On behalf of the National Disability Authority, NDA, I thank the Chairman and members of the Joint Committee on Housing, Planning and Local Government for the opportunity to make a presentation on housing for persons with disabilities. The NDA is an independent statutory body, and while it is not a representative body, it was established to provide independent and evidence-informed advice to the Minister for Justice and Equality on matters of policy and practice relevant to the lives of persons with disabilities. A function of the NDA is to promote the adoption of a universal design approach to the built environment, products, services and ICT so that they can be easily accessed, understood and used independently to the greatest extent possible by all people, regardless of their age, size, ability or disability. That broadens the remit of the NDA beyond disability. The NDA engages with many stakeholders, in particular the Department of Housing, Planning and Local Government and the Housing Agency, on issues relevant to persons with disabilities.
Based on the returns from Census 2016, we know there are more than 640,000 persons with disabilities in Ireland. Most persons with a disability will have acquired their disability, especially in adult life. We are talking about all types of disability, from physical, sensory and intellectual disability to mental health, autism and sensory impairments. Persons with disabilities are more likely to rely on local authority housing than other citizens - 12.8% compared with 8.3% of the general population. This arises particularly where persons with disabilities have poorer employment prospects than others, and it is also due to higher costs they may have related to their disability. Therefore they may be more dependent on the State for support in securing a permanent home. This generates a demand for more social housing options.
The right to adequate housing has its origins in the United Nations Universal Declaration of Human Rights 1948 and the international conventions that followed. In particular, the UN Convention on the Rights of Persons with Disabilities 2006, UNCRPD, which was ratified by the Government last year, further elaborates on the meaning of the right to adequate housing as it relates to persons with disabilities. The convention creates a new benchmark for the realisation of the right of persons with disabilities to adequate housing through Article 19, which refers to living independently and being included in the community. This requires that Ireland delivers on the rights of persons with disabilities to “live in the community with choices equal to others” and to “have the opportunity to choose their place of residence and where and with whom they live”. This is at the heart of the policy of decongregation being progressed by the HSE, but is also relevant to persons with disabilities in the community who, for example, may wish to move out of the family home. Article 28 of the UNCRPD requires the State to deliver on the right to “adequate housing” and to “ensure access by persons with disabilities to public housing programmes”.
The Department of Housing, Planning and Local Government has made a number of commitments regarding persons with disabilities under various strategies on housing, including the Social Housing Strategy 2020, Rebuilding Ireland, and in the National Disability Inclusion Strategy, NDIS, 2017-2021. The Department’s National Housing Strategy for People with a Disability 2011-2016 has been incorporated into Rebuilding Ireland and extended to 2020 for delivery. The NDA was on the Department’s advisory group and related subgroups on the development of that strategy, and is on the Department’s implementation monitoring group for that strategy.
The Department affirms the commitment to implementing the national housing strategy in the national disability inclusion strategy, NDIS. The NDIS is undergoing a mid-term review, and the NDA suggests that there is an opportunity to strengthen actions therein on housing for persons with disabilities. To date we know a number of actions have been progressed under the national housing strategy, including for example, the designing housing to meet the needs of all toolkit and website as a resource for housing authorities, developers and housing providers to develop and design housing projects to be inclusive, adaptive and accessible. There are also actions progressed to promote the take-up of the capital assistance scheme, CAS, for persons with disabilities and to streamline the application and decision process. There was the production of a summary of social housing assessments on households qualified for social housing support who have yet to have their needs met. A guide by the Housing Agency on the housing assessment and allocation process for persons with disabilities was produced to assist local authority staff in applications and managing waiting lists. There has been some streamlining of the housing adaptation grants scheme, with rising numbers of grants paid each year. There have been advances in making housing related application processes more accessible. Housing and disability steering committees were established in each local authority. These are just a few examples of what has been achieved, and even within those, further work will be needed to achieve greater impact on access to housing for persons with disabilities. The NDA has been advising on the various initiatives and will continue to do so within its independent role.
At the same time, the NDA notes that there are more goals that have yet to be realised within the national housing strategy, given that it has to be completed next year. While decongregation of persons with disabilities from institutional living arrangements to community living continues, it has been acknowledged that the original timeframe of 2019 for decongregation will not be met, so that timeframe will need to be extended. Some of the delays relating in part to access to housing are due to the need to tender and retender for refurbishments and to planning permission issues. The NDA continues to advise on such matters, including conducting an evaluation project for learning from decongregation.
Changes in the structure and delivery of housing benefits cannot alone make it easier for persons with disabilities to secure accommodation. There are difficulties accessing private rental accommodation not only because of the lack of accessible properties but also because many persons with disabilities are priced out of the rental market. The Irish Human Rights and Equality Commission, IHREC’s recently published annual report states that it is apparent that there is systemic discrimination against people in general in receipt of housing social welfare payments and that persons with disabilities are more than twice as likely to report discrimination relating to housing and over 1.6 times more likely to live in poor conditions.
Scarce resources are, understandably, being directed to dealing with those in emergency accommodation and experiencing homelessness. The issue of homelessness for those with disabilities and mental health difficulties needs particular attention and the NDA will be funding research on this shortly. There have been difficulties with a lack of uniformity across the country on combining an offer of housing with the availability of an appropriate care package.
We recognise the housing crisis means not enough houses are being built to meet needs, but it is important in addressing this that the right type of housing is being built to meet the needs of persons with disabilities and the changing needs of householders who may acquire a disability over time. We advise that Part M of the building regulations of 2010 needs to be reviewed and updated, with due regard to the NDA’s universal design homes guidelines so that the accessibility standard for new builds would be higher.
While we have a summary of social housing needs assessment, further work is required to ensure robust data to plan housing to meet housing needs. Actively considering the potential for better collection of data on accessible housing and the range of housing available would also be helpful.
The type of housing we build, how it is designed and where it is located all impact on the individual. The long-term benefits from housing, following a universal design approach, could realise savings to the State in health and social care, could help alleviate the challenges presented by climate change and could help improve the well-being and fabric of communities. The NDA has been engaging with many stakeholders, including local authorities and the Department, on the adoption of a universal design approach to housing. We welcome the recent commitment by the Department of Housing, Planning and Local Government and the Department of Health, in their recent policy statement on Housing Options for Our Ageing Population, to ensuring that 30% of all new dwellings will be built to incorporate universal design principles to accommodate our ageing population. We also welcome the report last year of this joint committee in which it recommended looking at universal design and a cost-benefit analysis. That is included in the NDA's work plan and we will be commencing a scoping exercise on that shortly. The focus on universal design in older housing stock sets an important precedent that should also prove to be important for persons with disabilities.
The NDA will continue to engage with professional bodies such as Royal Institute of the Architects of Ireland, RIAI, and third level institutions like the Technological University of Dublin to embed a universal design approach in the relevant academic and professional courses, in order to provide the skilled practitioners that will be required to plan, design and construct universal design homes. We are also working with bodies and continuous professional development in this regard.
The NDA is also aware of the particular needs of persons with mental health difficulties and the needs of persons with autism. We have previously published guidelines for persons with mental health difficulties as well as guidance for local authority officers to assist persons with autism.
The NDA has also briefed the Housing Agency about the importance of preparing officials working in local authorities on their potential roles under the Assisted Decision Making Capacity Act 2015. When the Act is operational, it will be up to local authority housing officers to be as supportive as they can to applicants who may have capacity issues in making decisions on housing. The Housing Agency has been very proactive in engaging with the NDA about the development of its own guidance in this regard.
Like other countries, our population is living longer and the number of older persons is growing. It is expected that the numbers of persons with disabilities will increase by approximately 20% by 2026. This has particular implications for housing and supported living in the community, and the need to ensure a sustainable housing model in Ireland. There is, therefore, an obligation on all stakeholders involved in planning, design and construction to take action to achieve this. There are various strategies and policies in place that when fully implemented can help progress access to housing for persons with disabilities in Ireland, particularly as part of mainstream housing developments. As well as the greater need for social housing, we advise that there should be a greater emphasis on creating liveable and sustainable neighbourhoods where persons with disabilities can live full and active lives as part of a real community.