Accessible London?

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Page 1 of 35 Accessible London? Wheelchair accessibility in London: A review of public transport and an access audit of public and commercial buildings . Dan Thistlewood BSc Environmental Management Birkbeck College Winner of the Eila Campbell Prize as highest quality research projectof 2014 Email [email protected] Website environmentallychallenged.org

Transcript of Accessible London?

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Accessible London?

Wheelchair accessibility in London: A review of public transport and an access

audit of public and commercial buildings .

Dan Thistlewood

BSc Environmental Management

Birkbeck College

Winner of the Eila Campbell Prize as ‘highest quality research project’ of 2014

Email – [email protected]

Website – environmentallychallenged.org

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“Excellent project – a pleasure to read. This dissertation

really shows the best of our students - it brings felt life

experiences together with theoretical acumen and methodological

rigour to produce an insightful and policy relevant piece of work

incorporating well analysed research findings.”

Marker’s Comment (July 2014)

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Acknowledgements

I would like to thank all those who helped and supported me throughout the writing of this research

project.

I would like to express my gratitude to Birkbeck College, in particular to those in the GEDs

department, whose lectures, field trips and projects have entertained and inspired me over the last

four years.

Thanks are also due to Oak Lodge School; without the support from my friends and colleagues this

project would not have been possible. Special thanks go to (Name Removed), for helping me to

explore and understand the issues faced by wheelchair users on a daily basis; along with providing

the motivation for studying this area. I am also grateful to everyone in my class, for putting up with

my irritability and lack of patience over the last few weeks while finalising the report!

Heartfelt thanks also go to my parents, for their unceasing support and guidance.

Finally, I would like to thank my partner for her love and encouragement, and without whom I would

have struggled to complete this dissertation.

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'The long term physically impaired are neither sick nor well... neither

dead nor alive, neither out of society nor wholly within it. They are

human beings but their bodies are warped and malfunctioning, leaving

their full humanity in doubt. They are not ill, for illness is transitional to

either death or recovery... The sick person lives in a state of social

suspension until they get better. The disabled spend a lifetime in a

similar suspended state. They are neither fit nor foul; they exist in a

particular isolation from society as undefined, ambiguous people.'

(Murphy, 1987, p. 112)

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Contents

Contents ............................................................................................................................................... 5

List of Figures ........................................................................................................................................ 6

List of Tables ......................................................................................................................................... 6

Abbreviations ........................................................................................................................................ 6

Abstract ................................................................................................................................................ 7

Introduction .......................................................................................................................................... 7

Definitions ............................................................................................................................................ 8

Disability ........................................................................................................................................... 8

The Individual Model of Disability ..................................................................................................... 8

The Social Model of Disability ........................................................................................................... 9

Establishing the Rights of People with Disabilities ................................................................................ 9

UK Legislation ..................................................................................................................................... 10

Disability in the UK .............................................................................................................................. 13

Background Research ......................................................................................................................... 14

Wheelchairs and Public Transport in London ..................................................................................... 17

Access Audit ........................................................................................................................................ 22

Methodology .................................................................................................................................. 22

Results ............................................................................................................................................ 23

Discussion ........................................................................................................................................... 28

Conclusion .......................................................................................................................................... 29

Appendix 1 .......................................................................................................................................... 30

Bibliography ........................................................................................................................................ 31

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List of Figures Figure 1 - The International Symbol of Access ...................................................................................... 7

Figure 2 - The Prevalence of Disability within the UK, 2002-2011 (DWP, 2012) ................................. 14

Figure 3 - Zone 1 of the London Underground - from the Standard Tube Map (TfL, 2014b) .............. 18

Figure 4 - Zone 1 of the London Underground - from the Step Free Tube Guide (TfL, 2014d) ............ 18

Figure 5 - Excerpt from the Station Index (TfL, 2014d) ....................................................................... 19

Figure 6 - Platform Hump at London Bridge Station (Rory, 2008) ....................................................... 20

Figure 7 - Sample Areas surrounding Kings Cross and Green Park Underground Stations .................. 22

Figure 8 - Premises Sampled in Green Park ........................................................................................ 23

Figure 9 - Premises Sampled in Kings Cross ........................................................................................ 24

Figure 10 - Results of the Accessibility Audit in Green Park ................................................................ 25

Figure 11 - Results of the Accessibility Audit in Kings Cross ................................................................ 25

List of Tables Table 1 - Wheelchair Access on the London Underground. Data from (TfL, 2014d) ........................... 19

Table 2 - Step free access at London Overground Stations. Data from (TfL, 2013 & 2014a) ............... 21

Table 3 - Results of the Accessibility Audit in both Green Park and Kings Cross ................................. 26

Table 4 - Entrance Type - At ground level ........................................................................................... 27

Table 5 - Entrance Type - Doorway ..................................................................................................... 27

Abbreviations ADM – The Building Regulations: Approved Document M BSI – British Standards Institution DDA – Disability Discrimination Act DfT – Department for Transport DLR – Docklands Light Railway DRC – Disability Rights Council DWP – Department for Work and Pensions NAA – National Assistance Act PwD – People with Disabilities TfL – Transport for London UN – United Nations WHO – World Health Organization

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Abstract

This paper aims to determine the nature of and compliance with UK policy and legislation

pertaining to people with disabilities, particularly with regard to access provisions for wheelchair

users. It explores two aspects of wheelchair access in London; those of access to public

transportation, and access to public and commercial premises. The findings suggest that the UK

still has a long way to go in order to meet the access requirements for all and as such further

research and policy adaptation are recommended.

Introduction

Access is considered by many to be at the heart of the modern disability movement (see Barnes, et

al., 1999; Clarkson, et al., 2003; Goldsmith, 1997; Gore & Parckar, 2010; Imrie, 1997; Oliver, 1990;

Swain, et al., 1993). In recent years accessibility has become something ‘to value and improve in an

urban setting’ (Church & Marston, 2003, p. 83). As a key aspect of the geography of space,

accessibility is currently a prime consideration in building design, transportation networks and land

use strategies. Unfortunately, this has not always been the case and as such much of the built

environment remains inaccessible to many people with disabilities (PwD1). In order to gauge current

levels of accessibility it is important to understand the varying processes undertaken in arriving at

this point. This will be discussed in the first section of this paper by defining disability and discussing

both the individual and social models of disability which are so highly debated in the literature. This

is followed by a short account detailing the establishment of basic human rights for people with

disabilities; and continues with a chronology of UK legislation with regards to both disability and

access. The section closes with a brief portrayal of the extent of disability within the UK.

The term disability covers an enormous range of conditions, affecting

people in countless ways thus causing a wide variety of access issues. The

depiction of a white wheelchair on a blue background (Figure 1) has

become synonymous with accessibility, and in fact, disability as a whole2

(Watson & Woods, 2005). The second section of the paper focuses on

wheelchair access within the UK, providing a review of prior research with

the aim of establishing the main access barriers faced by city dwelling

wheelchair users. The two main barriers were found to be a) getting to a

goods/service provider, and b) entering the premises.

An extensive review of wheelchair access throughout the London Public Transport Network attempts

to address a large facet of the first barrier, getting to a goods/service provider. The second issue,

1 Henceforth PwD

2 It is important to note that the majority of PwD do not use a wheelchair, around 10% of all PwD in the UK are wheelchair users (Papworth Trust, 2013)

Figure 1 - The International Symbol of Access

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entering the premises, was examined through the use of an access audit; the entrances of 241

goods/service providers were assessed in order to determine current levels of wheelchair access into

public and commercial premises within a 250m radius of two of London’s accessible Underground

stations.

The research in this paper will contribute to the existing body of literature in that it appears to be

both the first thorough review of public transport in London with regard to wheelchair accessibility

and the first large scale3 qualitative access audit in both London and the wider UK. This project seeks

to answer the following research questions:

1) How has accessibility policy within the UK changed in recent years?

2) Is current accessibility policy within the UK more closely aligned with the individual or

social model of disability?

3) What is the extent of wheelchair access to the London public transport network?

4) What is the extent of wheelchair access to public and commercial premises around two

accessible stations in London?

Definitions

Disability

‘…an umbrella term for impairments, activity limitations and participation

restrictions. Disability is the interaction between individuals with a health

condition (e.g. cerebral palsy, Down syndrome and depression) and personal and

environmental factors (e.g. negative attitudes, inaccessible transportation and

public buildings, and limited social supports).’ (WHO, 2013, p. 1)

There are two main models used when discussing disability; the individual model and the social

model. There is ongoing debate as to which of these models should be used when defining disability

for official purposes (Oliver, 1990; Oliver & Barnes, 2012); both will be referred to throughout this

paper and are described below.

The Individual Model of Disability

The individual model focuses on the medical definition of disability and describes a person as having

a disability ‘if he has a physical or mental impairment which has a substantial and long-term adverse

effect on his ability to carry out normal day-to-day activities’ (DDA, 1995, p. 1). Defined as such,

disability is cast as a ‘personal tragedy, where the person with an impairment has a health or social

problem that must be prevented, treated or cured’ (Oliver & Barnes, 2012).

3 Compared to previous studies, see (Lewis, et al., 2004).

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This medical definition of disability has been relied upon throughout UK government policies and

legislation; though it has been suggested that the use of the medical approach ‘produces definitions

of disability which are partial and limited and which fail to take into account wider aspects of

disability’ (Oliver, 1990, p. 5) and may, especially in Western societies, ultimately result in the

minimum provision of tokenistic gestures towards PwD (Barnes, et al., 1999; Bromley, et al., 2007).

The Social Model of Disability

The social model incorporates and acknowledges the underlying medical element of impairment as

described above, though it also ‘emphasises that society is the principal disabling force,

marginalising impaired people socially, economically and politically.’ (Bromley, et al., 2007, p. 230).

The social model asserts that the extent to which PwD are actually ‘disabled’ is largely determined

by the environment and society in which they live as opposed to solely being determined by the

individual’s impairment(s) (Oliver, 1990). A person’s disability is either increased or decreased due to

‘attitudinal, procedural and physical factors and barriers in society’ (Lewis, et al., 2004, p. 3). These

factors include the status of PwD within a society, the inclusion, segregation or institutionalisation of

PwD, accessibility of the built environment, accessibility of public transport networks and any other

aspects of society which may impose restrictions on PwD.

'On a material plane the disabled individual is... less able to adapt to the

demands of his environment: he has reduced power to insulate himself from the

assaults of an essentially hostile milieu. However, the disadvantage he

experiences is likely to differ in relation to the nature of the society in which he

finds himself.' (Wood & Badley, 1978, p. 149)

Establishing the Rights of People with Disabilities

The Convention on the Rights of Persons with Disabilities (UN, 2006)4 was the fastest negotiated

treaty in the history of the UN; it also had the highest number of signatories on its opening day than

any previous UN treaty. It took just four years from the conception of the Convention to its adoption

and on its opening day, the Convention received 82 signatories5 and the optional protocol received

44 (UN, 2014a). Currently the Convention has 158 signatories and the optional protocol has 92 (UN,

2014b).

The swiftness with which the Convention was adopted suggests that there was a pressing global

need for such a treaty, possibly coinciding with a paradigm shift from the individual model to the

social model of disability as described above. The Convention emphasised the need for a global

change in perspective regarding PwD; from the position of PwD being seen as ‘objects of charity,

medical treatment and social protection’, to one where PwD are acknowledged as being on equal

4 Henceforth, ‘The Convention’

5 ‘Signatories include countries or regional integration organizations that have either ratified, acceded or signed the Convention and its Optional Protocol’ (UN, 2014b)

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terms with the rest of humanity and afforded the status of ‘subjects with rights, who are capable of

claiming those rights and making decisions for their lives based on their free and informed consent as

well as being active members of society’ (UN, 2014a, 2014c).

The Convention is unique in that it was the first international, legally binding policy instrument

focusing on both development and human rights and which is both cross-disability and cross-

sectoral (UN, 2014c). The purpose of the Convention is to ‘protect and ensure the full and equal

enjoyment of all human rights and fundamental freedoms by all persons with disabilities, and to

promote respect for their inherent dignity’ (UN, 2006, Article 1, p. 3). The principles upon which it is

based include those of non-discrimination, respect, autonomy, independence, equality of

opportunity, accessibility and the removal of barriers to full and effective participation by PwD in an

inclusive society.

Upon signing, member states are obliged to create and/or amend governmental policies and

legislation in accordance with the treaty in such a manner as to ensure that PwD are not excluded

from any aspect of society. The UK had established the Disability Discrimination Act (DDA, 1995) 11

years prior to the Convention, and as such, was among the 82 initial signatories, signing the treaty

on its opening day (UN, 2014d).

UK Legislation

Shortly after World War II, the UK government introduced the National Assistance Act (NAA6) (1948)

which called for, amongst other things, the establishment of welfare services for PwD; with the

Attlee government asserting that 'the guiding principle of welfare services should be to ensure

that all handicapped persons, whatever their disability, should have the maximum opportunity of

sharing in and contributing to the life of the community, so that their capacities are realised to

the full, their self-confidence developed, and their social contacts strengthened' (NAA, 1948; as

quoted in Borsay, 1982 p. 153). Though the NAA made significant improvements in the lives of PwD

through the universal provision of healthcare and medical assistance, there was no mention of the

built environment.

The first official recommendations regarding disabled access in the UK built environment came from

the British Standards Institution7 in the form of Code of Practice CP96 (BSI, 1967), almost 50 years

ago. These recommendations were based on the work of architect and wheelchair user Selwyn

Goldsmith; whose book, ‘Designing for the Disabled’ (1963) was among the first to set out practical

standards in designing for accessibility, based primarily on wheelchair access (Clarkson, et al., 2003).

It was not until the Chronically Sick and Disabled Persons Act (CSDP, 1970) that any statutory

regulation regarding disabled access in the built environment was suggested. Under the CSDP, a

developer planning to construct a new public building, or carry out ‘substantial improvements’ to an

existing building must ‘make appropriate provision for [PwD], in so far as it is in the circumstances

both practicable and reasonable’ to do so (CSDP, 1970, Section 4). At that time, there was no further

clarification of the term ‘substantial improvements’, nothing to suggest what might constitute

6 Henceforth NAA 7 Henceforth BSI

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‘appropriate provision’ for PwD, nor any indication as to what counted as being ‘practicable and

reasonable’ (Borsay, 1982). Unfortunately, Section 4 of the CSDP (1970) did not come into effect and

very little changed with regard to the built environment (Holmes-Seidle, 1996).

A second requirement of the CSDP (1970) was that local authorities were to cater for PwD when

building public lavatories, again with little in the way of guidelines as to what provisions were

necessary. The third requirement was that where a special facility was provided for PwD, it had to be

prominently signposted, though at that time, there was no requirement for signs to be standardised

(Borsay, 1982). The CSDP (1970) also introduced the Orange Badge8 scheme which waived parking

restrictions for PwD who were eligible and able to apply, and insisted on the provision of more

disabled parking spaces.

The next statutory instrument to effect the plight of PwD was the Transport Act of 1978; this Act was

drawn up after a 1973 Department of Environment circular urged that buses and trains should be

immediately adapted to allow better access for PwD , and that all future vehicles should be designed

with accessibility in mind. The Transport Act (1978) was the first UK transport policy to include any

mention of PwD; it encouraged transport commissioners to ‘bear in mind the needs of handicapped

people when scrutinising routes, timetables, and proposed bus stops’ (Borsay, 1982, p. 154). Again,

there was no supporting documentation detailing what needs should be considered or exactly what

adaptations would be beneficial.

Both the Disabled Persons (Services, Consultation and Representation) Act (1986) and the

Community Care Act (1990) recognized some of the shortfalls of previous policies when portraying

the difficulties faced by PwD and in the measures implemented in attempts to reduce said

difficulties; with limited guidance on how to rectify the situation (Oliver & Barnes, 2012).

The introduction of Approved Document M (ADM9) to the Building Regulations in 1987 and its

extension in 1992 set out statutory requirements for accessibility in both new buildings and in

existing buildings undergoing improvements. The requirements were essentially an augmented

revision of the CP96 recommendations from some 20 years previous (Clarkson, et al., 2003). ADM

appeared to be a ‘radical breakthrough’ in UK access legislation as the area of control had been

increased to include the access of all public and commercial buildings and the document provided

detailed standards which should be adhered to during the planning and construction of any new

building or when substantially modifying existing buildings. The inclusion of standards provided

more clarification as to what was necessary in making a building accessible, though much like the

CSDP before it, ADM only insisted on access ‘where reasonable’, making the required adaptations

easily avoidable in all but new constructions (Imrie, 1997).

The first policy to make a substantial difference to PwD was the Disability Discrimination Act (DDA10)

of 1995. This Act highlighted four main kinds of discrimination faced by PwD: direct discrimination,

disability-related discrimination, victimisation, and failure to make reasonable adjustments. Through

the DDA (1995), PwD were, for the first time, given the right to challenge discrimination when

accessing goods and services (Gore & Parckar, 2010). The DDA was enacted some 11 years prior to

8 Nowadays it is the Blue Badge Scheme in accordance with the international symbol of access.

9 Henceforth ADM 10 Henceforth DDA

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the UN Convention on the Rights of Persons with Disabilities (2006), and was the first formal

acknowledgement by the UK government that the issue of disability was one of equality and human

rights. The DDA (1995) entitled PwD to rights in accessing goods, facilities, services and employment;

and also afforded them equal opportunities with regards to buying or renting land or property

(Bromley, et al., 2007).

The DDA (1995), despite being founded upon the medical definition and individual model of

disability, shifted the onus of access to public and commercial services from the individual to the

service provider who was henceforth required to ‘make reasonable adjustments to facilitate access

for disabled people’ (DRC, 2003). While there were no technical standards regarding access in the

DDA (1995), the Act was tied to requirements set out in the then most recent ADM (1992) and as

such, suffered the same limitations. Another important consideration is that the DDA applies to the

entire service, premises, or work place; there are aspects of the physical environment (i.e. street

furnishings, trees, dustbins) which fall outside of the curtilage of a building, thus are beyond the

remit of the Building Regulations and as such no guidance was provided on how to remediate access

issues (DRC, 2003).

The goals of the DDA (1995) appeared to be a move towards those set out in the social model of

disability, though it is important to note that the manner in which the DDA is written entitles PwD

access only to goods, facilities and services and not necessarily gain access to the particular buildings

where these services are normally made available to the public (Bromley, et al., 2007). In other

words a shop does not need to be physically accessible to PwD as long as there is provision of some

means of accessing the goods for sale within, such as a doorbell to ring for assistance outside the

premises. Imrie (1997, p. 427) suggests that ‘such provisions are problematical because they

reinforce the idea that a disability is somehow reducible to the individual impairment ('blame

the victim') while refusing to acknowledge that [PwD] have legitimate claims to the same rights of

access to places that other people have’.

The initial combination of DDA (1995) and ADM (1992) appeared to leave PwD in a very strong

position regarding their rights to access goods and services, though the vagueness and ambiguity

with which both were written, along with the fact that there were virtually no repercussions for non-

compliance, meant that PwD still faced a large struggle to gain equality of access (Imrie & Kumar,

1998).

The basic framework of the DDA was set out in 1995; however the rights for PwD were introduced

gradually over the following 9 years. It was not until 2004 that all service providers, including small

businesses, were included by the Act. The aim of this gradual introduction was to allow service

providers adequate time in which to comply with the new regulations. The DDA was extended

further in 2005 to cover rights of access to public transport; the results of which will be discussed at

length in a later section on Wheelchairs and Public Transport in London.

Research commissioned by the Department of the Environment, Transport and the Regions

prompted the creation of BS8300 (2001) by the BSI. This standard was based on ‘ergonomic

research’ into the interaction between PwD and their environment and provided both technical

specifications and an explanation of the reasoning behind them (DRC, 2003; Lewis, et al., 2004). This

appears to be the first time that a large cross section of PwD were consulted with regard to their

access requirements and as such BS8300 promoted a much more inclusive approach to design;

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suggesting that buildings should be planned in such a way as to meet the access needs of all, no

longer referring specifically to ‘disabled people’, and without the need for segregated or specialist

provisions for PwD. The ADM underwent a substantial revision in 2004 to include the guidance

provided in BS8300. ADM was again updated in 2010 and 2013, though these later modifications

apply only to the layout and structure of the document as opposed to regulatory changes affecting

PwD.

The Equality Act was passed into law in April 2010 and came into force in October of the same year.

It merged 116 pieces of the UK’s antidiscrimination legislation, including the DDA (2005), into one

single Act (EHRC, 2014). There were no significant changes in legislation pertaining to PwD. The

consolidation of previous antidiscrimination legislation is intended to assist individuals in

understanding both their own rights and the rights of other groups, and to help businesses

understand what is required of them in complying with legislation (Gore & Parckar, 2010).

The rights established in the DDA (2005) are upheld through the Equality Act (2010) and are current

at the time of writing this paper. According to the Equality Act (2010) it is unlawful for service

providers to:-

- Refuse to provide a service to any PwD without justification.

- Provide a service to a lesser standard or on worse terms without justification.

- Fail to make ‘reasonable adjustments’ to the provision of services to ensure that there is

no discrimination against PwD (Gore & Parckar, 2010).

Service providers of all sizes and across all sectors are now obliged to anticipate problems and

barriers which may be faced by PwD and must take reasonable steps to ensure that they can be

overcome. It is no longer sufficient for a service provider to wait until a PwD identifies an issue

before considering making a change.

It is important to note that 71% of PwD surveyed in 2010 by Gore and Parckar were either not aware

of, or knew little about the DDA (1995 or 2005) and as such were not aware of the rights ascribed to

them with regards to challenging discrimination when accessing goods or services.

Disability in the UK

Recent estimates suggest that there are currently some 11.6 million PwD within the UK; 5.7 million

of these are adults of working age (16-65), 5.1 million at or above state pension age, and 800,000

under 16s (DWP, 2014). The percentage of the UK population affected by disability has remained

relatively stable for at least the last decade (see Figure 2, below); though, due to increasing

population size, the number of PwD rose from an estimated 10.7 million in 2002 to 11.5 million in

2011 (DWP, 2012). Around 45% of State Pension age adults have a disability, and due to the ageing

nature of the UK population, the number of PwD may therefore be set to increase dramatically.

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Figure 2 - The Prevalence of Disability within the UK, 2002-2011 (DWP, 2012)

It is estimated that only 17% of the UK disabled population were born with disabilities; the large

majority of the disabled population acquire their disability during their adult lives (Papworth Trust,

2013).

There are an estimated 1.2 million wheelchair users within the UK, with 28% of wheelchair users

aged under 60 (Papworth Trust, 2013). Bromley et al (2007) suggest that wheelchair use is likely to

become more common, again due to the ageing UK population as ambulatory, cardiac, and

respiratory difficulties become more common as the numbers of elderly people increase.

Background Research

Within the last 30 years there has been a growing movement around issues faced by PwD, with the

majority of literature emphasising the need for a shift from the individual to the social model of

disability. Michael Oliver (1990) was among the first and most vocal proponents of the theory that

the way in which disability is defined in medical, social and political fields can directly affect the

realities that PwD have to face in all areas of their lives (See also Abberley, 1987; Swain, et al. 1993;

Barnes, et al. 1999; Drake, 1999; Oliver & Barnes, 2012).

Many academics see the issue of accessibility as being paramount to the disability movement and a

basic human right. Goldsmith (1997, p. 149) coined the term ‘architecturally disabled’ to describe

PwD that are restricted not by their disability, but by the design of the built environment around

them. Imrie and Kumar (1998) concur, suggesting that many built environments are ‘disablist’,

implicitly excluding PwD by design. Imrie (1999) also asserts that a major contributing factor to

inaccessibility is that the built environment has historically been planned and designed by people

with little or no awareness of disability access requirements: This may be because much of the

construction within modern cities occurred prior to the establishment of any regulation mandating

universal access (see UK Legislation).

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Large urban areas have been likened to ‘invisible jails’ for PwD as they are, through no fault of their

own, excluded from large facets of society (Gilderbloom & Rosentraub, 1990, p. 271) yet the social

exclusion faced by many PwD is not necessarily caused by a lack of social opportunities, rather it is

more likely to stem from a lack of access to those opportunities (Preston & Raje, 2007).

While there is an abundance of literature pertaining to the social and political implications of

disability as a whole, there appears to be a distinct shortage of empirical evidence relating to

wheelchair accessibility of public and commercial premises. Some researchers have investigated the

accessibility of a particular service in a given area (Edwards & Merry, 2002) while others have

focused on a specific service provider (Losinsky, et al., 2003). Another area of research concentrates

on the provision of assistive technology to help a wheelchair user in driving or navigating (Matthews,

et al., 2003; Beale, et al., 2006; Kim, et al., 2012). Other studies investigate the technical details of

the wheelchairs themselves (Boninger, et al., 1999; Sawatzky, et al., 2004). For the purposes of this

project, only two studies were found to be relevant indicating a potentially large gap in the

literature.

The study by Lewis et al (2004), commissioned by the DRC, aimed to provide a ‘’snapshot’ of … levels

of physical access to premises across a range of services in 4 town/city centres in Britain’ (p. 2). Based

on the social model of disability, the study uses principles of ‘inclusive design’ as the basis for

accessibility provision across different market sectors and within different kinds of town/city. It was

to establish a baseline to aid policy makers and academics in monitoring and evaluating future

changes in levels of access. The cities explored were Cardiff Bay, a new city; Edinburgh, a historic

city; Hitchin, a small rural town; and Leeds, a larger city (ibid.).

The authors completed a thorough review of academic literature, access guides and government

policy in order to develop an auditing framework which could be used to determine the accessibility

of a wide range of service providers. All technical measurements in the audit were based on

standards and guidelines set out in BS8300 and each site was audited by a trained access consultant

and at least one local PwD. While the audit framework proved an effective tool11, the research was

hampered by a small sample (8 sites per city, n = 32) rendering results contextual thus requiring

further research in the area.

Bromley et al. (2007) investigated wheelchair access in Swansea city centre to assess levels of

wheelchair accessibility a decade after the implementation of the DDA (1995) and determine which

aspects of both the built environment and public transportation posed the greatest challenge for

wheelchair users. Swansea, like the majority of UK city centres, features a large variety of uses for

space. Given the extent and scope of the research, this study can be used to enhance understanding

of the issues faced by wheelchair users across the UK. Qualitative data was collected via detailed

face to face interviews with 120 wheelchair users in Swansea, supplemented by another 30

interviews with wheelchair users in Bristol. A further 22 in-depth interviews with retail managers,

disability organisations, city planners and local authority personnel complemented the research.

11

It gathered general information about the premises, reviewing the car parking, approach, entrance, reception, general circulation, vertical circulation, toilets, emergency egress, general staff attitutes and other comments about the site

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The largest obstacle for wheelchair users in the city centre was found to be pedestrians; ‘lots of

people on pavements’ was rated a prohibitive issue for over half of the 150 wheelchair users

interviewed, and a major obstacle for a further 15% (Bromley, et al., 2007, p. 234). 41% of

respondents found ‘getting into shops’ a prohibitive obstacle, and a further 22% considered it a

major obstacle. Other common obstacles found in the city centre include a lack of dropped kerbs,

steps, uneven surfaces, narrow pavements and busy roads, all of which were deemed prohibitive or

major obstacles for 30-50% of respondents (ibid.).

Conducted prior to the inclusion of public transport accessibility in the DDA (2005), the study

established that 90% of wheelchair users found using the public bus system either difficult or very

difficult: the majority travelled by car (76%) or taxi (15%), some resorted to using the pavement (9%)

but none travelled by bus.

The study shed some light on the perception of wheelchair users with 61% agreeing that the

problems they faced in the city centre were intrinsic to ‘the way in which places are

planned/designed’, a view that is constistent with the social model of disability, while 39% stated

that their own physical disability was the problem (Bromley, et al., 2007, p. 237).

So far, it has been shown that the two main issues faced by wheelchair users when accessing goods

and services are a) getting to the service provider and b) entering the premises. This project aims to

contribute to the existing literature in two ways: Firstly by providing a thorough review of publically

available information regarding access provisions made for wheelchair users on the London Public

Transport Network and secondly by performing an access audit on all premises within a 250m radius

of two of London’s accessible Underground stations.

Page 17 of 35

Wheelchairs and Public Transport in London

TfL have significantly increased the accessibility of London’s public transport network over recent

years. Since the extension of the DDA (2005), the entire London Bus fleet has officially been

wheelchair accessible12; with lowered floors, driver operated ramps, and designated space for

wheelchair users. Over 60% of London’s 19,000 bus stops comply with accessibility standards, with

many more scheduled for improvement (TfL, 2012). Though in principle, these modifications to the

service sound very good, in practice it can still be very difficult for wheelchair users to travel on the

public bus. Ramps which are too steep, slippery, or malfunctioning, unhelpful/impatient drivers or

passengers and the limited space available for manoeuvre at the bus stop, on the ramp and once on

the bus regularly cause issues for wheelchair users and can exclude them from the service entirely13.

The London Underground recently celebrated its 150th year in service. The vast majority of the

construction and extension of the Underground network occurred in periods which gave little or no

consideration to access for PwD. As such, it remains largely inaccessible. TfL (2013) indicate that of

its 270 Underground stations, 66 have step free access from street to train. The ‘Standard Tube Map’

(see Figure 3, overleaf) highlights which stations have step free access from street to train with a

depiction of a white wheelchair on a blue background in accordance with the ‘International Symbol

of Access’ (as seen in Figure 1), and from street to platform using the inverse of this; though there is

no notification of other obstacles or restrictions which may apply. Access to this information is very

important to wheelchair users as, even within these highlighted stations, the step from platform to

train can be up to 323mm and the gap between platform and train up to 253mm; far too large to

allow wheelchair access.

12 With the exception of the 10 remaining ‘Heritage Routemasters’ which run a limited service on 2 tourist routes. TfL are currently discussing the closure of these routes (Lydall, 2014). 13 Personal Experience – The young man that I work with has to either drive his electric wheelchair up the ramp to board the bus and then reverse off, or reverse onto the bus and drive off as there is insufficient space to turn his wheelchair around on any of the current models of London Bus. This is a very intimidating manoeuvre and not possible without assistance from a helper experienced in the driving of an electric wheelchair along with the amenability of both the driver and other passengers and fully functioning access provisions on the bus.

Page 18 of 35

Figure 3 - Zone 1 of the London Underground - from the Standard Tube Map (TfL, 2014b)

Specific information regarding the accessibility of Underground stations can be found in the ‘Step

Free Tube Guide’ (TfL, 2014d); this provides PwD with much of the information that they require

prior to making a journey (see Figures 4 & 5, below), including the average step and gap between

the train and the platform, the presence of lifts, escalators or ramps, and any restrictions in direction

of travel. It is important to note that the complexity of this map and supporting information may

render it inaccessible to many, both with or without disability.

Figure 4 - Zone 1 of the London Underground - from the Step Free Tube Guide (TfL, 2014d)

Page 19 of 35

Data from the Step Free Tube Guide (TfL, 2014d) has been

used in the creation of Table 1(below) which shows the

number of Underground Stations, by Line, which are

accessible by wheelchair users. Stations described as

accessible by wheelchair have a gap between the platform

and the train <85mm, and a step <50mm. No further

information is given about the stations which fall into this

most accessible category, though stations with a step

>50mm or gap >85mm are given accurate measurements

(see Figure 5). It is important to note that many wheelchairs

have one or more wheels which are too small to cross a gap

of 85mm, thus potentially rendering access to the train

impossible without the provision of a ramp. Unfortunately,

due to insufficient provision of information, it may not be

possible for a wheelchair user to find out that a train is not

accessible, even on a wheelchair friendly route, until they

actually reach the platform in question. This element of the

unknown can be enough to prevent wheelchair users from

using the service entirely.

At present, only 13% of all possible routes from street to train are accessible to wheelchair users

compared with 24% as suggested by the Standard Tube Map (TfL, 2014b). As can be seen in Table 1,

fewer than 10% are permanently accessible to wheelchair users due to provisions at the station such

as the use of lifts, level platforms, or platform humps which allow step free access only to certain

carriages on the train.

Table 1 - Wheelchair Access on the London Underground. Data from (TfL, 2014d)

Line Number

of Stations

Number of Stations where Train Accessible to

Wheelchair Users without Assistance

Number of Stations where Train is Accessible via Portable Ramp

% Wheelchair Accessible

Bakerloo 25 0 0 0

Central 49 0 2 4

Circle 35 0 3 9

District 60 0 4 7

Hammersmith and City 29 0 3 10

Jubilee 27 13 0 48

Metropolitan 34 8 0 24

Northern 50 5 1 12

Piccadilly 52 7 0 13

Victoria 16 4 0 25

Waterloo and City 2 0 0 0

Total* 379 37 13 13 * This is higher than the 270 stations quoted from TfL above as stations have been counted on each line where interchange occurs i.e. Green Park Station is included in the count of each of the Jubilee, Piccadilly, and Victoria lines therefore counting as 3 stations in this total.

Figure 5 - Excerpt from the Station Index (TfL, 2014d)

Page 20 of 35

The installation of platform humps allows more wheelchair users to access the London

Underground, though adds yet another complication in journey planning; wheelchair users whose

journey requires the use of a platform hump must determine which carriage of the train they must

board to ensure that it coincides with the position of the hump at their destination (see Figure 6).

For example, a wheelchair user travelling on the Northern Line from Kings Cross (with wheelchair

access possible at any carriage) to London Bridge (with a platform hump) must make sure that they

board the second carriage as it is not possible to get a wheelchair off the train at any other point: If

the wheelchair user boards any other carriage, their only option is to stay on the train for an

additional 14 stops, to Morden, where they must then use the emergency help point to request

provision of a ramp to allow them to descend from the train, change platforms, and repeat the 14

stops back to London Bridge, adding a great deal of time and inconvenience to the journey.

Figure 6 - Platform Hump at London Bridge Station (Rory, 2008)

Underground stations which provide a ramp to allow wheelchair access can be used to begin a

journey without prior notification to station staff. Wheelchair users can arrive at the station and use

one of the ‘Help’ points to request assistance as part of TfLs ‘Turn Up and Go’ scheme. The assistant

sets up a portable ramp to provide access to the train, ensuring that the wheelchair user is in the

correct carriage to allow for easy departure at the other end of the journey. If a wheelchair user

must end their journey at a station with ramp access, they must request assistance prior to boarding

the train; an assistant will then accompany the wheelchair user from the gate to the platform,

ensure clear passage for the wheelchair user to board the train, and radio the destination with

details of exactly which train and carriage requires the provision of a ramp at the other end.

The most recent available data for the London Overground Network suggests that under half of all

Overground stations provide step free access from street to train; though the majority require the

use of a portable ramp (See Table 2, below); a wheelchair user requiring step free access from street

Page 21 of 35

to train must make a booking at least 24 hours in advance in order to ensure that someone is

available at both ends of the journey to provide access to the portable ramp14 (Transport

Committee, 2010).

Due to a lack of recent publicly available information pertaining to Overground stations, it is not

possible to accurately determine which, or how many stations or platforms are currently accessible

by wheelchairs and, as such can be an intimidating prospect for their users.

Table 2 - Step free access at London Overground Stations. Data from (TfL, 2013 & 2014a)

Access Criteria Count Percentage

Stations with step free access from street to all platforms of all lines from all entrances.

24 29%

Stations with multiple entrances, at least 1 of which provide step free access from train to all platforms.

11 13%

Stations with step free access from street to platform on a restricted number of lines or platforms.

9 11%

Stations with step free access from street to platform of London Overground services, though with no step free interchange to London Underground or National Rail Services.

1 1%

Stations with step free access from street to train. Includes access via platform humps and portable ramps *

40 47%

Stations with no step free access to platform or train. 39 46%

All Stations n= 84 * These stations are also included in the counts of step free access from street to platform so percentages total >100

Both the Docklands Light Railway (DLR) and the Tram Network have step free access between the

street and the train at all stations (TfL, 2012). These are both relatively recent developments

therefore had to feature inclusive design, thus allowing access for all without the need for special

provision in accordance with recent legislation (DDA, 2005; Equality Act 2010). London’s River

transport network has step free access to all of its piers, and ‘most’ of the riverboats are accessible,

with dedicated wheelchair spaces (TfL, 2014e). The Emirates Air Line, London’s cable car service, is

also accessible by wheelchair, as long as the wheelchair is ‘no bigger than 700mm by 1300m’ and

weighing under 300kg including the user (TfL, 2014f).

All of London’s Licensed Black Cabs are wheelchair accessible via the use of a ramp built into the

vehicle. TfL also have a Taxicard scheme for PwD resident in London. The scheme allows PwD to

receive subsidised rates for taxi travel, paying a flat fare of £1.50 per journey, plus anything above

the subsidised amount of £10.30 for a daytime trip, £11.30 at the weekend and £12.80 at night (TfL,

2014g). The scheme appears to be well used, with 1.9million Taxicard subsidised journeys being

taken in 2010/11 (TfL, 2012). TfL also offer a Dial-A-Ride service to PwD. This is a membership

scheme providing free door-to-door transportation to people who are unable to use other modes of

public transport. This service must be booked the day prior to any planned travel. 1.4 million Dial-A-

Ride trips were made in 2010/11 (TfL, 2012).

14

As of 14 March 2014, the ‘entire London Overground network [became] Turn Up and Go’ (TfL, 2014c), meaning it is no longer necessary to book access to a ramp in advance. It has not been possible to find updated data on the number of stations which this applies to.

Page 22 of 35

Access Audit

Methodology

As described above, the first accessibility issue pertaining to wheelchair access is that of getting to

the service provider, therefore the areas to be surveyed were selected based on provision of

accessible public transport. Areas surrounding both Green Park (GP15) and Kings Cross (KX16) stations

were surveyed as they are the two central London stations with the easiest potential for access by

wheelchair users17. The sample areas are shown below in Figure 7.

Figure 7 - Sample Areas surrounding Kings Cross and Green Park Underground Stations

An access audit framework based on that of Lewis et al (2004), was drawn up in order to assess the

entrances of all public and commercial premises in the sample area (see Appendix 1). Lewis et al

(2004) performed a comprehensive access audit, examining car parking provisions, the route to the

sample premises, the entrance, reception facilities*, general circulation within the premises, vertical

15 Henceforth GP 16 Henceforth KX 17 KX is a major transport hub, featuring step free access from all entrances to six London Underground lines; four through permanent features at platform level (Metropolitan, Northern, Piccadilly and Victoria), and two through provision of a ramp (Circle and ‘Hammersmith and City’). All London Overground and National Rail platforms at KX also offer step free access to the train via the use of a ramp. KX also provides wheelchair access to Taxi’s and numerous bus routes. GP provides step free access between street and train to three lines (Jubilee, Piccadilly and Victoria), all through permanent features; and also serves many bus routes. * where applicable

Page 23 of 35

circulation within the premises*, toilets*, emergency egress and general amenability of staff;

whereas the audit used in this project has been reduced in scope to focus solely on the entrance to

the premises.

The survey was conducted by the author between 15th February and 1st March 2014 following a pilot

survey conducted in July 2013 by the author with the assistance of an electric wheelchair user18.

Each of the premises sampled was numbered and its location noted through the use of a Garmin

Oregon 450 GPS tracker. The results of the survey were compiled and analysed using Microsoft Excel

2007 and maps produced using ESRI ArcMap 10.1 with the ‘World Street Map’ as baselayer19.

The premises sampled in GP are shown in Figure 8, and those sampled in KX can be seen in Figure 9.

Results

Figure 8 - Premises Sampled in Green Park

133 premises were audited in GP, with establishments in the ‘Food and Drink’ sector being the most

frequently encountered (40%) and ‘Retail’ establishments a close second (38%). The majority of

samples were independent (62%), followed by those which were part of national chains (19%),

multinational chains (16%), local chains (2%) and local authority (1%).

18 Thanks John! 19 Sources: Esri, DeLorme, AND, Tele Atlas, First American, UNEP-WCMC, USGS

Page 24 of 35

Figure 9 - Premises Sampled in Kings Cross

108 premises were sampled in KX20. The ‘Food and Drink’ sector was again the most highly

represented with 38% of samples, followed by ‘Hotels’ with 24%. Again, the majority of samples

were independent (64%), followed by those which were part of national chains (14%), multinational

chains (13%), local authority (6%), local chain (2%) and religious (1%).

20 Premises sampled in KX were only those outside of both Kings Cross Station and Kings Cross St Pancras Station. The reasons for this are twofold: i) both stations have been renovated since the implementation of the DDA (2005) and as such all facilities within the two stations are accessible by wheelchair (Total number of premises inside stations = 97); ii) The GPS unit cannot provide accurate location data when inside a building as a clear line of sight is required between the unit and several satellites.

Page 25 of 35

Figure 10 - Results of the Accessibility Audit in Green Park

Figure 11 - Results of the Accessibility Audit in Kings Cross

Page 26 of 35

The results of the access survey (see Figures 10 & 11, above, and Table 3, below) show that 57% of

all public and commercial premises within 250m of GP and KX Underground stations remain

inaccessible to wheelchair users almost two decades after the implementation of the DDA (1995).

Of the 241 samples, only 27 (11%) were found to be accessible to wheelchair users without any

assistance; i.e. featuring level access, free from both internal and external obstacles and having

either a fully automatic or ‘Press to Open’ door of width >800mm.

A further 78 samples (32%) were deemed to be accessible to wheelchair users when accompanied

by an able-bodied assistant21. The samples where assisted access was possible featured either level

access, a small threshold (<50mm), or a single small step (<± 100mm)22. Samples where wheelchair

access required the opening of a manual door of width >800mm were also categorised as ‘assisted’.

Table 3 - Results of the Accessibility Audit in both Green Park and Kings Cross

Green Park Kings Cross Total

Frequency (Count)

% Frequency (Count)

% Frequency (Count)

%

Accessible 13 10 14 13 27 11

Assisted 46 35 32 30 78 32

Inaccessible 74 55 62 57 136 57

n= 133 100 108 100 241 100

Table 4 (below) shows that the main access barrier for wheelchair users at ground level is that of

large or multiple steps, with 54% of samples featuring one or more steps with a total vertical change

of ≥ ± 100mm.

3% of samples featured a permanent ramp which complies with the latest Building Regulations and

<1% had a non compliant ramp. 1% of premises offered the use of a portable ramp23.

In 2% of samples, wheelchair access was blocked by either internal or external obstacles, such as

displays, signs or tables and chairs.

21 Henceforth referred to as ‘assisted access’ 22 A small threshold or single step can be surpassed, with the help of an able-bodied assistant by using the mechanics of the wheelchair to lever and push a wheelchair past the obstacle. Steps >100mm, or multiple steps require a substantial element of lifting on the part of the assistant and can also lead to discomfort for the wheelchair user and as such are not acceptable. 23

The provision of portable ramps may be under represented as they were only counted where visible, signposted, a member of staff offered, or there was a bell for assistance. If it was necessary to either enter the premises or give prior notification in order to request a ramp, it was not counted.

Page 27 of 35

Table 4 - Entrance Type - At ground level

Green Park Kings Cross Total

Frequency (Count)

%* Frequency (Count)

%* Frequency (Count)

%*

Level Access 43 32 25 23 68 28

Threshold 10 8 13 12 23 10

Step(s) with vertical

change of < ± 10cm

9 7 6 6 15 6

Step(s) with vertical

change of ≥ ± 10cm

70 53 60 56 130 54

Ramp (To Standard) 4 3 3 3 7 3

Ramp (Not to Standard) 1 <1 1 <1 2 <1

Portable Ramp 2 1 1 <1 3 1

Entrance Blocked by Interior or Exterior Obstacles

6 5 0 0 6 2

n= 133 108 241 * Percentages may equal >100% due to entrances possessing several features.

Table 5 - Entrance Type - Doorway

Green Park Kings Cross Total

Frequency (Count)

% Frequency (Count)

% Frequency (Count)

%

Outwards Opening 14 11 19 18 33 14

Inwards Opening 60 45 69 64 129 54

Bidirectional 40 30 7 6 47 20

Sliding (Sideways) 8 6 9 8 17 7

Revolving 7 5 1 <1 8 3

Single Leaf Width ≥ 80cm 71 53 55 51 126 52

Single Leaf Width < 80cm 5 4 12 11 17 7

Double Doors 47 35 37 34 84 35

Automatic 9 7 5 5 14 6

‘Press to Open’ 2 2 3 3 5 2

‘Press for Assistance’ 2 2 1 <1 3 1

Open during trading hours 0 0 6 6 6 2

Manual 114 86 89 82 203 84

n= 133 108 241 * Percentages may equal >100% due to entrances possessing several features.

As can be seen in Table 5 (above), the majority of the doors in premises sampled were manual

(84%), inwards opening (54%), single leaf doors of width >800mm (52%). Though these are deemed

appropriate to allow wheelchair access, assistance is required to open the door and when combined

with the presence of steps, could negate wheelchair access entirely. 7% of doorways sampled were

<800mm wide, thus too narrow to allow wheelchair access. Only 8% of the doors were either

automatic or ‘Press to Open’. The only entrance to 3% of the samples was through a revolving door,

which blocks wheelchair access entirely.

Page 28 of 35

Discussion

Though this study appears to be the largest access audit of its kind; sampling a large variety of public

and commercial premises based on location, irrespective of service sector or size of building; it

should be asserted that the study may not be representative of other areas within London or the

wider UK.

By focusing solely on the issue of wheelchair access, the study does not take into account other

areas of disability. Some provisions made in order to allow wheelchair access may pose barriers for

other PwD; for example automatic sliding doors allow for unaided wheelchair access, though can

prove confusing for those with visual impairments. In addition, it is important to note that this study

does not take into account the varying abilities of wheelchair users, focusing solely on the logistics of

entering the premises.

One issue repeatedly highlighted by the service providers whilst collecting the data was the fact that

many of the buildings in London are ‘listed’, as such building legislation mandates that these

buildings must maintain their original appearance due to their significant historical value. This

restricts the provisions that may be put in place to allow wheelchair access. It is unclear which

section of the Building Regulations takes precedence in this case and as such, service providers tend

to compromise accessibility in favour of appearance.

Whilst compiling the results, anomalies were noted in the locations of some of the samples collected

with the GPS device. For the most part, samples shown on the map represent the exact location of

the entrance, while others display up to 20m away from their actual location. This would suggest

inaccuracies attributable to the GPS device perhaps due to the large proportion of tall buildings

restricting the line of sight between the GPS device and the satellites upon which it relies.

One recommendation for future research would be to expand the access audit in those premises

that were found to allow entrance by wheelchair users in order to ensure that the whole service is

accessible. The full access audit framework, as designed by Lewis et al (2004), could be used for this

purpose.

Page 29 of 35

Conclusion

As can be seen throughout this report, the scope of accessibility policies in the UK has dramatically

increased over recent years; from a position giving little or no consideration to accessibility issues for

PwD, to one where inclusive access is a fundamental part of planning and design throughout the

built environment. Currently, in order to receive planning permission for new buildings, or when

making substantial changes to existing buildings, inclusive access must be featured in the design.

Though the definition of disability upon which the Equality Act (2010) is founded continues to reflect

the individual model of disability, the recently implemented policies relating to access suggest that

current political thinking is shifting towards that of the social model, aiming to reduce physical

barriers for PwD. It is yet to be seen the extent to which this political shift has translated into the

built environment, or into society as a whole.

TfL have made significant improvements to wheelchair access across all areas of the public transport

network since the extension of the DDA (2005). The entirety of the bus, tram and DLR systems

feature wheelchair access, along with all of London’s Black Cabs, the cable car, and most of the river

transportation. The Taxicard and Dial-a-Ride schemes provide a door to door service for wheelchair

users and appear to be well used by PwD as a whole. The Underground is in the midst of a long term

renovation project, with many more stations set to provide wheelchair access in the future; though

with only 13% of stations currently accessible, there is still a long way to go. The Overground

appears to be the most problematic system, though this may relate more to the lack of publically

available information regarding the service than it does to the provisions available at the stations. It

is not possible to accurately analyse the extent of wheelchair access throughout the London public

transport network without performing an in-depth study, using both qualitative and quantitative

research gathered with the assistance of a variety of wheelchair users; this is an enormous task and

beyond the remit of this study.

The access audit found that the premises sampled were only accessible to a limited extent, with only

11% of premises allowing unassisted wheelchair access; a further 32% were found to be accessible

to a wheelchair user with some assistance, while the majority (57%) remain inaccessible. This is very

poor considering that regulations mandating the universal provision of access have been in place for

almost 20 years and as suggested above, it is recommended that the UK government perform

regular surveys so that continued progression can be monitored in this field.

It is also recommended that the government increases the provision of information regarding the

rights of PwD to challenge discrimination. One final recommendation pertains to the gap in

literature encountered during the research process. More studies are required that investigate how

the social model of disability can be expanded into all realms of society in order to give PwD the

opportunity for an inclusive future.

Page 30 of 35

Appendix 1

Waypoint

Area Green Park Kings Cross

Name of building (e.g. Park House Dentist): ……………………………………………………………………………

Type of Organisation (e.g. Bank, Café): .…………………………………………………………………………..

Sector : Leisure Local Authority Health Retail F+D

Size of Organisation: Independent Local Chain National Chain Multinational

Size of Premises: Small Medium Large

Entrance to the premises Main Entrance Alternative Entrance

Entrance

Level Access

Threshold (cm)

Stepped (# & cm)

Ramp

Free from obstacles

Doors

Outwards opening

Inwards opening

Sideways opening / sliding

Revolving

Single leaf (width cm)

Double Doors

Automatic

Press to open

Manual

Is it possible to enter the premises when using a wheelchair without assistance? YES / NO

Is it possible to enter the premises when using a wheelchair with assistance? YES / NO

If no, specify:…………………………………………………………………………………………………………………………………

Page 31 of 35

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