Embracing Change: The NCC 2022 Updates in Housing Accessibility

The National Construction Code (NCC) 2022 has introduced significant updates to housing design, marking a pivotal moment in the journey towards creating more accessible housing stock in Australia.

The new Livable Housing Design Standards (LHDS) aims to ensure homes are designed to meet the needs of the community, by making them more accommodating for older people and those with mobility-related disabilities or temporary injuries. The intent is to have requirements that benefit all home occupants, but they are a minimum standard and may not fully cover everyone's needs. The Standards include specifications for step-free entrances, wider doors and corridors, and some spatial provisions for bathrooms.

Why now?

The housing and homelessness crisis is worsening in Australia, and it disproportionately impacts older people and people with disability due to housing affordability, availability and accessibility. In Victoria, we have the Big Housing Build, which includes requirements for all new public housing to meet certain Liveable Housing Australia (LHA) requirements. These include Liveable Housing Design Guidelines for a livable home, which are recommendations for homes designed and built to meet the changing needs of occupants across their lifetime.

We also have the Better Apartment Design Standards which include some accessibility features, required of 50% of apartments but in my opinion, these specifications are significantly lacking. So, up until now, regular single dwellings have NOT required any accessible features.

In 2017 the Government discussed the possible inclusion of minimum accessibility standards in the NCC. This led to what we now know as Livable Housing Design Standards. Originally drafted as ‘accessible’ rather than ‘livable’, it didn’t make sense for several reasons, mainly its similarity to the Livable Housing Australia Design Guidelines. Also, it does not and therefore should not pretend that it will be enabling access in the true sense of the word for people with disability (e.g. people who use wheelchairs).

In 2021, Commonwealth State and Territory building ministers agreed to include Livable Housing Design Standards in the NCC. However, not all states and territories have embraced the Standards. Currently, NSW and WA have not adopted them, but other start dates are:

-       Northern Territory and Queensland - 1 October 2023

-       Australian Capital Territory - 15 January 2024

-       Victoria - 1 May 2024

-       South Australia and Tasmania - 1 October 2024

What are the Livable Housing Design Standards?

The Standard consists of six parts, each covering different aspects of a dwelling. These are:

1. Dwelling Access: Getting to the entrance from the street or car park space.

2. Dwelling Entrance: Entering the home itself. The new Standards emphasise step-free access paths from the street or parking areas to the home, and requirements for the width and threshold of entrance doors.

3. Internal doors and corridors: Prescribes a minimum width for corridors and doorways, which increases ease of movement around the home.

4. Sanitary Compartments: Sets out a minimum clearance zone in front of the toilet pan. The NCC 2022 mandates the presence of an accessible toilet on the ground floor.

5. Showers: Allows for more independent access to a hobless or step-free shower.

6. Reinforcement of Bathroom and Toilet Walls: Provides the ability to add supports if needed for future installations of grab rails.

All parts of the Standard apply to Class 1a dwellings, i.e., houses. For Class 2 apartments, all parts of the Standard apply except for the dwelling access provisions. This is because the dwelling access provisions are already covered in NCC Part D4 of Volume One.

What are the gaps?

Despite these advancements, the NCC 2022 updates do not entirely bridge the gap in creating truly accessible housing. For instance:

1. Limitations for Wheelchair Accessibility: The provisions, while helpful, do not necessarily accommodate the needs of wheelchair users. The Standards fall short of ensuring that such individuals can comfortably and functionally occupy these spaces.

2. Varying Adoptions: The adoption dates and interpretations of the NCC 2022 vary across states, leading to inconsistencies in implementation. For example, in Queensland, NCC 2022 LHDS exemptions are included in the Queensland Development Code (QDC). The new QDC 4.5 has flexibility around the location of an accessible toilet where there are no habitable rooms on the entry-level, and bathroom and toilet renovations will not have to comply with the LHDS where it is not reasonable or practical.

3. Toilet Location: The LHDS requires at least one sanitary compartment to be located on the ground floor or entry level of a dwelling, with clear circulation space in front of and to the side of the toilet pan. The extra space intends to improve useability for children, older people and people with an ambulant-type disability. However, the prescription for an LHDS-compliant toilet on the ‘entry level’ is not well aligned (and rather redundant) with the intent of the LHDS, where there is a dwelling that has all other main living areas on upper or lower levels. For example, there could be a ‘fully LHDS compliant’ townhouse that has a garage and powder room on the entry level, with the first level having a kitchen and living area, and the second level with two bedrooms. This example questions how someone could truly have enhanced liveability or age in place and make minor adjustments to their existing dwelling without relocating.

4. Cost Implications: There are concerns about the cost implications of these updates, especially for lower-income households and in the context of the housing affordability crisis. Builders too, are worried about potential increase in construction costs. However, the Australian Building Codes Board estimates the additional cost to implement the minimum accessible design standards is between $2,900 and $4,400 per home, depending on the type of dwelling.

While incorporating these standards may require some upfront investment, it will save money in the long run. Applying the LHDS helps make homes easier to access, navigate and live in, as well as more cost-effective to adapt when life’s circumstances change. Integrating these features now will avoid more costly home modification if required at a later date.

Looking Forward: The Road to True Accessibility

The NCC 2022 updates are undoubtedly a progressive step, but there is a clear need for ongoing advocacy and policy development to address the remaining challenges. To move towards truly inclusive housing design, consideration of broader disability needs, uniformity in implementation across states, and strategies to manage cost implications are imperative.

Conclusion: A Continuous Journey

The NCC 2022 has set a new standard in accessible housing design, yet the journey towards complete inclusivity in housing continues. These updates serve as a reminder of the ongoing need to advocate for comprehensive, practical, and inclusive housing solutions that cater to the diverse needs of our community.

Regardless of the service we provide, whether it’s a large commercial office audit or a small report for a new toilet design, we always champion early involvement.

I am a registered architect, an accredited Access Consultant, an LHA and SDA assessor, and a registered LHA NCC Assessor. This means I specialise in guiding home owners, builders, developers, designers and certifiers/surveyors to employ the Livable Housing Design Guidelines.

I recommend having a concept design / DA set reviewed well before construction to confirm everything is on track and ensure minimal issues throughout construction and at sign-off.