Traditional accommodation buildings such as hotels and motels are considered Class 3 buildings for the purposes of applying the NCC, whereas residential apartment buildings are considered Class 2 buildings. This means that apartment buildings are subject to some different requirements, often less stringent than those for Class 3 buildings under the Deemed-to-Satisfy (DTS) Provisions of the NCC.
However, short-term accommodation in apartment buildings has become more mainstream in the last few years since the introduction of online platforms such as Airbnb and Stayz.
In response to some on-going concerns raised about the use of apartments for short-term accommodation, the ABCB undertook a project in 2017/18. The project consisted of two main components:
- Discussion Paper: A Discussion Paper was released to gather information on the problem and assist in determining any changes that may be required to the NCC, and
- Risk Analysis: A consultant was engaged to analyse the effect of occupant length-of-stay on fire safety risks in apartment buildings.
Limited responses were received to the Discussion Paper, with very few responders understanding that concerns related to occupancy numbers, noise control, car parking, refuse and party rooms represent use-management issues that cannot be regulated by the NCC. Those that did understand the limitations of the NCC, supported action by jurisdictions, local councils and the rental industry to deal with the issues. Importantly, no evidence was received to indicate an increased fire safety risk due to short-term accommodation in apartment buildings.
The Risk Analysis considered the fire safety risks to a person located in a Class 2 apartment unit where a fire initiated. The consultant determined there would be no material change in fire safety risks to a person based on their length of stay in the unit (variable for short-term accommodation).
In the majority of instances, the fire safety risks for building occupants, within various building configurations, would also be within the allowable range permitted under the current NCC DTS Provisions. However, it was identified that for an apartment building utilising DTS Provision D1.3, which allows an open stairway rather than a fire-isolated stairway, the fire safety risks may differ.
The ABCB considered the outcomes of the project in late 2018 and the Board agreed there is no known evidence to support any change to NCC requirements for Class 2 and 3 buildings and no need for further investigation. However, it was agreed that further research would be undertaken in 2018/19 on the efficacy and usage of DTS Provision D1.3.