GMCDP's Campaigns Subgroup and a number of interested members have been working together over the past few weeks to produce a response to the Ministry of Housing, Communities and Local Governments ' Raising Accessibility Standards for New Homes Consultation'. This consultation is as follows...
Q1. Respondent details:
Organisation: Greater Manchester Coalition of Disabled People
We are responding on behalf of the above organisation.
Q2. Greater Manchester Coalition of Disabled People (GMCDP) is a disabled people's organisation representing and campaigning for the interests of all disabled people living in the 10 boroughs of Greater Manchester (Bolton, Bury, Manchester, Oldham, Rochdale, Salford, Stockport, Tameside, Trafford and Wigan). GMCDP has been active since 1985 and is guided by the principles of Independent Living and the Social Model of Disability. All members and staff of GMCDP are disabled people.
Q3. Do you support the Government's intention to raise accessibility standards of new homes? Please explain your reasons.
Yes. The Government should seek to encourage sufficient accessible new homes to meet the current and future needs of disabled people of all ages (not only those of older people). While it is true that the increasing average age of the population means that more people will need accessible housing, there are also large numbers of younger disabled people who have been and continue to be stuck in unsuitable housing, including properties that do not meet their access needs, residential institutions that restrict basic freedoms, or living with families when they want to move out and may be prevented from moving to other places (e.g. to take up jobs or university courses) because of a lack of other accessible accommodation.
Accessible housing is one of the ‘Seven Needs of Independent Living” for disabled people.  Disabled people in England have campaigned since the 1980s to achieve independent living. As stated on GMCDP’s website, “accessible housing is crucial in enabling disabled people to live in society and be able to live an inclusive life as part of their local community. As people become older they can experience changes which limit their mobility, which causes their homes to be inaccessible to them. Additionally, anyone can become disabled at any point in their lives. It makes sense for society as a whole to ensure that suitable, accessible new homes are built.”
The 2020 English Housing Survey showed that 91% of homes do not provide the features to meet Building Regulation M4(1), the 'visitable' level of accessibility (HoME, 2020).  Not all Local Plans include policies intended to increase the amount of accessible housing Of the 263 (out of 365) local authorities in England that responded to Habinteg research, only 65% made reference to either the Lifetime Homes standard or category M4(2), and only 28.5% made reference to wheelchair user housing (Habinteg, 2018). 
As an organisation which employs exclusively disabled people (thus providing employment opportunities to people who may otherwise remain unemployed due to access barriers also existing in many workplaces), we at GMCDP have experienced a case of a disabled person living outside Greater Manchester, who was ideally qualified to take up the job that GMCDP had funding for, but was unable to take up the job opportunity because moving to the Manchester area was impossible for them due to the lack of accessible accommodation.
Many disabled people do not wish to live in 'specialist' forms of housing provision such as ‘supported’ and ‘extra care’ housing, particularly if it is away from a familiar area and away from friends and relatives and the support of their local communities. An adequate supply of decent quality, well-designed accessible ordinary housing can enable many more disabled people to live in their own homes and chosen areas, potentially having long-term effects on many other aspects of their lives including health, employment and involvement in local communities. Increasing the pool of new accessible and adaptable M4(2) housing would also enable more older people to ‘age in place’ without having to give up their housing as their needs change.
Inaccessible housing results in a wide range and often hidden consequences, including the loneliness and isolation. A 2018 report by the EHRC concluded that “The impact that living in an inaccessible home has on disabled people cannot be overstated; isolation and loneliness were common themes reported to our inquiry.”
Accessible homes do not only benefit disabled people. They may allow non-disabled family members of disabled people to reduce the level of unpaid caring responsibilities that may negatively affect family relationships, as well as allowing disabled people to visit their non-disabled friends and families’ homes. They also meet the needs of other sectors of the population, e.g. carers with pushchairs. Inaccessible housing therefore affects not only disabled people, but also their families, partners and their ability to plan for the future. The creation of new accessible homes needs to be done in a way that acknowledges that disabled people may have or want families.
"Disabled people don't always live alone through choice. The available housing limits the way they move through life. The creation of accessible homes needs to be done in a way that acknowledges that they may have or want families. You can build homes that can allow people to live with their partners and then children if they wish. It will build stronger communities if you could do this without the need to move for each life stage This includes layouts that both promote accessibility but also family life. External doors that can be accessed from inside the home; storage space for a busy family but also an electric wheelchair. Kitchens regulated for both a disabled person but designed for a couple to be in. If housing is built like this then it reduces isolation, opens housing to more and would mean that housing works for longer for more." 
The lack of sufficient accessible housing forces many disabled people into residential care. Disabled people consistently do not wish to live in such disempowering situations, but instead would prefer to live independently in their local communities alongside their non-disabled peers. The impact of institutionalisation on disabled people's health outcomes and life chances has been particularly starkly highlighted by the impact of the Covid-19 pandemic on residents and staff in care homes.
For all these reasons, GMCDP recommends that M4(2) is mandated as the minimum standard for all new homes. The EHRC has highlighted viability appraisals as a barrier to increasing accessible housing. GMCDP therefore recommends that proposals for accessible housing should not be subject to viability appraisals.
Q4. Which of the 5 options do you support? You can choose more than one option or none. Please explain your reasons, including the advantages and disadvantages of your preferred option(s).
Option 1 will not meet the Government's objective of ensuring 'that there should be enough suitable housing where it is needed'. Whilst the optional technical housing standards are helpful in prescribing minimum space standards (and we know that the UK has the smallest space standards in Europe) they make no reference to accessibility (wider door openings, wider corridors, etc.)
Option 2 and Option 3 both include M4(3) wheelchair accessible housing only where there is a local planning policy in place in which a need has been identified and evidenced. Evidencing the 'need' for wheelchair user housing seems to us problematic for a number of reasons, including that:
- The calculation is likely to vary between local planning authorities, creating confusion for developers of sites in different parts of the country;
- Evidence would have to include an anticipatory element, to comply with the 2010 Equality Act. It is unclear how this would be calculated;
- Evidence would have to be regularly gathered, reviewed, and kept up-to-date, by already-stretched planning departments;
- The EHRC and Habinteg have identified a range of data sources for evidence. Most local authorities do not currently aggregate such data so new processes would need to be set up by already-stretched planning departments;
- The process of identifying and evidencing need could be lengthy and take time to satisfy existing need;
- Some non-disabled people might purchase wheelchair accessible housing because they prefer the more generous space standards. Whilst social landlords might be able to exercise control over the occupiers of accessible social housing, there would be no control over who moved into an accessible private house. Provision of wheelchair accessible housing would therefore need to be more generous than purely to meet the need identified for wheelchair users.
Option 4 would mandate M4(2), with M4(1) applying by exception only, and would create an enforceable minimum standard for new housing. It would also include provision for a nationally set percentage of M4(3) wheelchair user homes which, in our view, is essential.
Option 5 would not cater for wheelchair users.
GMCDP therefore strongly advocates for Option 4. GMCDP would prefer a national percentage of 10% set for M4(3) wheelchair user homes. This is similar to the London Plan and is simple and easily to calculate and understand. Developers and designers will be clear about the provision they should be working to. The percentage could be increased in specific areas, but should not be reduced.
It would not place an additional onerous responsibility on planning departments, at a time of reduced resources, to gather, review and keep up-to-date calculations of need.
Having a set percentage of wheelchair accessible housing in each development would mean that these homes were better integrated into their local communities. This is greatly preferred by disabled people as it increases the chances of successful social inclusion, in contrast to the prevalent situation of disabled people often living in localised pockets of ‘specialist’ housing, which results in de facto segregation of disabled people from ‘mainstream’ communities, restriction of opportunities and social isolation.
If Option 4 is for any reason ruled out of consideration, GMCDP would consider Option 2 to be the least bad of the remaining options. However, we do not regard any option other than Option 4 as sufficient to ensure that disabled people can have equality with non-disabled people in regard to housing provision.
1. There needs to be clarity about the responsibility for funding adaptations, and sufficient funding made available to carry them out. Often sufficient funds are not available and so disabled people must fund their own adaptations. Disabled people generally have among the lowest incomes in the country and should not be required to fund the necessary adaptations that will enable them to lead lives that are as independent as possible.
2. Local authorities should be required to keep a register of accessible housing, including both social housing and housing in the private sector. This would be of assistance to disabled people who presently have no means of interrogating information about the accessibility of new housing, and to those advising them.
3. The provision of accessible housing should be a firm requirement in Local Plans and not subject to viability assessments. This would create a level playing field for developers.
Q5. If you answered 'None' to Q4, do you think the Government should take a different approach? If yes, please explain what approach you consider favourably and why?
Q6. Do you agree with the estimated additional cost per dwelling of meeting M4(2), compared to current industry standards in paragraph 44? If no, please comment on what you estimate these costs to be and how you would expect these costs to vary between types of housing e.g. detached, semi-detached or flats? Please provide any evidence to support your answers.
The increased cost of building an accessible dwelling varies according to the type of home. In 2018 the additional cost of building to M4(2) over M4(1) standard was estimated to be less than £1,400 for a 4 bed detached house. (EHRC / Habinteg, 2018). 
GMCDP does not build houses, so we can neither agree nor disagree with these figures. However, if M4(2) was mandated as the minimum for all new homes (with the exclusions described in option 4) and the requirement included a national percentage of wheelchair user homes, this would create a level playing field for developers which would be reflected in land values and reduce the additional cost. In addition, the bulk manufacture of components such as wider doors would result in some economies of scale.
Whilst the majority of this (minimal) cost would fall on developers in the first instance, the wider health and social care cost implications should be recognised. For example, the reduced cost to the NHS of fewer falls in the home (the most common cause of hospital admissions for older people) and earlier discharge from hospital into an accessible home. The estimated cost of poor housing to the NHS is £1.4 billion per annum (BRE Press, 2015) . Mandating accessible housing could also reduce the need for and cost of social care, as it would support independent living.
Q7. Do you agree with the proportion of new dwellings already meeting or exceeding M4(2) over the next ten years in paragraph 44? If no, please comment on your alternative view and how you would expect this to vary between types of housing e.g. detached, semi-detached or flats? Please provide any evidence to support your answers.
The evidence base for the figures provided in the consultation document is not clear. Currently 91% of homes lack even basic accessibility features (Care & Repair England, 2018) . It is therefore extremely unlikely that, even if M4(2) were to be set now as the minimum standard for all new homes, the proportion of accessible homes would rise to 45% by 2024. The minimum accessibility standard should apply to all types of housing, as disabled and older people deserve to have the same housing choices as everyone else.
Q8. Do you have any comments on the costs and benefits of the other options set out above. If yes, please provide your comments including any evidence to support your response.
The positive financial impact of building more accessible new homes could be considerable. It could reduce demand for NHS and social care services and reduce the need for costly adaptations to homes. If homes are not built to be accessible from the outset, these costs are pushed into the future and onto individuals, the government and the taxpayer. It would be much more effective to build the types of homes that are needed now, than to adapt unsuitable properties in the future, often at huge cost.
Currently, retrofitting and adapting existing homes will be necessary for many older and disabled people as 91% of existing homes do not meet even the lowest threshold of visitability. However, retrofitting can be very expensive, and is often not possible because of the design of the house. Future-proofing the homes that are built now means that fewer adaptations will be required, and those that are can be achieved more effectively and at lower cost.
The positive social impact of making all new homes accessible would mean that more people are able to stay in their own homes as their needs change, rather than being forced to move prematurely and unnecessarily into supported/specialist housing or residential care.. Returning home from hospital could be smoother and faster, the likelihood of falls and other housing-related health problems less frequent, and the need for care at home reduced, freeing up scarce NHS and social care resource.
Option 1 would only benefit house builders as this is the cheapest option in construction terms. It does not take account of more comprehensive (real) costs such as to the NHS in terms of unnecessary hospital admissions and delayed hospital discharges; unnecessary admissions to residential care, and increased support needs, both paid and unpaid.
Option 3 would remove M4(1) completely, thereby reducing the potential pool of housing for people who are not disabled, at cost to the totality of housing provision. There appear to be no benefits to this option.
Option 5 would benefit house builders, as it would be less expensive than building accessible homes. The comprehensive (real) costs would be similar to those at option 1, above.
Q9. Do you have any comments on the initial equality impact assessment? If yes, please provide your comments including any evidence to further determine the positive and any negative impacts.
Improving accessibility standards for new homes would have a positive impact on the age and disability characteristics. None of the proposed options would directly have a negative impact on any of the protected characteristics.
Option 1 is unlikely to have any positive impact because it maintains the status quo and would not improve accessibility standards.
Options 2, 3 and 4 could all have a positive impact on the Age and Disability characteristics by increasing the number of homes where disabled and older people can live safely and independently.
Option 5 does not make a clear proposal so it is not possible to gauge whether its impact would be significant.
Although the foreword states the hope that the consultation would give as many people as possible 'the chance to raise the challenges they have faced trying to find... accessible homes', none of the questions was designed to elicit information from the people most affected by the shortage of such homes, i.e. disabled people with housing access needs. For example, there were no questions that asked disabled people about the impact that a lack of accessible housing has on their lives, the difficulties of finding accessible accommodation, etc. All the questions were geared towards answers which were primarily of interest to the construction industry.
The consultation document appears unnecessarily complicated and would therefore have been inaccessible for many disabled people, particularly those with learning difficulties, as well as potentially for people who do not have English as a first language, including Deaf people whose first language is British Sign Language (BSL). Future consultations should be available in BSL and Easy Read (to make it more accessible for people with learning difficulties) formats. The ‘standard’ format of the documents should also be written in as simple and plain English as possible, and should be checked to ensure that it is compatible with screenreader technology (as used by many people with visual impairments and/or dyslexia).
Accessible housing has become even more important in the context of the Covid-19 pandemic, which has had a vastly disproportionate impact on disabled people. Improving the minimum standards of accessibility presents an opportunity to reduce the likelihood of inadequate housing conditions fuelling a future pandemic. This also potentially impacts on the Age and Ethnicity protected characteristics because older people and people for whom English is not their first language are also more likely to contract Covid-19, and this has been linked to poor housing conditions.
 ‘The Seven Needs of Independent Living’, Greater Manchester Coalition of Disabled People website
 Housing Made for Everyone (HoME) briefing: Raising accessibility standards for new homes, November 2020)
 'Accessible Housing in Local Plans', Habinteg (September 2018)
 ‘Housing and disabled people – Britain’s hidden crisis (EHRC 2018)”
 Greater Manchester coalition of Disabled People member
 'Housing and disabled people: A toolkit for local authorities in England: Planning for accessible homes', EHRC / Habinteg (October 2018)
 ‘Homes and Ageing in England', BRE Press (2015)
 'Ageing Well: A Housing Manifesto', Care and Repair England Older People's Housing Champions (2017)