A holding pattern is an aviation term, a technical term for a state of controlled stasis. It’s the name for what a plane does – turn in circles above its’ arrival airport – when it’s not yet able to land. The flight equivalent of waiting on the phone to be transferred to a different customer service department.
It’s a similar situation the construction industry finds itself in currently. Its very own state of controlled stasis.
Gateway application processes currently go a little something like this:
A design is submitted.
You wait.
For a while. And then a while longer.
And a bit further still.
The lucky few will get a few questions back. Many stagnate in silence.
Let’s make our stance on this abundantly clear: the Building Safety Regulator is not a bad thing. We are entirely supportive of the building safety regime.
But it has, through a potent mixture of being under-resourced and practising communicative opacity, become a sort of institutional shrug. For construction, an industry quite literally built on careful timing, specific sequencing, and collective choreography of a thousand simultaneous decisions, a shrug is a frustrating challenge.
Earlier this week, a successful Freedom of Information request from the Regulator (a rare thing indeed) provided, for the first time, hard figures for Gateway 2 applications. It gives us a chance to examine what it might all be costing us. Not just financially, but in drift, disruption, and systemic paralysis.
The cost of application
Let’s start with what we now know, in the present moment. As of latest figures, Gateway 2 applications to the BSR come with a now known cost, ranging from £6,500 to over £30,000 depending on the complexity, location, and supporting documentation of a building.
This is just the Regulator’s charge. When you factor in the professional time spent preparing safety case reports, collating performance evidence, coordinating consultants, revising designs, and searching statutes, the total cost can rack up quite quickly, before a single footing has been dug.
It’s the first time the Regulator has put a number on the gate. This is important because it’s a little of what the industry has been asking for: transparency.
Of course, the building safety crisis that triggered the formation of the BSR demanded action, and quickly, too.
Action, and accountability. We need and value those things. We are a noble, age old industry, with cultural foundations built on those very two principles.
But the pace (and, honestly, pain) of implementation so far has felt a little like peering through a thick fog without particularly clear direction on what it actually is you might be looking for.
Direction is needed. The Regulator must hand the industry a torch.
Signals from spec to site
If we are to take an economist’s view on this, we can see the impact of delays playing out numerically, in several ways. Sooner or later, these little waves will start to rock some of our own boats. Construction is such a tight web of interaction - when there’s a little squeeze, we all feel the pinch.
There are whispers of developers steering well clear of student accommodation, and high-rise residential projects: but is there any, currently visible, truth to it?
The proof is in the pudding, and the pudding says: quite possibly, yes.
Steel demand - a key proxy for tall construction - has dropped sharply, with construction consumption* and mill deliveries* down (nearly a million tonnes) since 2023. Starts* have stalled too, falling 32% in London and 5.3% in the North West – both high-rise hubs.
Planning approvals* are still coming through, but the gap between approval and actual build has stretched from 30 to over 40 weeks. Meanwhile, contractors are absorbing more risk, with tender prices* lagging behind build cost inflation*, with project delays cited as a key driver of rising cost. Margins squeezed, caution breeding.
It’s a clear picture. Projects are being quietly delayed, at scale, following the same pattern of delays across the board. And with over 800 schemes stalled in the Gateway process - those rumours may be well-founded.
A shockwave travels through the chain
The ripple effect of Gateway delays is felt across the entire construction value chain.
Architects are seeing frozen designs. Repeated revisions. Increasing pressure to become experts in areas that sit outside traditional design skill sets. Expectations are that design professional are able to speak the language of the Regulator, without a handbook.
Anecdotal evidence from practices working on high-rise schemes suggests that a large chunk of their design hours are now consumed by navigating BSR processes. Main contractors are watching mobilisation costs rise.
Faith is dwindling: if delays persist, some may begin to depart from HRB work, fearing sunk costs on paused or pulled projects.
Manufacturers are also feeling it. Those who can’t provide robust evidence of the performance of their system portfolio are being specified out. The pressure is on for the manufacturing sector: we must be agile and adapt, or sink under the weight of red tape.
Distribution channels, too, face erratic ordering patterns, and installers get caught in the whiplash. When the industry faces uncertainty like this, over a sector that’s home to a considerable proportion of our work, everyone gets bruised. This is not a trickle down problem, but a cross sector haemorrhage.
Why HRBs matter
Some make the argument that the industry could deter entirely from those build types that fall within the confines of ‘high risk’.
But high rises in particular have a key role to play in many of construction’s long term goals: they’re compact answers to complex questions. How to house more people, on less land, how to shape skylines, how to signal architectural ambition.
But the mighty high rise is also now procedurally high risk. In a market that has held strong against the storms of supply shocks, shutdowns, energy crises, and a stubborn labour shortage, our focus needs to be on how we can look to ease complications.
A future where high-risk buildings are deemed too much hassle to bother is one that’s lower (for one), broader, blander. It’s a built environment that’s less efficient, less ambitious, and less fit for the complex demands of urban life.
Both fight and flight
As, fundamentally, commercially motivated operations, cost is important to keep an eye on. But there’s an unseen cost, a silent impact.
It’s in the erosion of momentum. Talented architects could be sidelined. Risk-averse clients already are pulling out. Knowledge is wasted in limbo. There is a sense that good work is being quietly undone in the name of bureaucracy, rather than of quality and safety.
We are at risk of making the design and construction of fundamentally safe buildings feel like a punishment. That’s a cultural failure. And, for an industry grappling with a skills crisis, not exactly one we can afford.
The bits we can actually do something about
We cannot, at this present moment, make the BSR go faster. What we can do is keep pushing for clarity, and dialogue. What we can control is the response we make.
Specifiers, demand more from manufacturers. Not just proof of performance, but proof of understanding. Classification reports, not just fire tests. All the tools to ensure applications provide absolute clarity, rather than create clutter. Those with the power of selection wear the ring of power: wield it to apply pressure and force the entire industry to adopt a higher standard.
And manufacturers must step up. Listen to the voice of the market. Develop systems that meet not just the requirements of today, but of tomorrow. Provide information not just in the way we always have, because that’s how we’ve always done it, but take the action and lead the way. To a future of standardised, concise, reliable system and performance evidence.
We must back it, too. If we are to truly embrace the culture of change, of responsibility, of safety, if we are truly confident in the performance of our systems, and the competence of our people, then we should enter our own name into the ring.
That means owning design responsibility. Talking more. Sharing more. Working early. Working together.
The industry, we firmly believe, is totally supportive of the Building Safety Regime and all it stands for. Its founding principles aren’t up for debate. The process is. This is not resistance, but frustration. The BSR was born from failure, but it must not become a failure of its own.
We believe in safer buildings. In accountability.
In better.
*Data collected from ONS, UK Steel, BCSA, Costmodelling, and the Department for Business and Trade
