DMFD294 Strategic bulk fuel monitoring system

1.1    As part of national fuel-resilience arrangements, the London Fire Commissioner (LFC) must ensure that London Fire Brigade (LFB) can continue to operate during fuel disruptions. LFB maintains strategic bulk fuel reserves at 37 fire station sites, with a total capacity of 201,000 litres.

1.2    LFB is seeking approval of spend to upgrade its strategic bulk fuel monitoring system across all 37 sites. The system was installed in 1999 and relies on 2G SIM connectivity. This is obsolete and presents a cybersecurity risk. LFB considered procuring a 5G modem add on; but rejected this as it would not meet ICT security requirements.

1.3    LFB’s proposed solution is to replace all existing single board computers; but retain existing sensors, fuel pumps and tanks. This will remove the need for a separate SIM modem; but will maintain compatibility with existing fuel cards to support a straightforward rollout. LFB reports that the proposed system has passed a full IT security review. 
 

2.1    LFB expects the proposed solution to provide a system that accurately and reliably records dispensing data and fuel levels, while restricting access to authorised users via fuel cards. LFB will then have a fully functioning bulk fuel monitoring system that it can interrogate remotely. The system will:

•    replace the current manual process, reducing or removing the need for station crews to record weekly fuel stock levels

•    email data daily to an approved shared mailbox, providing a reliable record to support audit requirements.
 

3.1    The LFC, and the Deputy Mayor for Planning, Regeneration and the Fire Service (the Deputy Mayor), are required to have due regard to the Public Sector Equality Duty (section 149 of the Equality Act 2010) when taking decisions. The Public Sector Equality Duty requires the identification and evaluation of the likely potential impacts, both positive and negative, of the decision on those with protected characteristics (see paragraph 3.3).  

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. 

3.6    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. 

3.7    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. 

3.8    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. 

3.9    The bulk fuel monitoring system will be a cloud-based service accessible by nominated LFB personnel. LFB does not expect it to disadvantage any staff member with protected characteristics.

3.10    LFC-26-048 reports that the fuel dispensing equipment will not change under this proposal; and LFB has made additional checks to ensure that using this equipment meets the equalities requirements.
 

Procurement comments
4.1    LFC-26-048 sets out how LFB will source its new system to meet relevant procurement regulations and its scheme of governance. LFB intends to develop a procurement strategy jointly between its procurement and carbon net-zero teams, to identify the best compliant route to market and best-value solution. It plans to explore two compliant potential routes to market as the next step. 
Sustainability comments

4.2    LFB reports that LFC-26-048 does not introduce any significant sustainability impacts. It notes that an automated, robust and accurate reporting method for the quantities of bulk fuel LFB uses supports the ongoing carbon reporting data required by its sustainable development team. 

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    LFC-26-048 seeks authority to commit capital expenditure for the purchase of new strategic bulk fuel monitoring systems across 37 strategic fuel locations. LFB will purchase and implement these systems in the 2026-27 financial year, funded from LFB’s 2026-27 capital programme.  

5.2    While individual monitoring units at each site are below the £20,000 capitalisation threshold, they are functionally interdependent and operate as a unified corporate network to fulfil LFB’s strategic commitments under the National Emergency Plan for Fuel. The system is managed as a single functional network. The total cost will be recognised as a single Grouped Capital Intangible Asset in accordance with International Accounting Standard 38.

5.3    LFB reports that it has budget cover for the purchase of the systems in 2026-27. The supplier will provide the cloud-based back-office function free of charge in 2026-27. LFB will be charged an annual fee from 2027-28 onwards, budgeted for within the property management revenue budget.
 

6.1    The LFC’s General Counsel’s Department has confirmed the following.

6.2    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 LFC specific or general directions as to the manner in which the holder of that office is to exercise his or her functions.

6.3    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. Paragraph (b) of Part 2 of the said direction requires the LFC to seek the prior approval of the Deputy Mayor before “[a] commitment to expenditure (capital) of £150,000 or above as identified in accordance with normal accounting practices”.

6.4    The Deputy Mayor's approval is accordingly required for the LFC to purchase an updated Strategic Bulk Fuel Monitoring system which has an estimated cost exceeding £150,000 and is set out in full in part 2 of the report.

6.5    The arrangements proposed is consistent with the LFC’s duty under section 7 (2)(a) of the Fire and Rescue Services Act 2004 (2004 Act) to secure the provision of personnel, services, and equipment necessary to efficiently meet all normal requirements for firefighting and under section 5A of the 2004 Act to do anything it considers appropriate for the purposes of carrying out any of its functions.

6.6    LFC-26-048 sets out details for the proposed compliant procurement.
 

LFC-26-048 LFC Strategic Bulk Fuel Monitoring System – part 1