Letter to the Minister
On behalf of the Enabled Youth Disability Network Incorporated, we would like to take the opportunity to urge you to adopt the changes to the National Construction Code (NCC) which would see the implementation of mandatory minimum accessibility standards in new residential construction.
About the Enabled Youth Disability Network:
The Enabled Youth Disability Network (EYDN) is an organisation based in South Australia run by and for young people living with disability. EYDN provide systemic advocacy and peer networks, to give a voice to and support young people living with disability and improve their life outcomes.
Since 2008, EYDN has been supported by JFA Purple Orange, a non-government, social profit organisation. In 2020 EYDN became an incorporated organisation and has a board comprised entirely of young people living with disability.
From discussions with EYDN members, one issue that is consistently identified for people living with disability is the need for accessible housing, and the opportunity to exercise choice and control over where and who they live with.
In 2020 during conversations surrounding the future of Highgate Park, the disability community was consulted and made it clear that it was no longer appropriate for people living with disability to be living in institutions and group homes. DHS then acted on this advice and closed the facility.
Despite this closure, the SA Housing website still provides minimal advice and support for buying or renting properties and has a significant focus on public and community housing, group homes, and supported residential facilities. Concerningly, empirical research shows that group homes and institutions are linked to poorer mental health outcomes for people living with disability, compared to people living with disability in private homes (Scott & Havercamp, 2014, p. 557). The Australian Disability Royal Commission also found that people living with disability, placed in these segregated environments, are more at risk of abuse, neglect, violence, and exploitation.
Given the momentous step of closing Highgate Park and moving towards allowing people with disability more freedom to choose where they live, we were disappointed to hear that the South Australian Government has then rejected the new accessibility standards to the NCC. The government believes that these standards “do not go far enough in truly assisting those who require accessible homes and place an unjustified burden on the construction industry to mandate them across all future builds.” This goes against the direct voices of people living with disability and highlights an attitude that providing safe access to homes and community is an ‘unjustified burden’. This goes against the Convention on the Rights of Persons with Disabilities, which Australia is a signatory to and bound by. This Convention states that people living with a disability must enjoy all human rights and fundamental freedoms and have the right to actively participate in society. To enjoy these rights fully accessible homes and buildings are necessary.
Choosing not to adopt the National Construction Code also places the financial burden on people living with disability, and the National Disability Insurance Scheme, to fund the retrofitting of properties and make them accessible. This can be significantly more expensive than designing them with accessibility features from the beginning and means that choices on where to live will ultimately be decided by what funding is available to an individual, rather than individual choice and control.
The disability community deserves clarity, honesty, and collaboration around what the South Australian Government proposes to do in place of these standards if the NCC continues not to be adopted and the opportunity to use their lived experience to highlight the importance of adopting the NCC accessibility standards.
We hope our feedback has been useful and thank you for the opportunity to share our lived experience of disability to highlight the importance of these standards being adopted. We ask that our submission be considered and discussed in the lead up to the state election and would appreciate your advice as to whether your party will adopt the changes in the NCC by COB Monday 14 March 2022. We will be communicating each party’s position on this issue to EYDN members to support them to make an informed decision on Election Day
Please do not hesitate to email firstname.lastname@example.org or call (08) 8373 8388 if you would like to discuss our submission further.
Sarah Footner (Project Leader, EYDN)
Kathryn Mills (Chair of EYDN)
The Enabled Youth Disability Network Incorporated, 7 March 2022