Evacuation provision for wheelchair users at planning stage

Evacuation provision for wheelchair users planning decisions turn on is settled at outline and early detailed design, not at building control. An evacuation lift needs a shaft, a protected lobby and a power supply route. A refuge needs floor area inside a protected stair enclosure. Both eat into the core, and once the core dimension is fixed by an approved drawing, adding them later means either losing a flat or going back for a section 73 application. So the question belongs in the pre-application discussion.

For relevant buildings, the point is also formally in front of the planning authority. Article 9A of the Town and Country Planning (Development Management Procedure) (England) Order 2015 requires a fire statement with the application, and the Health and Safety Executive is a statutory consultee at that stage under the Planning Gateway One arrangements introduced by the Building Safety Act 2022 framework.

Why the issue reaches the planning stage at all

Three things drag it forward from the technical design phase.

First, the core is the least flexible part of a residential building. Stair width, lobby depth, riser positions and lift shaft dimensions are load bearing decisions in every sense, and they are drawn at planning.

Second, accessible dwelling mix is a policy requirement in many areas, and a policy that delivers wheelchair user dwellings on upper floors implies a means of getting those residents out. The London Plan requires a proportion of new dwellings to meet Building Regulations requirement M4(3) with the balance at M4(2), and boroughs apply the policy by unit and by tenure. Providing M4(3) units at level six with no evacuation lift is an internal contradiction the case officer can reasonably ask about.

Third, the second staircase change for taller new residential buildings has reopened core design generally. Where a scheme is being re-planned for a second stair, that is the moment to resolve evacuation lift provision rather than after.

Evacuation lifts and their spatial demand

An evacuation lift is a passenger lift specified and protected so it can be used under fire service control or, in some designs, by residents under a managed procedure. What it needs is more than the lift car.

1. A shaft with the required fire resistance, usually within or adjacent to the protected core.
2. A protected lobby at each level served, sized to hold waiting wheelchair users clear of the escape route.
3. A secondary power supply with cabling routed so a fire in one compartment does not take out both supplies.
4. Communication equipment at each landing and a point of control, normally at the fire service access level.
5. Machine space and overrun, which affects roof height and therefore the elevation.

The plan area consequence is the part design teams underestimate. A lobby that satisfies both the stair and the evacuation lift is deeper than a standard lift lobby, and on a small urban plot that depth comes out of the flats. On a single core scheme of eight or nine dwellings per floor, it can be the difference between a viable layout and one that loses a unit per storey.

The specification itself is a fire engineering matter. BS 9991 deals with fire safety in residential buildings and covers evacuation lift and refuge provision, and which recommendations apply depends on building height, occupancy and the design approach taken. PlanScope's Fire Safety Strategy report is a starting point for that work rather than a substitute: a BS 9991 or BS 9999 strategy is a fire engineering document and a professional with the necessary fire engineering competence is legally required to prepare it.

Refuge provision within the core

A refuge is a relatively safe waiting place, accessible from a storey exit, where someone who cannot use the stairs can wait for assisted evacuation. Approved Document B sets out the arrangement, including the wheelchair space that must be kept clear of the escape route and the communication provision that goes with it.

Two practical failures show up at planning stage. The refuge is drawn inside the stair enclosure in a position where a wheelchair reduces the effective stair width below what the escape calculation assumed. Or the refuge is shown on a plan but the stair core is dimensioned as if it were not there, so the area appears twice.

There is also the question of how many refuges a building needs and where. That follows from the escape strategy, so it cannot be resolved by adding a symbol to each floor plan.

Accessible and adaptable dwelling standards

Requirement M4(2) covers accessible and adaptable dwellings and M4(3) covers wheelchair user dwellings, with M4(3)(2)(a) for adaptable and (b) for accessible units. The distinction matters to evacuation because an M4(3) unit is designed for someone who is a wheelchair user now or will be, which makes assisted evacuation a foreseeable requirement rather than a possibility.

Where the local plan sets a percentage, say in the application how many units of each standard you are providing, on which floors, and how residents of those units leave the building in a fire. Putting all the M4(3) units at ground and first floor is one answer and it is not always the right one, because it concentrates a tenure or dwelling type in the least desirable part of the building.

A Fire Statement is where that reasoning belongs for relevant buildings. For buildings below the threshold, it belongs in the design and access narrative, and the question of what evidence to provide just under the threshold is covered in our note on fire evidence for a building just below the threshold.

Management responsibilities after occupation

Planning cannot secure a management procedure, and pretending otherwise weakens a submission. What planning can do is make the physical provision possible and record it.

The management layer sits under the Regulatory Reform (Fire Safety) Order 2005 and the Fire Safety (England) Regulations 2022, which place duties on the responsible person for a residential building, including information for residents and, for higher-risk buildings, information for the fire and rescue service. Arrangements for residents who cannot self-evacuate have been the subject of government consultation and the requirements have been moving, so check the current position rather than relying on an older summary.

Write the application so that the building works under a managed procedure if one is required, and do not commit the applicant to a procedure they will not control after sale or handover.

Equality duty considerations for the decision

Section 149 of the Equality Act 2010 places the public sector equality duty on the local planning authority when it decides the application. It is a duty to have due regard, not a duty to reach a particular outcome, and it cannot be discharged by a single sentence in the committee report.

Where a scheme provides wheelchair user dwellings above the ground floor and the submitted drawings show no evacuation lift and no refuge arrangement, an objector has an obvious line of attack. Where the submission explains the provision, the alternatives considered and why the chosen approach works, the duty is straightforward to record.

Illustrative example: a nine storey block of 54 flats, single core, with six M4(3) units distributed from level one to level seven. The scheme provides an evacuation lift in the core and a refuge at each level within the stair lobby, and the design and access narrative sets out the distribution by floor and tenure. The layout loses about 4 m2 per floor to the deeper lobby. Figures here are illustrative.

What the submission should commit to

Keep the commitments physical and drawable.

Show the evacuation lift on the general arrangement plans with the shaft and lobby dimensioned. Annotate the refuge position and its clear wheelchair space at each level. Schedule the M4(2) and M4(3) units by floor, core and tenure. Say where the secondary power supply enters the building and by what route. State which standard the fire strategy follows and who prepared it.

Then let the fire engineer confirm the detail. A planning submission that overstates what has been engineered creates a discharge of conditions problem later.

Enter your postcode on PlanScope to see which reports a residential scheme at your site is likely to need. This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.