The state government has committed to including accessible housing features in the next edition of the National Construction Code (2022).  The proposed new rules are intended to make homes easier to access, navigate and live in, as well more cost effective to adapt when life’s circumstances change. They will be based on the Silver Level of the Livable Housing Design (LHA) Guidelines.

While we don’t yet know the full shape and form of the regulations nor the exact timing, we do know that there is a lot to get right when including accessible housing features.

Provide complete compliance solution

Detailed solutions that set out how to comply are not currently provided.  The accessibility requirements conflict with other requirements for drainage, weatherproofing, termites and energy efficiency. This means that there needs to be bespoke solutions worked out for each dwelling (costing in the order of $1,800 each time).  This is a particular problem for the dwelling entrance requirements.

Provide clear and precise definitions

For certification, regulation must provide a clear and precise benchmark against which to assess.  Currently too much is left open for interpretation.  It is not clear how the terms ‘community’, ‘older’, ‘easy to enter/navigate’ (for whom and/or what?), ‘safe’ and ‘unobstructed’ are to be interpreted and assessed.

Allow tolerances for on-site variables

It is usual practice to allow some building tolerance for on-site variables.  Accessible housing is unique in allowing no tolerances.  For example, a timber frame surface may be out by up to 4 mm and still be compliant (QBCC Standards and Tolerances Guide) but under accessible housing any hallway even a millimetre less than 1000 mm will mean the whole house cannot be approved for occupancy.

Continue to allow flexibility to exclude costs from the build contract

Accessible housing requires that level thresholds be achieved at the entrance and to key living areas.  They must therefore be certified as having been achieved in order to secure occupancy approval.   This will require homeowners to include floorcoverings and landscaping (entrance paths) in the build contract, removing any flexibility to delay this work if their budget does not extend that far.

3 year transition period from when the provisions are formally adopted

Redesigning standard plans is a major undertaking which one major project home builder estimates the cost in the order of $200,000 to $300,000.  A longer time frame will allow more of this cost to be drawn from the usual process of design updates.  A short timeframe will have all builders working to adjust their standard plans quickly, adding significant pressure on the demand for designers, quantity surveyors and marketing professionals; unnecessarily drive up the cost of the work.

Project home builders will also need time to adjust their built sales product.  A display village home will often be 12 to 18 months in planning and construction and will then be open for a 2 year minimum.  These builders are already planning the display homes that will be used to sell their product for the next 3 to 4 years.

Provide exemptions for:
  1. significant renovations

    It will often be impossible to meet the larger dimensions retrospectively in renovation projects.

  2. conflict with town planning requirements

    A planning application can add $5,000 and significant time delays.

  3. small sites & small dwellings

    Smaller dwellings and sites are particularly important to housing affordability but will require significant compromises in the living space to allow for the larger dimensions.

  4. apartments not on the ground floor that are not accessed by a lift

Cannot be made accessible through the retrospective use of equipment such as a chair lift, therefore there will be no value in prioritising accessible housing design features over design choices.

Comprehensive implementation guide and consumer awareness campaign

The communication strategy must provide a detailed guide for the entire building supply chain: manufacturers, designers, builders and trade contractors.  The requirements are such a significant change in practice, so detailed there are many opportunities for problems that must be headed off.

The requirements must also be well communicated to homeowners by government.  It should not be left to builders to explain to clients that they cannot have their home the way they want to accommodate the requirements.  That liveability as they define it (a larger living area) needs to be compromised for liveability as the government defines it (larger toilet or wider hallways).  That the bathroom floor getting wet after each shower is not a defect.  It also needs to be explained why decisions on the floorcoverings, toilet and bath must be fixed early and cannot be changed. Why an access path must be included in a contract.

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