Report title

Fire Brigades Union response to the LSP5 public consultation

Meeting Date

Authority 18 July 2013

Report by Document Number

Commissioner

FEP 2091A

Public

Summary This report sets out my response to the issues raised by the Fire Brigades Union (FBU) in their submission to the public consultation on the draft London Safety Plan 5 (LSP5).

At the time of writing, it is understood that the FBU intends to make a further written submission and have requested an oral representation at the meeting of the Authority on 18 July 2013.

Recommendation That the report be noted.

Introduction/Background 1. Consultation of the draft LSP5 ran for a period of 15 weeks, from 4 March to 17 June 2013. This

was a public consultation and the widest possible range of stakeholders were actively encouraged to take part in the consultation. My consideration of all the feedback received from the consultation and associated meetings and other engagements have been set out in the covering report to the revised LSP5 which is also on the agenda for this meeting.

2. The FBU response to consultation which is the subject of this report was received on the 24 June, one week after the public consultation closed. The submission implies it is an interim response by the FBU and officers understand that a further written report will be made by the FBU in time for its meeting on 18 July. This report has been sent for despatch at 2.30pm (Wednesday 17 July) and at this time those further comments have not been received.

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3. The FBU response is attached as Appendix 1 to this report. I have annotated the FBU submission with my response as appropriate.

4. It is not typical for my covering report to address any issues of substance over and above the response I have made to the specific issues raised but on this occasion I believe that I need to make an exception. While I recognise that the FBU have a strong objection to proposals to reduce the number of fire stations, fire appliances and operational staff, there are numerous comments in the response to which I take very strong exception and where I believe that the FBU have cast a completely unacceptable slur against Brigade officers. I would hope that members would also find some of these comments and personal attacks unacceptable.

5. Leaving aside personal attacks, the FBU response also states: “There have been many official reports after serious accidents that have occurred resulting in deaths of operational firefighters, where it is concluded that insufficient training, lack of local knowledge, incorrect resources were not available as the main factors. The London Fire Brigade, has itself received a number of these reports, but failed to act upon them, almost in denial, and therefore continues to ignore all the warning signs of its failures in this area, and produces a safety plan that would inevitably worsen the current situation.”

6. The suggestion that I and other Brigade officers (and, by implication, Members of the Authority) do not take firefighters’ safety seriously and have not learnt the lessons from the deaths of firefighters is strongly rebutted. These statements are not true and are shoddy. If any Member wishes me to substantiate my statement, I would be more than happy to provide my evidence, including reports made previously to Members. I invite the FBU to do the same and to produce evidence to substantiate its claim.

Head of Legal and Democratic Services comments 7. None arising in the context of this report.

Director of Finance and Contractual Services comments 8. None arising in the context of this report.

Environmental Implications 9. There are no direct environmental implications from this report.

Staff Side Consultations Undertaken 10. The FBU have been full contributors to the public consultation meetings. A meeting of the

Authority Joint Council (AJC) was held on the 12 July 2013.

Equalities Implications 11. There are no direct equalities implications from this report.

Appendix to this report:

Fire Brigades Union response document to public consultation in respect of the proposed plans put forward by the Commissioner of the London Fire Brigade in his integrated risk management plan (LSP5)

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LOCAL GOVERNMENT (ACCESS TO INFORMATION) ACT 1985

List of background documents

1. Report FEP2021, Draft Fifth London Safety Plan (January 2013), and report FEP2021A, Draft Fifth London Safety Plan – supplementary report (January 2013)

2. FEP2027, Draft Fifth London Safety Plan – Mayoral direction 3. FEP 2028, Draft Fifth London Safety Plan - Mayoral Direction - Proposed Claim For Judicial

Review 4. FEP2029, Draft Fifth London Safety Plan – approval of new consultation material (and

clarification of attendance time calculations) 5. FEP2030, Draft London Safety Plan 5 – Matters relating to the public consultation

Proper officer Commissioner

Contact officer E-mail

Rita Dexter Telephone 020 8555 1200x30021l rita.dexter@london-fire.gov.uk

Appendix

Fire Brigades union response document to public consultation in respect of the

proposed plans put forward by the Commissioner of the London Fire Brigade in his

integrated risk management plan (LSP5)

Introduction The Fire Brigades union (FBU) represents 95% of the operational workforce in London Fire Brigade, with thousands of years of combined operational experience; we feel we are able to respond to this plan, taking a professional risk-based approach to the draft proposals. Since the introduction of integrated risk management plans (IRMP) in the UK fire service, the fire Brigades union has been the one organisation that has challenged successfully many of the proposals put forward by the various fire authorities in the UK. The Fire Brigades union London region has responded to the four previous plans pointing out many of the failures in the plans to date, and our predictions in many of the areas where cuts and changes were made have proven to be right.

Brigade response: I do not recognise the occasions or submissions that would substantiate this comment and invite the FBU to provide further details.

London safety plan five (LSP5) does not constitute a risk-based IRMP. It is our view it is solely based on financial restrictions placed upon the fire authority because of the lack of funding by central government and Mayor Boris Johnson. It has been known for some years prior to these proposals that there would be a financial deficit as a result of reduction of central grant funding settlement from Government.

Brigade response: The Plan has been drafted reflecting DCLG guidance. The government’s IRMP guidance from 2003 states that the guidance is “neither prescriptive nor exhaustive” and guidance from 2008 says “For the avoidance of doubt this guidance is not mandatory…”. I have already advised Members that I believe that the resources available are a relevant consideration and my view appears to be supported by Sir Ken Knight’s efficiency review (Facing the future: findings from the review of efficiencies and operations in fire and rescue authorities in England, May 2013).

The London Fire and emergency planning authority (LFEPA) until March 2012 had sufficient reserves to offset the effects of these reductions, thereby ensuring the current levels of fire cover as they are at the moment could be maintained. But the Mayor chose to take £50,000,000 from the LFEPA reserves and use it just before the election to boost frontline police numbers in London, knowing this would cause a funding gap in the LFEPA budget, and inevitably lead to a reduction in services of the London Fire Brigade. During the internal consultation process between Commissioner and principle managers and representatives of the FBU, detailed discussions were had between the two parties. The Fire Brigades Union raised its concerns. We pointed out to the Commissioner and other principal officers that the integrated risk management plan should be based around hazards and risk approach, pointing out the new requirements laid down in the Government’s national framework documentation for English fire rescue services. We addressed the following points:

• The absolute requirement for preplanning for all foreseeable incidents

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• The correct resources that is required to deliver safe systems of work. • The changes to operational policy and procedures with regard to resources to

achieve successful outcomes

• Crewing deficiencies on frontline appliances, and the cause and effect this had on a

successful outcome, as well the danger it posed to Firefighters safety on a daily

basis.

Brigade response: There are no proposals to change the level of resources on pumping appliances that are mobilised to attend incidents. Pre-planning, resources to deliver safe systems of work, operational policies and procedures, and crewing of pumping appliances will continue as currently. The proposals accept that the arrival of some pumping appliances will be slower than now, but in many cases they will be within the Authority’s target attendance times of 6 and 8 minutes for a 1st and 2nd appliance respectively.

• The need to consult with all persons on these proposals; detail how this would

affect them and importantly to take note and react to the responses, and adjust

accordingly if the public rejected the plan.

Brigade response: The Authority undertook a significant consultation exercise lasting 15 weeks, including 24 public meetings. There were 2,323 responses to the consultation, plus 13 petitions (21,770 signatures) against the various proposals to change the numbers of fire stations and fire engines. The views of the people who responded have been taken into account in developing the revised Plan.

During the lead up to the draft final proposals, not one of our submissions to the principal management team were taken up or responded to in sufficient detail to give us the reassurance that the Commissioner and his principal staff were abiding by the national framework documentation and guidance notes produced by central government on integrated risk management plans.

Brigade response: At the AJC meeting on 16 August 2012 I underlined my willingness to work in a collaborative way with the unions and there were plenty of opportunities for the FBU to put forward their views. I am not aware of any “submissions” from the FBU. The single major contribution made by the FBU has been that the plan should have no regard to the resources available, closely followed by their criticisms of data presentation and methodology. I have dealt with these points. The FBU did make two other suggestions at Authority Joint Council (AJC) meetings about how savings might be found (from the deletion of driver posts and a reduction in spend on national operational guidance work) and these were both addressed at those meetings, and savings included within the 2012/13 budget. There have also been a number of emails from the FBU, before and during the consultation period, all seeking clarifications and all have been answered in full. The requirements of the national framework are fully reflected in the Plan, and the Plan has also had regard to the IRMP guidance produced by government.

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London draft safety plan five (LSP5)

The final draft was submitted to the public for consultation, as a result of the direct intervention Mayor Boris Johnson. The FBU were appalled that Mayor Johnson had intervened with the procedural process contained within the legislation governing integrated risk management plans. We raised concerns with the brigade, and have made it very clear, that should the proposals be rejected again by the fire authority and the mayor uses powers of imposition, then the FBU reserves its right to take whatever action it feels as appropriate, including legal as well as industrial action in pursuance of its members’ safety.

The FBU rejects these proposals in their entirety, as unsafe and not fit for purpose. We believe that the proposals are solely based upon financial restrictions. This plan is not based upon the current risk to Londoners, and if imposed would indeed cause more fire deaths or other deaths as a result of lack of resources and manpower being able to arrive in sufficient time to have a successful outcome.

Brigade response: The justification for changes reflects lower levels of risk in London as demonstrated by reduced numbers of emergencies that require the attendance of the Brigade. Londoners have never been safer from fire than currently. As stated in the main report, I have applied the government’s methodology for assessing the fire death impact of the operational reduction proposals and (including the proposals as amended) that methodology says that they would not result in a predicted increase in fire deaths. I note the FBU use of the term “manpower”, which is unacceptable. It is clearly understood that the failure to use gender neutral language is an issue in the service.

Proposed cuts to frontline services contained in LSP5

• The draft plan outlines reduction of 12 fire stations mainly based in the inner city areas of

London, in densely populated areas with high levels of social deprivation and the largest life

risk. • Further proposals, include scrapping a further 18 appliances from frontline services.

Brigade response: The plan proposed a net reduction of 18 appliances and this included the 12 station closures (they were not “further” appliances as stated). The revised plan includes a net reduction of 14 appliances from 10 station closures and appliances removed/deployed from/to other stations.

• The reduction of over 10% of the operational workforce, currently employed by the LFEPA. • The introduction of alternate crewing for specialist vehicles, currently permanently crewed

and available 24 x 7 x 365.

• Reduction in senior operational managers. Fire Brigades Union response to LSP5 Draft Proposal .

We have spent many hours reviewing these proposals contained within the LSP5, and respond as follows in the first instance, with a brief submission, but will produce an in-depth report prior to the planned LFEPA meeting on the 18th July 2013.

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Data Submissions contained within the proposals.

We are deeply concerned with the lack of consistency contained within the report, and how the data is being portrayed by the Commissioner and his principle managers. There are a total of 24 supplementary documents as well as the original draft containing information. In many of the supplementary documentation the data seem to contradict one another and different time periods are consistently used through out the plan, rather than set date periods.

Brigade Response: Some data for the plan is for calendar years and some is for financial years. These different periods, when compared, have been shown to be consistent. Different periods were used because (a) older historic data – used to provide historic trends – was only available by calendar year; and (b) financial years were used for performance reporting and gives a consistent view with data published elsewhere.

For instance, the brigade supporting evidence uses a period of 10 years of fire reductions to justify its cuts contained in the proposals. However, it fails to point out in detail that the first two years used, contains information collected in a totally different manner and not within the confines of the IRMP process. Therefore, we reject these data statistics has been misleading at best and at worst, a deliberate attempt to over emphasise the statistical information in support of a cuts agenda.

Brigade response: A ten year period is used to provide a context against which the proposed changes can be viewed. It is not used as a justification for the changes. It is not correct that the “first two years” (of the ten year period) was collected in a “totally different manner”. The Brigade started electronic recording of incident data in April 1999, and there has been a remarkable degree of consistency, both before and after April 1999, in the way in which LFB data has been collected. The most recent data collection change was the introduction of the national Incident Recording System (IRS) in November 2008 for LFB. Ten years was used as a statistically significant period over which to show change, but the reduction in the volume of calls received, and incidents attended, shows a reduction over other shorter periods. In fact, there was a 10 per cent drop in incidents attended between 2011/12 and 2012/13.

It is the FBU belief, that only data since the introduction of the IRMP process LSP1 to the current period should be used with any confidence or accuracy. This is further supported in supplementary documentation, which the commissioner uses to justify target attendance times and call data, using only the preceding 3 year period contained in the LSP4 period, and not the 10 year period used to distort the level of fires in London.

Brigade response: The reasons for this suggestion are unclear; surely, the more data used the better. Use of data from 2004 only (when LSP1 was produced) would be arbitrary. No significant changes were introduced in data collection at this time.

The various graphs included in the documentation are very hard to read, and give a distorted perspective of the information. We have produced bar chart graphs based on the same information, which gives a totally different perspective, and does not seem to show the vast variations the complicated graphs detailed in the draft plan.

Brigade response: The FBU have not been specific about which

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charts they refer to. I cannot find any charts that give a ‘distorted’ view of the information.

We question the use of the data averaging process, there is no supporting evidence of how the calculus was worked out, no information about the error factor used in the data submissions.

Brigade response: It is not clear what “data averaging process” the FBU mean. If it is the calculation of average 1st and 2nd appliance attendance times, then the method of calculation is set out clearly in Annex A of LSP5 supporting document 8 (Getting to emergency incidents as quickly as possible).

There is inconsistency right across the plan, further supplemental reports on target attendance times have proven, that the mean averages suggested by the brigade on target attendance times for boroughs is incorrect, therefore we call upon the fire authority, to instigate an investigation into how this data has been produced, why there were are such variations in the timescales being used to justify the cuts agenda.

Brigade response: If the FBU have evidence of incorrect calculations, I would ask them to supply it. The average borough attendance times published to support the draft LSP5 are entirely consistent with the ward level data published and are not incorrect.

We dispute one of the main KPIs produced by the brigade in terms of time spent by firefighters at operational incidents. It is our belief the data supporting this evidence is deeply flawed. To date we have never been given the information how this is calculated. The brigade reports only 7% of the time of an operational firefighter is spent at operational incident. This data, paints a very distorted picture of operational readiness. Firefighters spend a great deal of time ensuring that the equipment provided by the brigade is in a fit operational state, on a daily basis. Firefighters also spend a considerable amount of time post incident, ensuring that the same equipment is maintained/ replaced so it is ready for use as soon as possible after an incident, both the time before and afterwards has not been included in this data, and further distorts the plan, by suggesting that there is more time available for firefighters to do other activities, when clearly there is not. Therefore we call upon the fire authority to make sure that there is transparency and all the facts are in the presentations, giving a detailed description of all work that is carried out in support of attending operational incidents, and ensure this information is correctly portrayed in data submissions provided as supporting evidence in reports.

Brigade response: This measure is intended to highlight that the Brigade’s resources, when compared to the other blue light emergency services such as the London Ambulance Service, has a much lower utilisation rate. This was broadly acknowledged and not contested through the consultation process. The data is derived from the appliance ‘Status’ changes that are captured through the mobilising system. As such the figures are an accurate and reliable reflection of the operational activity of the Brigade’s resources. LSP5 supporting document 10 (Station workloads and capacity) makes clear how the time firefighters spend at emergency incidents is calculated and says it includes “… travel to and from the incident scene as well as time dealing with the incident.”

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Therefore we call upon the fire authority to instruct the Commissioner and principal managers to:

• Cease using average systems that have the potential to mislead the public, use

100% of the real data in producing any information in future plans or reports. • To use consistent time and date periods in all information in future plans. To

engage and agree in advance any further proposals and IRMP’s data modelling

process. • Included fully researched risk based management assessment, including risk based

impact assessments on any future proposals, which are independently audited by

someone with the correct professional experience. • Before proposals are put to the LFEPA for a decision and public consultation, they

are to ensure that the information provided in public consultation is user-friendly

and statistical graphs are produced in an easily understood format. Target attendance times

After detailed questioning of the Commissioner and deputy Commissioner, we have pointed out that the target attendance times produced in this report do not reflect the public expectation. The target attendance times published in this report are taken from when an appliance depresses button on the fire appliance and leaves the station, and then when the fire appliance arrives at the address (which does not necessarily mean they are in attendance at the incident).

Brigade response: There is a clear statement in LSP5 supporting document 8 (Getting to emergency incidents as quickly as possible), confirming how the Authority calculates 1st and 2nd appliance attendance times, and that information was in the original supporting document published with the November version of the plan. The FBU are not correct that counting starts when “an appliance depresses the button” (as stated here); counting currently starts when the appliance is mobilised, and not when the appliance leaves the station, so includes the time taken by the crew to ‘turn-out’ of the station. The error above is despite the FBU seeking clarification of the attendance time calculation, before and during the consultation period. This calculation methodology has been used since 2008 and can be relied upon to accurately exemplify the impact of the LSP5 proposals. Changing the way the Brigade calculates attendance times at the point when it is proposing a significant reconfiguration of its front line operational resources would have made it extremely difficult to explain and exemplify the LSP5 impact during consultation, and the Authority might have been open to criticism that it was trying to confuse the public. As stated in my covering report to the revised Plan, I am proposing to report to Members about how attendance performance might be published in the future.

We have made it very clear, that the true attendance time should be measured from when the 1st call is placed to the 999 services and then the arrival of the correct number of firefighters at the incident to deal with the nature of the emergency. In most cases, the operational procedures of the London Fire Brigade require the attendance of two appliances with a minimum 9 firefighters before offensive firefighting can take place.

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Brigade response: All aspects of the mobilising process, including the time to answer and deal with 999 calls in Control is set out in LSP5 supporting document 8. It is not true to say that offensive firefighting cannot take place with fewer than 9 firefighters. The Brigade has a catalogue of policies and mobilising protocols that provide for the correct number of firefighters for any given incident, including those incidents where offensive firefighting becomes necessary. Where an incident requires the attendance of 2 appliances, these appliances will be crewed by between 8 and 12 firefighters depending on the availability of staff and the locations from which the appliances are mobilised. If the Incident Commander believes additional resources are required to resolve an incident, further appliances can be requested.

The FBU believes that a minimum of three additional minutes should be added to every target attendance time to truly reflect the time period a fire appliance arrives.

Brigade response: This appears to be an entirely arbitrary proposition and it would do nothing to improve a better understanding of what happens in real life. I have said that there is more work to undertake to look at approaches to understanding and communicating attendance times.

It is not about the number of appliances, but the number of firefighters on board those appliances attending that make the difference; if there are only eight firefighters attending a dwelling fire on the two appliances, then a third appliance is needed on the initial attendance.

At the moment, the brigade does not take the crewing numbers into account when mobilising, and this is a change that must happen!

Brigade response: This is completely wrong; only appliances with sufficient crew are available to be mobilised. The minimum ridership levels for the pumping appliances have been agreed with the FBU so its unclear why they are now choosing to raise this issue.

Therefore we dispute the target attendance times produced in support of this draft plan, and call upon the fire authority to instruct the Commissioner and the principal management team to produce a report detailing the real actual attendance times. We further submit, attendance times must also contain the crewing levels on the appliances attending, to ensure that firefighters are able to achieve a successful outcome in the time period the fire authority believes is acceptable.

Brigade response: Detailed data to support average 1st and 2nd appliance attendance times was published during the consultation periods (as supplementary supporting document 23 Attendance time performance distributions by borough) which shows the range of different times achieved in each borough. In addition, attendance times for 1st and 2nd appliances at every incidents for five years to 2011/12 was published on the London DataStore on 8 February 2013.

It is not about the number of appliances, but the number of firefighters on board those appliances that makes the difference. If there are only eight firefighters on board attending a dwelling fire, then three appliances are needed on the initial attendance not

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two.

Brigade response: See earlier comments. LFB mobilise the pre determined attendance (PDA) by number of appliances not by number of personnel. Appliances are only available to be mobilised if they are staffed by at least the minimum requirement for that type of appliance. The aim is always to send sufficient weight of appliances to deal with the reported incident type. Dwelling fires attract a minimum of two pumping appliances. This PDA may be enhanced by a local manager submission or by policy decision and known high-rise dwelling fires (of 6 storeys or more) do attract a PDA of three pumping appliances. It is not true to state that eight firefighters would be insufficient to carry out firefighting at a dwelling fire. In fact many fires in dwellings are resolved by the initial attendance, with only 0.5 per cent of all incidents in 2011/12 resulting in a request for additional resources (make ups). There are many different types of dwellings and the size, type, complexity of the property and the severity of the fire are all factors that would influence the dynamic risk assessment that the incident commander would carry out in order to determine the level of resources required to bring the incident to a safe conclusion. Only that incident commander will be able to determine if the initial resources in terms of personnel or appliances arriving at an incident are sufficient to bring the incident to a safe conclusion. If they believe they need more then they send priority messages to Control to achieve that.

Failure to produce this information is a breach of the requirements to share the correct information contained within the national framework documentation for UK fire services and the guidance notes for integrated risk management plans.

Brigade response: There is no requirement in the Fire and Rescue National Framework for England (2012) to produce statistics on the number of firefighters on each fire appliance. The National Framework requires fire and rescue services to ensure that integrated risk management plans reflect up to date risk analyses and evaluation of service delivery outcomes. This is reflected in LSP5.

Station Closures We do not accept the assertions in this report that closing 12 fire stations in inner London will not affect the safety of Londoners. The current disposition of fire stations in inner London were based upon national standard attendance times applied to the UK fire service. In the main most of the appliances in these areas were able to achieve an attendance of 2 fire appliances with sufficient personnel on each appliance to arrive at an incident within the space of 5 minutes, and a 3rd appliance in 8 minutes. Whilst there were no actual requirements for all of these areas to receive this type of attendance the principal officers of the London Fire Brigade at the time used a risk-based approach, taking into account travel time between stations. This ensured the overlap of resources, and the ability to ensure credible attendance times based upon buildings and life risk.

Brigade response: The government’s national recommended standards of fire cover were in place between 1947 and 2004. The

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standards operated with a system of categorising geographic areas against risk categories. The areas receiving the greatest speed and weight of attack in London (2 appliances in 5 minutes and 1 in 8 minutes) were categorised as ‘A’ risk. In London, ‘A’ risk only accounted for 2 per cent of London’s area. Most of London was categorised as ‘C’ risk which, under the national standards, only required one appliance in 8-10 minutes, and a further 17 per cent of London was categorised as ‘D’ risk which meant one appliance in 20 minutes. When the national standards operated (up to 2004) it was LFB policy to always send two appliances to a property fire. It is not true that that was a more sophisticated risk based approach adopted by (then) “principal officers”. If anything, less understanding of risk underpinned the old national system, which was based on some pretty crude calculations and arbitrary assumptions. Times have indeed changed, I believe for the better, as the Brigade now provides a more equitable level of emergency cover across the whole of the London. This is an underpinning principle adopted by the service (with cross party political support) when the old standards of fire cover were repealed in 2004.

When the greater London Council (GLC) was formed many of the now, outer LFB stations were part of other fire rescue authorities. The legislation extended London’s boundaries, and a number of stations were transferred to the London Fire Brigade. The stations were built and resourced on other fire authorities planned response, therefore the London Fire Brigade has always failed to deliver equality of attendance times in these areas because of historical reasons.

Brigade response: The stations inherited from neighbouring counties by the GLC in 1965 (and incorporated into the London Fire Brigade) and which are now located in outer London boroughs were planned and operated to the same national standards as those used in London at the time.

We applaud the current Commissioner Ron Dobson for trying to equalise attendance times across London. But we do not accept reducing station numbers in inner London areas is an acceptable method. We believe that if there is a requirement for equalisation, the same level of response currently received by Londoners in inner-city areas, should also be delivered to those outer London areas as well. Where we differ is that it is our belief the only way this can be achieved is by increasing resources in the areas that are not meeting the attendance times. For instance, the current Commissioner recognised this problem in LSP4, by the opening of a new fire station at Harold Hill on the out skirts of east London. Why, because the brigade could not meet a suitable attendance time in a high area of life risk. This therefore proves, that in areas where standards in outer London cannot be reached, the brigade should either increase staff numbers or build new fire stations as a blue print to ensure the equality of service across London.

Brigade response: The Authority has access to a finite level of resources and has to provide the best fire and rescue service for London within those resources. It is unreasonable to expect that additional, new, funding would be available to the Authority to allow for the building of new stations in outer London as the FBU propose. LFEPA’s pan-London attendance standard is based on the principle that London residents, wherever they live, have the right to expect a similar level of response to a similar type of incident regardless of

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where that incident is in London. Even with the re-distribution of four pumping appliances, as proposed in the draft and the revised LSP5, places in inner London will still generally get a higher standard of service than most parts of outer London. To the extent that the risks in inner London require more resources to deal with them, they will continue to receive those additional resources. It is also wrong to assume that directing new resources to existing fire station locations would resolve the equity objective. The location of a fire station will always determine the speed of response for 1st appliance attendance performance and as such it would require a significant amount of capital investment to build sufficient fire stations (assuming space and planning consent was not a constraint) to fully realise the equity aspiration. There are 157 wards which do not meet either target, 110 which meet second but not first and 37 which meet first but not second. Broad estimates (i.e. not detailed modelling) indicate that to try and achieve both average response standards in every ward, the following would be required: +25 second appliances at existing one-pump stations +25-30 new one-appliance stations +10-15 new two-appliance stations

If the stations were to close, enormous workloads would be placed upon adjacent stations; in the short-term and long-term this would have an adverse effect for those living in the areas where the stations have closed. It will also affect a number of the Brigades key policies in community fire safety. It will reduce the number of operational training hours available to ensure competent standards of readiness for operational staff. We already have major concerns, with the level of training and quantity/quality of training been delivered to firefighters at the moment, which is borne out in recent years by various reports and one in particular from the health and safety executive.

Brigade response: It is true that if proposals proceed, some stations will become busier. But I believe that this will be at a level that is realistic and achievable. There are firefighters who welcome the prospect of being busier; like me they are concerned about low levels of operational exposure. There is capacity to do more, use time better or prioritise time and the policies already in place (like shut in lifts release reduction) and those as part of the LSP5 (e.g. reduction in attendances to false alarms due to AFAs) will free up more station time for outside duties (for familiarisation) and community safety work. The health, safety and welfare of firefighters remains of paramount importance. This was fully taken into account in the drafting of the Plan and the resulting proposals. It is not clear what issues the FBU are referring to in respect to their HSE comment. I am assuming they relate to the issues that arose from the Bethnal Green Road incident in 2004. As a result of this tragic incident the Brigade, in consultation with the FBU, developed a detailed Action Plan to address all of the issues arsing from this event. I am pleased to say that the HSE revisited the Brigade in November 2012 to follow up on their management investigation and they have confirmed that they are satisfied the Brigade have successfully discharged all aspect of the Acton Plan.

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In essence, if you close 12 fire stations and remove those firefighters, the workload has to be taken up by others. There are no proposals in this plan to increase numbers at other fire stations adjacent to where the proposed station closures would take place. One of the key components of the fire service response to emergency incidents is the local knowledge gained by station personnel when analysing of the potential hazard risks on the station ground that they serve in. There is an absolute requirement by station personnel to familiarise themselves with all high-risk areas within their boundaries. Inspections known as 7,2,D are familiarisation inspections that are carried out yearly by station personnel. In inner London areas, there are far greater numbers, and these continue to grow on an annual basis as London increases its building stock for business, residential, and tourism.

Brigade response: Adjustments to station grounds following any station closures would have regard to workload as well as geographic coverage. The introduction of dynamic mobilising (with the new mobilising system in July 2014) will obviate the need for station grounds for mobilising purposes. This will allow much greater flexibility in drawing station areas that reflect more balanced workloads between stations, including those unaffected by LSP5 proposals. This means that familiarisation work can be carried out by neighbouring stations where this leads to a more equitable workload. The ability to share information about premises visited via the operational risk database and the mobile data terminals on appliances, means that this information is more widely available to all crews and officers that need it.

Key planning assumptions made by local managers and firefighters to ensure that in the event of an incident in any one of these high risk areas, a pre-planned fully documented process is put into place so that, should there be an emergency requiring the attendance of the fire service. Ensuring that if it is required it is carried out in the fastest and most efficient way to achieve a successful outcome. This is better known to firefighters as a risked based planning process, they determine the level of resources; submit plans for approval to deal with incidents. Local training then takes place around these plans, and importantly dialog with those that live and work in these area’s to enable them to know what will do when we arrive. These plans are both essential to the safety of firefighters, but more importantly allow for the quickest response in terms of rescue and firefighting activities. With the closure of stations, this important work will lapse, and inevitably lead to loss of important information, and as a consequence the reduction in the quality level of service provided to the public in the event of an emergency in these areas. In short, closing fire stations is a very high-risk strategy, which we believe will inevitably lead to an increase of fatalities of all types at fire rescue service incidents. Also it has the potential to increase serious injuries to our members, because of insufficient knowledge and awareness of the risks being imposed to firefighters to attend incidents in areas that are unfamiliar to them. There have been many official reports after serious accidents that have occurred resulting in deaths of operational firefighters, where it is concluded that insufficient training, lack of local knowledge, incorrect resources were not available as the main factors. The London Fire Brigade, has itself received a number of these reports, but failed to act upon them, almost in denial, and therefore continues to ignore all the warning signs of its failures in this area, and produces a safety plan that would inevitably worsen the current situation.

Brigade response: The FBU suggestions in the last paragraph of this

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section are completely fallacious and on my own behalf, and on behalf of the Authority itself, I reject and condemn them. Given the seriousness of this accusation I invite the FBU to provide evidence that supports their assertion, or to retract their statement. I am satisfied that the London Fire Brigade is a learning organisation and has always responded positively and proactively to any actions that have arisen from either internal or external enquiries or investigations. For any significant investigation the Brigade always aims to work jointly with the FBU in developing an agreed set of actions. This was the case after the Bethnal Green Road incident and more recently following a significant safety event, where four firefighters received burns, at an incident in East Hill, Wandsworth. The Brigade also aims to learn from and respond to other significant safety events that have occurred in other Fire Authority areas and has robust governance arrangements in place to manage these issues. Preplanning and information gathering are an essential part of incident management. The introduction of Mobile Data Terminals (MDTs) on appliances has significantly improved the way the Brigade manages and distributes information. The MDTs present a map to crews of appliances centred on their present location, and are linked to the Outside Duty records. Should the station closure proposals in LSP5 be implemented, then the 7.2 (d) visits would be distributed to other stations. Information gleaned from familiarisation visits and our Incident Monitoring System, will be incorporated into the borough training plans and made available to all crews via the MDT.

We therefore call upon the fire authority to reject the station closures, and take a longer term view in providing the correct number of fire stations in London that deliver a sufficient and suitable risk-based approach to the protection of the public in London. This process, should take into account the public perception of what is required by its fire service. It is not necessarily totally based upon the number of incidents station personnel attend, but as has been pointed out on many occasions, the absolute assurance should there be a need for the fire service to attend an emergency it is able to do so in sufficient time to instigate a successful outcome.

Brigade response: In the deliberative work that the Brigade undertook in advance of the public consultation exercise (and published in LSP5 supporting document 15 (Deliberative work and polling results) it was clear that the Brigade’s actual response times were “… better than most had anticipated…”

Removal of Eighteen Frontline Emergency Appliances

On top of the station closures, the Commissioner proposes to reduce the number of frontline appliances across London by eighteen. The fire Brigades union professional response to this proposal is one of complete opposition, on the grounds of insufficient consideration to operational procedures and resources required to deal with emergency incidents in London.

Brigade response: This mis-represents what the draft plan proposed. The reduction of eighteen fire appliances in the draft plan includes the appliances removed by the closure of stations and are not additional to it.

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As has been said previously, the only requirement to reduce the number of available operational appliances is based upon financial reductions to the service. It is not based upon a risk-based approach, and will seriously impact and affect the successful operational outcomes on all services provided by the London Fire Brigade to the public. Standard operational procedures produced by the London Fire Brigade are based upon a risk assessment approach, taking into account all the hazards, and the potential risks to firefighters employed by the brigade, their ability to carry out successful firefighting procedures in a safe manner, but also able to achieve the requirements set out in legislation.

Brigade response: The proposals in LSP5 are risk-based. There are no proposals to change any standard operating procedures as a result of the changes in LSP5. All existing policies and procedures remain relevant and current.

Quite simply if you take away eighteen appliances, it will reduce the London Fire Brigade’s ability to deliver a high quality service. The brigade’s current inability to provide normal crewing levels for fire appliances is well recognised by the FBU, and is a constant source of dispute between the principle managers of the London Fire Brigade and the unions H&S safety representatives. Clearly It’s fair to conclude, taking a further eighteen appliances out of action will have a detrimental effect, will increase the risk to our members, by our inability to reach incidents in sufficient time to deal with it at the earliest opportunity. Should these proposals to reduce the number of appliances go ahead, we will have to re-evaluate all the operational procedures currently used, with a view of giving guidance to our members how they should deal with firefighting activities. We predict that firefighting activities will be in a defence mode far more than at present, fire damage will be far greater, and inevitably this will lead to increases in fatalities. We do not support the evidence provided by the brigade in this draft submission as being accurate in this area.

Brigade response: It is not for the FBU to decide how incidents are dealt with. This statement potentially has very serious ramifications and I would invite the FBU to elaborate their intentions.

We call upon the fire authority to seek from the Commissioner and the principle managers a full risk assessment based upon this element of the proposals, and the potential changes to operational procedures as a result, be produced before these proposals as they currently stand, are put forward, so that the real outcomes and impact is known.

Alternate crewing proposals

The London fire brigade is the only brigade in the country that does not have retained fire fighters, and therefore uses the term constant crewing for full time firefighters. Bar the one specialist foam appliance station at Eltham in South East London in the past, all operational appliances and special fire rescue service appliances have been permanently crewed (note: "Permanent crewed" means always available 24x7x365).

Brigade response: Alternate crewing was introduced in 2003 for Incident Response Units (IRUs) and was extended to include High Volume Pumps (HVPs) and later under LSP4, Hose laying lorries (HLL) and Bulk foam Units (BFUs).

Where Alternate Crewing arrangements are used in other UK fire rescue service, it is generally based around retained crews being called into the fire station by emergency pager, to then ride the

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appliance left behind because of the normal crews being ordered to attend an incident riding a special fire rescue appliance. These arrangements are not the model that London Fire Brigade would use. We understand the Commissioner agrees with the FBU in this area, that using the retained duty system in London is both impractical and too problematic against the possible risk of unavailability.

Brigade response: There are no proposals to introduce retained crewing in London.

This then causes us the greatest concerns, for in this case, the commissioner is proposing to use this Alternate Crewing at a number of front line stations using these arrangements, and disposing of the constant crewing system. Where his proposals fall down, is when a call is received at a station that has a permanently crewed fire appliance, this fire appliance then becomes completely unavailable, with no resources to supplement this reduction. This then leaves the station and those that live on the station attendance ground without any first attending appliance. Yes, if there was to be a call, of course an appliance will be ordered from the nearest available station, but and it's a big but, there is a very high probability that it would not attend in six minutes (note add three minutes for real attendance times) and may not even get there at the second attending time of eight minutes. There is no supporting evidence contained within the plan that gives any confidence in this area of resilience.

Brigade response: Nowhere in London would be without a first attending appliance. It is the Brigade’s aim to get to emergency incidents as quickly as possible, and we will continue to do this. As stated above, the use of alternate crewing for special appliances is not new and was introduced in 2003. The proposal in the Plan is to extend alternate crewing to further special appliances (USAR modules/SSUs/IRUs). There are occasions where alternately crewed appliances are mobilised at the same time as the appliance which provides the crew if they are going to the same incident, and this ensures that the full crew is available at the incident location. Alternate crewing is not new in London and has been proven to work well.

The more times this occurs the greater the risk, but it only takes one occasion for this to happen to increase the risk by a factor of 120% as opposed to if both appliances are being constantly crewed and available.

Brigade response: It is not clear where the figure of 120 per cent comes from. It would be helpful if the FBU would share their risk modelling approach that produced this risk factor value.

This also has a reverse affect as well, should the fire appliance be unavailable, because if it is busy else where, then specialist rescue vehicle is also unavailable, given that most of these vehicles are generally for terrorism and special rescue equipped appliances, this unavailability means that in the event a major incident is likely to worsen than the planned outcome. This is supported by evidence and learning needs from the last major terrorist attack in London 7/7. Also this then calls into question the safe systems of work in any preplanning work carried out to deal with an incident of this type. Secondly, under legislation there is an absolute requirement to have these arrangements in place as part the civil contingency act 2004, H&S legislation and core guidance to the FRS in IRMP planning process and lastly the National framework documentation for UK for services.

Brigade response: There is more than one of each type of specialist

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appliance so that if one is unavailable, another from a different location can be mobilised. Should it be necessary, it would also be possible to return a pumping appliance a station to enable the special vehicle to be mobilised. It has not been necessary to do this in the ten years since alternate crewing was introduced. It should also be noted that none of the LFB’s specialist appliances have attendance time criteria. Also, whilst its true to say that the National Resilience (NR) assets (High Volume Pump, Urban Search and Rescue, etc) do have attendance times thresholds set nationally, these can easily be achieved even when the alternate crewing proposal is applied.

The major point to be noted is at no stage did the Mayor indicate in his manifesto, that it was his and his party’s intention to reduce fire rescue service levels to Londoner's. Lastly on this point, the commissioner has stated very clearly that the operational and safety procedures will not be affected by this change. Yet we the staff side safety representatives have yet to see any revised risk assessments or proposed amended operational policies, taking any such proposed changes into account.

Brigade response: Revised risk assessments are not needed as there is no change in the availability of specialist appliances. No standard operating procedures are changing as a result of the proposals in LSP5.

We have already seen the major failing in training as a result of the poor management process put in place and this still continues to date, therefore we say provide the detailed planning, Risk Assessment and other work that supports the proposals, not numbers and statistics, which at best are highly questionable.

Brigade response: I do not recognise the point being made regarding the alleged “major failure in training as a result of the poor management process”. As members are already aware, whilst I acknowledge that the first quarter (2012/13) of the new outsourced training contract was disappointing, the performance has improved significantly through out the year. At outturn 2012/13 the training contractor (Babcock) trained 89 per cent of the total delegate requirement. This compares to 79 per cent in 2011 and 65 per cent in 2010 when training was delivered in-house.

We therefore call on the fire authority to reject these proposals for alternate crewing, maintain the current levels of constant crewing at stations where pumping appliance would be taken out of operational use should these proposals go ahead. We accept that could be scope for alternate crewing arrangements between specialist appliances, whilst this model would also cause us concern, it would not affect the frontline crewing fire appliances.

Proposed Changes to senior officers/ Middle managers

The commissioners proposed plan also includes a reduction in operational senior officers and extending their existing responsibilities. As with the reduction in the number of firefighters by over 10% proposed in the plan, managing operational incidents for senior managers will also be affected. In recent years the most significant group of employees being placed sick with stress related injuries

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has been in this officer group. In the last stress audit carried out by the fire authority, this same group was defined to be the most at risk group of workers employed by the fire authority. The fire authority has also agreed this year to carry out a further stress audit, in line with the health and safety executive guidelines, which the brigade failed to do in the previous stressed audit. It is the view of the FBU the planned audit will show yet again our senior officer members still remain the most at risk group because of increased workloads.

Brigade response: The average number of shifts lost to stress, anxiety or depression (SAD) amongst operational officers was 3.55 shifts in 2005 prior to the previous stress audit and had reduced to 2.79 shifts in the twelve months ending 30 June 2013. This represents a reduction in absence from 1.51 per cent to 1.19 per cent for this group of staff. SAD related absence remains the highest single reason for absence amongst operational middle managers, as a group, although this is at a relatively low level of absence (2.62 per cent over the last twelve months). As the FBU point out, the Brigade will be running a further stress audit in 2013/14 and the outcomes of that audit will be fed into future action plans. Officers will, amongst other approaches, be assessing the impact of stress on particular grade groups.

If these proposals in this area were to be accepted and put into place, we expect to see a significant rise in sickness levels, we believe the additional workloads are excessive and go well beyond the national role maps for station managers and group managers.

Brigade response: Officers do not consider that the changes proposed will generate unmanageable additional workloads and role maps measure responsibilities and role requirements, not volume of work.

The experience of our current operational middle managers is at an all-time low; in the last year significant numbers of very experienced officers have left the service because of disillusionment with the current strategies & policies being introduced by the Commissioner. Those that have replaced them, have little operational experience, and whilst this represents only 25% of their workload, this workload is the risk critical element of their Job. It places a great deal of responsibility on those that are tasked to manage emergency operational incidents at medium to large scale. The knowledge base required to undertake these roles has never been as extensive as it is at the moment. These proposals seek to add additional task and responsibility to this already at risk group of employees; the FBU believes this is a step too far.

Brigade response: Leaver rates for operational staff in 2012/13 were at their lowest levels since 2007/08. The total number of Station and Group Managers who left the service in 2012/13 was 10 less than the previous year and reflects the average total length of service for staff retiring, which was 31 years for Station and 30 years for Group Managers. Only two staff left below the retirement age which again reflects the average for the last five years. Officers continue to monitor leaver rates very closely and the risk of an increase in retirements is due primarily to the effects of pension contribution and tax changes. 5.47 per cent of Station Managers and Group Managers are currently on development and 16.01 per cent are temporarily promoted. This compares to 25 per cent on development and 17.5 per cent temporarily promoted four years ago. The reason for the higher

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numbers of temporarily promoted staff compared to staff in development is that the Brigade is waiting to promote staff from the last middle management recruitment round, but has delayed formalising this pending the outcome of LSP5 due to the proposed officer reductions. The average operational length of service for Group Managers is 23.1 years and for Station Managers is 22.4 years. The result of reducing officer posts will have a temporary effect of reducing promotion opportunities which would actually increase the average experience of officers at this level. It is accepted that decreasing incident rates results in less opportunity for operational staff, including officers, to gain operational experience and that is why there is such a focus on operational simulation and incident command training for officers.

We have seen criminal prosecutions against middle managers in the fire service, regarding their actions and decisions at operational incidents; this has caused much alarm amongst our middle managers, as they can now be held directly responsible as individuals. They do not receive the correct training, yet they are expected to manage operational incidents of increasing complexity, manage the health and safety and welfare of operational firefighters, and ordered them to carry out intensive and dangerous activities without the skills and operational experience one should have in these roles.

Brigade response: Middle managers in the Brigade are selected through a robust Assessment and Development Centre (ADC) which includes an assessment of their Incident Command skills and knowledge. They then progress through a development and assessment process which provides the necessary training and support to enable a candidate to attain the skills, knowledge and understanding for their role as outlined in the appropriate National Occupational Standard. Ultimately the candidate must successfully demonstrate competency against theses standards in a formal assessment environment. Middle managers are then required to regularly attend Incident Command refresher training in order to maintain their competence. In addition to this robust process the Brigade has several quality assurance mechanisms which ensure that middle managers continue to perform their role competently. These include, the attendance at incidents of both a Monitoring Officer and Operations Review Team Officer, Performance Reviews of Command (PRC), the Incident Management Performance Database (IMPD) and the reporting of incident management performance and information to the Operational Directorates Co-ordination Board (ODCB).

Middle managers report to us, the training delivered to them is best described as poor, and the

responsibilities they are continually being asked to undertake without additional payments or other

remuneration is unacceptable and a red line must be drawn.

Brigade response: The feedback the Brigade receives from middle managers regarding Incident Command training is consistently supportive of the courses and their delivery. However, the Brigade is working with our training provider Babcock seeking continual improvements across the complete training portfolio. In the specific case of Incident Command, this suite of training interventions are currently the subject of a review to ensure they remain current and fit

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for purpose going forward. In addition to this, it should be recognised that attending incidents and performing the role regularly is important in maintaining competence and minimising skills fade. The potential for increased attendance at incidents that these proposals offer will lead to greater consolidation and development of Incident Command skills and knowledge. The table below provides a breakdown of the feedback received for incident command training since training was outsourced to Babcock.

Course Content Trainer

Course Good Average Poor Good Average Poor

National Incident Command System

65% 27% 8% 79% 20% 1%

Incident Command Observation 73% 23% 4% 78% 22% 0%

Incident Command Exercise 56% 36% 8% 74% 22% 4%

Discussions on a revised terms and conditions package for middle managers are on-going and no doubt the FBU will raise any concerns they have in regard to payments for any additional responsibilities.

We therefore call upon the fire authority to reject these proposals until the planned stressed audit is carried out and the findings are reported to the fire authority later this year. Once the findings are known, a joint review of these proposals should take place, evaluating whether the planned changes are achievable within the current roles, or whether amendment should be made by way of additional payments or reduction of workloads.

Conclusions We find this the most reckless integrated management plan ever put forward by any fire rescue authority in the country. If a company on the stock exchange cut over 10% of its operational workforce and closed its outlets at the same time, saying it was their professional judgment it would not impact upon the delivery of services to their customers, the share price would fall dramatically, the board would be taking a very hard look at the decision of the management team and more importantly the professionals who work in analyzing the information would be making sure that the advice to share holders would be to get out as quickly as possible. But to suggest this by the Professional Principle managers of an emergency response service tasked to manage the capital safety is irresponsible and reckless. As said by many of the public attending consultation meetings, this raises serious concerns about their abilities, and should the proposals be rejected by members LFEPA, serious consideration must be given to those that run and manage the London’s fire service, as both employee’s and the public we serve in London will have a complete lack of confidence in the future of the brigade. Every public meeting we have attended, we have yet to find any individual that supports the Commissioner’s plan. The level of cuts being proposed is so extensive, that the public taxpayers of London have no interest in any of the positive work that has been carried out in other areas of the brigade contained within the plans. This is a testament to the failure of the report, and importantly a

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failure by the Commissioner and the principal managers to carry out risk based IRMP, taking into account as it is required to do, the IRMP guidance notes, the fire service national framework documentation for UK fire rescue service and most importantly failure to take into account services users and their expectations. As we have said earlier, we believe the Commissioner and the principal managers of the London Fire Brigade, have solely based this plan around the financial constraints placed upon them by central government and Mayor Boris Johnson. These basic principles for all future plans should be:

• Coherent proposals • Honesty around the documentation • Full Transparency • Produce a plan that takes into account all the hazards and risks posed to Londoners

in all areas. • Produce a plan that meets the expectation of Londoners.

Recommendation to the LFEPA

Quite clearly, these proposals have been rejected three times by members of the fire authority already, and they have not changed. We believe that the plan should be rejected again by LFEPA for all the reasons we have outlined above, and quite simply because Londoner’s want to be able to count on its fire service when and if it is needed. Accepting these proposals in our professional view would mean Londoner’s would not have a fit for purpose fire service.