BCAB #1908

May 23, 2023

Re: Requirement for firefighting water supply at a pumphouse and a substation structure at LNG Canada’s River Water Intake facility

Project Description:

There are two structures: the pumphouse and the substation. The pumphouse is one storey in height and 616.48 m² in area and the substation is one storey in height and 438 m² in area. Both structures shelter primarily electrical equipment. The structures are normally unoccupied and are accessed for maintenance of equipment; they do not include offices, control rooms or washrooms.

Applicable Code requirements: (BCBC 2018)

3.2.2.2. Special and Unusual Structures
1) A structure that cannot be identified with the characteristics of a building
in Articles 3.2.2.20. to 3.2.2.92. shall be protected against fire spread and collapse in
conformance with good fire protection engineering practice. (See Note A-3.2.2.2.(1).)
(See also Notes A-3 and A-3.2.5.12.(1).)

3.2.5.7. Water Supply
1) Every building shall be provided with an adequate water supply for firefighting.
(See Note A-3.2.5.7.(1).)

Note A-3.2.5.7 in part states:
The intent of Sentence 3.2.5.7.(1) is that an adequate water supply for firefighting be readily available and of sufficient volume and pressure to enable emergency response personnel to control fire growth so as to enable the safe evacuation of occupants and the conduct of search and rescue operations, prevent the fire from spreading to adjacent buildings, and provide a limited measure of property protection.

Decision being appealed: (local authority’s position)

The local authority has determined the structures require a firefighting water supply in accordance with Article 3.2.5.7. as follows:

Due to the proposed size, use & occupancy, and the fact that these structures are located within the District of Kitimat’s municipal boundaries (within the 10 minute response time of the District of Kitimat’s fire hall), the BC Building Code requires fire water supply and that the design of these structures be based on the assumption that firefighting capabilities are available in the event of a fire emergency.

As per BCBC Section 2.3 Alternative Solution, it is of the District of Kitimat’s opinion that your submittal does not demonstrate that the alternative solution will achieve at least the level of performance required by Clause 1.2.1.1.(1)(b) of Division A and as outlined in Section 3.2.5.7 of Division B.

Appellant's position:

The appellant proposed an alternative approach on the basis that the structures are unoccupied and the risk of fire occurring or spreading is inherently low. Thus, an adequate water supply is no water supply. The approach to firefighting includes designing the structures to protect potential occupants, the public, and neighbouring properties but to ultimately sacrifice the structures themselves.

Appeal Board Decision #1908

It is the determination of the Board that in accordance with Article 3.2.2.2. the structures are special and unusual and therefore Sentence 3.2.5.7.(1) does not necessarily apply.

Reason for decision

The intent of Sentence 3.2.5.7.(1) is based on the assumption that firefighting is provided by emergency response personnel using water. The appellant has provided documentation that confirms the use of water for firefighting is not appropriate or effective in these structures. In addition, the appellant has addressed egress and potential fire spread to adjacent properties. The alternative approach, which is not an alternative solution, needs to make reference to Article 3.2.2.2. that provides methods for protection for special and unusual structures in conformance with good fire protection engineering practice.

Frankie Victor
Acting Chair, Building Code Appeal Board