239. Views were also invited on the following documents that were published alongside the main consultation document:
- A Business and Regulatory Impact Assessment ( BRIA); and
- An Equalities Impact Assessment ( EQIA).
Q17: Do you have any comments on these impact assessments?
240. Twenty-one respondents, across all sub-groups with the exception of those involved in lettings / residential lettings and property management, opted to provide commentary on the impact assessments.
241. Some of these respondents simply noted their support for the consultation and measures that will improve fire safety in homes across Scotland.
242. Most of the comments made were in relation to the BRIA. Comments in relation to this, each made by very small numbers of respondents, included:
- The BRIA is fair and accurate.
- Concerns over the ability of social landlords to meet new requirements in the proposed timescales; together with a request for an estimate of the likely overall costs for larger landlords to comply with a new minimum standard rather than just estimating the cost of installing a single alarm.
- It would be reasonable to expect local authorities to conduct enforcement work without additional resources.
- Any measures adopted need to be proportionate and use risk-based assessments.
- A need to consider the requirements of a new minimum standard alongside other issues such as energy efficiency as there will be a cumulative financial impact for which households will have to plan.
- There is a need to undertake a cost benefit analysis of fire safety measures such as sprinkler systems.
- The costings need to be broken down more fully.
243. Other comments raised by respondents included:
- Any improvement would be in the right direction.
- Scepticism because assessments tend to single out the most unknowledgeable and vulnerable among the population.
- A need to include a briefing document for landlords.
- A need to increase fire service enforcement powers.
- A need to update Building Standards and SHQS in the light of a new minimum standard.
- The equalities assessment should note that many tenants live in fuel poverty and cannot afford basic fire safety provision, so there will be a need for Scottish Government interventions.
244. A very small number of respondents noted that they would be pleased to provide a response when the BRIA and EQIA are revisited. There was also a request to involve lead bodies in the private rented sector in any further discussion or consultation.
245. There were also suggestions from a very small number of respondents for additional impact assessments to be conducted; a Health Inequalities Impact Assessment ( HIIA) and an Environmental Impact Assessment ( EIA).
246. One respondent in the 'other' sub-group disagreed with the EQIA which suggested no negative impacts on any equality groups as, they said, there would be a financial impact for those in vulnerable groups experiencing poverty.
247. Finally in response to this question, there was a comment from a local authority for regular reviews of the impact assessments as the policy moves forward.
Q18: Do you have any other comments on this consultation?
248. Thirty-four respondents opted to provide commentary to this question, many of whom reiterated points made in earlier questions.
249. Some respondents noted their support for the consultation or welcomed the opportunity to provide their views on the consultation. A small number also noted their willingness to participate in any further discussion in this area.
250. A small number of respondents noted the need for this consultation to link into a wider approach in raising safety standards in general or linking into other policy areas such as health, with one local authority noting the need to consider other commitments such as energy efficiency required in the social rented sector. There were also a small number of calls for a wider consultation on fire safety standards to include issues such as escape routes in high rise tenements or flatted properties.
251. Themes reiterated by respondents included:
- The need for high standards across all housing sectors regardless of tenure.
- The need for fire risk assessments for all high rise domestic buildings or risk assessments to identify residents at a greater risk of fire (cited by residents associations / tenant participation or local authorities).
- The need for careful consideration of the timescales and expense of compliance (housing associations).
- The difficulties in enforcing the new minimum standard in the owner occupied sector.
- The need to consider financial incentives such as grants, loans or subsidies.
- The need for education / advertising campaigns to help raise awareness of issues in relation to fire safety.
- Requests for representation from professional fire engineers within on the Ministerial Working Group.
- Reference to work undertaken by Dundee University.