New homes - enhancing accessibility, adaptability and usability: consultation analysis

Executive Summary

Background

In June 2023, the Scottish Government launched a public consultation on proposals for updates to Part 1 of the Housing for Varying Needs design guide and for an all-tenure Scottish Accessible Homes Standard which will be implemented through changes to building standards and guidance. The proposals aim to enhance the accessibility, adaptability and usability of homes in Scotland. This summary sets out key findings from an analysis of responses to the consultation paper.

The consultation

The consultation opened on 29 June and closed on 21 December 2023. Across 52 questions, each of which included a closed question and space to provide additional open comments, the consultation allowed members of the public and representatives of organisations to give their opinions about the proposals.

Questions were wide-ranging and covered issues such as access to dwellings and provision for vehicles; communal access areas, stairs and lifts to flats; entrance doors to individual houses or flats; circulation spaces and internal doors; living and sleeping areas; storage; kitchens; bathrooms and WC compartments; interior finishes; windows; heating, ventilating and water services; power and communications; external facilities; proposals for the Scottish Accessible Homes Standard; and initial assessments of the possible impacts of the proposals.

The consultation attracted 114 responses; 19 from individuals and 95 from organisations. Twenty of these responses were campaign responses, submitted by 17 housebuilders/property developers, two architecture organisations and one individual. The analysis also included notes from 10 consultation events facilitated by the Scottish Government. The events involved 255 attendees in total, although some attended more than one event.

Public consultations invite everyone to express their views; individuals and organisations interested in the topic are more likely to respond than those without a direct or known interest. Moreover, those who have the capacity to respond are also more likely to take part than those who do not. This analysis is representative of the views expressed by those who attended the consultation events and respondents to the consultation paper.

Proposals for the updated Housing for Varying Needs design guide

Overall, there was broad support for the proposed updates to the Housing for Varying Needs design guide. Typically, for each closed question, over half of the respondents who answered agreed with all the proposals, with around seven to eight in 10 agreeing with either some or all proposals where multiple proposals were presented.

Across all the proposals for the updated Housing for Varying Needs design guide, the highest levels of agreement were recorded for measures about the location and number of power sockets (Question 36, 92% agreed with some or all the proposals in the question), the proposals for main bathrooms in cases where a wet floor shower facility is not provided (in dwellings that are not specifically designed for wheelchair users) (Question 26, 88%), the proposals for Section 6 of Part 1 of the current guide (covering the overall plan of a dwelling) (Question 2, 88%), the proposals for situations where the accessible sanitary accommodation is located on the principal living level and the accessible bath or shower is located on another level (in dwellings that are not specifically designed for wheelchair users) (Question 27, 88%), the proposals for interior finishes (Question 32, 87%), the proposals for heating, ventilating and water services (Question 35, 87%) and the proposals for communal access areas, stairs and lifts to flats (Question 10, 87%).

Other proposals received more mixed responses. For example, 50% agreed that the main living room within a dwelling should be provided with a glazed area of not less than 1/8th of the floor area of that room (Question 33), 60% agreed with some or all the proposals related to the provision of a through floor lift in cases where a dwelling is specifically designed for wheelchair users and is constructed on more than one level (Question 17), and 69% agreed with some or all the measures relating to corridors outlined in Question 16.

There were some differences in responses from individuals and organisations. In general, among respondents who answered the closed questions, individuals tended to be more supportive of the proposals compared to organisations. For example, 80% of individuals agreed with all the proposals set out in Question 16 about corridors, while 32% of organisations agreed with all and 34% agreed with some. However, there are also examples where organisations were more supportive than individuals. For instance, 49% of organisations agreed with all the proposals for Section 6 of Part 1 of the current Housing for Varying Needs design guide (Question 2), compared to 27% of individuals.

Among organisations, responses from housebuilders and property developers who answered the closed questions tended to be less supportive than other types of organisations. It is important to note however that a large number of housebuilders and property developers did not answer the closed questions because they submitted campaign responses. However, the campaign responses also indicated opposition to many proposals.

Proposals laid out in Question 4, for example, about entrance platform dimensions in cases where a communal entrance door opens outwards, attracted limited support from housebuilders and property developers, 67% of whom disagreed with the proposal, compared to 23% of all organisations. Similarly, 75% of housebuilders and property developers disagreed with proposals relating to space in kitchens in front of fittings and appliances in dwellings specifically designed for wheelchair users (Question 24) compared to 28% of all organisations.

While responses to the closed questions about the Housing for Varying Needs design guide were broadly supportive, a range of views were expressed in open comments. Some themes were mentioned by a large proportion of respondents at multiple questions, often highlighting issues to consider if the proposals are implemented.

The perceived or assumed cost implications of the proposals was the most prevalent recurring theme. Comments on costs related to the installation and maintenance of items required to implement the proposals, such as the provision of through floor lifts within dwellings designed specifically for wheelchair users that are constructed on more than one level, as well as the increased cost of building larger properties to accommodate the requirements outlined in the proposals. Respondents argued the proposals could increase costs for developers and landlords. Many assumed this could result in higher property prices and rent costs, reduced housing affordability, and decreased supply of homes, especially smaller, more affordable properties, although respondents did not provide evidence to support these points.

Other overarching themes included potential advantages of the proposals, such as enhanced accessibility for residents, and disadvantages, such as some measures that could potentially reduce storage and usable space. Opposition to implementing proposed measures ‘as standard’ was also expressed in response to multiple questions, as were calls for more information and clarification about the proposals.

The Scottish Accessible Homes Standard

In questions about the Scottish Accessible Homes Standard, 64% of those who answered the question agreed with some or all the exceptions proposed to identify the criteria within the updated Housing for Varying Needs design guide that will not be transposed into building standards to implement the Scottish Accessible Homes Standard (Question 42). In open comments, some were concerned that Exception C (‘Clauses relating to design criteria for specific user groups including buildings and dwellings specifically designed for wheelchair users’) could weaken provisions for wheelchair users. Some called for more exceptions to be included.

Just over two-fifths (43%) of respondents who answered Question 43 felt that all the proposed criteria within Table 1 of the consultation paper would be appropriate to apply to all new housing across all tenures and 38% said some but not all criteria would be appropriate. The proposals were praised for enhancing future-proofing of homes for the needs of an ageing population, but the perceived cost implications were also highlighted in terms of housing affordability and supply. Some suggested that the criteria should apply to a proportion of new build properties, rather than all, while there were calls for more information and clarification about a range of specific clauses.

Some suggested specific additional criteria they would like to be included. However, ideas were wide-ranging and there was little consistency among respondents. Suggestions included criteria specifically related to the needs of wheelchair users, safety, nosing on all steps, storage and charging facilities for mobility scooters, restrictions on kitchen windows being placed above worktops or sinks, ensuring the principal living room is south-facing and signage for people with visual impairment.

Similarly, there was little consensus in comments about the existing design guidance for stairs. Most commonly, some made observations about banisters, including general support for their use and suggestions for specific situations when they should be used, such as when winder stairs are used.

Conclusions

The responses provide valuable and informative evidence to draw on when planning the updated Housing for Varying Needs design guide and the Scottish Accessible Homes Standard. Overall, the key message is that while there is broad support for the proposals, respondents identified challenges and potential consequences that should be considered when informing next steps.