3. Part 2 - High Risk Buildings (HRBs)
Part 2 of the consultation paper outlines the proposed introduction of the High Risk Buildings (HRB) fee structure. High risk buildings are defined as domestic or residential buildings with any storey at a height of more than 11 metres above the ground, education establishments, hospitals and residential care buildings. Research suggested that the current building warrant fee structure should be revised to allow an enhanced fee for high risk buildings to cover the additional costs of ensuring compliance.
Q2.1 Do you support the introduction of an enhanced fee for High Risk Building warrant applications?
|% Strongly support
|% Do not support
|% Strongly do not support
|% No answer
|All respondents (n=)
|All respondents (%)
|Designer / Consultant
|Contractor / Developer
|Membership body / association
Four fifths of respondents (81%) supported the introduction of an enhanced fee for High Risk Building warrant applications; 44% strongly supported and a further 37% supported the proposal. Among organisations, 91% were in favour, with 48% strongly supporting the proposal. While a majority of all organisation types were in favour, the strength of support varied from 75% of membership organisations and 71% of local authorities strongly supporting the proposal, compared to 32% of designers/consultants and only 6% of contractors/developers.
Complex applications should have a higher fee
Around two thirds of respondents commented in Q2.1. The most common theme, mentioned by many, was support for an enhanced fee for high risk buildings as their applications are more complex. Respondents acknowledged that high risk buildings also required additional inspections and enhanced service.
“HRB applications require significant resources and expertise, in addition external third party consultants may be required. These additional costs incurred with HRB applications should be reflected in the application fee paid.” – Local Authority
Support for better oversight
Several respondents, both individuals and organisations, supported the proposal because they felt it would ensure better oversight and an enhanced verification system for high risk buildings. A few specifically highlighted Grenfell, noting that changes must be made to ensure a similar tragedy is not repeated.
“There must be oversight to ensure the Grenfell type disasters cannot happen again. This should involve a 'hands on' approach by planning and building control officers and should not just become a rubber stamp situation for builders to progress without adequate checks and safeguards. This is where an expert led approach to decide on suitable, safe alternatives that can be used should be adopted. All council officers must ensure that the correct materials are used and not just accept the word of the builders. This would entail multiple site visits and councils must ensure they have sufficient trained staff to complete all necessary checks.” - Individual
Ensuring the increased fees are allocated to the appropriate local authority building standards staff was mentioned by some. These respondents were mostly contractors/developers or membership bodies. A few others suggested they would support the proposed changes if the quality of service they received from verifiers improved.
“Yes as long as the additional fee is used solely to support the high risk specific building assessment.” – Organisation
Current fee structure should be sufficient
Some respondents disagreed with the proposal. Two respondents disagreed without providing more detail; however, some others disagreed as they argued that high risk buildings often already incur higher fees under the existing fee structure because they are typically larger and more expensive buildings.
“I can see that this would take more time to assess but the fee is larger. There are plenty of easy warrants for every difficult one” – Organisation
“High risk buildings are still buildings with standards to follow. Enhanced fees are an excuse, the fee based on cost should be sufficient to cover the application.” - Individual
Less commonly mentioned themes
The following points were each raised by one respondent:
- An organisation noted that an enhanced fee may be unnecessary if the Compliance Plan Approach is required for high risk domestic buildings. This would require companies to use an Independent Compliance Plan Manager for regular inspections, reducing the burden on local authority verifiers.
- A local authority noted their support with “the caveat that any third party checking for fire engineering should be borne by the applicant”.
- The inclusion of additional calculation checking fees for projects that do not include a Certificate of Design for Section 1 and 5 was requested by one organisation.
- A concern about the impact the proposal on the level of insurance cover required by architects was raised by one individual.
- Another individual requested regular inspections, every four years, to ensure there have been no compromises to the high risk building fabrication after receiving the warrant.
- Rather than higher fees for high risk buildings, one individual suggested there should be consideration for higher fees in environmentally sensitive areas, although they did not provide any further detail.
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