Advocates for universal design features in all new homes are nervous. State and territory building ministers will be making a decision on whether to make access features mandatory. Industry is advocating for no change to the building code. Some states claim they are already addressing the problem of accessible housing through piecemeal planning policies. Others think it’s something the NDIS is doing. Regardless, we need all new homes fit for purpose.
What will sway the politicians when they meet and vote on this in March? Will it be the evidence? Will it be the lobbying from industry? Will it be the lobbying from advocacy groups? Or will it be the voice of the people from a public petition?
Petitions are about people power. This is a one-time opportunity to sign the petitionto give everyone a better chance of staying at home regardless of age or ability.
Every new home built today has a 60 percent chanceof having an occupantwith a disability. Moreover, more than 30% of households currently have a person with disability – and this affects all members of the household. And it’s not just about people who use wheelchairs – it’s a mainstream issue.
Signing up to a United Nations (UN) convention isn’t just a feel-good affair. It actually brings obligations with it. That means reporting on a regular basis to the relevant UN committee. In Australia, the Commonwealth Attorney General’s Department is responsible for the government reports on the Convention on the Rights of Persons with Disabilities. But it isn’t all up to the government. People with disability must also be involved. Their reports are known as “Civil Society Shadow Reports”. This is where the story gets interesting when it comes to housing.
The Australian Building Codes Board is looking at options to include universal design features in the National Construction Code. It’s using a cost-benefit analysis framework. But if we are to meet our UN obligations, we cannot allow cost, if any, to be the barrier. If we argue that rights cannot be afforded we are saying that people with disability cost too much.
Abstract :The United Nations Convention on the Rights of Persons with Disabilities (UNCRPD) obliges Australia, as a State Party, to embrace the concept of universal design as a guide for its activities. The UNCRPD triggered significant changes in the last decade directed by the 2010-2020 National Disability Strategy (the Strategy), with its vision for an inclusive Australian society that enables people with disability to fulfil their potential as equal citizens. This paper reviews Australia’s national and international reports on these obligations over the last decade focusing on Australia’s response to the Strategy’s commitment in 2011 to support the ‘National Dialogue agreement’, a self-regulatory approach to incorporate universal design in housing. It argues that both the Australian government and the housing industry largely disregarded the National Dialogue agreement, and misrepresented to the United Nations the progress made in achieving accessibility within the housing stock. It evidences the importance of advocacy and a direct line of communication to the United Nations from people with lived experience, something the United Nations relied on to discover that the National Dialogue agreement had failed. Given this past disregard and willingness to misrepresent the facts, the Australian governments will need to be monitored closely in the consideration of a minimum access standard for all housing in the National Construction Code. The question remains whether a net benefit to society will be found to be of greater priority than the self-interests of the private housing sector and the political vagaries of government. Again, it will take the voice of people with lived experience and those who represent them to make the argument.
Across the globe, older people want to stay put as they age. They do not aspire to residential care and are also moving away from the retirement village model. But are our planners, designers and builders listening? COVID-19 pandemic is also challenging established policy about where older people want to live.
“Encouraging older people to age in place in their own homes is a common response internationally to the economic and social demands of population ageing. It is recognized that the nature of the built environment at various scales is critical to optimizing the social participation and wellbeing of older people and hence in facilitating ageing in place. This insightful book showcases a range of design, planning and policy responses to ageing populations from across the rapidly changing and dynamic Western Asia-Pacific region.
Ageing in Place considers diverse cultural, political and environmental contexts and responses to show that regional governments, industries and communities can gain, as well as offer, important insights from their international counterparts. With significant changes in caring, family dynamics and the supporting roles of governments in both Eastern and Western societies, the chapters demonstrate a clear and increasingly convergent preference for and promotion of ageing in place and the need for collaborative efforts to facilitate this through policy and practice.
The unique geographical focus and multi-disciplinary perspective of this book will greatly benefit academic researchers and students from a variety of backgrounds including architecture, urban planning, sociology and human geography. It also provides a unique entry point for practitioners seeking to understand the principles of design and practice for ageing in place in homes, neighbourhoods and care facilities.”
The book is edited by Bruce Judd, Emeritus Professor, City Futures Research Centre, University of New South Wales, Australia, Kenichi Tanoue, Professor, Department of Environmental Design, Faculty of Design, Kyushu University, Japan and Edgar Liu, Senior Research Fellow, City Futures Research Centre, University of New South Wales, Australia.
Australian Network for Universal Housing Design (ANUHD) update has important information about the continuing work for regulating (or not) universal design features in all new housing. This update is about the extra work done after the close of submissions on the Consultation Regulation Impact Statement. The advice to government is to adopt Gold level of the Livable Housing Design Guidelines. Here is the information from the ANUHD newsletter.
Melbourne Disability Instituteand Summer Foundation submitted a response to the Consultation RIS for accessible housing with the recommendation that, based on the independent assessments and research they commissioned, Governments adopt Option 2, that is to regulate to Livable Housing Gold Level in the National Construction Code, as the benefits clearly outweigh the costs. The independent assessments and research are:
REVIEW OF THE ECONOMIC REPORT The review identified four key issues that individually have a large impact on the benefit-cost ratios reported. Taken together, they totally reverse the economic credentials of the regulation.
SURVEY OF PEOPLE WITH DISABILITY This extra data aligns with the advice from the Office of Best Practice Regulation to include qualitative analysis in all Regulatory Impact Statements, particularly when important elements cannot be quantified or monetised.
AUDIT OF ACCESSIBLE FEATURES This study found that many accessibility features are already incorporated into the most popular house designs being built in Australia, but not in a systematic way. It also demonstrates that accessible features are basic elements of good house design for the general population, and indicates that the likely cost of including further accessible features to be fully consistent with the accessibility standards in new builds is very low.
SUPPLEMENTARY REPORT MDI and the Summer Foundation prepared further information for the ABCB on 6 October 2020 to substantiate their position that that governments should adopt Option 2, which would set minimum mandatory standards for accessible housing at the Gold (LHDG) standard.
CUDA and ANUHDmade comprehensive submissions to the Consultation Regulation Impact Statement.
Consumers buy things that they want and need now rather than purchasing things with the future in mind. Well, that makes sense. For everyday items this poses no problems. But for expensive, longer lasting items, such as a home, it can be a problem. Many older Australians live in a home that was purchased in mid life. It was suitable then. But now that cherished home is challenging their independence in older age. That’s why all homes should have universal design features.
A new report based on a survey of care-givers, both paid and unpaid, provides insights into their experiences and observations on the impact of home design on their caring role. The researchers found that housing design features and proximity to amenities had a value that extended beyond those of residents. That is, it facilitates community capacity and social engagement, physical wellbeing and ease of providing care services.
The executive summary concludes with a statement that supports universal design in housing for people to age well:
“The public value implicit in universally designed housing is conceptually demonstrated by associated increases in ageing well outcomes and reduction in the need for, the level of, and the time spent on, care to support positive ageing outcomes (ie. generating efficiency gains in achieving ageing well outcomes).
The key findings of the study include:
Universal design features impact on the level of care needed to support ageing well.
The location of the home and access to amenities also has an impact on the level of care needed.
The time needed to support people with basic living activities is reduced.
The study was undertaken by RMIT University and the Longevity Group Australia.
Abstract:In this report, we explore the public value implicit in housing incorporating universal design principles. Value is conceptually demonstrated by identifying housing design and location attributes, associated with increases in ageing well outcomes via the reduction in the need for, the level of, and the time spent on care to support ageing in place. To do this a survey instrument is developed to capture the experiential knowledge of in home care service providers and their observations of the impact of the home on the ageing well outcomes of the seniors they care for and also on their capacity to provide care. We find that certain housing design and location feature have value that extends beyond that experienced solely by its residents, facilitating community capacity and social engagement, physical wellbeing and ease of delivery of public services such as care support.
What is so difficult about including universal design features in all new housing? Is it cost? Is it technical difficulty? The answer to both is, no. Perhaps this is more about a regulation ideology. The Housing Industry Association (HIA) has a policy statement that says as much. But do they have a case to continue that position for universal design in housing?
In 2006 when the HIA policy was written (and ratified again in 2018) we hadn’t signed up to the UN Convention on the Rights of Persons with Disabilities. We didn’t have a National Disability Strategy or Livable Housing Design Guidelineseither. But other businesses are recognising their ethical obligations for equity and inclusion and that inclusion has a strong business case. And here is the difference – the housing industry is a fragmented system that relies on regulation to hold all the parts together to guarantee consistency and certainty. Consequently, nothing will change without regulation.
So, should we have regulation for all new homes to have universal design features? To answer this question the Australian Building Codes Board commissioned a cost benefit analysis.It concluded that costs outweighed benefits. Even if it did cost more, is this a reason to continue building homes as if we are never going to grow old?
In responding to the cost benefit analysis, two camps emerged. The community and academic sector claimed the cost benefit analysis was skewed in favour of costs. Consequently the cost argument doesn’t hold. The housing industry continues to prosecute a cost argument as a basis for the status quo to remain. So who will decide the outcome? It will be a political one made by a sub committee of COAG – the Building Ministers’ Forum.
Key submissions to the ABCB
You can check out some of the submissions to the Australian Building Codes Board:
Property Council of Australia supports information and education initiatives for consumers. “If the additional costs laid out in this submission were estimated and included, this would reinforce the negative cost/benefit ratio outlined in the RIS.”
CUDA supports Gold level of Livable Housing Design Guidelines and questions whether a cost benefit analysis was the right approach to answer the object of the project, “To ensure that new housing is designed to meet the needs of the community, including older Australians and others with mobility limitations.
Editor’s note: The HIA’s policy statement focuses on wheelchair users and this is common in the industry. It also ignores all other disabilities and long term health conditions, and that we are talking about families. Consequently, they see this as a responsibility for government, not the market. They argue, “The overwhelming majority of private homes will not be used, now or in the future, by people requiring wheel chairs [sic]”. This statement also ignores the human right to visit your friends and family.
Time has come for the housing industry to catch up with the rest of society. Inclusion and diversity are now recognised as Australian values. Discrimination still exists of course, but many sectors, business and government, are striving to do better. That means designing products and services to embrace population diversity. However, the housing industry continues to resist change. They say it will substantially increase the cost of building a home. But how much is “substantially”.
One of the reasons the housing industry says it will cost more is because level entry is difficult to achieve on a steep slope. This can be true, but that is no reason for no change at all. Exceptions would be made for one-off situations. Besides, mass market housing in a greenfield site is rarely on a steep slope – these are not favoured by developers. That’s because it cuts down on building efficiency. But any excavation needed benefits builders too.
The Australian Building Codes Board (ABCB) is asking for people to comment on their consultation document on Accessible Housing. This is a difficult read. It is a very long and convoluted way of concluding costs outweigh benefits. However, the wrong question was researched. It shouldn’t be, “can we afford to make changes?” It should be “we need to make changes, what’s the best way to make it happen?”
Fortunately, two eminent economists responded to the call to comment and they have concluded the opposite. The benefits outweigh the costs. Also dense reading but the document challenges the ABCB document at every point. They also conclude that Gold level of the Livable Housing Design Guidelines are not only beneficial to the community but they offer the best value overall.
You can respond with your story of how the design of your home, or that of a family member, has impacted their life. Good, bad and ugly stories are welcome. Send an email to Kieran O’Donnell at the ABCB. Every story counts. Like a picture, it paints a 1000 words for politicians.
Just because accessible features make sense to most of us, do not assume it is a done deal. We still need grass roots action.
Australia Cannot Afford NOT to Build Accessible Homes, gives an overview of why we must mandate universal design features now. We’ve had ten years for Livable Housing Australia to show that it can do this voluntarily. It has failed. It’s time for them to come good.
The Australian Network on Universal Housing Design (ANUHD) has advocated for universal design in housing for almost 20 years. Finally the Building Ministers’ Forum (part of COAG) agreed to look at the issues. This has been done in the form of a cost-benefit analysis. ANUHD has shared their draft response that contains all you need to know to respond with a submission.
The Australian Building Codes Board results are reported in a Consultation Regulatory Impact Statement(RIS). Bottom line? Costs outweigh benefits. However, this is not the end of the story. But it is a complex one. The Silver and Gold levels of the Livable Housing Design Guidelines formed the basis of the cost benefit analysis.
ANUHD has prepared a comprehensive draft responsefor sharing. Disability and ageing advocates, housing advocates, housing designers and policy makers can use this as a guide for their own submissions. It will help with finding the way through the complexities.
If you are confused as to why we are still fighting for accessible homes, the answer is in a short policy document from the Housing Industry Association.
The RIS is supposed to include qualitative data, but has failed to do so. The University of Melbourne is filling this gap. You are asked to complete a survey by 26 August so they can get the data submitted by the closing date 31 August..
ANUHD has lobbied for a more inclusive and accessible process to make submissions. This is because the process is geared towards the housing industry rather than home occupants or community advocates. The concession is that individuals can send their personal experiences by email to Kieran O’Donnellat the Australian Building Codes Board.
Personal stories are very important. They will add the missing information in the cost-benefit analysis. The cost benefit analysis significantly contradicts the costs of UD features calculated by Livable Housing Australia – an industry body. They found there was little, if any, extra cost.
You can find out more on the history of this project by using the search term “ABCB” in the search box on this website. A previous post on the costs and benefits has all the links for information and how to respond.
“Accessible” housing is more than wheelchairs and mobility for occupants and visitors. However, this is the perspective that the Australian Building Codes Board (ABCB) has taken to its consultation paper on theproposal to include accessibility features for housing in the building code. This approach does not consider the broader picture for individuals, families and the community. This matters because it has to do with costs, who pays them and how they are measured.
A cost benefit analysis is an economic exercise. It does not measure outcomes. And because outcomes are a bit harder to measure, they often get left out. However, the change to the building code for public adult change toilets did measure more than the cost of the building. So it can be done.
The Consultation Regulation Impact Statement (RIS) recommends no changes to the building code based on costs outweighing benefits. The calculations were based on the Silver and Gold levels of the Livable Housing Design Guidelines that were established in 2010. These voluntary Guidelines were devised by the housing industry and drafted to minimise any extra cost.
The RIS provides options other than Silver or Gold level of the Livable Housing Design Guidelines. CUDA and the Australian Network for Universal Housing Design recommend Option 2, Gold level, as being the most workable minimum with the greatest benefit for the cost. What is really clear is that voluntary guidelines have failed to make the change happen. That’s why we have the push to make them mandatory.
The Consultation Hub has all the documents related to the project at the bottom of the page. Documents are provided in PDF and Word. They include the cost benefit analysis, and a preliminary draft for the building code should changes be approved.
Note that in the preliminary draft for the building code they have reduced the doorway widths and step free doorways. They have deviated from the Livable Housing Design Guidelines. Of course if you can’t get in or out then any other features are a waste of time.
The idea of universal design in housing is not new. In spite of academic research proving the need for it, and practice guidelines based on real lives, we are still a long way from achieving access for everyone at home. With the Accessible Housing Consultation Regulation Impact Statement(RIS) out for comment, I thought it useful to pull together a few resources on housing.
There is more on the RIS in a related post, UD in housing: Beyond wheelchairs. The consultation process is not inclusive or accessible unless you are an industry stakeholder. But you can send your story to Kieran O’Donnell at the Australian Building Codes Board by email.