Written evidence submitted by Chartered Institute of Housing (CIH) [DPH 020]

CIH welcomes the opportunity to respond to the committee’s call for evidence. CIH is the professional body for people working in housing. We are also a founder member of the Homes Made for Everyone (HoME) coalition, a group of nine charities and NGOs working together to make the case for more accessible and inclusive housing to meet the wide range of needs of disabled and older people living with a range of impairments.

Introduction

Having a safe and decent home that is suitable for our needs is fundamental to health and wellbeing and living a good life. However, not all disabled people are able to find such a home. Currently the mandatory standard of accessibility in housing is a low one, including only some basic accessibility features, such as wider doors, that makes a home ‘visitable’ rather than liveable. The number of homes that are accessible, or easily adaptable are severely limited. However, 14.1 million people or 21 per cent of the UK’s population is disabled, including a significant increase in people of working age and children within that figure. In 2019-20, 53 per cent or 1 million households did not have the adaptations they needed in their homes. The most acute housing shortage is for people requiring wheelchair adapted homes; Habinteg Housing Association estimate that about 400,000 people requiring such housing are stuck in unsuitable homes.

What can the government do to ensure that disabled people across England have access to accessible and adaptable housing?

The government made a welcome commitment in July 2022 to make the higher accessible and adaptable standard mandatory for all new homes built, with limited exceptions (Building Regulations Part M 4 (category 2), similar to the previous Lifetime Homes Standard).  This will ensure that homes have more measures to make them easily adaptable as people’s needs change, more quickly and with less cost. Requiring all new homes to be built to this standard creates a level playing field for developers, so that none are disadvantaged by agreeing to incorporate this standard as currently, which often leads to challenges to local authorities’ requirements on grounds of viability.

However, no progress on enforcing this has been made since that date, so we are still seeing new homes proposed and completed that incorporate only minimum measures, being added to the existing stock of homes of which already 91 per cent have only basic features that make a home visitable rather than liveable.

Government should bring in Part M 4 (2) without delay and ensure that there are stringent criteria for any exception allowed. This would enable local planning authorities to focus on identifying and meeting the need for fully accessible wheelchair homes in their area. Government should strengthen requirements in the NPPF that local planning authorities assess and make provision for fully wheelchair accessible homes; where this is lacking in local plans, there should be a minimum mandatory provision (for example 10 per cent of new homes) that is required.

Homes England’s funding of social, affordable and low-cost home ownership schemes should also incentivise the inclusion of wheelchair accessible homes to address identified need.

The government should also work with local authorities and marketing agencies such as Right move/ Zoopla etc. to develop a consistent way to identify and market wheelchair accessible homes, to help people to identify suitable homes more easily.

Does the National Planning Policy Framework ensure that the Equalities Act 2010 is complied with when building housing?

The NPPF could have a stronger approach to ensuring the Equalities Act requirements are met when planning for housing and neighbourhoods.  No direct reference to disabled people or wheelchair accessible housing is made at all, and a foot note reference to the current optional standards seems to indicate the need for accessible and adaptable homes, rather than explicitly addressing wheelchair accessible homes (footnote to paragraph 130 (f)). The connection between accessible homes and safe and accessible neighbourhoods is critical for disabled people and should be highlighted within the NPPF.

The guidance note on housing for older and disabled people needs to be strengthened in requiring local authorities to assess and plan for the needs for older and disabled people. When the higher accessible and adaptable standard is brought in, this guidance should focus more directly on requirements to assess the needs of fully wheelchair accessible housing and housing choices for older people, including level of provision required and potential locations identified within the local plan.

There should also be clear expectations about the involvement of older and disabled people in the consultation process for local plans. The Planning Inspectorate should require assurance on that involvement, as well as appropriate action taken to identify and meet needs for wheelchair accessible homes, and develop accessible local neighbourhoods through the local plan.

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? Has it been sufficient?

There has been no further action since the government announced its commitment to raising the mandatory level to the accessible and adaptable standard. No other local areas have indicated taking action in advance of this and so the impact on provision is likely to be minimal, if at all.

Research by Habinteg into local plans in 2020 identified overall a slight decrease in the number of homes required to meet accessible standards planned for delivery between 2020 and 2030; from 34.4 per cent in 2019 to 31.5 per cent in 2020. Only 1.5 per cent of homes planned outside London will be wheelchair accessible. A third of local planning authorities still lacked any policies on the current optional accessible homes standards.

Without the mandatory requirement to build homes to the higher standards, requirements set in local plans are likely to continue to be challenged by developers, and local planning teams often lack resources and capacity to tackle this.

Local planning teams are significantly overstretched, with reductions in government funding since 2010. The National Audit Office identified a real terms reduction of almost 38 per cent in expenditure on local planning functions between 2010/11 and 2017/18. The COVID-19 pandemic saw increased demand for planning services and a growing backlog, which has led to difficulty in retaining sufficient staff (CIPFA/ Institute for Government Performance Tracker 2022/23). The need to step up housing delivery significantly overall is likely to require additional resources and funding for local planning teams, albeit the introduction of the mandatory will help by enabling teams to focus on identifying and meeting needs for wheelchair accessible homes.

What role should government, local authorities and developers have for ensuring the development of suitable housing for disabled people?

In addition to implementing its commitment to raising the accessibility standard for all new homes as above without further delay, the government should set out a long-term plan for housing setting out how it will deliver the number of homes needed over 10-15 years. This should include a focus on the provision of accessible wheelchair homes and specialist housing to meet needs.

Investment in social housing through Homes England should incentivise provision of wheelchair accessible housing to meet identified local needs (across social, affordable and low-cost home ownership tenures). Homes England should prioritise schemes that deliver such homes, mirroring the approach taken in London.

Local authorities should be required to develop local housing strategies and needs assessments for wheelchair and specialist housing, linked with the development of accessible neighbourhoods and connecting with accessible transport in local plans. The strategies should also connect with integrated care strategies to ensure access to appropriate services, identifying the health and social benefits of suitable housing for disabled people and wider public services (evidence of this to be fund in the recent report by LSE, commissioned by Habinteg: Living not existing: the economic and social value of wheelchair user homes).

The local housing strategy and plan should include a clear target for accessible housing to address identified needs; where this is lacking there should be a baseline requirement set by government (e.g. 10 per cent) to ensure the step up in delivery of new wheelchair accessible homes.

Local authorities should actively involve disabled people within the consultation on developing local plans. Support on approaches to this are provided in event planning guidance provided by the Equalities and Human Rights Commission (2018).

Local authorities and social housing provider partners should work together to ensure that allocations and lettings policies provide support and maximise the best use of existing homes, mapping out the location of wheelchair and accessible homes in the local area, to enable development of a local and national database to support households to find appropriate housing more easily (introducing/ building on accessible housing registers). The Equalities and Human Rights Commission previously produced guidance on allocations.

Developers should prepare for the new mandatory standards before it comes into effect. They could work with accessibility experts to ensure that they incorporate the standards appropriately in plans and build designs. Accessibility does not have to equate to clinical or medical design, and developers should ensure they address this in their designs, which will also tackle misconceptions amongst potential buyers.

Developers should work with government, local authorities and marketing platforms to identify accessibility features and target marketing appropriately. Marketing material, hoardings, etc should feature disabled people in a positive way to raise awareness of the inclusion and value of accessible homes.

Does the Disabled Facilities Grant fully support housing adaptations?

The Disabled Facilities Grant is a significant investment from government. In 2016/17 it received a large increase in funding (79 per cent) reflecting the rising demand for adaptations, the role of adaptations in supporting people to be successfully discharged from hospital, and the economic and social benefits from spending to save (reducing or preventing further increases in demand for health and care services).

However, due the ageing population and more people living with life limiting conditions, the disabled facilities grant (DFG) funding is still severely stretched. Coupled with that, in some places the process of using DFGs to access adaptations can still be a lengthy and protracted one, in spite of improvements being made in many areas. Growing numbers of older people with limited assets and living in private rented homes means that the level of demand for DFGs will only increase (ONS, Living longer: implications of housing tenure in later life, 2020).

Not all people are eligible for DFGs; ONS analysis of the English House Survey of 2019-20 identified that at 63 per cent, middle income households were most likely to be lacking necessary adaptations compared to lower and higher income households. The issue for such households is often not only funding but also help to identify suitable solutions and access reliable trades people. Solutions for households that are ineligible for DFGs should include information and advice and support to undertake adaptations as well as funding solutions, where their wealth is locked in their homes.

How can the government ensure it provides sufficient provisions to support disabled residents who do not live in new build homes?

In addition to increasing funding for DFGs as above, the government should look to support the provision of information and advice and support for disabled and older households to access adaptations. Mapping out and expanding the provision of handy person services, home improvement agencies, access to reliable mechanisms to unlock housing assets – all of these measures would help people to undertake appropriate adaptations. The good homes hub model, developed by the Centre for ageing better’s Good Homes Inquiry, has potential to do this, if replicated across the country.

In social housing, the new proactive consumer regulations will involve expectations that social landlords cooperate and support tenants to access adaptations, and make best use of their existing adapted homes when allocating and letting properties. This should be underpinned by a local and national accessible homes register.

What can the government do to support disabled tenants in the private rented sector?

The NRLA developed guidance to encourage its members to support tenants who required adaptations. This identified the potential for DFGs not only to provide the adaptation but also to restore the property to original condition once the tenant had moved. This would require a further investment to DFGs to enable this to happen, but is offset by the value for tenants being able to access adaptations to help them live safely. However, work by government and local authorities to develop cross tenure accessible housing registers would enable landlords to find tenants more quickly that could make use of some of the existing adapted features as an alternative to removal.

The government has recently reviewed the health and housing safety rating system, and is reviewing its decent homes standard with the aim to apply this across social and private rented sectors. It could use this review as an opportunity to require landlords to work cooperatively with tenants and local authorities to access DFGs and adaptations. The government should also work with local authorities to ensure that landlords and tenants are aware of the right to request adaptations to common parts as well. The model of a good homes hub or other clear single place for help, information and advice would be beneficial for disabled people living in all tenures.

About CIH

The Chartered Institute of Housing (CIH) is the independent voice for housing and the home of professional standards. Our goal is simple – to provide housing professionals and their organisations with the advice, support, and knowledge they need. CIH is a registered charity and not-for-profit organisation. This means that the money we make is put back into the organisation and funds the activities we carry out to support the housing sector. We have a diverse membership of people who work in both the public and private sectors, in 20 countries on five continents across the world.

September 2023

5