Written evidence submitted by Fleur Perry [DPH 019]
Responding as: Disabled person; campaigner following bad experiences. I'd like to one day no longer need to campaign on the lack of accessible housing.
1. What can the Government do to ensure disabled residents across England have access to accessible and adaptable housing?
Build, adapt, and make affordable.
Build
Build some. It's that simple. We know the number of people who need accessible housing, and we can predict how many people will need accessible housing in the future. We have to build to match this.
Requiring M4(2) as the minimum standard (as promised) and 10% M4(3) (as is standard in London and has been for 18 years) would very quickly have an important impact.
Adapt
Fund the Disabled Facilities Grant at a level which meets the need. This will quickly save more than it costs (more below).
Make affordable
Encourage the building of affordable housing, for example by encouraging the use of pre-fab kit houses, which take less time and labour on-site and therefore will be cheaper even with developer's profit margins.
Examine the profit choices of developers to ensure they are within the law (I do not have the expertise to know).
Other measures outlined below.
2. Does the National Planning Policy Framework ensure the Equality Act 2010 is complied with when building housing?
No. The NPPF does not even mention the Equality Act in relation to disabled people. It needs to be changed to explicitly state that Local Planning authorities have a legal duty to pay due regard to the needs of disabled people under the Public Sector Equality Duty. Without this information, it looks like a recommendation, not a legal duty. If the Local Planning authorities are unaware of their legal duties, they are less likely to follow them.
Many do not. Research from the EHRC in 2018 shows how few were and as far as I'm aware, little has changed. I began to record how many Local Plans contained an M4(2) and M4(3) proportion requirement last year, but did not complete the project for health reasons. The majority did not require any accessible housing.
Equality and Human Rights Commission, 2018: https://www.equalityhumanrights.com/sites/default/files/housing-and-disabled-people-britains-hidden-crisis-main-report_0.pdf
Habinteg, 2019: https://www.habinteg.org.uk/localplans
It found that: “Less than a third of the local plans analysed set out a requirement to use current accessible housing standards.”
... and that: “just 1% of new homes outside London are set to be suitable for wheelchair users despite 1.2 million wheelchair users in the UK and a rapidly ageing population.”
New Local Plans are supposed to be checked by the Planning Inspectorate. Their role in ensuring that new Local Plans show due regard to the needs of disabled people needs to be highlighted and made accountable.
3. Since the Government consultation ‘Raising accessibility standards for new homes’ (July 2022), what has been done to improve housing provisions for disabled residents in England? And has it been sufficient?
To my knowledge, nothing has been done. The last I heard was a commitment to make M4(2) a minimum standard, but I have not seen this happen yet.
Just under Recommendation 114c: https://www.gov.uk/government/publications/disabled-peoples-rights-uk-2022-follow-up-report-to-uncrpd-2016-inquiry/un-committee-on-the-rights-of-persons-with-disabilities-2016-inquiry-uk-2022-follow-up-report
4. What role should the Government, Local Authorities and developers have for ensuring the delivery of suitable housing for disabled people?
Current situation: It’s a hustle. By building houses that do not match the accessibility needs of the population overall, developers are saving money, but harming the health and opportunities of millions, whilst creating an increased obligation on government to fund adaptations. They are passing a cost on to the taxpayer to fix their mess and hurting people.
Local authorities have a legal responsibility to make sure this doesn't happen, and that the housing built is matching the needs of the local population. This is not being done by many local authorities, and the developers are getting away with it.
Meanwhile, the government does not fund DFGs adequately, and this increases the costs to the taxpayer and harm to the public, as avoidable injuries need treatment, lost opportunities decrease participation, and impossible to use environments increase the need for social care. Further issues within social care and the NHS mean that people do not always get what they need, meaning further harm caused. All whilst developers make billions.
Proposal:
Make M4(2) the standard, as promised, and make it so that 10% of housing is built to M4(3). If local authorities or developers wish to build less M4(3), they should work together to produce the data showing why a lower figure will meet the needs of the local authority area.
Fund DFGs correctly (below).
Create an Accessible Housing Grant
There should be a government grant towards buying an accessible house, at the same level as a Disabled Facilities Grant, designed to cover the gap between the costs of an accessible property and an inaccessible property in the same area. Many disabled people cannot afford to buy a wheelchair accessible house even as a childless couple both in work and saving for a deposit. Having a grant available to make accessible housing as achievable to purchase as any other property would resolve this. Placing it at the same level as a DFG would mean that the couple could choose between buying somewhere to adapt, or buying something that's already ready.
The accessible housing grant should also be available to housing associations and local authority social housing teams, as well as NHS ICBs, so that housing can be purchased for individuals/families who are eligible, but are stuck on never-ending waiting lists.
The accessible housing grant would only require a note from a GP saying “Patient needs to use a wheelchair at home, or will need to in the next 3 years.”; or “Patient's current housing is not meeting their accessibility needs and is having a significant impact on their health, or will in the next 3 years.”; or similar from OT, wheelchair services or a specialist consultant.
This would resolve the issue often raised by developers “Wheelchair users don't buy them because they're expensive, so why should we build them?”
Remove barriers to accessible social housing
Work with local authorities to identify and remove barriers to accessible social housing, for example removing minimum residency requirements in cases where a person is living in an inadequately accessible home due to acquiring a disability after moving in/moving into an inaccessible property because they could not find/afford an accessible house, or where their health is being or will be impacted by their unsuitable housing.
Another barrier is minimum age requirements on accessible social housing: the criteria should be based on a person's accessible housing needs, not their age, as this blocks younger disabled people from moving into accessible housing.
5. Does the Disabled Facilities Grant fully support housing adaptations?
No.
The DFG amount is far too low to cover major works such as an extension/annex to be built to allow a wheelchair user to have a bedroom and bathroom they can use in the event that a stairlift/platform lift cannot be installed. This is a common issue.
Change the amount of the maximum Disabled Facilities Grant to a more appropriate amount. It was last changed in 2008 to £30,000. However, using the Bank of England's inflation calculator, the same goods and services would now cost over £46,350. In effect, by not tracking inflation, the grant's value has been cut by more than a third without anyone making this decision. Please remedy this.
https://www.legislation.gov.uk/uksi/2008/1189/contents/made
https://www.bankofengland.co.uk/monetary-policy/inflation/inflation-calculator
This was promised in December 2021, but has not yet happened.
“The upper limit to the Disabled Facilities Grant - which funds adaptations to people’s homes – is set to be increased alongside an unspecified amount of funding for a new service to make minor repairs and changes to people’s home.”
£300m fund to boost supported housing announced in social care reforms | News | Housing Today
6. How can the Government ensure it provides sufficient provisions to support disabled residents who do not live in new build homes?
Bring back the Warm Homes and Decent Homes grants. Disabled people are less likely to be able to afford to install loft insulation or make repairs, and the knock-on impacts on health are more likely to be significant. New housing already has good insulation etc., and so these are issues that disproportionately affect disabled people living in older housing.
Reinstate funding for homelessness prevention support.
Make home ownership more accessible to disabled people.
Accessible housing, being mostly new and of good quality, may be financially out of reach for many disabled people and their families. To maximise the benefit of building accessible housing, we have to make sure that disabled people can move into those properties. Some ways of doing this include:
- encouraging the financial sector to innovate and offer mortgage/renting products that offer the opportunity to buy a percentage of their home in a flexible way, with no penalties for stopping buying further amounts. For example, a person living in a £150,000 house may not be able to afford a mortgage for that amount, or even 25% of it. But, if they paid their rent weekly and an extra £150 whenever they could afford to do so, they could gradually increase the share of the property they own, 1% at a time, and reduce their rent proportionately. If a payment was not made, then the percentage owned simply does not increase at that time, meaning that there is no risk of the person losing their home. Given the savings limit on many in work and out of work benefits, this would remove the barrier of being unable to save a large deposit.
- Make it easier for those living in rented accommodation from individual landlords to buy their accommodation. Housing Association and council properties have Right to Buy, but there is nothing similar in the private rented sector.
- Allow disabled people receiving benefits to save for essential equipment, support, and accessible housing. In many areas of the US, people can open an ABLE account, which can hold savings that are excluded from financial assessments for social security benefits. The money can only be withdrawn for specific purposes, including purchasing accessible housing. Family, friends, etc. can contribute to a person's ABLE account to get them to their goal.
7. What can the Government do to support disabled tenants in the private rented sector?
Remind landlords of their duties regarding DFGs.
September 2023