in Scotland as of yet but is only in force in England and Wales.� The relevant British Standard for Scotland is still (unfortunately) the BS5810 which is outdated.
British Standard is very much a minimum requirement and as such is the only standard that most architects are likely to use unless directed to always try and better the minimum.� This is born out over years of inadequate facilities being designed because the relevant British Standards are outdated and only deliver the bare minimum requirements.� Something must be written into The Building Regulations that extend and encourage the use of ‘Best Practice’ and not simply the minimum because it happens to be the relevant BS at that given time.
Pre-application Consultation
The Scottish Executive has the power to specify who and how the pre-application consultation will take place and must use this power to ensure that disabled people are involved in the process. In the past disabled people have had to cope with inadequate and inaccessible facilities that have failed to meet their needs. If this situation is to be overcome then the Scottish Executive should have recourse to legislation.
The issue of who is allowed to design facilities for disabled people could be enshrined within legislation so that consultation with someone who is experienced and/or academically qualified in the field of Inclusive Environmental Access and Design is mandatory. �In 2002 the Declaration of Madrid stated that:
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“The recently adopted EU Charter of Fundamental Rights acknowledges that to achieve equality for disabled people the right not to be discriminated against has to be complemented by the right to benefit from measures designed to ensure their independence, integration and participation in the life of the community. This synthesis approach has been the guiding principle of the Madrid congress that brought together more than 600 participants in March 2002”.
Part of the pre-submission process must be that the applicant can prove that consultation has taken place with organisations that represent disabled people or individual disabled people.
It is not only imperative that consultation with disabled people and specialists occurs at every level during the planning process but further that specialist in the field of Inclusive Environmental Access and Design have a statutory place in any and all Design Teams during the complete process.� Further, that these specialists are involved in the construction and fitting process of the build.
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