Inclusive design statements for London schemes

An inclusive design statement for a London scheme has to show how everyone will approach, enter, move through and leave the development, including in an emergency. Policy D5 of the London Plan 2021 sets that expectation, and the Greater London Authority reads the statement as the evidence that the design team has thought about it rather than copied a compliance checklist. The document is not the same as the access section of a design and access statement, and a scheme that submits only the latter usually gets a stage one comment asking for the former.

The useful discipline is to write it as a journey rather than as a schedule of standards. Standards are the floor. Policy D5 asks for more than the floor.

What the policy asks a scheme to demonstrate

Policy D5 expects development to be designed so that it can be used safely, easily and with dignity by everyone, without separate or special arrangements and without undue effort. That phrasing matters, because a ramp around the back of a building meets the Building Regulations and fails the policy.

Part of the policy deals specifically with emergency evacuation. London Plan policy expects buildings to incorporate suitably sized evacuation lifts, and the statement should say where they are, how they are managed and how the evacuation strategy works for a resident who cannot use stairs. That is now the question most frequently raised at stage one.

Policy D7 sits alongside it on accessible housing, requiring a proportion of dwellings to meet the wheelchair user standard in Approved Document M4(3) and the remainder to meet the accessible and adaptable standard in M4(2). The inclusive design statement should carry the schedule showing which units meet which standard and where they sit in the building.

The difference from a design and access statement

A design and access statement is required by Article 9 of the Development Management Procedure Order 2015 for major development and for development affecting listed buildings or conservation areas. It covers design principles across the whole scheme, with access as one of several themes.

An inclusive design statement is a separate, longer document that follows the user through the development. It records the decisions, the trade-offs and the people consulted. Where a design and access statement says that level access is provided, an inclusive design statement says where the level threshold is, what the gradient of the approach is, what the surface is, how the drainage is handled at the threshold and what happens in snow.

Write it as a standalone document with its own contents page. Officers and access consultees read it on its own, and burying it as an appendix makes it harder to find and easier to criticise.

Approach, entrances and horizontal circulation

Start at the street. The statement should describe the route from the nearest accessible bus stop, station and Blue Badge parking bay to the main entrance, with gradients, crossfalls, surface materials, lighting levels and rest points.

Seating at intervals along a long approach is one of the lowest cost inclusive design measures and one of the most frequently omitted. People with limited stamina plan journeys around where they can sit.

At the entrance, deal with the door. Automatic sliding doors with an adequate clear opening width, a level threshold, a weather-protected approach and a manifestation pattern on glazing are the baseline. Where the entrance is shared with a commercial unit, say how the two uses are separated without creating a secondary entrance for residents.

Inside, circulation widths, turning spaces, floor finishes and acoustic conditions all belong in the statement. Hard reflective surfaces in a tall entrance hall create a reverberant space that is hostile to anyone using a hearing aid, and that is a design decision rather than a specification detail. Blue Badge parking provision in London follows the parking policies in the London Plan, which require a proportion of dwellings to have access to a bay from the outset with capacity to increase later, so check the current figures and state them.

Vertical circulation and evacuation for all users

Lifts are the part of the statement that gets scrutinised hardest. Cover the number of lifts per core, their internal dimensions, door widths, controls, tactile and audible indication, and the maintenance regime that keeps them running.

Then deal with evacuation separately. An evacuation lift is a lift with a protected shaft, a secondary power supply and a management procedure that allows it to be used under fire conditions. Saying that a lift is an evacuation lift without describing the procedure, the refuge locations, the communication system and who operates it will not satisfy the consultees.

Personal emergency evacuation plans for residents who need them are a management matter, and the statement should say who will prepare them and how. For a scheme caught by Planning Gateway One, the Fire Statement covers the fire engineering case and should be consistent with the inclusive design statement on evacuation, since contradictions between the two documents are noticed.

Stairs still matter. Handrails both sides, contrasting nosings, consistent rise and going, and a landing where someone can stop.

Wayfinding and the external spaces

Wayfinding is where inclusive design most often stops at signage. Good wayfinding starts with the building form: a legible entrance, a clear line of sight from the door to the lift core, and a plan that does not require a decision at every junction.

Signage specification then covers character height, contrast, mounting height, lighting and the use of symbols alongside text. Tactile and large print information at the entrance helps, and a tactile plan at the main entrance is now common in larger schemes.

Outside the building, cover dropped kerbs, tactile paving, the treatment of shared surfaces, street furniture placement clear of the pedestrian route, and the design of any level change. Play space within the development should be inclusive rather than segregated, which is a question for the Play Space Assessment as well as this document.

Dense urban schemes also raise amenity questions that interact with inclusive design, since a resident who spends more time at home is more affected by poor daylight, a point covered in applying BRE 209 daylight guidance in dense London.

Management and maintenance of accessible features

Accessible features fail through management rather than design. A Changing Places toilet locked because nobody has the key, a lift out of service for six weeks, a dropped kerb blocked by a parked delivery van, an accessible bay used for storage.

The statement should set out who maintains what, what the response time is for a lift failure, how accessible parking is enforced, and how the management company will handle requests from residents whose needs change over time. Where a planning obligation or a condition can secure an access management plan, say so and offer it.

Adaptability over time is the other half of this. A wheelchair adaptable dwelling only works if the adaptation can actually be made, so show the structural provision for a through-floor lift or a hoist, the drainage provision for a level access shower and the door sets that can be widened.

Structuring the statement

A structure that works, and that officers recognise, runs in this order.

1. Inclusive design principles for the scheme and how they were set.
2. Engagement: who was consulted, including disabled people and local access groups, and what changed as a result.
3. The approach: transport, parking, routes and the surrounding streets.
4. Entrances and horizontal circulation.
5. Vertical circulation, including evacuation.
6. Dwelling standards, with the M4(2) and M4(3) schedule.
7. Sanitary provision, including any Changing Places facility.
8. Wayfinding and signage.
9. Management, maintenance and adaptability.

Keep the schedule of accessible units as a table referenced to the drawings. The density and massing decisions behind the layout sit alongside this in the design-led approach described in optimising site capacity under London Plan policy D3, and the two statements should tell the same story.

Enter your postcode on PlanScope to see which supporting documents a London scheme is likely to need alongside the inclusive design statement.

This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it.

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