Three of the five things a Design and Access Statement must do are about access

I went and read the statute rather than the guidance about it - and the split surprised me.

A Design and Access Statement isn't a document with an access paragraph in it. Under the law that creates it, access is most of the job.

Here's the article, and then what it means for the section you're probably writing in a hurry at Stage 3.

What article 9 actually says

The requirement lives in the Town and Country Planning (Development Management Procedure) (England) Order 2015, article 9. England only - Wales, Scotland and Northern Ireland run their own regimes.

Article 9(3) lists five things the statement must do. Two are about design:

Explain the design principles and concepts applied. Demonstrate the steps taken to appraise the context, and how the design takes that context into account.

The other three are these, verbatim:

9(3)(c) - explain the policy adopted as to access, and how policies relating to access in relevant local development documents have been taken into account.

9(3)(d) - state what, if any, consultation has been undertaken on issues relating to access to the development, and what account has been taken of the outcome.

9(3)(e) - explain how any specific issues which might affect access to the development have been addressed.

Three of five. Not an appendix, not a paragraph near the end. Three of the five statutory content requirements.

Which also means a statement with a thin access section isn't merely a weak statement. It's one that might not meet 9(3) at all - and that's a validation problem, not a planning one. It can come back before a planning officer has looked at the scheme at all.

First, check you need one

Worth saying - because I'd rather talk somebody out of a document they don't need.

Under 9(2) a DAS is required for major development, or, in a conservation area or World Heritage Site, for one or more dwellinghouses or a building of 100 square metres or more.

It isn't required for section 73 applications, engineering or mining operations, material change of use, or waste development.

If your scheme doesn't trigger that, you don't need one. There's often still an access case worth making, as a standalone statement or inside a Heritage Statement for listed building consent, but it isn't this.

9(3)(c) has two halves and the second one gets skipped

The first half is the policy you've adopted on access. That's a position, not a features list. One inclusive entrance everybody uses. Level thresholds throughout. Step-free access to every storey the lift serves.

Write it as a commitment - because a commitment is the thing that can be held to later. "Level access is provided" is checkable. "Consideration has been given to level access" is not, and an officer can tell the difference instantly.

The second half is how local policies on access have been taken into account - and that one can't be boilerplate, because it's specific to the authority.

So somebody has to open the Local Plan and find the inclusive design policy. Then check for a supplementary planning document on access. Then read the validation checklist, which is where the local expectation actually lives. Then quote the policy number.

A planning officer looking for their own policy reference and finding it is the difference between a quick read and a query. Reusing the last scheme's references for a different council is the fastest way to get one.

9(3)(d) is the weakest section in most statements

It asks what consultation happened on access, and what account was taken of the outcome.

The usual answer is nothing - written to sound like something. "The design team has considered accessibility throughout." That isn't consultation, and an officer has read that sentence a hundred times.

What counts is narrower. A disabled people's organisation or access group consulted on the scheme. An access consultant engaged, and at what stage. User testing, or a disabled panel. Pre-application discussion with the authority's access officer, where there is one.

Then the half that actually matters: what changed.

"We consulted X" is a statement. "We consulted X, who raised the approach from the car park, and the drop-off moved from the service yard to the front elevation as a result" is evidence that the consultation was real.

And if nothing changed, say what was considered and why it wasn't adopted. An honest account of a rejected option reads as a real process. Consultation where nothing moved reads as a tick box, because it was one.

There's a practical point for architects in that. If you bring somebody in at Stage 2 or 3, that engagement is your answer to 9(3)(d). The fee isn't only buying advice - it's filling in a statutory requirement that's otherwise going to be written as a sentence nobody believes.

9(3)(e) is where most statements stop too early

It asks how any specific issues which might affect access have been addressed. It's deliberately open - and that's the problem. An open question invites a short answer.

The short answer is usually Physical - and nothing else. Door widths. A lift. An accessible WC. Done. That addresses some specific issues, which leaves an officer with the obvious follow-ups unanswered.

What it should work through is the journey somebody actually takes.

Arrival and approach: bay numbers and the access zones beside them, the setting-down point, the route from public transport, gradients, what the surface does underfoot.

The entrance: which door disabled people use, and whether it's the same one as everybody else. If there's a revolving door or a security line, where the accessible alternative sits and whether it's immediately adjacent or round the corner.

Circulation: corridor widths, turning space, lift car size, and what happens at a dead end.

Sanitary provision: the wheelchair-accessible unisex toilet, the ambulant cubicle that gets forgotten, and whether a Changing Places is required. Since 1 January 2021 that's an Approved Document M requirement for certain buildings above threshold, and since 1 October 2024 Approved Document T governs toilet accommodation too.

Means of escape: refuges, evacuation lifts, and the plan for people who can't use stairs. It belongs here even though it's a Part B matter - because it's the question an officer won't ask and a disabled occupant will.

And then the three nobody writes about. Lighting and contrast. Hearing enhancement at reception and in any assembly space. Wayfinding logic, which is the one that decides whether somebody arrives at your building able to do the thing they came for. PAS 6463 is the reference for sensory and cognitive design, and citing it marks a statement out immediately, because almost nobody does.

Last, how inclusive access is maintained over the building's life. Who tests the hearing loop. Who keeps the refuge clear. Good guidance expects it - and it's the paragraph that separates a serious statement from a compliant one.

Why I care about this more than I probably should

Because the access section is where a building's intentions are written down before it exists, and because I'll be the one finding out later whether they were true.

A statement says level access is provided. The building has a ramp to a side door by the bins. That gap was designed, agreed and signed off - and then I arrive and find it. That paragraph was the last point at which it was cheap to fix.

Three of five. If you write those three properly, the building is better - and the statement is stronger. If it helps to see one, I've written a full worked example against an invented scheme. If you write them as one paragraph at the end, the law hasn't been met and neither has anybody else.