• Implement an immediate moratorium on the expansion of the Waymo pilot until a transparent safety audit is completed.
•
Publish a full log of all safety breaches, "near misses", and traffic
violations involving autonomous vehicles in London to date.
Why is this important?
Over the last few weeks, American company WAYMO has been testing autonomous vehicles in Harlesden and across London. On 22 April, a WAYMO vehicle drove through a live police cordon on Harlesden High Street while officers were investigating a double stabbing.
We,
the undersigned, call on the Mayor of London and Transport for London
(TfL) to immediately suspend the trial and roll out of Waymo autonomous
vehicles on London’s streets. We further request a police investigation
into near misses and other incidents where public safety was at risk.
REASONS FOR THIS PETITION
The
current rollout of Waymo autonomous vehicles (AVs) across London, and
specifically within the Harlesden area, is proceeding without adequate
democratic oversight or proven safety protocols for complex urban
environments. Our concerns are based on the following:
1. Breach of Police Cordons: Footage has emerged of a Waymo vehicle in Harlesden breaching a live police line.
Such actions constitute "wilful obstruction" of the police. If a driver
of a regular vehicle had committed this act, they would likely be under
investigation and could face criminal prosecution. We cannot allow a
"two-tier" justice system where corporate AI is exempt from the laws
that govern Londoners.
2. Unresolved Safety Risks:
Autonomous vehicles are struggling to navigate the "edge cases" of
London’s busy streets, including responding to emergency sirens,
physical police barriers, and the unpredictable movements of pedestrians
and cyclists in high-density areas like Harlesden.
3. Lack of Community Consent:
Residents in Brent have not been adequately consulted on this trial.
Public streets are being treated as a laboratory for unproven technology
without a clear framework for liability when things go wrong.
4. Extra traffic on our roads:
if Waymo or any other autonomous vehicles are allowed on the streets of
London, that will lead to extra traffic on our roads. It will further
compromise the Mayor of London's traffic reduction aims, led by Sadiq
Khan, focus on reducing overall traffic volumes by 10-15% by 2041 and
cutting car kilometres by 27% by 2030 to meet Net Zero and health
targets. We need more accessible and affordable public transport,
instead of more cars on our roads.
5. Vision Zero Compromise :
The Mayor’s "Vision Zero" strategy aims to eliminate road danger.
Introducing vehicles that fail to recognise and respect police cordons
is a direct contradiction of this safety goal.
Discussing the Waymo issues in Harlesden Town Centre
The London Mayor's Office has launched a short investigation (one month) on the issue of autonomous vehicles in London. These have been in the news recently with a demonstration in Harlesden over Waymo vehicles supported by Brent Green Party, the App Drivers and Couriers Union and Pull the Plug.
The campaign is being spearheaded by Councillor Amandine Alexandre, who represents Harlesden, alongside Councillor Suzanne Gallagher, who represents Kilburn.
They were joined byby Councillor Stephen Malonga from Kilburn and Ahmed Ahmed, who recently stood for election in Harlesden.
The campaign is growing rapidly across the capital. From safety incidents to the massive threat that unregulated corporate automation poses to the livelihoods of London’s 105,000 private hire drivers, they are refusing to accept a tech first, people last experiment.
They are demanding that the Mayor of London puts a pause on the rollout until transparent safety standards and strict protections for workers are guaranteed.
Investigation aims and objectives (Terms of Reference)
Several trials of autonomous passenger vehicles (more commonly known
as driverless taxis or robotaxis) are underway in London in 2026, with
operators aiming to launch commercial services by the end of the year.
In this investigation, the Committee will:
Explore whether and how autonomous passenger vehicles could be
licenced for commercial operations in London, and what role the Mayor
and TfL should play in this.
Understand the impact of autonomous passenger vehicles, particularly
in regard to employment in the taxi and wider private hire vehicle
sectors, interactions with other road users and the ambitions in the
Mayor’s Transport Strategy, including ‘Vision Zero’, a traffic reduction
of between 10 to 15 per cent, and the target for 80 per cent of all
trips to be made by active modes or public transport.
Key issues
In June 2025, the Department for Transport (DfT) announced that it
would fast-track “small scale ‘taxi- and bus-like’ services without a
safety driver” to take place in spring 2026 before a wider potential
roll out in 2027. Several companies, including Uber and UK company
Wayve, are seeking to obtain regulatory approval to transport passengers
in automated vehicles in London as soon as this year.
Waymo, an Alphabet-owned company, which is also seeking approval for
passenger trials, began testing on London roads without passengers and
with a driver at the wheel this year. Its current fleet comprises 24
vehicles. Other operators have not confirmed how many vehicles they are
planning to deploy.
Autonomous passenger vehicles are a common sight in some US cities.
Waymo has reported that it is currently providing approximately 500,000
paid rides every week, using over 3,000 vehicles deployed across ten US
cities. The company’s average weekly trips have grown tenfold over the
last two years. Estimates from 2025 suggest that Waymo accounts for
around one in four ride-hailing trips in San Francisco, surpassing the
market share of Uber and Lyft.
Research carried out by automotive data firm HPI found that while
Londoners were the most trusting of self-driving technology of
respondents from all UK regions, its survey of over 2,000 UK adults
found that 79 per cent of Londoners would not trust a driverless car or
feel comfortable about travelling in one, while only 21 per cent of
Londoners would. The results also showed that 35 per cent of all those
surveyed had concerns about the reliability of the technology.
Some experts have also raised concerns around entrusting key
elements of London’s transport system to private companies, resulting
‘proprietary lock-in’, whereby transport in a city could become overly
dependent on (in some cases foreign) private companies. The Government
in 2022 found that CAVs are attractive targets for cyber attacks and
that ensuring cyber security is essential when developing them. There is
a risk of terrorist attacks causing large-scale chaos across the
transport network and cyber attacks targeting a vehicle’s hardware with
the aim of disabling it until a ransom is paid.
Key questions
Who is responsible for licensing autonomous passenger vehicles in London and what role do the Mayor and TfL play in this?
How close are commercial operators to deploying autonomous passenger vehicles for hire in London?
Are autonomous passenger vehicles compatible with London’s strategic transport goals in the Mayor’s Transport Strategy?
What are the principal risks associated with autonomous passenger vehicles in London, and can they be mitigated?
To what extent are autonomous passenger vehicles accessible to all Londoners?
Are there any benefits that autonomous passenger vehicles could
offer in London, and how likely are those benefits to be realised in
London?
What lessons can London learn from trials and deployments elsewhere?
What role should TfL and the Mayor play in the development and oversight of autonomous passenger vehicles?
What do Londoners think about autonomous passenger vehicles?
1. Call for Evidence
As part of this investigation, the Committee has launched a Call for Evidence, inviting those with knowledge of this topic to respond.
If you are responding on behalf of an organisation, in a
professional capacity, or have knowledge of this topic, please send your
submissions to scrutiny@london.gov.uk. Please use ‘Transport Committee call for evidence’ as the subject title.
News from Bdonline is of interest. Major planning applications go to the London Mayor consideration. The project below was turned down by the local council but their decision was overturned by the London deputy mayor. It is similar to many applications in Brent but contained a higher proportion of affordable accommodation, at 17.5% London Living Rent, than we often see. It did not comply with local plan and London Plan criteria re tall buildings but the design was considered acceptable.
The deputy mayor of London has overturned a council’s rejection of plans for
a 228-home build-to-rent tower in Abbey Wood.
Bexley Council had previously refused permission for Abbey Wood Sedgemere
Limited’s plans to demolish existing commercial buildings and build a 25-storey
tower next to the Elizabeth Line.
The council rejected the plan, designed by architect GRID, for several
reasons, including the height of the building, harm to the nearby Lesnes Abbey
and increased flood risks.
The scheme was called in by the Greater London Authority and Jules
Pipe, has now said in a decision notice: “Considerable weight and importance
has been attached to the harm caused by the proposals to Lesnes Abbey. However,
it is concluded that the public benefits delivered by the scheme, improved over
the course of the application, would clearly and convincingly outweigh the
heritage harm.”
Pipe added that the scheme would “make a positive contribution” towards
achieving housing targets in alignment with the National Planning Policy
Framework, London plan and Bexley’s local plan.
The developer made several changes to the scheme since it was called in. The
scheme will include 35% affordable housing, and the proportion of these homes
that are London Living Rent was increased from 30% to 51%. The flood risk
assessment and drainage strategy was also altered. It proposes to discharge
surface water into the sewer within Harrow Manorway.
The notice said the development is considered to be largely in accordance
with relevant design policy requirements. It said that while there are partial
conflicts with London plan and local plan policies relating to tall building
criteria, “the overall design is considered to be acceptable in response to the
surrounding context and emerging character.”
Pipe said: “The proposed development would deliver new homes and affordable
homes, along with non-residential town centre floorspace, public realm and
landscape improvements within a highly accessible location. It would bring
forward an underutilised brownfield site in close proximity to Abbey Wood
Station.”
Marketing video for purpose built student accommodation in Wembley Park
There has recently been discussion about the amount of purpose built student accommodation in Brent, with some disquiet even in the Brent Planning Committee. (See LINK) Rather than reflecting an anti-student prejudice it is often about the loss of sites that could otherwise be used for family housing and questions about balancing local communities.
Brent planners have insisted that the need for student accommodation both in Brent and London as whole has been established and contributes to housing targets,
The London Mayor has recently published London Plans guidance for London local planning authorities which reviews some of the issues. The full document can be found HERE and key extracts follow (my highlighting):
The Purpose-built student accommodation (PBSA)
London Plan Guidance (LPG) provides advice on how to apply London Plan Policy
H15 to best meet London’s needs. This guidance applies to a specialist form of
housing designed and managed for students. This typically comprises a mixture
of flats for 6-8 students with shared living spaces, and larger studio flats,
plus additional communal social spaces and other facilities.
As well as providing students with a place to live, PBSA can play an
important role in alleviating pressures on the wider private rental sector.
Indirectly its provision also helps underpin London’s higher education sector
as a global player, and the wider knowledge economy of the city.
The LPG sets
out detailed advice on siting, designing and developing such housing, including
balancing it with other housing types. It aims to ensure that these
developments are designed and managed to be of good quality, safe and inclusive
and integrated into their neighbourhood. The guidance is aimed at those
designing PBSA schemes and decision-makers assessing them as part of the
planning application process.
London’s
universities are disproportionately concentrated in a few areas,including within the CAZ (Central Activity Zone) .
PBSA (Purpose Built Student Accommodation) has clustered in similar areas,
particularly ininner
London. This has diversified the student accommodation offer from thetraditional, university-built PBSA, and private
rented homes. Several boroughswhere this
is the case have sought to limit further growth in such (purpose built)student accommodation, as well as in some cases,
HMOs Homes of Multiple Occupation). This reflects their concerns about housing
mix in their neighbourhoods and the potential ‘crowding out’ of conventional
housing, given other types of housing need amongst their population. However,
in turn, other boroughs (including within outer London, some distance from
where London’s universities are concentrated) have since seen a particularly
high influx of PBSA schemes, giving rise to similar concerns.
PBSA in
relation to neighbourhood housing mix can be considered in two ways:
• In support
of PBSA proposals that help disperse from traditional concentrations to
alternative, suitable locations – perhaps adding an element of student housing
to existing residential stock that is primarily conventional housing. This may
be particularly relevant where there is a shortage of family homes, which
students are currently occupying as HMOs or which they could be in future, in
light of PBSA shortages.
• As a more negative
consideration, where there are long-standing or more recent concentrations of
PBSA, or similar, non-self-contained accommodation, relative to conventional
housing. This may be spatial (in particular neighbourhoods) or as a proportion
of housing delivery, where PBSA may be considered to be ‘crowding out’
conventional housing schemes. Such dominance may be particularly acute under
certain market conditions; and where development sites are limited (which would
ordinarily be equally attractive for conventional residential use).
PBSA should
form part of a wider positive strategy in delivering mixed andinclusive neighbourhoods in most Local Plans. It should be acknowledged thatwhat is considered an appropriate balance of PBSA
and conventional housingwill differ
across London, and within boroughs. Local Plans should identify ifand where spatial concentration of PBSA, or
proliferation of PBSA deliverycompared to
conventional housing delivery, is impacting the ability to ensuremixed and inclusive neighbourhoods. They should
also identify more positiveopportunities
for PBSA to help contribute to local and strategic objectives.
Thiscould be used to develop spatial policies; or to
indicate the significance ofneighbourhood
or pipeline housing mix in decision-making.
Green Assembly member Caroline Russell is able to make fun at herself over a seeming obsession with toilets but in truth it is her campaigning success that will have an impact on the lives of many Londoners and visitors to London.
She deserves congratulations because her persistence has paid off with the London Mayor announcing plans to expand and improve toilet provision. We know that many people are put off using public transport for longer journeys because they fear that they will not find a toilet when needed. As an ex-teacher who has taken hundreds of primary age children on trips into London I also know how important it is to be able to find a toilet at short notice for a desperate child!
In it Press Release announcing a programme of expansion and improve TfL said:
Transport for London (TfL) has announced its ambitious programme to
increase and improve toilet provision on London's transport network, in
support of TfL's Equity in Motion plan to make London's transport
network more accessible, fair and inclusive. The plan will see new
accessible toilets delivered across the network, and improvements made
to many existing facilities.
Earlier this year, the Mayor announced the biggest dedicated
investment in toilet provision that London's transport network has
seen, totalling £3million per year over five years. This will be
invested in improving and increasing the number of accessible toilets on
the network.
TfL is committed to making toilets more accessible for everyone and
closing the gap in existing toilet provision so that Tube, Overground
and Elizabeth line customers are always within 20 minutes of a toilet
without having to change train. Following engagement with customers,
campaigners and staff, a new programme has been developed to ensure new
toilets benefit customers who need them most. Stations were then chosen
according to a number of factors, including whether the location is a
terminus station, operates night services, has step-free access, high
passenger footfall, proximity to other toilets on the network, and
onward connections.
TfL is committed to creating new facilities and enhancing existing
facilities, including reopening closed facilities, and improving the
cleaning of facilities. Following the study, TfL has shortlisted a
number of locations for new toilet provision in the first round of
works:
Camden Road Overground station
Clapton Overground station
New Cross Gate London Overground station
South Tottenham London Overground station
White Hart Lane Overground station
Morden Underground station
Hammersmith Underground station
TfL and the Mayor recognise that the provision of toilets is critical
to many customers, sometimes determining whether a customer can travel
by public transport at all. This is why TfL is also looking to convert a
further four existing non-accessible toilets to accessible facilities
within this first phase of the project at Amersham, Green Park and
Sudbury Hill Underground stations and Seven Sisters Overground station,
improving availability at other busy toilets that are currently misused
or vandalised. TfL has also made improvements to more than one-third of
London Underground stations with toilet provision in recent years,
including repairing faults and re-painting areas.
Construction work to deliver new and accessible toilets at these
stations is expected to start at several locations within the next year,
following detailed assessments to determine viability.
TfL have a map of existing toilet facilities HERE although I would treat with caution as they may not be available due to vandalism or misuse, particularly in the evening. This is an extract for our area. The Bakerloo/Overground is particularly poorly served:
There is also a searchable site for the whole of the UK which is very much a work in progress with users able to add toilets in their area. LINK
The Brent Council website has a short list of public toilets in the borough LINK:
Address: Vale Farm Sports Centre, Watford Road, North Wembley, Middlesex, HA0 3HG
Queens Park and Roundwood Park have toilets connected with their cafes and Barham Park has limited access via the Community Library. King Edward VII toilets near the Park Lane entrance were demolished years ago due to drug misuse but publicly accessible toilets are planned for the Stonebridge Boxing Club facility if it gets off the ground.
Brent Green Party has previously argued for a Brent Toilet Scheme that would incentivise cafes and retail premises to allow public access to toilets, perhaps through a reduction in business rates.
Camden are advertising for more businesses to join their Community Toilet Scheme:
Join our Community Toilet Scheme
We are looking to expand our Community Toilet Scheme, and work with more
local businesses that would allow the public to use their facilities
during normal opening hours (without the need to buy goods or services).
We’d welcome interest from anywhere in the borough, but especially from
businesses in Kilburn, Camden Town and Bloomsbury.
We would pay an annual fee to members of up to £750 (including VAT).
At a recent Planning Committee meeting where an application for new student accommodation in Wembley Park was made, existing residents spoke against on the grounds that it created would imbalance and undermine community cohesion because students were short-term residents not committed to the area. There were also concerns about anti-social behaviour. Countering this officers argued that students contributed to the local financial and cultural economy.
Now the London Mayor is undertaking a consultation on provision of student accommodation to which residents might want to conribute. Details below:
The Mayor of London is consulting on new London Plan Guidance (LPG) relating
to student housing, otherwise known as purpose-built student accommodation or
PBSA.
The guidance supports London Plan policy H15 to best meet student housing
needs as part of a wider approach to housing delivery and regeneration. It aims
to unlock PBSA delivery and also address imbalances to help achieve a more
mixed and inclusive London.
This event is a Q&A session for stakeholders to bring any queries they
have about the document or the consultation. It assumes that attendees have
watched the two minute introductory video or read the draft document, both
available on our consultation site.
Questions can be
submitted in advance by email to studenthousingLPG@london.gov.uk or you are
welcome to just turn up on the day and ask them and listen to our responses to
other people's questions.
[Images courtesy of
Unite and Affordable Accommodation for Students Ltd]
Frequently Asked Questions
Is the event free? Yes.
Who is this event for? The event is open to all and is
suitable for interest groups, public campaign groups, developers, landowners,
agents and Londoners to ask questions and find out more.
How will the session take place and how can I join? The
session will take place online. Once you have registered via Eventbrite, you
will be emailed a link to join the event 24 hours before the event takes place.
Will I be able to ask questions during the event? Yes the
whole event is structured around Q&As.
Do I have to submit questions in advance? You are welcome
to send questions through in advance by email to
studenthousingLPG@london.gov.uk which will help us prepare, but you can also
just turn up and ask them and we will do our best to answer them on the spot.
Is
this a repeat of the event on the 3rd November? Yes, there is no need
to attend both events.
What if I have accessibility requirements? Please let us
know when booking your ticket on Eventbrite. Please let us know as soon as
possible. We will endeavour to meet any requests made within two weeks of the
event, however these cannot be guaranteed.
Where can I find out more and share my views? To watch the
introductory video, read the guidance and share your views, visit the consultation page. Consultation on the
LPG closes on 11 January 2024
How can I find out more about this event? Please contact studenthousinglpg@london.gov.uk
if you have any further questions about the event.
The consultation, including the survey (below) will be open until 11th
January 2024.
We have 2 open-to-all Q&A events in October and November, and further
engagement events are also planned with specific stakeholder groups, notably
the cross-sectoral Mayor’s Academic Forum and boroughs. More information on the
public events can be found on the 'events' section on this page.
All feedback will be reviewed and a consultation summary document will be
published alongside the final guidance.
This story from Green Party Asssemby Member Zack Polanski, puts today's retrofit announcement from Brent Council in perspective. Brent was awarded the second lowest amount of the successsful London boroughs:
Green London Assembly Member Zack Polanski today revealed to the
Mayor that just 45 homes had been retrofitted across London under the
Government’s Social Housing Decarbonisation Fund, despite £18 million being
made available to London councils over a year ago.
The measures to improve the energy efficiency of
London’s homes were supposed to be completed by the end of March 2023, but a
shortage of skilled workers has delayed delivery.
Green London Assembly Member Zack Polanski said:
The Mayor is still sitting on his hands despite
declaring a ‘retrofit revolution’ two years ago.
His failure to get a handle on the retrofit skills
gap is preventing London benefitting from available Government funds.
The Mayor needs to get his retrofit revolution on the right track,
support the upgrading of homes and protect Londoners from sky-high energy
bills.
Nine of the 11 London boroughs awarded funds have
failed to deliver any retrofitting works at all. This represents over £13
million of available government funding not being put to use.
Across the country, just 14% of the planned 20,000
homes expected to be upgraded have had works completed. As a result, the
deadline for local authorities to spend the first wave of funding has been
extended to June.
Housing experts, including representatives from
the Chartered Institute of Housing, say the slow rollout of retrofit upgrades
stems from a national skills shortage in the retrofit sector.[5] London
Councils have said that London needs 110,000 people working in retrofit by
2030. Currently, there are only 4,000
The publication of this data comes after the Mayor
of London showed hesitance to ramp-up his retrofit skills training offer using
his £320 million Adult Education Budget. Speaking to the London Assembly in
November, the Mayor said, “what we need is some certainty there are [retrofit]
jobs to go to.”
With Londoners facing rising bills during the cost
of living crisis, retrofitting homes to improve their energy efficiency is a
way to reduce energy bills and household costs – while reducing emissions.
The second wave of funding, being made available
to local authorities and housing associations later this year, is around four
times the budget of the first wave, at almost £800 million.
Brent Schools Forum this week was over-shadowed by budget concerns. Schools have been hit by high energy costs, inflation, falling pupil numbers, delays in awarding funding for EHCPs (Education Health and Care Plans for pupils with special needs) which means that schools fund extra support from their own budgets. There is now the prospect that any staff salary increases will have to be funded from the individual school budgets rather than be fully funded by the government.
A significant number of Brent schools will have an in-year deficit in 2023-24, relying on the use of their reserves or a contribution from the Council via the Direct Schools Grant.
Against this background, although the Mayor's one year (and one-off) provision of universal free school meals was welcomed by Forum members, they also noted that there were issues around implementation.
Officers are still trying to ascertain details from City Hall but if the GLA financial contribution is just for meal ingredients, and perhaps energy costs, there are other costs involved.
One headteacher pointed out that in his school, if those children currently bringing in packed lunches, switched to hot meals, it would double the number having school meals. This would mean investing in the kitchen capacity (equipment and staffing) but as a 'windfall' provision, without further funding in the future, this expansion would end after a year. In his school there would be double the number of pupils for whom food would have to be prepared, served, supervised and cleared.
The impatct will vary between schools depending on how many children bring in a packed lunch at present.
Getting the expanded provision up and running by September 2023 would be a further challenge, especially if kitchen infrastructure work was needed, given current rising building costs and unreliable supply chains.
At a practical level the switch from children sitting down to their own packed lunches, basically serving themselves, and instead joining the lunchtime queue at the servery would present logistical problems that would extend the lunch break and require additional supervision.
An unintended consequence might be that because at present parents of junior aged children have to register for free school meals, and this is used as a base for pupil premium funds, universality would mean parents would no longer bother to register - reducing the amount of pupil premium allocated to the school.
Gwen Grahl, Cabinet member for Children, Young People and Schools, responding to the discussion said:
There are definitely legitimate concerns about how this will be implemented. We have recognised for a while now that there is a need for better measures to tackle food poverty. We hear that, not only from teachers, but also from foodbanks that we visit. It (universal free primary school meals) is a positive measure in that regard and we think that the amount of money (£170m) is something we want to use, but we have been in touch with City Hall and have raised some of the concerns.
We have made it clear that there wil be challenges with implementation. We want to have the confidence that we can implement by September and we would need support from City Hall in doing so. We would also need the confidence that the projected amount it will cost is accurate as I think that City Hall has done its own research and what they think it will cost in every borough. I think the amount is £2.71 per meal, so it is going to be a stretch. We also raised the issue of whether it would affect the pupil premium.
I am sure you will appreciate none of the details have come out yet. We want to reassure you that we have raised raised these issues with City Hall and we are looking for a lot of detail and support from them in implementation.
We will be able to disucss this with headteachers as soon as broader details have been refined for Brent.
Sadiq Khan has responded to the Government's post-Grenfell consultation on Emergency Evacuation Information Sharing which they undertook after rejecting the Grenfell Inquiry's recommendation on Personal Emergency Evacuation Plans (PEEPs).
It would be useful to know if Brent Council agrees with the London Mayor's response.
Response
to Emergency Evacuation Sharing Information Consultation 17
August 2022
Summary
The
Mayor of London reiterates his view that legislating for Personal Emergency
Evacuation Plans(PEEPs) in all buildings of any height covered by
the Fire Safety Order, and providing centralfunding, is the only way to ensure there is
comprehensive and consistent implementation acrossthe entire country.
The
proposals set out in this consultation on Emergency Evacuation Sharing
Information (EEIS)amount to little more than a watered-down version
of PEEPs. The Mayor has identified several oflimitations to the EEIS proposals and has
detailed them below.
Government’s
ongoing failure to implement this recommendation from Grenfell Tower Inquiry isdisappointing and
concerning. Government must ensure that the recommendations from theGrenfell Tower Inquiry
do not become a missed opportunity for change, as was the case after theLakanal House fire.
Five
years on from the Grenfell fire, the Mayor pays tribute to the bereaved and
survivors who arecampaigning for change so that a disaster like
Grenfell never happens again.
Response
to consultation
Following
the tragic loss of life in the fire at Grenfell Tower, in which 41 per cent of residents
withdisabilities
died, the Grenfell Tower Inquiry recommended that owners and managers of everyhigh-rise residential
building be required by law to prepare PEEPs for all residents whose ability toself-evacuate
may be compromised (such as persons with reduced mobility or cognition).
Given
that 83 per cent of respondents to the original PEEPs consultation in 2021
supported theproposal,
it is clear that there is significant demand for this recommendation to be
implemented infull.
The
Mayor is pleased to read that a working group of disabled groups and housing
providers isbeing
set up by government and would stress that the group membership must be diverse
andreflect
all views, including those who would benefit from PEEPs. It is vital that the working
groupconsiders
and establishes the best way to implement PEEPs in practice.
While
the call for evidence on PEEPs is welcome, government should also be conducting
pilotschemes
and undertaking research to make a more informed assessment of PEEPs in
residentialhousing.
The Mayor hopes that this would lead government to reconsider its latest
position.
Following
a commitment to implement PEEPS fully, the evidence collected from this process
couldthen
inform a nationwide protocol, guidance and training on how the housing and
developmentsector
could implement the requirements of any legislation on PEEPs.
The
Emergency Evacuation Information Sharing (EEIS) consultation released on 18 May
2022proposes
alternative measures to protect the fire safety of residents who would need
support toevacuate
in an emergency. This proposal differs from PEEPs in a number of key ways.
First, it onlyfocuses on residents who are mobility impaired as
opposed to those with other physical or cognitive
impairments. Second, it only applies to buildings with a simultaneous
evacuation strategyand not buildings with a stay put strategy. Third,
it proposes five steps that involve conducting aPerson Centred Fire Risk Assessment (PCFRA)
as opposed to a PEEP, and then sharing informationwith the local Fire and
Rescue Service (FRS). Fourth, it relies on the FRS to conduct rescues of thosewho would be unable to
self-evacuate.
1.
Scope
The
Mayor is concerned that EEIS only focuses on residents that are mobility
impaired and urgesgovernment to take a more inclusive approach.
People who may be unable to self-evacuate includethose with mobility issues but also those
with other physical and cognitive impairments which maybe permanent or
temporary.
2.
Building fire strategy
The
Grenfell Tower Inquiry recommended PEEPs for all high-rise residential
buildings andgovernment
consulted on that proposal on 8 June 2021. Government is now proposing to
introduceEEIS –
a watered down version of PEEPs – only for buildings with a simultaneous
evacuationstrategy
in place. Under these proposals, those buildings with a stay put policy in place
would not be
required to provide EEISs for relevant residents. It is welcomed that
government has movedaway from using height as a distinguishing factor,
but the new categorisation of fire strategy cannotbe the correct approach
either. A resident affected by smoke or fire must have a plan and means toget to a place of
safety, regardless of whether the building has a stay put or simultaneous evacuation
policy.Grenfell
Tower was a building with a stay put policy and 72 people lost their lives. The
GrenfellTower
Inquiry Phase 1 report recommended government develop national guidelines forevacuation of high-rise
buildings as a result. It is clear that stay put cannot be the only strategy
andall
buildings must have a Plan B so that residents can evacuate to a place of
safety if stay put is nolonger viable.
Since
Grenfell, countless buildings have been found to have fire safety defects and
have thereforebeen forced to change their fire strategy to
simultaneous evacuation until remediation is complete.
Linking
EEIS to buildings with simultaneous evacuation risks suggesting building owners
can retireEEISs
once the building has been remediated. That was never the intention of the
Grenfell TowerInquiry recommendation around PEEPs.
3.
Person Centred Fire Risk Assessments (PCFRAs)
A
PCFRA is a risk assessment that helps identify residents who are at higher risk
from fire in theirown flat. It differs from a PEEP in that it is not
a bespoke escape plan to assist residents who mayhave difficulties in evacuating a building
unaided during an emergency.
The
EEIS consultation proposes a process whereby the Responsible Person (RP) offers
a PCFRA toresidents
who self-identify as requiring assistance to self-evacuate and then connects
them withthe
local FRS to arrange a home fire safety visit.
The
Mayor is content with the proposed reliance on self-identification but notes
that its successrelies on proactive communications from the RP.
These communications should encourageresidents to consider whether they need
support and inform them of their rights.
PCFRAs
will help identify residents who are at higher risk from fire in their own
accommodation andmeasures such as fire-retardant bedding and fire
safe ashtrays can be put in place for them in theirhomes. While PCFRAs are
welcome and indeed already being undertaken now by some RPs, they focus
on reducing the probability of fire inside someone’s flat and, unlike a PEEP,
they do notincorporate
an evacuation plan.
4.
Reliance on FRS conducted rescue
The
consultation makes the following argument against PEEPs: ‘the time between a
fire beingreported
and the FRS mounting their operational response at the scene is the period in
which aPEEP
would be enacted. In a residential setting, there will inevitably be a limit as
to what could besafely achieved by a single staff member or even a
small team regarding support to mobility impaired
residents in advance of the FRS attending with a greater number of competent,
trainedpersonnel.’
In other words, government is claiming there is insufficient time for a PEEP to
add valueand
that FRS conducted rescue is always preferable.
The
Mayor does not agree with this view for two reasons. First, the time that FRS
takes to arrive atan emergency may be quick, but the time taken to
actually set up a bridgehead, hoses and get intoa position to fight fire and rescue residents
in tall buildings is far greater. In reality there is more time
for a PEEP to be effective than government is suggesting.
Second,
expert evidence in the Inquiry has underscored the importance of timely
evacuation toavoid
serious and potentially fatal smoke inhalation. This highlights the risk
inherent in the EEISapproach which relies solely on FRS conducted rescue
instead of supporting self-evacuation.
I asked the Green Party Disability Group for a comment on the issue. They said:
Personal emergency evacuation
plans are critical to sustain human life in this climate crises-ridden world of
today. For disabled people to be valued equally as human beings by those in
power then society and safe & sustainable environments must be designed for
everyone.
We are also living through a mass
disabling event with an estimated 2 million people in the UK suffering from
Long Covid. Tories view disabled people as having no value & as ‘other’. If
those in power designed for us all equally & inclusively we would no longer
be disabled.
We would be what we really are - people with
impairments. And living equally with everyone else. Against the horrific
backdrop of Grenfell & needless loss of life and great suffering each and
every Tory voter must hang their heads in shame. Peeps are humane, this Govt
isn’t.