DFS 19 - Neath Port Talbot County Borough Council

Thank-you for the invitation to submit evidence to the Committee regarding the above and I have consulted with colleagues and would comment as follows to the specific questions raised

It is our opinion in principle that legislative competency, in the area identified in Matter 11.1 of the Order, should be conferred on the Assembly

The Authority would support any initiative that supports increased fire protection to occupants of properties in the private housing sector

Taking into account the role of Local Authorities in terms of enforcement (and enabling); it is our view that he terms of the proposed order are too broadly drawn. Furthermore, taking into account evidence based statistics that the risk of fire in such premises is significantly higher, then it is suggested that the requirement to fit sprinkler systems or not, should be solely risk based, in line with the Housing Health and safety Rating System.

In more general terms the Authority would like to make the following observations:

The construction and forming of new dwellings is controlled by The Building Act and The Building Regulations. Contained within existing guidance is the need for smoke alarms and heat detectors, escape windows, fire protected stairways and means of escape as well as space separation.

Referring to paragraph 12 of the explanatory memorandum; clarity is sought on how many of the 16 deaths per year in Wales were/are in houses that were constructed to the current standard?

The existing provisions of the Building Regulations are set to ensure that occupants have early warning of a fire and that adequate escape routes are provided. Passive fire protection is provided to the structure of the building. The provision of active fire protection measures, i.e. sprinklers, would no doubt increase margins of safety within the dwelling, but the cost of provision would be quite significant.

There is an assumption that the provision of sprinkler systems will offer design freedoms offered in respect of other fire safety measures; is this the case? If it is then it is recommended that any proposals regarding sprinkler systems will benefit from cost/benefit analysis to consider the cost savings resulting from any design freedoms

For such a system to be effective it would have to be maintained. How can maintenance be enforced? Specific legislation, for example relevant Housing Acts may provide for this indirectly (e.g. HMO) but it should be noted the Building Act (as it relates to Building Control provisions) does not allow for ongoing supervision following completion.

It is noted that the order refers not only to new build, but also to new dwellings created within existing buildings through conversion or sub division.

There will be added revenue costs to Local Authorities et al after installation, which will need to be budgeted for.

I apologise for the lateness of the response and hope that these comments are taken onto consideration. There is no necessity for the Authority to give oral evidence.

Robert Rees

Head of Housing Services

On behalf of Neath Port Talbot County Borough Council