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

5. HfVN Part 1 Section 7: Access to dwellings and provision for vehicles

This chapter of the report presents the analysis of Question 3 to Question 5.

Question 3. How do you feel about the proposal to update clauses 7.5.1 and 7.5.5 of the current guide to require that:

• all entrances to individual dwellings should be step free
• all entrances to individual dwellings should have an accessible threshold
• there should be a level area of at least 1200mm by 1200mm immediately in front of each entrance?

Just over a third of the respondents who answered Question 3 (37%) agreed with all the proposals (which applied to all dwellings except for those specifically designed for wheelchair users), 36% agreed with some but not all, 26% disagreed with all and 1% neither agreed nor disagreed. Support for all the proposals was slightly higher among individuals (43%) than organisations (36%).

Potential advantages

Nearly two-thirds of respondents to the consultation included open comments in response to Question 3. Several praised the proposals for enhancing homes’ accessibility, especially for older people and disabled people, and a few felt residents could experience reduced risk of falls as a result. A small number commented on the potential positive impacts on an individual’s health and wellbeing through, for example, being more able to access gardens and greenspace.

“Scotland's new homes need to be accessible for all to use. A ramped entrance will provide for this and will hopefully prevent falls for those who require mobility aids.” - Organisation

Potential disadvantages

Many respondents described the proposals as technically challenging and potentially unfeasible in some cases, especially sloping sites. This view was especially prominent among Registered Social Landlords and their representative bodies, architects, local authorities and housebuilders and property developers. As a result of the perceived technical and cost challenges, many felt these proposals should not be implemented ‘as standard’.

“Although this may be desirable in some scenarios it may not always be a feasible option depending on the topography of the site.” – Organisation

“Providing level access within a steep sloping site may be challenging to the design of the dwellings and this should be recognised as an exception.” – Organisation

Despite independent cost analysis of two sample house types within the consultation paper suggesting that the proposals would not result in additional costs, many felt that making all entrances to individual dwellings accessible would have cost implications that could reduce the supply of homes and make some sites unviable for development.

“These additions will result in sloping sites being undeliverable. Substantial costs will be incurred with the addition of retaining walls, drainage and the like. The increase in level area required will reduce the density of housing within sites, again making these undeliverable.” – Individual

“I do agree that where possible all entrances should be step free, however, this shouldn’t be ‘as standard’ as there are locations and situations that step free access to all entrances is not achievable without significant retention and cost which could result in sites [being] undevelopable.” – Organisation

Many commented on a potential increased risk of flooding as a result of level access at every entrance. A respondent noted water ingress (when water from outside makes its way into a building) could cause residents to slip, while another commented that an ‘accessible threshold’ should be defined in the context of fire regulations. One organisation warned the proposals could restrict residents’ privacy where there are shared pathways.

Other suggestions

Some respondents suggested that one entrance (or at least one) should be step free, rather than all entrances, while some called for the size of the level area to be greater than 1200mm by 1200mm, especially for people who use larger wheelchairs or prams.

Question 4. How do you feel about the proposal to update clauses 7.6.3 and 7.6.5 of the current guide to require that the entrance platform should have dimensions of at least 1500mm by 1800mm in cases where a communal entrance door opens outwards?

Just over two-thirds of respondents who answered the question (68%) agreed with the proposal (which applied to all buildings containing dwellings where the communal entrance door opens outwards), 22% disagreed and 10% neither agreed nor disagreed. Support was higher among individuals (80%) than organisations (65%).

Potential advantages

Slightly more than half of all consultation respondents provided open comments in response to Question 4. Several felt the proposal could make it easier for residents to access a building. Some noted this would particularly benefit wheelchair users, people with walking aids, and people using pushchairs, but others noted it would enhance accessibility for all residents. One argued that the proposal could help people to stay in their own home for longer.

“Too often these spaces are extremely small and confined and a fully able person sometimes has difficulty moving around these spaces. This would create a better, more open area to move around in.” – Individual

Potential disadvantages

Some commented on the potential costs of implementing the proposal, with a few disagreeing with the indicative cost outlined in the consultation paper. A less commonly mentioned theme related to potential technical difficulties, especially on sloped sites. Some respondents argued that existing guidelines are sufficient and do not need updated.

“The suggestion to augment the size of the entrance platform carries the risk of extending the distance between a dwelling and its front curtilage, resulting in a cost implication that surpasses the £27 per dwelling as proposed in the consultation.” – Organisation

Comments about presumed potential negative impacts of the proposal on residents or potential unintended consequences, each mentioned by one or two respondents, included:

• decreased accessibility if properties are sited further from car parking spaces
• safety concerns including difficulties of access in an emergency if doors and frames would need removed, and dangers for other users or visitors in flats
• possibly an increased distance to reach handrails at the platform edge
• potentially reducing floorspace inside the property to make room for the entrance platform
• a requirement for windows to be situated further back from entrances to avoid privacy issues in ground floor flats

Question 5. How do you feel about the proposals for the rest of the clauses within Section 7 of Part 1 of the current guide?

Among those who answered Question 5, 42% agreed with all the proposals for the remaining clauses in Section 7 (as set out in Annex G of the consultation paper), 39% agreed with some but not all, 8% disagreed with all, and 12% neither agreed nor disagreed. Individuals were more likely to agree with all the proposals (57%) than organisations (38%).

Specific proposals that respondents disagreed with

Just over half of all consultation respondents provided open comments in response to this question. Many respondents identified proposals they disagreed with and suggested clauses that should be retained, removed or amended. Respondents identified a wide range of clauses, with little commonality or consensus across responses. However, some respondents made nearly identical comments about clauses related to the width of gates (7.4.1) and any unprotected drop at the edge of paths and ramps (7.9.2), as illustrated in the quote below.

“7.4.1 – remove ref as twin buggies not relevant… 7.9.2… alternative wording ‘Any unprotected drop to the edge of path[s] and ramps is a hazard to anyone. The surface of a path should therefore be level or graded to the adjacent ground. Or provision for ramps should be as per the Technical Standards.’” - Organisation

In addition, several identified clauses where further information or clarification is required.

“The relationship between the requirements of 7.5 [entrances to individual dwellings] and subsequent requirements for steps in 7.8 could be clarified, in order to determine whether requirement of 7.8 applies to communal access areas only.” - Organisation

Comments about existing standards and guidance

Several organisations commented that existing standards and guidance are adequate. Some identified specific clauses that could be removed from the proposals because existing guidance or standards are adequate. Again, a wide range of clauses were referred to, but 7.9.2 (unprotected drops at the edge of paths and ramps) was mentioned repeatedly.

Many respondents agreed with proposals to remove clauses from the guide where these are already addressed within Building Standards to help reduce duplication.

“Agree there is no requirement for duplication if proposals have been factored into the Building Standards Technical Handbook.” – Organisation

Potential disadvantages

Some respondents commented on the perceived cost implications of the proposals and the negative impact this could have on the supply of homes. Several argued that the particular proposals should not be implemented ‘as standard’ but only where necessary or beneficial for a particular individual or group of residents.

Other drawbacks included potential negative impacts on residents. For instance, trip hazards could potentially occur because of clauses around steps such as 7.8.1 if they result in an unusual going or rise.

From a developers’ or landlords’ point of view, some respondents also referred to the challenging technical nature of certain clauses. For example, some argued that installing a canopy at all main entrance doors in dwellings specifically for older or disabled people, referred to in clause 7.12.2, could be impossible in exposed locations. However, it should be noted that the clause calls for a canopy or a porch.