Evacuation alert systems: consultation response and impact assessment
Updated 1 June 2022
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Consultation response
Introduction
1. From 5 September 2019 to 28 November 2019 the government consulted on proposals for ‘Sprinklers and other fire safety measures in new high-rise blocks of flats’. Among other proposals, this consultation sought views on the inclusion of a recommendation in Approved Document B (ADB) for evacuation alert systems (EAS) and the potential height threshold for them should the provisions be introduced.
2. Subsequent to the launch of the government’s consultation, the Grenfell Inquiry Phase 1 report recommended EAS in high-rise residential buildings.
3. The Grenfell Tower Inquiry: Phase 1 Report (October 2019) Volume 4 page 777 Section IV Subsection 12 Para 33.22d: “That all high-rise residential buildings (both those already in existence and those built in the future) be equipped with facilities for use by the fire and rescue services enabling them to send an evacuation signal to the whole or a selected part of the building by means of sounders or similar devices.”
4. A British Standard (BS 8629) was also introduced, in October 2019, to provide a code of practice for the design, installation, commissioning and maintenance of EAS for use by fire and rescue services in buildings containing flats.
Consultation outcome
5. The government response to the consultation was published in May 2020.
6. As was noted in the government response, there was strong support expressed (92% in favour) in the consultation for the inclusion in ADB of guidance on EAS.
7. However, many respondents raised concerns about the use of this recent technology. These concerns included:
a. Whether an EAS would increase risks arising from its unsafe use.
b. Whether, in some instances, they could potentially allow smoke spread from flats into corridors and stairwells as multiple doors are opened.
c. Whether they increased the potential overcrowding on stairwells as a result of a simultaneous evacuation.
8. The National Fire Chiefs Council (NFCC) also expressed a concern that firefighters needed to be properly trained and suitable guidance available in the use of EAS.
9. The government committed to work with the NFCC to address the concerns that had been raised to ensure that EAS can be used safely and effectively, and that there are clear guidelines about their use available to fire and rescue services.
Progress since consultation
10. The NFCC has informed the government that it has completed work to produce guidance and a national training package for operational firefighters in using EAS.
11. With the launch of the new training package, the NFCC is now satisfied that suitable guidance and support is available for operational crews to ensure they can be trained on the purpose and safe use of EAS. The NFCC are therefore now supportive of the inclusion of EAS in an update to ADB.
12. DLUHC has also worked with the Home Office to commission live trials to inform the operational use of EAS, with a report of the research expected in later in 2022.
Updated outcome
13. In view of the NFCC’s progress and support for the systems; along with the commissioning of the necessary research by government, we are now able to make the proposed change to ADB to make provisions for EAS in new high-rise blocks of flats over 18 metres.
14. Amendments to ADB typically include a 6-month transition period before changes take effect. During this transition period we will review the outcomes of the government commissioned research as they arise and continue to engage with the NFCC to address any operational issues.
15. The options considered are set out in the impact assessment below.
Impact assessment
Summary: intervention and options
Cost of Preferred (or more likely) Option (in 2019 prices, 2020 present value, all other figures in 2021 prices, 2022 present value)
Total Net Present Social Value: -£178.1 million
Business Net Present Value: -£149.4 million
Net cost to business per year: £17.4 million
What is the problem under consideration? Why is government action or intervention necessary?
The Grenfell Tower Inquiry Phase 1 found that there were no plans in place for evacuation of the building should the need arise. The Inquiry subsequently recommended Evacuation Alert Systems (EAS) in both new and existing high-rise residential buildings. DLUHC is responsible for maintaining the Building Regulations 2010 and the associated statutory guidance in Approved Documents that set minimum standards for the design and construction of buildings. Government committed to review the advice in ADB after the Grenfell fire and accepted the Inquiry’s recommendation on EAS in principle. DLUHC worked with the National Fire Chiefs Council and the Home Office following consultation on a proposal for EAS in new high-rise residential buildings.
What are the policy objectives of the action or intervention and the intended effects?
The objectives are to improve fire safety in buildings and satisfy the Grenfell Tower Inquiry Phase 1 recommendation, by introducing a change to ADB to make provisions for an EAS in buildings over 18 metres in height . The intended effects are to ensure that firefighters have an optional means for alerting residents of the need to evacuate as part of a phased and controlled plan in the event of a serious fire and that the person in charge of the in-scope building has included the EAS in their emergency evacuation plan.
What policy options have been considered, including any alternatives to regulation?
This impact assessment considers 3 options:
Option 1 - Do nothing: no provision for EAS to be included in ADB.
Option 2 – Preferred: Make provisions for EAS in ADB for buildings with a storey more than 18 metres in height.
Option 3 - Make provisions for EAS in ADB for buildings with a storey more than 11 metres in height.
Option 1 (do nothing) is not preferred as this would not achieve government objectives to improve fire safety in buildings.
Option 2 is preferred as it is expected to provide the biggest benefit in terms of improving fire safety proportional to the risks associated with the buildings in question.
Summary: analysis & evidence - Policy Option 2; Preferred
Description: Make provisions for Evacuation Alert Systems in Approved Document B for buildings with a storey more than 18 metres in height
Full economic assessment
Price Base Year: 2021
PV Base Year: 2022
Time Period Years: 10
Net Benefit (Present Value (PV)) (£million)
Low: -£139.6m
High: -£259.3m
Best Estimate: -£199.5m
| Costs (£million) | Total Transition (Constant Price) | Total Transition: Years | Average Annual (excl. Transition) (Constant Price) | Total Cost (Present Value) | |
| Low | £0.2m | 0 | £16.2m | £139.6m | |
| High | £0.4m | 0 | £30.1m | £259.3m | |
| Best Estimate | £0.3m | 0 | £23.1m | £199.5m |
Description and scale of key monetised costs by ‘main affected groups’
The costs above are the installation, operating and maintenance costs associated with introducing an evacuation alert system in all new residential buildings and building conversions with a storey above 18 metres.
There are also general familiarisation costs outlined as transition costs associated with the changes in Approved Document B.
Other key non-monetised costs by ‘main affected groups’
There are no hypothesised non-monetised costs modelled in this impact assessment.
| Benefits (£million) | Total Transition (Constant Price) | Total Transition Years | Average Annual (excl. Transition) (Constant Price) | Total Benefit (Present Value) |
| Low | £0.0m | £0.0m | £0.0m | |
| High | £0.0m | £0.0m | £0.0m | |
| Best Estimate | £0.0m | £0.0m | £0.0m |
Description and scale of key monetised benefits by ‘main affected groups’
There are no benefits that have been monetised in this impact assessment.
Other key non-monetised benefits by ‘main affected groups’
The measures in this impact assessment may reassure residents in in buildings where they are installed and will provide Fire and Rescue Services with an additional tool which can be used where they deem it necessary in the event of a significant fire. None of these have been monetised.
Key assumptions/sensitivities/risks Discount rate (%) 3.5
The costs and benefits of the policy options have been estimated using several assumptions:
a. Forecast of stock and the rate of erection of 18 metres+ new buildings and building conversions into residential properties.
b. Proportion of 18 metres+ buildings currently installing a fire evacuation alert system.
c. The rate of which industry learns how to install these new systems.
d. Voluntary compliance during the transition period.
There may be a risk that residents do not follow the orders of Fire and Rescue Services during a managed evacuation.
Business assessment (Option 2; Preferred)
Direct impact on business (Equivalent Annual) £million:
Costs: | Benefits: | Net: £23.2m |£0.0m |-£23.2m
Summary: analysis & evidence - Policy Option 3
Description: Make provisions for Evacuation Alert Systems in Approved Document B for buildings with a storey more than 11 metres in height.
Full economic assessment
Price Base Year: 2021
PV Base Year: 2022
Time Period Years: 10
Net Benefit (Present Value (PV)) (£million)
Low: -£340.9m
High: -£633.0m
Best Estimate: -£487.0m
| Costs (£million) | Total Transition (Constant Price) | Total Transition: Years | Average Annual (excl. Transition) (Constant Price) | Total Cost (Present Value) | |
| Low | £0.6m | 0 | £39.5m | £340.9m | |
| High | £1.2m | 0 | £73.4m | £633.0m | |
| Best Estimate | £0.9m | £56.5m | £23.1m | £487.0m |
Description and scale of key monetised costs by ‘main affected groups’
The costs above are the installation, operating and maintenance costs associated with introducing an evacuation alert system in all new residential buildings and building conversions with a storey above 11 metres.
There are also general familiarisation costs outlined as transition costs associated with the changes in Approved Document B.
Other key non-monetised costs by ‘main affected groups’
There are no hypothesised non-monetised costs modelled in this impact assessment.
| Benefits (£million) | Total Transition (Constant Price) | Total Transition Years | Average Annual (excl. Transition) (Constant Price) | Total Benefit (Present Value) |
| Low | £0.0m | £0.0m | £0.0m | |
| High | £0.0m | £0.0m | £0.0m | |
| Best Estimate | £0.0m | £0.0m | £0.0m |
Description and scale of key monetised benefits by ‘main affected groups’
There are no benefits that have been monetised in this impact assessment.
Other key non-monetised benefits by ‘main affected groups’
The measures in this impact assessment may reassure residents in in buildings where they are installed and will provide Fire and Rescue Services with an additional tool which can be used where they deem it necessary in the event of a significant fire. None of these have been monetised.
Key assumptions/sensitivities/risks Discount rate (%) 3.5
The costs and benefits of the policy options have been estimated using several assumptions:
a. Forecast of stock and the rate of erection of 11m+ new buildings and building conversions into residential properties.
b. Proportion of 11m+ buildings currently installing a fire evacuation alert system.
c. The rate of which industry learn how to install these new systems.
d. Voluntary compliance during the transition period.
There may be a risk that residents do not follow the orders of Fire and Rescue Services during a managed evacuation.
Business assessment (Option 3)
Direct impact on business (Equivalent Annual) £million:
Costs: | Benefits: | Net: £56.6m |£0.0m |-£56.6m
Policy background
16. This impact assessment considers a proposed technical change to the guidance in ADB to make provisions for EAS in buildings with a storey more than 18m in height.
17. The Grenfell Tower Inquiry recommended in their Phase 1 report that all high-rise residential buildings should “…be equipped with facilities for use by the fire and rescue services enabling them to send an evacuation signal to the whole or selected part of the building by means of sounders or similar devices.”.
18. DLUHC launched a consultation on 5 September 2019 which proposed multiple changes to ADB. The consultation sought views on the provisions of EAS in ADB; and the benefits/risks of such a system as well as the potential height threshold.
19. The consultation, which closed on 28 November 2019, received 184 responses. The government response to the consultation was published in May 2020.
20. 92% of respondents to the consultation were in favour of EAS in residential buildings.
Rationale for intervention
21. DLUHC is responsible for maintaining the Building Regulations 2010 and the associated statutory guidance in Approved Documents that set minimum standards for the design and construction of buildings.
22. Recent high-rise fires, including the Grenfell Tower fire, resulted in calls for enhancement of fire safety provisions in high-rise buildings and the government is conducting a full-scale technical review of ADB. The Grenfell tragedy highlighted the potential benefits of better information on emergency evacuation routes within blocks of flats and providing Fire and Rescue Service incident commanders with an additional tool to foster phased evacuation through an alert system.
23. Prospective occupiers are unlikely to have access to sufficient information and expertise to assess the overall benefit of fire safety measures when deciding whether to move into a new building.
24. There is evidence that the construction industry has become more risk averse since the Grenfell Tower fire in 2017, in some cases resulting in enhanced fire safety measures in new buildings. However, there is a risk that over time this risk aversion will fade, and so the industry may revert to being less cautious. Hence a need for government intervention.
25. Although some property developers achieve a high level of fire safety, this is by no means the whole market. Market incentives are weak and government intervention is necessary to implement these improvements.
Policy objective
26. The objective is to improve fire safety in buildings, while satisfying the Grenfell Tower Inquiry Phase 1 recommendation, by introducing a change to ADB to make provisions for an EAS in buildings over 18 metres in height.
27. The intended effects are to ensure that firefighters have an additional means for alerting residents of the need to evacuate as part of a phased and controlled plan where they deem it necessary.
Options considered
28. This impact assessment considers 3 options:
a. Option 1 - Do nothing: no provision for EAS to be included in ADB.
b. Option 2 – Preferred: Make provisions for Evacuation Alert Systems in Approved Document B for buildings with a storey more than 18 metres in height.
c. Option 3 - Make provisions for Evacuation Alert Systems in Approved Document B for buildings with a storey more than 11 metres in height.
29. Option 1 (do nothing) is not preferred as this would not achieve government objectives to improve fire safety in buildings.
30. Option 2 is preferred as it expected to provide the biggest benefit in terms of improving fire safety and is proportional to the risks associated with the buildings in question.
Costs
Option 2 (Preferred Option)
31. We have monetised the impacts to businesses and society, under Option 2 this is for all new residential buildings and building conversions over 18 metres in height. For businesses it will result in an estimated annual net cost to business between £13.8m - £25.6m[footnote 1] , with a central estimate of £19.7m, and effects approximately 500 buildings in scope on average per annum . As ongoing and maintenance costs are likely to passed onto leaseholders, this option in total will result in an estimated annual net cost to society between £16.2m-£30.1m, with a central estimate of £23.2m.
32. Costs are split into 3 broad categories:
Installation
33. Each system is expected to have an installation cost in the range of £27,000-£50,000, with a central estimate of £39,000, for 18m-30m buildings and £48,000-£89,000, with a central estimate of £68,000 for 30m+ buildings. These figures include both the cost of the product and the cost of labour to install the system in 18m-30m+ buildings.
34. There is small component of the installation cost where some time by a facilities manager (Building Safety Manager or alternative counterpart) will have to prepare an information leaflet.
35. This results in an approximate installation cost per flat in 18m-30m buildings of £400-£8000, with a central estimate of £600 and a cost per flat in 30m+ buildings of £600-£1100, with a central estimate of £800.
Ongoing/ running
36. As the systems will continuously use electricity, there will be an associated cost. We estimate this will cost around £100 per annum. This increase in electricity usage is likely to also increase carbon emissions.
37. There are additional annual costs incurred where a facilities manager (or alternative counterpart) will brief residents on the evacuation system. We estimate this will take around 7.5 hours, costing around £400 per annum; this includes printing costs of the information leaflet, prepared upon installation.
38. This results in an approximate running cost per flat of less than £10.
Maintenance
39. The systems must be maintained for them to work as necessary in the event of a severe fire where the evacuation system will be used by Fire and Rescue Services. We estimate this cost of maintenance to be £300-£500 per annum, with a central estimate of £400, for 18m-30m buildings, and £500-£900, with a central estimate of £700, for 30m+ buildings.
40. Therefore, the approximate maintenance costs per flat of less than £10.
Option 3
41. We estimate that this option will bring an additional 1,100 buildings in scope per annum over Option 2, a total estimate of 16,000 buildings over the appraisal period, including building conversions.
42. Option 3 has an estimated annual net cost to business between £32.6m - £60.5m, with a central estimate of £46.5m. Ongoing costs and maintenance costs are expected to be passed on to leaseholders, therefore, in total, the estimated annual net cost to society is around £39.6m-£73.5m, with a central estimate of £56.6m.
43. Costs are split into 3 broad categories:
Installation
44. Each system is expected to have an installation cost in the range of £21,000-£39,000, with a central estimate of £30,000, for 11m-30m buildings and £48,000-£89,000, with a central estimate of £68,000 for 30m+ buildings. These figures include both the cost of the product and the cost of labour to install the system in 18m-30m+ buildings.
45. There is small component of the installation cost where some time by a facilities manager (or alternative counterpart) will have to prepare an information leaflet.
46. This results in an approximate installation cost per flat of £600-£1100, with a central estimate of £800.
Ongoing/ running
47. As the systems will continuously use electricity, there is an associated cost to this. We estimate this will cost around £100 per annum. This increase in electricity usage is likely to also increase carbon emissions.
48. There are additional annual costs incurred where a facilities manager (or alternative counterpart) will brief residents on the evacuation system. We estimate this will take around 7.5 hours, costing around £300 per annum; this includes printing costs of the information leaflet, prepared upon installation.
49. This results in an approximate running cost per flat of just over £10.
Maintenance
50. The systems must be maintained for them to work as necessary in the event of a severe fire where the evacuation system will be used by Fire and Rescue Services. We estimate this cost of maintenance to be £200-4500 per annum, with a central estimate of £300, for 11m-30m buildings, and £500-£900, with a central estimate of £700, for 30m+ buildings.
51. Therefore, the approximate maintenance costs per flat of less than £10.
Familiarisation costs
52. Upon changing Building Regulations, there will be some transitional cost element for all users of the guidance, in this case ADB.
53. It is most likely that professionals will familiarise themselves with the changes to the guidance in ADB when they come to use it for the first time following the update.
Option 2 (Preferred Option)
54. We estimate it will take 48,000 professionals working on 18 metres+ buildings, with an average hourly rate of c.£50 across the industry, 15 minutes each to familiarise themselves to these changes, at a cost of approximately £0.1m - £0.3m, with a central estimate of £0.2m.
55. Additional familiarisation costs have been modelled on top of the time it will take for professionals to refamiliarize themselves with changes to ADB. EAS are still a relatively new concept to industry and so this will take 1,600 electrical engineers, with an hourly rate of c.£60, who work on 18 metres+ buildings 1 hour each to familiarise themselves with these new systems, at a cost of approximately £0.1m.
56. The total familiarisation costs for ADB professionals and electrical engineers who work on 18m+ buildings are £0.2m - £0.4m, with a central estimate of £0.3m.
Option 3
57. There are approximately 100,000 more professionals who use ADB who work on 11 metres-18 metres buildings, in addition to the 48,000 professionals working on 18m+ buildings, resulting in almost 150,000 professionals who need to familiarise themselves because of changes to ADB caused by Option 3. This has a total estimated cost of £0.5m-£0.8m , with a central estimate of £0.6m.
58. There are an additional c.3,200 electrical engineers who work on 11 metres-18 metres buildings and so the total cost of these professions plus those who work on 18 metres+ buildings to familiarise themselves with the new systems are £0.2m-£0.4m , with a central estimate of £0.3m.
59. The total familiarisation costs for ADB professionals and electrical engineers who work on 11m+ buildings are £0.6m - £1.2m, with a central estimate of £0.9m.
Benefits
60. In the case that a severe fire, one that spreads beyond the initial flat or compartment in which evacuation beyond the flat of origin is necessary, EAS are in place to increase the speed and efficiency at which residents are alerted about the need to evacuate the building. The availability of an EAS will provide Fire and Rescue Services with an additional tool which can be used where they deem it necessary.
61. The system gives Fire and Rescue Services the possibility of triggering the evacuation of the building in a phased manner so that escape routes are not overwhelmed.
62. Across 2017/18 – 2020/21, there have been 23 primary fire incidents that involved an evacuation of more than 20 people[footnote 2] in England. As a result of making the provision for EAS in ADB, an additional c.5,000 18m+ residential buildings (new builds and office conversions) will have an additional facility to aid in the evacuation process.
63. However, the response of residents cannot be guaranteed despite an EAS in place, for example residents may not respond to the alarm or struggle to comply with the evacuation procedure. This may mean there will still be a requirement for Fire and Rescue Services to continue to alert residents door to door.
62. The above benefits cannot be robustly monetised due to issues valuing the increase in speed and efficiency of an evacuation as well differentiating this from other building safety regime changes which may affect the way buildings are evacuated. ###Rationale and approach
64. The analysis in this impact assessment is proportional to the cost and benefits outlined above given current availability of data.
65. This impact assessment has considered the costs and benefits of changes to ADB relative to the counterfactual of the current regime and current voluntary practices in the industry.
66. All costs are any additional costs incurred by the policy options, and the benefits are a measure of any improvement above the counterfactual, though no benefits have been monetised.
67. Modelling is to the standards as set out in the Green Book, using a discount rate of 3.5% over the 10-year appraisal period, using 2021 as the Price Base and Price Value year. Alarm systems are assumed to last approximately 10 years, and so maintenance and installation costs of the alarm across the full lifespan of the alarm is included within the total cost. (E.g: Alarms installed in 2031, would be expected to last until the end of 2040, and so the maintenance and installation costs of this is still included within the total cost figures).
68. We have modelled a 6-month transition period where buildings in scope near completion within the first 6 months of the preferred policy being in legislation can voluntarily comply with the requirement to install an EAS.
69. The building stock for both 11m-18m and 18m+ buildings used in this model are as at February 2022 as part of the Building Safety data release.
Risks and assumptions
70. There is a degree of uncertainty about the estimates and the assumptions that have been made to model the costs. Therefore, to reflect this uncertainty, high and low estimates have been calculated.
71. The modelling utilised input from a number of consultants, who had a good and diverse industry knowledge. Their professional opinion helped direct assumptions and estimates where necessary.
72. Adroit Economics consortium obtained a sample of quotes from industry to create an estimate of the installation, maintenance and ongoing costs of EASs (Evacuation Alert Systems).
73. The costs and benefits of the policy options have been estimated using several working assumptions which are subject to change. These are not official data based on factual information and therefore should be used with caution. The key areas where assumptions have been made:
a. Forecast stock and the rate of erection of new buildings and number of building conversions into new residential flats for the 10-year appraisal period . The modelling has assumed a growth rate per annum of 3.0 % for 18 metres+ buildings and 1.3% for 11 metres-18 metres buildings. This means on average there will be an additional 400 residential 18 metres+ buildings and 1,000 11 metres-18 metres residential buildings built per year over the appraisal period. Additionally, it has been assumed that there will be on average 80 office conversions at 11 metres –18 metres per year and 80 office conversions at 18m+ into new residential buildings per year.
b. We have also had to assume some properties of the buildings in scope. These assumptions have been used to model indicative costs per flat.
| Building Height | Average Number of Floors per Building | Number of Floors with Flats on | Flats per Floor | Average Number of Flats per Building | Number of Stairways |
|---|---|---|---|---|---|
| 11m-18m | 5 | 4 | 9 | 36 | 2 |
| 18m-30m | 8 | 7 | 9 | 63 | 2 |
| 30m+ | 15 | 14 | 6 | 84 | 2 |
c. The proportion of buildings currently installing a fire EAS. In the counterfactual, the model has assumed 5% of buildings would have installed an EAS in the absence of any policy intervention.
d. The rate of which industry learn new products and so saving time and expense as installers become more familiar with these products. We assume a decrease of 5% in installation costs per year for the first 4 years. At this point, industry professionals are assumed to be fully competent and knowledgeable of the new systems.
e. During the 6-month transition period we have estimated that 50% of buildings in scope will voluntarily install an EAS.
74. To realise the benefits of installing an EAS the Fire and Rescue Services must utilise the alarm. As a relatively recent technology, time will be required for the Fire and Rescue Services to develop operational guidance to do so effectively.
75. We have assumed that 6 months (and the subsequent build period for new projects) will allow enough time for robust testing and training to allow the relevant individuals to develop such guidance and be ready to use these new systems if necessary.
76. Whilst Option 2 (the preferred option) only gives guidance for 18 metres+ new-build residential buildings, it is likely that buildings of lower height may be encouraged to install such safety systems and so voluntarily comply with the new guidance. The extent of this is unknown, and as it’s not a direct result of the policy option, costs or benefits have not been modelled for this.
77. Although some new buildings will likely be developed by local authorities, during construction most costs will fall on housing developers and housing associations in the first instance.
78. Maintenance and ongoing costs of the EASs is likely to fall on the freeholders of the building and building management firms in the first instance, but will likely be recovered by leaseholders through increased services charges, therefore there will be a present value cost to leaseholders of approximately £20.9m-£38.9m, with a central estimate of £29.9m.
79. For businesses, the net present cost to businesses is approximately £118.5m - £220.1m, with a central estimate of £169.3m, and an annual net cost to business of around £16.2m to £30.1m, with a central estimate of £19.7m. Therefore, the total net present social cost is approximately £139.4m - £258.9m, with a central estimate of £199.2m.
80. Costs to the public sector have not been highlighted. We anticipate very few new-builds to occur over the appraisal period which would be owned local authorities and not meet the requirements proposed by the policy change.
Wider impact tests
Equalities
81. An initial equalities screening of the preferred policy was carried out and determined that a full equalities impact test was not required as the proposal is unlikely to disproportionality affect any groups sharing a protected characteristic.
Social
82. Changes brought about by the preferred policy option will not affect family relations or the use and privacy of data. It was therefore determined that no further social impact tests are required.
Competition
83. The proposals do not make any long-term significant impact on competitiveness of English companies within the UK (United Kingdom) or elsewhere in Europe. The proposals will also not limit the number of installers or product suppliers either directly or indirectly, nor will it limit the ability of suppliers to compete or their incentives to compete.
84. Therefore, it was determined the proposal outlined above will apply in a proportional and equitable way.
Small firms
85. We have considered the impact on small businesses and concluded that the impacts and costs of the preferred policy choices will not disproportionately affect businesses with a low turnover.
86. Therefore, there is no exemption for small and micro businesses.
Environmental
87. We have considered the impact of the proposals on the environment. It was determined that a full environmental test was not required.