After working in the access industry for more than 30 years, I cannot remember a time when the focus on the need for improved access features in housing to meet the wide-ranging needs of the community, has been highlighted as much as it is now.
After many years of advocacy and work by a wide range of stakeholders, there is now a range of Standards and Guidelines that have formed the basis of an emerging framework to support the diverse housing requirements of everyone in the community.
These requirements include consideration of the needs of people with disabilities, people who wish to age in place, families with small children, multi-generational families and more recently people who wish to work from home.
Whilst most of these Standards and Guidelines incorporate some similar design features, they are all different in terms of their key target groups and reflect the diverse needs of the community. Each Standard or Guideline details particular technical specifications and requirements. Whilst some may argue that all housing should meet the needs of all people, a one size fits all approach does not satisfy the unique requirements of many people due to their particular access needs or preferences.
For example, whilst there may be some housing features that would benefit all housing user groups, such as step free entrances, wider corridors, easy to use door handles, and more generous spaces to accommodate a more flexible lifestyle, there are still other features that must be considered for many people. These additional considerations support people with particular needs related to hearing loss, vision loss, neurodiversity and of course, mobility. They consider the needs of people with a variety of access challenges who may not need Specialist Disability Accommodation (SDA), or are ineligible for this, but have particular access requirements.
Unfortunately, in some part due to the inconsistency of language and terms used in each of these different Standards and Guidelines and a general lack of understanding of the technical requirements detailed in each, there is significant confusion in the marketplace regarding the appropriate application of each.
Therefore, it appears some of these Standards and Guidelines have been adopted by a variety of organisations without a full understanding of their implications and appropriateness in different housing contexts.
This confusion has the potential to undermine the important outcomes of housing for everyone and creates uncertainty, perpetuates misinformation and confusion.
What are these key housing Standards and Guidelines and what are the differences?
The Livable Housing Design Guidelines (LHDG) were developed more than ten years ago through work undertaken by the National Dialogue on Universal Housing Design. This incorporated a collective of stakeholders including representatives from the government, housing, disability, and ageing sectors who agreed on the need for a national approach to address liveability features in all new homes being built in Australia.
The National Dialogue agreed on the need to codify a national approach that addressed:
- The value of universal design to the community
- A definition and a set of principles defining livable housing design
- What livable housing design features are in relation to housing
- The need for a national approach for harmonisation across the country.
Livable Housing Australia (LHA) was established and supported by government and LHDG were developed.
The LHDG support an approach to the design and building of homes that ensures a home is:
- Easy to enter
- Easy to navigate in and around
- Easier and more cost effective to adapt
- Responsive to the changing needs of home occupants.
The LHDG respond to the recognition that many people will benefit from a home that incorporates these features. These include:
- Baby Boomers and people who choose to age in their own homes
- People caring for young children
- People with temporary injuries or illnesses
- People with some ambulant disabilities and other access challenges.
The LHDG incorporate 15 Design elements applicable to 3 Performance levels- Silver, Gold, and Platinum.
- Silver level incorporates the first 7 Design elements
- Gold level incorporates the first 12 Design elements
- Platinum incorporates all 15 Design Elements.
These elements relate to basic features that support livability for a wider range of people and improved livability of generic homes, particularly for those being designed at that time.
The LHDG have been used by a wide range or housing organisations and governments over the past ten years to achieve a higher level of livablity in a home.
The LHDG were developed as a voluntary set of Guidelines, however they have been mandated as a minimum benchmark for new housing by some local and state governments, as well as some housing developers wishing to attract a broader market for their homes. Regardless of the introduction of the LHDG, changes to housing design over the past ten years to incorporate more open plan living and more generous and flexible spaces in homes, has meant that many of the features of the LHDG have been incorporated into generic designs without any specific assessment against the LHDG. This has provided more flexible options in the marketplace.
To be clear, the LHDG were not developed to meet the needs of people with significant disabilities. For example, they do not incorporate requirements for accessible toilets in any performance level i.e., Silver, Gold or Platinum. There are no requirements in minimum Silver level, for a shower to be on the ground or entry level of a home, therefore the shower could located at the top of a set of stairs. There are no requirements for effective contrasts to be incorporated on stair treads to support a person who has reduced vision, or design features to support people who have reduced hearing, such as visible fire alarms. These are clearly critical design features that would need to be incorporated into a home if it were to meet the basic needs of many people, particularly as they age, as well as people with other disabilities. Livable Housing is not accessible housing.
AS4299:1995 Adaptable Housing
Adaptable housing includes design features that support easier adaptation of a home, if required, by a housing occupier as they age, develop or acquire a disability.
Adaptable housing is a benchmark or basis on which to develop the accommodation needs of users of all ages and abilities. Adaptable housing, by incorporating sensible design features often lacking in other housing, serves as a bonus to the owners and occupants. The adaptable house must, in its adaptable features, suit any future occupant with any type of disability.
AS4299:1995 Adaptable Housing is still the current technical reference for the design of adaptable houses. It is outdated and the technical specified requirements in many instances are not relevant to current housing requirements of the population in 2022. For example, since AS4299 was developed there is much greater demand for housing to meet the needs of people with a wide range of disabilities who wish to live independently in the community. This includes people who may have previously been housed in institutions, as well as people who wish to age in place and need the flexibility to easily adapt their homes to support their changed circumstances. In addition, the dimensions of wheelchairs and other mobility aids have significantly changed, and the general size of people has also increased. Another key consideration is the ongoing enhancement and development of technology that can have a significant positive impact on many people, if it is easily able to be installed in their own home.
Much work has been undertaken by a range of advocates and stakeholders to update the AS4299 to make this more relevant, as it provides an important part of the framework for necessary housing options. However, there is currently a roadblock to this update, with Standards Australia refusing to undertake the necessary work required to make this a relevant and meaningful document.
Given that the Adaptable Housing Standard in referenced and therefore mandated in NSW legislation, professionals working in the access and housing industry are expected to apply this to developments in 2022. This can result is very unsatisfactory outcomes for housing.
Adaptable Housing does not replace Livable Housing or Specialist Disability Accommodation (SDA) but provides another important piece in the housing framework, therefore an updated version relevant to the needs of the community in 2022 is urgently needed.
Specialist Disability Accommodation (SDA)
With the introduction of the National Disability Insurance Scheme (NDIS), came the imperative to appropriately address housing requirements of people with a significant disability, at least to a minimum measurable benchmark. The Specialist Disability Accommodation (SDA) Design Standard was introduced across Australia in 2019. It details the minimum technical requirements required for dwellings to accommodate the needs of NDIS participants.
The SDA Design Standard incorporates twenty five Design Features that apply to four Design Categories: Improved Liveability, Fully Accessible, High Physical Support and Robust. Each of these Design Categories incorporates a range of technical design requirements that must be met for a dwelling to be enrolled with NDIS and to be used as SDA. Once this is done, an eligible NDIS participant can use funding they receive through NDIS for accessing SDA that meets their needs.
The SDA Design Standard targets people with significant disabilities and are a critical component in the housing framework for everyone.
It is also worth touching on accessible housing as this is term that is often used when describing housing for use by a person with a disability. There is no accessible housing standard in Australia. An accessible house typically describes a bespoke designed home that meets the needs of the particular person living in the home. For example, the access needs of a person with low vison or hearing loss will be quite different to the access needs of a person using a wheelchair. Unfortunately, the term accessible housing is often only used when referring to the needs of a person using a mobility aid and therefore very limiting in its understanding of scope and application.
Why is there confusion?
When the LHDG were introduced more than ten years ago, they were the first real attempt to improve ‘liveability’ to new generic housing. They were a set of voluntary guidelines that were encouraged for use across the housing sector to expand and improve housing options. The uptake of the LHDG has differed between developers, states, and local jurisdictions. It has become clear that until there is a regulated approach to the provision of liveability in homes, this adhoc approach will continue. This does not provide consistency or certainty to the market and does not ensure that there will be suitably designed housing stock available to meet the needs of much of the community.
With the introduction of the NDIS, the need for immediate access to appropriate housing for people with disabilities was a priority. In an attempt to fast track this, in 2016, the NDIS adopted the LHDG to provide part of minimum benchmark for SDA. This was seen as a quick and easy option to fill a gap until the SDA Design Standard was developed, however, it meant that the LHDG, which only addressed liveability, was underpinning a requirement for accessibility for housing for people with disabilities.
Subsequently, the confusion in the marketplace began in force as developers and governments applied that LHDG assuming they were an effective basis for provision of housing for people with disabilities. The terminology and narrative also changed. The term ‘accessibility’ rather than ’liveability’ began to be used in narrative when discussing the LHDG.
This supported a misunderstanding that dwellings that complied with the LHDG would be suitable for people with disabilities, who could now purchase or rent homes and be confident that the design features would address their access needs, including provision of an accessible toilet.
Of course, this was not the case, but the confusion had started. I had many conversations with housing stakeholders questioning this approach and providing feedback that this has created confusion, reduced an understanding of the housing needs of many people and created unrealistic expectations relating to the scope and impact of the LHDG in addressing the housing needs of people with disabilities.
When the SDA Design Standard was introduced in 2019, it was clear that the technical requirements that are necessary to meet a minimum requirement of a variety of people with disabilities were significantly more detailed, incorporated more generous dimensions and included specific requirements for accessible toilets in several design categories, unlike the LHDG.
Further confusion has occurred since April 2021, when the commonwealth, state, and territory Building Ministers agreed to include minimum ‘accessibility provisions’ for residential dwellings in the NCC 2022 based on the Livable Housing Design Guidelines (LHDG) Silver level.
This again has reinforced the idea that the LHDG will address accessibility – not liveability – for generic home dwellers. The use of the term ‘accessibility provisions’ has further cemented the confusion regarding the housing design features to be included and attracted backlash from some sectors of the housing industry who believe that incorporating ‘accessibility provisions’ will impose a significant cost impost to generic housing. However, given that the benchmark for these ‘accessibility provisions’ is the Silver level of the LHDG there is no substantive evidence to suggest this is the case. In fact, anecdotal evidence from building developers since the introduction of the LHDG, indicates that there is little or no cost impost when utilising the LHDG Silver level requirements to many new builds, particularly on relatively level sites.
Perpetuation of the confusion
Now ‘the genie is out of the bottle’ and the narrative regarding the requirements for housing liveability and accessibility are being touted as the same, it appears that some housing industry stakeholders are in fact keen to perpetuate the misunderstanding and confusion to meet their own objectives. An alternative explanation is they just don’t understand the difference.
For example, some housing industry peak bodies such as Master Builders Australia argue that incorporating ‘accessibility provisions’ (based on the LHDG) will add significant cost impost to general housing and are advocating strongly against changes to the NCC to incorporate these.
As indicated previously, there is no substantive evidence to support this, particularly when much generic housing design already incorporate larger, open plan spaces with level transitions due to the popularity of these design features in the marketplace.
Despite agreement at the Building Ministers Forum on the need for ‘accessibility provisions’ to be incorporated into the NCC, some States are now refusing to participate in adopting these. The full reason for this is unclear but appears to be linked to advocacy applied by organisations who perpetuate the idea of cost impost on the generic housing sector.
There also appears to be another area of confusion in the sector regarding the importance of each of the different housing design options based on the requirements of liveability, adaptability and Specialist Disability Accommodation. These are all different and have distinct roles to play in ensuring all Australians are adequately housed.
For example, AS4299 Adaptable Housing is not being advocated for mandatory adoption in any generic housing. It is however supported by many industry peak bodies as an important component in ensuring that many people who acquire disabilities and older adults can age in place more easily or purchase homes that will support their independence in living in the community. The cost impost of not doing this is not lost on the government or industry bodies, as the cost of the alternative in providing supported accommodation to a fast-growing ageing population is well documented. The urgent review of AS4299 is necessary in order to support these community sectors who cannot all be accommodated appropriately by the introduction of the proposed mandated provisions in the NCC.
The Association of Consultants in Access Australia (ACAA) is heavily engaged in drafting an updated AS4299 and is supported by Occupational Therapists Australia, Australian Institute of Architects and Physical Disability Australia. However, the Australian Network on Universal Housing Design (ANUHD) has refused to support this update, citing that the LHDG will be adequate in meeting the needs the community. This highlights the confusion regarding the different housing design options that are needed to support everyone. Whilst the LHDG will improve livability they will certainly not support the needs of people with higher level access needs but who don’t need or are ineligible for SDA.
Without an updated Adaptable Housing Standard that can be referenced by designers, and with only the LHDG – Silver level – to provide a benchmark in the NCC for people with higher support needs, there is no doubt that some people will be forced to move into supported aged care or SDA rather than remain living in the community or be able to age in place.
ANUHD has strongly advocated for LHDG Gold level to be mandated in the NCC, however this is not occurring, therefore the decision not to support the update of AS4299 is perplexing and detracts from enhancement of appropriate options for housing.
Australia consists of a diverse community and a one size fits all approach will not meet the imperative of housing for everyone. Having a range of Standards and Guidelines to support these diverse community housing needs only adds to the range of housing options – it does not detract from these.
Adequate housing is a fundamental human rights issue and fostering a clear understanding of the variety of housing design options that will support the needs of everyone is imperative. It is the responsibility of all sectors of the housing industry and related stakeholders, to work collaboratively to achieve this outcome and ensure the needs of everyone in the community are considered in the design, development and upgrade of housing.
Liveability, adaptability and SDA are all equally important and worthy of support and consideration in order to continue to work towards addressing everyone’s housing requirements.
Ms. Joe Manton
9th May 2022