Joint briefing to Hon Phil Twyford

Minister of Housing

13 November 2017

1

Executive summary We fully endorse the Prime Minister’s statement that housing is a right.

The Convention on the Rights of Persons with Disabilities requires

governments to ensure disabled people access, on an equal basis with

others, housing

The New Zealand Disability Strategy requires the government to ensure

disabled people have access to warm, safe and affordable housing.

With an ageing population, the number of people who need accessible private

homes and social housing is rapidly growing.

Previous research has found strong evidence of a significant undersupply of

accessible private homes and social housing

It is often difficult to make homes accessible once built. Retrofitting homes is

expensive, time-consuming and sometimes impractical.

It is vital that Kiwibuild homes use universal design.

Universal design is not a requirement for private housing in the building code

and therefore building inspectors do not check for compliance.

An independent checking process is required to ensure universal design

features are included.

A review we did of most social and private sector housing developments

found that three key access features were present in about 5% of all new

homes built and that only 2% of new dwellings would meet the higher

standards of a Lifemark® 3 star rating.

In our experience, when the right incentives are in place, building

professionals can easily incorporate these features provided they have

access to expert advice and guidance.

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RecommendationsThat you, together with the Minister for Disability Issues, meet with Lifemark® to

discuss how universal design can be used in the Kiwibuild programme.

That you work together with the Minister for Disability Issues to:

Actively promote Lifemark® 3 star rating as a minimum requirement for all

housing.

Actively promote a Lifemark rating process for all Kiwibuild homes.

Require all social and affordable housing to achieve Lifemark® 4 & 5-star

ratings. This should eventually be enshrined in the new Access Law.

Ensure the new Housing Commission has the availability of affordable

accessible housing as a key area of focus.

3

ContentsExecutive summary.....................................................................................................1

Recommendations......................................................................................................2

Introduction.................................................................................................................4

About CCS Disability Action....................................................................................4

About Lifemark®.......................................................................................................5

The right to housing....................................................................................................6

We need more accessible social and affordable housing...........................................6

Kiwibuild....................................................................................................................10

Recommendation..................................................................................................11

New housing should use universal design................................................................11

Setting a standard for universal design.................................................................12

Minimum requirements..........................................................................................13

Lifemark® can ensure New Zealand has a standard for accessible housing.........13

Exemplar projects..................................................................................................14

Housing commission.............................................................................................15

Recommendations.............................................................................................15

Conclusion................................................................................................................15

Bibliography..............................................................................................................17

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IntroductionDisabled people are more likely to need social and affordable private housing1. Yet

housing providers and developers have often not considered their needs. The 2013

Disability Survey found that 107,440 people with a physical impairment had an

unmet need for a house modification. 26,880 people with a vision impairment had an

unmet need for a housing modification.

When people make do with an inaccessible home they often face an increased risk

of injury. It can also prevent them from being as productive and as engaged with

their local community as they could be. A lack of accessible housing, including social

housing, is one of the factors holding back disabled people from being involved in

and contributing to society.

The government urgently needs to take a leadership role and actively promote

accessible social housing. With an ageing population, it makes social and economic

sense to promote and invest in accessible housing. We recommend that all new

houses meet universal design standards, especially the houses built through the

Kiwibuild scheme.

This will position New Zealand as a leader in universal housing design and

accessible housing.

About CCS Disability ActionCCS Disability Action is a community organisation that has been advocating for

disabled people to be included in the community since 1935. As of May 31 2017, we

were providing support to around 4,000 children, young people and adults through

our 17 branches, which operate from Northland to Invercargill. Our support focuses

on breaking down barriers to participation. We receive a mixture of government and

private funding.

Accessibility is a major focus for our organisation. CCS Disability Action runs the

Mobility Parking Scheme. We have a nationwide network of access coordinators who 1 The 2013 Disability Survey found that disabled people are more likely to live in low income

household and are more likely to rent their house.

5

work with local government as well as the building and transport industries. We are

rolling out a new accessibility app called Access Aware. We are a member of the

Access Alliance, which is pushing for a new Access Law. We have developed ways

to collect data on accessibility, including the Measuring Accessible Journeys project

and the Street Accessibility Audits.

We established Lifemark®, which certifies and promotes accessible housing. The

government initially provided some support for setting up Lifemark®. Since then we

have had to fund Lifemark® ourselves. While Lifemark® is making progress; we need

more government support to expand Lifemark® to truly prepare New Zealand for our

ageing population.

About Lifemark®

Lifemark® work alongside developers, architects, designers and builders to offer

advice on how to make best use of space in a home, based on the principles of

Universal Design. Any new home design and any size home can be Lifemark® rated.

It is about designing to have space in the right place.

Lifemark® rated homes are designed to be usable and safe for people of all ages and

stages. They are easy to live in – for a lifetime. Universal design is as equally

applicable to first homes as it is to forever homes. Lifemark standards ensure safer

and more flexible living solutions that are responsive to the needs of different

occupants, for the life of the home. These requirements do not require more space

and fit comfortably in an affordable building programme, because the lifetime costs

of the home are significantly lower and the initial additional capital requirements are

negligible.

First home buyers in particular will benefit from flexible spatial designs and product

specification and selection that will reflect their changing needs.

6

The right to housingWe fully endorse the Prime Minister’s statement that housing is a right (Cooke,

2017). The Convention on the Rights of Persons with Disabilities has two articles

that apply to housing.

Article 9This article requires governments to ensure disabled people access, on an equal

basis with others, housing.

Article 28 This article requires governments to:

1. Ensure disabled people have adequate housing.

2. Ensure access by disabled people public housing programmes.

The New Zealand Disability Strategy requires the government to ensure disabled

people have access to warm, safe and affordable housing. The Strategy also

requires the government to consult with disabled people on legislation and policies

concerning housing (this includes home ownership, social housing and private

rentals) (Office for Disability Issues, 2016, pp. 32-33).

We need more accessible social and affordable housingWith an ageing population, the number of people who need accessible private

homes and social housing is rapidly growing. Previous research has found strong

evidence of a significant undersupply of accessible private homes and social housing

(Saville-Smith, James, Fraser, Ryan, & Travaglia, 2007, pp. 50-53)

A lack of accessible housing limits the choices available to disabled people. This, in

turn, can limit their involvement with the community, their ability to find employment

and is likely to increase their dependence on government-funded support services

(Saville-Smith & Saville, 2012, p. 14).

Disabled people are also not a static group. The line between being ‘able-bodied’

and having an impairment is thin. All people can gain impairments that in turn give

7

them access needs. Access needs are no problem if the built environment is

accessible. If not, people can be force out of the workforce or even their home.

Even parliamentarians can gain access needs

Disabled people are more vulnerable to housing issues. Disabled people have lower

incomes, are more likely to rent and are more likely to have problems with their

housing. Across every age-range, disabled people are more likely to be renting a

house, rather than owning it.

0-14 15-44 45-64 65+0%5%

10%15%20%25%30%35%40%45%50%

Percentage renting - 2013 Disability Survey

Disabled peopleNon-disabled people

8

Disabled people are more likely to live in low-income households and have lower

personal incomes. The 2013 Disability Survey found that:

33% of working age disabled people live in households that earn under

$50,000 a year, compared to only 21% of working age non-disabled people.

17% of working age disabled people live in households that earn under

$30,000 a year, compared to 10% of working age non-disabled people.

17%

15%

16%

51%

Working age disabled people household income

Less than $30,000 $30,001–$50,000$50,001–$70,000 $70,001+

10%

11%

15%64%

Working age non-disabled people household income

Less than $30,000 $30,001–$50,000$50,001–$70,000 $70,001+

In addition, the 2016 General Social Survey found that 20% of disabled people

reported not having enough income to meet every day needs, compared to 10% of

non-disabled people. 52% of disabled people either had not enough or only just

enough money, compared to 34% of non-disabled people.

Not enough money

Only just enough money

Enough money

More than enough money

0%5%

10%15%20%25%30%35%40%45%50%

Enough income to meet everyday needs

Disabled peopleNon-disabled people

9

The 2013 Disability Survey using a similar question, found that 27% disabled Māori

reported not having enough income to buy everyday things, compared to just 7% of

non-disabled Māori.

Not enough money

Just enough money

Enough money

More than enough money

0%5%

10%15%20%25%30%35%40%45%50%

Enough income for everyday things

Disabled MāoriNon disabled Māori

Disabled people are more likely to have difficulty keeping their house warm and are

more likely to experience dampness. Disabled people are also twice as likely,

compared to non-disabled people, to report other housing problems (such as

weather tightness issues).

Difficu

lty ke

eping

hous

e warm

Experi

ence

s dam

p

Other h

ousin

g prob

lems

0%

10%

20%

30%

Housing problems - 2013 Disability Survey

Disabled peopleNon-disabled people

10

Disabled children are more likely to live in an overcrowded house.

Need m

ore be

droom

s

Enoug

h bed

rooms

Spare

bedro

oms

0%10%20%30%40%50%60%

Household crowding measure - 2013 Disability Survey

Disabled childrenNon-disabled children

In the 2013 Disability Survey, 17% of people with physical impairments, or 107,440

people, and 16% of people with vision impairments, or 26,880 people, had an unmet

need for housing modifications. Our ageing population means the number of

disabled people is likely to increase. Disability rates increase with age. In the 2013

Disability Survey people over 65 had a disability rate of 59%, compared to 28% of

people aged 45 to 64 and 16% of people aged 15 to 44.

When people make do with an inaccessible home they often face an increased risk

of injury. It can also prevent them from being as productive and as engaged with

their local community as they could be. A lack of accessible and affordable housing,

including social housing, is one of the factors holding back disabled people from

being involved in and contributing to society.

KiwibuildThe plan to build 100,000 warm, dry, well designed, affordable homes will make a

difference to our housing market. It is vital that Kiwibuild homes use universal design

and incorporate access features throughout the building programme. Otherwise,

people with access needs and their whānau will be further disadvantaged.

Without the adequate consideration of accessibility, Kiwibuild will be only a

temporary fix. With the ageing population, a growing number of families will have

members with access needs. Unfortunately, it is often difficult to make homes

accessible once built. Retrofitting homes is expensive, time-consuming and

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sometimes impractical (BRANZ). It is of limited value to make homes affordable, if

the necessary access modifications are then too expensive, or impractical, for

owners to afford later. In addition, when access features are added at a later stage,

the government must often pay through ACC or health funding. A whole of

government approach would take advantage of the opportunity to save future

spending by using universal design on new homes.

We recommend that the Government consult with Lifemark® early on to determine

the best way for Kiwibuild homes to incorporate universal design. Universal design

ranges from basic accessibility features with the ability to make future changes easily

and cheaply through to fully accessible housing. For example, Lifemark® has three

levels of star ratings. A Lifemark® 3 star standard delivers baseline accessibility and

a 5 star standard delivers a house that can meet the needs of nearly every tenant.

Recommendation That you, together with the Minister for Disability Issues, meet with Lifemark®

to discuss how universal design can be incorporated and included in the

Kiwibuild programme.

New housing should use universal designNew Zealand has yet to make universal design in housing a priority. The design of

houses is focused on water tightness, energy efficiency, colour pallets and the use of

sustainable materials. While all these are important, they need to be balanced with

making sure everyone can use and access houses. Sustainability needs to extend to

the sustainability of the home for the owner/tenant’s lifetime, during which they and

people close to them are likely to gain access needs.

Our ageing population is not an immediate issue so tends to get overlooked by

government and housing developers. The rights of New Zealanders with disabilities

are equally overlooked. We are failing to deliver the right type of house for the right

person.

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We need the government to show leadership and guide the development of housing.

Every day and long-term requirements need to be balanced against each other.

Currently, the lack of universal design features in most housing developments is very

concerning.

The Kiwibuild programme is aimed at first home buyers, however, the ages of these

people will range from 20’s to 50’s. Over the life of the housing asset, there may be

many different occupiers. The Government has the opportunity to be strategic and

deliver a future-proofed housing environment.

Setting a standard for universal designMost architectural practices in New Zealand have only a limited understanding about

universal housing design, and almost none have primary user expertise. Universal

design is not a requirement for private housing in the building code and therefore

building inspectors do not check for compliance. The result is that any requested

universal design features are not quality assured and therefore inconsistently

delivered, if at all.

As a result, we have developed standards and a process to ensure universal design

delivery. Lifemark® standards are based on universal housing design best practice.

We first released the standards in 2012 and then updated these standards in 2016 to

reflect changes in technology and incorporate medium density developments. The

standards are based around 17 areas in a dwelling and provide a mix of options for a

designer that encourages flexibility and innovation in design, whilst satisfying the

fundamental concepts of accessibility, safety and usability.

These standards relate to how people live, rather than building or structural design

integrity. They are people centred and improve the social and health outcomes for a

wide range of people, including those with temporary or permanent disabilities. The

inclusion of these standards at the initial build, reduces the requirement for future

modifications due to changes in age or health. A dwelling that is not suitable for a

person after hospitalisation will require modifications costs and can also make life

more difficult for the person as well as increase the risk of injury. Developers are

13

currently excluding people from homes, or limiting their movements, because of poor

design features and a lack of inclusive foresight.

We also provide a plan review, assessment and feedback service that ensures these

features are included and then managed throughout the build process. Simply

providing standards and contract specifications, does not, ensure the delivery of

accessible dwellings. A quality assurance service is also required.

Minimum requirementsThe Lifemark® rating system has 80 standards for home design as well as a plan

review and advisory service. Many of these standards are considered global best

practice for accessibility. Global best practice at a bare minimum would require that

three simple criteria are met.

These are:

1) A step free pathway and entrance;

2) A bathroom on the same floor as the entry level that can be used by most

people;

3) Doorways and circulation space that allows for easy movement around the

house.

A review we did of most social and private sector housing developments found that

these three features are only present in about 5% of all new homes built and that

only 2% of new dwellings would meet the higher standards of a Lifemark® 3 star

rating. The exclusion of these features in housing developments is of grave concern

considering our ageing population and the current needs of disabled people.

Lifemark® can ensure New Zealand has a standard for accessible housingA Lifemark® 3 star standard or similar delivers baseline accessibility and a 5 star

standard delivers a more resilient dwelling that can respond to the changing needs of

nearly every tenant. Given that a housing asset should last for between 50 and 100

years, the inclusion of universal design features is of critical importance. The way to

ensure universal design features are included in housing projects is to have a robust

independent feedback and review process. Specifying universal design features in a

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housing development without actually assessing and certifying the features leads to

ad hoc compliance and variable performance.

Feedback and review needs to be provided throughout the housing development

process. Waiting until the end to assess a housing project, often means expensive

retrofitting is needed. The saying “a stitch in time saves nine” is very apt for universal

design processes.

Lifemark® offers a robust review process that incorporates a baseline accessibility

report at the concept stage before resource consent is issued as well as a

provisional certificate of performance for each individual dwelling before building

consent is awarded. A final certificate for each dwelling is provided before the code

of compliance is issued for the dwelling to ensure a measurable and reliable

process.

Exemplar projectsWe have been involved in several large housing projects that have had universal

design as a requirement for between 33% and 50% of all new dwellings. These

developments are the Tamaki regeneration project and the Christchurch East frame

project developed by Fletcher Living. Both projects are using the Lifemark®

independent rating system as a mechanism to check and ensure accessible best

practice is followed.

Both of these projects requested universal design features at an early stage of

development. Because of our early involvement, the architectural firms involved in

these developments were able to come up with creative solutions that limited costs.

In our experience, when the right incentives are in place, building professionals are

able to include universal design features at minimal additional cost. The inclusion of

universal design will also deliver the right new trade skills for any apprentice builders

who work on these projects.

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Housing commissionWe note that the Coalition Agreement between the Labour Party and the New

Zealand First Party commits to the establishment of a Housing Commission. This

Commission should have the availability of accessible affordable housing as one of

its key areas of focus.

There are a range of inefficient policies with access improvements that the

Commission should investigate. For example, Housing NZ sometimes strips house

of accessibility features between tenants as part of their standard maintenance

process. Yet there are people with access needs on the waiting list. It also means

that if new tenants gain access needs the features have to be reinstalled, often at the

government’s expense.

RecommendationsWe recommend you work together with the Minister for Disability Issues to:

actively promote Lifemark® 3 star rating as a minimum requirement for all

housing.

actively promote a Lifemark rating process for all Kiwibuild homes

require all social and affordable housing to achieve Lifemark® 4 & 5-star

ratings. This should eventually be enshrined in the new Access Law.

ensure the new Housing Commission has the availability of affordable

accessible housing as a key area of focus.

ConclusionToo often disabled people do not get a fair go. They do not get the same

opportunities as non-disabled people. This affects the lives of disabled people and

also impacts the wider community as well as New Zealand’s economic performance

and international reputation. This is true of housing, where the needs of disabled

people are seldom at the forefront of housing developments.

Yet we have an ageing population and the number of people who have access

needs will grow and grow. We need to urgently prioritise universal design in housing.

Investing in accessible housing is investing in the future. 100,000 accessible and

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universally designed homes will make a significant difference to the lives of many

New Zealanders. Thank you for taking the time to read this briefing.

17

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sn=215&st=1&pg=11034

Cooke, H. (2017, October 31). Labour will make all existing homes 'sensitive',

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https://www.stuff.co.nz/national/politics/98417459/labour-will-make-all-

existing-homes-sensitive-effectively-banning-foreign-buyers

Office for Disability Issues. (2016). New Zealand Disability Strategy 2016-2026.

Wellington: Ministry of Social Development.

Saville-Smith, K., & Saville, J. (2012). Getting Accessible Housing: Practical

Approaches to Encouraging Industry Take-up and Meeting Need. Centre for

Research, Evaluation and Social Assessment.

Saville-Smith, K., James, B., Fraser, R., Ryan, B., & Travaglia, S. (2007). Housing

and Disability Future Proofing New Zealand's Housing Stock for an Inclusive

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http://www.stats.govt.nz/browse_for_stats/health/disabilities/disability-survey-

2013-additional-tables.aspx

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Retrieved from Statistics New Zealand:

http://m.stats.govt.nz/browse_for_stats/health/disabilities/disability-housing-

2013.aspx

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lds/WellbeingStatistics_HOTP16.aspx