Opinion piece by John Van der Have
The vast majority of those areas of New South Wales that encourage medium and high density housing are covered by planning controls that refer to AS 4299 – Adaptable housing. Yet this Standard is no longer current, leading to less than desirable outcomes for people with disabilities. Thankfully, a revision may be in the wings.
A brief history of AS 4299 – Adaptable housing
AS 4299 Adaptable housing was published in 1995. It is a major standard within the Standards Australia portfolio of publications covering building design and construction. It is widely referenced in the development control plans of the more heavily populated regions of New South Wales.
There are 33 Local Government Areas in the Greater Sydney Metropolitan Area. Of these, AS 4299 is referenced in 30, ie the great majority. Even Development control plans that have been revised in the past year or two have called up AS 4299 (1). Additionally, AS 4299 is referenced in several other Local Government Areas outside of the Sydney region that have high population densities (2).
Over the past three decades thousands of adaptable housing units, designed to AS 4299 have been built. Councils in the more heavily populated parts of New South Wales typically require a proportion of housing units in multi-unit housing developments and in residential apartment buildings to comply with this Standard.
The advantage of such units is that they can be easily adapted, or modified, should ever the need arise, to accommodate the needs of people with disabilities or progressive frailties. Therefore, if an occupant or family member has an accident or illness that requires that person to use a wheelchair, crutches, etc, the housing unit can be readily modified to suit his/her needs.
AS 4299 has been a big seller for Standards Australia, who state on the inside front cover of their publications:
‘Standards are living documents which reflect progress in science, technology and systems. To maintain their currency, all Standards are periodically reviewed, and new editions are published. Between editions, amendments may be issued.’ (3)
AS 4299-1995 has never, so far, been revised. This is notwithstanding the fact that technology covered in this document has advanced significantly in the three decades since AS 4299 was published, with substantial implications for the its contents.
As a result, AS 4299 is now well out date. It is also seriously out of sync with AS 1428.1-2021 (Design for access and mobility Part 1: General requirements for access – New building work) causing major problems in practice for users. A gulf of 26 years now separates these two related Standards: AS 4299-1995 and AS 1428.1-2021. That is a whole generation of innovation in technology and housing design that is not now reflected in the Adaptable housing Standard.
I have in the past taken up with Standards Australia the need for urgent revision of AS 4299. The Association of Consultants in Access also, in April 2022, proposed to Standards Australia that AS 4299 be reviewed and revised. That proposal was supported by other stakeholders including Occupational Therapists Australia, the Australian Institute of Architects and Physical Disability Australia.
I am pleased to report that due to heavy lobbying by the ACA management committee, I have recently been advised that Standards Australia is now considering a proposal to include revision of this important document in its works program. A decision in this regard is likely to be made in September 2024.
The Livable Housing Design Standard
Over the past three decades, other players moved into this space. Among these was the Australian Network for Universal Housing Design (ANUHD). ANUHD came up with its own document intended as a set of guidelines to residential design for for people with disabilities. They called their document the Livable Housing Design Guidelines (LHDG).
These guidelines were clearly modelled on AS 4299. For example, they contained three categories of compliance. Where AS 4299 had Classes A, B and C, the LHDG proposed three classes – Silver, Gold and Platinum. The LHDG covered the same ground that AS 4299 had already covered. However in doing so the LHDG substantially weakened the provisions included in AS 4299.
We have to remember that the LHDG were not based on research, nor on evidence of what works when it comes to design of buildings to suit the needs of people with disabilities. The LHDG were developed by a group of well-meaning parties, under the guidance of ANUHD, who took the provisions of AS 4299 and substantially watered them down, to produce a set of guidelines that they hoped would serve the housing needs of the disability community.
In this the LHDG have failed. For example, a person in a wheelchair cannot use a toilet of the size prescribed by the LHDG. Door clearances and circulation areas are less than adequate. In many other details, the LHDG likewise fail to meet the needs of people with disabilities. Every spatial requirement in AS 4299 was reduced or omitted by those who prepared the LHDG.
The LHDG were intended to be a set of guidelines that industry would voluntarily adopt. However, they failed to gain traction with their intended market. Take-up by the property development industry was miniscule. The LHDG were simply not seen by industry participants as a compelling proposition.
When it became apparent that voluntary take-up by industry was headed for failure, ANUHD turned its attention to politicians overseeing building regulations. In response to lobbying by ANUHD and others, in April 2021 the majority of Building Ministers agreed to include amendments to the BCA based on the LHDG, silver level. The purpose of such amendments was supposedly to meet the needs of the community, including older Australians and those with a mobility-related impairment.
As a result, the ABCB Standard known as the Standard for Livable Housing Design (based on the Livable Housing Design Guidelines, fourth edition, 2017), is today a referenced document in the Building Code of Australia (BCA).
Amendments contained within BCA 2022
BCA 2022 Volume One contains Part G7, Livable housing design (Part H8 in Volume Two). This part of the BCA came into effect in most states in October 2023 (October 2024 in Tasmania). Despite active lobbying by ANUHD, the jurisdiction of New South Wales rejected this part of BCA-2022. New South Wales, with its high level of implementation of adaptable housing and AS 4299, has elected not to include the Standard for Livable Housing Design within the NSW version of the BCA.
While the stated objective of this part of the BCA is to meet the needs of the community, including people with mobility-related disability, the deemed-to-satisfy provisions, contained within the ABCB Standard for Livable Housing Design, will not meet that objective.
The past three decades have been fraught with competing views in regard to adaptable and accessible housing. In promoting the inclusion of the contents of LHDG into the BCA, ANUHD claimed in 2022 that AS 4299 no longer reflected government or industry best practice, and sought deferral of any review of AS 4299 for four years. Prior to this, as mentioned above, in April 2022 the Access Consultants Association had asked Standards Australia to review and update AS 4299.
The need for a register of adaptable houses and apartments
The shortcoming, in practice, with the current system of building adaptable housing units is that there is no register anywhere which identifies such units. The many thousands of adaptable houses and apartments that have been built so far are effectively ‘ghost units’, in that they cannot be readily identified. They look and present just like any other units.
Adaptable houses and apartments have inherent advantages over other housing units and should sell at a premium. Yet they exist in a twilight zone, where they cannot be readily identified when needed.
Conclusion
It is heartening to be able to report that Standards Australia is now considering a revision of AS 4299 Adaptable housing. The post-adaptation provisions of AS 4299 remain best practice when it comes to detailed, specific information covering the design of accessible housing. These provisions will be better still when AS 4299 is revised to reflect current technology and design thinking.
I look forward the speedy revision of AS 4299 (to bring it in line with related Standards and current technology), and the commencement of a register of adaptable housing units. Achievement of these twin goals will represent a major advance for the community of people with disabilities in Australia. This major advance could be achieved at minimal cost.
Footnotes
- For example, Willoughby DCP 2023; Hornsby DCP 2024
- For example, Wollongong DCP 2009; Ballina DCP 2012; Byron DCP 2014; Shoalhaven DCP 2014; Dubbo DCP 2013; Wingecarribee / Bowral DCP; etc
- For example, AS 3700:2018 – Masonry structures
AUTHOR BIO: John Van der Have
John Van der Have is the principal of Bio-Building Design Pty Ltd – Architects and Access Consultants, based in the City of Blue Mountains, NSW. He is an accredited member of ACA, and also a member of the Australian Institute of Architects. He has served as access consultant on numerous medium and high-density residential projects.