Saturday, 5 December 2015

Response to the 2015 Hampshire Fire and Rescue Authority Consultation

The Hampshire proposals will have a significant effect on West Sussex, so I have responded to the consultation as follows:

This response should not be edited or altered and should be presented to Fire and Rescue Authority Members as submitted. This and other submissions should be made available for the public to read on the Fire and Rescue Authority website.

Provision of Information

It is disappointing that some of the information in the consultation document, and that provided at the consultation meetings, was inaccurate or misleading. Both also sadly lacked sufficient detail to support the case for change.

The Chairman’s claim that there has been a 52% reduction in fire related incidents is misleading. No timeframe for the claim is given, so it cannot be substantiated, and it ignores the fact that the number has both increased and decreased over time. The area covered by the current Hampshire Fire & Rescue Service now responds to three times the number of emergencies that they did in the 1950s.

Even recent trends show a significantly smaller reduction in fires than claimed. Had a more accurate five year average figure been used for fires in the home (dwellings), which are of the greatest concern to most people, the reduction since 2000/2001 would have been significantly lower.       

The Chief Fire Officer’s claim that “we refuse to compromise the safety of Hampshire residents or our firefighters and our response to emergency incidents”, is deliberately misleading spin. The proposals will clearly compromise safety and response. Inadequately crewed vehicles and longer waits for an effective response can only increase the risk to residents and firefighters, and will therefore compromise their safety.

The incident figures shown in the document for fire stations are wholly misleading. To provide a fair and accurate guide to the activity of fire stations, all incident responses should have been shown. Omitting incidents attended in other station areas, in other counties, as relief crews and as standby crews is dishonest. The excuses that the public would not understand, and that it would be ‘double counting’, are insulting and without merit.

The claims made for improved response times at each station are dishonest, as the criteria has been changed. Current response times are based on a fire engine with at least four firefighters, but the estimates for after the proposed changes are based on just two firefighters arriving on a different vehicle. It is only a fair comparison if the estimates are based on the arrival of at least four firefighters. Had that been done response times would have been significantly worse.

A recent YouGov poll showed that 95% of the public feel that rapid response must be a high priority for the fire & rescue service. There is no doubt that they were thinking of an effective response with enough firefighters to rescue them, not just a crew of two who can only stand and wait for help to arrive from further away.

There is a complete lack of detail on the planned new vehicles, which seriously undermines any claims made for their effectiveness. It is not sufficient, when proposing such major changes, to be told, “we expect”, “we believe”, and “we hope”! Hard evidence is required before such far reaching proposals are accepted and that is sadly lacking.

One of the most significant flaws, as the proposals and claims largely depend on it, is that new technology can enable an effective response with fewer firefighters. This is not only lacking in evidence to support the contention, but all the evidence that is available contradicts the claims and therefore undermines the proposals.

The manufacturers of the high pressure lance have many years of reports from fire services that use their equipment. Peter Oom at Cold Cut systems, the Swedish Manufacturer, has confirmed that none of them record a life being saved by using this technology - “I don’t have any confirmed cases where the cobra has saved lives, neither fire fighters or victims”. He also confirms the equipment can be hazardous to people inside a burning building - “the jet can be potentially harmful if sprayed (certainly with abrasive on) at a close distance”. I asked for copies of training notes, presentations, and any research documentation, but have had no reply. Had there been evidence I am sure I would have been sent it, but it appears that there is no hard evidence, just speculation and theories.

The only reports that mention lifesaving refer to firefighters, wearing breathing apparatus, completing rescues before the high pressure lance was used. So the claim by HF&RS that it can be used to save lives is without foundation. It is also clear from the reports that on many occasions breathing apparatus wearers had to be deployed to use the high pressure lance. To comply with safe working practices for breathing apparatus, at least four firefighters must be present if used externally, and at least nine firefighters if breathing apparatus is to be worn inside a building.

The high pressure lance only offers benefits if it is available as an addition to the equipment already carried on fire engines. In the right circumstances, and with no lives in danger, it may be useful, but in other circumstances different equipment and procedures will be more suitable and effective. In addition to being unsuitable at fires where rescue is required, it is also unsuitable for slow burning fires, where there is lots of smoke but little heat, where the room on fire does not have an external wall, and for fires in the open, or where the roof has already vented.

Contrary to claims by HF&RS this technology is not new and it is not widely used. Where it is used it is mostly as an addition to the equipment on standard fire engines. Even where it is fitted there is no evidence of frequent use. With the majority of UK, European and worldwide fire services not using it, and those who do have it only using it rarely, the real evidence suggests that HF&RS claims about its capabilities are little more than wishful thinking.

No safe systems of work exist for crews of less than four firefighters, and there is no evidence to support the contention that they can be developed. The Health & Safety Executive have previously made clear that systems of work, which prevent employees from completing tasks unless they ignore safety instructions, are unacceptable. These proposals will place firefighters in situations where their instructions will be to not act until support arrives, yet the pressure to act will be enormous. They will face unacceptable moral and public pressure to ignore safe working practices, and will inevitably be compelled to take unacceptable risks. It would be wrong, morally and legally, for Hampshire Fire and Rescue Authority to put their employees in that position.

Response Times & Risk

The questions in this section are misleading and the claim that response times will be improved and risk reduced are false.

The Fire & Rescue Service claim, that response times will improve, is based primarily on reducing the minimum crew on a fire engine from four to two, thus increasing the theoretical speed of response. Yet this will inevitably increase the risk to firefighters and it will increase the time taken for an effective response to arrive. That is especially so where rescue is required. The proposals will significantly increase the potential for loss of life at fires and at other incidents where people are trapped, such as road crashes, where time is of the essence.

Reducing the number of Retained firefighters at each station will also increase the number of occasions when only two firefighters are available, thus increasing the number of times an effective response is delayed. Common sense says that with up to a third fewer firefighters, the number actually available at various times will decrease, which will make overall availability worse. It will also result in many more occasions not even two firefighters will be available. Consequently response times will rise, not fall.

Retained firefighters are also likely to feel unreasonably exposed to risk and public criticism when only two of them are sent to emergencies. There is a significant risk that this will result in more of them resigning and of it becoming more difficult to recruit. Especially so when the inevitable complaints of firefighters ‘not doing enough’, or ‘refusing to go in’, are highlighted by the media.

Costs and Efficiency

The inference is that the proposals will increase efficiency, but they will not. There is no evidence in the documentation that the changes will be efficient or effective.

Experience in other Fire & Rescue Services suggest that initially reduced costs may quickly rise, as overtime and retained firefighter payments increase to cover crewing problems. Problems created by cutting the overall number of firefighters too severely.

The safe minimum of nine firefighters required at a building fire is now usually met with two fire engines from one or two fire stations. With minimum crews of two, that may rise to as many as five vehicles from five different fire stations. Not only increasing response times, with longer travel distances, but increasing travel costs and the cost of extra hours for retained firefighters on longer journeys.

Larger incidents will also see many more vehicles needed from a much wider area than they do now. That is neither efficient nor effective, and it will also leave significantly more areas without effective fire cover. References to standby moves at the consultation meetings was misleading, as they do not increase fire cover. Every standby move involves reducing fire cover somewhere else. As more and more fire engines are committed to the incident, the remaining ones are just spread out to provide a reduced level of fire cover across a bigger area. The more that are committed to a major incident, or to simultaneous incidents, then the thinner the fire cover becomes.


The concept of different vehicles for different incidents is fundamentally flawed.

A properly equipped and crewed fire engine can be sent to any call and the crew can begin to take effective action every time. That provides full flexibility and ensures that, if the initial report is inaccurate, then nothing is lost. Members of the public, especially when stressed, do not always give accurate information on the nature or seriousness of the incident. Similarly, automatic alarms do not give any indication of how serious a fire is.

In many areas the proposal is that smaller vehicles, that have yet to be designed, will be sent to all incidents. It is claimed that this will be adequate for 70% of calls. This also means that it will be inadequate for at least 30% of the most serious and life threatening emergencies. No evidence is provided to support the Fire & Rescue Service’s claim that these vehicles will be adequate for the other 70% of calls, so they could actually be inadequate for 40%, 50% or even more.

Sending crews of just two or three to incidents, in the full knowledge that they will not be able to cope with at least 30% of serious incidents, is reckless.

Over many years, in different UK fire services, there have been several experiments involving the replacement of standard fire engines with smaller vehicles. All of them have ended in failure, with the smaller vehicle ultimately being replaced with a proper fire engine. The only exception is in locations with severe access difficulties, where smaller vehicles are provided and crewed in addition to, not in place of, standard fire engines. There is nothing in these proposals to suggest that this large scale experiment will be any more successful.

Claims, made at the consultation meetings, that firefighters will be able to decide what equipment they want on these new vehicles are deceitful. If the vehicles are smaller it is obvious that many requests from professional firefighters will be refused, because there is no room on the vehicle, or because it will overload it.

It is also a nonsense to talk about different areas needing differently equipped vehicles. The fundamental equipment needed at a fire, at a road crash, for flooding or for other emergencies is the same. It does not matter if that is in the centre of a city or on a remote farm. Also, at busy times, and for major incidents crews can find themselves in any area, so the flawed concept would then result in crews having the wrong equipment for the area they have been sent to.

The concept of standard fire engines carrying equipment that enables them to tackle, or begin to tackle, any emergency, supported by specialised equipment carried on support vehicles where necessary, has withstood the test of time. Not just in the UK, but across the World. Significant evidence would need to be provided to justify a departure from such sound practice. There is no such evidence in the consultation documentation.

Fire Station Crewing

The concept of crewing fire stations with differing numbers of firefighters according to type, number and timing of incidents is seriously flawed. Incidents of any type, and of any severity or scale, can occur anywhere and at any time. It is complete nonsense to propose that some will be better and more quickly resourced than others.

An incident that requires five, nine, twenty, fifty or a hundred firefighters, will need that number no matter where or when it occurs. This is not about a supermarket that knows when their busy periods are and varies their staffing accordingly. This is a lifesaving service that needs to be able to respond to any emergency, at any time, and anywhere.

It is seriously concerning that the proposals to have less firefighters available is at times when the risk to life and the potential for more serious incidents is greatest. It is simply reckless to reduce the effectiveness and speed of the response at times when people are most vulnerable.

Council Tax

As a resident of West Sussex, who will be affected by the Hampshire changes, I support a rise in Council Tax in West Sussex to increase payments to Hampshire Fire & Rescue Service to maintain the status quo.

It is clear that West Sussex Fire & Rescue Service has not been fairly contributing towards the cost of support from Hampshire Fire & Rescue Service. Less than £300 per incident, irrespective of the number of firefighters and fire engines attending from Hampshire, is wholly inadequate. With a significant area of West Sussex dependent on Hampshire support, consideration should be given to an arrangement where West Sussex pays a fair share of the actual operating costs for Hampshire fire stations that provide first response in to West Sussex.

The additional payment should be such that the current provision can be maintained at Emsworth, Havant, Horndean, Petersfield and Liphook fire stations.

Proposals for Each Fire Station

This section is divisive, unfair and improper.

Quite rightly West Sussex views are not being accepted on Hampshire Council Tax increases. At the consultation meetings people were also told that it would be improper to trade one station’s cuts off against another’s, yet this trades one council area’s cuts off against another’s.

The responses to the questions for each district cannot be evaluated fairly. The majority of people responding will only be directly affected by changes in their areas, so they will be unfairly inclined to oppose those, whilst supporting proposals that do not directly affect them.

In addition, the numbers of people affected by each proposal are not the same. Some districts have more than double the population of others, which will also distort the responses.

These concerns apply even more to the question about options for Andover, Gosport, Havant and Winchester. Only people living in those areas should have been permitted to respond to the specific question for their community.


These proposals unfairly discriminate against the more significant effects 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 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. Yet the proposals will have the most detrimental effect on the very rural areas that these people live in.

Information about you

I do not work for Hampshire Fire & Rescue Service, but served in the fire service for 32 years. I was subsequently a local authority emergency planner working with all agencies at local, regional and national levels until 2014. Before, during and since my fire service career I have studied fire service management, procedures, equipment and operations around the World. My comments are therefore based on a sound and extensive understanding of the fire service and of current threats and hazards.

The other questions in this section are irrelevant to the consultation. To demonstrate equality, you need to show that you have ensured that all sectors of the community have had the opportunity to respond to the consultation. That is not demonstrated by asking for personal details of only those who actually respond.

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