Update 2020-09-01: Although the term ‘Vulnerable People’ remains unaltered, I considered it wise, and very necessary bearing in mind the obvious myopia in the mainstream health, safety and design worlds … clearly demonstrated by the 2017 Grenfell Tower Fire in England, and this current CoronaVirus / CoVID-19 Global Pandemic … to include references to specific social groups …
Vulnerable People: Those people – in a community, society or culture – who are most at risk of being physically, psychologically or sociologically wounded, hurt, damaged, injured, or killed … and include, for example, people with disabilities, young children, people with health conditions, frail older people, women in late pregnancy, refugees, migrants, prisoners, the poor, and homeless.
2020-07-20: So many diverse design disciplines and interested groups are involved in the realization, operation and maintenance of a Safe, Inclusive, Resilient and Sustainable Human Environment (built, social, economic, virtual, and institutional) … that the use of simple, easily assimilated language and precise, harmonized technical terminology must be widely exercised. For the effective application of Building Information Modelling (BIM), this is particularly important.
And concerning Fire Engineering, it is not clear when the practice began, but defining a concept simply in terms of performance in a ‘standard test fire’ is entirely inadequate, and fails to explain the actual meaning of the concept.
This Terminology … a body of particular terms, each explaining and defining a single concept, covering inter-related building requirements, e.g. human health, accessibility and fire safety for all, firefighting, social rights, design, performance monitoring, and facility management … takes account of:
Sustainability Impact Assessment (SIA)
WHO International Classification of Functioning, Disability and Health (ICF)
Universal Declaration of Human Rights (UDHR)
U.N. Convention on the Rights of Persons with Disabilities (CRPD)
Fire Engineering Terms … take account of the ‘realistic’ end condition, i.e. a real fire in a real building which is occupied or used by real people with varying behaviour and abilities in relation to self-protection, independent evacuation to an external place of safety remote from a fire building, and active participation in a building’s Fire Emergency Management Plan.
General Terms … are also included in order to facilitate a better understanding of:
the complexity of human behaviour and perception (visual, auditory, olfactory, gustatory, tactile and proprioceptive) ;
the wide range of health conditions ; and, more specifically
2020-03-23: The Grenfell Fire Inquiry’s Phase 1 Recommendations (Part V in Volume 4 of the Phase 1 Report), were published on 30 October 2019. The initial issues covered in those Recommendations are fragmentary, lack depth and coherence … and in the case of Fire Alarms, with just one indirect reference to them in Paragraph #33.22 … they are in serious error …
[ Paragraph #33.22 ] There were no plans in place for evacuating Grenfell Tower should the need arise. I therefore recommend:
d. that all high-rise residential buildings (both those already in existence and those built in the future) be equipped with facilities for use by the fire and rescue services enabling them to send an evacuation signal to the whole or a selected part of the building by means of sounders or similar devices ;
FUNDAMENTALS OF A SOLUTION
1. A Fire Alarm (more precisely from here on, a Fire Detection & Warning System) is a critical safety feature in all buildings … ALL BUILDINGS … from the smallest and most simple, to the biggest and most complex … no exceptions !!
In order to survive in a fire emergency, Vulnerable Building Users need more time to react, and evacuate, than other occupants/users. The valuable time provided by early, accurate and precise detection is the only way to effectively facilitate this. The ‘Required Time’ to prepare for evacuation depends on many factors, e.g. building complexity, familiarity of users with evacuation routes, range and severity of user activity limitations, etc.
It follows, therefore, that if building occupants/users have to wait 15, or 20, or 30 minutes before firefighters arrive at the fire scene (Full Response Time*) and ‘an evacuation signal to the whole or a selected part of the building’ is only then sent by those firefighters … all of that valuable evacuation time for vulnerable building users has been lost. This is ridiculous, and makes no sense whatsoever. This Recommendation must be rejected out of hand, and ignored !
[ *Full Response Time: The time interval from the receipt of an emergency communication at the primary public safety answering point (#PSAP) to when emergency response units are initiating action or intervening to control a fire incident. ]
Important Note: In Chapter #34: ‘Looking Ahead to Phase 2’ of Moore-Bick’s Phase 1 Report, Volume 4 … Paragraph #34.14 states …
A question was raised about the width of the stairs, given that they provided the sole means of access to the upper floors of the tower for firefighters as well as the sole means of escape for the occupants. However, the stairs appear to have complied with requirements of the legislation in force at the time of their construction and the expert evidence supports the conclusion that they had sufficient capacity to enable all the occupants of the building to escape within a reasonable time. This aspect of the building will not, therefore, be the subject of further investigation in Phase 2.’
Astounding ! Absurd !! FUBAR !!!
All Fire Emergency Warning Systems must be designed to accommodate People with Hearing Impairments. Audible and visual warning devices must be provided together, as a single combined unit. This is particularly important in noisy and isolated building spaces, e.g. bathrooms, small meeting rooms. Vibrating devices, such as pagers or mobile phones, can be integrated into a building’s fire emergency warning system in order to provide any individual with a tactile emergency alert.
Important Note: Audible sounders, on their own, are never a sufficient Fire Emergency Warning !
2. The Purpose of a Fire Emergency Warning System is to provoke calm, efficient and adaptable evacuation movement by ALL building users/occupants at the earliest possible stage in a fire incident, without causing user confusion, disorientation or panic. In all building types, therefore, a reliable, informative and accessible fire emergency warning system must be installed, and such a system must always have a fire protected electrical supply.
3. To provoke a Calm Response from Building Users … the output from Fire Emergency Warning Devices, e.g. light, sound and messages, must be adapted to the local context of people and building surroundings.
Fire Emergency Audible Warnings … A sufficient number of low-output audible sounders, i.e. between 60-80 dB, must be specified for effectiveness. Small numbers of sounders with high output (in order to reduce costs) should never be specified, as this can lead to confusion, disorientation and panic attacks among some building users/occupants. The output of sounders must be adapted to suit interior surroundings, e.g. in small spaces with hard surfaces a lower sound output will be adequate.
Important Note: When they are asleep, hearing-able children (around ten years of age and under) … and hearing-able older people (around 65 years of age and over) are more difficult to wake and rouse sufficiently for evacuation when alerted by an audible signal alone.
Fire Emergency Visual Warnings … Light strobes/beacons must be clearly visible. To reinforce #1 above … light strobes/beacons must be placed in wash rooms and in other locations within buildings where people may be alone ; they must also be placed in noisy environments.
A sufficient number of low-output strobes/beacons must be specified for effectiveness. Small numbers of strobes/beacons with high output (in order to reduce costs) should never be specified, as these produce a glare which may cause confusion, disorientation and panic attacks among some building users/occupants. The light output of strobes/beacons must be adapted to suit interior surroundings, e.g. in dark rooms.
For light strobes/beacons, a slow rate of flash is important, i.e. no faster than once every two or three seconds, in order to encourage a calm response from building users/occupants and to avoid photosensitivity seizures. Most importantly, the flash of one strobe/beacon must be synchronized with the flashes of all other light strobes/beacons in view.
Fire Emergency Voice Message Warnings … Are essential to improve Warning Credibility. In other words, building users are far less likely to sit around wondering, waiting to see whether this is a ‘real’ fire emergency, a false alarm, a practice evacuation, or an electrical error. Verbal or voice messages must be short and contain appropriate warning information which is easily assimilated. The speaker should be distinct and easy to understand. Live messaging during a fire emergency is preferred over pre-recorded, standard messages. In today’s multi-cultural social environment, messages must be transmitted in at least two to three different languages, as appropriate.
Fire Emergency Directional Warnings … Combination sounder, visible strobe/beacon, and voice messaging Fire Emergency Warning Devices are now a mainstream technology, are readily available, and are being specified in new and existing buildings.
Audible directional signalling must be installed when dealing with difficult building configurations, e.g. in large open office layouts/spaces with minimal signage … where building users/occupants are unfamiliar with their surroundings in modern shopping centres/malls and other complex building types … or visibility of high-level signage may be reduced because of smoke logging.
Directional sounders, which guide building users during a Fire Evacuation towards Exits, Areas of Rescue Assistance and Lift/Elevator Lobbies, must be positioned at carefully chosen, suitable locations. Once reached, a directional sounder must also have a voice messaging capability in order to inform people about the next phase of evacuation.
4. Fire Emergency Warning Systems must be Accessible (for People with Activity Limitations), i.e. capable of transmitting a warning in many formats in order to ensure that all users/occupants perceive and act upon the warning in a calm manner and, thereafter, that effective evacuation movement commences without delay. Warning Credibility improves in direct relation to the type and number of different warning formats.
As well as indirectly referring to Fire Detection and Warning Systems, Paragraph #33.22 in Moore-Bick’s Phase 1 Recommendations has some other things to say about Evacuation. So this is an opportune moment to discuss some practical and human issues concerning Fire Emergency Evacuation … and, straight away, to deal with an unexpected consequence arising from the current CoronaVirus/CoVID-19 Emergency …
CoronaVIRUS / CoVID-19 PANDEMIC
There have been widely reported instances, in many countries, of panic buying in shops because of the 2020 CoronaVirus/CoVID-19 Emergency … but the photograph below illustrates an example of a panic reaction by building management. This appears to be a crime scene … the yellow and black tape is so dramatic. In a real Fire Emergency, many building users/occupants will be reluctant to use this final fire exit ; they will not have the time to read the small print on a notice ; they will attempt to re-trace their path of evacuation and find another exit.
This panic reaction by building management IS a serious impediment to Fire Evacuation !
Whatever the Motives of Building Management …
in countries which have Fire Codes / Regulations, this action is illegal ; and
in these days, when a wide range of ‘smart’ technologies is readily available … this action is inexcusable.
SOME PRACTICAL FIRE EVACUATION ISSUES
A Skill is the ability of a person, resulting from competent training and regular practice, to carry out complex, well-organized patterns of behaviour efficiently and adaptively, in order to achieve some end or goal. All building occupants/users must be skilled for evacuation to an external ‘place of safety’, which is at a safe and remote distance from the fire building. Practice fire evacuations must be carried out sufficiently often to equip building users, particularly vulnerable users, with this skill, i.e. at least once every six months ; in complex building types, practices should be carried out more often. Prior notification to occupants/users, and regular scheduling of practice evacuations should be avoided.
Familiarity with Fire Evacuation Routes will be fostered and greatly improved by means of normal, everyday use by occupants/users. This is an important task for pro-active Building Management in existing buildings … and an important aspect of new building design for Architects and Fire Engineers.
While the transmission of fire emergency warnings in many formats will increase Warning Credibility, close observation of past tragic ‘real’ fire events, e.g. the WTC 9-11 Attacks in New York City, shows that initiation of evacuation and the actual process of evacuation itself can be problematic. An interesting, easily assimilated and user-targeted skills programme of training should incorporate practical solutions to deal with the following typical problems:
Fire Emergency Preparedness: Irregular attendance of building occupants/users at fire prevention and safety training sessions, and participation in practice fire evacuations. Users not being familiar with a building’s fire emergency management plan and not knowing who is in charge … not using a building’s fire evacuation route(s), particularly staircases, during practices … or having no information about where to assemble after evacuating … or, once at a place of safety, not having any head count or identification process ;
Delaying Activities Inside The Fire Building: Once building occupants/users decide to evacuate, but before moving to evacuate, they gather personal effects … seek out friends/co-workers … search for others … make phone calls/send tweets … finish tasks/turn off computers … wait around for instructions … change shoes … and try to obtain permission to leave ;
Delaying Activities Outside The Fire Building: Once outside the building’s final fire exit, but before moving directly to a place of safety, building occupants/users stop to see what is happening … look for friends/co-workers … look for a phone … do not know where to go … or, within the ‘danger zone’ of the fire building, stop to receive medical attention.
It may seem obvious that Fire Evacuation Routes must also be Accessible (for People with Activity Limitations), which also makes routes much safer for every other building user … and sufficiently wide to accommodate Contraflow (emergency access by firefighters or rescue teams into a building and towards a real fire, while building users are still moving away from the fire and evacuating the building) … a harsh lesson learned from the 2001 WTC 9-11 Attacks and the 2017 Grenfell Tower Fire. Since they are new, strange and unusual for many building designers, and most fire engineers … these aspects of building performance are overlooked in nearly every building.
Practice Evacuations should include exercise of the buddy system ; fire safety fittings, e.g. portable fire extinguishers ; and fire evacuation devices intended for use by people with activity limitations which will require more intensive training.
Important Note: During fire emergencies, People with Activity Limitations must be permitted to keep possession of their own personal Facilitation / Mobility Aids.
SOME HUMAN FIRE EVACUATION ISSUES
The actual people who use and occupy buildings are individuals. They are different from each other, and they each have a different range of abilities (in relation to self-protection, independent evacuation to an external place of safety remote from a fire building, and active participation in a building’s fire emergency management plan), behaviour and manner of perceiving their surroundings. Two apparently similar people will also show variations in how they react to and behave in any specific situation, particularly a fire emergency.
Ability / Disability is a Continuum – a gentle gradient on which every person functions and acts at different levels due to personal and environmental, i.e. external, factors.
In situations of severe stress, e.g. during a fire emergency in a building, where there is a lack of preparedness for such an event, a lack of familiarity with evacuation routes, lack of reliable evacuation information, lack of competent leadership and clear direction, and the presence of smoke, user/occupant confusion, disorientation and panic will occur. Standard evacuation movement times will also be non-existent. In addition, people with activity limitations must then deal with many physical barriers which routinely impede their evacuation from buildings, e.g. fire resisting doorsets which are difficult to open, steps along evacuation routes and at final fire exits.
In the case of people with a mental or cognitive impairment, there is a particular need to encourage, foster and regularly practice the adaptive thinking which will be necessary during evacuation a real fire incident.
People with respiratory health conditions will not be able to enter or pass through smoke. People with visual impairments will require continuous, linked tactile and/or voice information during the whole process of fire evacuation. People with psychological impairments, i.e. vertigo and agoraphobia, will be unable to use fire evacuation staircases with glass walls in high-rise buildings. Because of the stigma still associated with disability in many countries, some users/occupants who will need assistance during a fire emergency will be reluctant to self-identify beforehand. Other people may not even be able to recognize that they have an activity limitation or a health condition.
Meaningful Consultation with a person known to occupy or use a building, for the purposes of receiving his/her active co-operation and informed consent (involving a personal representative, if necessary), is an essential component of adequate pre-planning and preparation for a fire emergency.
Building Designers, Fire Engineers and Firefighters should be aware of the following human conditions:
Agoraphobia: A fear of open spaces.
Commentary: Agoraphobia is one of the most commonly cited phobic disorders of people seeking psychiatric or psychological treatment. It has a variety of manifestations, e.g. a deep fear of leaving a building, or of being caught alone in some public place. When placed in threatening situations, agoraphobics may experience a panic attack.
Anosognosia: A neurological disorder marked by the inability of a person to recognize that he/she has an activity limitation or a health condition.
Dementia: Any degenerative loss of intellectual capacity, to the extent that normal and occupational activities can no longer be carried out.
Panic: A sudden overwhelming feeling of anxiety, which may be of momentary or prolonged duration.
Panic Attack: A momentary period of intense fear or discomfort, accompanied by various symptoms which may include shortness of breath, dizziness, palpitations, trembling, sweating, nausea, and often a fear by a person that he/she is going mad.
2019-11-11:Kensington and Chelsea’s wilful disdain for the Health, Safety and Welfare of ALL the residents within its functional area … and knowing neglect of its legal and ethical Duty of Care towards ALL … resulted in a significant number of people with activity limitations living high up in Grenfell Tower prior to June 2017 … in spite of the now incontrovertible fact that, in the event of a fire emergency, many would be left behind … to die.
‘All human beings are born free and equal in dignity and rights.’
Article 1, 1948 Universal Declaration of Human Rights
London Fire Brigade was an easy target for the Grenfell Fire Inquiry’s Phase 1 Report, made all the more so following some careless, insensitive and ignorant public comments by its Commissioner, Dany Cotton. However, we must clearly distinguish between the behaviour of LFB’s Frontline Firefighters, who were brave and dedicated despite inadequate training, and lack of proper equipment, back-up resources and personnel strength … and LFB’s Senior Commanders … which is another matter.
In England … there is widespread indifference, and some rabid resistance, to answering the desperate needs, and mitigating the agonizing plight, of Vulnerable Building Users during fire emergencies … which includes people with activity limitations, children under 5 years of age, frail older people (not All older people !), women in late stage pregnancy, people with disabilities, refugees, migrants, the poor, and people who do not understand the local culture or cannot speak the local language. British National Standard B.S.9999 (not solely those sections previously contained in B.S.5588:Part 8) and England’s National Building Regulations – Approved Document B: ‘Fire Safety’ – offer only token, i.e. inadequate, protection for vulnerable people in fire emergencies. When a senior representative of BSI, the British Standards Institution, was directly approached by me, and requested to open up B.S.9999 for meaningful updating … the answer was a firm “NO” ! The same attitude is deep-seated among fire research organizations in the country, and among people who develop computer fire evacuation models.
Grenfell Fire Inquiry’s Phase 1 Recommendations – Chapter #33
After hearing the first media reports about the tough Recommendations aimed at London Fire Brigade, I had naturally expected that the other Phase 1 Recommendations would be equally as tough. But NO … they are far from comprehensive … they are fragmentary, lack depth and any sort of coherence. Specifically with regard to Vulnerable Building Users, the Recommendations are pathetically and disgracefully inadequate !
And in case there is any doubt, the status quo in England – and to be fair, in many other countries as well – is entirely unacceptable !!
Few people realize that the fire safety objectives in current fire regulations/codes are limited and constrained. To implement changes to the flawed regulations in England, it will take many years … and, based on recent past history, implementation will be incomplete and unsatisfactory. Residents in high-rise buildings, whether public or private, must no longer wait in vain for this to happen. Instead, the time has arrived to become proactive, and to immediately initiate their own comprehensive programmes of Self-Protection In Case Of Fire … which go far and beyond the pathetic Recommendations in Moore-Bick’s Phase 1 Report.
Fires Similar To Grenfell Tower Are Frequent
[ Paragraph #33.5 ] … although not unprecedented, fires of the kind that occurred at Grenfell Tower are rare.
[ Response ] Not true … misleading, and a complete fallacy !
Just since 2010, fires similar to Grenfell Tower have occurred in South Korea, many in the United Arab Emirates, France, Chechnya, Australia, Azerbaijan, Russia, and most recently in Turkey. Each one of these fires has been recorded and illustrated on our Twitter Account: @sfe2016dublin. Seeing, and understanding, this striking pattern of unusual fire behaviour … a competent person would react and plan accordingly.
Effective Fire Compartmentation Is A Delusion … A Fantasy !
[ Paragraph #33.5 ] Effective compartmentation is likely to remain at the heart of fire safety strategy and will probably continue to provide a safe basis for responding to the vast majority of fires in high-rise buildings.
[ Response ] Not true … demonstrates a fundamental flaw in European fire safety strategizing !
In an environment of lax or non-existent compliance monitoring … the quality of architectural/fire engineering design and the reliability of related-construction will both, inevitably, be poor and unacceptable. Fire loads in today’s residential buildings are also far higher than a generation ago, for example, because of more electrical/electronic equipment and synthetic furnishings. And whatever about first-built, i.e. whether it’s good, bad or ugly, later alterations and other construction work will typically compromise the original performance of fire resisting doorsets and service penetration fire sealing. Modern ‘green’ building materials and construction methods are further aggravating these problems. A competent person would be aware of fire research at the UL Laboratories, in the U.S.A., which confirmed the above developments.
‘ Rigorous enforcement of building codes and standards by state and local agencies, well trained and managed, is critical in order for standards and codes to ensure the expected level of safety. Unless they are complied with, the best codes and standards cannot protect occupants, emergency responders, or buildings.’
U.S. National Institute of Standards and Technology. Final Report on the Collapse of the World Trade Center Towers. NIST NCSTAR 1. 2005.
‘Stay Put’ Policies Are Criminal
[ Paragraph #33.5 ] However, in the case of some high-rise buildings it will be necessary for building owners and fire and rescue services to provide a greater range of responses, including full or partial evacuation. Appropriate steps must therefore be taken to enable alternative evacuation strategies to be implemented effectively.
[ Paragraph #33.15 ]e. that policies be developed for managing a transition from ‘stay put’ to ‘get out’ ;
[ Response ] Too little … and far too late !
[ Solution ] Two fatal fires separated in time and space … the 2009 Lakanal House Fire, in London, and the 2017 Marco Polo High-Rise Apartment Building Fire, in Honolulu, continue to clearly demonstrate that effective fire compartmentation is a delusion. Even if carried out by a competent person … it is not possible to establish with reasonable certainty, by means of a visual/surface building inspection alone, whether or not fire compartmentation is effective in an existing building. The London and Honolulu buildings were not fitted with any active fire suppression system, e.g. fire sprinklers or a water mist system.
Buildings must remain structurally ‘serviceable’, not merely structurally ‘stable’, for a Required Period of Time. See the Presentation Overhead below.
Authorities Having Jurisdiction (AHJ’s), firefighters, client organizations, design teams, and building owners/managers must not, therefore, direct, or even suggest, that any of its building users wait (‘stay put’) in that building during a fire emergency. A competent person always connects building fire performance with its structural performance, and vice versa … and always learns from the evidence of ‘real’ fatal fires.
All Lifts/Elevators Must Be Used For Fire Evacuation
[ Paragraph #33.13 ] When the firefighters attended the fire at Grenfell Tower they were unable to operate the mechanism that should have allowed them to take control of the lifts. Why that was so is not yet known, but it meant that they were unable to make use of the lifts in carrying out firefighting and search and rescue operations. It also meant that the occupants of the tower were able to make use of the lifts in trying to escape, in some cases with fatal consequences.
[ Response ] There is a ridiculous assumption in Moore-Bick’s Phase 1 Report that it is only firefighters who use lifts/elevators during a fire emergency, and that it is dangerous for anybody else to use them.
[ Solution ] In order to adequately protect Vulnerable Building Users … ALL lifts/elevators in a building must be capable of being used for fire evacuation during a fire emergency.
Until such time as firefighters arrive at a building fire scene in sufficient strength and are properly prepared to carry out effective firefighting and rescue operations … Firefighter Lifts/Elevators must be used for the fire evacuation of building occupants/users. Prior liaison and pre-planning with local fire services is always necessary with regard to the use of firefighting lifts/elevators for the evacuation of occupants/users.
A fundamental principle of fire safety design is that there must be alternative, safe and accessible evacuation routes away from the scene of a fire, which can occur in any part of a building during its life cycle ; these evacuation routes must be capable of being used by all building users, including people with activity limitations.
This is why there must always be at least 2 Fire Evacuation Staircases in High-Rise Residential Buildings !
The location of lifts/elevators and lobbies, within peripheral building cores, must always be considered in relation to the position of adjacent fire protected evacuation staircases, which must be easily found by building occupants/users, and the areas of rescue assistance adjoining those staircases.
To be used for fire evacuation, a lift/elevator must be ‘fit for its intended use’, must operate reliably during a fire emergency, and must comprise a complete building assembly which meets specific performance criteria.
A Lift/Elevator Fire Evacuation Assembly is an essential aggregation of building components arranged together – comprising a lift/elevator, its operating machinery, a hard-construction vertical shaft enclosure, and on every floor served by the lift/elevator a sufficiently large, constantly monitored lobby for people to wait in safety and with confidence, all robustly and reliably protected from heat, smoke, flame and structural collapse during and after a fire – for the purpose of facilitating the safe evacuation of building occupants/users throughout the duration of a fire emergency.
If a building is located in a Seismic Zone, Lift/Elevator Fire Evacuation Assemblies which can safely operate during an earthquake must always be specified and installed.
Gravity Evacuation Chair Devices, which are not electrically-powered and operate by gravity, facilitate downward movement, only, on straight flights of stairs. Having descended a staircase, with the user having left his/her wheelchair behind, these devices are not fully stable when travelling the long horizontal distances necessary to reach an external ‘place of safety’ remote from a building, perhaps over rough terrain.
If lifts/elevators in existing buildings undergo a major overhaul, or if they are replaced, they should then be made capable of use for fire evacuation.
Lifts/elevators used for fire evacuation must always have a fire protected electrical supply which is separate from the main building electrical supply, in order to ensure that they can continue to operate without interruption during a fire emergency.
In addition to conventional passive fire protection measures, Lift/Elevator Lobbies must also be protected by an active fire suppression system. Water mist is the preferred fire suppression medium, because it is user-friendly, will not greatly interfere with user visibility, uses far less water compared to water sprinklers, and is also climate-friendly. Furthermore, because people with activity limitations will be waiting for evacuation in lift/elevator lobbies, building designers and managers must ensure that these lobbies are properly fitted out with appropriate fire safety equipment, facilitation aids, smoke hoods, signage and communications, etc., etc.
Proper Use of Personal Emergency Evacuation Plans (PEEP’s)
[ Paragraph #33.22 ]f. that the owner and manager of every high-rise residential building be required by law to include up-to-date information about persons with reduced mobility and their associated PEEP’s in the premises information box ;
[ Response ] There is No Recommendation or explanation in Moore-Bick’s Inquiry Phase 1 Report concerning the ‘what’, ‘why’ or ‘how’ of PEEP’s.
[ Solution ] A Personal Emergency Evacuation Plan is a person-specific and location-specific document, and is an integral part of the overall Fire Emergency Management Plan for a building. It is intended for regular occupants/users who may be vulnerable in an emergency situation, i.e. those with limited abilities in relation to self-protection, independent evacuation to an external place of safety remote from the building, and active participation in the building’s fire emergency procedures.
In new buildings, which are effectively accessible (including fire safe) for all, Personal Emergency Evacuation Plans are not necessary.
In existing buildings, Personal Emergency Evacuation Plans must not be used to limit or restrict access by an individual to any part of a building and its facilities. To ensure this, sufficient accessibility works must be carried out and appropriate management procedures put in place.
In buildings of historical, architectural and cultural importance, where the historical, architectural or cultural integrity of the building must be protected, Personal Emergency Evacuation Plans may limit or restrict access to parts of a building and some of its facilities. Refer to the ICOMOS 1964 International Charter for the Conservation and Restoration of Monuments and Sites.
There are No Recommendations in Moore-Bick’s Inquiry Phase 1 Report concerning these critical issues.
[ Solution ] There are many fire safety problems associated with high-rise and tall buildings. Evacuation by staircases alone can take many hours ; the physical exertion involved in descending even 10 floors/storeys by staircase is too much for many able-bodied people and is impossible for most vulnerable building occupants/users, particularly people with activity limitations. Passive fire protection of staircases, alone and/or supplemented by pressurization to prevent smoke ingress, is far too unreliable. And heavily equipped firefighters cannot be expected to ascend more than 10 floors/storeys by staircase before carrying out arduous firefighting and search/rescue operations. Furthermore, uninterrupted lift/elevator shafts, extending throughout the full height of a tall building, pose a significant risk of uncontrolled fire spread.
A Floor of Temporary Refuge is an open, structurally robust floor/storey in a tall building – having an exceptionally low level of fire hazard and risk, ‘intelligently’ fitted with a suitable user-friendly and climate-friendly fire suppression system, e.g. water mist, and serviced by sufficient accessible, fire protected lifts/elevators capable of being used for evacuation during a fire emergency ; it is designed and constructed to halt the spread of heat, smoke and flame beyond that floor/storey, and is intended as a place of temporary respite, rest and relative safety for building users before continuing with evacuation, and as a forward command and control base for firefighters.
In a high-rise, tall, super-tall or mega-tall building, every 20th floor must be a Floor of Temporary Refuge, even if the building is co-joined with another building, or there are sky bridges linking the building with one or more other buildings.
Special provision must be made, on these floors, for accommodating large numbers of building occupants/users with activity limitations … and because people will be waiting on Floors of Temporary Refuge, perhaps for extended periods of time, building designers and managers must ensure that these floors/storeys are properly fitted out with appropriate fire safety equipment, facilitation aids, smoke hoods, signage and communications, etc., etc.
Conclusion: Fire Engineering Capacity in England is Lacking
In England … the very important 2005 and 2008 U.S. NIST Recommendations following the 9-11 (2001) Attacks on the World Trade Center, in New York City, were completely ignored. Following the 2009 Lakanal House Fire, in London, the 2013 Coroner’s Recommendations were only partially implemented.
With regard to Vulnerable Building Users … there is NO capacity within the English Fire Establishment, including the National Fire Chiefs Council (NFCC), English Authorities Having Jurisdiction (AHJ’s), and its Building Design and Fire Engineering Communities … to properly respond to … never mind understand … the Fire Safety, Protection and Evacuation for ALL in Buildings.
2019-04-08: A much needed ‘quickie’ for these worrisome times … a reminder for spineless politicians and an introduction for mindless citizens !
This is the United Nations …
And these are Articles 13, 14 and 15 of the Universal Declaration of Human Rights … a fundamental constitutive document of the United Nations … which was adopted by the U.N. General Assembly, on 10 December 1948:
Everyone has the right to freedom of movement and residence within the borders of each State.
Everyone has the right to leave any country, including his/her own, and to return to his/her country.
Everyone has the right to seek and to enjoy in other countries asylum from persecution.
This right may not be invoked in the case of prosecutions genuinely arising from non-political crimes or from acts contrary to the purposes and principles of the United Nations.
Everyone has the right to a nationality.
No one shall be arbitrarily deprived of his/her nationality, nor denied the right to change his/her nationality.
I was very pleased to make a Presentation at both events, adapted to suit an Irish context, on … ‘Sustainable Fire Engineering – Necessary Professional Transformation For The 21st Century’ … which continues to evolve.
Sustainable Fire Engineering: The creative, person-centred and ethical Fire Engineering response, in resilient built form and smart systems, to the concept of Sustainable Human and Social Development … the many aspects of which must receive synchronous and balanced consideration !
Annual Fire Losses, both direct and indirect, amount to a very significant percentage of Gross Domestic Product (#GDP) in all economies, whether they are rich or poor … and result in enormous environmental devastation and social disruption. Some losses have not yet been fully identified, e.g. environmental impact … while others are not yet capable of being fully quantified, e.g. business interruption, brand and reputation damage. Globally, fire statistics still remain unreliable. In all cases, however, the waste of valuable human and natural resources caused by preventable fires is unsustainable and no longer acceptable.
From an entirely different perspective … Sustainable Buildings are presenting every society with an innovative and exciting re-interpretation of how a building functions in response to critical energy, environmental, climate change and planetary capacity pressures … an approach which has left the International Fire Engineering and Firefighting Communities far behind in its wake, struggling to develop the necessary ‘creative’ and ‘sustainable’ fire safety strategies.
The Aim of Sustainable Fire Engineering (#SFE) is to dramatically reduce direct and indirect fire losses in the Human Environment (including the social, built, economic, virtual, and institutional environments) … to protect the Natural Environment … and, within buildings, to ensure that there is an effective level of Fire Safety for All Occupants, not just for Some, over the full building life cycle.
The following Priority Themes for SFE lie outside, or beyond, the constrained and limited fire safety objectives of current fire regulations, codes and standards – objectives which do not properly protect society, a fire engineer’s clients, or the facility manager’s organization:
Fire Safety for ALL, not just for Some. Nobody left behind !
Firefighter Safety. Everyone goes home ! It is easy to dramatically improve firefighter safety with building design. So, why haven’t NIST’s 2005 and 2008 WTC 9-11 Critical Recommendations been properly implemented anywhere ?
Property Protection. Fire damage and post-fire reconstruction/refurbishment are a huge waste of resources. On the other hand, protection of an organization’s image/brand/reputation is important … and business continuity is essential. Heritage fire losses can never be replaced.
Environmental Impact. Prevention of a fire is far better than any cure ! But prevention must also begin by specifying ‘clean’ technologies and products. Low Pressure Water Mist Systems are not only person/environment-friendly and resource efficient … they are absolutely essential in airtight and hyper energy-efficient building types (e.g. LEED, PassivHaus, BREEAM) in order to achieve an effective level of fire safety for all occupants, and firefighters. [ Note: Environmental Impact Assessment (#EIA) has been superseded by Sustainability Impact Assessment (#SIA).]
Building Innovation, People and Their Interaction. Fire engineers and firefighters must begin to understand today’s new design strategies.
Sustainable Design and Engineering. Wake up and smell the coffee ! Legislation can only achieve so much. Spatial planners, building designers and fire engineers must subscribe to a robust Code of Ethics * which is fit for purpose in the Human Environment of the 21st Century.
Sustainable Fire Engineering Solutions are …
Adapted to a local context, i.e. climate change/variability/extremes, social need, geography, economy, and culture, etc ;
Reliability-based – lessons from real extreme and hybrid events, e.g. 2001 WTC 9-11 Attack, 2008 Mumbai/2015 Paris/2016 Brussels Hive Attacks and the 2011 Fukushima Nuclear Incident, are applied to frontline practice ;
Person-centred – real people are placed at the centre of creative endeavours and due consideration is given to their responsible needs, and their health, safety, welfare and security in the Human Environment ;
Resilient – functioning must be reliable during normal conditions, and include the ability to withstand, adapt to and absorb unusual disturbance, disruption or damage, and thereafter to quickly return to an enhanced state of function.
Long before the Rest of the World was introduced to the term Fire-Induced Progressive Damage, in the late afternoon of 11 September 2001 (WTC 9-11), with the collapse of World Trade Center Building No.7 in New York City …
… decades earlier … Noel Manning had intuitively discovered the same Structural Fire Engineering Concept … and had developed and tested a suite of domestic-scale building systems to deal with this very dynamic aspect of fire behaviour …
The International Fire Engineering Community is still shy about discussing this concept, never mind understanding it … and most importantly, solving it ! Which makes me seriously wonder … is there a deep-seated flaw in International Fire Research ? Are mainstream Fire Researchers more interested in sourcing funding than in actually solving ‘real’ world fire engineering problems ???
And I also wonder … why have the 2005 and 2008 NIST (USA) WTC 9-11 Recommendations on the WTC Building Collapses still not been properly implemented within the USA … and why have they been ignored everywhere else ?????
At this time, in London … multiple, fragmented investigations are taking place into the actual fire incident … the role of the Local Authority, and building management … those involved in the refurbishment (‘tarting up’) design and construction … the fire services, particularly their ‘Stay Put’ Policy and how it adversely impacted on vulnerable Tower occupants during the emergency … and the highly flawed regulatory model of Building and Fire Codes with light-touch Control, which is still operating in England. One of Murphy’s Laws immediately springs to mind with regard to the intended ineffectiveness of this overly-complex process !
Many other countries have adopted some or all of this modern English regulatory model which, after the repeal of an older Bye-Law format, has been shaped by political expediency, cost-effectiveness and general ineptitude … with little or no adaptation to local conditions in the adopting jurisdictions. Ireland adopted this model with some, but not a lot, of adaptation.
Fire Safety In Ireland ?
On 6 June 2018 … while that investigative activity was hitting the headlines in England … Minister Eoghan Murphy, T.D., Ireland’s Minister for Housing, Planning and Local Government, quietly published the Report: ‘Fire Safety in Ireland’ … http://www.housing.gov.ie/local-government/fire-and-emergency-management/fire-safety/eoghan-murphy-publishes-report-fire … by a High-Level Task Force within his Department’s National Directorate for Fire and Emergency Management, after serious concerns and fears had been expressed in the public media that a similar fire tragedy might also occur in this jurisdiction.
To be crystal clear … this Report is a Bureaucratic Whitewash … an insult to the Public ! Nice sounding technical ‘blarney’ camouflages a failure to deal directly with critical issues, and answer concerns … while other important issues are avoided altogether.
.May 2018 – Ireland’s Department of Housing, Planning & Local Government Report
Expanding on my comments in the Interview with Barry Lenihan, on RTE Radio 1’s Drive Time early evening news programme on Friday (2018-06-08) …
A. Initially, Irish Local Authorities were requested to carry out a preliminary survey to identify all buildings of more than six storeys, or 18m in height. Specifically, they were asked to identify those buildings which had an external cladding system which might be a cause for concern.
This height threshold of six storeys/18m is arbitrary … an external cladding system can be just as much a cause for concern in a building which is lower. Imagine discarded cigarette butts or a rubbish fire at the base of such a system … and the resulting speed of fire spread and development across a building façade !
B. The highly flawed regulatory model of Building and Fire Codes, with light-touch Control, which resulted in the Grenfell Tower Fire Tragedy … we also have. Wake up and smell the coffee Ireland !
At the beginning of the 1990’s, when Ireland had been persuaded by the European Commission to finally introduce legal, national building regulations having a functional format … our National Authority Having Jurisdiction, in desperation, grabbed the then Approved Documents for England & Wales … brought them back to Ireland, put Irish covers on them, and originally called them ‘Technical Documents’ … but, after seeing a tiny ray of inspiring light, later changed their title to the more accurate ‘Technical Guidance Documents’ ! This hunger for adopting all things English which are fire safety related continues to this day … with a similar, ongoing division of Technical Guidance Document B: ‘Fire Safety’ into 2 Separate Volumes.
This may have been a convenient response under pressure … but it has been very short-sighted. It has impeded the growth of a comprehensive and coherent philosophy on Safe, Inclusive, Age-Friendly, Resilient, Sustainable Planning, Design and Construction Codes/Controls which is suited to an Irish context and responsible local needs (not desires!).
C. Everywhere … this Report has a lot – too much – to say about Fire Risk Assessment ! After the Grenfell Tower Fire, however, Fire Risk Assessments must only be carried out by competent persons … and the process of Fire Risk Assessment, itself, must be radically improved ! And of course, prior to any Risk Assessment … a proper Fire Hazard Appraisal must be carried out.
D. To accurately present Fire Safety Trends in Ireland … it is not enough to furnish reliable fire fatality statistics. It is also necessary to produce reliable fire injury statistics … and reliable information on direct/indirect socio-economic losses.
E. The quality of fire safety related construction on Irish Building Sites continues to be very poor and problematic. Fire Compartmentation is nowhere near being adequately – never mind acceptably – reliable ! And during the last few years we have had quite a number of close-calls concerning fire incidents in medium-rise residential buildings.
F.Fire Evacuation for people with activity limitations is still handled atrociously in our current building regulations. This is ironic because, on 20 March 2018 last, Ireland had to be dragged screaming to ratify the U.N. 2006 Convention on the Rights of Persons with Disabilities (CRPD) !
Positive Progress By Another Path !
1. Abandon the outdated English functional requirements in THEIR building regulations … and adopt a far better, more up-to-date body of functional requirements which is already on the Irish Statute Books … Annex I of the European Union’s Construction Products Regulation 305/2011. And because there are important horizontal linkages between requirements … immediately finish the ridiculous current separation between Fire Safety requirements and all of the other requirements. And yes … new Technical Guidance Documents will have to be drafted.
.Regulation (EU) No 305/2011 of the European Parliament and of the Council, of 9 March 2011, laying down harmonized conditions for the marketing of construction products and repealing Council Directive 89/106/EEC
2. Yes … ‘Persons Having Control’ of buildings have responsibilities with regard to fire safety. But that is only one side of the coin ! National and Local Authorities Having Jurisdiction have greater responsibilities.
If we are at all serious about Consumer Protection … bad, inadequate, faulty construction must be prevented beforehand … it is too late, too costly and, in many cases, too impractical to correct afterwards. Self Regulation by building design professions and construction organizations is NO Regulation ! Stringent, independent technical control inspections must be carried out on all projects by Building Control personnel … which used to happen in Dublin City/County and Cork City/County prior to the introduction of legal building regulations in the early 1990’s … and, depending on complexity, must also be carried out at critical stages during the construction process.
Building Control Sections in all Local Authorities must be properly resourced with competent personnel, equipment, training and support infrastructure.
Inspections concerning compliance with all functional requirements in the building regulations, including fire safety, must be carried out only by Building Control Personnel. Chief Fire Officers must not be allowed to manage or be involved in any aspect of Building Control. On the same project … a Disability Access Certificate Application and a Fire Safety Certificate Application must be inter-linked and overlap sufficiently, showing no gaps in compliance. Inspections must be carried out in connection with all Certificate Applications. Building Control personnel must satisfy themselves that actual construction at least matches, if not improves upon, what is shown in design documentation.
Building Control Inspection Reports must be made available for public view.
3.Firefighters are NOT a disposable Social Asset ! National and Local Authorities Having Jurisdiction … and some Chief Fire Officers … must begin to understand this fundamental truth !
Fire Services in all Local Authorities must each be properly resourced according to local needs … with competent personnel, equipment, training and support infrastructure. Shared provision of resources looks very neat on paper but, in practice, works very badly. Refer to the Grenfell Tower Fire and London Fire Brigade having to borrow firefighting equipment from other Fire Services.
After the 2015 Tianjin Regional Fire Devastation, in China, and the 2001 WTC Attacks on 9-11, in New York City … front line firefighters must be supported by Specialist Hazard Appraisal and Structural Engineering Units.
For Firefighter Safety in buildings and to quickly find people with activity limitations waiting in Areas of Rescue Assistance and/or other survivors in different locations … a portable and reliable Thermal Imaging Camera is an essential piece of every firefighter’s equipment.
And Firefighter Safety begins with good building design. In all but the most simple building types, Circulation Routes must be designed for Contraflow … people moving away from a fire in a building and towards safety while, at the same time, heavily equipped firefighters are entering the building and moving towards the fire.
There is no place for ‘Stay Put’ Policies in Irish Residential Buildings of any height.
Ireland’s 2017 Oireachtas Report: ‘Safe As Houses’ …
December 2017 – Houses of the Oireachtas – Joint Committee on Housing, Planning & Local Government
This was a good effort by our public representatives … but they missed core issues !
After The Grenfell Tower Fire !
Further to my last Blog, dated 2017-10-10 …
The 2017 Fire in England was not an extraordinary fire. Since the beginning of this decade, we continue to see a series of such fires: South Korea (2010) – UAE & France (2012) – Chechnya (2013) -Australia (2014) – UAE, Azerbaijan & UAE again (2015) – UAE (2016) – UAE & Russia (2017) – Turkey (2018).
With regard to Command & Control of Large Scale Emergencies … English AHJ’s should have paid attention to the 2005 & 2008 U.S. National Institute of Science & Technology (NIST) Recommendations following the 9-11 WTC Buildings 1, 2 & 7 Collapses.
The Fire Safety Objectives in current Building & Fire Codes/Regulations are very limited. In Ireland, this is clearly stated in Technical Guidance Document B …
‘ Building Regulations are made for specific purposes. Part B of the Second Schedule to the Building Regulations is therefore primarily concerned with the health, safety and welfare of persons. The fire safety measures outlined in this guidance document are intended for the protection of life from fire.’
Only insofar as it is necessary to protect the lives of able-bodied building users/occupants … is there a concern for property protection.
There is only inadequate, token concern for the protection of people with disabilities.
Client organizations, facility managers, building designers, construction organizations … and journalists … must fully comprehend these limits.
In the photograph below … look closely at the External Firefighting Operations at the bottom of the Tower. There are limits to what can be achieved from outside a building !
A Fire Suppression System (Water Sprinklers/Mist/Hybrid) is an essential Fire Protection Measure in ALL Medium and High-Rise Residential Buildings … which include Apartment Blocks, Hotels, Hostels, Student Accommodation & Social Housing, i.e. ANYWHERE there is a Sleeping Hazard.
A Reliable and Credible Fire Detection & Warning System is an essential Fire Protection Measure in ALL Buildings … and must be capable, under the control of Building Management, of transmitting warnings in many formats, i.e. Audible + Visual + Multi-Lingual Voice + Tactile.
Fire Evacuation Routes in Buildings must be designed for CONTRAFLOW … people moving away from a fire and towards safety while, at the same time, heavily equipped firefighters are entering the building and moving towards the fire.
Good Fire Evacuation Route Design is INTUITIVE and OBVIOUS. In many buildings, however, this is not always the reality. Effective Fire Evacuation Signage … comprising high-level signage, low-level signage, with both supplemented by photoluminescence … must be installed in ALL Buildings.
For the purpose of protecting Vulnerable Building Users in Fire Emergencies, ALL Lifts/Elevators in Buildings must be capable of being used for Evacuation.
Fire Risk Assessments must NO LONGER be carried out by people WITHOUT COMPETENCE in Fire Engineering AND Building Design & Construction … and the Fire Risk Assessment Process itself must be thoroughly re-examined and upgraded.
2016-05-05: A Mickey Mouse Effort would be a polite way of describing the long drawn-out and tortuous process of implementing NIST’s Recommendations in the United States. A better description might be … FUBAR !
15 Years After the 2001 WTC 9-11 Attacks in New York City … absolutely nothing has been done concerning the implementation of a significant number of Recommendations … other Recommendations have been only partially implemented, with many being limited to application in buildings over 128m high (420 feet in ye olde silly imperial units of measure), or else buildings over 22.86m high (75 feet) which have an occupant load exceeding 5,000 people or are essential facilities, e.g. hospitals. And believe it or not, some implementing measures are still being challenged and they may yet be reversed in the years ahead. Forget about discussing the already narrow Fire Safety Objectives in building codes/regulations, or Protecting Society, etc., etc. In essence, it has all come down to that ‘durty’ four letter word: COST !
But read this 2011 Status Report for yourselves. I have kept in touch with the current situation over there.
In 2005 & 2008, the U.S. National Institute of Standards & Technology issued a series of very important [ critical ] Recommendations on badly needed revisions to the Design – Construction – Management – Firefighting Procedures for Very High/Tall Buildings, High-Risk Buildings, Iconic Buildings, and Innovatively Designed Buildings. Many, if not all, of these Recommendations were, and remain, just as valid and just as necessary in the case of other building types … whatever their height.
A lot of effort was expended here, a few years ago, on a detailed examination of the NIST Recommendations. In one respect, the Recommendations have become dated and obsolete. The recent 2016 Brussels and 2015 Paris Hive Attacks have altered how we must categorize and deal with buildings of ‘high-risk’. From the start, however, the disability-related Recommendations only concerned mobility impaired building occupants … a serious flaw.
NIST does not have the legal authority to implement its own Recommendations within the United States. However, implementation by the Model Code (e.g. IBC & NFPA) Organizations has been brutally slow and entirely inadequate.
And … it is very noticeable how so many other countries around the world are continuing to completely ignore NIST’s Recommendations. 9-11 never happened !
On the day before that, 21 April, in a Press Release issued by the World Meteorological Organization (WMO) …
A prolonged run of record global temperatures and extreme weather, the rapid melting of Arctic ice, and widespread bleaching of ocean coral reefs underline the urgent need to sign and implement the Paris Agreement on Climate Change, according to the World Meteorological Organization (WMO).
WMO Secretary-General Petteri Taalas said that 2016 has so far overshadowed even the record-breaking year of 2015.
“The magnitude of the changes has been a surprise even for veteran climate scientists. The state of the planet is changing before our eyes,” said Mr Taalas.
A little earlier in April 2016 … and within the above international context came this problematic, but not-entirely-unexpected tale from Great Britain … the tip of a foul-smelling iceberg in quite a few countries …
Green Deal & Energy Company Obligation
“Improving household energy efficiency is central to government achieving its aims of providing taxpayers with secure, affordable and sustainable energy. The Department of Energy and Climate Change’s ambitious aim to encourage households to pay for measures looked good on paper, as it would have reduced the financial burden of improvements on all energy consumers. But in practice, its Green Deal design not only failed to deliver any meaningful benefit, it increased suppliers’ costs – and therefore energy bills – in meeting their obligations through the Energy Company Obligation (ECO) Scheme. The Department now needs to be more realistic about consumers’ and suppliers’ motivations when designing schemes in future to ensure it achieves its aims.”
Amyas Morse, Head of the British National Audit Office (NAO), 14 April 2016.
[ And as you read further down … consider how important it must be for future effective climate change policy implementation in all of our countries, particularly those countries with an ‘historical responsibility’ …
that accurate, precise and reliable climate change data and statistics be gathered together and properly managed … and this means, for example, that at European Union Member State level, the national statistics organization must be in control of the process … and at EU level, Eurostat must be in control ;
that implementation be stringently and independently monitored for long-term effectiveness ;
that economists be removed from core decision-making in this area … and the veto they currently exercise over necessary mitigation and adaptation actions be removed. ]
The National Audit Office has today concluded that the Department of Energy and Climate Change’s (DECC) Green Deal has not achieved value for money. The scheme, which cost taxpayers £240 Million including grants to stimulate demand, has not generated additional energy savings. This is because DECC’s design and implementation did not persuade householders that energy efficiency measures are worth paying for.
The NAO Report: Green Deal and Energy Company Obligation also found that DECC’s design of its Energy Company Obligation (ECO) scheme to support the Green Deal added to energy suppliers’ costs of meeting their obligations. This reduced the value for money of ECO, but the Department’s information is not detailed enough to conclude by how much suppliers have met their obligations for saving carbon dioxide (CO2) and reducing bills.
The report finds that while the Department achieved its target to improve 1 Million Homes with the schemes, this is not a direct indicator of progress against the objective of reducing carbon dioxide (CO2) emissions. This is because different types of energy-efficiency measures save different amounts of CO2.
The schemes have saved substantially less CO2 than previous supplier obligations, mainly because of the Department’s initial focus on ‘harder-to-treat’ homes, as its analysis showed that previous schemes had absorbed demand for cheaper measures. The Department expects the measures installed through ECO up to 31 December 2015 to generate 24 Mega Tonnes of carbon dioxide (Mt CO2) savings over their lifetime, only around 30% of what the predecessor schemes achieved over similar timescales.
Demand for Green Deal finance has fallen well below the government’s expectations, with households only funding 1% of the measures installed through the schemes with a Green Deal loan. The schemes have not improved as many solid-walled homes, a key type of ‘harder-to-treat’ homes, as the Department initially planned. As part of changes to ECO in 2014, the Department enabled suppliers to achieve their obligations with cheaper measures, moving away from its focus on harder-to-treat properties. ECO has generated £6.2 Billion of notional lifetime bill savings to 31 December 2015 in homes most likely to be occupied by fuel poor people. Beyond this, the Department cannot measure the impact of the schemes on fuel poverty.
There are significant gaps in the Department’s information on costs, which means it is unable to measure progress towards two of its objectives: to increase the efficiency with which suppliers improve the energy efficiency of ‘harder-to-treat’ houses, and to stimulate private investment. The lack of consistency in the government’s approach during the schemes could increase the long-term costs of improving household energy efficiency.
In the NAO’s accompanying investigation into DECC’s loans to the Green Deal Finance Company, also published today, it found that the Department expects that it will not recover its £25 Million stakeholder loan to the finance company, plus £6 Million of interest that has accrued on it. The Department based its stakeholder loan on forecasts of significant consumer demand for Green Deal loans. But demand for Green Deal finance was lower than the Department forecast from the outset, meaning the finance company could not cover its operating costs. The Department agreed a second loan worth up to £34 Million in October 2014, of which the finance company has drawn down £23.5 Million. The Department still expects to recover this loan in full as it will be repaid before other investors in the finance company.
Is it any wonder that the ‘real’ Greenhouse Gas (GHG) Numbers continue to climb relentlessly ?!?