Written evidence submitted by Mrs J Hewitt [DPH 037]
The questions have been completed with insight and support from accessibility colleagues at Buro Happold and across wider industry networks, from people who actively work within the housing sector and see first-hand the issues created by inadequate housing for individuals and families with a wide range of impairments and disabilities. We are generally frustrated by the lack of attention to this important area and the inevitable negative and life changing impacts it has on individuals needing suitable homes as well as the impact on vital support services such as healthcare providers, who often need to accommodate and support people as a result of the lack of suitable housing at times when it is most needed.
a) Amend building regulations to mandate M4(2) as the minimum standard and include a mandatory % provision for M4(3) unless a council provides robust evidence why this is not needed, rather than relying on planning authorities to impose this through policy.
b) Amend terminology relating to adaptable and accessible dwellings as the current wording is still confusing to many designers.
c) Add flexibility into all housing stock to allow for later adaptability beyond M4(2) (for example, the ability to modular additions.
d) Establish a cross party task force to agree the housing strategy for disabled people and engage with disabled people direct.
e) Establish a national entity to provide consistent and clear cross tenure advocacy and support, led by disabled people and supported by housing professionals and occupational therapists specialising in housing and others experienced in housing adaptations and needs. Services should include supporting people to find and apply for accessible or adaptable housing in the right area as well as how to adjust or adapt existing homes.
f) A register should be kept of accessible homes addressing the issues identified in the EHRC 2018 report ‘ Housing and Disabled People: Britain’s hidden crisis’. This is essential to ensure accessible properties are let to people who need them most which is a particular issue that Landlords seem unable to address through lack of knowledge.
g) Influence, fund, promote and embed education on living with a disability into housing courses, to ensure developers and designers understand the complexities and demand and are able to interpret, build and appropriately market accessible homes going forward, including the information that should be provided to an accessible housing register.
h) Review the DFG and LA funding for experienced Housing Occupational Therapists who understand the barriers people face and ensure the LA is informed by robust evidence on the need for more accessible housing and can be involved in the provision of new build housing to ensure it meets these needs.
i) Ensure LAs have sufficient resources to assess and influence the provision of wheelchair-accessible accommodation across a variety of tenures (see also h above)
The 2019 Parliamentary Inquiry into Housing for Older People and the 2021 Centre for Ageing Better’s Good Home Inquiry have mostly not been acted upon but remain highly relevant.
(See also 1a)
Amend NPPF to make M4(2) as the minimum standard and include a mandatory % provision for M4(3) as the default planning policy.
Very little perceived progress – of particular concern is the delay in implementing the changes to mandate M4(2) and continuing lack of M4(3) housing, as well as the absence of the Part M Research findings.
a) Give transparency by sharing research in this area (especially the Part M research) and giving clear national rules for local authorities and developers to follow;
b) Update Building regulations (ADM Vol 1) and NPPF/national planning policy on accessible housing, including measures that take into account non-physical disabilities and differences, such as mental health, isolation and loneliness, vestibular, sensory and neurodivergent conditions. Make reference to BSI PAS646 Design for the Mind – Neurodiversity and the Built Environment;
c) Provide updated guidance and education around accessible housing;
d) Provide training/education/awareness programmes on accessible housing;
e) Update guidance to the housing sector and built environment professionals generally on accessible housing;
f) Update guidance on Design and Access Statements and what planners should demand about housing schemes;
g) Provide guidance to building control professionals on housing assessments;
h) Signpost at every opportunity the new RIBA Plan of Work Inclusive Design overlay
i) To set targets in Local Plans for 10% M4(3) homes across all tenure – see Habinteg’s 2023 LSE report unless robustly justified otherwise by the Local Authority.
j) Encourage and fund all local authorities to employ access officers and specialist housing occupational therapists.
The DFG level should be increased from £30,000 which is a fraction of what it would cost to create a small extension at today’s prices. However, it is important that this is supported by an increase in access officers and housing specialist occupational therapists to ensure that it is spent wisely to maximise the impact on disabled users. Timely adaptations can prevent bed blocking at hospitals and support greater independence and better health, and are very cost effective – saving more money to the healthcare sector than is expended on grants. Regulating the adaptation work without knowledgeable professionals on board is extremely difficult.
Advocacy and support in making applications for funding is very important to ensure everyone is able to access funding. The Royal College of Occupational Therapists and partners report Adaptations without delay is relevant in reducing delays.
DFG’s currently only support people with a physical disability (as defined in the 1948 National Assistance Act) and it should be extended to include sensory and sensory processing, learning disabilities and mental health conditions.
This has to be a repeat of suggestions made in my previous answers, such as the presence of an accessible housing register, adaptations and advocacy support, increased funding for access professionals and Occupational Therapists, increases and extension to the DFG funding and simplifying the process. Engaging disabled people when implementing changes to planning and building control regimes is also important.
Having a suitably structured and maintained accessible housing register, ready access to national support services for advocacy and advice will help, but better standards mandated in new build and change of use cases would ensure that more accessible homes exist in the private sector.
Educating developers and designers about the importance of accessibility features and likely reasonable adjustments that may be requested should also happen.
September 2023