Response 420083325

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Understanding and quantifying the problem

8. Do you agree that the problem is adequately established?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please indicate below your opinion, whether the issues described under the problem section (its nature) adequately establish a case for action, or if there are other problems not identified under the status quo:
Silver level is usually considered anyway by people having a house built for their own use.
People who are driven only by the financial returns of property development and ownership will see accessibility as an impost, just as they saw insulation as an unwarranted expense. But over time, buyers and renters have shown that they DO prefer energy-efficient accommodation and probably the market will lean somewhat towards accessibility as well. Certainly in retirement villages.

9. In general, do you agree the Consultation RIS adequately describes the extent of these problems?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No

10. The impact of a lack of accessible housing on equity, dignity and employment outcomes is difficult to fully measure. How does a lack of accessible housing contribute to these issues?

Please describe how and to what extent:
Equity: People with injuries or other mobility issues (short-term or long-term) will not have equal opportunities, principally because they will be confined to institutions of one sort or another.
Dignity: Intimacy and solitude are two big psychological drivers (Dowrick) and the physical situation of an individual will often influence their access to adequate levels of privacy and independence.
Employment: In a private home, access to transport and on-line work facilities can be customised to individual needs. If there is not enough accessible housing they will spend more time "standing in line" to use those services.

11. Are the assumptions made to estimate the costs to the community from a lack of accessible housing (set out in Appendices A to H) appropriate?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please explain your answer below and what other evidence could be considered:
If the CIE document is the matter in question, then it is very comprehensive and would require a lot of time to audit.

12. What other information could be used to estimate the costs associated with a lack of accessible housing to make estimates more reliable?

Please provide your response below:
NDIS budgets.

13. Do you have information about the type and cost of home modifications that are made to improve the accessibility of a home?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No

14. In your opinion what is main contributor to a lack of uptake of universal design principles in new dwellings:

Please select all that apply
Checkbox: Unticked buyers failing to think about their future accessibility needs
Checkbox: Unticked volume builders being reluctant to deviate from standard plans
Checkbox: Ticked other barriers
If other barriers exist, please describe these below:
Reluctance by Govts to apply/enforce sustainability principles, resulting in an imbalance between financial, social and environmental aspects of new Dwelling projects, in favour of the Developer's financial profit. See answer to Q8 above.

Objectives of intervention and Options

15. Of the options considered by the Consultation RIS, select from the list below those that are feasible:

Please select all that apply
Checkbox: Unticked Status Quo: No change to the NCC.
Checkbox: Ticked Option 1: Accessibility standard, broadly reflecting LHDG silver standard, in the NCC applying to all new Class 1a and Class 2 buildings.
Checkbox: Unticked Option 2: Accessibility standard, broadly reflecting LHDG gold standard, in the NCC applying to all new Class 1a and Class 2 buildings.
Checkbox: Unticked Option 3: Accessibility standard, broadly reflecting LHDG gold standard (with some platinum features), in the NCC applying to all new Class 1a and Class 2 buildings.
Checkbox: Unticked Option 4: Accessibility standard, broadly reflecting LHDG Gold standard, in the NCC applying to all new Class 2 buildings only.
Checkbox: Unticked Option 5: A subsidy program to encourage additional availability of accessible rental properties.
Checkbox: Unticked Option 6: An enhanced approach to voluntary guidance, which includes turning the current proposals into a non-regulatory ABCB handbook and other measures to encourage additional uptake of universal design principles, including: a search engine for dwellings certified as complying with the LHDGs and provision of information at the point of sale.

16. Are there other feasible regulatory or non-regulatory options with the potential to meet the objective that should be considered?

Please select all that apply
Checkbox: Unticked Applying the accessibility standards to only residential Class 1a (single detached house, row house, town house, terrace house or villa unit) or Class 2 (multi-storey residential) buildings?
Checkbox: Unticked Applying the accessibility standards to only a proportion of residential Class 1a (single detached house, rowhouse town house, terrace house or villa unit) or Class 2 (multi-storey residential) buildings?
Checkbox: Unticked Applying a different combination of the LHDG elements?
Checkbox: Unticked Applying a subset of the LHDG elements (e.g. step-free entry, wider doorways only)?
Checkbox: Ticked Another option?
Please provide additional information to support your response (for example, how these options would be delivered in practice) below:
The "proportion" philosophy has validity but would be too difficult to enforce across the whole residential spectrum. Class 3 developments COULD escape with a requirement that 20% of SOU's have to be accessible, in similar fashion to what now prevails for motels etc. Silver Standard should be mandated for classes 1 & 2. People need to have an expanding choice of location and affordability so that they can fully participate in society under all of their circumstances occurring in their life-spans.

17. Which of the options, in your opinion, have the ability to meet the objective? (select all options which in your opinion can meet the objective from the list below)

Please select all that apply
Checkbox: Unticked Status quo
Checkbox: Ticked Option 1
Checkbox: Unticked Option 2
Checkbox: Unticked Option 3
Checkbox: Unticked Option 4
Checkbox: Unticked Option 5
Checkbox: Unticked Option 6
Checkbox: Unticked Other Option

18. Are there any less intuitive or unintended consequences likely to arise from the adoption of any of these options?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
If yes, please elaborate below:
Standard accessible designs and components will become cheaper due to economies of scale.

19. Which option is your preferred option?

Please select one item
Radio button: Unticked Status quo
Radio button: Ticked Option 1
Radio button: Unticked Option 2
Radio button: Unticked Option 3
Radio button: Unticked Option 4
Radio button: Unticked Option 5
Radio button: Unticked Option 6
Radio button: Unticked Other Option

Estimating the cost of the proposals

20. Are the scenarios of possible impact (as described in the DCWC report) broadly representative of the scale of adjustments required to comply with the proposed accessibility standards (Options 1-3)?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No

21. For each of the building types, are the weighted average cost estimates broadly representative of the additional construction costs to comply with the proposed accessibility standards (Options 1-3)?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No

22. Do you agree with the approach taken to valuing the opportunity cost of the additional space required?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No

23. Are additional excavation costs likely to be required in order to provide homes that comply with the regulatory options (Options 1-3)?

Please select one item
Radio button: Unticked Highly unlikely
Radio button: Ticked Unlikely
Radio button: Unticked Likely
Radio button: Unticked Highly likely
Describe where in your opinion this will occur (e.g. which option and building type) and what you have based your answer on below:
For Option 1, vehicular access will be a requirement anyway. There are other ways to provide access, and digging a building into the ground creates undesirable consequences for inundation and sanitary plumbing.

24. Are the excavation cost estimates presented in table 5.12 reasonable?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No

25. Are there any other costs (e.g. transition costs) not identified for builders to transition to a new accessibility standard under the regulatory Options (Options 1-3)?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No

Estimating the benefits

27. Are the assumptions relating to the occupation of accessible housing by owner occupiers and renters over time reasonable?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please outline your assumptions and what evidence could be considered to make the assumptions more robust:
Use the analogies of sustainability and the RIS of energy-efficiencies. We need to consider 3BL when justifying these changes, not just $'s.

28. Do you agree with the assumption of the extent features are currently not provided in new dwellings?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No

30. Where dwellings have some accessibility features but not others, would this reduce the size of the problem?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
In your opinion, by how much? (please provide your reasoning/data for your estimate below):
A building needs to be reasonably accessible for the whole range of disabilities, with wheelchair access being the traditional LCD.

31. Do you agree with the assumption that additional features required under accessibility standards in Option 2 and Option 3 would increase the number of beneficiaries compared to Option 1?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Please explain your response and describe what you have based your answer on below:
We are only going for Silver standard. This will improve accessibility for the majority of occupants at little real financial impost to industry.

32. To what extent would better information provision and promotion of an enhanced non-regulatory approach (Option 6) be effective in encouraging the voluntary uptake of universal design principles in new dwellings?

Please select one item
Radio button: Ticked Not effective
Radio button: Unticked Somewhat effective
Radio button: Unticked Very effective
Radio button: Unticked Unsure

34. There is a mismatch between the amount of accessible housing being built and the apparent willingness of many survey respondents (including households without any persons with limited mobility) to pay above cost for Option 1. What explanations are there that could explain this mismatch? Is this a reflection of the market failure?

Explain your reasoning for your answer below:
The cost impost for Silver is not huge, and could be negated by economies of scale anyway. Thinking, reasonable people will embrace the change and recognise that there might come a day when THEY need accessibility. People who want financial gain from housing will complain - they can always invent Performance Solutions.