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

20. Impact assessments

The consultation paper concluded with five questions about the possible impacts of the proposals for the updated Housing for Varying Needs design guide and the Scottish Accessible Homes Standard on different groups of people, different communities and different businesses. This chapter presents the analysis of responses to Question 48 to Question 52.

Question 48. Do you have any feedback on any possible impacts that the proposals set out within Chapter 2 and Chapter 3 of this consultation paper may have on groups of people with protected characteristics, as identified in the Equality Act 2010?

Just under a third of all respondents left an open-text comment in response to Question 48 covering a range of protected characteristics, presented below from most to least frequently mentioned.

Disability

Some respondents highlighted the potential benefits of the proposals for disabled people. These included improved accessibility, more opportunities to live and work in different areas of Scotland, better physical and mental health, improved independence and the ability to remain living at home for as long as possible.

One, however, called for more consideration of the needs of people with profound and multiple learning disabilities, and another reiterated their disappointment that housing designed specifically for wheelchair users is excluded from the proposals for the Scottish Accessible Homes Standard.

Age

A few commented that the proposals could lead to an increased range of housing options that can better meet the needs of families with children. One noted the potential positive impact that providing space for studying at home could have on educational attainment.

The potential benefits of the proposals for older people were highlighted by some, particularly by helping them to live independently at home for as long as possible. A few highlighted the potential positive impact for physical and mental health and wellbeing.

“People who have protected characteristics around age or disability could be expected to benefit from the proposals making accommodation more accessible and contribute to their health, wellbeing and independence.” – Organisation

Sex and gender reassignment

Views about the impact of the proposals on groups of people with protected characteristics related to sex and gender reassignment were noted by some respondents. Comments focused on various issues including evidence that women may be less likely than men to have sufficient income to afford adaptations or better accessible housing, the dangers of making individual dwellings more visible for survivors of domestic abuse, and the disadvantages of requiring toilets at a higher level for women who tend to be smaller than men. Another respondent commented that needs related to gender reassignment should be considered in greater detail.

Pregnancy or maternity

One respondent noted that improved space standards would benefit households that use pushchairs and prams, while another felt this protected characteristic should be considered in greater detail but did not elaborate on why.

Race

Two respondents commented on the impact of the proposals on ethnic minority communities. One referred to research that suggests older ethnic minority households with physical disabilities often live in housing that is unsuitable for their needs. This respondent felt the proposals will have a positive impact but suggested that other barriers that ethnic minority communities face related to housing should also be considered, although they did not specify what they were.

Groups of people with protected characteristics in general

Some respondents made general comments about the impact of the proposals on groups of people with protected characteristics without commenting specifically on any individual group. Some reiterated that the proposals could reduce the supply of homes, especially affordable homes, and this could have an adverse effect on groups of people with protected characteristics. More positively, a few commented that the proposals would have a positive impact in terms of accessibility and independence.

Question 49. Do you have any feedback on any possible impacts that the proposals set out within Chapter 2 and Chapter 3 of this consultation paper may have on island communities which would be significantly different from the impact on other communities?

A fifth of all consultation respondents provided an open-text comment in response to Question 49. Aligned with the recurring theme of the perceived cost implications of the proposals, respondents commented that building costs can be higher in island communities than others. Some also noted the cost implications for rural areas more widely, not just island communities, arguing that high costs could negatively impact housing affordability and supply in rural and island communities.

As noted in Chapter 3, five housebuilder/property developers who submitted campaign responses elaborated on the possible negative impact on rural housing supply.

“If there is no assistance or mechanism to match subsidy to offset the increased build costs, then this will ultimately have a financial impact for residents in these communities as costs will inevitably need to be passed on.” - Organisation

“Island communities can encounter greater build costs with housing development and therefore may be affected to a greater extent by these proposals, impacting on the viability of developments.” - Organisation

Some highlighted challenges related to islands’ topography and weather, difficulties with accessing materials and tradespeople, and potentially poor mobile or internet coverage, while one warned of a possibly unreliable electricity connection in these areas.

“Due to the location and infrastructure of rural and island communities, it may be more difficult to meet enhanced accessibility/design standards. Construction is generally more expensive in Island developments, and there is lack of publicly owned land to build accessible housing. In terms of wider accessibility and the updated definition of adaptations, energy efficiency plays a key role, and this may be more difficult or expensive to do in rural and island areas, due to the nature of the climate, land, increased costs of labour and materials to build efficient homes, and the resources available for affordable energy.” - Organisation

“The build costs are already high on the islands which can further reduce ability to deliver houses to this standard. Grant requirements would be increased.” - Organisation

Question 50. Do you have any feedback on any possible impacts that the proposals set out within Chapter 2 and Chapter 3 of this consultation paper may have on the challenges that people can face as a result of socio-economic disadvantage?

Open comments were provided at Question 50 by just over two-fifths of all respondents. The most prevalent theme again related to the perceived cost of the proposals. Many respondents, mostly organisations, noted that the proposals could lead to increased property prices and rent costs, thereby having a negative impact on housing affordability. One respondent stressed that the costs of building more accessible social homes should not be funded by social tenants through increased rents. Several commented that the proposals would lead to larger dwellings and this could have other adverse financial impacts on residents such as increased costs related to energy, flooring and furnishing.

“This could restrict the access to affordable housing for people with socio-economic disadvantages.” - Organisation

“There may be a possible impact on people with low and/or no wealth; people from deprived areas; or people with a poor socio-economic background given that some of the proposals may mean developers face a higher cost per unit, which may affect house affordability for individuals.” – Organisation

“The knock on from this will hit family pockets and people who are more disadvantaged financially will struggle to cover the cost of living and the heating and upkeep of their homes.” – Organisation

Question 51. Do you have any feedback on any possible impacts that the proposals set out within Chapter 2 and Chapter 3 of this consultation paper may have on the human rights and wellbeing of children and young people?

Nearly a third of all respondents provided feedback about possible impacts of the proposals on the human rights and wellbeing of children and young people. A range of issues were raised but, most commonly, some respondents expressed concern about reduced housing affordability which could add to families’ cost of living challenges and have a negative impact on wellbeing among children and young people. However, a few respondents argued that enhancing the accessibility and usability of homes would have a positive impact for children and young people, especially those with health conditions.

“With regards to the ongoing cost of living crisis, there could be a detrimental impact on the wellbeing of children and young people.” – Organisation

“Enhanced accessibility, adaptability and usability of housing will benefit children and young people, as set out in the proposals.” – Organisation

Question 52. Do you have any feedback on any possible impacts that the proposals set out within Chapter 2 and Chapter 3 of this consultation paper may have on businesses and the third sector?

Open comments were included by nearly two-fifths of all respondents at Question 52. Many were concerned about the perceived cost implications of delivering the proposed requirements. Several respondents were particularly concerned about the financial impact of the proposals for Registered Social Landlords and other third and community sector housing providers. Some called for increased subsidies to support these providers.

“Some of the proposals will come at additional costs, which may impact on affordable housing providers’ ability to deliver these standards without increases in funding.” - Organisation

“The financial costs for landlords will increase significantly, and without additional financial support, the development of new affordable homes will decrease. This will have a knock-on effect on other third sector organisations who support persons in need.” - Organisation

Some noted the potential negative impact on builders and other businesses in the building supply chain. If fewer houses are built due to the perceived costs associated with the proposals, this could have a negative impact on businesses in the sector.

Two respondents suggested that the proposals could lead to reduced need for hospital and other residential care services, which could have a positive cost impact for society. One noted that the proposals may help people to live at home for longer, but this would increase pressure on services who care for and support people in the community.