In direct response to our advocacy to the Building Ministers Forum, the Australian Building Codes Board (ABCB) is undertaking Regulatory Impact Assessment (RIA) of options for potential minimum accessibility standards for housing, to be applied through the NCC. Called the Accessible Housing Project, it includes any housing that has features to enable use by people either with a disability or through their life stages. The RIA will consider the Livable Housing Design Guidelines Silver and Gold level specifications as possible options for a minimum accessibility standard, and additional options identified through consultation.
Options Paper Consultation Report
The Options were outlined in the ABCB’s Options Paper and was accompanied by a national consultation last year. The result of that consultation is now available in the Options Paper Consultation Report.
Some of the key issues raised in the submissions on the Options Paper are summarised below:
- There is a need to consider aligning the project objectives to the concepts of equity and independence, and consideration of the principles of universal design.
- Previous government commitments, including the UN Convention on the Rights of Persons with Disability and the COAG National Disability Strategy, were generally interpreted as commitments to regulate accessible housing.
- The prevalence of households with an occupant with a disability and the future impact of the population ageing need to be properly taken into account in establishing the need for regulation of accessible housing.
- Consideration should be given to the application of accessible housing provisions on difficult sites, where local planning policies may also impact upon the feasibility of an access standard applied to housing.
- Consideration should be given to residential tenancies legislation that may be restricting some groups from obtaining suitable housing or modifying rental housing to improve its accessibility.
- The importance of a step-free path to the dwelling entry door, and conversely, the practical difficulties associated with mandating such a feature in 100 per cent of circumstances.
- Whether or not features that are more difficult to retrofit — generally referred to as ‘structural features’ — should be prioritised in the design of possible NCC changes.
- Qualitative, or intangible, benefits should be identified and given due consideration in the RIS, as well as ensuring that it goes beyond consideration of people with a disability. Generally, stakeholders suggested that such benefits include reduced social isolation, and increased community participation and inclusion.
- It is important that costs are accurately quantified and the distribution of costs and regulatory burdens between industry and consumers is clearly identified.
- Although outside the scope of the NCC, non-regulatory options — including financial incentives and the further development and promotion of voluntary guidelines — should still be assessed against regulatory options and considered by governments.