Gateway 2 approvals process Is Improving. Should we focus on Gateway 3 Next?

DMWR welcomes the significant improvement in Building Safety Regulator Gateway 2 performance. An overall approval rate of 84%, rising to 92% for new higher-risk buildings and 89% for remediation projects, represents considerable progress compared with the position a year ago.

Our own experience reflects both the progress being made and the continuing pressures within the system. DMWR has submitted 29 Gateway 2 applications to date, of which nine have now received approval, with the remaining applications progressing through the regulatory process. This gives us direct experience across a substantial portfolio of live Gateway 2 submissions and an increasingly clear understanding of what is required to navigate the process successfully.

The improving national approval figures must, however, be considered alongside the rapidly increasing BSR workload. There are now 1,654 live Gateway 2 applications, with more than 100 additional applications added during August alone. Internal refurbishment presents a particular challenge, with 457 applications received during the latest 12-week period against only 143 decisions.

With the Building Safety Levy commencing on 1 October, BSR is also anticipating further growth in applications. While BSR has increased its technical resources, there remains a significant pipeline of applications to determine.

Therefore, clients should not interpret improving approval rates as meaning that Gateway 2 programme risk has disappeared. New-build applications are still taking a median 22 weeks to determine, with complex applications taking significantly longer.

DMWR’s experience across our 29 submissions reinforces the importance of early Gateway planning and submission readiness. Building Regulations compliance cannot be addressed immediately before submission. It needs to be embedded within the design process, supported by coordinated information from the architect, Principal Designer, fire engineer, structural engineer, MEP designers, contractor and specialist supply chain.

For clients, this means Gateway 2 needs to be treated as a fundamental project milestone from the outset. Programmes should incorporate realistic periods for design development, compliance reviews, preparation of the submission, BSR determination and responses to regulatory queries.

The improvement in remediation approvals is particularly encouraging for DMWR given our involvement in façade and fire remediation projects. However, the growing volume of refurbishment applications demonstrates why complete, coordinated and technically robust submissions remain essential.

Attention must now also turn to Gateway 3 and the construction period. BSR inspections are already identifying instances where construction has departed from Gateway 2 approved designs and remedial work has been required.

Gateway 2 approval therefore cannot be regarded as the end of the compliance process.

For architects, Principal Designers and contractors, robust change control during construction will become increasingly important. Changes to approved information need to be properly assessed, recorded and, where required, progressed through the appropriate BSR change-control procedure while maintaining the Golden Thread.

The overall direction is positive: BSR capacity is increasing and approval performance is improving. But increasing application volumes mean programme certainty remains a significant challenge.

DMWR’s experience from 29 Gateway 2 submissions demonstrates that successful navigation of the new regime depends upon early planning, coordinated technical information and active management of Building Regulations compliance throughout design and construction.

The regulatory system is becoming more efficient, but it is not becoming less rigorous. The next challenge for the industry is not simply achieving Gateway 2 approval, but maintaining the approved compliance strategy through construction and successfully through Gateway 3.

Building safety Gateway 2 applications soar as levy looms | Construction Enquirer News