Mr Mark Dreyfus QC MP
Chair, House of Representatives Standing Committee on Legal and Constitutional Affairs
PO Box 6021
Parliament House
Canberra
ACT 2600

19 May 2009 

Dear Mr Dreyfus,
I am writing to provide the Committee with further information in relation to the draft Premises Standards concerning costs associated with the construction of new buildings and the relative cost of providing a lift to the upper floor in small low rise buildings.
During the Roundtable held on 7 April Mr Small from the Australian Human Rights Commission referred to a Photo essay produced by the Commission a number of years ago. This document was developed to try and give a picture of the typical High Street small business that would benefit from the proposed 200 square metre upper floor concession in the draft Premises Standards.
At the time of developing the document the Commission made some broad assessment of costs associated with the construction of new Class 5 (Offices) and Class 6 (Retail) buildings and the relative costs associated with providing access to the upper floors of two and three storey buildings.
That assessment was based on the only data availably to the Commission at the time which came from the ACT Government which identified a cost of $1200 per square metre for a 2/3 storey Office block.
 http://www.legislation.act.gov.au/ni/2008-116/current/pdf/2008-116.pdf 
Using that figure of $1200 the cost of a basic 2 storey 200 square metre per floor building would be in the vicinity of $500,000. Assuming such a building, if it were required to provide upper floor access, would be able to use a stairway platform lift costing $50,000 (a high estimate of cost) the cost of providing upper floor access would be approximately 10%.
Since the document was developed the Commission has been alerted to the fact that the ACT Government figures are under review and that costings produced by other industry bodies may provide a more realistic set of figures.

The Commission has reviewed the material produced by a leading provider of information on construction activity and building costs, Reed Construction and specifically their Cordell Commercial & Industrial Building Cost Guide which can be found at:
http://www.reedconstructiondata.com.au/products/costs.html#commerical-building 
This data indicates that a more realistic costing for a 2/3 storey office building, for example, would be in the area of $1850 per square metre. Using the same assumptions as above a 200 square metre per floor two storey building would cost approximately $750,000 and the cost of providing access to the upper floor would comparatively be reduced to 6.5%.
These costs do not take into account costs such as purchase of land or fit-out of buildings to meet client specifications. These increased costs would have the effect of lowering the comparative percentage cost associated with providing upper floor access.
I hope this information will be of value to the Committee in its deliberations.
Yours sincerely,

Graeme Innes AM
Human Rights Commissioner and
Disability Discrimination Commissioner

T +61 2 9284 9692
F +61 2 9284 9797
E graeme.innes@humanrights.gov.au