Please use this template to draft your response and email your response to SeneddHousing@senedd.wales

Ymateb gan: James Drew BSc (Hons) PgDipCHE MRICS, Syrëwr Adeiladu Senior – Ymddiriedolaeth Genedlaethol Cymru | Evidence from: James Drew BSc(Hons) PgDipCHE MRICS, Senior Building Surveyor – National Trust Cymru

Y Pwyllgor Llywodraeth Leol a Thai | Local Government and Housing Committee

Bil Diogelwch Adeiladau (Cymru) | Building Safety (Wales) Bill

1. What are your views on the general principles of the Bill, and whether there is a need for legislation to deliver the stated policy intention?

1.              We support the general principles of the Bill and the need for legislation to deliver the stated policy intention.

2. What are your views on the provisions set out in Part 1 of the Bill – Safety of buildings containing two or more residential units (sections 1 -66 and Schedule 1)? In particular, are the provisions workable and will they deliver the stated policy intention?

2.            We believe that broadly the provisions are workable and will deliver the stated policy intention but with possible unintended consequences.  See answer to Question 8.   

3. What are your views on the provisions set out in Part 2 of the Bill – Fire safety in certain houses in multiple occupation (sections 67 – 80)? In particular, are the provisions workable and will they deliver the stated policy intention?

3.            We believe that broadly the provisions are workable and will deliver the stated policy intention but that there is a need for additional guidance to be developed to support this.

4. What are your views on the provisions set out in Part 3 of the Bill – Enforcement and investigatory powers (sections 81 – 97 and Schedule 2)? In particular, are the provisions workable and will they deliver the stated policy intention?

4.            We believe that broadly the provisions are workable and will deliver the stated policy intention but that there is a need for additional guidance to be developed to support this and we concerned that the stated 48-hour window may be too slow for afford the fire service the tools to immediately reduce risk and by default this may introduce an unintended risk to people. We believe the fire service should have special powers to immediately act where the risk is great.   

5. What are your views on the provisions set out in Part 4 of the Bill – Supplementary and general (sections 98 – 114 and Schedules 3-4)? In particular, are the provisions workable and will they deliver the stated policy intention?

5.            -

6. What are the potential barriers to the implementation of the Bill’s provisions and how does the Bill take account of them?

6.            -

7. How appropriate are the powers in the Bill for Welsh Ministers to make subordinate legislation, as set out in Chapter 5 of Part 1 of the Explanatory Memorandum)?

7.             -

8. Are there any unintended consequences likely to arise from the Bill?

8.            The terminology being used may lead to unintended consequences.  We would welcome consideration to splitting the definition of block of flats from the definition of assessment of risk, so two residential units does not automatically result in a high risk when one non-residential part of the building exceeds 18m.

 

9. What are your views on the Welsh Government’s assessment of the financial implications of the Bill, as set out in Part 2 of the Explanatory Memorandum?

9.            -

10. Are there any other issues you would like to raise about the Bill and the Explanatory Memorandum or any related matters?

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