Mr Robert Domm
Acting General Manager
City of Sydney
GPO Box 1591, Sydney NSW 2001
Friday, 27th February
2004
Dear Mr Domm,
City of Sydney Draft
Access Development Control Plan
The Physical Disability
Council of NSW (PDCN) is the peak non-government
agency representing the interests of people with
physical disability in NSW. We are funded by the
NSW Government, through DADHC, to provide
systemic advocacy services on behalf of people
with physical disability.
Our first comment is
general. We wish to congratulate the Council for
acknowledging that access for people with
disability requires a detailed Development
Control Plan. We believe it to be important that
planners, regulators and providers of goods and
services give detailed thought to the needs of
people with disability, integrating measures to
ensure people's rights are met into the totality
of the policies, procedures and standards that
govern the activities of organisations seeking
to engage with the public. An 'access DCP' helps
to achieve this goal.
Secondly, we are broadly
supportive of the Objectives set out in Section
1.3 of the draft Access DCP. We propose,
however, a specific alteration to the third of
the specified objectives regarding housing
design and access. We do so mindful of the
announcement by the NSW Minister for
Infrastructure, Planning and Natural Resources
on 18th February 2004 that a discussion paper
would be forthcoming that may require all new
housing to be vistable and adaptable. We are
aware, also, that the Australian Building Codes
Board has commissioned research into the
provision of accessible new housing that is
highly likely to result in alterations to the
Building Code of Australia that go further than
the proportions set out in Section 5 of the City
of Sydney draft Access DCP.
Thirdly, we note that one
of the objectives set out in section 1.4 is "To
clarify the various standards, codes and
regulations and Acts with regard to their
requirements for both new and existing
development." It is not our intention to specify
appropriate references, alterations or
amendments to all the technical specifications
set out in Part 4 - Design Criteria. We suggest
that the City of Sydney Council commission an
external, accredited access consultant to ensure
that the access DCP accurately relates to the
most recent and current instruments that inform
the legislative requirements under Federal and
State laws.
We recommend to the City
of Sydney Council that its draft access DCP be
amended to incorporate the technical
requirements of the draft DDA Disability
Standard on access to premises published in
January 2004. It is clear that a broad consensus
has emerged around the requirements of the draft
DDA Disability Standard. There is a very high
probability that the federal Attorney General
will introduce the draft to parliament within
the next eighteen months to two years. It seems
prudent and desirable that the City of Sydney
Council recognise the context of developing
standards nationally. In short, we believe the
City should 'get ahead of the game'.
Fourthly, we wish to
comment on Section 4.2.10 Accessible Room
Requirements. We believe that the proportion of
units / dwellings / rooms proposed on page 20 of
the document will not ensure that real choice of
accommodation type will be possible for visitors
with disability to the city. We are especially
concerned that low cost accommodation will, to
all intents and purposes, remain
inaccessible.
We propose that 10% of all
dwellings / rooms / units with up to 100 beds be
at least visitable by wheelchair users. We
further propose that in all larger developments,
those with 100 beds or more, all rooms should be
visitable by wheelchair users. At least 10% of
all rooms in all developments of all sizes
should have shower and toilets that conform to
the appropriate Australian Standard for
accessible facilities.
Fifthly, we wish to
comment on Part 5, Adaptable Housing. We welcome
the acknowledgement by the City of Sydney
Council of the crucial role that appropriate
housing plays in the lives of people. Our home
is the base from which people develop the
relationships of fulfilled lives. The houses
that we plan and build today must meet the needs
of the population as a whole that we can
envisage in the future.
The effects of demographic
change over the next 50 years have been
discussed and documented by many agencies. It is
clear that our population is ageing. Over the
next twenty years the 'baby boomer generation'
will move into retirement. There will be an
irreversible shift in our population. More of us
will live longer. Almost all of us will 'age in
place' as the jargon puts it. That 'place' must
be a visitable and adaptable home.
At the same time as our
population ages, policies in favour of social
inclusion of people with disability mean that
more and more people with physical, sensory,
intellectual and psychiatric impairments will
live in the community than ever
before.
The NSW Government has
started to consider and plan for the
consequences of these predictable and
foreseeable social changes. We note that on 18th
February, Minister Knowles issued a statement on
SEPP5. We agree with his assessment that it no
longer meets the need of the state's population
of older people and people with
disability.
The NSW Minister's report
on SEPP5 includes this recommendation, page 4
(underline by the report's author)
"People with a
Disability and Accessible Housing - Prepare a
Discussion Paper to review methods of
achieving greater provision to allow public
debate on the issue
It is
recommended that:
1. A discussion paper
be prepared that should canvas options to
achieve from housing a greater level of stock
which is accessible and adaptable for people
with physical disability of all
ages.
2. Options could
include introducing new controls that
would require all new housing to be
accessible to the UK standards i.e. for
private path, entry, ground level circulation
space and visitable toilet that allows use by
a person with a disability
Some developers, such
as Masterton Homes, are to be congratulated
for already incorporating adaptable features
in their homes. This is recognition by the
market of the need to make housing more user
friendly for an ageing population and people
with a disability."
We are sure that the state
Government has realised that the time is now
here for all new private dwellings to be
visitable and adaptable. We agree with
them.
We believe that Table
4 in Section 5.3 Rates of Adaptable
Housing Units and Parking Spaces to be
Provided does not represent an adequate
strategy for meeting the housing needs of people
with disability and their families in the
decades ahead.
We must provide accessible
housing that makes living in the community a
reality. People with disability do not live in a
vacuum. There is a need to ensure that all new
houses in all communities allow people with
disability to fulfil the whole range of social
roles that we think of us normal: family member,
parent, grand parent, neighbour, colleague. To
make it possible for people with disability to
be active citizens and residents new housing
must not perpetuate the barriers of
inaccessibility of the past.
Finally, we urge the City
of Sydney council to re-constitute a standing
committee on access. It would play an
indispensable and valuable role in ensuring that
the access DCP will be as effective as all
stakeholders must surely hope it can
be.
Yours
sincerely,
David Brice
PDCN President
