NDIS Fed Ex Talk

Introductory excerpt…

Focussing on high quality design outcomes and ethical practices, Anthony will showcase innovative housing solutions, including real and hypothetical case studies and answer questions about how to address complex regulatory requirements while creating new opportunities and housing choices for SDA recipients.

Quote needs reference and details of the location.

The provision of housing for people with a disability has been an interest of mine for some time and I’ve been fortunate to have been involved in numerous projects over the years.

We’re clearly operating in interesting times right now with the roll out of the NDIS and I’ve spent a lot of time over the past months attending lots of talks & events, following closely developments from NDIA website and following consultants and practitioners involved in this space.

In terms of my response to the NDIS I have to admit to a level of shock that the NDIS will not be directly addressing housing needs for most participants in the scheme, as it is the expectation of the NDIA that the vast majority participants will seek accommodation through existing systems:

  • social and community housing
  • homelessness and emergency accommodation services
  • Commonwealth Rent Assistance is a payment through the Department of Human Services that will assist eligible participants with the cost of housing
  • the National Rental Affordability Scheme (NRAS) is creating additional affordable rental dwellings

It’s fair to say that all of these systems are already under stress and the provision of housing it’s going to be a source of ongoing concern to many NDIS participants.

On the plus side the NDIS does offer housing support packages to some high needs participants and the scheme includes several key reforms that I think should lead to improved outcomes.

Firstly, the SDA model provides a welcome shift away from the established five-bed group home typology to include apartments, villas, duplexes, townhouses and small-scale shared houses, but it doesn’t provide a clear roadmap for their planning, design or delivery.

Secondly, while the key lynchpin of the NDIS (the separation of care and accommodation services) enables participants to choose housing options that are not tied to care packages for the first time, there is still little information available about how to make that happen.

In effect, the broad scope of the NDIS means that anyone can become a registered SDA provider: participants themselves, family members, groups and organisations. However, existing community housing providers are best placed to take on this challenging role, thanks to their track record of managing housing portfolios, encompassing large-scale property management and working with specialist clients.

Its going to be an interesting time while the market establishes who will build SDA.

I’m being approached by a fair number of people, NGO’s & even private sector operators at the moment and am constantly surprised & somewhat encouraged by the variety of approaches on offer.

The NDIA has established a clear pricing incentive from for different housing models as reflected in the relatively low prices paid to 5 bedroom group homes compared to other accommodation types.

The Pricing Policy states that: “SDA properties have an alternative use and can be either sold or rented to the broader residential market”

The NDIA is effectively discouraging investment in ‘stranded assets’, that is spending huge sums of money on projects that don’t have an alternative economic use. The days of the 5 bedroom group home in a location with cheap land & a level block are numbered – thankfully.

I think this is tremendous.

SDA should be well located, offering independence and choice. There should be easily access public transport, a place where friends and family feel comfortable visiting, somewhere that is homelike and inviting for others

But even if additional incentives materialise, SDA developers face many hurdles as they seek to carve a path through building code regulations, the SDA Pricing Policy and local planning rules.

The NSW Planning System codifies ‘Group Homes’ as a specific form of residential accommodation that is distinct from other development.

You need planning consent to operate a group home. Need to check land use zoning for permissibility.

You’ll find references to Group Homes in the planning information applicable to many blocks of land. There are numerous sites that have planning restrictions preventing group homes, for example flooding and bushfire risks.

There is also a specific State Environmental Planning Policy provision that describes ‘Complying Development’ that can be built without need to lodge a Development Application.

Complying Development is appealing to many as it offers a degree of certainty. It can be difficult. Note that any ADHC Group Homes would be unlikely to comply with CDC – they didn’t have to.

Under the National Construction Code, SDA housing is likely to be classified as either Class 1b or Class 3 (both of which require stricter fire safety standards and accessibility provisions than regular housing).

To date many Group homes have been designed as Class 1b, but it’s somewhat controversial as not everyone agrees that housing for people with a disability isn’t a Class 3 building. The main differences relate to fire safety and acoustic separation. To date ADHC have provided over and above on fire safety, eg full fire sprinklers and we’ve been comfortable, but going forward we don’t have these guarantees.

It’s also noteworthy that the Liveable Housing Australia requirements for platinum certification differ somewhat from the requirements for access in the NCC. You’ll need to comply with both if you are to maximize funding. At present NDIA only require a design certification but it’s foreseeable that they will seek as built as well over time. This can be onerous.

Example 1 – 2+3 split

Modification to a group home to offer greater independence between the two groups living in the house while retaining onsite support.

Example 2 – Villa under 1 roof

Further modification of a group home to offer independence at a personal level. This project still operates as a single group and presents as a single house to the street.

Example 3 – 2 storey group home

This project effectively contains a series of separate 1 bed villas stacked above a 3 bed villa.

There is an accessible lift to the top floor.

Other current projects are not planning a lift.

Is actually similar in form to an apartment building.

It’s noteworthy that boarding houses group homes are not physically described, but are described in terms of occupancy.

Example 4 – Medium Density Housing

This project incorporates accessible housing within a range of medium density housing models.

The project was built for a Community Housing provider and had to fit seamlessly into a new land release area.

While not specifically a SDA project I think it could be a good model to develop further.

Example 5 – Residential Flat Building

I was at a SDA housing seminar earlier this year and was surprised at the call that was being made to include SDA within apartment buildings.

It’s a good example of regulatory failure in my view as many local councils already require the provision of a percentage of accessible housing, and the NCC already has extensive requirements for the provision of access. Apartments are currently being built that could very easily be made suitable for SDA but they are currently seen as undesirable by developers. The Summer Foundation has done some good work in this area.

Issues of Scalability

One of my big interests is the issue of scalability of any SDA housing models that are developed. To date many examples on offer are too bespoke to be rolled out at a large scale. I know that there is interest for example in the development of ‘project homes’ that would be suited for use as SDA.

Opportunities of Missing Middle

The state government recently released a draft planning guide called The Missing Middle3. It aims to increase density in inner- and middle-ring suburbs with new medium-density housing, which ties in with the stated goal of the NDIS to move away from building stranded assets – such as five-bed houses on the periphery of cities – where residents are isolated from services and effectively trapped.

In summary, even though it’s early days for this new housing model, it’s becoming clear that SDA housing doesn’t need to be markedly different from other housing types – especially because universal housing design principles are being adopted more widely – but compliance with the various regulatory frameworks will require careful thought and management.