Automatic Fire Suppression System installations - traditional building conversion to hotels: cost benefit analysis

2. Defining Traditional Buildings

2.1 Introduction

2.1.1 The recommendation set out by the Sheriff recommended consideration of risk in “future conversions of historic buildings”. ‘Historic building’ is not currently a term defined in relevant legislation. Accordingly The Scottish Government has directed that assessment be based upon the term ‘traditional building’. This is a defined term and is considered to encompass, amongst other types, ‘historic buildings’. It makes reference to construction characteristics that can reasonably be deemed present in that type of building in Scotland.

2.1.2 One of the key issues for this study to establish is whether there is a greater incidence of fires in hotels in traditional buildings compared to fires in non-traditional buildings. This raises a few issues surrounding the definition of a traditional building and the approach to determining whether the fire was in a traditional building. There is also a need to understand the distribution of the total hotel stock in Scotland between traditional and non-traditional buildings.

2.1.3 The FAI recommendation is clear that the analysis should focus on hotels. Consideration has been given to whether guest houses and bed and breakfast accommodation should be included in the analysis. Given that bed and breakfast accommodation is typically provided in domestic dwellings on a relatively small scale and any decision to mandate AFSS is unlikely to include guest houses and B&Bs. The analysis will therefore focus on hotels.

2.2 Hotel Fires in Traditional Buildings

2.2.1 A traditional building is defined in the building standards technical handbooks as:

“A building or part of a building of a type constructed before or around 1919:

a. Using construction techniques that were commonly in use before 1919 and

b. With permeable components, in a way that promotes the dissipation of moisture from the building fabric.”

2.2.2 The Scottish Fire and Rescue Service (SFRS) provided detailed incident data for all fires in hotels in Scotland between 2013/14 and 2023/24. However, this data does not include any information on the age of the building or whether traditional construction techniques were used. Hence, an approach was required to enable hotels to be allocated to building type i.e. traditional/non-traditional

2.2.3 Historic Environment Scotland (HES) indicated that traditional building construction techniques were used after 1919 such that there is some flexibility in the date for a building to be described as traditional. Use of the HES listed building database was considered as a means of identifying hotels which are in traditional buildings, but a number of limitations were identified:

• Many former country houses which have been converted to hotel use may not come up in a hotel search. As buildings are listed by statutory address, a search will only identify the building if ‘hotel’ is in the address. Hence, the database may not be comprehensive for the purposes of this research.
• Many traditionally built hotels may not be listed as a building must be of ‘special’ architectural or historic interest to be listed.
• As tourism is closely associated with heritage, many traditional hotels may be sited in conservation areas, but there is no planning or heritage database that would record which buildings are hotels. Many traditionally built and listed hotels were built for that function in the 19^th century but some would have been built as country houses or townhouses and then converted.

2.2.4 Following discussions with HES, BSD and other members of the Fire Safety Expert Group, it was agreed that the best approach to determining if a hotel fire is in a traditional building would be to undertake an internet search and review photographs of the hotel.

2.2.5 The approach to determining whether the fire was in a hotel which was a traditional building was based on the list of hotel fires provided by SFRS and included the following steps:

• Search for each hotel and access the hotel website.
• Review any description of the hotel building. Some websites included the date of construction while others described the hotel as being in a certain type of building. Anything described as Edwardian, Victorian or Georgian was included as a traditional building.
• Where there was no clear description, a review of external photographs was undertaken and a judgement made.
• Where there were no external photographs, a review using google street view was undertaken.
• Where the study team was unable to make a decision, BSD and three members of the Expert Group reviewed the information and made a recommendation on building type.

2.2.5 Where part of the building was traditional but there was also a more modern extension or annex, the building was classified as traditional.

2.3 Total Hotel Stock in Scotland

2.3.1 To determine whether the incidence of hotel fires in traditional buildings is different from the incidence of hotel fires in total, an estimate of the total stock of hotels is required. While the census of population collects data on the number of residential dwellings and other censuses collect data on other types of buildings (e.g. schools), there are no such data sources for hotels.

2.3.2 Several sources of information have been reviewed to establish the potential stock of hotels in Scotland:

• Businesses in Scotland^[2] is a Scottish Government publication showing the number of businesses in Scotland. In 2023, there were 2,955 accommodation businesses in Scotland. The figure includes registered and unregistered businesses^[3]. Unfortunately, this category covers hotels and similar accommodation, youth hostels, holiday centres, other holiday accommodation, recreational vehicle parks and other accommodation.
• Scottish Valuation Roll^[4] contains a list of all hotels as these are rateable for non-domestic rates purposes. The valuation roll allows hotels to be identified separately from guest houses and as at March 2024 there were 2,134 properties listed as hotels on the valuation roll.
• Visit Scotland and other accommodation booking providers were considered as sources of hotel information. However, these sources only cover properties where owners have made the decision to register and therefore are not comprehensive.

2.3.3 The valuation roll was adopted as the basis for the stock of hotels. Within the ‘hotel’ category on the assessor’s database, three sub-categories were excluded for the following reasons:

• Aparthotel: entries were serviced apartments.
• Guest accommodation: entries covered a variety of accommodation but mainly guest house/room only/B&B accommodation.
• Hotel annex: the hotel is already included in the list.

2.3.4 Table 2.1 provides a summary of the number of hotel properties by valuation office area included in the analysis.

2.3.5 The assessor’s database of hotels does not provide information on the age of the building or whether it is a traditional building. To determine the distribution of the total hotel stock between traditional and non-traditional buildings, the approach detailed in paragraph 2.2.4 was applied to a 10% sample of hotels.

2.3.6 Table 2.2 shows that of the sample of 212 hotels across Scotland, 147 (69.3%) were in buildings assessed as traditional.

2.3.7 Applying the percentages in Table 2.2 to the total number of hotels in Scotland (2,022) yields an estimate of the number of hotels in traditional buildings of 1,401 and 621 hotels in non-traditional buildings.