DFS 15 - Home Builders Federation and the Confederation of British Industry

(Saesneg yn unig)

This is a joint response to the above LCO consultation from the Home Builders Federation and the Confederation of British Industry. Our comments are provided below.

The HBF and CBI understand the ethos behind the proposal and remains fully committed to the addressing the serious issue of fire safety in new homes. Our members pay strict regard to the requirements under Part B of the Building Regulations and are satisfied that provisions within the regulations are robust enough in terms of being an effective deterrent from fire in new homes and the associated hazards than often ensue.

Our members are fully committed to ensuring the safety of residents in new homes, be that in relation to fire or any other hazards that may prevail. However, we have concerns with the implications that such a proposal might have to the viability of many developments throughout Wales, especially in areas where regeneration is of considerable importance.

We understand that the English and Scottish Governments have pursued this course of action in the past. Both Governments have undertaken extensive studies and consultation in relation to this issue and in doing so concluded that the mandatory installation of fire sprinklers in all newly built homes would be unfeasible. In relation to the English example, The Buildings Research Establishment (BRE) was appointed by CLG to support a review of Part B (Fire safety) of the Building Regulations. They undertook a project in order to establish whether or not fire sprinklers would be effective for use in residential premises. The research made a number of conclusions in terms of cost-benefit analysis and found that the installation of fire sprinklers in single residential dwellings would not be a cost effective course of action.

In arriving at this conclusion, the BRE research provides a detailed analysis of the estimated costs in relation to the installation of fire sprinklers in new homes. The research takes information from the Fire Sprinkler Association (FSA) and provides detail with regard to the installation of sprinklers into a number of different accommodation types. For example, the research provides a cost estimate for installing sprinklers into a newly built three bedroom home, which is given as ranging from £1500-£1800 per dwelling. However, this estimate is taken at the lower end of the installation costs, and assumes there are no unusual circumstances to hinder the installation.

The research also provides costs from actual projects that have been undertaken, which show a substantial increase in the costs given by the FSA. In this context, one-off installation costs for a three bedroom property could range from £2000 - £3000 per home and a four bedroom property could range from £3000 - £4000 per home.

A critical factor to be taken into account with these figures is that they assume no extra water storage facilities or pumps are required for residential schemes and that sprinklers can use the mains water supply at no additional cost. In Wales, we have been advised that there may be issues with connecting sprinkler systems to mains water supplies and that pumps and storage facilities might be required. The BRE research provides a number of costs taken from actual projects associated with providing water storage facilities and pumps. For a residential system, costs can range from £2500 - £3000 per installation and for smaller domestic systems the cost is quoted as being £1500 per installation.

In addition to this, the research shows that the cost of connecting to the mains water supply can differ between areas, and even if no storage or pump facilities are required, the cost of connecting to the mains supply can range from £600 to £1500. Again this is based on actual projects.

The BRE research sums up the installation costs using the FSA’s figures, even though they have quoted the lower end of installation costs, assuming no unusual circumstances and that connection to the mains water supply is possible. Taking these issues into account, the estimated cost of installing a fire sprinkler into a newly built three-bedroom home would range from £1500 - £2730 per property, depending on the cost of connecting to the mains water supply (given in the research as an estimate ranging from 0 - £930)

However, if we use the figures taken from actual projects, there is evidence to show that the costs could actually be a lot higher, especially if additional storage facilities and pumps are required.

The evidence from the BRE’s research is significant. However, we have added concerns in relation to the operation and implementation of such systems. As stated, we understand that additional burdens might be placed on existing water supplies and that in many cases, water storage systems might be needed to enable the systems to run effectively. This not only has the potential to add considerable costs to developments (as shown above), but would also require extra space on the building footprint. We are concerned that this may conflict with the Welsh Assembly Government’s requirements for an increase in building densities, especially on previously developed land where space is limited.

We would also like to raise concerns with respect to infrastructure and capacity problems faced by the industry in Wales. At present Welsh Water state in their Business Plan that infrastructure and capacity problems are holding up the development of 20,000 new homes. We are therefore concerned that these proposals might exacerbate existing problems in Wales, especially at a time where Welsh Water is experiencing difficulties meeting current demands.

Our members are fully aware of their market and consumers interests and have raised concerns about how customer confidence might be affected by the proposals. The concept is relatively un-tested in terms of how systems would operate on a day to day basis and issues such as maintenance, operation and false alarms that may trigger the systems unexpectedly have raised concerns with our members, especially at a time where people are buying more expensive electrical household items and where insurance costs are rising.  In terms of insurance, whilst giving evidence to the Scottish Finance Committee, the Scottish Federation of Housing Associations expressed concerns that it had received evidence that insurance premiums for sheltered housing and HMOs would not necessarily decrease as a result of installing fire sprinklers and may actually increase because of the potential for water damage, both in false alarms and real situations.

The impact of these proposals also needs to be judged against the Welsh Assembly Governments objectives, particularly the zero carbon building agenda, where water conservation will be an integral component of meeting the targets under the Code for Sustainable Homes.

We reiterate our understanding of the principles and impetus behind the introduction of these proposals and also would like to reaffirm our members’ fervent commitment to ensuring the safety of residents within new homes. The HBF and CBI remain fully committed to working with the Welsh Assembly Government on serious issues of this nature, however in light of the issues stated above, we object to the proposal to require new fire sprinkler systems to be installed within all new homes.

Thank you for taking the time to consult us at this stage of the process and we look forward to working with you in the future.

Yours sincerely,

Richard Price
Planning and Policy Advisor – Wales
Home Builders Federation

Leighton Jenkins
Assistant Regional Director- Policy
Confederation of British Industry- Wales