Information Commissioner not fooled by County Council excuses

The Information Commissioner rejects 

West Sussex County Council's claims

Some may recall the refusal of my freedom of information request for details of incidents where the County Council's target response times were not met. Initially they claimed that "the information you seek would be likely to endanger the physical or mental health of any individual or the safety of any individual." 

The internal review upheld the refusal but then bizarrely claimed, "this Authority does not hold data relevant to your request." A dishonest claim when that core performance information is used in reports to Councillors and to Government. The Information Commissioner's report says:

The Council has been given 30 days to locate the information and to provide a fresh response. We will have to wait to see if they finally provide the information they hold or try some other excuse to conceal worrying performance information.

Poor performance is no excuse for unlawful secrecy

How bad is the performance?

Well, as they won't make it public it is not possible to be exact. However, for example, firefighters have reported it taking 25 minutes for the first fire engine to arrive at a critical fire in Rogate, because the nearest fire engines did not have firefighters to crew them.

I have also had reports of a critical fire in Wisborough Green, where four Horsham firefighters had to struggle until back up crews arrived from Dorking (18 miles), and Chichester (21 miles). Again, several nearer fire engines did not have firefighters available to crew them.

Now there may be other reasons for problems on that day, but with details kept secret there is no way of knowing.

The public deserve to know the truth

Ineffective Fire & Rescue Service Scrutiny Committee 

This committee should be asking for details of the worst failures and investigating why it has been kept from them. If they were scrutinising properly, they would be demanding the information from Cabinet Member Duncan Crow. They should also be asking why he is allowing legitimate freedom of information requests to be unlawfully rejected. 

When a Conservative controlled committee fails to properly scrutinise the worst effects of Conservative cuts to the fire & rescue service, the public are going to be suspicious. Those in the service can only do their best with the resources they have. By not investigating the Council's inadequate resourcing, which has resulted in a failure to provide an effective service, the scrutiny committee is neglecting their responsibilities.

Effective scrutiny of deteriorating performance is long overdue

Another unlawful Freedom of Information refusal by WSCC

A Mr Robert Dymond requested attendance details, times, and messages for the 2023 fires at the Angel Hotel in Midhurst and the Harvester in Littlehampton. All quite legitimate performance information that is provided on request by other fire & rescue services. With their casual disdain for the legislation and West Sussex residents, the County Council refused the request. The disingenuous grounds given for refusal were that the information is already available through the 'Request a Fire Report' process. 

Not only is the attendance detail requested not usually included in fire reports, but the County Council will only provide a fire report to the occupier, or someone connected to the occupier who has a legitimate interest (e.g. building owner, or insurer). I would be very surprised if Mr Dymond would meet that requirement for both incidents. I hope that he requests an internal review and, if that is unsatisfactory, he will submit a complaint to the Information Commissioner.

Once again, the County Council is illegally hiding performance data from the public

Consultation on a plan that is not a plan

Now I know it says it is a plan, but it is just a list of objectives with no plan on how to achieve them. Completely lacking in detail, unrealistic, and with no funding to make any improvements. At best it is a wish list, at worst it is just County Council spin.

Take 3.1, where they say they are going to enhance the availability of fire engines. There were similar claims, sorry objectives, in the two previous CRMPs, but availability has got steadily worse. They ask, "To what extent do you think the Service Delivery objectives outlined in this plan will improve WSFRS’s ability to respond to fires and emergencies quickly and effectively?" 

The only informed answer must be:

This 'plan' is meant to be West Sussex County Council telling Government how it will meet its legal obligation to provide an effective service. It is already providing a less effective and less safe service than it has ever done, and nothing in this document indicates that they will act to reverse the decline. Indeed, with some of the reviews mentioned, the County Council is likely to make West Sussex firefighters and residents even less safe and less well protected.

Should you complete the consultation? Yes, I think you should, the more people that tell the Council this plan is inadequate the better.

Consultation closing date - 22 September 2025

 

Whatever happened to the previous consultation about response standards?

This closed in February, but the outcome does not appear to have been published or even shown to the scrutiny committee. It was intended to deviously change the standards so that more failed response times would in future look like the standard was met, even though the actual times were the same. This chart shows how the last published response time failures would be reduced by the new 'standard'.

So, have consultation responses not been published because the public rejected the proposals?

April 2018 Update

Consultation - West Sussex Fire & Rescue Service Community Risk Management Plan

Well I have submitted my response to the West Sussex Fire & Rescue Service consultation, which closes on Friday this week. The 'additional comments' (item 2) are reproduced below and if anyone wishes to include any of the text in their response, then please feel free to do so.

"This document does not meet the requirements of an Integrated Risk Management Plan (IRMP), and even fails to deliver as a Community Risk Management Plan. Much of the information in the document may be useful in a general information brochure, but the absence of key information on the outcomes of the last IRMP and plans for dealing with future risk makes this an inadequate IRMP.

Despite a statement that ‘Station Profile’ and ‘County Profile’ documents are produced each year and are available on the website, I have been unable to find them on the website. Even a search for them only resulted in ‘Sorry, no results were found’ being displayed.

The dubious selection of figures for fire deaths seems intended to disguise the failure to deliver on the 2010-15 IRMP’s statement that fire deaths would be reduced. The latest figures, that would show accidental dwelling fire fatalities for 2015/16, have been omitted and, oddly, figures for 2004/05 have been included. That is presumably to misrepresent the situation by starting the chart with a particularly high number of fire deaths.

According to Government figures, the actual deaths for the period of the last IRMP were 28, compared to the previous five years when there were just 13. So instead of a reduction they have more than doubled.

The 2010-15 IRMP also said that WSFRS would “look at new and creative options to maintain cover and continue to attract new retained recruits.” Not only has WSFRS failed to do this, but changes to contracts, training and management of Retained Duty System (RDS) personnel have made things worse.

Mysteriously, the retained appliance availability target of 88% in 2011/12 has been cut to 75%. Despite the serious implications, this has apparently been done without any consultation with either the public or with County Councillors. Yet even this reduced target is not being met and average availability has fallen from 87% in 2009/10 to 59% last year. Some stations have even dropped from 100% to just 30% availability during that period.

The failure to address this problem suggests that WSFRS is happy to allow the retained service to wither and die. This is evidenced by inadequate efforts to stop the decline and the repeated process of removing lower availability RDS crewed fire engines from service. Nine have been cut so far. Clues to the root causes of these failures may be shown in a recent national survey of RDS firefighters by the Retained Firefighters Union. The results showed that 69% did not feel their service was doing enough to resolve the problem, and 60% felt that they were undervalued by Principle Officers.

The only way WSFRS is going to properly tackle the RDS problem is by working with communities, County Councillors, Parish Councils, local business and community groups, partner agencies, the South Downs National Park Authority and others. Much is made of partnership working, yet on this critical problem WSFRS seems intent on avoiding the involvement of anyone that may be able to help find new and creative options.

Whilst the Crewing Optimisation Group may seem a useful interim solution to the RDS crewing difficulties, it is expensive as a long term solution and fails to cover all periods of RDS crew shortages. Operating it when there are 12 wholetime crews available, but not operating it when there are only 8 wholetime crews on duty suggests a lack of planning. Especially as there are times, during the periods that the Crewing Optimisation Group is not available, when RDS shortages are as bad as they are when the Crewing Optimisation Group is available.

There continues to be an inadequate assessment of risk and an even more inadequate provision for dealing with it. The last IRMP is claimed to have resulted in “a considerable reduction in the number of ‘Very High’ Critical Fire risk areas”, yet no evidence can be found to support this claim. It appears that this may not be an actual reduction of risk, but simply a slight drop in the number of calls received in some areas.

The risk to individual lives and property remains, and the risk of losing lives or property is actually greater in areas classed as ‘low risk’, because it takes longer to get firefighters to those areas. The risk to life is particularly high in respect of road traffic collisions, with the more serious ones tending to occur in rural areas. Not only are response times greater, but WSFRS is failing to meet target times for one in four incidents.

Neither is the provision matched to the risk or the volume of calls. Crawley continues to be the fire station area requiring the most fire & rescue service responses in the County. In addition, this document says that the population in that area is expected to increase by 25%. Yet, WSCC has cut the number of fire engines and crews in Crawley from five to two. There is a correlation between population and number of calls, yet this document has no proposals to deal with an inevitable increase in emergencies in the Crawley area. 

The document states, “We use analytical resources, such as computer modelling software, to help us predict risk and assess the likely impact of changes”. Unfortunately, history shows that the results of that modelling are ignored when it does not suit the Council’s political agenda. Modelling of proposed changes in 2010 was reported, as it showed no increase in deaths or property damage. Yet when modelling of the cuts in 2015 showed an increase in deaths and property damage, efforts were made to disguise and later discredit the modelling.

It is reassuring that WSFRS recognises the reduction in firefighter experience of real fires. However, extra training at the Fire Service College is not enough. The cut in wholetime firefighter numbers and the shortage of retained firefighters have made it difficult to maintain skills with continuation training, and at the same time maintain adequate fire cover. In house training facilities need to be improved and more firefighters must be employed to enable training facilities to be used without undermining fire cover.

The document includes the Sussex Control Centre (SCC) in the list of specialist teams in WSFRS, when in fact the SCC is operated by East Sussex Fire & Rescue Service (ESFRS). The Control function is effectively contracted out. No mention is made of the worrying fact that the combined mobilising system, that was fundamental to the improvement of the control function, is now three years overdue. ESFRS has refused to state how many times the combined mobilising system has failed acceptance tests and they have given no indication of when this problem will be resolved.

Other problems with the SCC are not mentioned, including the excessive amount of overtime required to maintain minimum staffing levels. In 2015/16, overtime was required on 425 shifts. Of particular concern is that, unlike the previous WSFRS Fire Control, the SCC does not record mobilising errors. If they are not recorded, then problems are not being identified and remedial action cannot be taken.

The document states that around half the incidents attended by WSFRS were false alarms. It is concerning that this number has been artificially increased by classifying attendance at some road traffic collisions as false alarms, simply because no action was required when the service arrived. To describe an actual road traffic collision that the service attended as a false alarm is misrepresenting the facts and the work of the service. Will attendance at actual fires that are out on arrival be the next to be misrepresented as false? 

The document states, “our change in operating model has not altered the emergency response standards we agreed with you in 2009”. Yet it fails to inform the public that those standards are not all being met and that the degree of failure has increased. In particular for both fire engines arriving at critical fires and for the first fire engine arriving at critical special services.

The addition of the High Volume Pumping Unit is to be welcomed, but it does not offset the loss of 11 fire engines. Storms and flooding primarily require a large number of standard fire engines to respond to the high volume of emergency calls received in a short space of time. WSFRS is now less well prepared to respond to the predicted increase in severe weather events and no improvements are planned.

The claim that this is a ‘Community Risk Management Plan’ is dubious. Despite fine claims about integration, this document has little or no mention of the smaller units now controlled by the Chief Fire Officer, the legislation covering their work, or any plans for their future work. These smaller departments seem to be completely overshadowed by the fire & rescue service and their effectiveness seems to have suffered as a result.

A recent example being the Council’s latest IT Strategy report. The Civil Contingencies Act and resilience are not mentioned, yet resilience of such a core facility, which is essential to all WSCC services, should be a key strategic objective. If the Council cannot meet their legal obligations on such a fundamental report, there is little hope of them setting an example to others.

Finally, the inadequacy of the consultation. There are just two sections on the ‘Plan’, one of which contains four questions designed to get a favourable response, and the other is simply blank for additional comments. Yet there are seven sections about the person submitting the response!

There are no questions about the public’s views on deteriorating fire engine availability, or on increasing failures to meet response times. Both are of significant concern to the public and they are entitled to be properly informed and invited to comment. They should also be asked if they consider £33.68 per person per year is sufficient to spend on their protection. I consider it inadequate and I am sure many others would agree.

Firefighters continue to do a superb job, but the decreasing support they receive from the County Council is a disgrace. The public also deserve a much more open, transparent and accountable fire & rescue service. This Community Risk Management Plan does little to meet those objectives. Sadly, it’s inadequacies will simply strengthen the Police & Crime Commissioner’s case to take control of the fire & rescue service."

A genuine consultation or more smoke and mirrors?

You may well see the latest West Sussex Fire & Rescue Service consultation as insincere and only intended to tick the ‘have you consulted’ box. You may also feel that commenting on it is a waste of time, because they will ignore responses.

You may well be right, but I would encourage people to respond to the consultation and to voice concerns about it being a sham, about the Community Risk Management Plan not meeting the requirements of an Integrated Risk Management Plan, about the so called 'plan' failing to give any real performance information, and about the suspicious selection of statistics that appear intended to deceive.

An IRMP should provide up to date risk information and a proper evaluation of previous service delivery. It should also show how they will mitigate the impact of risk on communities. This document does none of that. It simply describes the current fire & rescue service, with no indication of how they have performed or how they are going to address problems. In other words, it is a PR document, not a plan!

In the plan for 2010-15 they said they would reduce fire deaths, but fire deaths actually increased during the IRMP period.

To try and disguise this, they illogically decided to show figures for eleven previous years. A cynic might say they included 2004/05, as it was particularly high and would make later figures look better. It was not indicative and was actually higher than the four previous years. A cynic might also wonder why the 2015/16 figures were not shown. No doubt it was because there were accidental dwelling fire fatalities in 2015/16, which would not look as good as ending that part of the table with a ‘0’ figure for 2014/15.

They also said they would report on the cost of incidents to our community annually, and on the consequences of fire incident outcomes (types of fires and numbers of people injured), and response standards achieved quarterly, but they did not. They have also failed to report on these factors in this ‘plan’.

They said in 2010 that they would look at "new and creative options to maintain cover and continue to attract new retained recruits". They have failed miserably and things have got worse, as these official availability figures show:

Station	Fire Engine	2009/10	2015/16
Arundel	1	84%	66%
East Preston	1	100%	47%
East Wittering	1	89%	54%
Hurstpierpoint	1	90%	33%
Lancing	1	100%	30%
Petworth	1	98%	72%
Shoreham	1	100%	88%
Shoreham	2	87%	30%

In fact, every retained crewed fire engine, except one, has seen availability get worse during the period of the last IRMP. In the worst cases, even despite the new Crewing Optimisation Group, some fire engines are unavailable for periods equal to more than eight months of the year.

Remember also that the fire engines that were removed just over a year ago, were available between 75% and 100% of the time in 2009/10. So the wonderful table showing Fire Appliance and Specialist Vehicle Locations is itself misleading. It gives the impression that they are available resources, when often they are not.

They say “Our change in operating model has not altered the emergency response standards we agreed with you in 2009”. Yet they don’t confess that they fail to meet them more often as a result of the cuts, or as they like to spin them – “change in operating model”. More people in West Sussex are waiting longer for help to arrive and all the County Council does is try to hide the truth.

If this was commercial advertising it would be facing criticism and possibly action from Trading Standards, but of course with the Chief Fire Officer now in charge of Trading Standards that would never happen.

There is a section called "Progress since the last Risk Management Plan", yet very little of it relates to the previous IRMP. They claim "a considerable reduction in the number of ‘Very High’ Critical Fire risk areas", but offer no evidence to support that. Given their previous misuse of the term 'risk', when they actually mean frequency of calls, it may simply be a small drop in calls in those areas. The public not only remain at risk of death, injury or loss of property in those areas, but the increase in response times has increased that risk.

Finally, the nonsense about calling the IRMP a Community Risk Management Plan. This is supposedly because they created the Communities and Public Protection Directorate to also bring “Trading Standards, Community Professionals and Resilience and Emergencies colleagues” under the control of the Chief Fire Officer.

Yes, they tinkered with management structures and gave the Chief Fire Officer a fancy new title, presumably with extra pay, as part of council cuts (or as they spin it - reorganisation), but there has been no real change. The fire & rescue service has always worked closely with other council services and partners. The sham title is actually well exposed by the content of this ‘Community Risk Management Plan’, with virtually no mention of Trading Standards, Community Professionals and Resilience and Emergencies staff, or their work. 

Not only is this an inadequate plan and consultation, but it will yet again strengthen the Police and Crime Commissioner's case to take over the running of the Fire & Rescue Service. I don't want to see that happen, so it is frustrating to see West Sussex County Council and West Sussex Fire & Rescue Service again playing in to her hands.

The consultation is open until 5 August 2016, so please have your say.

County Councillors again try to ignore Fire & Rescue Service concerns

Once again County Councillor Margaret Evans, tried to stop me speaking during the “tell us your concerns” section of the Chichester South County Local Committee meeting last evening. My concern – the effect on parts of West Sussex of Hampshire Fire Authority cuts. I refused to be bullied and reminded her that this is a matter that directly affects people in the Committee’s area.

After explaining the dangers for West Sussex residents, I asked a question, “Following the closure of Bosham fire station, the reduction of fire engines in West Sussex from 46 to 35, and the 7% increase in building fires in West Sussex last year, how will you, as County Councillors, ensure that there is adequate protection for the Chichester South area, if Hampshire cuts go ahead?”

Her answer - Well I am not a fire officer, so that would have to be up to the fire officer, so I can’t really deal with that.

Leader of the Council, Louise Goldsmith, then said, “May I also suggest that we do not comment on other authorities, because we just don’t do that.” She later said, “Our Chief Fire Officer advises us accordingly, and as a professional we take his advice”.

They both also insisted that I should respond direct to the Hampshire consultation. Fortunately though there were some voices of reason and concern at the meeting.

County Councillor Sandra James said, “It’s pretty outrageous, as I sit on this panel, to listen to the leader and the chair say it’s not our business. She spoke about how important Emsworth and Havant fire crews were to the people in her division. She also asked for the Chief Fire Officer to provide her with the information she had requested, and for a link to the Hampshire consultation to be provided on the West Sussex County Council website.

She received no answer from the Chairman or the Council Leader to the first question, and it also became clear that they are not going to put a link on their website. The Chairman of Westbourne Parish Council, who said they are just one metre from Hampshire, pointed out that other parishes are unaware of the “serious changes that will have dire effects on our families”. His call for a link on the West Sussex website was also ignored.

So what does this say about the ruling group on the County Council?

1. They ignore their legal responsibility to ensure that West Sussex residents are properly protected.
2. They accept the advice of the Chief Fire Officer without checking if it is good or bad advice.
3. They dismiss anyone who dares to suggest that the advice they are given may not be in the best interests of West Sussex residents.
4. They won’t express any concern to the Hampshire Fire Authority, “because we just don’t do that.”
5. They bury their heads in the sand and cross their fingers, instead of properly reviewing the operation of the Fire & Rescue Service in West Sussex.

How bad will things have to get before they begin to carry out their responsibilities properly?

Environmental & Community Services Select Committee

If anyone else wishes to email their concerns to the members of the  Environmental & Community Services Select Committee, their addresses are:

andrew.barrett-miles@westsussex.gov.uk, 
heidi.brunsdon@westsussex.gov.uk, 
dennisn@westminster.ac.uk, 
graham.jones@westsussex.gov.uk, 
michael.jones@westsussex.gov.uk, 
roger.oakley@westsussex.gov.uk, 
simon.oakley@westsussex.gov.uk,
joan.phillips@westsussex.gov.uk, 
john.rogers@westsussex.gov.uk, 
graham.tyler@westsussex.gov.uk, 
derek.whittington@westsussex.gov.uk, 
philip.circus@westsussex.gov.uk

You are welcome to use any or all of my points in the previous post.

More misleading and inaccurate information from the Chief Fire Offcier

The Environmental & Community Services Select Committee meet on Thursday to consider a report from the Chief Fire Officer about the cuts. You will not be surprised that the report contains inaccuracies and misleading information. I have emailed the committee members to point the worst of these out (see below). The numbers below refer to the paragraphs in the CFO's report that can be found with the agenda on the WSCC website http://www2.westsussex.gov.uk/ds/cttee/ecs/ecs180914age.pdf

Dear Committee Member,

At Thursday’s meeting I believe that you will be taking, for the first time, decisions that are matters of life and death. I would therefore be most grateful if you would read these comments alongside the report by Sean Ruth (Executive Director Communities, Public Protection and Chief Fire Officer).

Para.	Claim	True or false	The reality
1.4	“There has been an increase in the average response times to building fires in England”	True	The closure of fire stations and reductions in the number of fire engines across the UK have increased response times. Some deaths have been attributed to these closures and cuts. These proposals will make that situation worse.
1.4	“The severity of fires and numbers of casualties has decreased”	Partly true	Despite some decreases, the cost of fire damage has increased. The number of fire deaths in West Sussex has increased every year since 2008-09.
1.4	“National trends over the last decade” etc.	Misleading	The number of incidents fluctuate annually, so just looking at the figures for two years, ten years apart, does not give you a trend.
1.4	“WSFRS has followed the national trends”	False	The changes in West Sussex have not been shown in this paragraph, because they are less impressive. If you take the last 30 years and look at a more reliable four year average at each end of that period, the figures are: Total incidents attended up 45% Special services, including road crashes, up 78%. Fires have dropped, but only by 1% Fire engines have already been cut by 13%.
2.3	Removing a fire engine from service at Horsham will, “improve Service performance”.	False	Improving response times for Littlehampton’s 1st fire engine at night will come at the cost of poorer response times both day and night in the North of the County.
2.4.4	Cutting the number of firefighters at immediate response stations will, “maintain existing crewing levels where possible”.	Worrying	‘Where possible’ indicates that the CFO knows this proposal will see reduced crewing levels more often, so he has built in a get out clause.
2.4.4	Cutting the number of firefighters at immediate response stations will, result in “no reduction in response standards”.	False	There is no evidence to support this contention. It has not been analysed or risk assessed. Common sense says that with fewer firefighters there will be more occasions when fire engines become unavailable. The cuts will reduce the ability of stations to withstand absences resulting from leave, promotions, transfers, sickness, injury, jury service, parental leave etc.,
2.5.5	Removing the 2nd fire engines at Midhurst, Petworth and Storrington, will have a “minimal impact on performance”.	False	Even the overly optimistic Modelling and Analysis Technical Report concedes that this proposal will result in ‘more cost in terms of life and property damage’. A full analysis using more data is likely to show that cost will be much greater.
2.5.5	Removing the 2nd fire engines at Midhurst, Petworth and Storrington, will “improve flexibility”.	False	Removing the 2nd fire engine significantly reduces flexibility. There is no improvement in flexibility offered by the 4x4s, as these stations already have them.
2.6.2	Removing the 3rd fire engine at Crawley will have “minimal impact on Service performance”.	False	Even the overly optimistic Modelling and Analysis Technical Report concedes that this proposal will result in ‘more cost in terms of life and property damage’. A full analysis using more data is likely to show that cost will be much greater.There has also been a recent increase in fire deaths and fire rescues in Crawley.
2.6.2	Removing the 3rd fire engine at Crawley will be “more proportionate to risk and operational demand”.	False	Crawley has the highest number of calls in West Sussex and more occasions when more than one call has to be dealt with at the same time. It is already under resourced and this will make the situation even worse. It will also reduce cover in other areas when their fire engines have to deal with calls in Crawley.
2.10.2	Remove the 2nd fire engines at Midhurst, Petworth and Storrington will save £63,000	Not sure	The documents issued with the consultation suggested that the saving for each station would be £41,400 (total £124,200). Which is correct? If the saving is only £63,000, surely there are alternatives to avoid the extra deaths and property damage.
2.10.2	Reductions in management and Support Services will save £290,000	Not sure	No detail has been published, so it is impossible to know if this figure is correct
2.10.2	Total saving = £1.6m	False	Proposal six is an increase in spending of £220,000, and proposal 8 will incur additional costs arising from overtime and recall to duty payments. The saving cannot therefore be £1.6m.
3	“Alternative Options Considered”	True, but worrying	It was quite right to rule out the other crewing options, but why was that the only alternative considered?
5.2.2	“There were only two specific alternative proposals submitted”	Misleading	Alternative proposals were not requested. Had they been there may well have been more.
5.2.2	Merger - this has previously been considered by the County Council.	Misleading	Previous consideration is not a reason for excluding this option. There has been time to overcome any obstacles to a merger with East Sussex, and time to consider a merger with Surrey or Hampshire. A responsible review would have looked at these options as they would be highly likely to save over £1m without affecting service provision.
5.2.3	A full report on the consultation feedback will be presented to the select committee meeting by ORS	Misleading	Whilst ORS have done a professional job, their research has been undermined by the misleading information and omitted information provided by WSFRS. Consequently, for example, forum attendees and consultation respondents were not aware of the additional cost in terms of life and property damage associated with some of the proposals, or that claims of West Sussex becoming safer omitted the increase in fire deaths. The samples at the forums were extremely small, so are not representative. For example, the FBU response gives the views of around 30 times the number of staff who were at the staff forum. ORS says that consultation with informed audiences is especially valuable. The 300 or so firefighters represented by the FBU are clearly well informed, so their views should be given considerable weight.
5.3.1	“The figures for fatalities in West Sussex for the last three years have risen from 4 in 2010/11 to 6 in 2013/14.”	False	There were only 3 fire deaths in 2010/11. Actual figures were: 2008-09 = 1 2009-10 = 2 2010-11 = 3 2011-12 = 4 2012-13 = 6
5.3.2	“The Service do not believe that it has deliberately been misleading or provided inaccurate information”.	Misleading	So is ‘the service’ saying it accepts that it has been misleading and has provided inaccurate information, but did not do so deliberately? Deliberate or not, omitting information such as the predicted increase in lives lost and property damaged from both the consultation document and at the forums has denied people the full facts.
5.3.3	Proposals one, two, three, five, six and eight” will improve service delivery.	False	The limited night time improvement from proposal one at Littlehampton is offset by the reduced service delivery at Horsham both day and night. Proposal six may offer limited improvement, but that will be more than offset by the reduced service delivery from proposals one, two, three, four and five.
5.3.3	There will be some improvements to service delivery and improvement in the Service’s resilience through proposal eight.	Unclear	There is nothing new in this proposal, so it is unclear how there will be an improvement. If there is any improvement, it will be more than offset by the reduction of 5 fire engines.
6.0	Resource Implications and Value for Money	Unclear	The additional costs are vague, but it looks like far more will be spent to achieve these cuts than will actually be saved.
8.1	Equality Impact Report	Misleading	The Equality Impact Report has completely failed to consider the more significant effects of proposal 3 on the rural poor, rural elderly and rural ethnic minorities, and the more significant effects of proposal 4 on the elderly, poor and ethnic minorities in Crawley Borough.
8.5.1	The Service has met with the Gatwick Airport Fire Service Manager, who raised no objections to the proposals.	Misleading	I have no reason to doubt this, but he has no responsibility for fire cover at Gatwick. It is West Sussex County Council that is responsible, so he no doubt would not wish to interfere.
8.9	The Service believes that its proposals, when implemented, will improve emergency cover in certain rural parts of the county.	Misleading	This is unbelievable spin, as there is no evidence to support the claim.

  

There are also some unanswered questions that you may wish to have answered: 

• Why were some proposals not analysed and risk assessed, especially as the consultation suggests that they all were?
• Between 11 and 17% of attendances fail to meet the standards, so why are they not investigated and reported to County Councillors?
• How bad are the worst examples of those attendance failures and why did they occur?
• Why has WSFRS not followed WSCC initiatives to significantly reduce senior and middle management positions?
• If money is short, why are officer cars being replaced with more expensive and more polluting 4x4xs?
• Why is it suggested that the 4x4s are for flooding, when they are not designed for flooding and standard advice is for them not to enter flood water?
• Why are there twice as many cars in WSFRS, as the proposed number of fire engines?
• Why has WSFRS not followed WSCC policy on reducing travel by car in favour of using public transport?
• At the restaurant fire in Petworth on 12 September why were the nearest available fire engines Arundel, Selsey, Haslemere and Horsham.