The ambition of the latest meeting of the NLA Expert Panel on Tall Buildings was to gather first thoughts on the Mayor’s consultation for the Fire Safety London Plan Guidance (LPG), which sets out changes to compliance with London Plan Policies D12 Fire Safety and D5(B5) Inclusive design (evacuation lifts) in order to demonstrate that schemes achieve the highest standards in fire safety.  

The consultation runs until 20 June 2022. No official briefing events have happened yet. Public consultation events run from 9th March to 17th May https://www.london.gov.uk/firesafety – so, NLA is quick off the mark!

The draft guidance considers:

·     The requirement to submit a Fire Statement or Planning Fire Safety Strategy (PFSS) with a planning application for certain residential developments – but excluding householder applications.

·     Incorporation of evacuation lifts specifically designed to be used as means of escape for people that require level access and exit or assistance during an emergency – in addition to firefighting lift(s).

 

The provisions appear to aim to offer a practical way of structuring information required, aligned with Gateway One coverage of fire safety, in a range of building types. 

 

Everyone in the group believed that fire safety must be considered from the outset to ensure the most successful outcomes are achieved for building occupants and users. It was generally the experience of the group that new tall buildings, inevitably major projects, require significant investment including fire engineered solutions with specialist advisors – so it is not unusual for our panel to already have documents of this calibre pre-planning. 

 

We were all glad to have recognised, in the introduction to the LPG, that the evolution of a fire safety strategy and associated evacuation strategy is expected to be ’iterative’, progressing alongside the detailed design of the development and understanding of how it will be used and occupied. It is not, however, explicit that the monitoring of such design development will not be the responsibility of the planning team to track post- approval.

 

Process was a particular area of concern. While many European countries also have fire safety as part of the planning process they also engage with and require the support or approval of Fire Officers/Brigade at an early stage – not only providing technical support but also practical engagement to resolve approaches that impact on urban design principles including fire truck access, egress and even muster points.

 

There was concern that the consultation could result in a Local Authority planning team being challenged on the Planning Fire Safety Strategy (PFSS), particularly because of the current level of lack of trust between the public and building designers/developers. Through the democratic process, Planning Officers will be able to check a PFSS has been submitted and that it has been prepared by the requisite fire engineer – but have no capacity or skills to be an arbiter of its competency or safety for the community who will live in and around such projects. Potentially objectors will interrogate a PFSS and pick up loose ends or details that are not relevant to the principle of development. It may be naive that such engagement is not envisaged in the consultation. At its most extreme, interrogation of the PFS could open debate about Building Control compliance, which should, we concurred, for the planning and internal detailing of a project, be part of a later iterative work stage.

 

Gordon Roy, Head of Building Control at City of London Corporation, shared his knowledge on the recent appointment of the Building Safety Regulator, the forthcoming Fire Safety Act measures, an updated BS 9991, the increasing role of the Principal Designer and the introduction of Fire Safety Managers. But this consultation document does not clearly set out the road map post planning for clarity and harmonisation of all these new roles and measures and how they will effectively and eventually all work together. Without such a roadmap and with 2-3 years ahead of contradictory guidance in place there will be potential for confusion, for all. Beyond these principal concerns there is much to engage with as the NLA Tall Building and Technical groups progress with the detail of this important consultation.