Enhancing the accessibility, adaptability and usability of Scotland's homes: consultation

Chapter 4 – Impact assessments

Introduction

An impact assessment is an evidence-based process used by the Scottish Government during the development of proposals to consider the possible effects and outcomes on people, communities and businesses. We undertake a range of impact assessments to allow us to consider the impacts our proposals will have on different groups of people, different communities and different businesses.

The Scottish Government created the National Performance Framework to explain its aims for Scotland, the values that guide its approach, and the national outcomes it is committed to achieving. Undertaking impact assessments helps us to understand if our proposals align with our national outcomes. We can address any unintended consequences at an early stage and develop our proposals appropriately to mitigate any potential negative impacts on any groups of people, communities or businesses.

We would therefore like to use this consultation to hear your views on any possible impacts that the proposals for updating Part 1 of the Housing for Varying Needs design guide, and for introducing amended building standards and guidance from 2025-26 to implement an all-tenure Scottish Accessible Homes Standard, may have in a number of areas that we may not have considered to date. A summary of what we have learned so far is provided below.

Equality Impact Assessment

The Scottish Government uses Equality Impact Assessments to help consider how a proposal could affect different groups differently when it is being developed, as well as thinking about how any proposed changes could be used to improve equality. In developing the proposals set out in this consultation paper we looked at equality information to identify where changes could affect some groups more than others, either positively or negatively, and where there are opportunities to make changes which would improve equality.

We paid particular attention to groups of people with protected characteristics as identified in the Equality Act 2010. The protected characteristics covered are age, disability, gender reassignment, sex, pregnancy or maternity, marriage and civil partnership, race, religion and belief, and sexual orientation.

The impacts that we have identified so far for each protected characteristic are set out below.

Age – Scotland faces a number of demographic challenges, one of which is an ageing population. The number of households headed by someone aged 70 and over is projected to increase by 55% by 2043 compared to a drop of 2% for those under 70 (Source: Household Projections for Scotland, 2018-based).

Scotland’s ageing population was one of the key themes in the Housing to 2040 stakeholder engagement which took place in 2018. It also featured extensively in the responses to the Housing to 2040 public consultation in 2019-20. The main feedback from stakeholders included concerns with regards to the rapidly increasing ageing population, the role of health and social care in the Scottish Government’s approach to housing, use of technology to improve accessibility, and flexible housing options for older people with varying needs. Stakeholders also raised issues such as a significant shortage of accessible housing in relation to both old and new housing stock and the need for this to be addressed.

Older people might be more likely to experience a range of housing disadvantages. Most older people and disabled people live in mainstream homes and want to continue to do so, but these properties may or may not meet their current needs. By 2040, it is projected that there will be over 720,000 people in Scotland aged 75 or over, putting much greater demand on housing and health and social care services to help people to live independently at home (Source: Projected Population of Scotland (2020-based)). It is therefore evident that the need for accessible housing will increase as the population continues to age.

Children and young people also face particular challenges.

Child poverty featured as one of the key themes in the Housing to 2040 stakeholder engagement and the public consultation. There was consensus among stakeholders that housing and child poverty are inextricably linked and that there is a relationship between expensive, poor quality housing and offending, mental health issues, educational attainment, excess winter deaths, and child and fuel poverty.

The proposals set out in Chapters 2 and 3 of this consultation paper recognise the challenges outlined above for both older and younger generations and the anticipated demographic changes which the population of Scotland is likely to face over the next two decades. Their focus on enhancing the accessibility, adaptability and usability of homes – through incorporating measures such as (a) requiring step free and accessible thresholds to all entrances (b) future proofing bathrooms so that they can be adapted at a later date to incorporate a wet floor shower area and (c) providing a space allowance for a desk or work space with chair in all homes – are expected to have a positive impact of the quality of housing for people of all age groups.

It is acknowledged however that the additional cost of delivering the proposals may result in fewer new homes being delivered than would otherwise have been the case, all other things being equal.

We would also highlight that building standards do not apply to residential mobile homes, which are built to British Standard BS 3632. This is a type of accommodation chosen by some members of Gypsy/Traveller communities. Within the settled community, people who choose to live on permanent residential mobile home sites are commonly older people who downsize to free up equity and join a retired community, with some sites having a lower age limit for residents. Given that the Scottish Accessible Homes Standard will be implemented through changes to building standards and guidance, these types of homes would not be required to comply.

Disability – According to the 2018 Equality and Human Rights Commission (EHRC) report on housing issues affecting disabled people, Scotland’s disabled population faces considerable housing challenges. Appropriate and accessible housing is the cornerstone of independent living and can transform people’s lives for the better, yet many disabled people across Scotland live in homes that do not meet their needs. According to analysis of the 2019 Scottish Household Survey, just over half (53.6%) of surveyed households with at least one member with a disability or long-standing illness that also require adaptations to make it easier for all householders to go about their daily activities self-report requiring one or more adaptations which they do not already have. This equates to around 80,000 households (Source: Housing and regeneration outcomes framework: indicator updates).

The 2018 EHRC report highlighted that a chronic shortage of accessible and wheelchair-accessible homes across all tenures was one of the main housing challenges faced by disabled people in Scotland.

Feedback from the Housing to 2040 stakeholder engagement and public consultation also highlighted a number of housing challenges for disabled people. This included a shortage of, and increasing need for, accessible housing across all tenures (and also for specific groups, such as people with motor neurone disease and people with dementia). Amongst other things, stakeholders also called for single all tenure building standards and an improved definition for wheelchair accessible housing.

The travelling exhibition final report Present Voices, Future Lives also highlighted the need for houses which can adapt and change with their occupants over the course of a lifetime, particularly as they grow older and potentially encounter mobility issues.

The proposals set out within Chapters 2 and 3 of this consultation paper, such as those listed below, are intended to have a positive impact for disabled people:

• increasing the area inside the main entrance door to allow space for a wheelchair beyond the door swing
• increasing the minimum clear opening width of doors, and
• ensuring that a WC compartment on the principal living level (where the main bathroom is located on another living level) is capable of being adapted to form a larger space for wheelchair use or to accommodate the addition of a shower if needed.

It is acknowledged however that the proposals are also likely to result in the cost of buying a home that is suitable for a wheelchair user being higher than that for other households – this is therefore an issue that we would wish to explore further during the consultation period.

It is further acknowledged that the additional cost of delivering the proposals may result in fewer new homes being delivered than would otherwise have been the case, all other things being equal.

Gender reassignment – Across all of the proposals presented in Chapters 2 and 3 of this consultation paper, we are not aware of any negative impacts for people to whom the gender reassignment protected characteristic applies.

Sex – While the Housing to 2040 consultation that took place in 2019-20 did not yield any sex specific suggestions and/ or views from stakeholders, Housing to 2040 aims to alleviate the disadvantages that women experience in the housing system and ensure that women are empowered to realise, articulate and claim their right to housing in a way that addresses their experiences of housing disadvantage in all of its wide-ranging aspects.

In noting the above, we do not believe that the proposals outlined within Chapters 2 and 3 of this consultation paper will have a significant impact on one sex over the other.

Pregnancy or maternity – No recommendations or views with regards to the pregnancy and maternity protected characteristic were suggested by stakeholders taking part in the Housing to 2040 stakeholder engagement and consultation process. Housing to 2040 puts a strong focus however on ensuring that everyone lives in warm, safe, affordable and accessible housing that meets their needs.

The proposals set out in Chapters 2 and 3 of this consultation paper are expected to have a positive impact for people to whom the pregnancy or maternity protected characteristic applies. In particular, the focus on enhancing the accessibility and usability of homes – through incorporating measures such as (a) requiring step free and accessible thresholds to all entrances (b) increasing the width of corridors within dwellings and (c) increasing the area inside the main entrance door to allow space for a pram or buggy beyond the door swing – is expected to be of particular benefit.

It is acknowledged however that the additional cost of delivering the proposals may result in fewer new homes being delivered than would otherwise have been the case, all other things being equal.

Marriage and civil partnership – While the evidence available for the marriage and civil partnership protected characteristic is relatively limited, it is possible to explore certain patterns and better understand the housing situation and housing outcomes of this group from the evidence available.

Evidence suggests that those who are married or in a civil partnership are slightly more likely to own their home outright. Figures from the Scottish Surveys Core Questions published in 2019 show that there was a higher percentage of adults who owned their homes outright who were married or in a civil partnership (60%) compared to those who owned their homes by mortgage (56%), those who lived in the private rented sector (27%), and those who lived in the social rented sector (25%).

The survey also explored figures for this group across all housing tenures. It showed that for adults living in social rented housing, 49% have never been married, 25% are married or in a civil partnership, 4% are separated, 14% are divorced or have had a dissolved civil partnership, and 9% are widowed or are a bereaved civil partner. A higher proportion of adults living in the private rented sector have never been married (62%) compared to those in the social rented sector (49%), those who owned their homes with a mortgage (36%) and those who owned their homes outright (18%). There was also a slightly higher percentage of adults in the social rented sector who were separated (4%) compared to people in the private rented sector (3%), those who owned their homes with a mortgage (2%) and those who owned their homes outright (1%). A higher percentage of adults were divorced or had experienced a dissolved civil partnership in social rented homes (14%), compared to those in the private rented sector (6%), people in mortgaged homes (6%) and those who owned their homes outright (7%). And lastly, a higher percentage of adults who had been widowed or were a bereaved civil partner owned their homes outright (15%) compared to those who lived in social rented homes (9%), privately rented homes (2%) and those who owned their homes through a mortgage (1%).

Having considered the evidence, we are not aware of any unintended impacts that people with this protected characteristic may experience as a result of the proposals set out within Chapters 2 and 3 of this consultation paper.

Race – The 2011 Census showed that the 'White: Scottish' group made up 84% of Scotland's 5.3 million population, while the 'White: Other British' group made up 8%. Other non-British 'White' groups made up a further 4%. Minority ethnic groups made up the remaining 4% of the population.

In the Housing to 2040 stakeholder engagement in 2018, and during the public consultation in 2019-20, stakeholders highlighted that the needs of ethnic minority older people with complex needs were not being met by current service provision. A number of stakeholders also called for Gypsy/Travellers’ need for accessible housing to be better met in future. In this respect, Gypsy/Travellers are more likely than the general population to have a limiting long term health problem or disability (28% compared to 20%), emphasising the need to provide accommodation that is accessible and can meet the needs of people as they change over time (Source: Gypsy/Travellers in Scotland: A Comprehensive Analysis of the 2011 Census). Gypsy/Travellers are also twice as likely to provide a high level of unpaid care, reflecting cultural traditions of mutual and family support.

In addition, an evidence review published in 2021 on the Housing needs of minority ethnic groups also highlighted that mobility issues experienced by older ethnic minority people often left them in accommodation which was unsuitable and did not fully meet their needs. The ability of the home to be modified over time, as people age, was also referenced in the review.

The proposals detailed within Chapters 2 and 3 of this consultation paper are not intended to have a detrimental effect on any particular ethnic group, and aim to have a positive impact on the needs of:

• Gypsy/Travellers through requiring publicly funded Gypsy/Traveller accommodation to meet the same accessibility standards as mainstream housing where applicable, and
• older minority ethnic people through incorporating measures such as (a) requiring step free and accessible thresholds to all entrances (b) future proofing bathrooms so that they can be adapted at a later date to incorporate a wet floor shower area and (c) ensuring that a WC compartment on the principal living level – where the main bathroom is located on another living level – is capable of being adapted to form a larger space for wheelchair use or to accommodate the addition of a shower if needed.

It is acknowledged however that the additional cost of delivering the proposals may result in fewer new homes being delivered than would otherwise have been the case, all other things being equal.

Religion or belief – Relatively limited evidence is available for the religion or belief protected characteristic.

Figures in the Scottish Surveys Core Questions published in 2019 show that for adults living in the social rented sector, 55% identify as having ‘no religion’, 17% identify as Church of Scotland Christian, 17% identify as Roman Catholic, 5% identify as Other Christian, 3% identify as Muslim and 2% identify as having other religions. In addition, the report also found that, whilst 55% of people who lived in the social rented sector have identified as having ‘no religion’, this was lower than those who owned their homes with a mortgage (60%) and those in the private rented sector (64%) but was higher than those with homes that are owned outright (42%).

Given the nature of the proposals described in Chapters 2 and 3 of this consultation paper, we have not identified any impacts on people to whom the religion or belief protected characteristic applies.

Sexual orientation – The available evidence clearly highlights that people with the sexual orientation protected characteristic face a range of inequalities across a number of areas and settings including, but not limited to, employment, healthcare, education, housing and homelessness. The Housing to 2040 stakeholder engagement and public consultation did not however yield any views, suggestions or recommendations by stakeholders on the sexual orientation protected characteristic.

Across all of the proposals presented in Chapters 2 and 3 of this consultation paper, we are not aware of any negative impacts for people to whom the sexual orientation protected characteristic applies.

Question 48:

Do you have any feedback on any possible impacts that the proposals set out within Chapter 2 and Chapter 3 of this consultation paper may have on groups of people with protected characteristics, as identified in the Equality Act 2010?

Please select one of the following only:

Yes

No

Don’t know/ no opinion

Please explain the reasons for your answer.

Island Communities Impact Assessment

This impact assessment is about testing any new policy, strategy or service which is likely to have an effect on island communities which is significantly different from the effect on other communities.

We are aware that island stakeholders have emphasised the importance of policy makers understanding the island experience. Each island has its own specific considerations and constraints, and there are several factors which impact on island residents' daily lives compared to people who live on the Scottish mainland. We would therefore like to take your views on any possible impacts that the proposals contained within Chapters 2 and 3 of this consultation paper may have on island communities.

Question 49:

Do you have any feedback on any possible impacts that the proposals set out within Chapter 2 and Chapter 3 of this consultation paper may have on island communities which would be significantly different from the impact on other communities?

Please select one of the following only:

Yes

No

Don’t know/ no opinion

Please explain the reasons for your answer.

Fairer Scotland Duty Assessment

This is about considering how the decisions we make about future policy can help to reduce the challenges that people can face as a result of 'socio-economic disadvantage' – which can be things such as having a low income, not having access to basic goods or services, or having a background which gives fewer advantages.

The proposals set out within Chapters 2 and 3 of this consultation paper are aimed at enhancing the accessibility, adaptability and usability of Scotland’s housing – whether that housing is, for example, delivered through the Scottish Government’s Affordable Housing Supply Programme or through the private housing market. While these are expected to have a positive impact on reducing socio-economic disadvantage for the reasons highlighted below, it is acknowledged that the additional cost of delivering the proposals may result in fewer new homes being delivered than would otherwise have been the case, all other things being equal.

Housing is crucial to our aspirations for a fairer country. The Scottish Government is committed to delivering 110,000 affordable homes by 2032, of which at least 70% will be available for social rent and 10% will be in our remote, rural and island communities – delivering this target would support a total investment package of around £18 billion and up to 15,000 jobs each year.

Changes to building standards and guidance from 2025-26 to implement the Scottish Accessible Homes Standard, which all new homes must achieve, will also improve the quality of homes and future proof housing stock to meet people’s needs.

Improving the accessibility, adaptability and usability of Scotland’s homes will help to improve people’s physical and mental health, helping to tackle health inequalities we know are caused by socio-economic disadvantage. These measures will also contribute to children’s wellbeing and happiness, helping to provide a healthy start to life.

Housing also creates and supports jobs and drives inclusive economic growth and social benefits. It makes a crucial contribution across all four pillars (economic, human, social and natural) which underpin our vision of an economy that delivers sustainable and inclusive growth for the people of Scotland.

Question 50:

Do you have any feedback on any possible impacts that the proposals set out within Chapter 2 and Chapter 3 of this consultation paper may have on the challenges that people can face as a result of socio-economic disadvantage?

Please select one of the following only:

Yes

No

Don’t know/ no opinion

Please explain the reasons for your answer.

Child Rights and Wellbeing Impact Assessment

While the proposals contained within Chapters 2 and 3 of this consultation paper will affect the lives of people of all ages and backgrounds, the Scottish Government is committed to ensuring that children’s rights, as determined by the United Nations Convention on the Rights of the Child, are recognised, respected and promoted.

A Child Rights and Wellbeing Impact Assessment therefore helps to ensure that our policies and measures protect and promote the human rights and wellbeing of children and young people. A child is defined as anyone under the age of 18, as per the United Nations Convention on the Rights of the Child.

We recognise that the proposals set out within Chapters 2 and 3 of this consultation paper will have an impact on children and young people, and that these will have an impact on the following articles of the United Nations Convention on the Rights of the Child: Article 23 (rights of children with a disability) and Article 27 (rights of children to an adequate standard of living (including housing)).

We consider that the proposals to enhance the accessibility, adaptability and usability of Scotland’s homes will benefit children. For example, the suite of proposals to enhance the accessibility and adaptability of homes will particularly benefit disabled children or children in a family with at least one disabled person, and the requirement for all homes to have space for children to study should have a positive impact on educational attainment.

It is acknowledged however that the additional cost of delivering the proposals may result in fewer new homes being delivered than would otherwise have been the case, all other things being equal.

Question 51:

Do you have any feedback on any possible impacts that the proposals set out within Chapter 2 and Chapter 3 of this consultation paper may have on the human rights and wellbeing of children and young people?

Please select one of the following only:

Yes

No

Don’t know/ no opinion

Please explain the reasons for your answer.

Business and Regulatory Impact Assessment

A Business and Regulatory Impact Assessment analyses the potential costs and benefits to businesses and the third sector of any policy changes, with the goal of using evidence to identify the proposal that best achieves policy objectives while minimising costs and burdens as much as possible.

A Partial Business and Regulatory Impact Assessment of the proposals set out in Chapters 2 and 3 of this consultation paper is provided at Annex V and we would welcome your views on this.

Question 52:

Do you have any feedback on any possible impacts that the proposals set out within Chapter 2 and Chapter 3 of this consultation paper may have on businesses and the third sector?

Please select one of the following only:

Yes

No

Don’t know/ no opinion

Please explain the reasons for your answer.