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

19. The Scottish Accessible Homes Standard

This chapter presents the analysis of Question 42 to Question 47 which aimed to gather views on the all-tenure Scottish Accessible Homes Standard.

Question 42. How do you feel about the exceptions that we are proposing be used to identify the design criteria within the updated guide that will not be transposed into building standards?

Just over a third of respondents (35%) who answered Question 42 agreed with all the proposed exceptions, 29% agreed with some but not all, 11% disagreed with all and 25% neither agreed nor disagreed with the exceptions. Responses were broadly similar across individuals and organisations. While 64% of those answering agreed with all or some of the proposals, this proposal was one of the least supported of the 34 questions which asked respondents if they agreed with all, some, or none of the proposals.

Comments about Exception C

Slightly more than a third of all respondents provided open comments at Question 42. Some commented specifically about Exception C (‘Clauses relating to design criteria for specific user groups including buildings and dwellings specifically designed for wheelchair users’). These responses focused on concerns that regulations that apply to dwellings for wheelchair users could be weakened. Respondents emphasised that the needs of these users should be protected to ensure that housing is suitable for their needs.

“Provision for disabilities and wheelchair users cannot be left as an opt out choice for the private sector. If not building regulations, then planning regulation must ensure appropriate provision, as it does for 'affordable' housing.” – Organisation

Calls for more exceptions

Some respondents called for more exceptions to be included. Most of these did not specify what they felt the additional exceptions should be.

Other themes

Similarly to Question 41, some respondents highlighted the benefits of streamlining the requirements into one document, as proposed in the consultation paper, rather than having to refer to multiple documents. The overarching concern about the proposals’ costs and impact on housing supply was also raised by some respondents.

Question 43. Do you feel that the indicative design criteria listed in Table 1 would be appropriate to apply to all new housing across all tenures?

Just over four in 10 (43%) of all respondents who answered the question felt that all the criteria would be appropriate to apply to all new housing across all tenures, 38% said some but not all criteria would be appropriate while 19% did not feel that the criteria would be appropriate. Responses were broadly similar among individuals and organisations.

Potential advantages

Open comments at Question 43 were provided by nearly half of all respondents. The proposal to apply the listed criteria to all tenures was supported by some because it would help to ensure that all new build properties are future-proofed for the needs of an ageing population. Other potential advantages of the proposals included reducing the need for adaptations in the future and supporting people to live in their own homes for longer.

“The design criteria in Table 1 are appropriate and necessary for housing across all tenures to provide suitable housing for the diverse nature of Scotland’s growing and ageing population.” - Organisation

Potential disadvantages

The most prevalent theme in response to this question related to the perceived cost implications of the proposals and concern that they could reduce the supply and affordability of homes, especially smaller properties and those aimed at first time buyers. Some respondents identified potential negative unintended consequences for residents related to, for example, overheating, privacy and reduced usable space.

“There may be repercussions on the potential number of units delivered and the overall viability of a given site.” - Organisation

Need for greater flexibility

Some respondents noted that applying the criteria to all new build homes could be overly prescriptive and restrictive. These respondents called for more flexibility to allow for bespoke design solutions. Some respondents suggested that the criteria should apply to a proportion of new build properties, rather than all.

Specific proposals that respondents disagreed with

Some respondents identified specific criteria that they disagreed with. The responses were wide-ranging and many clauses were mentioned. Most notably, some disagreed with the proposal for removing tapered treads in the design of stairs within two-storey houses (clause 10.3.2). Other clauses mentioned included clause 7.8.3 (regarding handrails to entrance steps), clause 7.9.2 (regarding unprotected drops at the edge of paths and ramps), clause 8.5.2 (regarding the maximum height of an individual flight of stairs without a landing in communal areas) and clause 8.8.1 (regarding the design of communal areas to allow for the needs of people with visual impairment). Please refer to pages 76 to 89 of the consultation paper.

Calls for more information and clarification

There were calls for more information related to specific clauses. Again, responses were wide-ranging but the clauses specified included, for example, 7.4.1 (regarding the design of gates and positioning of ironmongery), 9.6.3 (regarding space provisions in circulation areas inside the entrance door to avoid obstructions), 11.2.1 as updated (regarding notional furniture), 12.1.1 (regarding the provision of adequate and easily accessible storage), 13.3.1 (regarding kitchen storage), 14.5.1 and 16.3.2 (regarding the positioning of baths, wash basins and WCs), and 17.2.1 (regarding access to controls for ventilation). Please refer to pages 76 to 89 of the consultation paper.

Question 44. Are there any other design criteria that are not currently proposed to be transposed into building standards that you would wish to see included within the Scottish Accessible Homes Standard?

Just over a fifth of all respondents provided open comments in response to Question 44. Some suggested specific additional criteria they would like to be included. Ideas were wide-ranging and there was little consistency among respondents. For instance, two suggested criteria related to safety: one was concerned about the risk of falls on stairs (a topic that is covered in more detail in Question 45) while the other suggested measures to enhance the safety of people with cognitive impairments such as radiator covers and locks on cupboards.

Other ideas, each suggested by one respondent, included:

• storage and charging facilities for mobility scooters
• restrictions on kitchen windows being placed above worktops or sinks
• ensuring the principal living room is predominantly south-facing
• Housing for Varying Needs design guide section 6.2 (designing for further adaptability) and clause 7.11.4 (signage at the entrance area to allow for the needs of people with visual impairment)

A few called for criteria specifically related to the needs of wheelchair users to be included.

“The concern about not including any reference to wheelchair housing in the Scottish Accessible Homes Standard is that the reliance for the provision of wheelchair housing continues to be on affordable housing. This means that there is no real incentive/compulsion on private developers to design a standard house type to meet the needs of wheelchair users. There needs to be consideration to cost/benefit analysis of enhancing standards across all tenures as there are wider policy issues at play here including enabling people to live in their homes for longer when life changes may mean adaptations are required including when people need fully accessible wheelchair housing regardless of what tenure they live in.” – Organisation

Question 45. Do you have any comments on the existing design guidance for stairs contained within Standard 4.3 of the Building Standards Domestic Technical Handbooks?

Just over a quarter of all respondents commented on the existing design guidance for stairs within Standard 4.3 of the Building Standards Domestic Technical Handbooks.

There was a variety of comments with little consensus among respondents. However, most commonly, some made observations about banisters. Some of these respondents advocated for using banisters in general, while others identified specified situations when they should be used, such as when winder stairs are used.

“Comments made by members are that stairs should have a banister/handrail on both sides.” – Organisation

“Handrails should be provided on both sides of a stair with winders as standard.” - Individual

Some respondents supported the inclusion of a spur for stair lifts, while a few argued tapered treads should be avoided for safety reasons, in contrast to those respondents who called for their use in Question 19 and Question 43. Two commented on space at the top and foot of stairs, and calls for stairs to be at a safe pitch were made by a few.

Other suggestions, each made by one respondent, included:

• restrictions on windows positioned on a stairway at banister height
• stairs in all new build properties to comply with British Standard 5395-1
• including the criteria for private stairs stated in British Standard 9266
• stronger discouragement of stairlifts obstructing the normal use of any external exit due to concerns about evacuation in an emergency

Question 46. Do you have any examples of situations where you have gone beyond the minimum standards for stairs or access between storeys set out by building regulations, and the benefits such an approach has delivered?

Just over a fifth of all respondents included an open comment or provided an example of going beyond the minimum requirements for stairs.

Some gave specific examples of relevant actions. Most commonly, examples of providing lifts, or measures to enable a lift to be installed in the future were given. For instance, one installed a communal lift in two-storey flatted developments for wheelchair users and other residents so that disabled residents on the ground floor could visit their neighbours upstairs. Another reported installing a stair lift in a resident’s home to support them to remain in their home. Two further examples are described in the quotes below.

“Lift access provided to flats resulting in re-housing a broad range of tenant groups including elderly, ambulant disabled and ultimately a high yield over a small footprint.” - Organisation

“I designed a large four storey flatted development where the landings in the common stairs were aligned with floor levels at the external walls so that lifts could be easily added when four floors are not deemed walkable for more of the population.” - Organisation

Two reported providing wider than regulation stairs to allow for handrails, one routinely provides handrails on external stairs to a dwelling regardless of the level change, and one reported using straight stair lifts rather than curved to allow faster journeys between floors.

Conversely, some commented on the existing standards, describing them as onerous and conflicting.

Question 47. Do you have any other comments on our proposals for the Scottish Accessible Homes Standard?

Two-fifths of all respondents provided other comments or proposals for the Scottish Accessible Homes Standard. The most common theme reiterated recurring comments across the consultation about the perceived cost implications of the proposals and their impact on housing affordability and supply. While Question 47 focused on the proposals for the Scottish Accessible Homes Standard, it appears that some respondents have included comments in response to Question 47 about the proposals for the updated Housing for Varying Needs design guide and, in some cases, it is unclear which they are referring to.

“We feel a number of the proposals will have a significant impact on house type design, increasing the size of the dwelling therefore increasing the purchase price of such dwellings when cost of living and affordability issues are so high. This may result in a number of developments becoming unviable for the developer and unaffordable for the house buying public, particularly during a period of housing crisis and number of plots starting is dropping.” - Organisation

A few respondents made suggestions related to the dissemination and presentation of the Standard, including calls for a web-based version and emphasis on the document being clear and easy to understand.

A small number noted that the proposals will increase the time required for verification checks and site inspections. Again, it is unclear if these comments refer solely to the plans for the Scottish Accessible Homes Standard only or the proposals for the updated Housing for Varying Needs design guide as well. Two suggested that updates to Part 1 of the Housing for Varying Needs design guide should be incorporated into Building Standards to encourage compliance.

Other comments, each made by one respondent, focused on:

• considering applying proposals to all housing to ensure all stock is flexible to society’s changing needs
• bringing together partners from housing and other sectors, including health and social care, with an interest in housing, and ensuring that achievement of the vision is not the sole responsibility of the housing sector
• the potential of the Scottish Accessible Homes Standard to help Registered Social Landlords more comfortably purchase privately-built properties under Section 75, with concern that this could lead to Section 75 purchases becoming standard practice for affordable housing providers rather than direct development
• Local Development Plans’ role in delivering a suitable variety of housing types

While not directly addressing the proposals for the Scottish Accessible Homes Standard, a small number used Question 47 to make comments about the public consultation. Two commented about the consultation paper itself. One described it as “confusing” and “arduous”. The decision not to include proposed updates to Part 2 of the Housing for Varying Needs design guide in the consultation paper was questioned by a few respondents as well as participants at a consultation event.