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

3. Overview of campaign responses

This chapter provides an overview of the campaign responses received to this consultation before the following chapters analyse each question in turn.

Twenty respondents submitted a campaign response to the consultation; 17 were from housebuilders/property developers, two were from architecture organisations and one was from an individual.

While these campaign responses did not directly answer the closed or open consultation questions, the themes in their responses did align with some themes raised by other respondents. To avoid the thematic analysis being dominated by the views put forward by the campaign, the key themes have been summarised here, then noted at appropriate points throughout the report.

These campaign responses used very similar wording. After introducing their organisation and the nature of their work, respondents expressed support for the delivery of more homes suitable for people with a variety of accessibility needs.

However, they highlighted their concern that the current minimum standards are becoming unaffordable, and that introducing new standards could impact the number of affordable homes being built. This is consistent with concerns expressed by consultation respondents more widely.

It was noted that private homes are built to the accessibility standards set in the current Building (Scotland) Regulations 2004 (as amended), that new homes regardless of tenure adhere to the 'Building Standards technical handbook: domestic buildings', and that developers already consider the possibility of future adaptation to homes as residents’ needs change over time.

Respondents who submitted a campaign response highlighted that their concerns about the proposals in the consultation paper align with those expressed by their representative organisation, specifically:

“The proportionality of the proposals given that new homes of all tenures in Scotland are already built to ensure an enhanced level of accessibility and adaptability.

The cumulative impact on all-tenure housing supply given the associated increase in costs and building footprint.

Reductions in the delivery and affordability of homes for First Time Buyers.

The challenge of increased development costs for SME (small and medium-sized enterprises) home builders.

The timing of the consultation engagement sessions (most of which took place within a month of the closing date leaving insufficient time for active participation between government and business, contrary to the New Deal for Business).

The state of constant policy change and lack of alignment across Scottish Government directorates in relation to housing supply.”

In relation to the fifth point, it should be noted that there will be the opportunity for further stakeholder engagement beyond the consultation.

These respondents typically concluded their submission with a short, personalised statement which reiterated the need to consider the potential cost implications of the proposals and the impact this could have on the supply of affordable housing in Scotland. For example:

“Given the age of the Housing for Varying Needs guidance documents, the review of these is a positive step. This will ensure that homes for those that have varying needs are appropriately accommodated for. However, applying the standard to all new homes extends beyond what is required, and will result in higher construction costs.” - Organisation

Five of the 20 campaign responses included additional text elaborating on the impact of the proposals on the supply of affordable housing in rural areas. These comments have been included in the analysis of Question 49 in Chapter 20, which sought feedback on any possible impacts that the proposals set out within Chapter 2 and Chapter 3 of the consultation paper may have on island communities which would be significantly different from the impact on other communities.