Merton CIL’s Response to National Planning Policy Framework

May 2018


We are pleased to have the opportunity to respond to the National Planning Policy Framework consultation[1]. We are an organisation run and controlled by Deaf and Disabled people, delivering services within The London Borough of Merton. We are a pan-Disability organisation championing the rights of people across the full spectrum of disabilities. We take the view that that society creates barriers that ‘disable’ people with impairments from participating fully and on an equal basis with others, for example, by creating and perpetuating physical, information and attitudinal barriers. These barriers must be removed in order to support the independence and inclusion of Deaf and Disabled people, and the National Planning Policy Framework has a role to play in that.


We asked our members what life is like for Disabled people locally and they highlighted a range of issues relevant to planning[2]:


“At Raynes Park station it is only possible to go in one direction.”

“They have taken dog poo bins away so there is more poo on pavements which we can’t see to avoid, or our wheelchairs and scooters can’t avoid it.”

“Pavement parking is an issue – I have to go on the road around it. It is dangerous.”

“Why can’t scooter users plug into electric car charging points?”

“It is so hard to get into the Wimbledon theatre - I have to stand by the stairs waiting to be noticed.”

“Why do shops and restaurants have accessible toilets up a set of stairs? Like the chicken shop in Wimbledon!”

“That bus-stop in Wimbledon! Even after a 3 hour meeting where we told them, this would be a problem, they didn’t listen, and now it is a problem, you can’t get on a bus there.”


We would like to raise the following three issues:

1. The definition of accessibility

The word access or accessibility is used throughout the National Planning Policy Framework, however, whilst we welcome the use of the word, this is not actually defined, and we are concerned that you are not using the word in the sense of being accessible to all. Our understanding of accessibility is ensuring the removal of barriers that are disabling and the use of inclusive practices. The word ‘inclusive’ only appears twice in the framework and is itself not defined in the glossary, and yet, the principle of inclusive design[3] is a long-established one and we would expect to see this reflected in the framework.


2. The principle of Visitability

Visitability[4] is the design approach for homes whose main principle is that a non-resident with a mobility impairment who uses a wheelchair or other mobility device should be able to visit the home. A social visit requires the ability to get into the house, the ability to pass through interior doorways of the house, and the ability to get into a bathroom to use the toilet. Far too often, newly constructed homes often contain the same major barriers as older, existing homes; steps at every entrance and narrow interior doors, with the bathroom door usually the narrowest door in the house. Supporters want to change new home construction practices so that virtually all new homes, whether or not designated for residents who currently have mobility impairments, offer three specific accessibility features that will make it possible for most people to visit:

-      at least one zero-step entrance

-      all interior doors being wide enough to allow a wheelchair to pass through (approximately 81 cm or 32 in), and

-      a bathroom on the main floor which a wheelchair can get into


Merton Centre for Independent Living supports the notion of visitability as being in line with the aims of the National Planning Policy Framework’s stated aims, specifically to: “support(s) communities’ health, social and cultural well-being[5] ..and promote(s) social interaction, including opportunities for meetings between people who might not otherwise come into contact with each other[6].”


3. Consultation and engagement with Deaf and Disabled People

“All those plans to develop town centres - we keep being assured we’ll be involved, and we aren’t.”

Merton CIL would like all sections of the community to be consulted in planning decisions at an early stage. Our members recently responded to a consultation on the Local Plan and were able to provide a wealth of lived experience and bring these to bear on a range of issues across community facilities, the local economy, safeguarding the environment, housing and infrastructure.[7] One of the reasons that our members were able to respond to the Local Plan was because it was provided in an accessible format. We have seen other planning consultations which are almost impossible for a lay person to get to grips with and to respond to meaningfully.


Whilst we welcome the use of the term accessibility in the National Planning Policy Framework, we think that it is crucial to spell out exactly what this means so that it ensures accessibility to all people including Disabled people. A key concept that incorporates accessibility is Visitability, which we would like you to consider. Consulting Disabled people will be crucial to plan-making.


Thank you for your time in reading this.