Fire Safety Issues -Object Now!

Please copy the text below into an email, add a few words of your own and send it to and . They really need to know that approval of the Blenheim Centre redevelopment could have tragic consequences!


Planning Reference: 23/00178/FULL1 – Request to Call in Due to Serious Fire Safety Breaches

I am writing to request you reject or call in of the above planning application, (to build a 16 storey multiple tower block housing development in Penge High Street) on the grounds this could be a serious breach of fire safety regulations and legislation.

This development was approved by Bromley Council on 5 March, overriding strenuous opposition from, inter alia, the London Fire Brigade (LFB). The LFB opposed the plan in the strongest possible language, stating that it contravened “the spirit of the guidance” (ie London Plan policies 2021 D5 and D12) and could not be“ethically justified.Addendum, Page 6, Section 1, attached.

It is my belief that the issue of fire safety was not properly considered, and that lives could be at risk if the developer is permitted to proceed with this project for the reasons outlined below. Hence, my request that this development be called in for further consideration, before it is approved.

Firstly, the LFB’s warnings about fire safety hazards were only released to councillors as an addendum at the decisive DCC meeting itself. This meant the LFB’s strongly worded case concerning substantial breaches in fire safety legislation was all but buried at the meeting. As a result, councillors were unable to discuss this serious matter – the topic which dominated the DCC meeting – in a fully informed and knowledgeable manner. They were probably completely unaware and innocent of the scale and nature of the infringements they were signing off on.

It seems clear that, had councillors been aware of the full implications and the scale of the disregard of fire safety protocols, this development would never have been approved. 

To ensure that we are all not walking blindly towards another Grenfell, I urge you to reject or call in this development. This will allow for full examination and digestion of the LFB’s concerns, and fire safety breaches involved, with appropriate remedial action taken.

Secondly, while carrying out a thorough inspection of development documentation, I uncovered a major discrepancy in official height figures for one of the tower blocks. This may indicate that a serious breach in fire safety regulations has slipped through the net.
I discovered these discrepancies while examining architect Rolfe Judd’s planning statement, comparing their figures against those of Design Fire Consultants’ (DFC) Fire Statement. To make this absolutely clear, here is the verbatim record from architect Rolfe Judd’s  Planning Statement (Revised), see page 4, Section 1. Introduction, 1.4 Supporting Application Documents, 1.4.2

“The overall height reductions are shown below: Submitted (1st iteration): BLOCK A Storeys: 6; Maximum Height 24m; Revised: Storeys: 6, Maximum Height 22.5m.”

 I went on to compare this figure with DFC’s fire safety report.  This is what I discovered: See FS 001.6 Page 6, Section 2, verbatim: “Block A: 6 storeys (L00 to L05) with a height to topmost occupied storey of approximately 17.7m.”

To make this absolutely plain yet again, DFC’s approximate 17.7m figure appears nowhere else other than their own fire safety report. It does not appear in any other official document, original or revised. This figure is just 30cm shy of the qualifying 18m height required for a second stair, and it is an approximate figure, so that only three bricks more and the tower block will reach this. A few more bricks and it will reach 22.5m as planned.

How did this discrepancy arise, I asked myself? Well, it looks like the source of the trouble is how height gets calculated. For instance, architect Rolfe Judd calculates the height of the tower block by measuring its height. On the other hand, DFC favour their own device of calculating height not by height but to the highest habitable level. Again, to be clear, regulations are clear – buildings over 18m require a second stair, no if’s or but’s.

By adopting this device, DFC were able to bring in the height of Block A at 17.7m, shaving 5m (15ft) approx off the architect’s plans while the architect was able to stick to 22.5m in the real world.

To make this as plain as I can, Fire Safety Regulations BS9991 require a second evacuation stair for buildings over 18m. At 22.5m – 4.5m in excess of the qualifying height – Block A requires a compulsory second evacuation stair to comply with fire safety regulations. At 17.7m, it does not.

DFC then passed this incorrect height figure to the LFB, who took it in good faith to be accurate, and used it as the basis for applying statutory fire safety regulations in their own report. Even with this incorrectly under reported height of 17.7m, the LFB were adamant that Block A required a second evacuation stair. The LFB expressed their opposition in the strongest possible language, stating that the plan could not be “ethically justified” and contravened “the spirit of the guidance” (ie London Plan policies 2021 D5 and D12).

IF DFC had passed on accurate information regarding the full height of Block A to the London Fire Brigade, the LFB would have been able to compel the developer to comply with statutory fire safety regulations for a second evacuation stair.

IF DFC had given accurate full height information to the London Borough of Bromley’s Planning Department, officials there would have spotted substantial breaches in fire safety regulations and recommended rejection of the plan to councillors at the DCC meeting.

IF DFC had given accurate full height information to the LFB, councillors at the DCC meeting would have swooped on this and stopped the plan in its tracks, rejecting planning permission on the grounds of breaches in fire safety regulations.In short, planning permission for this development was attained through nothing other than a major slip up on the part of fire safety experts DFC, and not on its merits or its compliance with the letter ofLondon Plan policies 2021 D5 and D12.

Moving on. At the DCC meeting on 5 March, the developer gave categorical assurances to councillors that all qualifying blocks had a second evacuation stair. Based on my analysis of the developer’s own documents (see attached), THE EVIDENCE DOES NOT BEAR THIS OUT AND PUTS THE PLAN IN BREACH OF BS9991. This, in turn, places residents and fire-fighters at unnecessary risk in the event of a fire. 

By incorrectly stating one of the tall buildings is under 18m, DFC has, accidentally, relieved the development of the necessity to comply with fire safety regulations. As councillors only had sight of the LFB’s detailed technical report at the start of the DCC meeting itself, they simply didn’t have the time to digest the LFB’s case. This meant the LFB’s call for action on fire safety grounds missed the mark with councillors who simply hadn’t read the document, through no fault of their own. 

The sting at the end of this part of the tale is that this monumental mistake has STILL to come to light publicly. Currently, there is no chance of this hazard being remediated and Block A brought into compliance with BS9991 regulations as no one knows this breach in fire safety exists.

The developer does not appear to know about it, the fire safety experts do not appear to know about it, the London Borough of Bromley’s Planning Department does not appear to know about it, the councillors at the DCC meeting did not know about it and, to cap it all, the London Fire Brigade are also in the dark about it. In other words, there is absolutely NO necessity for the developer to correct this monumental breach of fire safety regulations because nobody knows about it.

The regulation that tall buildings over 18m was brought in following the terrible Grenfell tower tragedy with the full wholehearted intention of averting another disaster. This rule must be respected, applied with due diligence and a strong ethical commitment, to live up to the regulatory detail and spirit of its inception. I urge the GLA to reject or call in this plan in order to remediate this error, along with other breaches, and bring this into line with current fire safety regulations.

Thirdly, I should also add here that the LFB has “fundamental concerns” relating to what they consider as conflicts between fire safety guidance and revised design of secondary staircases for Blocks B, D, and E.

Fourthly, there is the apparent rejection, without justification or explanation, of the LFB’s recommendation for an additional firefighting lift for all five tower blocks A, B, C, D, E. The essence of the LFB’s case is that all tall buildings have enough staircases and evacuation lifts to allow for the dignified evacuation of residents in the event of a fire, in compliance with statutory guidelines. As the LFB state: “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.”While fighting firesin tall buildings, in firefighters’ experience, a single lift can often fail, leaving them without this essential means of access and egress. To quote the old adage, in the event of a fire, it is better to be safe than sorry.

The LFB are not asking to be served pate de foie gras on toast along with a nice chianti when they attend a fire, they are simply asking for the basic tools to do their job and save lives.

Fifth, the LFB raise the critical matter of “ensuring suitable means of escape for all occupants in open plan apartments.” In their earlier report, the LFB expressed serious concerns about the layout of apartments where kitchen and cooking appliances are located by the front door. In the event of a fire in an apartment, the LFB warns, residents would be trapped with no safe way of escape. This matter is still to be addressed and rectified.

The above are not the only serious breaches of fire safety regulations.
There are many others to choose from.  Particular statutory infringements include:

1) Fire Safety Regulations BS9991

2) Guidance (ADB V1 paragraph 3.18 and BS 9991:2015, clause 9.1

3) London Plan 2021 Policies D5 & D12

4) Specifically, London Plan 2021 Policy D5 (B5.12)

5) In the LFB’s official report, in their own words, this plan is in breach of the spirit of London Plan 2021 D5 & D12 and cannot be “ethically justified”.

Sixth, the Grenfell Tower disaster exposed the weaknesses of “Stay Put” as a fire safety strategy. I gather from previous LFB responses this is in place here. However:
– “Stay put” should not be used to legitimise minimum fire safety standards
– “Stay put” should not be used in place of best practice dedicated to the safety of residents and firefighters
– “Stay put” is not an alternative to the provision of adequate fire safety evacuation routes
– “Stay Put” is not to be used to deflect from ill thought-out interior design layout. 
To be plain, residents should not be told to “Stay Put” in the event of a fire just because there are not enough escape routes for them to get out.

I conclude this with one memory – Seven years ago, Wednesday 14 June – Friday 16 June 2017, 72 people died in the fire at Grenfell Tower. On the grounds of multiple monumental unresolved and unacknowledged fire safety breaches, we ask you to call in or reject this development and potentially avert another terrible tragedy in the making