The Department for Levelling Up, Housing and Communities’ (DLUHC) consultation to make it mandatory for all new residential buildings over 30m (approximately 10 storeys) to have a second staircase is drawing close to its conclusion.
This strategy is in response to suggestions that more people may have escaped the Grenfell tragedy if there had been a secondary exit route, although it was not one of the recommendations made in the Hackitt Review’s Building Safer Futures report.
The paper indicated that there would only be a short transition period and urged “all developments to prepare for this change now” and the lack of clarity over detail and timing of this statement has thrown the sector into some confusion as how best to move forward and at what cost?
Meanwhile, the Greater London Authority have announced, with immediate effect, that all residential buildings over 30m within London would require a second staircase before any Stage 2 referral, although the statement noted that buildings with only one staircase that had been approved before 23 December 2022 would still be eligible for GLA affordable housing grants.
Whilst this clarity from the GLA has been welcomed by many, there is still much debate over the height at which a second staircase is required. Whilst the government and the GLA are suggesting 30m, the National Fire Chiefs Council [NFCC] believes that a second staircase is required from 18m due to the advantages it brings for fire crews tackling fires and dealing with evacuations.
The NFCC are proposing to widen the scope of the proposed regime of ‘high risk’ residential buildings from 30m down to 18m based upon their own advice, data and evidence that, despite the prevalence of stay put policies in building design, many residents make a choice to evacuate. The NFCC shared that Incident Recording System data on mass evacuations shows that from 1 April 2019 to 31 March 2022, the London Fire Brigade reported 154 cases where 10 or more people evacuated from a block of flats of at least six storeys. This means nearly 8,500 residents chose to evacuate buildings rather than stay put, either before, during, or after the fire and rescue service arrived.
Schemes which had previously been granted outline planning permission will now have to go back to the drawing board with plans reconfigured to accommodate the second stair and restart the planning process.
This will have an obvious implication on a project’s timescale and potentially lead to delays in work starting on site, with developers attracting extra design costs to deal with the changes.
As well as the expense of additional design fees, there are also considerable cost implications for the development itself. Developers are essentially left with two options for reconfiguring their schemes:
- lose available living area to accommodate the second staircase, or
- increase the building’s footprint to maintain the number of apartments/bedrooms available for rent or sale.
Working within existing envelopes to accommodate a second stair has a negative effect on the saleable area. On schemes that we are currently working on, we are seeing the loss of at least one bedroom or an entire flat per floor to accommodate the extra circulation space and core. For developers in London, in real terms this amounts to an approximate loss of 200 sq ft. per storey. For a ten-storey building, this equates to a sales loss in excess of £2 million at £1,000/sq ft.
Clearly this will have a fundamental impact on scheme viability and we believe that developers are likely to look to change the mix of affordable housing first, to accommodate the extra stair and mitigate the loss to the overall gross development of the project. In this scenario, even if developers can incorporate a second staircase and mitigate the impact on scheme viability, Planning Approval is still required to deal with the changes in mix, so there will be a real time delay to these projects. We are estimating these delays at 6 to 12 months, which will undoubtedly come at further costs to the developer.
As an alternative to incorporating the extra staircase, developers are looking to add the staircase to a building, increasing the building’s size. Using the same example as above the same extra 200 sq ft. per storey, over a ten-storey building, equates to an overall increase in build cost starting from £250,000 for a simple staircase alone.
Clearly this seems to have a lesser effect on the overall scheme viability as the sales area remains the same, and this might be a preferred route for many developers who see changing the form and size of the building a better solution than changing the mix. However, it is worth noting that, in this scenario, Planning Approval may be more difficult to achieve due to the change in form and mass of the building. Real time delays to projects adopting this strategy is more likely to be in the region of 12-18 months, again resulting in further costs to the developer.
It is estimated that these measures will cost the construction industry £1.6bn over the next decade and in the short and medium term will negatively affect the supply of affordable housing, to mitigate this risk which provides another challenge to dealing with the housing crisis. We look forward to reviewing the results of the DLUHC consultation and hope that this will provide the clarity and timescales to move forward. However, we are cautious that even now at this late stage, the debate over a 18m or 30m minimum height is a key factor that continues to create confusion and conflict in this debate over building safety.