Submissions

To: Ministry of Business, Innovation & Employment
Date: August 2024

Purpose

This submission’s purpose is to highlight the inaccessibility of existing private housing stock and advocate for the mandatory application of universal design standards in the construction of all new smaller homes.

DPA adopts a neutral stance on the overall government proposal, acknowledging both positive elements and significant concerns, particularly regarding potential exploitation and compromised building standards.

Summary of DPA submission

DPA has long highlighted the inaccessibility of private housing stock in New Zealand, noting that less than 1% of private dwellings meet universal design standards. DPA acknowledges the Government’s desire for affordable housebuilding costs but stresses that this should not come at the expense of accessibility for disabled people. Buildings incorporating universal design from the outset cost only about 1% extra, with 1-2% set aside for accessibility. DPA supports the development of small accessible homes for both social and private housing markets, citing Able Abodes as an example.
 
DPA cautiously agrees with the principles of enabling small housing in resource management and building systems and supports Option 2 (establishing a new schedule in the Building Act) if combined with Options 4 and 5 to ensure flexibility and minimum standards. DPA agrees that a national environmental standard with consistent permitted activity standards is the best way to enable minor residential units, as it allows for common standards across the country, particularly regarding accessibility.
 
DPA also generally agrees that the proposals support Māori housing outcomes, enabling disabled Māori to live closer to whānau while retaining independence.
 
However, DPA is concerned about the potential for exploitation by unscrupulous landlords who might create numerous granny flats to rent at exorbitant rates, especially in areas with growing populations and minimal housing. DPA expresses significant concern about proposals to relax building regulations, which could lead to poor weathertightness, structural issues, and compromise healthy homes standards, drawing a parallel to the "leaky homes scandal". DPA is also concerned about the prospect of charging fees for data requests related to electricity usage, as this would be prohibitive for many low-income and disabled customers.
 
Key Recommendation:
DPA recommends that smaller housing is built to universal design accessibility standards.
 
Supporting Statement 1:
UNICEF reports that buildings incorporating universal design accessibility from the beginning only cost an extra 1% of any build project budget, with approximately 1-2% needing to be set aside for accessibility.
 
Supporting Statement 2:
This is an important consideration given that the number of disabled people is expected to rise with the ageing population, making it crucial that all housing stock is future-proofed to enable accessibility.