Exploring Gateway 2 at the London Build Expo

This article is based on our panel discussion at London Build in 2024 titled, “Navigating Gateway 2 Submissions – Experiences, Challenges, and Insights.”

The 50-minute session brought together industry professionals to share their knowledge and experiences from Willmott Dixon’s first complete gateway submission for their project, The Stage.

The panellists included:

• Craig Wells, Sales Director – Quelfire
• Graeme Whitty, National Product Director – Willmott Dixon Construction
• James Felstead, Director – Child Graddon Lewis
• Jeremy Ockenden, Technical Director – Affinity Fire Engineering
• Tom Hughes, Principal Building Safety Consultant – Safer Sphere

The Stage is a classic high-risk building; it has three large residential blocks and is 10 stories in height, creating 292 homes in total.

After an extension to the 12-week statutory period for Gateway approval, Willmott Dixon is now in conversation with the relevant parties to meet any requests and queries, hopeful for a positive result.

Background on the Building Safety Act and the Gateways

The Building Safety Act (BSA) came into force back in April 2022. It set the foundation for building safety in the construction sector, amending the Building Safety Act 1984. Establishing the concept of high-risk buildings (HRBs), it created a new system of Gateways to control the planning, design, construction, and maintenance of these buildings.

Also placing new responsibilities on the accountable person, dutyholders, client, and the principal contractor and designer. Most importantly, it requires those working on construction projects to demonstrate that they are competent to do so.

When explaining Gateway 2, Graeme Whitty said it’s the fundamental difference between a set of planning drawings and some ‘pretty’ elevations with text. It is a highly in-depth design that is costly and time-consuming. Ultimately, the Gateway regime controls the flow and progress of high-risk buildings.

Demonstrating competency

Competency is made up of four components: skills, knowledge, experience, and behaviours. Craig Wells commented that the behaviour aspect is often challenging to measure, but it’s one of the most important things.

An individual can have the skills, knowledge, and experience, but without the willingness to do the right thing, it all amounts to nothing.

Adding to this, Tom Hughes said that competency allows design practices to interrogate their internal processes and procedures. This ensures they are able to de-risk and hit compliance targets even before thinking about speaking to building control.

Because competency has been a grey area, the idea of demonstrating it has led many to question why. James Felstead highlighted that its purpose becomes clear once you get past the emotional reaction.

He advised the audience to get ahead of the curve. If you’re likely to work on a HRB that will go through the Gateway regime, start reviewing the competency point now. Much of the process involves demonstrating and documenting processes you may already be doing.

What has the Building Safety Act changed?

While the BSA has introduced regimes such as the Gateways, it has also been the catalyst for cultural change, especially regarding attitudes towards fire safety: ‘design, then build’.

Jeremy Ockenden stated that the current attitude of design teams is that they must collaborate and demonstrate compliance with building regulations. He said, “We have to be absolutely rock solid; there’s no let’s test the waters, let’s see if we can get away with this.”

Furthermore, highlighting the increase of investment for customers up front, Whitty argued that they will have to choose contractors, consultants, and product suppliers earlier; “they can’t play the game, drive lowest cost, or best-value decision.” A successful submission relies on partnerships built on integrity and a commitment to getting it right the first time around.

What challenges are associated with a Gateway submission?

Like anything new, challenges are to be expected. One main challenge stressed by Whitty was the lack of guidance on how much information the regulator required. Willmott Dixon submitted over 900 documents for The Stage submission. Whitty added that they effectively ended up creating two separate submissions, which caused them some problems.

Submitting this level of information at Gateway 2 also includes the procurement of products. Hughes explained that this may cause issues later down the line if the chosen products are discontinued, causing uncertainty around the correct level of information.

Whitty added to this, explaining that the regulator must approve any slight change to the submission before implementation; therefore, circumstances like discontinued products could cause extra costs and delays.

The industry is still in a transitional phase. While this may be beneficial in years to come, it will take time to reach ultimate compliance, Felstead emphasised. He also added that clients are used to appointing contractors and consultants around fee structures and programmes.

There are projects that have undergone viability assessments based on these, and they’re all going to be different. He stated, “I think we’re in for two or three years of quite hard lessons that we’re all going to have to learn.”

And the benefits?

Although this will inevitably be a learning curve for the entire industry, embracing these new processes offers many benefits that will ultimately protect people and property.

Hughes highlighted that by adopting the ‘design then build’ model, projects will avoid potential risk due to having more information to work with at the tendering stage.

Additionally, Whitty is seeing an increase in collaboration. He said, “There has got to be a common drive and understanding that it cannot be done alone.” In order to achieve the correct solution for the project, consultation with the entire team is essential.

Regarding the collaboration of teams, Ockenden stated that before the BSA, there was a tendency to think, we’ll sort out the management at the point of occupation. But now, this is being brought earlier into the process because the regulator wants full consideration.

This means that collaboration is now not just between the design team, but it involves the client and the person operating the building.

To conclude, Felstead added that the BSA is trying to shift how the whole system works. He said, “I’m hopeful that that will give the whole industry the right platform to actually deliver much safer buildings and work in a much more positive way.”

The Stage – key learning outcomes

To round up the discussion, Wells invited the panellists to share their learning experiences from Gateway 2:

• Evidence is crucial; you need to show all your workings out – Wells
• Submissions take time; be clear on your decisions and how you’re going to move forward as a team – Whitty
• It’s essential to give as much thought to Gateway 3 as you do to Gateway 2; it’s all interconnected – Hughes
• Communication and the style and language of how you present information is key. The burden of demonstrating compliance very much falls back on the team, so you’ve got to be specific – Felstead
• Information needs to be consistent, not just in what you’re producing but also across fire safety information – Ockenden

Though the industry has made some positive progress, there is still a long way to go, especially in navigating Gateway 2 successfully. It’s crucial to remember you’re designing and building homes, which highlights the need for more education.

But, ultimately, it comes down to collaboration and building transparent relationships.

Working together to design and then build.