Water Bill

Written evidence submitted by London Fire and Emergency Planning Authority (WB 31)

1. The London Fire and Emergency Planning Authority (LFEPA) run the London Fire Brigade (LFB) and is a functional body of the Greater London Authority.

2. London’s fire and rescue service is the busiest in the country and one of the largest firefighting and rescue organisations in the world. We provide services across the whole of the Greater London area, serving London’s 8.2 million residents as well as those who work in or visit the city.

3. Around 6,500 staff work for the LFB. This includes over 5,500 operational firefighters, 100 Brigade Control staff dealing with 999 emergency calls and a range of non-operational staff working behind the scenes to deliver support services such as getting fire safety messages across.

4. LFEPA‘s interests in the Bill are around the Water Industry Act (1991) on the topics of hydrants and sprinklers. We belelive the Water Industry Act (1991) could provide more clarity in relation to fire hydrants and their installation in new developmenets and this submission supports that from the Water Liaison Group calling a duty for water undertakers to provide a supply of water for extinguishing fires via service pipes.

Fire hydrants

5. The Fire and Rescue Services Act (2004) require fire authorities to take all reasonable measures to ensure the provision of an adequate supply of water available for use in the case of fire and fire hydrants are the main source of water supply available to the LFB for fighting fires.

6. We suggest that the clause amending section 8 of the Water Industry Act (1991) specifically includes the fire authority appropriate to the area in which the inset appointee has proposed inset sites. This is to allow fire hydrant requirements to be determined at planning stage and the arrangements for their future maintenance.

7. It should be noted that not all fire authorities fall under the governance of the local authority applicable to the area, so should be regarded as a separate body at application.

8. We also propose that the inset appointee enter into agreement with the fire authority regarding apparatus installed and maintained for fire fighting purposes.

Water supply for sprinklers

9. LFEPA has promoted the use of sprinklers for life and property protection as they are very effective in limiting fire spread and fire/water damage. There is clear evidence that sprinklers (and other automatic fire suppression systems) can be effective in helping to put fires out quickly. They can help reduce the numbers of deaths and injuries from fire, reduce the risks to firefighters and the costs of fires and the disruption they cause to the community and businesses. LFEPA’s sprinkler position document is attached at Appendix A.

10. We understand that you have received written evidence from the Water Liaison Group (WLG) and we would like to add our support to their submission in relation to their amendments to Sections 57, 65 and 147 of the Water Industry Act (1991). Namely:

(i) Section 57 be amended to create a duty upon water undertakers to provide a supply of water for extinguishing fires via service pipes. The duty outlined in this section should extend to the supply of water for extinguishing fires supplied via a service pipe to premises, and the means of extinguishing fires may be via manually operated or automatic apparatus;

(ii) Section 65.1(b) be amended to have fire hydrants fixed upon them or connections to equipment installed in any premises for extinguishing fires.

December 2013

LFEPA’s Sprinkler Position Statement


The London Fire and Emergency Planning Authority (LFEPA) is committed to reducing the impact of fire on people, property and the environment. There is clear evidence that sprinklers and other forms of automatic fire suppression systems (AFSS) can be effective in the rapid suppression of fires and can therefore play an important role in achieving a range of benefits for both individuals and the community in general. This is because sprinklers can significantly help to:

Reduce death and injury from fire

Reduce the risks to fire-fighters

Protect property and heritage

Reduce the effects of arson

Reduce the environmental impact of fire

Reduce fire costs and the disruption to the community and business

Permit design freedoms and encourage innovative, inclusive and sustainable architecture

LFEPA plays a key leadership role in promoting better understanding of the benefits of sprinklers and, accordingly works to encourage building owners and developers to install these systems where there is a risk-based case for doing so, for example, where the risks to people are unacceptably high, or where there is a clear business case in terms of cost and benefit.

While sprinklers play a positive role in reducing the human impact and economic and environmental cost of fire in any building they are installed in, we believe that our focus should be directed to those properties where the most significant impact can be achieved: Schools, Residential Care Homes, Domestic Premises housing the most vulnerable and Commercial Premises that present a significant risk due to their size, construction or use.


The importance of sprinklers in schools has been recognised for many years. The latest reports suggest that these fires are getting bigger and more costly. The impact of these fires is significant, not just in financial terms, but also in terms of the devastating effect on the communities they serve, the environment and the disruption to students, teachers and families. The effects on children’s education are not confined to lost course work but often include longer travelling times, disrupted social groups and poorer facilities.

If sprinklers are considered at the design stage of building a new school or the refurbishment of existing buildings, the costs can be kept to a minimum (as low as 1% of build costs). By engaging with designers and architects schools could be designed to inspire learning, address the broadening requirements being placed upon them as community resources and incorporate this essential fire safety system as standard.

To this end we continue to work with schools, colleges and education authorities to ensure that the benefits of sprinklers are fully considered. In new and refurbished schools we expect that the Department for Children, Schools and Families risk assessment tool and policy are used and that sprinklers are installed when recommended.

Residential Care Homes 

Fire death and injury data indicates that those most at risk are younger people, older people, people with mental health problems, and particularly those with mobility problems who are unable to leave buildings easily. We therefore consider that all residential care homes should be fully fitted with sprinklers for the protection of residents from fire. In Scotland there is already a requirement within Building Standards for all new build residential care buildings to have automatic fire suppression systems installed and we strongly advocate that this should be the case in London.

Domestic Premises 

Fires in the home still account for the greatest number of fire deaths and injuries each year and therefore the installation of sprinklers in domestic premises would have a significant impact in reducing these. While it would be ideal for all domestic premises to have sprinkler systems installed, we realise that this is neither practical nor realistic. We therefore advocate that in those domestic premises where our most vulnerable residents live sprinklers should be fitted, in addition to smoke alarms, as this would further reduce the risks.

To achieve this we are working in partnership with developers, the London boroughs and social housing landlords to encourage the installation of sprinklers in the homes of the most vulnerable people either by retro-fitting them where possible, or as part of the construction of new builds .

It is important that we use our influence to ensure that new housing and other social infrastructure projects consider the benefits of sprinklers. To this end we seek to work closely with the GLA, the Mayor and planning authorities in order to influence building, planning, design and development at every stage so that the benefits of automatic suppression can be considered before the design and costing decisions are so far advanced that it is too late to include sprinklers.

Commercial Premises 

There are a range of thresholds which already require sprinklers to be fitted in some types of commercial premises by national building regulations. These are further enhanced in some parts of London where Section 20 of the London Buildings Act 1939 applies, e.g. Section 20 requires a new hotel construction of 25 metres in height to have a sprinkler system installed if it has a floor area greater than 930m². There is no requirement however to sprinkler this type of building of any height under national building regulations. In general however, these requirements are still much greater than in other parts of Europe where sprinklers are required for much smaller sizes of building.

Irrespective of size however there is a compelling case to be made for sprinklers in any commercial premises on the basis of loss of production or interruption to business, as this is a real impediment to business continuity and productivity. It is a recognised fact that 85% of small and medium businesses that suffer a serious fire either never recover or cease trading within 18 months. The installation of sprinklers in these types of premises will aid growth in the economy as fewer businesses will cease to trade, losses due to fire will reduce and fewer businesses will be forced to relocate often destabilising and affecting whole communities.

Major new developments and future proofing 

It is recognised that even with our best efforts we will not be successful in persuading developers to install sprinkler systems in every case, however there are still benefits to be gained in future-proofing the building by including basic sprinkler infrastructure (for example adequate supply pipework), so that sprinklers can be more easily retrofitted if there is a significant increase in risk.

New and Refurbished Buildings 

Where new developments are being considered and when significant refurbishment and upgrade of an existing building is being planned, especially involving buildings with vulnerable people we strongly advocate the installation or retrofitting of sprinklers. In older buildings, built to an earlier standard, the level of risk may no longer be acceptable and in these cases we also advocate the retrofitting of sprinklers to overcome these risks.

Design Freedoms 

Even where not required by building regulation guidance we strongly support the inclusion of sprinklers to achieve the many benefits they provide. We also encourage developers to use sprinklers to allow design freedoms where it can be demonstrated that there is an equivalent level of safety and that the functional requirements of the regulations are met.

In today’s challenging built environment there is a will and a motivation to construct innovative and aesthetically exciting buildings that often require design solutions that depart from traditional fire safety approved codes of practice. The application of a performance-based approach using more specialised building codes, for example the BS7974 series or BS9999, allows stakeholders to demonstrate that sprinklers can offer an equivalent level of fire protection and life safety, resulting in greater freedom to fulfil their overall vision for such buildings. The installation of sprinklers allows for such flexibility and includes such features as:

Larger compartment sizes

More open spatial designs

Extending travel distances

Reducing exit door widths

Reducing periods of fire resistance to elements of structure

Reducing space separation constraints for example, distances between buildings

Reducing design fire size allowing for alternative smoke management strategies

Overcoming fire fighting access constraints

Allowing more flexible building management plans for the end user

We continue to encourage and support proposals for such design freedoms for both commercial and residential developments where it can be robustly justified that the functional requirements of the building regulations can be met.

Preventing damage to the environment 

Sprinklers can increase the sustainability and life expectancy of buildings by limiting fire development and significantly reducing the amount of smoke, CO² & other pollutants. Because only the sprinkler head or heads immediately above the fire actuate, less water is used and there is a significant reduction in the amount of water run off carrying pollutants into the water system.

Affordability of sprinklers 

One of the perceived barriers to the more widespread use of sprinklers is the initial cost of the system, even when a cost benefit analysis has shown sprinklers to be beneficial through the lifetime of the building. Through our involvement in standard setting forums we support the development of new and innovative suppression systems and encourage the provision of cost effective water supplies.

Communication & Public Education 

We are developing our communication methods in order to increase our influence with decision makers and stakeholders at every level about the benefits of the more widespread use of sprinklers based on the many benefits above, as well as educating them where misconceptions exist relating to the facts and performance of sprinklers. Our target audience will include:

Architects and designers

Developers and associated consultants

Researchers, trade associations, and manufacturers

Building control and approving authorities

National/Local Government departments, policy makers, and forums

Social and private landlords


Water authorities/providers

Building occupiers/users

The general public

By improving communications and working with these audience groups we continue to promote better understanding of sprinklers as an effective and reliable fire protection measure, be it from specific local development projects to national initiatives and legislative frameworks. 

Prepared 18th December 2013