The project is the design and construction of an addition to an existing building supply and garden centre store. The addition will be constructed in two phases and, when complete, the building will be approximately 1 400 m2 in building area, two storeys, unsprinklered, and regulated by Part 3.
An adequate water supply for firefighting is required. Supply options include a water-shuttle operation by the local fire department from a hydrant located 1.2 km away from the property, or enlargement of a “swamp” located on the property to provide a fire water storage pond equipped with a dry hydrant.
Sentence 3.2.5.7.(1), Division B, 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.(1) Water Supply.
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.
The water supply requirements for buildings containing internal fire suppression systems, including sprinkler systems and standpipe systems, are contained in specific standards referenced in the Code. Compliance with the referenced standard, including any variations made by this Code, is deemed to satisfy the intent of Sentence 3.2.5.7.(1). However, it will be necessary to verify that an adequate source of water is available at the building site to meet the required quantities and pressures.
For a building with no internal fire suppression system, the determination of the minimum requirements applicable to the water supply for firefighting is relevant mainly to building sites not serviced by municipal water supply systems. For building sites serviced by municipal water supply systems, where the water supply duration is not a concern, water supply flow rates at minimum pressures is the main focus of this provision. However, where municipal water supply capacities are limited, it may be necessary for buildings to have supplemental water supplies on site or readily available.
The sources of water supply for firefighting purposes may be natural or developed. Natural sources may include ponds, lakes, rivers, streams, bays, creeks, and springs. Developed sources may include aboveground tanks, elevated gravity tanks, cisterns, swimming pools, wells, reservoirs, aqueducts, artesian wells, tankers, hydrants served by a public or private water system, and canals. Consideration should be given to ensuring that water sources will be accessible to fire department equipment under all climatic conditions.
The volume of on-site water supply is dependent on the building size, construction, occupancy, exposure and environmental impact potential, and should be sufficient to allow at least 30 minutes of fire department hose stream use. For the purposes of calculating adequate water supply requirements for fire fighting, the following documents may be useful:
• Insurance Services Office (ISO), “Needed Fire Flow Guide,”
• NFPA 1142, “Standard on Water Supplies for Suburban and Rural Fire Fighting,” and
• American Water Works Association, “Distribution Requirements for Fire Protection.”
The Fire Response Plan prepared by the local fire department is acknowledged by the fire department to be a best-case scenario. The water shuttle response may not always be able to be provided based on volunteer availability.
The water shuttle supply option is not adequate to satisfy the requirements of the Code.
A Fire Response Plan prepared by the local fire department outlines a response with four water-equipped apparatus arriving to supply water at the start of the incident response. As those water supplies become depleted in sequence, a rotating water supply shuttle with those four vehicles to the nearest hydrant can supply sufficient water such that “there should never be a situation where there is no water to fill the apparatus fighting the fire.”
The Code requires an adequate water supply for firefighting but does not prescribe a single method by which that water supply must be provided. The Code does not expressly require that firefighting water be provided exclusively through a hydrant located at the building site. The adequacy of a firefighting water supply should be assessed based upon actual firefighting capability, available resources, and the ability of the responding fire department to sustain suppression operations.
The plan by the fire department demonstrates that firefighting water is available through a documented and operational water shuttle system supported by trained personnel, multiple apparatus of sufficient capacity, a nearby hydrant with an adequate flow rate, and established response procedures, thereby satisfying the Code requirement.
The Board varies the decision of the local authority.
It is the determination of the Board that a water shuttle method of providing water for firefighting can be acceptable provided that it is demonstrated to meet the requirements of NFPA 1142 – “Standard on Water Supplies for Suburban and Rural Fire Fighting”.
Through application of NFPA 1142, it may be determined that the water shuttle supply is fully adequate, or it may be determined that supplementary on-site stored water is necessary to satisfy the Code requirement and the local authority.
The Code anticipates that all manner of water sources might be used to supply water for firefighting. Many of those sources will require fire department activities to convey the water from the source to the destination.
NFPA 1142 provides full guidance, including calculations with regard to water sources, water shuttles, and supplementary water stored on site.
Don Pedde
Chair, Building Code Appeal Board
Dated: August 6, 2026