Jacquel Runnalls is a housing occupational therapist and inclusive environments specialist. She is a member of the Access Association, the British Standards Committee B/559 and the Royal College of Occupational Therapists Specialist Section in Housing Co-opted Lead on Accessibility and Inclusive Design (with an MSc of the same title).
Jacquel previously sat on the Government’s Technical Housing Standards Review Access group which led to the revised Part M Volume 1and co-authored Habinteg’s 2018 Wheelchair Housing Design Guide.
The campaign to make the M4(2) standard the baseline for all new homes goes back to the 1980s when the Access Committee of England looked to update the 1974 Mobility Housing Standards, and organisations including Helen Hamlyn, Habinteg and the Joseph Rowntree Foundation developed what became known as the Lifetime Homes Standards (LTHS).
The final 2010 edition of LTHS brought together key stakeholders, aiming to accommodate housebuilder requirements, with Habinteg taking on the administration and technical support. It was also hoped that ‘Lifetime Homes Lifetime Neighbourhoods’ and the Code for Sustainable Homes would lead to LTHS being the baseline, particularly in light of increasing research and evidence base supporting its wide-ranging benefits, but it was not to be.
In 2010, a new administration announced an industry-led examination to simplify and streamline standards, ultimately leading to the Technical Housing Standards Review. LTHS was broadly assimilated into the new 2015/2016 Building Regulations Part M, Volume 1 but only as an optional Category M4(2).
Confusion & misinterpretation
The government’s recent proposal to update the guidance is welcome due to continued confusion and misinterpretation of the Approved Documents, including M4(2) and M4(3) titles.
Despite the existence of BS 9266: Accessible and Adaptable General Needs housing since 2013, and separate wheelchair housing guidance for decades, some Local Planning Authorities (LPAs) still think that by only requiring a percentage of M4(2) dwellings, they are meeting the needs of wheelchair users, when they are not.
Updates to the guidance should also consider the daily barriers disabled and older people face due to poor design, and propose ways in which they can be mitigated through accessible, genuinely adaptable, flexible and inclusive design from the outset. From experience, this should address missing detail, provide explanations and evidence of what works and why, including a ‘lessons learnt’ approach that considers post-occupancy evaluation. All of which also applies to M4(3).
What about wheelchair housing?
About 98% of the government’s raising accessibility standards consultation respondents supported accessible housing, yet government has set no requirements for wheelchair housing, or mandating space standards. This is, again, despite long-running campaigns and an increasing research and evidence base.
London, the highest density city in the UK, has required 90% M4(2), 10% M4(3) and NDSS (or similar) since 2004, having undergone independent viability testing. Habinteg’s 2020 Forecast for Accessible Homes shows that despite at least 1.2 million UK wheelchair users, a rapidly ageing population, and 400,000 wheelchair users living in homes that are inaccessible, just 1.5% of new homes outside of London are set to be suitable for wheelchair users.
We need to level the playing field – people who need wheelchair housing do not have a choice and, despite continued misunderstanding and misrepresentations, M4(2) is not appropriate – in fact, M4(3) will not meet the needs of all wheelchair users, their families, and personal assistants, etc. There are also no M4(3) equivalent space standards. I, therefore, welcomed the government’s National Disability Strategy commitment to provide desperately needed research on wide-ranging population requirements to inform future revisions of Part M.
Levelling up and aligning planning policy
The government’s response to its raising accessibility standards consultation states that LPAs should continue ‘as now’, have planning policies which evidence and identify a need for M4(3) dwellings, and tailor the supply to local demand. When determining need, current National Planning Policy Framework (NPPF) guidance does not capture or accurately reflect need, and some wheelchair users will simply not be on their radar.
The Habinteg and EHRC toolkits try to assist local authorities, but it is important they include a mix of property type, size and tenure and much-needed larger family homes. For real progress and to provide genuine ‘levelling-up’, the government should align with the London Plan policy of 10% wheelchair accessible homes.
Developers and housebuilders should also understand the potential marketability of wheelchair housing, instead of saying they cannot sell them when they do not actively or appropriately advertise them alongside other housing. Critically, they need to understand that wheelchair housing need not look ‘institutional’, but must be designed inclusively and attractively, appealing to all future occupants.
The government’s response also states that providing certainty in requiring the M4(2) standard for all housing in England will assist in freeing up resources and expertise to focus on the need and proportion for M4(3) dwellings. Many LPAs will still be under-resourced and, critically, lack expertise on the design and build of accessible, adaptable, functional and inclusive housing and neighbourhoods. This is where the unique role of specialists, such as Housing Occupational Therapists (OTs) who see the barriers faced by disabled and older people due to poor design, can assist in ensuring compliance, evidencing need, and ultimately adding value.