This is an extract from the London Fire Brigade’s response to Hadley’s proposals. There are 9 areas of concern.
“London Fire Brigade (LFB) has been consulted with regard to the above-mentioned premises and in
response to the resubmission of this application makes the following comments/observations in relation to the comments originally addressed:
Fundamental concerns relating to single stair for Block A
- We note that the updated design for the height of Block A has been reduced to below 18m
however it is noted that the height of the building is identified at 17.7m and is reliant on a single
staircase. We draw your attention to the announcements from government stating their
expectation that multiple staircases will be required in residential buildings above 18m. Whilst
we note that transitional arrangements will apply, it is the National Fire Chiefs Council (NFCC)’s
position, as stated in the December 2022 NFCC ‘Single Staircases Policy Position Statement’ that
all residential buildings over 18m or seven storeys in height should be provided with multiple
staircases. We therefore do not see this as deferring to the spirit of the guidance used
and doesn’t ethically justify this decision.
Design teams and developers should also be planning for the new requirements under the
Building Safety Act for in scope buildings once occupied, including the need to provide a safety
case review. The design as currently proposed may have implications on those responsible for
demonstrating the ongoing safety in the building.
Fundamental concerns relating to single stair for Blocks B, D & E - We note the addition of a secondary stair for Blocks B & D. It is noted that the design for two
staircases serving all floors in these blocks is not satisfactory in relation to the relevant guidance
used. It is noted that the proximity of all staircases do not provide a suitable secondary means of
escape, as in all buildings escape to a second stair is either past an un-lobbied stair or through the
lobby of the stair that is not being used. Whilst we appreciate the proposals include the provision
of a second stair, we are of the opinion that occupants should be provided with an appropriate
route to either escape stair without having to move through a lobby associated with one stairway
to get to a lobby associated with another stairway
We note the clarification of the amenity areas in Blocks B, D E, and expect this to be included in
subsequent building control consultations.
Ensuring suitable means of escape for all occupants in open plan apartments - We await further information in subsequent building control consultations.
Evacuation lifts for Blocks A, B, C, D & E - Noted. Our original comment regarding the provision for an additional evacuation lift in each core
remains to ensure safe evacuation for all persons in the event of a lift failure. We expect this to
be clarified in more detail in subsequent building control consultations.
Access and facilities for the fire and rescue service for Blocks A, B, C, D & E - Noted. Our original comment regarding the provision for an additional firefighting lift in each
core remains to ensure sufficient access for firefighters to all areas of the buildings in the event
of a lift failure. We expect this to be clarified in more detail in subsequent building control
consultations.
In addition to the responses above, further comments in relation to this application are:
Proposed vertical means of escape design in Block C - It is noted that the design for two staircases serving Block C is not satisfactory in relation to the
relevant guidance used. It is noted that the proximity of all staircases do not provide a suitable
secondary means of escape for any ‘Adaptable’ flats, as escape to a second stair is either past an
un-lobbied stair or through the lobby of the stair that is not being used. Whilst we appreciate the
proposals include the provision of a second stair, we are of the opinion that occupants should be
provided with an appropriate route to either escape stair without having to move through a lobby
associated with one stairway to get to a lobby associated with another stairway
Mechanical Ventilation - We note the decision to use mechanical ventilation as a justification the enclosed horizontal
means of escape. We expect this to be justified by provided suitable CFD modelling
documentation and a relevant 3rd party analysis in subsequent building control consultations.
Electric Vehicles - We note that the proposals include enclosed car parking areas and recommend that
consideration is given in relation to electric vehicle (EV) charging units, together with the
potential fire risk posed by their battery systems. The following should be considered,
preferably as part of a Qualitative Design Review (QDR) and, following the recommendations
given in BS 7974. This is not intended to be an exhaustive list of considerations:
· Whether the smoke ventilation provisions for car parks are sufficient to manage the
products of combustion from a fire involving one or more EVs
· Whether AWFSS require enhancements beyond the minimum recommendations of the
relevant standards
· Whether the fire resistance of elements of structure should be increased beyond the
minimum recommendations of this code of practice
· Whether car parking spaces served by EVCUs should be located closer to the access
points to the car park for the fire and rescue services and to any fire main outlets in order to
assist firefighters in applying extinguishing media to the fire
· Whether there should be provision for the safe removal of any EV car that has been
involved in a fire and may still pose a risk of reignition. If access to the space is only via a car
lift, for example, this may not provide such suitable provision
· Whether the water supplies provided for the fire and rescue services should be enhanced
beyond the minimum requirements of BS 9990 and other relevant standards, in particular
with regard to the duration of water supply available
· Suitable protection to car park internal surfaces and drainage systems to facilitate post-fire
clean-up and environmental protection
A means of isolating the power supply to EVCUs should be provided for the fire and rescue
services in a suitable location associated with, but outside of, the fire resisting enclosure to any
car park containing EVCUs. This should be at the main designated access point to the building
or car park for the fire and rescue services. Signage should be provided to identify the power
supply isolation controls, and this should state:
“FIREFIGHTERS ELECTRICAL ISOLATION SWITCH FOR CAR PARK ELECTRIC VEHICLE
CHARGING UNITS”
The signage should conform to BS 5499-1.
The location(s) of power supply isolation controls serving EVCUs should be indicated on
premises information provided for firefighters. The power supply to all EVCUs should also be
automatically isolated upon actuation of the fire warning and detection system or sprinkler
system serving the car park in which they are located. EVCUs should be provided with a
suitable level of water resistance to ensure that they do not pose a hazard to firefighters should
they become immersed in water, either as a result of the activation of the sprinkler system or
firefighting operations. It is our strong recommendation that car parks containing EVCUs should
be provided with sprinkler coverage in accordance with BS 9251:2021 or BS EN
12845:2015+A1, irrespective of whether a building is otherwise provided with a sprinkler
system.
Cycle Storage Area - The proposals include a cycle storage area. It is our opinion that consideration is given to the
storage (and potential charging) of electric bikes and electric scooters and the potential fire risk
posed by these electric powered personal vehicles (EPPV)s which may be located within these
areas. There is increasing evidence showing that EPPVs can spontaneously ignite and burn for
long periods so there is an increased potential for toxic gases/smoke/fire spread. It is therefore
our recommendation that adequate automatic fire suppression and smoke control systems for
the area are necessary. As such storage would be deemed an ancillary area, we are of the view
that it should be provided with a ventilated lobby in accordance with the recommendations
given in clause 32 of BS 9991:2015.”