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Raising Accessibility Standards for New Homes

Updated: Dec 11, 2020

The NPC's Housing Working Party has submitted it's response to the call for evidence for the Accessible Homes Consultation for the Ministry of Housing, Communities and Local Government.

The consultation details can be found on:

Download and read the NPC response below

NPC Evidence for Accessible Homes Consul
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Accessible Homes Consultation Ministry of Housing, Communities and Local Government 2nd Floor SW, Fry Building 2 Marsham Street London SW1P 4DF

20 November 2020

Dear Sir/Madam

NPC Evidence for Raising accessibility standards for new homes


The National Pensioners’ Convention (NPC) is Britain’s biggest independent organisation of older people, representing around one thousand local, regional, and national pensioner groups with a total of 1.5 million members. The NPC is run by and for pensioners and campaigns for improvements to the income, health and welfare of both today’s and tomorrow’s pensioners and this response is based on the views and experiences of our members and Housing Working Party. We wish to submit the following views to the Accessible Homes Consultation.

Raising accessibility standards for new homes

We urgently need more accessible homes to end the growing shortage as currently, 91% of our homes do not provide the four access features for even the lowest level of accessibility.

We know that accessible and inclusive homes can help to improve our independence at home, keep us safer, and delay or avoid unwanted moves to more specialist housing all of which can help lower costs for social care and NHS care.

At the same time having an accessible home can improve wellbeing, foster social and family relationships, and reduce isolation and loneliness. Building homes that are future-proofed, will help make housing more sustainable and reduce the environmental impact. Building to accessible and adaptable standards does not cost the earth. Crucially, were all homes built to the same higher standard this would level the playing field and lower the average additional costs.

The reality is that millions of older people live in homes that do not meet our daily needs. England’s existing housing is simply not suitable for the diverse and changing needs of our ageing population, and often the new homes we build are not either.

In the next twenty years, there will be a huge age shift in our society with one in four of us aged over 65. One in five adults aged 65-69 need help with one or more activities of daily living (such as bathing, cooking, or using the toilet). By the time people reach their 80s, this figure rises to more than one in two of us. But as it stands, only one new accessible home is planned for every fifteen people over 65 by 2030.

Contrary to common misconceptions, more than 90% of older people live in mainstream housing rather than specialist housing or care homes. Understandably, most of us want to stay in our own homes, streets, and communities for as long as we can, and our homes should enable more of us to do this. We must build new homes that meet the current acute need and the growing future need in mind.

Changes are now needed to regulations, so they equally apply to newly built homes and older homes as the ‘default’ position. Alongside this should be an increase in the supply of wheelchair accessible housing.

The following is our response to the questions posed in these consultations:

Question 3: Do you support the government’s intention to raise accessibility standards of new homes?

Answer Yes

Please explain your reasons.

Answer The government is right to seek to raise accessibility standards. To achieve this, the government must include making the accessible, adaptable design standard (M4(2)) the mandatory baseline for all new homes as the starting point. The reality is that millions of us, particularly those who are older or disabled, live in homes that do not meet our daily needs.

Question 4: Which of the 5 options do you support? You can choose more than one option or none.

Answer Option 2 and option 4.

Question 5: Please explain your reasons, including the advantages and disadvantages of your preferred option(s).

Answer Option 1 is effectively to ‘do nothing’. This is not acceptable and will have a negative impact on the lives of older people now and in the future. We have a dire shortage of accessible and adaptable new homes and to continue to do nothing to address that would be a disaster for our growing population of older and disabled people. The government should lower the current high bar needed to introduce relevant planning policies. By making M4(2) mandatory, we believe that this will help to free up local authority capacity by removing the need to make the case locally. We would like government to set a firm expectation that all local authorities maintain a register of the number of people awaiting wheelchair accessible housing in their area along with details of their household profile and tenure type that will help to plan the right homes to meet needs across the country.

Option 3. We are opposed to Option 3: as this proposes to get rid of M4(1) altogether and only allow homes to be built to M4(2) or M4(3). This will have similar consequences to Option 2 but removes the ability for any home to be built to the previous M4(1) standard. Whilst this should result in more accessible homes being built, the requirement for homes to have a no step entrance in order to meet M4(2) would prevent some much needed homes from being created at all and could therefore reduce delivery of new homes (which in turn could have a negative impact on development longer term). We believe there is a case for allowing a M4(1) to still apply. However, this must be exceptional and extremely rare with strict tests that developers will have to meet to prove that M4(2) is not possible. The default position must be that every home is required to meet M4(2) as a minimum.

Option 4: We are supportive of Option 4 if additional steps are taken to support its success. on mandating M4(2) homes as the new baseline, with M4(1) applying only in exceptional circumstances where M4(2) cannot be achieved and setting a nationally applicable percentage of new homes to M4(3) wheelchair user standard. national and local government support the development of a national accessible housing register so that it is much easier for wheelchair users to find and apply for suitable housing in which ever location and tenure they require.

Option 5: We object to this option as we believe that option is not as strong as M4(2). We believe that M4(2) as it is currently worded captures what should be minimum standard for new homes.

Question 6: Do you agree with the estimated additional cost per dwelling of meeting M4(2), compared to current industry standards, in paragraph 44?

Answer No.

If no, please comment on what you estimate these costs to be and how you would expect these costs to vary between types of housing e.g. detached, semi-detached or flats? Please provide any evidence to support your answers.

Answer Construction costs would be much lower if councils were to jointly work with other neighbouring councils to establish their own building direct labour organisations. This would also allow for much needed work of aids and adaptions and would take out the typically 20% profit margin made by contractors and thereby lower the overall cost of building these homes.

Question 7: Do you agree with the proportion of new dwellings already meeting or exceeding M4(2) over the next ten years in paragraph 44?

Answer No

If no, please comment on your alternative view and how you would expect this to vary between types of housing e.g. detached, semidetached or flats? Please provide any evidence to support your answers.

Answer Over the past decade, the English Housing Survey shows we have only managed to increase the number of households with at least one adaptation for a person with a disability by 1%, from 9% to 10%. Only 9% of homes in England have all four accessibility features. In the next twenty years, there will be a huge age shift in our society with one in four of us aged over 65. By the time people reach their 80s, this figure rises to more than one in two of us. But as it stands, only one new accessible home is planned for every fifteen people over 65 What is clear is that the existing number of accessible homes is woefully inadequate for current needs. We should be building in more costs in adaptations needed in the future.

Question 8: Do you have any comments on the costs and benefits of the other options set out in the consultation document?

Answer Yes

If yes, please provide your comments including any evidence to support your response.

Answer. The positive social impact of building more accessible homes has the potential to be vast. We would expect this to reduce demand for NHS and social care services.

The “Better Care fund” needs to be hugely increased from the £5050m of Disabled Facilities Grant in 2019-2020 (1)

Question 9: Do you have any comments on the initial equality impact assessment?

Answer No

Additional comments

The scope for this consultation is too narrow as there is an urgent need for a review of all aspects of accessibility and adaptions needed for older people’s homes not just space standards. Such as:

· Fuel efficiency

· Environmentally friendly

· Fire safety

· Easy reach facilities, cupboards, electrical and water connection.

· Far better design of all adaptions.

· Size of rooms to meet all individual diverse needs.

· Communications connection for internet TV and phone.

· All aspects relating to homes and disability

We need homes designed to minimise maintenance and cleaning tasks and ease of access .to facilities. For those who are vulnerable and have a disability for example, there should not be any high-level cupboards or utilities build into these homes. Equally we do not want to have to kneel on the floor to reach plugs or low-level deep cupboards. All bathrooms should have walk in bath or shower facilities. Most homes should be built at floor level If not, lifts that work and have mechanical assistance staircase lifting equipment installed. Emergency contact utilities be installed in all homes and include a supply of mobile emergency devices. Access to buildings should be level as some have or incline with gardens for dogs that assist those blind or who have impaired vision.

Overall, we know that over 2 million older people are living in non-decent housing in England. Overall, we know that over 2 million older people are living in non-decent housing in England. According to a report in July 2019 by the cross-party group of MPs (2) older people are suffering physical and mental ill-health and face early death because of living in substandard and non-accessible homes.

Yours Sincerely

Jan Shortt

General Secretary


3.Ageing Better calculations based on ONS (2019), ‘Population projections’ & Habinteg (2019), ‘A forecast for accessible homes’. Available at:

4. Foundations (2015), ‘Linking Disabled Facilities Grants to Social Care Data: A freedom of information survey’. Available at:

Your requested information of us.

Name: Jan Shortt

Position: General Secretary

Name of your organisation: National Pensioners Convention.

Address: Marchmont Community Centre. 62 Marchmont Street, London, WC1N 1AB.

Email address:

contact telephone number: 02078376622.

We are applying to this consultation as a Campaigning organisation



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