DMFD211 Provision of Increased Electrical Power at 55 Fire Stations

1.1    Report LFC-23-072y to the London Fire Commissioner (LFC) explains that the Mayor has set the London Fire Brigade (LFB) a target of becoming carbon net zero by 2030. This project to install electrical infrastructure at fire stations forms Pillar One of LFB’s carbon net zero (CNZ) plans and will put in place the building blocks for LFB to become carbon net zero. 

1.2    The LFB currently operates from 103 fire stations located throughout Greater London.  The incoming electrical capacity at each station is on average 140 amperes (amps) and to meet the CNZ targets this will need to be increased to an average of 800 amps. This is required primarily to charge electrical vehicles in LFB’s operational fleet, but also the increased usage of electricity at fire stations. 

1.3    The existing electrical supply is aligned to the current daily requirement and very little further electrical load can be placed on fire stations until incoming capacity is increased.  The level of electrical increase required to decarbonise is significant as the planned future requirements of LFB are based on removing fossil fuels from the entire property and fleet portfolio.  The proposed solution to replace the current gas and oil-based fuels is electricity.  LFB would be procuring an individual electrical sub-station at each LFB fire station to provide the required electrical load capacity, the sub-station will be solely for LFB fire stations and will increase the electrical capacity by six times.  

1.4    The increased electrical capacity will also enable LFB to provide electric vehicle charging to functional bodies of the GLA.

1.5    Under the LFC’s Community Risk Management Plan pillar ‘representing you’, LFC will work with other organisations to provide a safer future for everyone and opening the infrastructure and becoming CNZ meets this challenge.
 

2.1    The overall objective is to provide LFC with the electrical capacity to implement the CNZ strategy. Pillar one of the strategy includes this objective, as well as opening the infrastructure to functional bodies to provide electric vehicle charging capacity. A detailed strategic business case for the project is appended to report LFC-23-072y and includes information on objectives, selection of options, costs, risks and plans for delivery.  
2.2    The objectives set out for the project in the business case are as follows:
•    Estate objectives:  The objective of the opening infrastructure project would be to resolve the challenges highlighted by the shortage of available electrical power. Increasing the electrical capacity at stations will enable LFB to remove the dependency on greenhouse gas (GHG) burning equipment (boilers and cookers) and will provide additional Electric vehicle charge points (EVCP) required to achieve CNZ.
•    Fleet Objectives: Increasing the number of EVCPs would provide robust operational readiness to respond to incidents. It would also permit other functional bodies to utilise the LFC electric vehicle charging infrastructure, as the requirement to implement an electric fleet becomes greater.  The fleet de-carbonisation strategy requires LFB’s fleet to become fully electric and this will require LFB to have a suitably sized electrical infrastructure to support the charging requirements of heavy battery powered electric vehicles. 
•    GLA objectives: For LFB as a functional body to lead by example and adopt CNZ by 2030.  Opening the infrastructure will also meet the GLA’s requirements:
o    For further electric vehicle charging infrastructure throughout London. As set out in the Mayor’s Electric Vehicle Infrastructure Strategy (EVIS), Transport for London (TfL) estimates that London will need between 40,000 and 60,000 public charge points by 2030, with up to 4,000 of these being rapid. TfL estimates that a quarter of these rapid charging points could be located on GLA Group owned land, including land owned by all functional bodies;
o    The additional requirement for Metropolitan Police Service vehicles, London Ambulance Service (LAS) and TfL to access electric vehicle charging infrastructure;
o    The GLA has a commitment to provide a network of electric vehicle charging points in London.  The LFB additional electric vehicle charge points would meet the requirements of ‘London’s 2030 electric vehicle infrastructure strategy (appendix 3 of report LFC-23-072y); and
o    The Mayor’s transport strategy 2022 revision includes the requirement for additional electric vehicle charging and infrastructure.
•    Delivery objectives: Being deliverable by end 2030, being affordable for LFB, providing acceptable value for money overall.
Options
2.3    Opening LFB’s infrastructure and increasing electrical capacity is a key requirement by 2030 to achieve CNZ. The LFC has considered a number of options, which are summarised below and set out in detail in the business case (appendix 3 of report LFC-23-072y).
•    Base case - Do nothing and continue to reduce carbon emissions using biofuel for the fleet and electrification of station heating only where possible. This does very little to mitigate the risks currently posed to LFB and this option has, therefore, been discounted as an unacceptable way to continue. 
•    Option two - Increase the power capacity at fire stations to accommodate the needs to de-carbonise the buildings. This option will meet the needs of the estate objectives and removes the dependency on burning gas. This option will cost an estimated £4,000,000.  However, it will not provide any electrical capacity for electric vehicle charging including the Zero Emission Pumping Appliance (ZEPA) and operational vehicles. Electric response cars and private cars are expected to increase in number and this option does not allow for this. Therefore, the LFC will need to continue with a fossil fuel powered fleet which may not be possible in the long term due to the phasing out of combustion engines. If this option is adopted and then in later years option three is required, it would mean that the road is again excavated with further disruption. 
•    Option three (LFC’s preferred option) - Electrical capacity is increased at 30 LFC premises to meet the needs of the planned zero-emission fleet, and property requirements (phase one). Following completion of this project the LFC would increase the electrical capacity at a further 25 stations (phase two). LFB’s Carbon Reduction team will then pause for evaluation for the remainder of the LFC estate and apply for approval for further expenditure based on the present market and environmental requirements. This preferred and recommended option is costed in Part Two of this Report.
2.4    The delivery of option three includes the requirement to increase electrical capacity at individual LFC premises by 600 per cent. Providing the electrical infrastructure and staffing resource now allows the LFC to work towards gaining the additional funding that achieving carbon net zero requires.  It also creates a stable operating platform for the ZEPA project as it expands and the on-going fleet de-carbonisation programme.  LFB may be able to offer EV charging to the LAS and GLA functional bodies.  The LFC plans to undertake decarbonisation of all fire stations. After the initial delivery of 55 stations, the project team will pause to reflect and allow for consideration of future environmental, technology and market conditions. The expenditure for the latter part of the decarbonisation programme will require further approval as the expenditure for that work is not included in this report. 
Resourcing and expenditure
2.5    Option 3 will need a multi-disciplinary team including location (surveyor) services, electrical engineering, and civil engineering works.
2.6    Delivery of these options will incur internal staff-related costs of an additional posts. as well as potential impact to resourcing levels of supporting functions such as LFB’s Procurement department, who will be required to support specific carbon net zero projects. Progression through the next stage of the project will involve three main areas of expenditure and cost avoidance:
•    Professional fees: LFB’s Carbon Reduction team would manage the entire project in house and therefore professional fees would be minimal.
•      LFB Project team: This would require the extra resourcing for the creation of an LFB Carbon reduction team.  
•    With additional resource LFB could identify the contestable elements of each Distribution Network Operator (DNO) project installation and identify cost avoidance measures for contestable works (building works and planning requirements) which can be procured independently to realise cost avoidance. This does require additional project management and therefore staffing resource, which will be permanent posts.
2.7    The preferred option three would require the following team:
•        FRS G role - one officer
•        FRS F role – one officer (already in the structure)
•        FRS E role – one officer
•        FRS D role – one officer (already in the structure)
2.8    A breakdown of the estimated cost for this work is provided in the Part two report.
2.9    The work to upgrade the 55 fire stations is expected to begin in 2023 and be completed by 2028/29.  The project is in two parts with part one starting in April 2024 and part two starting in 2026 with both parts complete during 2028/29.
 

3.1    The LFC and the Deputy Mayor for Fire and Resilience are required to have due regard to the Public Sector Equality Duty (section 149 of the Equality Act 2010) when taking decisions. This in broad terms involves understanding the potential impact of policy and decisions on different people, taking this into account and then evidencing how decisions were reached.

3.2    It is important to note that consideration of the Public Sector Equality Duty is not a one-off task. The duty must be fulfilled before taking a decision, at the time of taking a decision, and after the decision has been taken.

3.3    The protected characteristics are age, disability, gender reassignment, pregnancy and maternity, marriage, and civil partnership (but only in respect of the requirements to have due regard to the need to eliminate discrimination), race (ethnic or national origins, colour, or nationality), religion or belief (including lack of belief), sex, and sexual orientation.

3.4    The Public Sector Equality Duty requires decision-takers in the exercise of all their functions, to have due regard to the need to:
•    Eliminate discrimination, harassment and victimisation and other prohibited conduct.
•    Advance equality of opportunity between people who share a relevant protected characteristic and persons who do not share it.
•    Foster good relations between people who share a relevant protected characteristic and persons who do not share it.
3.5    Having due regard to the need to advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it involves having due regard, in particular, to the need to:
•    Remove or minimise disadvantages suffered by persons who share a relevant protected characteristic where those disadvantages are connected to that characteristic.
•    Take steps to meet the needs of persons who share a relevant protected characteristic that are different from the needs of persons who do not share it.
•    Encourage persons who share a relevant protected characteristic to participate in public life or in any other activity in which participation by such persons is disproportionately low.
3.6    The steps involved in meeting the needs of disabled persons that are different from the needs of persons who are not disabled include, in particular, steps to take account of disabled persons’ disabilities.
3.7    Having due regard to the need to foster good relations between persons who share a relevant protected characteristic and persons who do not share it involves having due regard, in particular, to the need to:
•    tackle prejudice 
•    promote understanding.
3.8    An early-stage Equalities Impact Assessment (EIA) has been undertaken indicating that the project will have a Low impact on equalities because there are no adverse impacts predicted at this stage.  The EIA will continue to be developed during the next phase the project which will put staff consultation and equalities at the centre of the design process to ensure alignment with the provisions of the Equality Act 2010.
 

Workforce comments
4.1    Outside of the Carbon Reduction team resourcing this project will affect station staff whilst the electrical upgrade building works are taking place and some disruption may be experienced as the DNO dig extra trenches for electrical cabling that would be required. The management of this disruption will be under the control of LFB project team to keep to a minimum with operational resilience being prioritised to ensure readiness. No stations will be required to close temporarily during the project.
Sustainability comments
4.2    One of the project's objectives is to deliver environmental sustainability – capital build options will be aiming for at least a Building Research Establishment Environmental Assessment Method (BREEAM) Excellent rating and sustainability will be built into consideration during the process of design and / or selection of buildings. The project team are working with LFB’S Sustainable Development team and will carry out the necessary Sustainability Impact Assessment during the next stage of the project.
Conflicts of interest
4.3    There are no conflicts of interest to declare from those involved in the drafting or clearance of this decision.
 

5.1    Under Part Two of this Report, commercially sensitive information is disclosed. This report recommends that capital expenditure for providing increased electrical power provision at 55 fire stations, as well as associated revenue expenditure, are agreed for the amounts set out in Part Two of this report.
5.2    In terms of longer-term capital costs, these will need to be incorporated into the future capital plan along with the associated financing of any such project once given approval and this will be developed throughout the budget setting process.
5.3    DNO organisations make a standing charge based on agreed supply capacity per KVA (kilovolt amp) and therefore upgrading from 69 KVA to 430 KVA will carry an extra cost per month. It is the intention however to hold the agreed supply capacity at current levels until it is required for use. The decision requested at this time refers to capital investment in the infrastructure. Further business case(s) will be required to be submitted through appropriate governance for schemes that will ultimately use that infrastructure. Increased costs associated with higher electricity usage will need to be considered, along with any potential savings, as part of that process.  
5.4    An application will be made to GLA green finance initiatives borrowing as set out below.  These schemes are designed to allow functional bodies to borrow funding at a lower rate than Public Works Loan Board (PWLB) by at least one per cent.
5.5    The Green Finance Fund (GFF) will initially be up to £500 million and is loan finance provided by the GLA to the GLA Group and London boroughs at an interest rate that is cheaper than PWLB. The £90 million of GLA grant funding has been split: £75 million to subsidise the costs of finance offered by the Green Finance Fund and the £15 million will be used to provide funding to develop the pipeline of projects, mainly through the Accelerators.  Hence, the £75 million will be used, internally by the GLA, to reduce the cost of finance from the GFF so that it is more competitive than PWLB, in a similar way to how the UK Infrastructure Bank (UKIB) is setting up the cost of its finance.
5.6    The GLA has established a GFF to support the GLA Group, London boroughs and the NHS Trusts by providing competitive, flexible finance to help accelerate the delivery of a range of environmental projects that re being delivered in pursuit of achieving net zero. This GFF can provide a loan to the LFB to support the delivery of a project or a portfolio of projects that have been developed to support the LFB in getting to net zero. This finance, at below PWLB rates, is available to the LFB as an organisation and will need to be paid back by the LFB. Therefore, it will be for the LFB to decide from which of their budget streams it will be paid back from; for example, from the savings/revenues generated by the projects and/or another existing or new budget stream within the LFB and/or (least preferred) by the GLA top-slicing future budget that is being provided to the LFB. The finance being provided by the green finance Fund will be cheaper than borrowing from the PWLB. 
 

6.1    Under section 9 of the Policing and Crime Act 2017, the LFC is established as a corporation sole with the Mayor appointing the occupant of that office. Under section 327D of the GLA Act 1999, as amended by the Policing and Crime Act 2017, the Mayor may issue to the Commissioner specific or general directions as to the manner in which the holder of that office is to exercise his or her functions. 
6.2    By direction dated 1 April 2018, the Mayor set out those matters, for which the LFC would require the prior approval of either the Mayor or the Deputy Mayor for Fire and Resilience (the "Deputy Mayor").
6.3    Paragraph (b) of Part 2 of that direction requires the LFC to seek the prior approval of the Deputy Mayor before “[a] commitment to expenditure (capital or revenue) of £150,000 or above as identified in accordance with normal accounting practices…”. The Deputy Mayor's approval is accordingly required for the LFC to incur the expenditure set out in part 2 of this report. 
6.4    The statutory basis for the actions proposed in this report is provided by sections 7 and 5A of the Fire and Rescue Services Act 2004 (“FRSA 2004”). Section 7 (2)(a) FRSA 2014 states that the LFC has the power to secure the provision of personnel, services and equipment necessary to efficiently meet all normal requirements for firefighting and section 5A allows the LFC to procure personnel, services and equipment they consider appropriate for purposes incidental or indirectly incidental to their functional purposes. 
6.5    These comments have been adopted from those provided by the LFC’s General Counsel Department in report LFC-23-072y to the LFC.
 

Appendix 1 – Report LFC-23-072y - London Fire Brigade (LFB) – Carbon Net Zero (CNZ) – Provision of Increased Electrical Power at 55 Fire Stations