Memorandum by the Disability Rights Commission
(DRC) (AH 85)
INTRODUCTION
About the Disability Rights Commission
1.1 The Disability Rights Commission (DRC)
is an independent body, established by Act of Parliament in 1999
to eliminate the discrimination faced by disabled people and promote
equality of opportunity. We have set ourselves the goal of a society
in which disabled people can participate fully as equal citizens.
Our interest in this inquiry
1.2 Ensuring an adequate supply of affordable
and accessible housing is central to this mission. Lack of choice
and inappropriate housing has a fundamental and immediate impact
upon a disabled person's autonomy (40% of respondents to a survey
carried out for John Grooms Housing Charity felt their housing
situation made them unnecessarily dependent on other people)1,
but may also impact upon the experience of isolation, the role
in public life and ability to shape their community.
1.3 Disabled people of all ages are more
likely to live in poverty than non-disabled people and only one
in two disabled people of working age are currently in employment,
compared with four out of five non-disabled people and experience
social exclusion often in part due to their housing conditions.
The current shortage of accessible housing (and even just the
absence of any information on what accessible or adaptable housing
is available in most localities) for example makes it extremely
difficult for disabled people to consider applying for a job outside
of their current area.
1.4 We believe there is a huge gulf between
the current and future needs of Britain's 10 million disabled
people and the present supply. This is evidenced by:
— Research by ODPM which shows that
there are an estimated 1.4 million disabled people in England
who are in need of specifically adapted accommodation. Of this
total, nearly one quarter (320 000 disabled people) are currently
living in unsuitable housing.2
— Research by John Grooms Housing Association
which has estimated a countryside shortfall of 300 000 wheelchair
accessible homes.3
— The number of people who have required
wheelchair adapted homes in general needs housing and supported
housing has been steadily increasing from 2.6% to 3% and 1.4%
to 2.1% respectively.4
— In 1996-97, while undertaking a study
of housing needs of wheelchair users (Harris, et al 1997) Sapey
and Stewart identified what appeared to be approximately a 100%
increase in the number of wheelchair users in England and Wales
over the previous decade.5
— Research commissioned by the TCPA
(Town and Country Planning Association) which projects a need
for upwards of 200,000 new homes per annum to 2021 and shows that
the single biggest factor in the projected increase in the number
of households—between 25% and 30%—is the fact that
people are living longer. (Housing the next generation: Household
Growth, Housing Demand and Housing Requirements, A report for
the TCPA by Alan Holmans with Christine Whitehead of the Cambridge
Centre for Housing and Planning Research, University of Cambridge.
September 2005). As the Committee will be aware, there is a strong
correlation between ageing and impairment.
1.5 We believe there is a link between restricted
supply of housing and high house prices. This is a problem for
everyone but poses particularly acute barriers for disabled people
who are more likely than non-disabled people to live in poverty.
1.6 It follows that failure to tackle the
general crisis in housing supply will disproportionately impact
on disabled people who will face ever more restricted choice and
life chances. But we submit that it is not enough to clamour for
"more homes' or lower house prices. The crisis we face is
not just about affordability. It is, crucially, also about a chronic
dearth of housing which is accessible to disabled people and designed
to meet and adapt to the needs of occupants over their lifetime.
1.7 This is a crisis which the Barker Review
completely ignored and which there is no coherent Government strategy
to address. Our ageing population now makes this a fundamental
and mainstream issue for housing and planning. Failure to address
it will render any aspirations for truly sustainable communities
null and void. We would therefore urge the Committee to make this
issue a central focus and, to that end, we would be very eager
to provide further, oral evidence.
2. RESPONSE TO
SPECIFIC QUESTIONS
The potential benefits of and scope to promote
greater home ownership
2.1 Disabled people are currently overrepresented
in social housing. Economic and social inequalities, involuntary
exclusion from the labour market and a benefits system that fails
to adequately meet the extra costs associated with impairment
combine with inflated house prices to put home ownership out of
the reach of too many. We would certainly support action to widen
housing tenure options and choice for disabled people. We would
suggest that widening access to home ownership for disabled people
is likely to require specific strategies and initiatives. We would
further note that there are likely to be some disabled people
who may not wish to become home owners, for a variety of reasons,
and who would prefer to rent. Any housing strategy must also take
on board their needs for better choice in the private rented sector.
Whether we are seeking to expand home ownership or choice in renting
one thing is vital: developing and maintaining a much larger stock
of accessible/adaptable homes across all types and tenures.
The economic and social impact of current house
prices
2.2 House price inflation is an issue for
disabled people because it serves to put the option of home ownership
further out of reach, and thereby deprives people of real choice
and control in their own lives and entrenches patterns of social
exclusion. We consider it unlikely that the Government can meet
their goal of increased employment rates among disabled people
unless this issue is tackled effectively since disabled people
will continue to be deprived of the ability to move easily to
where suitable jobs may be in good supply. If the full provision
for new housing as set out in the Government's Sustainable Communities
Plan does not materialise it is likely that disabled people will
be amongst the first to lose out in the increasingly fierce competition
for homes.
2.3 We would also urge the Committee to
consider the economic and social impact on the life chances of
disabled people, children and older people of the failure of current
housing policy to insist on the Lifetime Homes Standards as the
norm for all new development. These Standards must become mandatory
in local and regional plans and in building regulations. See below
for further discussion.
The relationship between house prices and housing
supply
2.4 As stated above we believe there is
an obvious link between restricted housing supply and spiralling
house prices. Major development in specific locations is particularly
likely to affect prices. We consider that it is sensible for the
planning system to respond to price and affordability as long
as this is not the only or necessarily major determination. We
cannot, for example, address the housing crisis without planning
to meet current and future need for accessible and easily adaptable
homes. Key to this is: (a) making the Lifetime Homes standards
mandatory and (b) establishing a system for long term monitoring
and evaluation of the national housing needs of disabled people
across property types and tenure (a system which should be replicated
at regional and local level to enable authorities to much more
precisely meet the demand for appropriately designed and located
housing available for disabled people).
Other factors influencing the affordability of
housing for sale including construction methods and fiscal measures
2.5 Disabled people need not just accessible
homes but accessible homes connected to accessible transport infrastructure
and accessible public and community services. This requires significant
Government investment and a question mark hangs over the extent
to which planned investment is adequate to the task. It is right,
in our view, to expect house builders to contribute towards this
through Section 106 agreements or new tax measures such as those
proposed by the Barker Review. It should be possible to adopt
measures which contribute to the accessible housing and infrastructure
we need without creating disincentives to house building.
2.6 Here we would also point out that adopting
the Lifetime Homes Standards should not result in increased house
prices, since building to this standard is inexpensive. On the
other hand, we would point out the other very positive benefits
to the Exchequer of adopting these standards.
2.7 Adopting the Lifetime Homes Standards
would reduce the demand on land, materials and financial resources
required to provide institutional accommodation and make costly
alterations to existing dwellings. It would also enable the occupants
to remain in the same property for longer, maintaining their independence,
existing social links and connections to employment, education,
services and the local economy.
2.8 As the Prime Minister's Strategy Unit
report Improving the Life Chances of disabled people points out:
"Improving the suitability of new-build
and renovated homes for disabled people would also help reduce
future public expenditure on housing adaptations, equipment and
care services. Adopting Lifetime Homes Standards would save, on
average, £1,100 per dwelling on the cost of major adaptations
while the average cost of building a three bedroom, five person
house to Lifetime Homes Standards was calculated to cost an additional
£100 to £300 per dwelling (in 1997 prices). This was
calculated to be a total saving of £39million per year on
major adaptations. Further savings would also be made in terms
of expenditure on minor adaptations and equipment, care services,
hospital stays, and temporary residential care. Lifetime Homes
Standards apply to all age groups, including children and elderly
people, so the potential savings would be significant."
The scale of the Government's plans to boost housing
supply
2.9 In the light of the recent TCPA/Cambridge
University research showing a need for over 200,000 homes per
annum to 2021, the scale of the Government's current plans (as
outlined in the Communities Plan) appear rather modest. If, as
seems likely, these plans are further driven down by local authorities
and regional assemblies—without any consideration of the
impact upon disabled people—the consequences will be severe.
We are becoming increasingly frustrated by the Government's reluctance
to fully adopt the accessible housing agenda since this would
give disabled people such a strong stake in delivering the Communities
Plan.
The relative importance of increasing the supply
of private housing as opposed to subsidised housing
2.10 We attach equal importance to increasing
the supply of private housing and the supply of subsidised housing.
What is equally important to disabled people now and in the future
is securing a drastic increase in the supply of accessible and
easily adaptable housing across all types and tenures. Further,
there is a need for purpose built wheelchair housing as evidence
by the John Grooms and ODPM research.
How the planning system should respond to the
demand for housing for sale
2.11 There is a more fundamental question
which is how the planning system should respond to the demand
for housing which is truly sustainable and can meet the needs
of all members of a household over a lifetime. We have very clear
views on that as outlined above. We feel that the planning system
does need to take account of housing market information and an
understanding of housing markets as well—it is a question
of getting the balance right between this and social and environmental
objectives. Our most fundamental concern is to ensure that new
housing is sustainable. That involves adoption of Lifetime Homes
Standards but also tough eco-standards. Disabled people are likely
to benefit significantly from the latter given that they are disproportionately
likely to experience fuel poverty. Our Chairman, Bert Massie,
has spoken recently of his deep concerns over the impact on disabled
people of steep fuel price increases combined with what is expected
to be the coldest winter for years. Many impairments require extra
warmth yet only disabled people over 65 are currently eligible
for winter fuel payments. We have called for the urgent introduction
of comprehensive winter fuel payments system to protect disabled
people. In the longer term we would look to tougher eco-standards
for new housing to reduce reliance on such payments and remove
the need for them altogether.
The scale of housing development required to influence
house prices and the impact of promoting such a programme on the
natural and historical environment and infrastructure provision
2.12 It is clear to us that large scale
housing development, combined with tough new accessibility and
ecological standards for house building and increased investment
in accessible infrastructure and social housing, is necessary
to bring house prices down and to realise disabled people's aspirations
for equal citizenship. We see no reason why a properly managed
programme should not enhance the natural and historical environment.
As we understand it, the Government's intention is to reclaim
as many brownfield sites as possible. Further we would advocate
ensuring new builds are to the greatest extent possible carbon
neutral, energy efficient and even energy-generating with the
gardens and green spaces that research shows enables a far greater
level of biodiversity than you could find in your average green
field.
The regional disparities in the supply and demand
for housing and how they might be tackled
2.13 Fundamental to this will be requiring
local authorities to establish Disability Housing Registers or
equivalent schemes which could provide the basis for comprehensive
monitoring and evaluation—and thus better planning for—the
current and future housing needs of disabled people. Disability
Housing Registers are an increasingly popular mechanism of matching
disabled people with suitable, accessible housing reducing current
waste and delays. They can be operated within traditional housing
registers or within choice-based lettings schemes. As Shelter
has pointed out "Developing DHRs would promote more accurate
mapping of current and future levels of need." (Shelter memorandum
to Joint Committee on the Draft Disability Discrimination Bill,
February 2004). We have repeatedly called for such a system to
be placed on a statutory basis—indeed this was a recommendation
of the Joint Committee on the Draft Disability Discrimination
Bill.
2.14 Equally necessary will be realising
the vision of community involvement in planning. Certain levers
to address this have been included in recent planning legislation.
We would also draw the Committee's attention to the potential
of the forthcoming extension of the Disability Discrimination
Act 1995 to cover public functions (ensuring planning processes
are comprehensively covered) and, more particularly, the forthcoming
duties on the public sector duty to promote disability equality
(from December 2006) for ensuring disabled people's involvement
in ensuring sustainable regional and local housing development.
2.15 The Disability Equality Duty (DED)
marks a fundamental shift in disability discrimination law putting
the onus for change on the public sector, rather than disabled
individuals. Public authorities must give due regard in all decisions
and functions to the need to:
— Eliminate unlawful disability discrimination.
— Eliminate unlawful harassment.
— Promote equality of opportunity.
— Promote positive attitudes towards
disabled people.
— Encourage the participation of disabled
people in public life.
2.16 This is called "the general duty".
Public bodies with a specific duty are required to set out their
plans in a Disability Equality Scheme and to demonstrate how disabled
people have been involved and to monitor and report on progress.
Among those with specific duties are local authorities and regional
development agencies. Regional assemblies will be covered by the
general duty and there will equally be an expectation that they
should involve disabled people in deliberation on Regional Spatial
Strategies (reflecting certain requirements in regional planning
guidance). Disabled people are sure to use this to lobby locally
and regionally for the inclusion in development plans of explicit
policies on Lifetime Homes, provision of wheelchair accessible
homes and systems for mapping future need. Combined with the exhortation
on authorities to develop clear and comprehensive policies for
access and inclusion (a welcome addition to PPS1) the Disability
Equality Duty will provide an invaluable tool to promote accessible
housing through the planning system.
2.17 It is worth noting that the Greater
London Authority—to its great credit—has already taken
a lead here enshrining a requirement for all new homes to be Lifetime
Homes with 10% fully wheelchair accessible.
2.18 However there needs to be a strong
and clear lead given by the Government. Rather than merely expound
the virtues of Lifetime Homes or Disability Housing Registers
and urge voluntary compliance (something which in our experience
is just not going to deliver the changes needed quick enough),
the Government must make a clear, unambiguous commitment on these
matters now. And in the case of Lifetime Homes this means embedding
a requirement in the planning system and in the building regulations.
At the time of writing we are anticipating a shift away from a
commitment given to this very committee by the then Building Regulations
Minister, Phil Hope MP on 10 March 2004 to undertake a review
of Part M with a view to incorporating the standards. This is
of great concern and we hope it is something the Committee will
follow up.
REFERENCES
1 John Grooms Housing Charity (2003).
2 ODPM (2005) Survey of English Housing 2003-04.
3 John Grooms Housing Charity (2003).
4 CORE Social Housing Lettings Database 1998-99
and 2002-03.
5 The evidence for the increase in wheelchair
use lay primarily in two national studies. In 1986 the OPCS disability
surveys had put the figure of wheelchair users in England and
Wales at 360,000 (Martin et al 1989). Ten years later Aldersea's
(1996) investigation into the NHS Disablement Services showed
that the number was then approximately 710,170 in England, about
a 100% increase.
| 
