19 Jul


I have taken the liberty of reproducing the consultation document that @SaveSouthwark have shared via their website  savesouthwarkfirestation.org

I firmly believe that everyone should read it and keep up the pressure to prevent cuts to Fire Services.

I know it is a long document but PLEASE read it through to the end.  Sobering reading.    Jules aka @julieanneda


‘We are taking a risk based approach to providing fire cover in London.’

James Cleverly, chairman of the LFEPA – 12th May Public consultation – GLA headquarters.  

The aim of this document is to demonstrate that the proposed closures of Southwark & New Cross Fire Stations coupled with the removal of the second pump at Peckham Fire Station is based on a model that does not reflect the risks in the surrounding built environment.

The model does not take into consideration the exceptional nature of the risks associated with Southwark Borough in terms of social deprivation and population demographics.

The proposed implementation of LSP5 does not take into account the significant additional reduction in fire cover for a 3 year period whilst PFI rebuilding works at Old Kent Road Fire Station and Dockhead Fire Station are undertaken.

This document will directly contradict the claim that LSP5 uses a risk based model and that implementation of the LSP5 proposals as they stand will disproportionately, dangerously and unfairly impact those who live in, work in and visit LB Southwark.

We wish for this document to be considered as part of the LSP5 consultation process.


We also want you to reconsider LSP5 in its current format and that the proposal to close E33 Southwark Fire Station is withdrawn



Implementation of LSP5 in its current format will:


  • Dangerously and disproportionately see a reduction in essential fire cover in LB Southwark.
    • LB Southwark has had more fire deaths than any other London borough over the last 10 years (34 compared with the London average of 17) and 27,808 fires (compared with the London average of 11,103). Yet fire cover is due to be cut by 1/3.


  • Further endanger the residents of LB Southwark by not taking PFI station closures into consideration
    • As PFI will see another 1/3 of fire cover relocated out of LB Southwark. The cumulative effect of PFI and LSP5 will see additional increases to the attendance times above those that have been published, and upon which the plan is based.
  • Increase the risk of fire, injury & death within a socially deprived and transient population of people
    • Due to a longer wait for sufficient fire crews to arrive on scene.
  • Fail to take into consideration the fact that 75% of residential accommodation in LB Southwark is high rise
    • And therefore requires 3 or more fire appliances to implement LFB high rise procedure and ‘safe systems of work’.
  • Adversely affect attendance times in all LB Southwark Wards
    • As is clearly evident from LFB’s own ward data provided in LSP5 supporting document 22
    • Increase the severity of fires
  • Increase attendance times in Wards with the highest number of fires and total incidents by over a minute and a half for the 1st & 2nd appliances
  • Seriously contradicting the assertion that LSP5 is ‘risk based’, with the Ward experiencing the highest number of fire incidents seeing the highest increase in attendance times.
  • Create unacceptable delays in Fire Crews tackling high rise incidents
    • As fire-fighting does not start when crews ‘arrive’ at the Ground Floor of a high rise block. Research has shown it takes up to an additional 20 minutes to safely get high rise procedure implemented and fire-fighting operations underway.
  • Put Fire Fighters at increased risk of injury or death
    • Because the increase in attendance times will result in fire fighters attending more severe fires, which will be compounded by a longer wait for essential back up.


  • Have a detrimental effect on the volume of Community engagement and preventative work currently undertaken by the LB Southwark Fire Stations
    • A reduction of 2 fire appliances equates to 864 less HFSV’s per year and 6,328 less Community Fire Safety hours, at current target levels.
  • Detrimentally impact the ability of Fire Crews to carry out familiarisation visits on high risk premises
    • Central London Fire Stations currently have some of the most extensive and demanding visit schedules. By increasing workloads on surrounding stations, the time available to carry out inspections will be reduced and the quality of inspections will inevitably suffer.    This is contrary to LFB’s response to the Coroner’s Report (under Rule 43, recommendation 2) for the Lakanal House fire deaths inquest, where Commissioner Ron Dobson advised that LFB would “Create an inspection regime that targets high priority residential and non-residential buildings with a view to increasing the number of premises records which are available to the Brigade’s operational staff on the Operational Risk database”
  • Increase the cost of fire to LB Southwark, a borough which is already significantly financially deprived
    • The public money saved, by the fire cover reductions proposed in LSP5, will be more than cancelled out by the increase in fires and fire severity. Demonstrating that the rationale behind these cuts simply doesn’t add up.
  • Impact LFB’s ability to develop and share as best practice, the kind of successful projects that has benefited both LFB pan-London and the London Borough of Southwark.
    • As the watch officers and fire fighters at E33 Southwark Fire Station have consistently been prepared to embrace and commit to new projects and equipment development. Making invaluable contributions in this area.





  • Summary                                                                                                                                     page 4
  • Borough Fire station profiles                                                                                                  page 6
  • Borough Demographic Profile                                                                                                page 7
  • LB Southwark Property profile: Residential                                                                         page 10
  • LB Southwark Property profile: Commercial                                                                       page 11
  • Current Fire Prevention Measures in LB Southwark                                                           page 13
  • Operational Considerations                                                                                                    page 16
  • Attendance times                                                                                                                      page 18
  • Economic Cost of Fire                                                                                                              page 23
  • LFB Policy & Project Development                                                                                        page 24
  • Conclusion                                                                                                                                  page 25
  • Appendices                                                                                                                                 page 26
















  • Station Profiles:
    • The closure of E33 Southwark and E38 New Cross along with the removal of E37 Peckham’s pump, will dangerously reduce the level of fire cover in LB Southwark.  The proposals contained in LSP5 effectively remove a third of the fire cover for LB Southwark.
    • In addition the LSP5 proposals have been developed with no consideration to the significant redevelopment works being undertaken at Old Kent Road and Dockhead which will close both of those stations during the redevelopment works, reducing fire cover in the borough by a further third.
  • Demographic Profile:
    • LB Southwark is one of the most densely populated & risk laden areas in the country for vulnerable populations and already suffers an above average number of fires and the highest number of fire deaths in London.
    • The model LFB has applied does not recognize this specificity of risk and that by removing vital fire cover, LFB will be directly contravening their own strategy as laid down in LSP5 and the number of fires, fatalities and injuries, along with the severity of those fires, will increase.
  • Fire Statistics:
    • The model refers only to average attendance times and makes no acknowledgment to the average frequency of calls or the severity of fires.   LB Southwark has the highest average fire fatality statistics in London over a ten year period along with significantly higher averages for injuries, rescues and frequency of incidents including primary fires. Accidental dwelling fires are increasing in the borough, contrary to the average London trend.
  • Property Profile:
    • LB Southwark is the largest social landlord in the Capital.  Of the 130,000 recorded households around 40,000 are local Authority properties. A further proportion are owned by other significant social landlords such as Peabody, Guinness Trust and City of London Corporation.
    • Many of these premises are within areas of significant social deprivation.  Approximately 75% of residential premises within the borough fall within the LFB definition of high rise premises.
    • At the opposing end of the risk matrix there are multi million pound developments such as the Shard, GuysHospital and major transport hubs.
  • Fire Prevention and pre planning:
    • The LFB model does not recognise this time intensive and high profile work e.g. The Shard, GuysHospitaletc and makes no adequate provision to maintain the level of proactive pre-planning.
  • Operational Considerations:
    • LBS is one of the most densely populated and risk laden areas in the country for vulnerable populations with a significant proportion of its risk being commercial and residential high rise.
    • The reduction in fire cover will directly impact the arrival time of resources with a corresponding detrimental effect on the severity of all incidents occurring within the borough’s risk matrix.
  • Attendance Times:
    • The model LFB has applied does not recognise the specificity of risk with attendance times.  It does not take into account the actual arrival time at the upper floor of a high rise premises.
    • The average times for first appliance arrival will increase by 26 seconds, the second appliance average attendance time will increase by 38 seconds.
    • Figures haven’t been produced for the third and fourth appliances.
    • The increased times will seriously compromise the effectiveness of the initial attendance.
  • Economic Cost of Fire:
    • DCLG figures give the estimated cost of dwelling fires within the borough at just under £18million per year. 
    • The removal of borough resources for prevention, protection and response will have a significant impact on our ability to reduce this figure. .

Across all categories of incident LBS has considerably higher incident rates including fire fatalities, than the   London average and yet is suffering disproportionately in the context of reduction in cover.

In simple terms the LFB model makes no sense when you deconstruct it, as it removes resources from the most risk laden area of London and replaces them in some areas where there is a much lower risk and frequency of almost all types of incident.

Borough Fire Station Profiles:  Impact of LSP5 closures and PFI remodeling works

Southwark Fire Station (E33) in LB Southwark is a 1 appliance station & covers approx 20% of Newington Ward as well as Chaucer, Cathedrals & 50% of East Walworth Wards.

  • Southwark Fire Station is on the list of 12 stations to be closed under LSP5

Peckham Fire Station (E37) in LB Southwark is a 2 appliance station & covers Peckham, BrunswickPark, Camberwell Green & part of S Camberwell Wards.

  • Peckham Fire Station is on the list of 7 stations to lose a fire appliance under LSP5


Old Kent Road Fire Station (E35) in LB Southwark is a 2 appliance station which also houses a Turntable Ladder & covers 50% of East Walworth Ward & 50% of Livesey Ward along with Faraday & Grange Wards

  • Old Kent Road Fire Station is due to be closed for at least 18 months whilst PFI remodelling works are undertaken.
  • The 2 appliances from Old Kent Road will be based and mobilised from Deptford Fire Station in LB Lewisham
  • The Turn Table Ladder will be located & mobilised from Dockhead Fire Station.

Dockhead Fire Station (E34) in LB Southwark is a 1 appliance station & covers Riverside Ward, Surrey Docks & part of Livesey Ward

  • Dockhead Fire Station is due to be closed for at least18 months whilst PFI remodelling works are undertaken.
  • The appliance from Dockhead will be based & mobilised from Deptford Fire Station in LB Lewisham during these works.

New Cross Fire Station (E38) is a 1 appliance station & is located in LB Lewisham but has LB Southwark’s Nunhead and Peckham Rye Wards within its station ground.  E38 regularly attends incidents requiring more than one fire appliance within the borough of Southwark.

  • New Cross fire station is on the list of 12 stations to be closed under LSP5


Lambeth Fire Station (H22) is a 2 appliance station & is located in LB Lambeth but has approx 80% of LB Southwark’s Newington Ward within its station ground.  H22 regularly attends incidents requiring more than one fire appliance within the borough of Southwark.

  • Fire Commissioner Ron Dobson is recorded as stating (at a planning hearing) that Lambeth fire station may be closed, if planning permission for the old HQ site cannot be agreed.
  • A planning appeal inquiry was dismissed  in May 2013


  • The closure of E33 Southwark, E38 New Cross and the removal of the pump from E37 Peckham will dangerously and disproportionately see a reduction in essential fire cover in LB Southwark.
  • It is proposed that, even as a temporary measure while PFI remodeling works are completed, that E33 Southwark should not be closed, to maintain essential fire cover in LB Southwark.

Borough Demographic Profile:

In 2011 the population of LB Southwark was recorded as 288,717.  Over the next twenty years, the population is predicted to grow by 100,000 taking the estimated population to just under 400,000


LB Southwark is the 8th most densely populated local authority area in the UK; the largest social rented landlord in the UK & the 12th most deprived Borough in London.

The Ward of East Walworth, covered by E33 Southwark is ranked within the 10% most deprived in the UK.

According to GLA predictions Walworth Community Council area, covered by E33 Southwark will almost double in size by 2029 and the population of Borough & Bankside Community Council area, also covered by E33 will demonstrate a similar trend by increasing approximately 40% by 2029.

LB Southwark is ranked third highest in London in terms of mental health service users with 8,751 people accessing services per annum.

The Community Mental Health Profile (CMHP) 2013 produced by the Department of Health cites Southwark as worse than the England average in the following categories that are considered wider determinants of health:

  • Episodes of violent crime
  • Population living in the 20% most deprived areas in England, 2010
  • Working age adults who are unemployed 2010 / 11

The CMHP also cites the following risk factors in Southwark as worse than the England average:

  • Statutory homeless households
  • First time entrants into the youth justice system (10 – 17 year olds)
  • Rate for hospital admissions for mental health
  • Rate for hospital admissions for unipolar depressive disorders
  • Hospital admissions for schizophrenia, schizotypal and delusional disorders
  • Number of people using adult & elderly NHS secondary mental health services
  • Numbers of people on a Care Programme Approach
  • In-year bed days for mental health
  • Number of contacts with community psychiatric nurse
  • Number of total contacts with mental health services
  • Recovery rates following psychological therapies

The links between social deprivation, population density and incidents of fire are well documented and research identifies those households associated with both an increased risk of experiencing a fire and a lesser likelihood of owning a working smoke alarm as: housing containing a smoker; financially unstable households; households located in areas of high physical disorder & properties in poor physical condition.

Such households are particularly vulnerable & it is intuitive that those groups at a higher risk of having a fire are more likely to be killed or injured.

LFB recognise this fact in LSP5 Supporting document number 5, by identifying overrepresented groups of people experiencing accidental fires and injuries including:

  • Older People living in social housing with high care needs
    • In LB Southwark 15% or 35,370 Housing tenants are over the age of 65
    • There are 3,830 community based health and social care users
  • People living in social housing with uncertain employment in deprived areas
  • 41.9% of Southwark housing tenants are unemployed
  • Of those households that are employed, 47% have annual incomes of £15,000 or less

This correlation between deprivation and incidence of fire is proven true in LB Southwark where LFB data demonstrates that in the past 10 years, LB Southwark has experienced the highest number of fire deaths in London.  Over the past 5 years LB Southwark has experienced a further alarming increase in fire deaths, with fatalities and injuries also above the London average.

This increase in fire deaths is in contrast to the general trend of reductions in fire deaths proving that the risk in LB Southwark is much higher than across the rest of London.

LFB Borough Statistics 2007 – 2012


London Average

Difference from London Average













Source: LFB Borough Statistics Pack 2012 & IMS Report Manager


In fact LB Southwark exceeds the London average for fires and fire appliance mobilisations on numerous reporting criteria, as detailed in the table below.

LFB Borough Statistics 2011/12


London Average

Difference from London Average


All fires





Dwelling fires





Other building fires





Road vehicle fires





Number of pump mobilisations





Number of pump mobilisations within borough





Number of pump mobilisations into the borough




Source: LFB Borough Statistics Pack 2012

Already, for the financial year to date, LB Southwark is well above the London averages for the number of fires, fatalities, injuries and rescues as the table below demonstrates.

LFB Borough Statistics 01.04.13 – 31.05.13


London Average

Difference from London Average

Total Incidents
















Source: IMS Report Manager

LFB also identify in LSP5 Supporting document number 5 the following demographic as being at a significantly increased risk of fire & that over a 3 year period accounted for 27% of casualties:

  • Educated, young, single people living in areas of transient populations
    • 26% of LB Southwark households are made up of this demographic

In addition to high levels of socially deprived individuals living in densely populated social housing, LB Southwark also has a population of approximately 18,000 students with nearly 8,000 bed-spaces managed by 6 student accommodation providers.  On E33 Southwark’s ground alone, there are 20 Halls of Residence containing over 6,000 bed-spaces which is over 75% of all student accommodation in the Borough.  This represents an extremely concentrated population of high risk individuals on an already risk laden geographical area and which has high resource requirements for E33 Southwark in terms of Fire Safety preventative work and mobilisations.  Furthermore, because the student population is renewed each year, the risk and the high resource requirements remain constantly high.

E33 Southwark has undertaken a substantial amount of work with Halls of Residence providers to improve their students’ fire safety, a testimony from one of these providers can be found in appendix 1 on page 26.

E33 Southwark mobilisations to Student Halls of Residence: 01.04.08 – 31.03.13

Mobilisation type Number
False alarm, good intent 28
Automatic Fire Alarm actuation 586
Fire 67
Malicious hoax call 33
Special service 28
Total 742

Source: IMS report Manager


Since 1st April 2013 there have been 3 primary fires in LB Southwark Halls of Residence. The most recent primary fire attracted a 6 pump attendance & saw the evacuation of over 50 students.


  • All of the factors discussed demonstrate the increased risk of fire within a socially deprived and transient population of people.
  • By reducing the fire cover in LB Southwark which is already at an extremely elevated risk of fire & which already has to request pump mobilisations into the borough 84% more than other boroughs, is directly contrary to the policy set out in LSP5.
  • Furthermore LFB Commissioner Ron Dobson has gone on public record to justify the higher funding level for LFB based on population density.  This risk based logic for funding levels is not being applied in a consistent fashion in relation to the proposed London closures; instead a London average is being applied.  If a Nationwide average for grant settlement is not acceptable, then how can it now be acceptable for London when discussing fire station closures and the removal of fire appliances?

LB Southwark Property Profile: Residential

The total number of households in Southwark is estimated as 120,400, an increase of 13.8 per cent since the Census in 2001 (LB Southwark Housing Profile: 2011 / 12)

LB Southwark has the ninth highest population density in England and Wales at 9,988 residents per square kilometre.   LB Southwark’s population density is higher than the London average of 5,199 residents per sq km, which is itself higher than the average for England, 407 residents per sq km.

In LB Southwark there are 39,845 council properties, of which approx. 30,000 are high rise (4 floors or over) this equates to 75% of all housing stock being high rise flats or maisonettes.  In addition there are also 15,404 Housing Association residential properties and 71,931 private residential properties; a significant proportion of which are also high rise.  According to LFB policy, all of these high rise premises require an annual visit by fire crews.

While vast improvements in residential fire safety have been made in recent years, the age of Housing stock in LB Southwark cannot be ignored as another significant risk factor with 57% or 17,100 residential high rise flats and maisonettes being built before 1964.

With “The Right To Buy” policy enabling council tenants to purchase properties most blocks of flats are now a mixture of tenants and leaseholders meaning that Local Authorities do not have exclusive control of building modifications nor do they monitor the repair condition of leasehold flats.  This inevitably leads to a compromisation of fire safety through modifications and wear & tear; this was tragically highlighted in LB Southwark by the Lakanal House fire.

LFB data taken from “Dwelling Fires” LSP5 Supporting document number 2, shows that fires in purpose built flats and maisonettes, as well as converted flats and maisonettes, account for 58% of all dwelling fires in London. This demonstrates that for LB Southwark where 75% of housing stock is high rise flats or maisonettes, that the risk of a fire is significantly higher than in Boroughs where low rise or street properties constitute the majority of housing stock.

In addition, within LB Southwark substantial numbers of new dwellings are being built including the redevelopment of the Heygate Estate and the Aylesbury Estate in Walworth which will eventually contain approximately 5,000 new homes.  These 2 areas are covered by E33 Southwark and E35 Old Kent Road which are both due to be affected by LSP5 closure or PFI remodeling works.

It is important to note that the regeneration of these two vast housing estates has seen a significant increase in deliberate fires; anti-social behaviour and criminality.  As secure tenants are decanted and the residual properties used for temporary accommodation, an influx of displaced and highly vulnerable individuals have been housed in close proximity and within properties that are old and in a state of disrepair. The nearness in location of these two sites has created a cluster of extremely high risk individuals, in high risk housing, in a area of high crime, arson, rough sleeping and drug use which has seen a marked increase in the number of fires attended by the Boroughs local fire stations.




  • LB Southwark is an extremely densely populated borough, with significantly high numbers of high rise housing stock that is over 50 years old.
  • Areas covered by E33 Southwark & E35 Old Kent Road have seen an increase in the incidence of fires and criminality.
  • These factors mean the model LFB has applied does not recognise this specificity of risk with attendance times in some very densely populated wards being seriously compromised by the proposals.



LB Southwark Property Profile: Commercial


E33 Southwark is a station ground laden with high risk premises, iconic buildings and critical national infrastructure; some of it subject to the official secrets act.  Sites include:

Property Risks
20 Student Halls of Residence 6,000 bed-spaces on E33 ground
BT Tunnels Site of specific importance to national security infrastructure
Shakespeare’s Globe Theatre 750,000+ visitors a year / historic listed building
Tate Modern Gallery 4,880,000+ visitors a year / priceless works of art
The Shard No 1 terrorist target in the UK plus 1.5+ million visitors a year
HMS Belfast 245,000+ visitors a year
“The Place” LondonBridge Quarter 40,000 sq m of office space over 17 floors
Southwark Cathedral Historic listed building
Borough Market 4.5+ million visitors a year
Golden Hind 300 tons of timber
London Bridge Station inc. tube 117 million passengers a year
GuysHospital & Campus 900,000+ patient visits a year
LUL Borough Station 5+ million passengers a year
LUL Elephant & Castle Station 18+ million passengers a year
LUL Southwark Station 10+ million passengers a year
Elephant & Castle Regeneration 5,000 additional high rise dwellings + major travel disruption during building works

Each one of these premises requires far more than 2 initial appliances to support an incident. For example the PDA on the Shard is 6 appliances to even begin any sort of fire fighting intervention.

In every case the contingency plan for these complex premises was written by E33 Southwark Watches, the accumulated work hours to complete and maintain these plans is substantial.

Furthermore these high risk sites generate a significant number of visits every year to ensure pre-planning strategies and critical operational information is updated.

Following the Coroner’s verdict into the Lakanal inquiry, it is also LFB’s intention to “create an inspection regime that targets high priority residential and non-residential buildings with a view to increasing the number of premises records which are available to the Brigade’s operational staff on the Operational Risk database”

This burden of work is critical to operational effectiveness & the expectation that neighbouring stations will be able to absorb the extra visits and carry them out to the same standard is unreasonable.  Additionally the existing local knowledge of these high risk premises will all be lost as the crews are individually redistributed; the stations who acquire the extra ground will have little or no understanding of the contingencies required at these sites since they weren’t directly involved in the creation of them.  There will be a severe knowledge deficit which major stakeholders on E33 Southwark’s ground will be unreasonably expected to suffer.

Simply stating that the surrounding stations will be able to pick up this volume of work is both unrealistic and impractical.  Surrounding stations have similar risk matrices and will simply not have the capacity to take this work on & deliver it to the same standards, as the table overleaf demonstrates.

Fire Station Number of appliances Number of outside visits
Southwark PL 98
Old Kent Road PL / P / TL 96
Dockhead PL 88
Peckham PL / P 74
Lambeth PL / P 105
Dowgate PL 105
Brixton PL / P 44
Clapham PL / P / ALP 59
West Norwood PL / P 35
Westminster PL / P / TL 65
Soho PL / P / TL 54
Paddington PL / P / FRU / ALP 59

Source: Outside Duty Master Schedule


  • LB Southwark has numerous high risk sites including significant critical national infrastructure and heritage sites.
  • The contingency planning for these has been carried out by local stations.
  • The LFB model used to justify station closures under LSP5 does not recognise this time intensive and high profile function eg The Shard, and makes no adequate provision to maintain it.
  • Plans to increase the number of visits carried out by LFB personnel, whilst reducing the capacity of boroughs to achieve these targets, is counterintuitive and can ultimately only reduce the quality and effectiveness of those visits.












Current Fire Prevention Measures in LB Southwark

Community Fire Safety

A significant proportion of LFB personnel’s time is dedicated to preventative work.  This is delivered via Home Fire Safety Visits (HFSV’s) and other Community Fire Safety (CFS) activity.

From 2008 / 09 – 2011 / 12 there was a 69% increase in the number of HFSV’s carried out in LB Southwark.

In 2011 / 12 alone, 3,347 HFSV’s were completed with a total of 2,668 (or 70%) being delivered in high risk dwellings.

The table below demonstrates LB Southwark’s achievements against the LFB average for London.

LFB Borough Statistics 2011/12


London Average

Difference from London Average


Home fire safety visits (HFSV)





HFSV to high risk people/places





Number of smoke alarms installed





P1 (priority) households





Source: LFB Borough Statistics Pack 2012

By closing E33 Southwark & E38 New Cross and by removing one appliance from E37 Peckham, there will be a significant reduction in the number of HFSV’s that are completed in LB Southwark.

The closure of E33 Southwark & the removal of one of E37 Peckham’s appliances will see an annual deficit of at least 864 Home Fire Safety Visits and 6,328 CFS hours carried out on a ground with significant risks as identified by LFB.  This does not take into account the additional deficit that the closure of E38 New Cross will create.

Surrounding stations will not have the capacity to pick up the shortfall as they will be gaining extra ground to cover operationally as well as extra visits to premises to complete.

Furthermore LFB Community Fire Safety partnerships are currently being wound down due to a lack of funding (HFSV’s targeting those most at risk FEP1740) which will see an even greater reduction in the amount of fire prevention work being undertaken.

Regulatory Fire Safety

In addition to Community Fire Safety intervention work, LFB Personnel in LB Southwark are also very proactive in regard to Regulatory Fire Safety (RFS) intervention work.

E33 Southwark crews in particular are very engaged with RFS Officers covering the Borough and have identified numerous high risk properties where there has been a failure to comply with Fire Safety regulations.

The table overleaf demonstrates the volume of properties identified:




Public Notices: LB Southwark


Property Type

Date of Notice

Notice Type

Mansfield Court, Sumner RoadPeckham, SE15 6JL

Purpose Built Flats>=4 floors


Enforcement Notice

Signal House, 137A Great Suffolk Street, SE1 1PZ

Purpose Built Flats>=4 floors


Enforcement Notice

60, Southwark Street, SE1 1UN

Licensed Premises


 Enforcement Notice

JourneysLondonBridge Hostel, 204 Manor Place, SE17 3BN



Enforcement Notice

The Old Justice, 94 Bermondsey Wall East, SE16 4TY

Licensed Premises


 Enforcement Notice

Locksfield, Catesby Street, SE17 1RH

Care Home


Enforcement Notice

74 Blackfriars Road, SE1 8HA

Licensed Premises


Enforcement Notice

Flats 221-241 (Block C) RuskinPark House, Champion Hill, SE5 8TQ

Purpose Built Flats>=4 floors


Enforcement Notice

Flat 121-221 (Block B) RuskinPark House, Champion Hill, SE5 8TN

Purpose Built Flats>=4 floors


Enforcement Notice

Commercial Units, Martara Mews, SE17 3DG

Other workplace


Enforcement Notice

Daniels Bar & Restaurant, 207 Old Kent Road, SE1 5NA

Licensed Premises


Enforcement Notice

Flats 1-120 (Block A) RuskinPark House, Champion Hill, SE5 8TQ

Purpose Built Flats>=4 floors


Enforcement Notice

1 Clink Street, SohoWharf, Bankside, SE1 9DG



Enforcement Notice

240 Camberwell Road, SE5 0DP

Factory or warehouse


Enforcement Notice

Flats 1-16 Lacine Court, Christopher Close, SE16 6PL

Purpose Built Flats>=4 floors


Enforcement Notice

Flats 1-16 Career Court, Christopher Close, SE16 6PN

Purpose Built Flats>=4 floors


Enforcement Notice

Flats 1-16 Harold Court, Christopher Close, SE16 6PP

Purpose Built Flats>=4 floors


Enforcement Notice

Flats 1-12 Fairway Court, Christopher Close, SE16 6PJ

Purpose Built Flats>=4 floors


Enforcement Notice

122-126 Tooley Street, SE1 2TU

Purpose Built Flats>=4 floors


Enforcement Notice

Stanhope House, 116-118 Walworth Road, Walworth, SE17 1JY

Other sleeping accommodation


Enforcement Notice

The Good Intent PH, 24 East Street, SE17 2DN

Licensed Premises


Enforcement Notice

54 Lordship Lane, SE22 8HJ

Licensed Premises


Enforcement Notice

Good Intent Public House, 24 East Street, SE17 2DN

Licensed Premises


Prohibition/Restriction Notice

Dulwich Constitutional Club, 33 East Dulwich Grove, SE22 0NP

Licensed Premises


Enforcement Notice

Residential premises above, , 246 Old Kent Road, SE1 5UB



Prohibition/Restriction Notice

Hot Wok, 614 Old Kent Road, SE15 1JB

Licensed Premises


Enforcement Notice

Mirlees Court, 50 Coldharbour Lane, SE5 9QW

Purpose Built Flats>=4 floors


Enforcement Notice

88 Walworth Road, SE1 6SW

House converted to flat


Enforcement Notice

Tesco Petrol Filling Station, Surrey Quays Shopping Centre, Redriff Road, SE16 7LL



Improvement Notice

614 Old Kent Road, , SE1 0LL

Licensed Premises


Prohibition/Restriction Notice

Tesco Petrol Filling Station, 107 Dunton Road, SE1 5HG



Improvement Notice

Rotherhithe Station, Railway Avenue, Bermondsey, SE16 4LF

Other premises open to public


Alteration Notice

49a Camberwell Road, LONDON, SE5 0EZ

House converted to flat


Enforcement Notice

Garavi Gujarat House, 1 Silex Street, London , SE1 0DW

Factory or warehouse


Enforcement Notice

UniversalChurch of the Kingdom Of God (1st floor) , 176 Rye Lane,  SE15 4NF

Other premises open to public


Prohibition/Restriction Notice

Banzi, 237 Lower Road, London, SE16 2LW

Licensed Premises


Enforcement Notice

Source: LFB website

An endorsement of the proactive RFS work carried out by E33 Southwark can be found in Appendix 2 on page 28.


  • The loss of E33 Southwark and removal of the pump from E37 Peckham will see an annual deficit of 864 HFSV’s and 6,328 CFS hours.
  • LB Southwark has an above average number of P1 individuals, identified as most at risk from fire.
  • The proposed removal of 2 pumps based within LB Southwark, will reduce the ability of LFB Personnel to carry out essential fire prevention work which can only increase the risk of injury or death from fire.  This is in a borough with significant volumes of people identified as being at an increased risk of having a dwelling fire, which is contrary to the policy set out in LSP5.


















Operational Considerations

The model presented in the public consultation document justifies the closure of some stations and movement of fire appliances to ensure all of London will receive 2 appliances within 6 and 8 minutes respectively. Whilst these appear laudable on the surface it does not take into account the very different risks across the Greater London built environment.

In the suburbs 2 appliances will be able to make a safe and effective first attack on a standard house fire, however, LFB operational fire fighting policy stipulates that for fires in properties over 4 floors, a minimum attendance of 3 fire appliances is required before offensive fire fighting can begin.

We have already demonstrated that 75% of housing stock in LB Southwark is 4 floors or over therefore, it is reasonable to assume that most dwelling fires in LB Southwark where the risk to life is the greatest, will occur in a property requiring a minimum attendance of 3 fire appliances.

LFB procedures dictate a High Rise incident attracts a minimum initial attendance of 3 appliances to set in place the support system to facilitate a first attack or rescue. The attack on a fire cannot be carried out with less than 4 appliances and as the list of roles taken directly from LFB’s own policy below demonstrates, requires 6 appliances to fully enact a safe system of work.

 Roles at High Rise Incidents

  • IC1
  • Pump Operator
  • Ff Logistics
  • MD-Comms/Messages
  • CM
  • ECO
  • 1 x 2BA
  • Ff lift operator
  • 2 x 2BA

>>>>>>>>>>>>>>>>>>>>>>>>>>    13

  • Safety Officer/GF Cordon
  • Safety Officer-BH
  • WM-BH
  • Comms Op
  • 2 x 2BA

>>>>>>>>>>>>>>>>>>>>>>>>>>       8

Total                   =                                    21

  • Sufficient surplus resources
  • Damage Control
  • Casualty Assistance/Handling Area

“Where a fire occurs in a high-rise block it can take a significant time before the fire and rescue service can commence fire fighting operations, with the potential of greater risk to fire fighters.”

“Hertfordshire Fire and Rescue Service have undertaken a series of exercises designed to test and practise their procedures for dealing with fires in high-rise housing blocks. As a result, they have determined that it takes 20min from arrival at the incident to establish a bridgehead with the resources required to deal safely with a fire on the upper floors. Compared to a fire in a low-rise block, this time delay before fire fighting can commence, clearly encourages significant fire growth, increases the risks involved for fire fighters and residents, and leads to greater damage being caused, with consequential increased remedial and rehousing costs.”

[Source basa.org.uk-The Callow Mount Sprinkler Retrofit Project]

It should be noted that investigations into Fire fighter deaths occurring in High Rise fires at a variety of locations across the country have identified that a significant common factor was the non-availability of sufficient resources early on in the incident; compelling Fire fighters to commence fire fighting activity outside of safe systems of work.

In Hampshire where two Fire fighters died in a significant high rise fire this has prompted the local authority to implement a minimum 6 pump PDA on all high Rise incidents. Whilst this document does not advocate that level of PDA and supports the LFB’s current operational model, it is clear that in removing the level of fire cover proposed, Fire fighters are likely to face increasing pressure to work outside that safe system of work, developed as the result of so many tragic Fire-fighter fatalities nationwide.

In LB Southwark there are a total of 876 premises with a PDA of 3 or more appliances.

On E33 Southwark’s ground alone there are 227 residential premises and 113 commercial premises with a PDA of 3 or more. This equates to 340 premises or 39% of all properties in LB Southwark with a PDA of 3 or more.

Since April 1st 2008 there have been 2,849 primary fire incidents in LB Southwark.  Of those, 1,339 were in high rise premises with a PDA of 3 or more. Of that Borough total, 463 primary fire incidents or 35% were on E33 Southwark’s ground. Of the 463 primary fires on E33 Southwark’s ground, 316 or 68% were in high rise premises with a PDA of 3 or more.  Additionally E33 Southwark also attended 321 primary fire incidents on a neighbouring stations ground (data taken from 08/09 to 12/13 for E34, E35, E37, H22, A24 & A28).


  • In the context outlined above, the arrival of two appliances is simply not sufficient to carry out the necessary rescue or fire fighting actions required. Hence why the current spread of stations in Southwark should remain to ensure the requirements of LFB’s own policy can be met.
  • Put simply the planning model applied; leading to the closure of two stations and the removal of a further appliance, in such a densely populated borough where 75% of dwellings are high rise, does not allow for fire fighting resources to arrive in good time to enact a sufficient attack on a fire occurring in the majority of LB Southwark’s residential premises.

Attendance Times

In 2011/12 the Borough of Southwark mobilised its fire appliances as follows:

Number of pump mobilisations 7,071
Number of pump mobilisations within Borough 6,086
Number of pump mobilisations into the Borough 2,661
Number of pump mobilisations out of Borough 985

Source: LSP5 Supporting Document number 8 & LFB Borough Statistics Pack

This totals 8747 incidents, making it the 4th busiest Borough in London for mobilisations


The Borough of Southwark currently has an average attendance time of 4:43mins for the 1st appliance & 5:45mins for the arrival of the 2nd appliance

At present, the percentage of time the first appliance arrives within 6mins in the Borough is 81% and the percentage of time the second appliance arrives within 8mins is 88% – demonstrating that 19% of the time the 1st appliance doesn’t arrive within LFB’s target times and that 12% of the time the 2nd appliance doesn’t arrive within LFB’s target times.  This is before 2 pumps are removed from the Borough.

Every Ward in LB Southwark will see an increase in first and second fire appliance attendance times. 

Information on third and fourth appliance attendance times has not been provided, yet we can assume that similar increases in attendance times will be experienced.

It should also be noted, that these attendance times DO NOT take PFI remodelling works into consideration.  This will inevitably, further increase attendance times.

The worst affected Wards are:

  • Cathedrals Ward, covered by E33 Southwark, which experienced the highest number of fire incidents as well as the highest total number of all incidents in 2011 / 12 will see an increase in attendance times  over a minute and a half for both the first and second fire appliances.
  • Chaucer Ward, covered by E33 Southwark will see an increase in attendance times of just under a minute and a half for the first appliance and over thirty seconds for the second appliance
  • Nunhead Ward, covered by E38 New Cross (bounded by E37 Peckham) will see an increase in attendance times of  over one and half minutes for the first appliance and one minute and fourteen seconds for the second appliance
  • Peckham Rye, covered by E38 New Cross (bounded by E37 Peckham) will see an increase in attendance times of one minute for the first appliance and thirty eight seconds for the second appliance.



The tables overleaf demonstrate the projected increase in attendance times in LB Southwark by Ward.

Those Wards highlighted below in red will see an estimated increase in attendance times over 25 seconds









First appliance predicted attendance times


BrunswickPark 73 254 4.11 4.20 0.09
Camberwell Green 54 295 5.15 5.24 0.09
Cathedrals 108 636 3.58 5.36 1.38
Chaucer 65 271 4.30 5.54 1.24
College 43 142 7.09 7.13 0.04
East Dulwich 20 106 6.30 6.37 0.07
East Walworth 64 297 4.46 5.11 0.25
Faraday 78 342 5.25 5.36 0.11
Grange 75 448 4.46 5.04 0.18
Livesey 66 298 4.51 5.05 0.14
Newington 64 212 6.10 6.39 0.29
Nunhead 36 256 4.25 5.58 1.33
Peckham 54 239 4.38 4.47 0.09
Peckham Rye 40 151 6.27 7.27 1.00
Riverside 87 412 4.33 4.45 0.12
Rotherhithe 49 265 5.33 5.39 0.06
South Bermondsey 73 259 4.53 4.59 0.06
South Camberwell 36 149 5.53 6.00 0.07
Surrey Docks 39 180 6.21 6.25 0.04
The Lane 64 256 4.45 5.14 0.29
Village 27 116 6.00 6.05 0.05

Source: LSP5 Supplementary Supporting document no: 22



















Second appliance predicted attendance times


BrunswickPark 73 254 4.57 6.36 1.39
Camberwell Green 54 295 5.22 6.20 0.58
Cathedrals 108 636 5.40 6.14 1.34
Chaucer 65 271 5.53 6.26 0.33
College 43 142 7.47 7.54 0.07
East Dulwich 20 106 7.07 7.28 0.21
East Walworth 64 297 5.09 5.25 0.14
Faraday 78 342 5.39 5.54 0.15
Grange 75 448 5.57 6.30 0.33
Livesey 66 298 5.45 5.58 0.13
Newington 64 212 6.10 6.37 0.27
Nunhead 36 256 5.29 6.43 1.14
Peckham 54 239 5.08 6.10 1.02
Peckham Rye 40 151 7.27 8.05 0.38
Riverside 87 412 6.12 6.32 0.20
Rotherhithe 49 265 6.45 6.49 0.04
South Bermondsey 73 259 5.04 5.13 0.09
South Camberwell 36 149 6.09 6.58 0.49
Surrey Docks 39 180 7.17 7.23 0.06
The Lane 64 256 5.37 7.33 1.56
Village 27 116 6.59 7.06 0.07

Source: LSP5 Supplementary Supporting document no: 22

Furthermore it needs to be noted that the LSP5 projected attendance times are calculated for arrival at street level.  In LB Southwark where 75% of its residential properties are high rise blocks, the arrival time at the fire site will be considerably longer than at street level.

Another factor that already increases the attendance time to a high rise flat fire in LB Southwark, is that since the Lakanal House fire, residents living in such properties are ignoring standard fire safety advice to “stay put” and instead are self-evacuating en masse.  In high rise blocks where there are upwards of 70 properties with, at a conservative estimate, 3 persons residing per property, this equates to 200+ people self-evacuating via central staircases.  This fact, will only further slow response times to fire sites in LB Southwark high rise premises.






Dwelling Fire Severity


Analysis of LFB’s dwelling fire severity data (01.04.08 – 31.03.13) demonstrates that LB Southwark has experienced above the London average for “categories of fire severity” over the last 5 years, as shown in the table below.

LFB Borough Statistics 01.04.08 – 31.03.13


London Average

Difference form London Average

Total number of Fires




Slight Fires




Moderate Fires




Significant Fires




Severe Fires




Source: IMS Report Manager


LFB classify fire severity in the following way (The Severity of fire in dwellings: further analysis. Document No: FEP1752):

  • Severe – fires likely to render a property as uninhabitable for a period of time; caused more than 5 meters of damage; required direct action from fire fighters; incident lasted longer than 45 minutes & more than 5 pumps attended.
  • Significant – fires that cause some damage and spread but don’t require significant resources to extinguish
  • Moderate – small fires where the details of damage are recorded but very little fire spread
  • Slight – very small fire; no fire fighting required to extinguish (beyond removal of heat source) & no damage to property evident.


FEP1752 concludes that factors contributing to the severity of a fire can be generalised as the difference in the type of property.  The proposition being that purpose built flats will withstand fire spread for longer.  FEP1752 concedes that property type is not the only factor that influences the severity of a fire and cites that the condition of housing stock, living standards and personal lifestyle characteristics also play a fundamental part in the severity of a dwelling fire.

The data provided above along with the evidence presented in this document demonstrates that LB Southwark has well above the London average in the number of fire incidents as well as significant numbers of housing stock over 50 years old and a population of socioeconomically deprived residents with above average levels of mental health issues.

These risk factors combined with increased attendance times will inevitably lead to the number of severe fires increasing in LB Southwark.

This in turn will lead to an increase in fire related injuries and fatalities; an increase in the economic cost of fire to LB Southwark & greater risk of injury to fire fighters who will be attending fires that have had longer to develop.

Other factors affecting attendance times


Consideration also needs to be given to the impact of major developments in LB Southwark that will detrimentally affect fire appliance attendance times, in particular, those fire appliances that will be required to cover E33 Southwark’s fire ground, if the station is closed.

The developments listed below will not simply mean short term closures of roads.  Each development will take years to complete and as such, the impact on traffic routes will also be lengthy & will see substantial disruption.


London Bridge Station Redevelopment

Elephant & Castle Regeneration – 5,000 new homes

  • The building phase is expected to reach its peak in 2019, with a projected 10 construction-related vehicle movements an hour round the Elephant & Castle roundabout
  • The upgrading of several “tributary” roads that converge on Elephant and Castle roundabout

One Blackfriars Development

  • The erection of three buildings including: a tower of 50 storeys plus basement levels, of maximum height 170m; a low-rise building of 6 storeys above ground level &  a low rise building of 4 storeys above ground level
  • In total, the mixed use scheme comprises: 11,267 sq m of Class C1 use (hotel); 52,674 sq m of Class C3 (residential use); 1,336 sqm of Class A uses (A1 to A5); 9,648 sq m of basement, ancillary plant, servicing and car parking.
  • This is land bounded by Blackfriars Road, Stamford Street, Rennie Street and Upper Ground,


  • All Wards in LB Southwark will see an increase in fire appliance attendance times
  • The average increase on the 1st appliance attendance time is 26 seconds and the average increase on the 2nd appliance attendance time is 38 seconds
  • On E33 Southwark’s ground, the Ward of Cathedrals will see an increase of 1 minute & 38 seconds on the first appliance and 1 minute & 34 seconds on the second appliance yet it is the Ward that experienced the highest number of fire incidents in 2011/12 in LB Southwark
  • Cathedrals Ward has a significant number of high rise residential and commercial premises which require a minimum of 3 appliances to tackle a fire. 
  • The projected attendance times are at ground level & do not factor in the extra time required to reach a fire in a property on upper floors of a high rise block.
  • Self-evacuation of residents since the Lakanal House fire already slows response times to fire sites
  • An increase in attendance times will lead to a corresponding increase in fire related injuries and fatalities; an increase in the economic cost of fire to LB Southwark & greater risk of injury to fire fighters.
  • Major development work in LB Southwark, predominantly on E33 Southwark’s ground will not only add risk to an already risk laden ground but will also slow the attendance times of other fire appliances who are required to cover this area if E33 is closed.



Economic Cost of Fire:


The DCLG “Economic Cost of Fire: Estimates for 2008” published in 2010 provides costings by fire type which enables us to determine approximately the cost of fire to a London Borough.

Analysis of LB Southwark fire figures from 2008 – 2013 demonstrated the following annual total approximate costs.

Year Dwelling Fire Non Residential Vehicle Outdoor Fatality Total Cost
2008 – 2009 £17,409,304 £7,266,168 £801,500 £5,430,964 £9,891,234 £40,799,170
2009 – 2010 £17,313,120 £7,196,301 £750,204 £4,321,688 £14,836,851 £44,418,164
2010 – 2011 £19,236,800 £6,357,897 £596,316 £4,071,620 £8,242,695 £38,505,328
2011 – 2012 £16,303,188 £6,497,613 £609,140 £4,392,220 £8,242,695 £36,044,856
2012 – 2013 £17,794,040 £5,519,493 £416,780 £2,442,972 £1,648,539 £27,821,539
Total cost for 5 year period £88,056,452 £32,837,472 £3,173,940 £20,659,464 £42,862,014 £187,589,057

General price assumptions: London (DCLG “Economic Cost of Fire: Estimates for 2008)


Type of Fire Cost per Fire in London
Dwelling £48,092
Non residential £69,867
Vehicles £6,412
Outdoor £6,412
Cost per incident in London
Fatality £1,648,539

Source: IMS Report Manager


Non-residential fire estimates have been derived from an average Commercial fire costs (£75,881 per fire) and Public Sector fire costs (£63,853 per fire)

Costings are also available for fire related injuries but are estimated on “serious” or “slight “ injury.  This level of data is not currently publicly available from LFB and so has been excluded from these figures.




  • The total approximate cost of fire in LB Southwark (between 2008 & 2013) amounts to £187,589,057.
  • The average annual approximate cost of fire in LB Southwark (between 2008 and 2013) amounts to £35,517,811.
  • The removal of essential fire cover can only lead to: an increase in the number of fires which occur due to the reduction in CFS activity; an increase in the severity of fires due to delayed attendance times & an increase in the number of injuries and fatalities due to delayed attendance times.
  • These factors, as a consequence, will also increase the cost of fire to LB Southwark, a borough which is already significantly financially deprived & which is in direct conflict with the strategy as laid out by LSP5.
  • The public money saved by implementing LSP5 will be cancelled out by the increases in cost of fire.








LFB Policy & Project Development

Below is a list of policies, projects and equipment trials that have been developed or carried out at E33 Southwark.  Its closeness to Head Quarters has made it the perfect venue for policies to be tested at the front line.  Losing the station would also mean losing the critical link between operational and non-operational staff which helps to test the effectiveness and deliverability of a wide range of new techniques.

    • Policy No:633 High Rise Fire Fighting & 10 pump high rise exercise
    • Policy No: 790 Fire Survival Guidance tested at 10 pump high rise exercise in conjunction with Brigade Control
    • Policy No:820 – Forward Information Board
    • BA boards
    • MDT testing
    • Shard “On Arrival Tactics” & Fire Plan Document – now being rolled out as best practice pan London
    • Shard – high rise exercise (Dec 2012)
    • Press related enquiries including photo / film opportunities
    • Uniform / kit trials
    • Sheltered Housing Unit project – referred to as “The Southwark Model”
    • Halls of Residence project
    • NHS Slips Trips & Falls project



  • The removal of resources in LB Southwark as outlined in LSP5 will seriously impact LFB’s ability to develop and share as best practice, the kind of successful projects that has benefited both LFB pan London and the London Borough of Southwark.
























E33 Southwark Fire Station Personnel have prepared this document, in off duty time over the past 4 months, in order to demonstrate that the proposed closure of E33 Southwark and the further reduction of fire cover in LB Southwark directly contradict the claim that LSP5 uses a risk based model.

Furthermore we believe that implementation of the LSP5 proposals as they stand will disproportionately, dangerously and unfairly impact those who live in, work in and visit LB Southwark.

We wish it to be acknowledged that PFI rebuilding works at E35 Old Kent Road and E34 Dockhead will further significantly reduce fire cover in LB Southwark for a minimum 3 year period.

E33 Southwark Fire Station Personnel felt compelled to write and present this document as we believe that the value of the station and the commitment and professionalism of its fire fighters cannot be adequately conveyed through a consultation form.

We are proud to serve the LB Southwark community as demonstrated by the willingness to travel further; pay more to travel and spend longer away from home as a result.

The Commissioner would expect nothing less than our full commitment and professionalism when responding to incidents and engaging with the community.  As serving Officers we believe that this commitment and professionalism needed to be demonstrated in the detailed response to the public consultation for the draft 5th London Safety Plan and in our opposition to the proposed closure of E33 Southwark.

Appendix 1  Halls of Residence provider: consultation response

Re:         Formal Consultation Response re proposed station closure and operational reductions within the London Borough of Southwark

My role within London South Bank University (LSBU) is that of Fire safety Manager. LSBU is one of London’s largest and oldest universities and has been delivering education since 1892. We are a cosmopolitan university with over 2000 staff and 23,000 students; the latter being representative in excess of 130 countries.

In accordance with the requirements of your consultation period and in consideration of my role within LSBU, I wish to formally raise my objection to the proposed closure of E33 Southwark Fire Station and the additional reductions of operational cover within the borough.

Accordingly I request that my comments be accepted as being my Formal Consultation Response and that they be considered as part of the consultation process.

As a key stakeholder in LB Southwark and a retired Operational and Fire Safety Inspecting Officer with East Sussex Fire & Rescue Service; in my professional opinion and based on previous experience, my belief is that the closure of the station E33 Southwark will have a significant and detrimental impact on our business functions and continuity, as well as to the safety of the 25,000 staff and students to whom we have a statutory obligation in our provision of a duty of care.

In The Fifth London Safety Plan (LSP5), LFB have identified which groups of people are most at risk from fire.  You will be aware that LSBU has a high percentage of the Mosaic Group identified by LFB in being at ‘high risk’ of accidental dwelling and casualties in the home; namely ‘Educated, young single people living in areas of transient populations’, who are deemed to be a ‘hard to reach’ audience.

LSBU and Southwark Fire Station have undertaken a monumental volume of work to reduce the risks associated with this demographic living within our facilities and the results have been extremely impressive.  As a direct result of the work carried out with E33 Southwark, we as an organisation have now reduced the annual number of fire related incidents in our Halls of Residence by 66% as well as establishing:

  • Clear lines of communication between E33 Southwark and our Halls of Residence Management
  • Strict tenancy agreements for students living in Halls of Residence regarding fire safety requirements
  • An annual programme of LFB visits to Halls of Residence to effect flat inspections and deliver fire safety information and advice to our students which enables
  • Early intervention and where appropriate, enforcement against students who breach their tenancy agreements in effecting automatic fire alarm (AFA) activations and other fire safety contraventions through unawareness or inappropriate behaviour.

This work has been so effective, that it was presented to the Fire Alarm Reduction Working Group for submission to the National Forum for University Safety and Health Association for Fire as a model of best practice in 2012/2013.

Furthermore my concern is that reduced interaction and business interface between LSBU and LFB will inevitably lead to a marked reduction of fire safety awareness and therefore increase demands on our Halls of Residence. This effect is two-fold in that;

a)      It will undo and seriously damage all of the previous good work that has been achieved in our professional partnership working to date and

b)      Increase the number of AFA calls to LFB, which is completely at variance with the ethos and strategy of LFB’s current Call Challenging considerations.

LFB’s proposition to then charge for false alarm attendances will in effect penalise stakeholders twice.  If the E33 Southwark closes, not only will we experience a reduction in the service that we currently receive, we will then incur significant charges due to the removal of our risk reduction measures in collectively reducing false alarms being directly gained from the intervention work carried out with the station personnel.

LSP5 also outlines what LFB plan to do about reducing false alarms.  The work LSBU has undertaken with Southwark Fire Station over the past 3 years has significantly reduced our false alarms within our Halls of Residence by an average of 14%. This figure continues to improve year on year.

I firmly believe that the closure of E33 Southwark would be detrimental, not only to our organisation and the facilities that we manage, but also to the wider community in which we are located.  It is immediately apparent that the level of engagement and service that we currently benefit from cannot be sustained if the station closes.

Furthermore, the operational response that we currently experience and expect will inevitably be detrimentally affected.  It is unrealistic and untenable to expect another station with its own area and inherent risks to assimilate further ground and still be able to deliver services with as much efficiency, commitment and professionalism.  Quite simply and collectively, there is too much to do but there will be insufficient resources to cover it.

When considering the evidence as it stands to date;

  • The current provision of operational pumping appliances within the LB of Southwark is 6
  • The cost saving proposal is to reduce the number of pumping appliances to 4
  • Although E38 New Cross is within the LB of Lewisham, much of their station ground includes that of the Borough of Southwark. It is therefore evident that the closure of this station will;
  • effectively remove one further pumping appliance from the LB of Southwark,
  • place an increased burden on the remaining three stations and
  • ultimately lead to a reduction in fire cover and operational capability
  • There is no known strategy in place that can effectively guarantee and significantly reduce the annual number of fire calls attended within the borough
  • There is no known proposal to reposition the remaining stations following the closure of Southwark and New Cross stations. Therefore the physical distance to be travelled when attending the station grounds of E33 Southwark and E38 New Cross will in some cases increase; as will the attendance times

Basic common sense and simple mathematics unequivocally identifies that a reduced provision in fire cover arrangements within LB Southwark will not be able to effectively deal with the number of fire calls that it experiences at present; nor will it be able to sustain the delivery of fire safety educational interaction and risk reduction measures that it currently provides, without loss to operational efficiency!

In summary, acknowledgement of the dedication that Southwark Fire Station has provided to the risks on its station ground and of the proposed loss of invaluable local knowledge cannot be overstated.  Neither is it reasonable that we as major stakeholders should be expected to tolerate a reduction in the level of service that we currently receive and then be charged as a result of LFB cuts.  Furthermore we should not be expected to accept the inevitable increase to response times, nor the loss of local knowledge and partnership working ; all of which has taken many years to replace and more often than not, can never be replicated.

Proactivity is and always will be the key factor to effective risk reduction measures. However your proposals for the reduction of operational capability and the inevitable loss of business partner interfacing opportunities from insufficient resource availability, can only lead to a need for increased reactivity on the part of LFB and a resultant escalation in fire loss related statistics.

I sincerely hope that you will consider my comments to be valid and that they are taken in the assurance of being presented by an ex-serving local authority area fire commander having sound professional managerial knowledge and experience in both operational and fire safety and risk reduction disciplines.






Appendix 2. LFB Regulatory Fire Safety: E33 Southwark Endorsement


May I enquire how you intend to amend your Borough plan to account for the loss of the station and personnel at Southwark?

As you are aware the current resources employed at Southwark Fire Station have been invaluable in gathering intelligence which has led to several high profile and ‘life risk’ issues being hugely mitigated or resolved.

Although it could be argued that it is the role of every operational officer and fire fighter to be proactive in fire safety it has been quite clear that the high level of risk within Southwark which is reflected in our workload has been addressed by personnel who have exceptional local knowledge, well above average fire safety abilities, excellent communication skills and time dedicated (the majority unpaid) to ensure a safe resolution to all the fire safety issues they have so far raised.

This station has set the benchmark in addressing fire safety issues and easily accounts for 80% of my operational based work.  Although not included in performance indicators, it is my view that the loss of this station and their crews could have a significant impact on fire safety in the borough.

I would be interested to know how crews with larger grounds, a base level of fire safety and a lack of local knowledge (which is built up over a number of years) are going to assist us to the very high level we have come to expect from Southwark Fire Station since we took over the responsibility of fire safety within the borough.

I have the upmost confidence in every officer employed within our borough but none have sought to learn, be as proactive, communicate or see through issues (even if this means in their own time) to the extent of Southwark Fire Station.

I would also be interested to hear your views on how long you anticipate it will take for new crews from other stations to familiarise themselves with the many fire engineered buildings like the Shard, More London, Globe, Tate and many other complex buildings constructed and under construction to the level of the incumbent station.

One Response to “#FireFire”

  1. retiredandangry Jul 20, 2013 at 7:20 am #

    Reblogged this on The Big Picture and commented:
    The Fire and Rescue Service, just one of our valuable public services being shafted by a short-sighted coalition

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The pretty good books of Susan Larson

There are still battles to be fought

A periodic blog on matters health, union, social justice, and the occasional random rant


Where discussion starts.....


Discovering we don't think inside the box or outside the box. We don't even know where the box is

Discordant Daydream

A vent of life's problems and delights

Grenfell Action Group

Working to defend and serve the Lancaster West community

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