Consultation outcome

Raising accessibility standards for new homes: summary of consultation responses and government response

Updated 29 July 2022

Introduction

1. In September 2020, government launched a consultation on raising accessibility standards of new homes, recognising the importance of suitable homes for older and disabled people.

2. The provision of appropriate housing for older and disabled people makes an important contribution to a safe and independent life. An ageing population will see the numbers of disabled people continuing to increase and it is important we plan early to meet their needs through policy change.

3. The consultation sought views on options to raise the accessibility of new homes which included mandating a higher accessibility standard.

4. The consultation is part of a full review of Part M of the Building Regulations, relating to access to, and use of, buildings. Other elements of the review include a research programme on the prevalence and demographics of impairment in England and ergonomic requirements and experiences of disabled people. It also reviews use of accessible and adaptable housing standards at the local level. This work will also help identify the technical changes needed to update statutory guidance (Approved Document M).

5. Evidence gathered has helped government consider what changes can be made to deliver accessible new homes.

Building Regulations and accessible homes

6. The Building Regulations control certain building work – principally to secure the health, safety, welfare and convenience of people in and around buildings. Part M of the Building Regulations sets minimum access standards for all new homes. In 2015 government made some important changes to Part M, with the introduction of a new way of setting technical housing standards in England. This included a new, simpler set of access standards as set out below.

7. The requirements in the regulations are supported by statutory guidance in Approved Document M. Building Regulations apply to new buildings, major refurbishments, and changes of use. Volume 1 applies to dwellings:

• Requirement M4(1) sets basic standards for all new buildings. Known as “Category 1: Visitable dwellings”.
• Requirement M4(2), introduced in 2015, sets a higher standard for accessible homes, which is broadly equivalent to the Lifetime Homes Standard. Known as “Category 2: Accessible and adaptable dwellings”.
• Requirement M4(3) sets a standard for wheelchair accessible homes. Known as “Category 3: Wheelchair user dwellings”.

8. Categories M4(2) and M4(3) are optional requirements which local authorities can apply through local planning policies where they have identified a local need and where the viability of development is not compromised.

9. The existing minimum standard for accessible housing in England has four main requirements that make homes accessible and visitable for most people, including wheelchair users: level access to the main entrance; a flush threshold; sufficiently wide doorways and circulation space; and a toilet at entrance level.

10. This applies as the minimum for all new build homes; but not to extensions or changes of use. However, where there is a material alteration to a building’s access, the building cannot be made less compliant than it was before the alteration.

11. The higher M4(2) standard requires additional features including having a living area at entrance level and step-free access to all entrance level rooms and facilities, wider doorways and corridors as well as clear access routes to reach windows.

12. It also includes further features to make homes more easily adaptable over time for a wide range of occupants, including older people, those with reduced mobility and some wheelchair users, for example sanitary provisions that can be adapted easily for installation of grab rails and stairs designed to allow easy fit of a stair lift.

13. The M4(3) requirement is achieved when a new dwelling provides reasonable provisions for a wheelchair user to live in the dwelling and have the ability to use any private outdoor space, parking and communal facilities.

The consultation

Raising accessibility standards of new homes

14. The consultation, published on 8 September 2020 sought views on how to raise accessibility of new homes. There should be enough suitable housing where it is needed, giving people the dignity and security they deserve in their homes.

15. Based on existing evidence, we developed five broad options. These considered whether to wait to see the full impact the of the optional technical standards introduced in 2015 and the 2019 additional housing and planning guidance on the use of these standards; or considering whether and how changes could be made by either mandating a higher standard or reconsidering the way existing optional standards are used. Any changes to standards would only apply to new homes, not to the refurbishment of existing homes.

16. The consultation asked for views on these 5 options:

Option 1: Consider how recently revised planning policy on the use of optional technical standards impacts on delivery of accessible housing

Option 2: To mandate the current M4(2) requirement in Building Regulations as a minimum standard for all new homes, with M4(1) applying by exception only, where M4(2) is impractical and unachievable (e.g. a new build flat above a garage). M4(3) would apply where there is a local planning policy in place in which a need has been identified and evidenced

Option 3: Remove M4(1) altogether, so that all new homes will have to at least have the accessible and adaptable features of an M4(2) home. M4(3) would apply where there is a local planning policy in place in which a need has been identified and evidenced. This would mean that no new homes could be built as M4(1)

Option 4: To mandate the current M4(2) requirement in Building Regulations as a minimum standard for all new homes with M4(1) applying by exception only, a set percentage of M4(3) homes would also need to be applied in all areas. So rather than local authorities setting a local planning policy for the provision of M4(3), a defined and constant percentage would apply to all new housing

Option 5: Change the content of the mandatory technical standard. This could be done by upgrading the statutory guidance to create a revised M4(1) minimum standard. This revised standard could be pitched between the existing requirements of M4(1) and M4(2), adding more accessible features into the minimum standard

17. We are grateful for the quality and breadth of the responses received, particularly from individuals and carers whose lives are enhanced by living in truly accessible homes. We have carefully considered all responses and set out a summary of responses and a government response below.

Summary of responses

Overview

18. We received 413 responses to the consultation. Responses were received via an online response form, email and hard copy. Not all respondents addressed every part or answered every question. Questions 1 and 2 asked for respondent’s details.

19. This document provides a summary of the consultation responses received. It does not attempt to capture every point made. It sets out the proposed changes the government is making, having taken the consultation responses into account.

20. There was an even split between individual and organisational responses. The table below provides a breakdown of responses to the consultation by type of respondent. Respondents in the ‘Others’ category included disabled people and carers.

Respondent type	Number of respondents
Builder/Developer	16
Designer/Engineer/Surveyor	14
Local Authority	78
Building Control Approved Inspector	0
Architect	19
Access Consultant	19
Occupational Therapist	24
Construction Professional	7
Property Manager/Landlord	7
Landlord Representative Organisation	2
Charity	38
Campaigner/Lobby Group	22
Other	167
TOTAL	413

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

21. Of those that responded to this question (412 respondents), an overwhelming number (98%) supported government’s intention to raise accessibility standards of new homes.

22. Comments from respondents highlighted the wider impact raising accessibility standards of new homes would have. This included the reduction in reliance on the NHS and social services, paid and family carers and helping to support disabled people to work, socialise and contribute to society as fully as possible.

23. Respondents also commented that raising accessibility standards would ‘future proof’ new homes for successive generations, saving costs associated with adapting homes.

24. There were some comments that raised the concern about the viability of building new homes to higher standards, which respondents suggested should be driven by evidence of local evidence and demand.

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

25. There were 664 responses to this question as some respondents chose more than one option. Options 2 and 4 were the most favoured options, with 208 (31%) and 245 (37%) votes respectively. 81 responses supported both option 2 and 4. The least favoured option was option 1 with only 40 (6%) responses supporting no change and waiting to see the full impact of recent planning policy changes on the use of the optional technical standards.

Option 1- Consider how recently revised planning policy on the use of optional technical standards impacts on delivery of accessible housing

26. Most respondents (94%) thought option 1 would be ineffective at realising the objective of improving provision of accessible housing. Only a few respondents favoured allowing existing standards to bed in fully before changing again. Some favoured option 1 because this was cost and demand led and allowed for viable development and delivery of affordable housing units. Support for option 1 was mostly from those considering costs to develop and from those working with viability assessments.

27. Option 1 was strongly opposed given the context of England’s changing demographics and was expected to have a negative impact on the lives of disabled people. With an ageing population and limited housing options for disabled people, option 1 was mostly viewed as delivering little impact or change in the choices for people needing accessible homes.

Option 2 - To mandate the current M4(2) requirement in Building Regulations as a minimum standard for all new homes, with M4(1) applying by exception only, where M4(2) is impractical and unachievable (e.g. a new build flat above a garage). M4(3) would apply where there is a local planning policy in place in which a need has been identified and evidenced

28. Respondents viewed option 2 as improving accessibility of and future-proofing homes. Option 2 was also favoured because it retained the lower M4(1) standard for exceptional circumstances. Making M4(2) the new minimum standard was welcomed as it was likely to boost numbers of accessible homes being delivered in every local authority. Respondents commented that retaining M4(1) would be critical to viability of development in some areas.

29. Other comments on option 2 were that it would be important to define what legitimate circumstances for using M4(1) should be. Consensus on practical exceptions to using M4(2) included topography, areas with a flood risk, in-fill sites, small blocks where lifts were not viable, but views varied on housing above garages. Other suggestions included having a threshold for the number of units or a percentage on a scheme that could be granted at M4(1).

30. Some respondents felt option 2 could relieve local authorities of the burden of making policy to use M4(2) and helping to divert available resource and expertise to create better locally evidenced policy for M4(3) wheelchair user dwellings.

31. Option 2 was also supported because respondents said it would create a level playing field for developers, a common starting point and reducing the impact of a “postcode lottery” of variation between areas.

32. Respondents commented that as option 2 did not have a specific target for M4(3) it would not make up for the lack of M4(3) homes. Others said that evidencing the need for M4(3) is problematic and there can be confusion between different local authority approaches. Respondents said local authorities did not aggregate data and are highly stretched on resources when putting evidence together.

33. Some respondents warned of unintended consequences of option 2 for both the Private Rented Sector (PRS) and the Social Rented Sector (SRS), such as a problem of under occupation in the SRS or M4(3) properties not being allocated or unaffordable to the people who need them.

Option 3 - Remove M4(1) altogether, so that all new homes will have to at least have the accessible and adaptable features of an M4(2) home. M4(3) would apply where there is a local planning policy in place in which a need has been identified and evidenced. This would mean that no new homes could be built as M4(1)

34. Respondents suggested Option 3’s change to regulatory requirements would ensure a higher accessibility standard cannot be manipulated by bias, negotiation or politics. In contrast some said it would be too restrictive to remove M4(1) and would not recognise the case for exceptions making this option too inflexible.

35. Respondents commented that by not allowing for exceptions there may be unintended consequences for areas with challenging topography or for small in-fill sites. Therefore, option 3 could have a negative impact on housing delivery, for example with high service charges to maintain lifts in smaller housing blocks.

Option 4 - To mandate the current M4(2) requirement in Building Regulations as a minimum standard for all new homes with M4(1) applying by exception only, a set percentage of M4(3) homes would also need to be applied in all areas. So rather than local authorities setting a local planning policy for the provision of M4(3), a defined and constant percentage would apply to all new housing

36. Option 4 was broadly popular, but with caveats and suggestions to improve it. Some respondents said setting percentages would guarantee enough accessible homes addressing a shortfall in a consistent approach across England.

37. Many respondents said this option should have allowed for better flexibility for areas with a higher proportion of need, which might require more wheelchair user homes than a set percentage would allow. Some said option 4 would make new housing unviable in their areas. Including flexibility in a new policy to exceed set percentages was proposed.

38. Others commented that a set level of M4(3) provision would make it clearer for all those negotiating with developers, clearer in terms of numbers to plan for, easier to apply and enforce and would give greater certainty for home users and that new homes will include fit for purpose space and facilities. Some respondents said, “front loading information with set proportions for accessible housing would avoid subsequent resource consuming negotiations and revisions”.

39. Those that did not support option 4 said it did not address the difference of delivering wheelchair user homes as either accessible or adaptable, i.e. M4(3)a (adaptable) or M4(3)b (accessible). Some suggested this option should be replaced with only M4(3)b because many people cannot afford to adapt their new home.

40. Some respondents commented that having a mandatory percentage could reduce the number of homes coming forward and therefore conflict with the objective to boost supply of accessible housing. Others cited examples of London, where set proportions of M4(2) and M4(3) are reported to have worked well, e.g. 90% M4(2)/10% M4(3) with no adverse impact on housing delivery. Some respondents explained that a set percentage would be too high or even too low for some areas, some suggested that these should be set regionally to reflect viability for housing around England. Having a set percentage of M4(3), some explained, would steady the pipeline of M4(3) homes ready for the long-term need, to meet population projections and make up for a shortfall in accessible housing options.

Option 5 - Change the content of the mandatory technical standard. This could be done by upgrading the statutory guidance to create a revised M4(1) minimum standard. This revised standard could be pitched between the existing requirements of M4(1) and M4(2), adding more accessible features into the minimum standard

41. Option 5 was viewed as not being ambitious enough and likely to cause confusion between new and older standards, more than support in delivering homes with higher accessibility standards. An upgraded M4(1) with most of the M4(2) features, would still be lower than M4(2). Many criticised M4(2) as not including all the Lifetime Homes’ principles.

42. Respondents commented that option 5 would depend on what an upgraded M4(1) standard included. Some said this option 5 would “muddy the water rather than provide clarity” for users. Respondents favouring option 5 thought it might be a stepping-stone to a later and better option 2 or option 4 solution. Some saw a standard above M4(1) and closer to M4(2) would lead to a lower quality baseline and would not be an improvement.

43. Option 5 was largely viewed as a distraction from using the already established detail included in M4(2). It was suggested that a separate review of M4(1) would delay the much-needed uplift in number of homes with better accessibility and adaptability. Developing a newer standard lower than M4(2) was seen by many as a missed opportunity to deploy existing and established standards more effectively.

44. Some respondents thought none of the options as presented were right, or some thought a mix of options would have been more appropriate. Some suggested improving the M4(2) standard by incorporating the Nationally Described Space Standard (NDSS) into a common minimum baseline. A few respondents recognised the current system as fit for purpose, but in contrast many said the robust framework for delivering accessible homes is not delivering the numbers, range and a country wide equal spread of homes and opportunities needed.

Question 5: If you answered ‘None’ to question 4, do you think the Government should take a different approach to the options set out?

45. 68% of respondents did not think government should take a different approach to the options set out in the consultation document. 32% of respondents thought a different approach would be preferable. Many respondents (74%) commented on this question, regardless of whether they gave a ‘yes’ or ‘no’ response.

46. Comments ranged from respondents setting out different approaches to those identifying issues with the existing optional standards and the wider building control and planning system.

47. Some respondents suggested introducing a system that delivers the current standards and other building/space standards, through a fully integrated Planning and Building Control regime. Others suggested linking the Nationally Described Space Standard and M4(2) within the building regulations.

48. Another alternative approach included a redefinition of the building regulations with divisions within M4(2) and M4(3) with adaptable and accessible being split into two separate standards.

49. In terms of wider improvements to Part M of the building regulations, respondents wanted a more inclusive approach, ensuring a social model of disability including hidden disabilities was implicit within regulations. It was suggested guidance be included on accessibility standards for those with mental illness, learning disabilities, dementia, and autism, e.g. on wayfinding and orientation, acoustics, colour, and contrast.

50. Further suggested improvements to the detail of Part M guidance included, for example, more space in bedrooms and kitchens to include mobility aids, for lifting equipment and adaptations and maximised amenity space post Covid-19.

51. Other suggestions included a housing register to help individuals and organisations find and manage stocks of M4(2) and M4(3) homes before and after their completion or after later adaptations and a register of people or families waiting for all tenures and sizes of accessible homes.

52. Respondents also suggested keeping a track of the delivery and availability of accessible homes in every area and considering the establishment of an accessibility performance certificate. Also proposed was a national label or kite mark for M4(2) and M4(3) connecting to property deeds and home information packs to share on the handover, sale or reletting of properties.

Question 6: Do you agree with the estimated additional cost per dwelling of meeting M4(2), compared to current industry standards, in paragraph 45 (of the consultation document)?

53. 20% of respondents agreed with the estimated additional cost of £1400 per dwelling of meeting M4(2). A larger proportion of respondents disagreed with this estimate (32%). However, 44% of respondents answered ‘don’t know’.

54. Of those that agreed with the additional cost of £1400, it was suggested that if higher accessibility standards are mandatory and processes standardised, the impact of additional building and space costs can be relatively low. All developers would be factoring in the same extra costs and buying land with the same assumptions and there would be a level playing field within the industry.

55. Some respondents, in particular builders/developers thought £1400 was too low based upon current construction costs and that the figure does not consider the overall increase to the dwelling size and thereby the reduction in density across a site. Some also felt the cost does not reflect the external costs associated with the regulations, such as access routes and additional parking width.

56. Other respondents said a more detailed cost assessment is needed, by unit type, scheme size and complexity, and to consider regional market land variation or other site externalities.

57. It was also suggested that to achieve more accessible dwellings, improved space standards are likely to be necessary, and if so significant additional costs to builders/developers is likely to be incurred.

Question 7: Do you agree with the proportion of new dwellings already meeting or exceeding M4(2) over the next ten years in paragraph 45 (of the consultation document?

58. Only 11% of respondents agreed with the estimate that the percentage of dwellings that would meet or exceed M4(2) would grow over time even without Government intervention from the current 10% to 30% in 10 years’ time. 43% of respondents did not agree with this estimate and a further 41% answered ‘don’t know’.

59. Respondents that disagreed with the estimate, commented that the proportion of accessible and adaptable dwellings would only increase (to the suggested 30%) if councils were successful in setting more onerous policies through their Local Plans. It was suggested that this could be dealt with more efficiently on a national scale through changes to Building Regulations.

60. There were also comments about the proportion being much higher in London than in the rest of England, given the requirements for higher standards in the London Plan. It was felt that this would skew the national figure.

61. Other comments were about the 30% figure still meaning most new homes built would be unsuitable for the needs of the population. And would lead to increased costs in adaptations needed in the future, more cost in terms of NHS and care spending and more carbon costs as homes aren’t future-proofed.

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

62. There was an even split of ‘Yes’ and ‘No’ responses to this question. Respondents commented that should M4(2) become the minimum standard, this would significantly impact on the provision of affordable first‐time buyer homes and should be carefully considered when the impact on reducing the need for social care has not been conclusive.

63. Respondents suggested alignment of any future requirements for changes to part M to those of the future homes programme so that all regulatory changes can be considered in relation to the potential cumulative impact on housing delivery and viability.

64. Respondents also mentioned that set percentages for wheelchair housing standards would have potential implications for viability in some areas and would not be responsive to evidence of localised need for such housing.

65. Other comments asked for a wider range of factors to be considered, such as adoption of Nationally Described Space Standards and spending on adaptations when assessing the overall potential costs and benefits.

Question 9: Do you have any comments on the initial equality impact assessment? If yes, please provide your comments including any evidence to further determine the positive and any negative impacts.

66. 48% of respondents answered, ‘Yes’ to this question, with 52% answering ‘No’.

67. Comments suggested without a sensible and holistic review of types of properties, including, for example, flats above shops/garage, the unintended consequences a change in policy could generate economic and social inequality, especially for young first-time buyers.

68. Other comments suggested there should be an analysis of the comparative impacts of each option including the intersections of disability impacts with sex and ethnicity.

69. Respondents also commented that it is unclear how option 1 would have a positive impact on age and disability. It was suggested that this option could potentially have a negative impact, as a rapidly ageing population will have access to less accessible and adaptable housing, suitable for their needs.

70. Most respondents said that Options 2 and 4 which would raise the minimum mandatory accessibility standard to M4(2) will have the biggest impact of increasing the number of homes for older and disabled people.

Government response

Raising the minimum standard for accessible homes to M4(2)

71. Government is committed to raising accessibility standards for new homes.

72. We have listened carefully to the feedback on the options, within the consultation and outside of this, including in Parliament, through a local authority survey of their use of the optional standards, and through discussions with stakeholders, and in the media.

73. Government proposes that the most appropriate way forward is to mandate the current M4(2) (Category 2: Accessible and adaptable dwellings) requirement in Building Regulations as a minimum standard for all new homes – option 2 in the consultation. M4(1) will apply by exception only, where M4(2) is impractical and unachievable (as detailed below). Subject to a further consultation on the draft technical details, we will implement this change in due course with a change to building regulations.

74. M4(3) (Category 3: Wheelchair user dwellings) would continue as now where there is a local planning policy in place in which a need has been identified and evidenced. Local authorities will need to continue to tailor the supply of wheelchair user dwellings to local demand.

75. While no change is proposed to how M4(3) is applied and established through a local planning policy, one simple alteration to the hierarchy of optional technical standards within building regulations should have maximum impact. We expect the saved resource and expertise on making M4(2) policies will help local planning authorities focus on evidencing the need and proportion for wheelchair-user dwellings.

76. Option 3 was rejected as it would be too restrictive to remove M4(1) and it would not recognise the case for exceptions. Option 4 was rejected as having a mandatory percentage for wheelchair homes could reduce the number of homes coming forward and therefore conflict with the objective to boost supply of accessible housing. Option 5 was rejected as it could cause confusion between an established standard and new standard.

Exceptions

77. The existing minimum standard - M4(1) (Category 1: Visitable dwellings) - will apply by exception only, where M4(2) is impractical and unachievable. The Building Regulations/statutory guidance will describe the circumstances in which M4(1) is acceptable. Site specific factors such as vulnerability to flooding, site topography, and other circumstances (e.g. a new build flat above a garage) may make a specific site less suitable for M4(2) compliant dwellings, particularly where step free access cannot be achieved or is not viable.

78. Developers will need to justify the use of the M4(1) standard against specific individual homes and justify why M4(2) is not appropriate on their project.

79. Building control bodies will check for compliance on building works, informed by the accessibility standard applied to each new build property.

Costs and benefits

80. We have carefully considered respondents’ views on the costs and benefits of the options and have used the evidence available to identify costs and benefits of the option that we are taking forward.

81. Indicative and early results of impact assessment work suggest that the net cost (costs minus benefits) to business for mandating M4(2) is £265m per year (2019 prices). The costs included in this figure are those of transitioning to the higher standard and the capital costs of constructing M4(2) dwellings, relative to constructing M4(1) dwellings. The benefits included in this figure are those that developers recover from increased sales prices, given M4(2) homes are typically larger and have other features consumers pay a higher price for. If these benefits are excluded, net costs increase to £661m per year.

82. Total benefits (to business and society) are estimated to exceed total costs under the central and high estimates, however under the low estimate (which excludes sales price benefits) they do not. The Net Present Social Value (the present value of all future cash flows, over 70 years) ranges from -£4,661m up to £1,930m (2022 prices). Figures calculating societal costs include the running costs of M4(2) homes that accrue to residents. Societal benefits include the health and non-health benefits of the policy. All figures are subject to change as impact assessment work progresses.

Implementation and next steps

83. Mandating M4(2) will require a change to Building Regulations and statutory guidance in Approved Document M (volume 1). Government will consult further on the technical changes to the Building Regulations to mandate the higher M4(2) accessibility standard, changes to ADM (volume 1) and on our approach to how exceptions will apply.

84. We consider that transitional provisions are necessary to allow the industry to adapt.

85. The new minimum standard will apply to any newly erected dwellings (excluding extensions) unless the building works have started on site or an initial notice, building notice or full plans have been deposited and work has started on site within a period of eight weeks.

Alternative approaches

86. We appreciate the range of alternative approaches suggested by respondents. We understand the reasoning behind respondents asking government to link accessible housing standards with wider policies such as the Future Homes Standard and the Nationally Described Space Standard to ensure better integration and delivery of policies. While some of these approaches have merit, we are keen to make a difference in the shorter term using the existing system to make a real change to the supply of accessible homes.

Equality impacts

87. We have considered all the comments received on the initial equality analysis and have completed a full equality impact analysis to fulfil the requirements of the Public Sector Equality Duty (PSED) as set out in section 149 of the Equality Act 2010.

88. Raising the accessibility standards of new homes will have a positive impact on household health and welfare, and are particularly relevant to the following protected groups:

• Age
• Disability

89. We believe there is no indirect discrimination in raising the minimum standard for all new homes to M4(2). While features of accessible and adaptable homes support people with physical disabilities and for people living with a reduction in their mobility, the accessible and adaptable features also support wider and other disabilities. For example, the presence of toilets on the ground floor will support people with invisible disabilities and other mental health or sensory issues. Wider inclusion is currently being considered in our Part M research which will lead to updates to statutory guidance going forward.

90. Accessible homes are of particular importance to older and disabled people, but there are likely to be important benefits for all people with protected characteristics and the wider population with the approach we are taking forward. In particular:

• Mandating a higher accessibility standard will over time improve the quality of design, whilst reducing the cost of accessible housing through economies of scale.
• Accessible housing will be delivered more cost effectively helping to make it easier to improve supply and availability of this kind of housing.
• If older and disabled people can live in suitable homes for longer, there will be a reduction in reliance on the NHS and social services.
• If older and disabled people can live more independently in their own homes, they have greater choice and control over their lives, and will be able to work, socialise and contribute to society as fully as possible.
• Raising the accessibility standard will ‘future proof’ new homes for successive generations, saving costs associated with moving or adapting homes.

91. Higher accessibility standards can increase build costs, potentially leading to a trade-off in the delivery of new homes and affordable homes. This could have a negative impact on groups who share protected characteristics who are most likely to benefit from these homes, including older and disabled households. On balance however, our overall assessment of equality impacts is deemed to be positive. The negative impact would be temporary as over time more homes will be built to the same standard through economies of scale and a more level playing field in the industry.

92. Setting a higher minimum accessibility standard is direct recognition of the need to ensure that housing provision is not a barrier in advancing equality of opportunity between people who share a protected characteristic and those who do not.

93. Delivering high-quality accessible homes, helps create sustainable, inclusive, and mixed communities. It considers current and future demographic trends and the needs of different groups in the community (such as, but not limited to, families with children, older people, people with disabilities). This in turn fosters good relations between people who share a protected characteristic and those who do not.