On July 6, the Australian Building Codes Board (ABCB) released an important document for consultation.
Known as a Consultation Regulatory Impact Statement (Consultation RIS) and prepared for the ABCB by the Centre for International Economics, the paper aims to quantify the benefits and costs associated with five options being considered to introduce mandatory accessibility requirements for housing into the National Construction Code (NCC). These options are based on the Livable Housing Design Guidelines (LHDGs) developed by Livable Housing Australia (LHA).
When doing this, the RIS found that costs associated with mandating accessibility requirements through the NCC exceeded the benefits for any of the options considered.
Despite this, for reasons outlined below, accessible housing requirements should be mandated through the NCC.
The aforementioned RIS is no ordinary Consultation RIS. It marks a turning point in reconsidering home design for the safety, convenience and access of all. It’s about tweaking existing structural elements to be more inclusive and accessible to more people.
The objective of the RIS is, “To ensure that new housing is designed to meet the needs of the community, including older Australians and others with mobility limitations.” The aim is to include accessible universal design features as standard – not as optional extras “for special people”.
In 2010, the housing industry devised well-considered universal design guidelines through LHA. These guidelines, however, are voluntary, and whilst there has been some interest from individual house-builders, adoption by volume builders has been extremely limited. If liveable housing is to become the norm, accessible housing requirements need to be mandated.
So why is this needed? Our lives, families and households are changing. Apart from fashion statements and size of housing, however, not much has changed in new home design and construction. Further, whilst Australia has obligations to all our citizens, we are leaving people behind. At the macro level, the Australian Government is obliged by two UN instruments to be more socially and economically inclusive: UN Convention on the Rights of Persons with Disabilities and the Sustainable Development Goals. Both instruments cite “universal design” as the means to achieve greater inclusion for all. This includes the built environment and housing.
Usually, the term “universal design” conjures up notions of “disabled” design, wheelchair users, access ramps and ugly rails. However, the LHDGs show how existing features can be adapted with style and not much fuss. The Guidelines also address the issue of cost by advising that impositions associated with the need to provide additional space can be minimised where accessible features are considered at the outset of design. In large homes, space not an issue.
A cursory look at the RIS shows that these documents are not for the faint-hearted. If you don’t understand the NCC or how a cost benefit analysis works, there is little chance of responding to the RIS. But what is so difficult about tweaking a few features to make homes more useable?
The answer is attitude and perspective. If you think that people with disability and older people are a government responsibility, then you will expect special types of housing for them. That is, housing products that are segregated living arrangements for the “others”.
Conversely, if you think of the same group in terms of a family member or yourself and experience exclusion and inconvenience at every step, you might think differently. But it is not all about wheelchair users. This is where terminology matters.
If universal design features were included in the NCC, it would not need a special name – it would just be a housing regulation. The decision to give it the Accessible Housing title underscores the assumptions upon which the RIS is formed. It focuses the mind on people with disability, particularly wheelchair users. This is because the Access to Premises Standard is related to the Disability Discrimination Act. This is the frame of reference the industry recognises, but we need to consider the broader picture. Four points should be considered.
First, ability is only temporary. (particularly in the construction industry). If you expect to live to a ripe old age, God will not be making exceptions. You can expect loss of capacity. Roy Morgan’s major study on behalf of the current Royal Commission into Aged Care Quality and Safety has some interesting findings. One is that whilst younger people had little concern about the idea of going into aged care (when they are older), older cohorts were more interested in receiving care at home. With the current pandemic we might want to re-think our response to aged care. Nevertheless, the evidence that older people want to stay put is overwhelming.
Second, universally designed features are good for many people. Trip hazards are a problem for young and old alike. A step free entrance is good for bringing in the shopping, the baby stroller or bicycle, someone temporarily on crutches, big items of furniture, emergency personnel and paramedics. More room to move around makes life comfortable for everyone.
Third, people with disability do not live alone – they live in households with others. While eighteen per cent of people report a disability, they live in more than one third of our households. If you add the twenty-two per cent of people with a long-term illness (counted separately by the ABS) around half of all households require easy to use features. And everyone in the household is affected in some way by that disability.
Fourth, family members are often carers, and carers often experience disability or chronic illness themselves. Many reduce their work hours to part time or give up work altogether. Studies on the efficacy of home modifications show that hours of paid care and family care are reduced by seventeen and forty-seven percent respectively when modifications to improve accessibility are introduced. Not only that, health and quality of life outcomes improve for all.
Now to cost. This is not a simple matter of weighing up extra costs associated with the changes against benefits that are likely to result. We are talking about family life, not bricks and mortar. The unanswered question remains, “What is the cost of NOT including universal design features?”
In the end the decision or otherwise to mandate accessible housing features through the NCC will be made at a Ministerial level – not by the ABCB. If the consultation does not raise convincing arguments about the way the cost benefit analysis was done, the question then should be: “Can we afford to exclude people from their own homes?’ A colleague raised an even better question, “What would you pay not to go to aged care?”
Yes, this is personal. This RIS that is not about “the others”. It is about all of us.
The Consultation RIS on Accessible Housing open for comment until 31 August.
By Dr Jane Bringolf, Centre for Universal Design Australia
Jane Bringolf is Chair of Centre for Universal Design Australia, a registered charity seeking a more inclusive world. She wants to see a world where designers and policy makers automatically consider the diversity of the population and create inclusive built environments, products and services. She writes regularly on universal design and inclusive practice and contributes to various advisory panels. Jane’s academic qualifications include a BSSc, MBA and PhD in Urban Studies that investigated the barriers to universal design in housing.
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