The Fair Housing Design Manual – Design

When HUD issued the Fair Housing Act Design Manual and its’ design requirements, there was considerable concern that it would add cost to apartment complex construction. However, the “cost” factor turned out to be less than expected. And, the design requirements actually reflected what was happening in the American marketplace. The biggest change in apartment-unit-design brought about by the design requirements of the Fair Housing Amendments Act (FHAA) was larger bathrooms and kitchens. But, if you looked at single family homes or general apartment design, you’d find that larger kitchens and baths were becoming the norm.

If you study the requirements of the Fair Housing Amendments Act, those items that would be expensive to change after the fact, once a building was constructed, are included in the design requirements of the Fair Housing Design Manual. For example, adding maneuvering room for a wheelchair into an existing apartment would be an expensive process. Adding a grab bar in a bathroom is a much less expensive endeavor. Especially if there is blocking installed in the wall, provided as a requirement of the FHAA.

Look at the requirements of the Fair Housing Amendments Act, and consider each in terms of what it would cost to provide in an existing apartment after construction:

• An accessible building entrance on an accessible route,
• Accessible public and common use spaces,
• Usable doors,
• Accessible route into and through the unit,
• Accessible switches, outlets, and thermostats,
• Reinforced walls for grab bars, and
• Larger kitchens and baths with maneuvering room for a wheelchair within the space and at each fixture or appliance.

In each case, making the change would require considerable “construction” within the unit after the fact, and could be impossible to change. For example, if a space isn’t wide enough to widen a door, how would you make it accessible? Providing sufficient square footage, sufficient room, and arranging spaces so that they can work for a wheelchair in the design phase is much less expensive than making those changes “after the fact”. Once concrete is poured, once the building is completed, making it accessible can be difficult and costly. Making the changes on paper in the design phase is much cheaper. The FHAA was designed to require those accessible features be that would be expensive to add later into the design “now”.

It doesn’t require all ground floor units or all units in an elevator building are accessible. It requires public and common use areas be accessible, and that ground floor units and all units in an elevator building have some adaptable features that would help make it accessible in future. It actually provides for “aging in place” – another concept that is becoming a part of American culture, like it or not. Apartments built after the implementation date of March 13, 1991 are designed so that people could move in, and as they age, adapt the unit to better serve their needs over the continuum of their lives.

Changing the height of an electrical outlet or switch after the fact is expensive. Locating the electrical outlet or wall switch at a different height on the wall costs roughly the same. Labor and material costs are almost identical. Granted, the cost of adding reinforcing for grab bars did add “cost” to apartments. But, the cost savings on the “other end” – when grab bars would be required – made the costs worthwhile. And, having that reinforcing for grab bars was a safety factor. Solidly installed grab bars are a great help to the disabled and elderly. If the grab bars were not solidly installed, they could do more harm than good.

Other items that would be required to “convert” a FHAA unit for full accessibility include removing a vanity to convert to a bathroom lavatory with knee space, or remodeling a kitchen to provide a greater level of accessibility. These items could be done relatively easily once the kitchen and bath have sufficient floor area.

All in all, HUD did a good job of compromise – providing sufficient accessibility in MFH to serve the needs of today’s and tomorrow’s disabled and elderly population, without going too far. In hindsight, the costs were not extravagant, nor the design requirements difficult to achieve. Unfortunately, even today they have not been universally adopted. There are still new construction Multi-Family Housing properties opening their doors that do not fully comply with the design requirements of the Fair Housing Amendments Act.