SFPE Discussions

MBIE Consultation

MBIE have just published the proposed changes to C/AS2. Many of the proposed changes are minor, but C/AS2.6.2.8 is effectively asking for a fire fighting water supply. This is NOT a rquirement of the Building Code, and is covered by town planning via the RMA. The building code covers buildings, not services external to the buildings.
Comments please.

The building code and the acceptable solutions don’t have to have a relationship and quite often they don’t. the important thing to remember is that a person who complies with an acceptable solution must be treated as if they have complied with the building code. I get where your coming from you just need a different angle.

Dear Mike
Would you like to expand on your comment. It appears to fly in the face of:

  • the “Document Status” in the front of every acceptable solution; and
  • s 22 of the Building Act 2004
    If the acceptable solutions don’t have a relationship with the NZ Building Code then what other relationships can it have? I haven’t seen any mandate in the RMA for acceptable solutions.

its all in the wording of s22(2)…… must for the purposes of this act be treated as having complied with the building code… it doesn’t say by complying with the acceptable solution they have complied with the building code. i can list countless examples of where the acceptable solutions require more or sometimes less onerous requirements than the building code.

C/AS2 6.2.8 could be an issue for some new construction.

Should it be included? I would have to consider this more before I form an opinion on this.

Is it going to create problems? Highly likely. For urban water supply most times it would not be a problem. For rural areas this would force water storage for new construction. Of course the water storage must be within 10 m of the hard standing, and that is a problem.

What I have found in rural areas is that you only have the land that is available and often the water storage will end up in the location where the fire fighters will not want to drive the fire engine (where there is only one way out). So why enforce a water supply standard that is poorly suited to rural areas?

I think FENZ should be cooperating with rural Councils to create water storage infrastructure for fire fighting for the whole community rather than only providing water storage for the wealthy that have recently built a new building on their property.

I also suspect that this will continue to create economic problems for rural communities. Should MBIE be supporting a failed rural fire fighting strategy that is the responsibility of FENZ?

Given that this could force work on public land it falls outside of work fits within the scope of a building consent. Network utilities fall outside of the building act under Section 9.

I would love to see the cost - benefit analysis for the fire fighting water supplies, especially in rural areas. In one case I had a few years ago, the fire commander quite cheerfully admitted that the local volunteer brigade would not get there in less than 45 minutes, may be more depending on the rugby, and the building will be a smouldering ruin by then. Being rural of course there was no danger of spread to other property. The cost of fire fighting water tanks is huge, both financial and space. Work out the water volumes under PAS4509 and price up a tank to suit, including valves, filling and controls etc - and you can’ t use it for anything else.

The other one which will be problem, especially in Wellington, being slightly hilly with small sites is 6.2.7

b) have a plan area that will contain a rectangle of at least 4.0 m wide and 15 m long, and
c) have a gradient no steeper than 1:50 in any direction

and I hope your client wants a 2m deep canopy over their front door. Might be a problem with public streets - where you don’t own the airspace. A 1m *1m approx canopy over a sprinkler inlet cost $10k not long ago - how much is this?

6.4.3 In unsprinklered buildings, the firefighter building access shall be
protected from falling glass by a rigid canopy. The canopy shall be 2.0 m deep and extend across the full width of the firefighter building access point door plus an extra 0.5 m either side.

NZ PAS 4509 is an unusual blend of philosophy. It assumes the free market will solve the issue of fire fighting water in rural areas, which it has failed to do since the introduction of the standard in 2008. Yet the organisation believes heavily in interfering with the market and continuously demands features that are more onerous than the building act requires.

I would have thought that for all the issues with the standard that it would have been updated so as to be more relevant to New Zealand. Even simple things like that standard requiring 100 mm couplings when I have encountered fire engines with only 75 mm couplings. Why require fire fighting water if the local fire fighters are unable or unwilling to use the water supply?

Interestingly the use of 4509 I sbased on a free burning bonfire. I have helped several councils remove this requirement from their District Plan and FENZ/NZFS have never taken the challenge up. the last one they decided not to fight because it woud mean that this would probably disapper from most, if not all Councils. The water storage is a false hope in rural areas anyway, because by the time the local firefighters arrive the house woud be too far gone to attempt to save. 4509is also NOT a standard - it is simply a Code of Practice. it is NOT mandatory and the fire service have pushed it for ages to try to get it into the Building regulations. They have always failed to do so, because it is NOT a building related item.

It looks like they’ve tried to convince MBIE seeing they’ve failed to convince local councils and their communities.

It is worth making submission in relation to the proposed changes as fire fighting water isn’t the only problem with the changes. I suspect I will need to make OIA requests to find out how exactly they evaluated the proposed changes, given that it looks like very little or no time was allocated to considering the impact of the changes and the associated negative consequences.

For those who can’t find the documents on the MBIE website - see https://www.mbie.govt.nz/have-your-say/building-code-update-consultation-june-2020/.
You have to look for it