23 - 02 - 2023

BPTW Participants: Neill Campbell, Partner – Architecture, Jill McGregor, Planning Director, Onur Osman, Senior Associate – Architecture

The information below has been superseded by a recent government statement. Please refer to BPTW’s latest insight article on second staircases in buildings over 18 metres or seven storeys available here.

The Department for Levelling Up, Housing and Communities is currently consulting on proposals to amend Approved Document B which covers building regulation in England on fire safety matters within and around buildings. Alongside other key proposed changes, it is likely to be mandating that residential buildings (and some other typologies) with a height of 30m and over will need at least two staircases.

In partnership with The Housing Forum, on the 22nd February, BPTW curated a Spotlight Session, drawing together a panel of industry practitioners including housing providers, regulatory bodies, consultants and others working across the sector to share their views and specific responses to the proposed changes. The panel discussed the impact of these changes on their work across a range of considerations from fire safety to viability, design quality, cost and design and delivery programmes. The session sought to understand a range of different perspectives on the impact of the proposed amendments, particularly in relation to the addition of second staircases in buildings over 30m.

Speakers and Contributors
• Neill Campbell, Architectural Partner, BPTW (Session Chair)
• Shelagh Grant, Chief Executive, The Housing Forum

Panel Discussion 1: The Regulatory Context
• Allison Flight, Deputy Head of Development Management, Planning, GLA
• Jeremy Ockenden, Technical Director, Affinity Fire Engineering
• Jill McGregor, Planning Director, BPTW
• Roger Arnold, Managing Director, Martin Arnold

Panel Discussion 2: The Impact on the sector and how we are responding.
• Michele Haniotis, Design & Technical Manager, Network Homes
• David Stronge, Design Director, Peabody
• Marc Bradfield, Head of Design, Bouygues
• Onur Osman, Architectural Associate, BPTW
• Kaye Stout, Partner, Pollard Thomas Edwards


Panel Discussion 1: The Regulatory Context – Summary

Chaired by BPTW’s Neill Campbell, the first panel discussion focused on scene setting and the regulatory context, and included commentary from Allison Flight, Deputy Head of Development Management at the Greater London Authority who confirmed the GLA’s position, announced on the 14th February, that with immediate effect, all planning applications for residential buildings over 30 metres must include at least two staircases in order to be considered by the Mayor of London for final (Stage 2) approval. She noted how this is currently being dealt with on schemes, and also confirmed the GLA’s position on projects which had already secured GLA planning and funding.

Jeremy Ockenden from Affinity Fire Engineering gave an insightful summary of the broader regulatory context and government’s position and timescales for implementation, with specific detail and guidance on the key elements of the proposals affecting residential development. Jill McGregor, Planning Director at BPTW, focused on the impact on the determination of planning applications, identifying how developers are amending/ can amend schemes in response to the changes.

The discussion then concluded with Roger Arnold, Managing Director of multi- disciplinary consultants Martin Arnold, giving a view across the lifecycle of a project, commencing with a quantifiable summary of the impact of the second staircase requirement on the viability of schemes, and finishing with a commentary on the need for a robust safety case for the second staircase, and the need for other fire safety measures to be given more prominence. The panel then welcomed questions from attendees.


Panel Discussion 2: The Impact on the sector and how we are responding – Summary

The second panel discussion commenced with Michele Haniotis, Design & Technical Manager at Network Homes, and David Stronge, Design Director at Peabody setting out the impact on their respective G15 housing associations. Both highlighted the impact on schemes currently in the design and planning process as well as future schemes. Key concerns raised in this discussion included concerns over uncertainty regarding Building Control signoff, and the impact on scheme viability affecting Housing Associations’ ability to deliver affordable housing. Both emphasised a call for clarity around the ‘purpose’ and safety case for a second staircase or core, and clear guidance on how it should be implemented in practice, for example by offering clarity on separation distances.

Marc Bradfield, Head of Design at Bouygues, highlighted the impact on projects from a contractors perspective, highlighting a noticeable drop-off in projects being tendered, with many being paused for review. He also championed the need for a holistic view of fire-safety within the industry. Calls for clarity on how the second staircase should be implemented were also highlighted by Architects Onur Osman, a Senior Associate at BPTW, and Kaye Stout, Partner at Pollard Thomas Edwards who summarised the impact on projects at different stages of the design process. They commented on the differing approaches from clients as well as the design quality conflicts and challenges of implementing a second staircase or core. Particular comments on the impact on dual aspect homes, unit sizes, and the pressures on the organisation of the ground floor were all highlighted.

The panel discussion then concluded with further questions from the attendees and a summary from each panellist on key areas which they would like to see emphasised in the response to the government’s consultation. An overarching theme of the responses was ‘Clarity’, specifically with regard to a roadmap and timeline for implementation, a clear safety case and purpose for the second stair (or core), and guidelines for how it should be implemented in practice.

The Government’s consultation on proposals to amend Approved Document B ends on 17 March 2023 and can be viewed here.

BPTW is an active participant of The Housing Forum and its Partners and Directors have contributed to many talks and events to raise the quality of housing in England. You can read more about their contributions to The Housing Forum, such as BPTW’s work for The Housing Forum’s Councils Network, on our Insights page.

Neill Campbell is an Architectural Partner at BPTW. A specialist in residential design and consultation, he has overseen the design and delivery of numerous successful new build residential-led schemes. Neill regularly shares his expertise by leading workshops for thought leadership organisations including The Housing Forum and Future of London, covering pertinent issues within the architecture and housing industry from design management and building safety to sustainability.

Jill McGregor brings 18 years of planning experience extensive knowledge of residential and commercial development in London and the South East. She has worked with a varied client base and her extensive and varied project experience ranges from large-scale estate regeneration and infill projects to permissions for the refurbishment, alteration, and extension of listed buildings and commercial projects.

Onur Osman is a Senior Associate at BPTW and is well versed in the day-to-day management and delivery of architectural services across all project stages from planning to technical delivery. He possesses a solid awareness of technical detailing and construction practice in both traditional and specialist construction technologies. Onur is a member of BPTW’s Building Safety Group and has overseen the technical delivery for numerous mixed-use schemes. He is also a Certified Passive House Designer.