Saturday, 30 August 2014

Fire consultation is misleading and dangerous

After an examination of West Sussex Fire & Rescue Service’s consultation document, ‘A fire service for the future’, I have significant concerns regarding the validity of the consultation and the real dangers of the proposals.

The document is misleading, omits significant information, and contains proposals that will increase the risk to life and property across West Sussex. A review of the published minutes from the County Local Committees also suggest that fire officers have provided some misleading information to County Councillors and the public.

Whether this was done innocently or deliberately, the result is that County Councillors and the public have been asked to approve the proposals based on inaccurate and misleading information. The consultation does not meet the standards expected of a public consultation and should therefore be set aside.

General issues related to the consultation

a.     The anticipated savings for each of the various proposals are not shown. People should be informed, so that they can decide if the anticipated saving of each proposal justifies the reduction in service.

b.    Much has been made of the drop in calls attended by the service, but this is misleading. This has largely been achieved by putting the public and firefighters at greater risk by refusing to attend some fire alarm calls. Many may turn out to be false alarms, but others are not, and by delaying the response to those calls public and firefighter lives are put in danger. What the public has not been told is that, since 1948, the area covered by West Sussex Fire & Rescue Service has seen 6 fire stations closed and 17 fire engines removed from operational service. These proposals will remove another five fire engines, even though call levels are three times greater than they were then.

The number of calls has never been a key factor in determining the provision and location of fire engines. The relevant factors are the number needed in each area to reach incidents in a reasonable time, to cope with more than one incident occurring at the same time, and to provide reinforcements or cover for larger incidents. There was no increase in the number of fire engines when calls increased fourfold, so there is no case to reduce them, because of a slight reduction. In addition, there is no evidence that calls will continue to decrease.

c.     The Government has said they want Fire & Rescue Services to increase the number of Retained Duty System (RDS) firefighters. In these proposals the Chief Fire Officer is ignoring that direction by reducing the overall number in West Sussex.

d.    The Chief Fire Officer claims that the number of people killed in fires has ‘significantly reduced’, but this is not true. His own figures show that fire deaths in West Sussex have tripled in four years (two in 2009-10, three in 2010-11, four in 2011-12 and six in 2012-13). So has risk reduction failed, or have delays resulting from previous cuts in the number of fire engines and firefighters contributed to this increase?

e.     This also makes the modelling, that claims ‘minimal cost in terms of life and property damage’, extremely suspect. Such modelling is unproven and its reliability in doubt. The more established modelling used by the Environment Agency said that the 1994 flooding in Chichester was a ‘one in five hundred year’ event, yet it was repeated just six years later. There is also no indication that all the negative costs of these proposals have been properly assessed. Such things as more people dying in hospital, after being trapped in crashed vehicles for a longer time, and increased property damage from flooding when firefighters are delayed, or unable to attend because of the volume of calls. It is highly likely that the cost in lives, more serious injuries and property damage will be much greater than claimed.

f.     Much is made in the document about reduced risk, yet this is based on call changes over just three years. It is not possible to draw reliable conclusions about trends from three, four or even five years of data. This is well illustrated by a previous Chief Fire Officer, who wanted to cut the number of firefighters at Chichester. He produced accurate figures that showed a drop in calls attended over three years, but falsely claimed that this downward trend would continue. Those opposed to the proposal produced figures going back about 30 years and these clearly showed that the overall trend was upwards. They projected that, instead of decreasing, the number of calls would actually increase by some 60% over the next 20 years and they were proved right. It is irresponsible to make changes based on inadequate data and unreliable modelling.

Making changes to the Critical Fire Risk map based on just three years data is irresponsible and dangerous. The reality remains that, irrespective of the data used, anyone, anywhere in West Sussex can suffer a fire in their home, be trapped after a road collision, or be at risk from a range of other hazards. When that happens people need a speedy and adequate response from the fire and rescue service. Telling people that they have to wait longer for help, because there have not been enough calls in their area, or the area is deemed safer than others, or more prosperous, or too modern, will be of no help to them whatsoever. They need help and should not be discriminated against, because of where they live.

g.    The Modelling and Analysis Technical Report states that ‘each proposal has been the subject of a risk assessment. However, risk assessments are only shown for three of the eight proposals and there is no risk assessment for the package as a whole. The criteria used for determining the scores have not been shown for the few risk assessments that are included, so their accuracy cannot be assessed. However, the likelihood and severity ratings appear to be rather on the low side, so the actual risk may well be greater.

h.     The Fire & Rescue Service has considerable responsibilities under the Civil Contingencies Act, yet none of the reports mentions these important responsibilities. It appears that the Chief Fire Officer has failed to assess the impact of these proposals on those responsibilities, which is a major omission. The Act requires the service to maintain critical functions during major emergencies, but these cuts in fire engines and crews will seriously affect the ability to comply with this legislation.

i.      The over use of RDS crews and too many responses outside the communities they joined to protect have been given as reasons for RDS resignations in the past. These proposals will increase the time that the remaining RDS firefighters have to spend responding to incidents. They will also have to respond to other station areas more frequently. This poses a significant risk of more RDS resignations and crew shortages.

j.      No alternative proposals are included in the consultation document, which wrongly suggests that there are no alternatives. Significant savings have been achieved by other Fire & Rescue Service mergers, and a £1.0m saving for West Sussex was claimed to be achievable with a merger of West and East Fire & Rescue Services during a previous consultation. I understand that government delays stopped the previous merger plan going ahead, but I see no reason why problems could not have been overcome in the intervening years.

k.     The South Chichester County Local Committee was told that there were no proposals to reduce the number of fire engines, when in fact the proposals will see a reduction of five.

l.      The North Chichester, and the North Horsham County Local Committees were told about the capabilities of the 4x4 vehicles, as if this would be an improvement. The stations concerned already have these vehicles, so already benefit from their capabilities. What they should have been told was that the loss of the second fire engine would mean that there would be less flexibility, as the station would no longer be able to attend two separate incidents.

For example in 2012, whilst the first fire engines from Midhurst, Petworth and Storrington were helping colleagues along the coast to deal with storm related incidents, the second fire engines on those stations were protecting their own areas and responding to other calls. Those present were also not told that, at building fires, the first crew will now have to wait longer, whenever they are in need of the additional water, hose, breathing apparatus, ladders etc that are carried on second fire engines. In a rural area the prompt arrival of additional water and hose can often mean the difference between fires being controlled, or becoming out of control.

m.   If these proposals go through, no matter where people live in West Sussex, they will be at higher risk of a delayed response from the fire and rescue service. With fewer fire engines and crews there is no guarantee that those nearest to the incident will be available. Increasingly those fire engines will be at other incidents, or helping in areas directly affected by these cuts, or unable to respond as there are not enough firefighters to crew them.

n.     The current proposals will see West Sussex with one of the worst resourced services in the UK. Cornwall, a poorer county, will still have 43 operational fire engines and crews (1 for every 12,500 people), whilst West Sussex taxpayers will only have 35 (1 for every 23,000 people).

Specific Proposals

Proposal 1 - Move one of the two immediate response fire engines at Horsham to Littlehampton, making it a 24-hour immediate response station.

a.     This claims a fire engine will be moved from Horsham to Littlehampton. This is not true, as it will actually result in one less fire engine and crew being available in West Sussex. Whilst response times at night will improve in Littlehampton, the level of cover throughout the day in the north of the county will deteriorate. The claim that the outcome will be ‘improved service performance’ is therefore false.

b.    The Modelling and Analysis Technical Report is also inadequate, as it fails to properly consider the effect on fire cover resulting from the loss of this fire engine and crew on the service as a whole. In particular, when considered with proposal 4, the very significant effect on the north of the county.

c.     In the Equality Impact Report the Chief Fire Officer claims that to mitigate the effect of this proposal he will improve the resilience of the RDS unit at Horsham and surrounding stations by ‘targeting recruitment and retention in these areas’. This suggests that work to improve RDS recruitment and retention has not been carried out at stations mentioned in proposals 3 and 4, when crew shortage has allegedly been a key factor in low use of those fire engines. If so, the question has to be asked, ‘why not?’ Alternatively work was carried out, but it has failed. If so, that raises serious doubts that it will work in this case. The Chief Fire Officer cannot have it both ways.

Proposal 2 - Introduce group-crewing model at immediate response stations.

a.     This claims no reduction in performance, but the proposal has been completely left out of the Modelling and Analysis Technical Report, so there is no evidence to support the claim. When West Sussex had higher crewing levels there were still occasions when immediate response fire engines were unavailable, or became dependent on RDS crews to supplement wholetime firefighters, which delayed their response. If the number of wholetime firefighters are reduced yet further, then the reality is that this will happen on more occasions.

b.    Previous cuts in firefighter numbers has seen a rise in occasions when the nearest specialist appliances, such as lifesaving Heavy Rescue Tenders and Aerial Ladder Platforms, cannot be crewed. Significant delays occur whilst waiting for the next nearest appliance to attend from stations that are 20 or 30 miles away. This proposal will see a significant increase in this type of delay.

Proposal 3 - Remove the 2nd fire engines at Midhurst, Petworth and Storrington.

a.     This claims ‘minimal impact on performance’, which is wholly misleading. That impact, according to the Modelling and Analysis Technical Report is a higher cost in terms of life and property damage. It is unacceptable to describe this as minimal, and omitting this information from the consultation document is shameful.

b.    The document also states that the second fire engines at Midhurst, Petworth and Storrington are often not crewed due to an insufficient number of retained firefighters being available. That deficiency is the responsibility of the Chief Fire Officer, not the firefighters at those stations. I was shocked to read in the station profiles that these stations have been deliberately understaffed. RDS stations with one fire engine should have an establishment of 12 and those with two fire engines should have 20 to maintain round the clock cover. Yet these stations have each been restricted to a maximum of 15 personnel to crew 2 fire engines and a 4x4 vehicle on a 24 hour, 365 day basis. Those stations should be applauded for crewing two fire engines on as many occasions as they have. They should not be criticised for the times they have been unable to.

No doubt the Chief Fire Officer will tell Councillors that it is difficult to recruit and retain RDS firefighters who can provide day cover. This is not a new problem, but what has the Chief Fire Officer done to overcome the difficulty? Occasional press releases and half-hearted recruiting campaigns are not enough. Why has there not been a comprehensive investigation in to why suitable people do not apply to be RDS firefighters, and in to why many RDS firefighters resign? Solutions will not be found without such an investigation in to the root causes of the problem. How many town or parish councils, local business groups, or professional partners have been consulted on this problem and invited to help find solutions? What reports have been submitted to County Councillors on the problem and on possible solutions? The Chief Fire Officer needs to remedy this neglect.

c.     The reference to use of the 4x4 vehicles is also misleading. The consultation document says that when additional firefighters are required, a 4x4 vehicle will proceed as well as a fire engine from another station. However, the Equality Impact Report states only that ‘consideration is being given to mobilisation of the four wheel drive’. Which is it? If it is only ‘consideration’, then the consultation document is again misleading.

d.    The Chief Fire Officer also claims that this proposal will improve flexibility, which is untrue. These stations already have 4x4 vehicles, so any flexibility they do afford is already available. The reality is that removing the second fire engines will drastically reduce flexibility. Currently the second fire engine can be used to support the first fire engine at more serious incidents, or attend other incidents as the first response when the first fire engine is already committed. There have been many occasions when one of the fire engines from these stations has been at incidents or providing cover in other towns, and the second fire engine has been available for incidents in their own area. That is true flexibility, which will be removed by these proposals.

e.     As no figures are included, it is not possible to confirm that the additional costs of this proposal have been included in the calculations. The response to a building fire in these areas would currently be two vehicles with a maximum of 12 firefighters. The proposals would change this to three vehicles with a maximum of 17 RDS firefighters, all of whom are paid by the hour. One of the vehicles will also be travelling further, so running costs will be greater and the extra time taken will, on occasions, see up to 6 firefighters having to be paid for an extra hour. These costs will add up and undermine any savings from the proposal. Not forgetting of course that the proposal will also cost more lives and increase property damage.

f.     The Equality Impact Report claims that planning takes into account the needs of the whole community. However, it has completely failed to consider the more significant effects of this proposal on the rural poor, rural elderly and rural ethnic minorities. These groups are more vulnerable for a variety of reasons. For example, they are more likely to be in rented, older and less well maintained properties where the risk of fire and the risk of becoming trapped is greater. With less access to public transport these groups also need their own cars, but often can only afford older second hand ones. These have fewer safety features, such as air bags, than modern ones and in a collision they are more likely to be trapped with more serious injuries. The Equality Impact Report has not been properly carried out.

g.    The report also suggests that the increase in response times to calls in the Midhurst, Petworth, and Storrington areas ‘will be slight’. With the number of fire engines on these adjacent station areas being cut by half, it will in fact result in considerable delays. Even a 10 minute additional response time is significant if you are trapped by a fire, trapped in a crashed vehicle, or at risk of drowning during floods. The reality is that there will be many occasions when the delay is 15, 20 or even 30 minutes. During severe weather conditions, when the number of calls rocket, these areas are highly likely to see even greater delays and potentially no response at all.

h.     In the Modelling and Analysis Technical Report it is claimed that the increase in the use of fire engines from Hampshire and Surrey in Midhurst’s area is ‘the introduction of AVLS (Automated Vehicle Location System)’. This is misleading, as the control room may know where West Sussex fire engines are, but they cannot see actual locations for fire engines in other counties. Requests for assistance are therefore based on the assumption that those fire engines are at their stations, when they may actually be further away and take longer to arrive. West Sussex should be providing adequate resources and not taking them away from other counties.

i.      In the station profiles we are informed that ‘where a second appliance has been removed in the past, the availability of the first appliance has been seen to subsequently decline’. This is a significant risk that will result in even more delayed responses, but the information has not been included in the consultation document.

j.      The figures only show incidents attended by second fire engines, which is misleading. They also fulfil a valuable role when standing by at other stations, when their fire engines are committed at incidents, and when carrying out community safety work. These figures should have been included to show the full value of these resources. 

Proposal 4 - Closure of retained unit and removal of 3rd fire engine at Crawley

a.     This claims ‘resources more proportionate to risk’, yet the Chief Fire Officer’s own figures show the situation is actually getting worse in Crawley. To reduce resources is clearly not ‘proportionate’. 75% of the fire deaths in West Sussex during 2013-14 were in the area covered by Crawley fire station. In addition, so far this year West Sussex Fire & Rescue Service have rescued 5 people from fires – all of them from fires in Crawley.

b.    The Modelling and Analysis Technical Report admits that this proposal will have a higher cost in terms of life and property damage, but this is omitted from the consultation document.

c.     In recent years the number of fire appliances available in Crawley Borough has been reduced from 5 to 3. This proposal will reduce it to just 2, which is totally unacceptable. Gatwick Airport and businesses in Crawley that supply the airport, are key contributors to the UK economy. They also add significantly to the West Sussex economy and to council coffers. A major fire at the airport, or at one of their key suppliers, would have massive implications, yet no consideration has been given to this as the Chief Fire Officer plans to cut yet more fire engines. The additional delay on response times for an air crash at, or near, the Airport is also totally unacceptable.

d.    Once again the Equality Impact Report has completely failed to address the more significant effect of this proposal on the elderly, poor and ethnic minorities in Crawley Borough. These people are statistically more likely to have fires and to need rescuing, so reducing further the number of fire engines in Crawley will unfairly have a greater impact on these vulnerable groups.

e.     The Chief Fire Officer claims that to mitigate the effect of this proposal he will improve the resilience of RDS units at surrounding stations by ‘targeting recruitment and retention in these areas’. As mentioned in relation to proposal 1, there are serious doubts that this will work and the residents of Crawley will therefore be at even greater risk.

Proposal 5 - Implement revised day crewing model at Variable Crewed Stations

a.     This claims to maintain response standards at reduced cost. However, this proposal has not been covered in the Modelling and Analysis Technical Report, so there is no evidence to support the claim.

b.    As mentioned in relation to proposal 2, with fewer firefighters the number of times fire engines become unavailable, or dependent on RDS crews, will increase along with response times.

Proposal 6 - Increase operational capacity and support for communities in flooding and severe weather

a.     This claims that it will provide an improved response to flooding and severe weather events, yet no evidence to support this is included in the Modelling and Analysis Technical Report. No details are given, so it is impossible to tell if this money is to be spent wisely, or if it would be better spent on avoiding proposed cuts in service.

b.    One of the most important requirements during flooding and severe weather is simply the availability of a large number of properly crewed fire engines, rather than specialist equipment. Any benefit from this proposal, for the few incidents where specialist equipment is required, will be undermined by having five fewer fire engines and crews to respond to the many other incidents where specialist equipment is not required.

Proposal 7 - Reductions in management and administrative support

a.     This contains encouraging words, but no substance. There has been plenty of time to review management and administrative roles, so there should have been concrete proposals in the document for people to consider.

b.    West Sussex County Council has achieved substantial reductions in management and administrative posts in all departments except the Fire & Rescue Service. They have even done away with the Chief Executive’s post, as well as all ‘deputy’ posts. Yet the Fire & Rescue Service, despite the financial crisis, continues to have a Chief Fire Officer, Deputy Chief Fire Officer and an Assistant Chief Fire Officer. In fact the Assistant Chief Fire Officer post was only recently reinstated after being removed during previous cutbacks. There was no consultation on the reinstatement, no business case was published, and the financial situation had not improved. The crews of the five fire engines proposed to be cut could have been used to save lives and property, the senior management posts will not save either.

c.     West Sussex County Council has also invested heavily in new technology to enable staff to participate in meetings without having to spend time and money travelling. The need for senior managers to run expensive vehicles can no longer be justified and this should have provided an opportunity for significant savings. The Chief Fire Officer will no doubt say that they need cars to respond to incidents, but the top three officers attend far less calls than the fire engines they want to cut. Perhaps they should have one shared small car between them, but they certainly do not need one each.

Not covered in the document, but relevant to this proposal, is the concerning news that officers are apparently now going to be provided with 4x4 vehicles. At a time of financial restraint, replacing cars with more expensive and less environmentally friendly 4x4 vehicles seems most inappropriate. It is not clear if this is for all officers, but the cost really needs to be questioned.

d.    If the service is to be modernised, the Chief Fire Officer and his senior colleagues need to set an example by cutting the costs associated with their attendance at meetings, seminars and conferences. Acceptable in better financial times perhaps, but not when frontline resources are being cut.

Proposal 8 - Utilise additional trained staff to improve operational resilience

a.     This is quite alarming, as this should be normal practice in the Fire & Rescue Service. It was certainly done in West Sussex under previous Chief Fire Officers, so has the Chief Fire Officer been failing to use his resources properly, or is this ‘proposal’ actually no change?

b.    There would also appear to be opportunities to utilise trained staff, not on frontline duties, to cover shortages of RDS staff. With modern technology it should be possible to locate some of them at RDS stations to carry out their normal duties. Whilst there they could also help crew fire engines at those stations at times when there are crew shortages. This opportunity does not seem to have been considered.


The implications of these proposals have not been fully explained in the consultation document, the supporting documents are deficient in a number of areas, and the proposal package represents a risk to the lives and property of people in West Sussex. The consultation is invalid and the proposals should be rejected. Revised proposals and a proper consultation should now be provided.

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