Overcoming the Barriers: Providing Physical Access to Historic Buildings
Cadw: Welsh Historic Monuments acting on behalf of the Welsh Assembly Government, carries out the statutory responsibilities vested in the National Assembly for Wales to protect, conserve, and promote an appreciation of the built heritage.
(c) Cadw: Welsh Historic MonumentsCrown Building, Cathays Park, Cardiff CF10 3NQ
Tel 029 2050 0200 Fax 029 2082 6375Cadw@Wales.GSI.Gov.UK http://www.cadw.wales.gov.uk
First published 2002 ISBN 1 85760 104 1
This publication is available in alternative formats. For details please contact Heritage Policy Section, Cadw: Welsh Historic Monuments, at the address above, or telephone 029 2082 5977.
Contents
Foreword 5
Part 2 - Policy and principles 12
Part 3 - Access in practice 15
Case Study: National Library of Wales
Case Study:St Deiniol's Church, Worthenbury, Wrexham
Case Study: Saron Congregational Church, Tredegar
Foreword by the Minister for Environment: Sue Essex AM
Since its inception the Welsh Assembly Government has acted positively to promote equality of opportunity. This continues to be one of three major themes, which apply across all our objectives and through which we seek to promote a strong culture in which diversity and equality are valued. In Plan for Wales 2001 we have set out what we have achieved and what we intend to do. As Minister for Environment, I am especially pleased to be personally associated with this guidance from the Assembly Government's heritage agency, Cadw: Welsh Historic Monuments, which I believe is a positive move in further opening up our historic environment and extending access to disabled people in Wales. I am grateful to all those who responded to the consultation exercise, including Disability Wales and particularly the Disability Rights Commission, which provided expert advice on the context of the disability legislation aspects in drawing up this document.
Wales currently has some 25,000 buildings that are listed because of their special architectural or historic interest. About half are private homes, but others will be buildings which offer services to the public and these fall within the framework established by the Disability Discrimination Act 1995. This guidance is aimed at the owners of such buildings to ensure that they take full account of the needs of disabled people in accessing services and at local authorities which are responsible for determining applications for alterations to listed buildings. We want to make sure that they consider the needs of the disabled visitor in concert with the particular character of the listed building. And we want to draw in architects and other professionals too. Many listed buildings were not designed with disabled people in mind and appropriate solutions call for imagination and creativity in design. There is no magic formula, no one solution to fit every circumstance. But there are some guiding principles and these are made clear in this document. Our new initiatives for high standards of design will bring benefits for all users of services, including those people who have disabilities.
The Assembly Government is committed to becoming an exemplar of best practice and works to influence others to take positive action in ensuring equality for disabled people. Although this document is directed at physical access to historic buildings, I make no apologies for taking this opportunity to raise awareness of issues beyond physical access and would encourage all operators to think about what improvements could be made to integrate and involve disabled people further within our society.
I am confident that we will do so, and that we will continue to preserve the historic environment in a form which can be enjoyed by all people for generations to come. We may not always get it right from the outset, but our chances of success will be all the greater if disabled people and their representative groups are fully part of the planning process from an early stage to ensure that their needs are met. Improved access benefits everyone and makes good business sense to all service providers.
Sue Essex AM
The aim should be to make historic buildings which provide services for the public accessible to everyone. This guidance is focused on people with disabilities, but overcoming barriers for disabled people will also benefit others, such as the elderly and parents of young children.
Cadw: Welsh Historic Monuments is the arm of the Assembly Government set up to oversee the protection and conservation of the historic environment of Wales. Cadw has a number of monuments of national importance in its care as well as having statutory duties in respect of applications for consent to alterations affecting the character of listed buildings.
Cadw has produced this guidance for local planning authorities, people who provide services to the public from historic buildings, designers, disability access groups, disabled people and their representative organizations. The guidance
_ explains how historic buildings from which services are provided for the public might be made more physically accessible;
_ explains the relevant planning legislation and how it interacts with the requirements of the Disability Discrimination Act 1995 (DDA); and
_ provides examples of how some buildings have been adapted to accommodate disabled access.
Generally, 'access' should be interpreted widely to include access into and within any building or site, and access to all facilities, services and information. The ultimate objective should be to provide a barrier-free environment for all. This document does not offer comprehensive guidance on the wider interpretation and presentation issues or the actual services provided by operators in historic buildings. This is because Cadw's duties relate to physical features and we cannot direct how services are provided to disabled people. However, we are taking this opportunity to highlight some of the broader implications of the DDA so providers can consider all the arrangements they have in place for their disabled customers.
Just as each historic building is unique, so is each access solution. This guidance is not therefore prescriptive about how access can be achieved. However, if access designers combine an understanding of the historic environment with the application of the general access principles outlined in this document, workable and acceptable solutions should be achievable. Throughout this document we have included a number of case studies and cameos demonstrating access solutions in practice. The examples simply illustrate the principles and concepts used in access and should not be treated as authoritative solutions or indeed best practice.
There will inevitably be some cases where full access will not be feasible without seriously damaging the character of the building. But these will be very few. Creative thinking and the application of general principles outlined both in this document and elsewhere in the access literature should always result in a reasonable access provision.
This guidance is not an authoritative interpretation of the legislation. That is a matter for the courts. However, it will be reviewed regularly to ensure that it reflects current legislation and principles.
Further detailed guidance on the Planning (Listed Buildings and Conservation Areas) Act 1990 is in Circular 61/96 and 1/98, available from Cadw. General conservation standards are noted in British Standard 7913:1998 Guide to the Principles of Historic Building Conservation.
Further detailed guidance and interpretation of the DDA can be obtained through the Disability Discrimination Act 1995 - Code of Practice on the Right of Access to Goods, Services, Facilities and Premises. British Standard 8300: 2001 Design of buildings and their approaches to meet the needs of disabled people has a wealth of information to aid designers find solutions to overcome difficulties in their particular buildings.
Relevant extracts of each Act are at Annex A and a list of useful contact points is at Annex B.
Disability Discrimination Act 1995
Introduced measures to prevent discrimination against disabled people.
Part III of the DDA is based on the principle that disabled people should not be discriminated against by service providers.
Since December 1996, it has been unlawful for service providers to treat disabled people less favourably than others for a reason related to their disability.
Since October 1999, service providers have had to make 'reasonable adjustments' for disabled people in the way they provide their services.
From October 2004 service providers will have to make 'reasonable adjustments' to the physical features of their premises to overcome physical barriers to access.
Service providers will be acting unlawfully if they fail to comply with this duty and cannot show that the failure is justified.
The DDA does not overrule planning or building legislation and existing requirements for planning consents remain.
Planning (Listed Buildings and Conservation Areas) Act 1990
There is a requirement to compile and maintain a list of buildings in Wales identified as of special architectural or historic interest. There is no discretion not to list and listed buildings are afforded additional protection in law.
Grading is a material consideration for the exercise of listed building consent. Grades I and II* identify exceptional buildings which are of particular importance and their significance will generally be beyond dispute.
Statutory controls also apply to Grade II buildings that make up some 90% of the list.
Listed building consent is required for any alterations that affect the character of a listed building.I
t is an offence to carry out any works, internal or external, without listed building consent, which should be sought from the local planning authority.
Listed places of worship are subject to listed building consent procedures or internal ecclesiastical controls if one of six approved denominations.
What is the purpose of this guidance?
This guidance suggests ways to improve physical access into, and within, historic buildings. It examines the obstacles to access and explores ways of removing or altering the physical barriers that may put disabled people at a disadvantage.
In the first instance, those providing services in historic buildings will need to consider what types of changes disabled people might require and then consider whether they are able to deliver such changes. Discrimination is often unintentional and may stem from a lack of awareness about disability. It may also result from mistaken assumptions or decisions based on speculation, generalizations or stereotyping. When plans for alterations are being considered, it is important that service providers consult widely with disabled users, local authority access and conservation officers, disability access groups and other disability organizations to obtain advice on how services and access arrangements can best be provided for all customers. The local fire authority should also be consulted to ensure that these access arrangements are appropriate should the building need to be evacuated in an emergency.
This prominent high street bank in central Cardiff was entered via two granite steps. These were overcome by constructing a ramp using a combination of techniques. The pavement was mounded to relieve most of the level difference and then the last step was modified by trimming the nosing and dressing the stone into an angle. The ramp continues to the original solid doors, fixed open during the day, and there is a new level porch in front of modern automatic doors.
Who is a disabled person?
A disabled person is someone who has a physical or mental impairment which has a severe and long-term adverse effect on their ability to carry out normal day-to-day activities. Disabled people may be those who
_ use a wheelchair
_ are blind or partially sighted
_ are deaf or hearing-impaired
_ are affected by arthritis
_ have a long-term illness
_ have learning disabilities
_ have hidden impairments.
The DDA Code of Practice offers a fuller interpretation of the meaning of a disability and service providers may wish to make themselves aware of that.
Who is a service provider?
Anyone involved in a business or an organization which
_ provides a service
_ offers facilities
_ supplies goods
to the public, or to a section of the public, whether in the private, public or voluntary sectors. It does not matter if services are provided free or in return for payment. The DDA Code of Practice offers guidance on what services are and are not affected by the legislation.
The DDA has introduced measures to prevent discrimination against disabled people. Part II covers the employment of disabled persons. This is fundamental to equality of opportunity and makes it unlawful for an employer to discriminate against a disabled person without justification and without considering making 'reasonable adjustments' first. Section 6 places a requirement on employers to take such measures as are reasonable to ensure that any physical features of the premises do not place disabled employees at a disadvantage in comparison to people who are not disabled.
This guidance centres on the duties set out in Part III, which are based on the principle that disabled people should not be discriminated against by service providers or those involved in the disposal or management of premises. Subject to limited exceptions, anyone who comes within these categories must comply with the duties set out in Part III. These are being introduced in three stages.
_ Since December 1996, it has been unlawful for service providers to treat disabled people less favourably than others for a reason related to their disability;
_ since October 1999, service providers have had to make 'reasonable adjustments' for disabled people in the way they provide their services; and
_ from October 2004, service providers will be required to make 'reasonable adjustments' to the physical features of their premises to overcome physical barriers to access.
It would be sensible for service providers to take any opportunities which arise, or bring forward refurbishment plans, to make alterations to benefit disabled people in advance of 2004. Alterations which affect the character of a listed building require listed building consent so careful consideration of ways of accommodating disabled access is needed at an early stage.
These requirements can pose considerable challenges to owners of historic buildings. These challenges and possible ways of providing appropriate access arrangements are explored further in the next sections.
This principal court house in Cardiff is entered from a podium above a grand entrance stair. This is an essential part of the character of the building.
To provide wheelchair access an existing pavement level door (on the left of the picture) was modified for use by disabled visitors. Within, a passenger lift takes visitors to all levels. A dedicated disabled parking space further facilitates access.
The nature of the building meant that this accessible entrance could not be utilized as the main entrance, but disabled visitors can enter the main hallway from the internal lift.
Case Study: National Library of Wales
The National Library is a large imperial building overlooking Aberystwyth. As a national institution it was intended to be imposing and the principal entrance in particular was designed to have a dramatic effect on its visitors. This it achieves, with the dark, oak-lined vestibule; the lofty, spacious hall lined with display cases and flanked with galleries; and the grand stair. All of these contribute to conveying the authority of the institution.
The main library on the first floor is entered from a high podium, which is at the top of a long flight of broad stone steps. From this platform, Cardigan Bay provides a backdrop as visitors enter the large bronze doors. The height of the podium made ramped access impossible and the formality of the architecture would be harmed by an external lift. As the library was undergoing comprehensive refurbishment, including a new auditorium, the whole visitor experience was examined afresh.
Following a full access audit, it was proposed to modify an existing entrance on the ground floor to be fully accessible by moving the original steps forward to permit a ramp, constructed adjacent to the steps, to land on a level area in front of the door. The basic rectilinear design of the steps remains, and the ramp is built in matching materials and in a complementary style. This was a good solution in itself. However, the design team went further by designating this as the new main entrance to the building. Though the original entrance will remain open, all visitors to the library will be directed to this new fully accessible entrance. A new reception, toilets and cloakrooms complete the remodelling and, once inside, new lifts will permit access to all areas of the building, including the grand entrance hall.
An important part of this solution was overcoming the particular problem of the strong horizontal emphasis of the building that would not be complemented by a visibly sloping ramp. It was therefore constructed between horizontal parapet walls surmounted by a glass barrier, which allowed the only sloping elements to be the handrails.
The solution respects the architectural integrity of the building and maintains the historic fabric. In addition to the physical alterations necessary to open up access, which are being put into effect in the first phase of redevelopment, the access audit also identified further changes to enhance the visitor experience that would be of particular benefit to disabled visitors. These included the installation of audio loops, the use of colour differentials for visually impaired visitors and the use of Braille. The disabled access is expected to be operational in 2002, and the full redevelopment of the library will be complete by 2004. The National Library of Wales website (http://www.llgc.org.uk) contains a virtual tour of the 'visitor experience' showing how the library will look when the refurbishment is complete.
Part 2 - Policy and principles
Wales has a rich legacy of historic buildings. The Assembly Government, through Cadw, has a statutory duty to identify important historic buildings that should be protected for future generations. Around 1% of buildings in Wales meet the standards for inclusion on the statutory lists of buildings of special architectural or historic interest. This means they are important buildings in Wales's historic environment. The number of listed buildings in Wales is expected to be around 30,000 by the end of the listing survey period in 2005. About half of these are private dwellings, but others provide services to the public. The law protects listed buildings to ensure that their architectural and historic integrity is not compromised. If alterations are proposed which affect the building's historic character, listed building consent is required from the local planning authority. The DDA does not override the statutory requirement for listed building consent, building regulations approval, planning permission or any other consents.
Historic buildings can present many difficulties for some disabled people. In some buildings, features that can be physical barriers to access may also be essential parts of the character of the original structure. This can apply equally to the narrow, low doors of the cottage or to the grand stone stairs of the mansion. The challenge is to design alterations to the fabric to permit access for disabled people without damaging the character that makes these buildings such a tangible part of the history of Wales. This can be achieved with all interested partners - including disabled people and their representative groups - working together to find the most appropriate, workable and sensitive solutions which retain the historic integrity of the building.
Cadw's policy on access
Cadw is committed to the principle of full access, wherever it is practical to provide it. It aims to provide safe and easy access to all buildings in its care, within the limits of any particular structure, and encourages others to implement schemes which reconcile the special character of historic buildings with improved access for all people in our society.
The DDA recognizes that full access to all buildings may not always be possible and the duty of service providers is to take reasonable measures. However, on the basis of its experience with historic buildings over many years, Cadw believes that a satisfactory solution to providing suitable access for all can almost always be found so long as imaginative and innovative approaches are explored fully. The aim in dealing with adaptations as part of the statutory planning process should be to seek solutions to overcome barriers in a positive way.
General principles
It is always good practice to provide access in a sensitive way that complements the character of the building, whether listed or not.
It is good practice to provide full access in new buildings and extensions.
When a new extension is designed for a building of special architectural or historical interest, it should be fully accessible. Exceptionally, the extension may have to harmonize with the historic building or streetscape to the extent that access could be difficult but in such cases provision can be made within the new structure. For example, if floor levels are too high internally, it may be preferable to install an internal ramp or lift if an external one would create a harmful juxtaposition with the original historic building.
The duty to improve access is a continuing duty.
The provision of reasonable access is not something to be considered once and then forgotten. Service providers should keep their duty under continuous review in the light of their experience with disabled people. Access arrangements should be frequently and critically reviewed as improvements in technology may make it possible to gain access to previously inaccessible areas.
Listed building consent is required for changes proposed in order to provide improved access that affect the character of a listed building.
Changes in character include external or internal ramps but consent might also be required for minor changes such as visibility strips or tactile flooring. Early consultation with the conservation officer of the local planning authority is advised.
The requirement to obtain the necessary consents should not be seen as a reason for service providers to neglect their duties to disabled users of their services. Not all adjustments necessarily require listed building consent. It may be possible to make minor alterations that provide a partial solution to make services available to disabled people while the necessary consents are being sought.
Improvements to access should be considered in the light of the statutory duty to conserve the historic environment.
The historic character of some exceptionally significant buildings can be particularly fragile and could be diminished by seemingly modest alterations. In such cases, the preferred option may be too damaging to the character of the building and alternative solutions should be explored to find an acceptable compromise.
The design and materials of this ramp respect the fine Edwardian stone fa‡ade of this Llandudno bank. All customers use the principal, and only, entrance.
Cadw encourages imaginative and inventive solutions to provide an acceptable level of access to an historic building.
Listed buildings come in all shapes and sizes and the solution for each building must be considered in an individual way. Unconventional or novel approaches could provide acceptable access when a more obvious solution might be too damaging to the historic character of the building.
The preservation of historic buildings is not necessarily achieved by the rigid application of guidelines.
Full access is always the objective but, in certain circumstances, a compromise that would allow an acceptable degree of access may better preserve the character of a building. A flexible approach, perhaps including a relaxation of the building regulations, is often the only way to achieve a measure of access that is appropriate to the historic building in question.
The DDA and historic buildings
The DDA intends that disabled people should be able to use historic buildings in the same way as everyone else. Service providers should be aware of the duties the DDA has already placed on them as well as those that become effective from 2004, and take steps to build these into any current maintenance plans.
Owners and service providers will have reasonable concerns about the costs and inconvenience of change, but research by the Disability Rights Commission suggests that most changes can be undertaken with minimal cost and inconvenience. Many alterations may cost nothing at all if they are built into the maintenance cycle. For example, changing the colour scheme to benefit visually impaired people will cost nothing if the change is accommodated in the repainting maintenance cycle.
In practice, providing access to all means that owners should aim to adapt buildings to allow disabled people to do the following -
Use the same routes as everyone else.
A disabled person ideally should not be obliged to enter via an alternative entrance such as at the rear of the building, and circulation within the public areas of the building should be possible for all visitors.
The steps in the porch of this library in Llandudno were removed by relaying the floors in both the porch and the entrance hall. The original materials were reused or replicated.
Use the building independently.
A disabled person should not be obliged to ask for help in getting into or around a building, though of course help should be provided if requested.
This ramp on a police station in Conwy successfully permits access to this prominent building. Good use is made of the difference in external levels to reduce the length of the ramp. However there was not enough room for a gentler ramp so it is slightly steeper than might be desirable. An intercom is proposed for the foot of the ramp to allow communication with the reception. The pavement is mounted by making use of the stone slab crossing shown in the photograph on page 27.
Use the facilities offered in the building in the same way as others.
A disabled person should not be deprived of the use of a facility because the service provider believes that it would inconvenience others or assumes wrongly that a safety risk would be created.
Both entrances to this bank in Rhyl are utilized to provide full access to the facilities. The original principal entrance remains unmodified but the counter area has been moved to the side entrance. Customers entering the banking hall via the grand corner doorway are directed through the building to the new customer service area. The ramped entrance to the side has thus become the entrance.
However ...
_ the legal requirement to preserve the character of an historic building may mean that on rare occasions not all of these objectives can be achieved. For example, the interventions necessary to permit every part of a ruined medieval castle to be fully accessible would be so harmful to its character as to destroy the pleasure of visiting the building for all.
_ in general, it may be appropriate for a disabled person to have less favourable access to a building only if the alternative is to have no access at all. For example, providing an alternative route through the building rather than the main thoroughfare might be justified if the modifications required to adapt the main route would be too damaging to the historic building. Similarly, directing disabled people to another fully accessible entrance might be justified if, for example, the arrangements necessary to gain access to the principal entrance would compromise the architectural merit of the historic building. Thought could be given to making this accessible entrance into the principal entrance, thus avoiding discrimination and benefiting all visitors.
This Victorian chapel in Haverfordwest is unusually in the Roman basilica style. As part of its restoration, the stone step beneath the ornate gates is being reset to pavement level and the forecourt stone flags realigned. Access through the portico would have required too much alteration to the disciplined Classical architecture but a side entrance to the left of the building has been altered to allow additional access.
_ a service provider should not assume that by making a service more accessible to one group of disabled people that this will automatically absolve them from considering other changes which might benefit other disabled persons. Furthermore, service providers should ideally plan services on the basis that disabled people can access them either independently or with assistance according to the disabled user's choice. There is nothing in the DDA that prevents a service provider from treating a disabled person more favourably.
The duty to disabled people is 'to take such steps as it is reasonable in all circumstances of the case' to ensure that they are not discriminated against because of their disability. The ability to adopt a fully inclusive approach to historic buildings and the opportunities to implement suitable design features will inevitably depend on the existing context of development and the degree to which the historic characteristics of the building may inhibit a particular design solution. Whilst Cadw believes that appropriate solutions for historic buildings can almost always be found, it may be that, despite the best efforts of the owners, including full consultation, the inherent limitations of the building may present insurmountable difficulties. In such cases, the duty under the DDA may be deemed to have been discharged only if service providers are able to demonstrate that they have taken reasonable steps to provide full access. Discharging the duty of the DDA is more than just obtaining consents. If the proposed alterations receive the necessary consents but are not implemented the offence under the DDA remains.
What is reasonable?
The following factors from the DDA Code of Practice might be taken into account when considering whether the adjustment is reasonable:
_ whether taking any particular steps would be effective in overcoming the difficulty that disabled people face in accessing the services in question
_ the extent to which it is practicable for the service provider to take steps
_ the financial and other costs of making the adjustment
_ the extent of any disruption which taking the steps would cause
_ the extent of the service provider's financial and other resources
_ the amount of any resources already spent on making adjustments
_ the availability of financial or other assistance.
How to approach the duty under the DDA
Those providing services in historic buildings should review current access arrangements, particularly if alterations are being considered, and ensure that any proposals fall within the requirements of the DDA, as soon as possible. These changes should be informed by an access audit that should be prepared in consultation with disability access groups, local authority access and conservation officers, disabled people and their representative organizations.
Service providers may wish to refer to The Disability Discrimination (Services and Premises) Regulations 1999 which define 'physical features' for the purposes of the DDA. These include features stemming from the design or construction of a building on the premises or any approach to, exit from or access to the building. Cadw's remit relates to the physical fabric, but we would encourage service providers to think about the wider implications of disabled access, including the way in which their staff treat disabled customers. It is good practice to establish a positive policy on the provision of services to ensure the inclusion of disabled people and to provide disability equality training for staff.
Justification
Applicants for listed building consent are advised by Circular 61/96, paragraph 69, that justification for their proposals is an essential part of their application. It is unlawful for owners of listed buildings to carry out alterations to the fabric of the building without first obtaining listed building consent. It is therefore both good practice, and a vital part of the proposal to alter an historic property in order to provide access, that applicants undertake a detailed assessment of the barriers to access in their building. Service providers may find that this can best be done as part of a wider review of its services to demonstrate that they have considered fully all aspects of service provision to disabled people. The element of this wider review that assesses specifically the physical barriers to access is the access audit, which could be part of the justification and would be considered by the local planning authority as part of the overall scheme.
The DDA Code of Practice states that justification is required for any action or omission that would cause a disabled person to be treated less favourably, such as the failure to comply with the duty to make reasonable adjustments. It is in the service provider's best interests to ensure that its services are fully accessible to all customers, including people who have a disability. However, in limited circumstances, the DDA does permit a service provider to justify the less favourable treatment of a disabled person or a failure to make a reasonable adjustment. This cannot be used as a general exclusion of disabled people.
This Victorian villa in Llandudno shows the steps and verandah typical of this type of building. As it is now in use as a doctors' surgery, a ramp was installed to reach the verandah which is at floor level. This is constructed in matching red brick and harmonizes well with the structure.
The access audit
The access audit need not be a large document, but it should contain the following information:
An assessment of the physical impediments to access
Identifying any level changes; unguarded areas; trip and other hazards; projections into circulation spaces at all heights; areas where tactile or auditory input would aid circulation; areas where handrails or grab-rails would assist mobility; surfaces which are difficult to traverse; approaches to buildings and parking facilities; lighting, signage and other relevant information.
An assessment of the circulation
Not all sections of some buildings are open to the public. Beyond making reasonable physical adjustments for employees and allowing reasonable alternative means of access where removing, or altering physical barriers to entry are impractical, such sections are not usually covered by disability discrimination legislation. However if a service provider undertakes an audit of the building it would be good practice to have the whole building audited as, in time, parts which are not currently open to the public may be opened in future.
Those providing services from historic buildings need to take into account access to all services offered from the enjoyment of the building to ancillary services such as parking, refreshments and toilet facilities.
An assessment of the historic fabric
Some areas, materials or features of historic buildings are more sensitive to alteration than others. For example, it may be more acceptable to adapt a secondary stair if, by so doing, the principal stair can remain unaltered. The basis for judging the adaptation should be its effect on the special character of the historic building (whether listed or not) and advice should be sought from conservation professionals, including the local authority conservation officers.
An assessment of users of the building
Different types of buildings have different access requirements. It is reasonable for public buildings, such as council offices or libraries, to have unrestricted, and usually permanent, access to the public areas. However other buildings, such as those only occasionally open to the public, could satisfy the statutory requirements by the provision of temporary access arrangements. Advice should be sought from relevant disability organizations on the installation, use and maintenance of such facilities.
An assessment of means of escape
Early consultation with the relevant fire authority on any design solutions is essential. Access to a property must also provide for emergency escape. The Fire Precautions Act 1971 and the Building Regulations require methods of escape to be safe and effective for all people in and around buildings. BS 5588 Part 8 contains advice on the fire precautions in the design, construction and use of buildings and the Code of Practice for the means of escape for disabled people. People can have a wide range of impairments, but everyone should be able to leave a building in an emergency without relying on others. However, if the alterations required to achieve this goal would be too damaging to an historic building, a managed evacuation of the premises could be acceptable. This could be in conjunction with other mitigating solutions, for examplefire compartments or active fire control systems (such as sprinklers). Staff training and awareness are an integral part of this solution as are other health and safety issues that do not necessarily require listed building consent and which will also need to be considered by the service provider. The organization and design of all such measures should respect the particular special architectural or historic interest of the property; be consistent with the safety of all building users; and be regarded as an integral part of the building's access audit.
Basic principles of providing access
Producing a comprehensive access audit is generally seen as a specialized task. Though an audit could be prepared by building professionals experienced in historic buildings, or owners confident in their knowledge of the building and potential barriers to access, the services of an access auditor should be considered. Such a consultant may often save time and money as the level of knowledge required to address all forms of disability should not be underestimated and the possible solutions to the problems may not be obvious. There is no requirement to use an accredited consultant, though this is recommended, but a useful starting point for those needing to undertake an access audit could be the National Register of Access Consultants, the address for which is at Annex B of this guidance.
The following principles should be followed by service providers and their agents when considering improvements to physical access in historic buildings. This is not an exhaustive list. The duty to make reasonable adjustments under the DDA is more likely to have been discharged if they:
_ carry out a survey of physical barriers to access for disabled people
_ design appropriate adjustments
_ receive necessary permissions
_ put the adjustments in place
_ maintain the access in good order, particularly if mechanical - for example, lifts and entrances should be kept clutter free
_ ensure that all staff who are in contact with the public are aware of their legal obligations and consider the provision of disability equality training which may be appropriate
_ if necessary, provide staff training relevant to the adjustments to be made
_ draw the adjustments, and how to request assistance, to the attention of disabled people
_ review regularly the effectiveness of adjustments and act on the findings of that review.
It is fundamental to improving access arrangements that disabled people and their representative groups are involved in the formulation of proposals to ensure that the measures being considered are appropriate to their needs.
One of the three arches in this Georgian market hall in Tenby was modified to provide ramped access to overcome the small step. The symmetry of the fa‡ade is preserved and the materials for the ramp match the original. The local planning authority also provided a drop kerb to complete the access solution.
Case Study:St Deiniol's Church, Worthenbury, Wrexham
The small village of Worthenbury, east of Wrexham, has one of the finest Georgian churches in Wales. It was constructed between 1736 and 1739 to the design of Richard Trubshaw, a mason and quarry owner from Staffordshire. The commission for the church probably came to Trubshaw by way of the Puleston family for whom he had rebuilt parts of nearby Emral Hall in the 1720s. The hall was demolished in 1936 but the church survives remarkably intact. It is notable for its internal fittings, including a complete set of box pews (of which those for the Puleston family have fireplaces), pulpit, font, chandeliers and hatchments. The east window incorporates fourteenth-century glass from the chapel of Winchester College.
The large churchyard is raised well above the level of the surrounding land and is enclosed by a brick wall. The entrance to the church is on the east side of the churchyard, where the wall takes a great inward curve centred upon iron gates flanked by tall brick piers. A flight of four stone steps leads up to the gates. Trubshaw's arrangement here emphasizes formality by means of scale and symmetry. The curved design also had the very practical advantage of allowing adequate space for horse-drawn hearses to turn full circle in the forecourt in front of the entrance. Drivers of motor hearses today still take advantage of this practicality.
The steps at the entrance to the churchyard presented an obstacle to disabled people. The original suggestion was to create a new opening in the left-hand section of the curved wall, approached by a ramped path. But this had several disadvantages: the ramp was short and quite steep; the design destroyed the symmetry and grandeur of Trubshaw's entrance; and the location of the ramp in front of the wall interfered with the turning area for hearses.
The solution to the problem was found only 17m (18 yds) away. To the north of the gates there was a small opening in the churchyard wall which originally allowed the vicar to gain access to the church via a door in the chancel. The gateway was wide enough to permit the passage of a wheelchair user, but immediately within the gate there were steep steps up to the churchyard level. By removing these steps it was possible to construct a shallow ramp at right angles within the churchyard, following the line of the wall back to the inner side of the main gates. From that point there is a level path to the church door, and no raised threshold at the building's entrance. A wheelchair user can therefore alight from a vehicle without difficulty at the new ramp entrance, where a vehicle can remain parked without obstructing the manoeuvring of hearses.
This scheme was implemented in 2001 and is working successfully.
The extension to this former church hall in Llandudno is modern in design but uses traditional materials in a creative way. The external steps were required to maintain a level floor internally, so a ramp was needed. This was constructed behind the existing stone boundary wall so it lands on the level area outside the new main entrance.
There are many ways in which full access can be incorporated into historic buildings. Some are listed below, but each building must be assessed on its merits and the nature of the service provided from the building. It may be that none of these suggestions is entirely appropriate for the particular case and a more innovative solution must be found. If the physical interventions necessary for access are considered too disruptive, a managed solution may have least effect on the fabric of the building.
In practice, physical alterations and management issues should be considered simultaneously as part of any improved access proposal. Both elements are inextricably linked in their contribution to good access. Accessibility is affected by management policies and staff practices. Disability equality training for staff who engage with the public should be seen as an important part of implementing managed solutions.
The DDA proposes four ways in which access for disabled people can be incorporated:
_ removing the obstacle
_ altering it so it no longer has that effect
_ providing a reasonable means of avoiding the feature
_ providing a reasonable alternative method of making the service in question available to disabled people. (This aspect has been in force since October 1999).
The DDA does not prescribe what approach should be used to ensure that a physical feature is not making services impossible or unreasonably difficult for disabled people to use or to adopt one way of meeting its obligations over another. The focus of the DDA is on results and the aim should be to make the services accessible. What is important is that this aim is achieved, rather than how it is achieved. Service providers should bear in mind that there are no hard and fast solutions, although it is good practice to consider removal of the barrier or alteration first.
Any proposal to provide greater access must be effective in achieving that objective since it would be a failure under the duty imposed by the DDA if service providers did not take positive steps to make their services accessible to disabled people. If the physical restrictions of a particular historic building are such that the preferred alteration would be too difficult for the disabled person for whom it was designed, it cannot be considered a positive step and alternatives must be examined. That is not to say that a particular solution must necessarily be accessible by all. Action which may result in reasonable access being achieved for some disabled people may not necessarily do so for others. Access solutions can often be a compromise taking account of the diverse nature of disability and the physical barriers presented by the historic building. However, if the access is functional for the majority of users when used as part of a wider solution identified in consultation, it is likely to be considered effective in meeting the objective of access. Equally, it is not enough for service providers to make some changes if they still leave their services impossible or unreasonably difficult for other disabled people to use, unless there is appropriate justification for doing so. If a service remains inaccessible, a service provider may have to defend its decisions. The aim must be to achieve unrestricted access for the greatest number of people, including disabled people.
In the same way, not all historic buildings have a principal entrance that is capable of sympathetic modification to provide disabled access. Where this occurs it is sometimes possible to remodel the interior space so that the accessible entrance is used by all. However, this solution may diminish the character of some buildings. For example, the main entrance of certain types of structure, such as grand mansions or imperial public buildings, may have been designed to be dramatic and to overwhelm the visitor on entry. Such an impression is an integral part of the experience of visiting the building and where these conditions exist service providers may wish to consider access arrangements which ensure that this visitor experience is maintained, either by retaining the original main entrance for those who are able to use it and considering internal refurbishment so that those who can not enter via that route can gain access to the entry hall by another means.
Ramps, handrails, tactile steps, colour contrast, etc.
Ramps should rise at as gentle a gradient as is practical. Approved Document M to the Building Regulations quotes 1:12 as the minimum and regards 1:20 as 'level' access (thus not requiring handrails or an alternative stepped entrance). Disability Wales recommends a gradient of no more than 1:15 to allow wheelchair access and considers 1:20 desirable. However, there may be exceptional circumstances where there is simply insufficient room for a ramp at the gradient recommended. In such cases a steeper ramp may be the only available option, but this solution should be approached with extreme care and should only be used when it will have a positive influence on improving access and where reasonable adjustments are not possible. If the distances are short, such a ramp could be acceptable but it may be necessary to provide help to negotiate the slope if requested. For example, it may be possible to remove a step into a shop and provide a ramp in the space available within the recessed doorway. Of necessity this ramp could be quite steep but, as the rise and length are so short, access would not be difficult, perhaps being similar to a drop kerb. Gradients steeper than the recommendations can only work over small distances and such ramps are not a practical solution for rises of more than a few steps. The Disability Rights Commission advises that even in such rare circumstances, service providers have to consider making reasonable alternative ways of delivering the service to those who could not use such a ramp.
Level areas at the ends of ramps are recommended, especially at thresholds. If space is exceptionally tight, the landing could be reduced in size but this would have to be combined with active solutions, such as automatic doors or barriers.
Ramps can be more difficult to use than steps for some semi-ambulant people so existing steps should always be retained.I
n this civic building in Llangollen, now housing the Tourist Information Centre, there was enough room on the wide pavement to construct a ramp. A level area outside the door is reached by steps from the front or the ramp from the side. The brick ramp surface contrasts well with the surrounding paving slabs and the railings are traditionally detailed.
When considering such a significant alteration to the external appearance of an historic building it is vital to use quality materials and have good attention to detail.
Additional handrails can aid mobility for people with all types of disability. They are seldom a controversial adaptation but they should nevertheless respect the character of an historic building. They should not compete with the architecture by being overly obtrusive. For example, it may be preferable to fit a discreet handrail to the building rather than install a full balustrade on the outer edge of a ramp. The sides of the ramp could be graded or steps could be constructed to mitigate the fall hazard, though of course no dangerous edge should be left unguarded.
Handrails should contrast visually with the background to enable use by the partially sighted. This can usually be achieved using traditional materials such as polished brass or contrasting coloured timber, though stainless steel or other modern materials could be appropriate. Handrails should be designed to be used by those with reduced grip and have tactile indicators at the top and bottom of flights of steps or ramps.
Varying light levels in different parts of the building can be confusing, particularly deep shadows or strong lights. More powerful bulbs or additional light fittings should be considered to even out the light distribution and remove shadows, particularly around fall hazards and stairwells, but care should be taken not to dazzle a visitor. Such adaptations, especially higher wattage bulbs, may not require any statutory consent. A transition zone between high and low light levels, typically between outside and the interior of dimly lit buildings, is desirable and can be incorporated in the entrance hall.
This university building in Cardiff is converted from a pair of Victorian town houses. A ramp has been installed to the left of the central path. The handrail is discreet against the foliage but clearly visible as the ramp is approached.
Existing balustrades are sometimes considered to be too low by modern standards, but can be an integral part of a feature stair or balcony. Cadw encourages local authorities to be imaginative in their approach to meeting safety requirements. If a handrail is dangerously low, a clearly modern intervention, such as a second slim handrail on top of the existing, is often preferable to removing or extending an ornate original feature.
Steep flights of steps are often part of a building's character but these can sometimes fall below the design standards for modern buildings. These should nevertheless be retained and alternative means of gaining access should be explored before any proposals to alter or replace historic stairs are considered. For example, the narrow winding staircase of a vernacular cottage should not be removed merely because it is difficult to use.
Increasing contrast of the nosings of existing steps to differentiate the tread and riser would assist people with visual impairments. Sometimes the step is strong enough for a thin metal band to be let into the surface to provide a visual indication of the front of the step. However, care must be taken not to introduce a weakness in this critical area and not to allow the indicator strip to protrude above the level of the tread. Alien materials, such as high visibility tapes, should be avoided but more subtle adhesive strips could be acceptable. Alternatively, selective lighting, such as skirting lights, could also provide the necessary contrast but care must be taken not to create a confusing light pattern for visually impaired users.
A tactile grid could be provided at the threshold of steps and steep ramps. This could be achieved using the same materials, for example, a differently textured stone or tile, or by introducing ridges or dimples into existing surfaces. Historic flooring materials should not be replaced with standard tactile patterns where such flooring would be intrusive.
Cobbles can be a particularly difficult surface for disabled people but are a rapidly vanishing part of the built heritage. Cobbles could be retained and access can usually be accommodated by either smoothing the surface by selective pointing or constructing narrow paths in complementary natural stone to cross-cobbled areas.
In this very sensitive area in the heart of Conwy the local planning authority has maintained the paving pattern as pavement and roadway. The pavement is in stone flags whilst the roadway is cobbled, though care has been taken to make this surface as even as possible. To ensure easy access, crossings in stone slabs are provided at strategic points.
Historic doors, both internal and external, are frequently an integral part of the design of an historic building and can be fine examples of craftsmanship. However, they can be one of the most common barriers to disabled people. It must be borne in mind that building regulations do not apply to existing features and the minimum width noted in the approved documents should not be taken as a requirement to modify existing doors. These should be retained, unmodified if possible, and widened if that is the only way access can be gained. In particular, the possibility of using other entrances should be explored fully before any alterations to historic doors are considered. Reducing the opening weight of the door assists all visitors and can be achieved with hydraulic mechanisms or installing a motorized opening system.
The foyer of this well preserved Art Deco department store in Llandudno was modified to provide two automatic sliding doors flanking the original oak double swing doors. These were constructed to match the style of the building and provide a sympathetic access solution.
Access can frequently be assisted by rehanging doors to alter the swing, either from left to right or from in to out. However, some doors may be more ornate on one side and can be part of the composition of a room, so these cannot be reversed. Other improvements to make historic doors more accessible, such as improved contrast between handles and background or installing a motorized opening system, seldom seriously affect the character of the building.
Because of the narrow pavement, the provision of an external ramp was not an option for this bank in Cardigan. However,the lane to the side rises to the internal floor level and this was utilized to assist access.
The lane was resurfaced and a window to the side elevation was modified by extending it to ground level, creating a doorway. Modern joinery with motorized doors operated by a large low-level button permit wheelchair users to gain entry directly into the banking hall.
In this 1950s Cardiff office block, the railings separating the pavement from the dual carriageway were used to advantage. It was a simple matter to raise the pavement to create level access and realign the railings. The co-operation of the local planning authority is essential when there are proposals to alter pavements.
It proved difficult for visually impaired visitors to distinguish between the smoked glass doors and flanking fixed panels, so contrasting handles were installed.
There is often a single step into an historic building. If the door opens on to private land, the path can usually be lifted into a ramp without difficulty. This option can also be considered if the door abuts the highway, when it is sometimes possible for the external pavement to be raised to provide level access. If neither of these is feasible, it is occasionally necessary to remove the step to provide ramped access. In such cases an historic door should be retained and extended down to the new floor level, perhaps using a brass kick plate. If the door has already been replaced with an inappropriate modern example, the opportunity could be taken to reinstate the original pattern of door, made to fit the new opening.
The steps in front of this church in the centre of Cardiff were overcome by removing the boundary wall around this area of the forecourt and raising the paving. The paving slopes in two directions so that the church door can be approached from either street.
Mechanical devices
Lifts, stair climbers, platform lifts, etc.
Any mechanical devices used to provide or assist access must be maintained in good order and be appropriate for the location. This would include the historic building aspects but also the type of plant chosen: for example, equipment designed for internal use can be unreliable if used externally. Any such devices must also take account of the needs of people with sensory impairments. Features that could be incorporated might include loop systems, automatic illuminated signs, audible announcements and tactile controls.
Wherever possible, mechanical access provisions should be located to use existing openings, perhaps on to existing landings if the balustrades are capable of sympathetic modification. They may be designed to harmonize with the building or contrast with it, but these modern facilities should always be sensitive to their location.In Cardiff City Hall a platform lift was installed to overcome the steps in the internal lobby. This involved removing a small portion of the grand entrance stair and cutting a door through one of the curved flanks of the entrance hall. This respects the character of the building while permitting wheelchair access. The handrails were installed some time ago. The brass is a traditional material and a good contrast with the background. The large round profile is easy to grasp.
The least intrusive solution to overcoming steps is usually a self-contained stair climber. This is a motorized carriage on which the wheelchair is attached so the user remains in the chair as they ride up a flight of steps. They offer flexibility as they are not tied to any location and, as such, they are useful temporary measures for providing access during a rolling programme of improvements to a property portfolio. However, they rely on trained staff to ensure the equipment is properly used and the current models can negotiate only modest stair angles.
Larger buildings could possibly accommodate a full size passenger lift. In some cases an existing light well could be used for a lift, perhaps entered through modified existing window openings. The lift mechanism should be within the building: rooftop plant room extensions are rarely acceptable. Alternative lift mechanisms, such as hydraulic lifts, could be less intrusive and can offer more flexibility in siting the plant. On some sites there may be an archaeological implication in excavating for an hydraulic lift.
These Victorian underground toilets in Llandudno are entered down two sets of curving steps flanked by stone balustrades. Access down these steps for wheelchairs was impossible.
The local planning authority designed and installed a lift between the two staircases. Its design is clearly modern but it respects the Victorian character of the facilities and the town.
Platform lifts designed for wheelchair use are now available with very small footprints and in a variety of mechanisms, for example enclosed vertical cable gear, scissors or hydraulic systems. Whilst it is desirable for a lift to be entered on one side and left from the other, it could be acceptable to compromise on the manoeuvring room, perhaps requiring a wheelchair to reverse out of the lift, if this is the only way the facility can be provided. It should also be remembered that some semi-ambulant people prefer to use lifts so designers should be aware that there might be a need for dual height controls and possibly drop-down seating.
Though this 1960s Cardiff office block is not historic, it is in an important conservation area surrounded by grand civic buildings. Access to the podium was achieved by inserting a platform lift into the stone clad plinth. It is operated by clearly labelled signs. The lift is designed to be as transparent as possible, even when in the 'up' position.
Where space is particularly tight, it is now possible to combine steps and a lift in a single unit. There is at least one company manufacturing mechanized steps that retract to reveal a vertical travel platform lift. After the lift has been used, it descends to its lowest level and the steps automatically extend out to cover it. At present the steps are only available in metal, but future models may have the facility to be clad in timber and stone.
Stair lifts and chair lifts can be an acceptable solution for simple stairs but can be too intrusive on grand staircases. In such cases, perhaps a secondary service stair could be more easily adapted for a stair lift. Alternatively, a vertical travel platform lift, whilst being alien, could be less intrusive in an historic stairwell than a complex stair-lift. Such lifts should be constructed to be as transparent as possible, and should only be considered if handrails and balustrades are capable of sympathetic modification.
As with adaptations to the main entrance, where a secondary stair has been adapted for use specifically by disabled people, consideration should be given to making this adapted stair the principal point of access to other floors for all users.
Managed solutions
There will be cases when the fabric of an historic building is so fragile, or the architecture so sensitive to intrusion, that only temporary access arrangements are possible. Under the DDA, a service provider must take reasonable steps to provide auxiliary aids or services if this would enable disabled people to use the building, such as providing a piece of equipment or simply having help available on request. This option must include having appropriately trained staff available to set up the equipment and offer discreet assistance if required, and so is perhaps best suited to commercial or public buildings. An example of such an aid would be the stair climber described above. Another solution could be portable temporary ramps, perhaps made in light timber or commercially available in metal. These could either be left in situ or be stored near the obstacle and brought out on request, perhaps by using a clearly signed external bell or intercom. However, the same thought should go into their design and impact on the architecture as more permanent interventions.
Case Study: Saron Congregational Church, Tredegar
Congregational Church is a listed chapel in the south Wales valleys town of Tredegar. The main entrance is up a flight of stone steps and is finished with a decoratively plastered gable. Tall timber doors lead to the vestibule, flanked by twin staircases to the gallery and separated from the chapel room by a timber screen set with decorative stained glass. This leads to the rear of the chapel room with the sˆt fawr at the opposite end.
A ramp was proposed to enable wheelchair users to enter through the main entrance. The height of the steps meant the ramp had to be very long, forming a switchback design that extended beyond the half-width of the building into the graveyard and necessitating the demolition of the graveyard wall. The steps would also have had to be moved forward to create a landing at the top of the ramp.
It was considered that the ramp and its railings would be detrimental to the character of the building so alternatives were sought. The wide door to the vestry/schoolroom adjoining the chapel had only a small step; within the broad hallway between the former external wall of the chapel and a modern partition, a short steep flight of steps rose to a side door into the rear of the chapel. It was proposed that this hallway be utilized to provide a timber ramp to gain access to the chapel. Once inside, the floor was level so all areas would be accessible. Initial calculations revealed that the modern partition would have to be moved, but this would not affect the character of the building.
Plans drawn for the ramp showed that the gradient would have to be steeper than 1:12. Though the developers considered that this gradient could be negotiated by wheelchair users, perhaps with assistance, and the local planning authority was prepared to be flexible in its interpretation of the building regulations, the chapel decided to forego the construction of a ramp in favour of the installation of a platform lift which was considered a more appropriate access solution in the circumstances.
This proposal received listed building consent and was successfully installed. Externally, the problem of the small step was overcome with a minor adjustment to the path, and internally the side door was widened as it was narrower than recommended in building regulations. (The door was not of historic importance).
This solution gives access to both the chapel and the vestry/schoolroom with negligible alteration to the Classical fa‡ade and with minimum intervention to the fabric of the building. It was also a less expensive option, even with the purchase of the platform lift, than the construction of a large and obtrusive external ramp.
The Planning (Listed Buildings and Conservation Areas) Act 1990
Section 7 states:
Subject to the following provisions of this Act, no person shall execute or cause to be executed any works for the demolition of a listed building or for its alteration or extension in any manner which would affect its character as a building of special architectural or historical interest, unless the works are authorized.
Section 16 (2) continues:
In considering whether to grant listed building consent for any works the local planning authority ... shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historical interest which it possesses.
The Disability Discrimination Act 1995
Section 21
(1) Where a provider of services has a practice, policy or procedure which makes it impossible or unreasonably difficult for disabled persons to make use of a service which he provides, or is prepared to provide, to other members of the public, it is his duty to take such steps as it is reasonable, in all the circumstances of the case, for him to have to take in order to change that practice, policy or procedure, so that it no longer has that effect.
(2) Where a physical feature (for example, one arising from the design or construction of a building or the approach or access to premises) makes it impossible or unreasonably difficult for disabled persons to make use of such a service, it is the duty of the provider of that service to take such steps as it is reasonable, in all the circumstances of the case, for him to have to take in order to:
(a) remove that feature;(
b) alter it so that it no longer has that effect;
(c) provide a reasonable means of avoiding the feature; or
(d) provide a reasonable alternative method of making the service in question available to disabled persons.
(3) Regulations may prescribe -
(a) matters which are to be taken into account in determining whether any provision of a kind mentioned in subsection (2)(c) or (d) is reasonable; and
(b) categories of providers of services to whom subsection (2) does not apply.(
(4) Where an auxiliary aid or service (for example, the provision of information on audio tape or of a sign language interpreter) would -
(a) enable disabled persons to make use of a service which a provider of services provides, or is prepared to provide, to members of the public, or
(b) facilitate the use by disabled persons of such a service,it is the duty of the provider of that service to take such steps as it is reasonable, in all the circumstances of the case, for him to have to take in order to provide that auxiliary aid or service.
(5) Regulations may make provision, for the purposes of this section -
(a) as to circumstances in which it is reasonable for a provider of services to have to take steps of a prescribed description;
(b) as to circumstances in which it is not reasonable for a provider of services to have to take steps of a prescribed description;
(c) as to what is to be included within the meaning of 'practice, policy or procedure';
(d) as to what is not to be included within the meaning of that expression;
(e) as to things which are to be treated as physical features;
(f) as to things which are not to be treated as physical features;
(g) as to things which are to be treated as auxiliary aids or services;
(h) as to things which are not to be treated as auxiliary aids or services.
(6) Nothing in this section requires a provider of services to take any steps, which would fundamentally alter the nature of the service in question or the nature of the trade, profession or business.
(7) Nothing in this section requires a provider of services to take any steps which would cause him to incur expenditure exceeding the prescribed maximum.
(8) Regulations under subsection (7) may provide for the prescribed maximum tobe calculated by reference to -
(a) aggregate amounts of expenditure incurred in relation to different cases;
(b) prescribed periods;
(c) services of a prescribed description; or
(d) such other criteria as may be prescribed.
(9) Regulations may provide, for the purposes of subsection (7), for expenditure incurred by one provider of services to be treated as incurred by another.
(10) This section imposes duties only for the purpose of determining whether a provider of services has discriminated against a disabled person; and accordingly a breach of any such duty.
The first point of contact for any works to a listed building should be the local authority planning department who will be able to advise on any consent which may be required for the proposals. The first points of contact on access issues should be the local authority access officer and the local access group. Information about access groups in Wales is available from Disability Wales and the Access Association.
The Access Association
The Access Association (formerly the Access Officers Association) was formed in response to the need to network and support professionals, whose primary responsibility was to promote and facilitate accessible environments and services for all, including people with disabilities. Mr Barry Thomas, Ynys Mon County Borough Council, Llangefni LL77 7TWTel: 01248 752254
Disability Wales
Disability Wales works with local authorities, disability organizations, professional bodies and local access groups in Wales to promote a barrier-free environment for everyone.Wernddu Court, Caerphilly Business Park, Van Road, Caerphilly CF83 3EDTel: 029 2088 7325 Fax: 029 2088 8702Email: info@dwac.demon.co.uk Website: http://www.disabilitywales.co.uk
Other useful contact points include:
Disability Rights Commission in Wales
The Disability Rights Commission has been set up to help promote civil rights for disabled people and to advise service providers and employers on using best practice to enhance equality of opportunity for disabled people. The DRC has a presence in Wales and operates a helpline to provide information and advice about all aspects of the DDA, as well as signposting specialist organizations where necessary. The helpline details are:DRC Helpline, Freepost MID 02164, Stratford-upon-AvonTel: 08457 622 633 Fax: 08457 778 878Textphone: 08457 622 644Website: http://www.drc-gb.org
HM Customs and Excise
Various locations across the country. Providing access for the disabled can be exempt from VAT.Website: http://www.hmce.gov.ukJ
JMU Access Partnership
The JMU Access Partnership is supported by the Royal National Institute for the Blind and the Guide Dogs for the Blind Association. Its aim is to bring about improvements to the built environment to enable people with sensory and physical disabilities to move around safely, independently and without undue restriction. Trevillian House, 904 Newport Road, Cardiff CF3 4SLTel: 029 2077 8996Email: jmuwales@rnib.org.ukWebsite: http://www.jmuaccess.org.uk
The National Register of Access
ConsultantsAccess consultants included in the register are subject to a strict accreditation process that underwrites their competence to undertake audits and access strategies. The organization holds information on courses in access auditing.Nutmeg House, 60 Gainsford Street, London SE1 2NY Tel: 020 7234 0434 Minicom: 020 7357 8182 Fax: 020 7357 8183Email: marynoble@nrac.org.ukWebsite: http://www.nrac.org.uk
The Institute of Historic Building Conservation
The Institute of Historic Building Conservation is the professional institute that represents conservation professionals in the public and private sectors. 3 Stafford Road, Tunbridge Wells, Kent TN2 4QZWebsite: http://www.ihbc.org.uk
Royal Society of Architects in Wales
The Royal Society of Architects in Wales is constituted as the regional organization in Wales of the Royal Institute of British Architects. Its mission is to promote architecture and the work of architects to potential clients, policy makers and the general public. Bute Building, King Edward VII Avenue, Cathays Park, Cardiff CF10 3NB Tel: 029 2087 4753 Fax: 029 2087 4926Email: wrennm@cardiff.ac.ukWebsite: http://www.riba.org.ribafind
Royal Institute of Chartered Surveyors in Wales
The Royal Institute of Chartered Surveyors is a global professional body that represents, regulates and promotes chartered surveyors and technical surveyors. 7 St Andrews Place, Cardiff CF10 3BETel: 029 2022 4414 Fax: 029 2022 4416Email: cmclean@rics.org.uk Website: http://www.rics.org.uk/public/index.shtml
The Society for the Protection of Ancient Buildings
The Society for the Protection of Ancient Buildings was founded to counteract the destructive 'restoration' of medieval buildings being practised by many Victorian architects. 37 Spital Square, London E1 6DYTel: 020 7377 1644 Fax: 020 7247 5296Email: info@spab.org.uk for general enquiriesWebsite: http://www.spab.org.uk Advice line for technical enquiries: 020 7456 0916 (open 0930-1230 Monday, Tuesday and Thursday)
Ancient Monuments Society
The Ancient Monuments Society was founded for the study and conservation of ancient monuments, historic buildings and fine old craftsmanship. St Anns Vestry Hall, 2 Church Entry, London EC4V 5HB Tel: 020 7236 3934Email: officeb@ancientmonumentssociety.org.uk Website: http://www.ancientmonumentssociety.org.uk
The Twentieth Century Society
The Twentieth Century Society exists to safeguard the heritage of architecture and design in Britain from 1914 onwards. 70 Cowcross Street, London EC1M 6EJTel: 020 7793 9898Website: http://www.c20society.demon.co.uk/
The Georgian Group
The Georgian Group exists to save Georgian buildings, monuments, parks and gardens from destruction or disfigurement, and where necessary to encourage appropriate repair or restoration and the protection and improvement of their setting.6 Fitzroy Square, London W1P 6DXTel: 020 7387 1720 Fax: 020 7387 1721 Website: http://www.heritage.co.uk/georgian/
The Victorian Society
The Victorian Society is the national society responsible for the study and protection of Victorian and Edwardian architecture and other arts. 1 Priory Gardens, Bedford Park, London W4 1TT Tel: 020 8994 1019 Fax: 020 8747 5899Email: admin@victorian-society.org.uk Website: http://www.victorian-society.org.uk/index.html
Architectural Heritage Web Pages
This website, provided by Pavilions of Splendour, has information and links to specialists and publications useful for anyone dealing with historic buildings. Website: http://www.heritage.co.uk
References
Plan for Wales 2001 National Assembly for Wales 2001
Planning (Listed Buildings and Conservation Areas) Act 1990 HMSO 1990
Disability Discrimination Act 1995 Code of Practice: Rights of Access, Goods, Facilities, Services and Premises The Stationery Office 2002
Building Sight RNIB Publications 1995
Buildings for All to Use CIRA 1996
Access to the Historic Environment L. Foster (Donhead 1997)
Working in Partnership to Implement Section 21 of the DDA Freeney et al., NHS Executive 1999
DDA Code of Practice National Disability Council 1999
Sign Design Guide JMU Access Partnership 2000
Design Guide for Use of Colour and Contrast JMU Access Partnership
Consultation Draft: Planning Guidance (Wales) Revised Technical Advice 12 'Design' 2001 National Assembly for Wales 2001
British Standard 8300 Design of buildings and their approaches to meet the needs of disabled people. Code of practice - The British Standards Institution 2001.