National Disability Authority submission on social housing strategy – July 2014
Submission on Social Housing Strategy
Executive Summary
The National Disability Authority welcomes the opportunity to contribute to the
development of a new Social Housing Strategy for Ireland. Social housing is
particularly important for many people with disabilities, who are less likely to
have a job than non-disabled people.
It is essential that the new Social Housing Strategy encompasses the existing
National Housing Strategy for People with a Disability. An integrated policy and
strategic approach is required to ensure that there is adequate supply of housing
for people with disabilities in integrated, diverse and sustainable communities.
The Universal Design Guidelines for Homes in Ireland should become the
minimum standard for new social housing build projects in the new Social
Housing Strategy. These guidelines should become the target for leased or
acquired housing units.
Social housing units for people with disabilities should be integrated with other
housing. Clustering of units dedicated to people with disabilities should be
avoided. Group homes should have no more than four people with disabilities
sharing together.
Technical and service staff should be supported to build skills and knowledge to
ensure they can meet the needs of the broad population, including people with
disabilities. Application forms and other written communications should be
updated to be readable and usable by most people.
A coordinated cross-departmental budgeting approach will be required to ensure
that housing and other supports are provided in an integrated manner, and
potential savings on the overall support budget can be achieved.
Long term vision for social housing
People with Disabilities are key users of social housing services
There are over 400,000 people in Ireland today living with a significant disability.
People with disabilities are more likely to rely on local authority housing than
other citizens - 12.8% compared to 8.3% of the public at large - and constitute
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National Disability Authority submission on social housing strategy – July 2014
about one in ten residents in public housing. 1There is strong evidence to show
that on average, people with disabilities have fewer educational qualifications and
poorer employment prospects than others.2 People born with a disability or who
have experienced onset of a disability by early adulthood are likely to be
economically vulnerable and to depend on the state for a permanent home.
People with disabilities are therefore a substantial and significant segment of the
population that depends on social housing. It is essential that the new Social
Housing Strategy recognises the importance of social housing for
people with disabilities.
UN Convention on the Rights of Persons with Disabilities
Article 19 of the UN Convention on the Rights of Persons with Disabilities states
that parties to the convention recognise “the equal right of all persons with
disabilities to live in the community, with choices equal to others, and
shall take effective and appropriate measures to facilitate full enjoyment by
persons with disabilities of this right and their full inclusion and participation in
the community”. Ireland plans to ratify this convention, so it is therefore essential
that the new Social Housing Strategy factors this in.
Integration of National Housing Strategy for People with a
Disability
The National Housing Strategy for People with a Disability was launched in 2011
and sets out a framework for the delivery of housing for people with disabilities
through mainstream housing policy. It is essential that this integrated approach is
continued and enhanced in the new Social Housing Strategy. The new Social
Housing strategy should encompass the needs of people with disabilities as set
out in the 2011 disability housing strategy.
An integrated social housing strategy that encompasses the disability
strategy is required to achieve integrated communities, where people
with disabilities live in ordinary houses in ordinary places, supported to
live regular lives. The needs of people with disabilities must be considered as
part of every acquisition for social housing – including property purchases, leasing
of property and capital approval for new builds.
1
Census 2011, Vol 8
2
Census 2011 showed that 33% of adults aged 20-64 had a job, compared to 66% of nondisabled adults
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National Disability Authority submission on social housing strategy – July 2014
New Social Housing should meet the Universal Design Homes
standard
The Centre for Excellence in Universal Design is currently completing the
development of Universal Design Guidelines for Homes in Ireland. A near-final
version of these guidelines was published for consultation to stakeholders,
including the Department of the Environment, Community and Local
Government in January 2014. The Universal Design Guidelines for Homes in
Ireland reflect the fact that all people experience changes in their abilities are
they progress through the different stages of life. The Universal Design approach
benefits a wide range of user groups regardless of age, size, ability or disability
including families with young children, people with a temporary or permanent
injury, people with a disability and older people living independently.
The National Disability Authority advises that these guidelines should
become the minimum standard for new social housing build projects in
the new Social Housing Strategy. Housing should be designed from the
outset to meet the changing and developing needs of the broad population over
their lifetime. This will reduce the need for expensive retrofitting to
accommodate individuals. 3This approach would have a number of significant
benefits:

New social housing units will be available to and usable by everybody,
regardless of their age, size, ability and disability. This will ensure that more
people can be housed in the community, and can remain in their regular
housing should they acquire a disability (be that temporary or permanent), or
as needs develop through ageing.

Over time, the quality of the national housing stock will improve, and more
housing units will be available and accessible to more people regardless of age,
size, ability or disability. This benefit will impact social housing, and indeed
private housing stock as a proportion of social housing units are bought out
by tenants.

Costs of adaptations, such as the Housing Adaptation Grants scheme, will
reduce over time, as fewer units will require adaptation or retro-fitting to be
usable by all people

More elderly people will be able to ‘age in place’ and will avoid the need for
nursing home or other residential placements.
3
This is in line with the ‘Three Pillars of Sustainability’ model, where the Universal Design
guidelines would form part of the Social pillar.
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National Disability Authority submission on social housing strategy – July 2014
Liveable neighbourhoods
The new Social Housing Strategy should aim to create liveable and
sustainable neighbourhoods, where people with disabilities can live full
and active lives as part of a real community. Social Housing is not just
about providing a roof overhead.
“Our Sustainable Future, a Framework for Sustainable Development for Ireland”
published by the Department of the Environment, Community and Local
Government in 2012 states that “Sustainable communities are places where
people want to live and work, are environmentally sustainable and contribute to a
high quality of life for residents. They are safe and inclusive, well-planned, built
and run, and offer equality of opportunity and good services for all.”
Social housing tenants and society as a whole will benefit from the development
of diverse communities, where people with disabilities are integrated into their
local community.
Roles and responsibilities
Statutory obligation for accessible procurement
There is a legal obligation on the Chief Officer of each public body to ensure that
all goods or services supplied to the body are accessible for people with
disabilities (Section 27, Disability Act 2005), except where this would not be
practicable or would result in unreasonable delay or costs would not be justified.
This legal obligation applies to the acquisition of housing, whether through
the purchase of completed housing units, leasing of housing or direct
capital funding of new build projects
The legal obligation does not apply would it not be practicable, would not be
justified having regard to the cost of doing so, or would cause unreasonable
delay. In such cases, it is good practice to include a written note on file to outline
the reasons for exclusion.
It is important that County Managers as Chief Officers are informed of their
statutory role in ensuring that housing is accessible through the new Social
Housing Strategy. Staff who are directly involved in the commissioning or
acquisition of housing also need to be advised of their role in this area.
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National Disability Authority submission on social housing strategy – July 2014
Housing needs and supports and affordability
People with disabilities have a variety of housing needs, just like the rest of the
population. Some people with physical disabilities have particular requirements
about physical access to the property. Other people with sensory, intellectual,
cognitive or mental health disabilities or autism have few or no requirements for
physical access, but may well have other needs related to their integration in the
community.
Perfect solution not always attainable
Most people, whether in private or social housing, have to compromise on some
aspect of their ideal home. For people with disabilities, there may equally be
trade-offs. For example, there could be a trade off between an excellent location
close to family support, or a home which fully meets all Universal Design
standards. It would be important that housing officers would engage with
prospective tenants with disabilities around such trade offs, rather than rejecting
what would be an acceptable option for the individual out of hand because of a
more minor breach of technical standards. This means a nuanced and commonsense approach which promotes high standards and does not default to lowquality options for people with disabilities, but at the same time can accept
reasonable compromise.
Adaptations in private rented accommodation
People who live in private rented accommodation with support of rent allowance
or the new Housing Assistance Payment may have more flexibility in choosing
where they live, and may choose to avoid segregated estates. This flexibility is
balanced by a lack of long term security. Security can be critical for prospective
tenants with disabilities, especially those with long term disabilities or progressive
conditions.
They often face difficulties in arranging physical adaptations/retro-fitting of homes.
Tenants do not qualify for the current Housing Adaptation Grants, which are
reserved for those who own their property. People on lower incomes may find it
difficult to fund a deposit required to move to a different property. Landlords
may be reluctant to select a person with an obvious disability as a tenant, due to
concerns about costs of adaptations or the impact of adaptations on the property
itself.
Given that the new Housing Assistance Payment will deem recipients to have
their housing needs met, it is important that requirements for adaptations/retrofittings are considered as part of this process.
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National Disability Authority submission on social housing strategy – July 2014
Flexible approach
Provisions for housing transfers need to be flexible and to take on board issues
relating to disability.
For example tenants who have progressive conditions such as multiple sclerosis
or motor neurone disease may have changing needs over time, as their condition
deteriorates. Options available could include adapting their existing home, or
offering a transfer to a more suitable home. A ‘Universal Design’ approach to
new housing will minimise difficulties relating to such transfers over time by
ensuring that new housing stock is accessible for people regardless of age, size,
ability or disability.
Individuals with disabilities who have lived in an institution may have more
difficulty in readily settling in to a new home and community, and there should be
flexibility to consider the offer of a transfer if the first tenancy is not working out
even with appropriate supports.
Demand
Quality demands
The Part M building regulations for access to housing for disabled people have
been largely untouched for nearly 15 years. The most recent revision to Part M
in 2010 focused on non-residential buildings with only a limited upgrade to the
requirements applying to dwellings, as it was considered premature at that stage
to extensively update the guidance on dwellings prior to the development of the
National Housing Strategy for People with a Disability. There is a significant need
to improve the standard of housing stock over time to ensure that people with
disabilities can independently access and use housing. The National Disability
Authority advises that this improvement could best be achieved by setting the
new Universal Design Guidelines for homes in Ireland as the
mandatory minimum standard for new social housing, and ultimately
for all housing. This standard should apply to all ‘new build’ social housing units
as soon as possible. The standard should also be the target for all purchases and
leases of existing properties, recognising that existing property will rarely meet all
aspects of the standard.
Work currently being completed by the Housing Agency to assess the costs of
the Universal Design approach indications that the incremental costs are largely
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National Disability Authority submission on social housing strategy – July 2014
insignificant, apart from the need for a minor increase in the footprint of the
property.
In London, there has been a requirement for all new homes to meet the Lifetime
Homes standard since 2004, and for 10% of homes to be designed to be
accessible for wheelchair users. Variations on these requirements can be found in
various local authorities. In Southwark, 10% of habitable rooms or units of major
new residential development are to be designated to be wheelchair accessible.
User demand
People with disabilities who will need social housing are in a range of different
situations at present. Some people are currently living in the community,
sometimes in a family home or sometimes living independently. For those living in
family homes, there is often a genuine and deep personal need to live
independently, just like other adults of similar ages.
Crisis situations can arise for adults with disabilities living with elderly parents,
when a parent dies or becomes unable to provide support and assistance.
Ultimately in some cases, these adults may inherit a share of a family home when
a parent dies. Consideration should be given to some form of ‘shared ownership’
solution for such adults where they could become joint owners with the local
authority, if they cannot afford full home ownership from such inheritance.
Some people with intellectual disabilities or severe physical or sensory disabilities
are living in residential institutions. The HSE 2011 report ‘Time to move on from
congregated settings’ set out a strategy for moving about 4,000 people from
institutions to community settings – ordinary homes in ordinary places. This
report has been accepted as Government policy, and the strategy is being
implemented under the umbrella of the National Housing Policy for People with a
Disability. As children with a disability reach adulthood, some of these will join
the group of adults in need of social housing supports.
There is will also be additional needs arising out of a greater number of elderly
people remaining in their own homes for longer periods. In general, facilitating
older people to stay in their own homes allows for more cost-effective care and
is generally far more appealing for the people concerned and their families.
Improvements in facilities and technology, including telehealth and telecare
technologies allow for offsite monitoring and support. This may result in
increased demand on social housing, and corresponding reduced demand for
residential care.
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National Disability Authority submission on social housing strategy – July 2014
Delivery mechanisms
Housing supply
Our observations on delivery mechanisms are largely based on experiences to
date with delivery of the National Housing Strategy for People with a Disability.
Progress to date with delivery of housing under this strategy has been
disappointingly slow. The initial approach of leasing properties was not successful,
and budget was switched from leasing to purchasing in the latter end of 2013.
While progress has been made in purchasing a much smaller number of
properties, the process of purchasing and adapting properties has again been
slower than expected. It is important provisions are made for an adequate supply
of social housing that will meet the needs of people with disabilities.
A number of key requirements come out of the HSE ‘Time to move on from
Congregated Settings’ report. This report strongly recommended ‘ordinary
homes in ordinary places’ for people with disabilities. People with disabilities
should be integrated in their communities, and should be living amongst and with
non-disabled people. NDA research shows the quality of life is significantly better
where people with disabilities live in ordinary housing which is dispersed through
the community, rather than in dedicated housing clusters for people with
disabilities. 4 ‘Clustering’ of units, where a number of adjacent houses or
apartments are dedicated for people with disabilities should be
avoided, as these tend to become mini-institutions.5
It is also important that any group housing units for people with disabilities
are designed for no more than four people with disabilities sharing
together. In larger properties with more than four people sharing, it is difficult
to achieve a homely atmosphere, and mini-institutions will tend to emerge.
Research confirms that quality of life is poorer in larger domestic settings. 6
Institutional features such as emergency exit signage and obtrusive safety
equipment make it difficult to achieve that homely atmosphere.
4
Mansell J and Beadle-Brown J (2008) Dispersed or clustered housing for disabled adults: a
systematic review. Canterbury: Tizard Centre.
5
In Sweden, for example, the practice would be to house people with disabilities throughout an
apartment complex rather than in adjacent apartments or on a single floor or block.
6
Tichá, Lakin, Larson et al (2012). Correlates of everyday living choice and supported choice for
8,892 randomly sampled adults with intellectual and developmental disabilities, in 19 States,
Journal of intellectual and Developmental Disability, vol 50 no. 6 p 486-504. This extensive study
shows significantly poorer outcomes where there are over three people with intellectual
disabilities sharing a home together.
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National Disability Authority submission on social housing strategy – July 2014
Funding models
Responsive to housing market conditions
It is important that funding models for social housing are responsive to housing
market conditions. It would be most unsatisfactory for progress on social housing
in general, and progress on moving people from institutions to community
settings is delayed or deferred as a result of housing market conditions.
While it is not possible to predict the direction or extent of change, it is almost
certain that the housing market will be changing over the lifetime of any long
term strategy. Contingency plans should be put in place as part of the strategy to
deal with rising or falling housing markets and regional variations in housing
markets.
Reduce retrofitting costs through Universal Design
There is currently considerable expenditure involved in adapting properties to
accommodate people with disabilities. The Housing Adaptation Grant supports
adaptations in private housing. In social housing, many adaptations are carried out
as people move from one property to another.
A Universal Design approach provides an opportunity to reduce retrofitting costs
over time, by designing properties from the outset to meet the needs of as wide
an audience as possible regardless of age, size, ability or disability.
Capacity issues
The new Social Housing Strategy should ensure that the staff involved in
delivering the strategy have the skills required to meet the needs of everybody
that needs social housing.
Technical skills – housing design
It would be important that professional staff who are involved in the design or
acquisition of social housing would be skilled up in the area of Universal Design,
and its application in the built environment. This goes beyond consideration just
of ramps and downstairs WCs, to consider needs across the spectrum of
disability, age, and ability. Technical guidance on Universal Design in the built
environment is set out in ‘Building For Everyone – a Universal Design approach’
www.universaldesign.ie/buildingforeveryone.
There is a need to educate and support staff to develop their skills and
experience in universal design. This would include architects, engineers, planners,
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National Disability Authority submission on social housing strategy – July 2014
surveyors and landscape architects in local authorities, Department of the
Environment, Community and Local Government and approved housing bodies
who are involved in preparing design briefs, approving housing acquisitions and
building control functions. Industry bodies such as the Construction Industry
Federation of Ireland should also be included under this umbrella of Universal
Design up-skilling. The National Disability Authority is currently engaged with the
Royal Institute of Architects in Ireland on the development of Continuous
Professional Development training courses on Universal Design.
In addition to Building for Everyone, the National Disability Authority has a
number of other resources nearing completion, that are expected to be available
before the end of 2014. These include:

Universal Design Guidelines for Homes in Ireland

Universal Design Homes for Ireland Cost Assessment

Universal Design Homes for people living with Dementia, their families and
carers
Service delivery
Communication with service users will be an essential feature of how the social
housing service is delivered. The recently published ‘Easy To Read’ version of the
National Housing Strategy for People with a Disability is a very positive example
of an effective communication tool for this target audience. Many people with
intellectual disabilities, poor literacy or poor language skills will struggle to deal
with the current social housing application form, or the legalistic, formal texts
often used in response letters to tenants.
The strategy should set out a vision of effective communication with service
users, through Plain English. The social housing form should be redesigned and
improved through a user-centred process so that it becomes simple and intuitive
to use. The investment in this redesign will be repaid to reduced time for staff in
dealing with queries and corrections to forms. Standard letters sent out to
tenants should be redrafted in Plain English, to ensure that they are understood
effectively. There may well be opportunities for using technologies such as email,
SMS messaging or social media to communicate effectively with tenants.
Customer service skills
The National Disability Authority also has a number of resources available that
will help housing staff to provide high quality services to people with disabilities.
These resources include:

NDA eLearning module on disability – a short, online training course to help
public sector staff to deal with customers with disabilities
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National Disability Authority submission on social housing strategy – July 2014

NDA Social Housing and Mental Health guidelines – guidance on best ways to
support people with Mental Health difficulties seeking social housing

Materials on universal design in customer service materials, developed for the
energy sector, but much of which is applicable in other service contexts – see
http://www.universaldesign.ie/guidelinesampstandards/universaldesignforcusto
merenagagementinenergyservices
The National Disability Authority plans over the coming months to develop
guidelines on dealing with housing needs of people with Autism.
Organisational structures
Cross-departmental operations and budgeting
Housing for people with disabilities is much more than just a roof overhead.
Provision of adequate housing services also requires provision of matching
support services to ensure that the housing tenancy is sustainable in the long
term.
Much work has been done on cross-departmental protocols between local
authorities and the HSE to ensure that housing and appropriate supports go hand
in hand. These protocols will need to be extended and enhanced over time to
ensure that people with disabilities get the services they need.
Also, provisions for some form of cross-departmental budgeting will be required.
There is often a trade-off between the existing health and housing budgets.
Changes on one side impact the budget on the other side, and vice versa. There
may well be opportunities for overall reductions in public spending through
increased housing spend to reduce health spending.
Other relevant policies
Other key policies that must be considered in the development of the new Social
Housing Strategy include:

HSE ‘Time to Move on from Congregated Settings’ report from 2011, which
sets out a roadmap for about 4,000 people with intellectual disabilities to
move from institutions to community housing

National Positive Ageing Strategy, which aims to ensure that “that people are
enabled to age with confidence, security and dignity in their own homes and
communities for as long as possible” and ‘older people [are facilitated] to live
in well-maintained, affordable, safe and secure homes which are suitable to
their physical and social needs”
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National Disability Authority submission on social housing strategy – July 2014

The Programme for Government 2011 commitment to “In planning
legislation, we will promote and support universal design whereby all
environments can be used to the greatest extent possible by all people,
regardless of age ability or disability”.

The M/420 EU Standardisation mandate by European standards bodies, CEN,
CENELEC and ETSI on new European accessibility requirements for public
procurement in the built environment. This standard for public procurement
is envisaged to be completed and operational by 2015.

The new European Directives on public procurement (Directive 2014/24/EU
and Directive 2014/25/EU) which states that in all procurement intended for
use for persons, except in duly justified cases, contracting authorities should
set down technical specifications to take into account accessibility criteria for
people with disabilities or design for all users

Government Policy on Architecture 2009–2015

Our Sustainable Future, a Framework for Sustainable Development for
Ireland, Department of the Environment, Community and Local Government,
2012
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