Public Comment 2021
This page includes:
Public Comment Drafts
Public comment closed on Monday 18 January 2021
for:
- The draft Revision of Technical Specification FPAA101D,
Automatic Fire Sprinkler System Design and Installation -
Drinking Water Supply
- The draft Amendment of FPAA101H, Automatic Fire Sprinkler
System Design and Installation - Hydrant Water Supply
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FPAA101D-2021 Revision
Pdf includes a clean copy (no mark-up) followed by a copy
with changes identified (with mark-up)
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FPAA101H-2021 (Amendment
incorporated)
Pdf includes a clean copy (no mark-up) followed by a copy
with changes identified (with mark-up)
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This draft revision includes:
- All changes to convert FPAA101D to the FPAA101H format to be
more readable (changes accepted)
- Additional changes to address stakeholder feedback (changes
shown).
To see the changes for the conversion to the FPAA101H format,
see this document here (note this document does not include the
additional changes, only the changes for the conversion).
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This is FPAA101H with the changes from the draft Amendment
incorporated into the full Technical Specification so that the
context of these changes can be readily understood.
There is also a draft standalone Amendment here, intended for people that already own a
copy of FPAA101H. It includes only the changes from the draft
Amendment.
Feedback is welcome on this standalone amendment too, but should
be limited to editorial feedback on how the changes have been
included in this standalone amendment (the content of the changes
is as per the changes in the "Amendment incorporated"
document).
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Background to the
draft FPAA101D Revision and FPAA101H Amendment
Since their publication in December 2018, and the subsequent
adoption into the National Construction Code 2019 (effective 1 May
2019), FPA Australia has received feedback from a wide range of
stakeholders involved in the implementation of systems to these
Technical Specifications, including from product manufacturers;
system designers and installers; water service authorities;
regulators; and more.
Now that there are sufficient changes to warrant improvements to
these Technical Specifications, FPA Australia has drafted the
proposed revision to FPAA101D and amendment to FPAA101H.
FPAA101D Revision
There are two major changes in the draft revision of
FPAA101D-one to address readability and another to address metering
of the drinking water supply.
There were also changes to address updates to referenced
standards and other minor issues.
Readability
We received much feedback on the difficulty of interpreting
FPAA101D in its current format where it adopts and varies AS
2118.5, particularly as this results in two sets of clause numbers
- one for FPAA101D (e.g. 1.0, 2.0, etc.) and another for the
variations to AS 2118.5 (Clause 1.3.2, 2.5.3.1, etc.). As such, the
first task in the revision was to revise FPAA101D to be in the
FPAA101H format.
Essentially, where FPAA101D currently adopts AS 2118.5 and
varies the requirements, in this draft revision of FPAA101D this is
reversed. Like FPAA101H, this draft revision of FPAA101D now
includes its specific requirements under its own heading and clause
structure and then refers to the relevant parts of AS 2118.5, where
applicable.
So that the editorial changes from this change in format are
clearly separated from the additional changes made afterwards, the
above revision only shows the additional changes in track changes
(the editorial changes from the change in format are accepted).
However, the editorial changes from the change in format can be
viewed in track changes in this document here.
Metering
Due to pre-existing policies in some circumstances requiring
sole-occupancy unit (SOU) water usage to be individually monitored,
some water supply authorities have requested the addition of an
option for the FPAA101D system to go through the SOU water meter
for billing purposes (currently, FPAA101D water usage comes under
the common water meter for the building).
This draft revision, developed in consultation with water
service authorities, addresses this feedback by providing two
additional options:
- A minor variation to the existing system configuration to
provide the option to add water meters by floor (which, depending
on building design and water service authorities' policies, may be
enough to address the above concern); and
- An alternative "SOU metered" system configuration, where the
sprinkler system goes through the SOU water meter (and then either
continues combined or separate to the piping network for the
domestic appliances).
Updates to Australian Standards
Since the publication of FPAA101D, several of the referenced
Australian Standards have been amended or revised and/or are in the
process of being amended or revised. As such, FPAA101D's references
have been updated to reflect the amended or revised Standards.
Other changes
In addition to the above changes, a variety of editorial and
minor technical changes have been made to address minor errors and
issues identified with the Technical Specification since its
introduction.
FPAA101H Amendment
Non-residential parts of the building having a disproportionate
effect on the system
The major change in the draft amendment is to address the
disproportionate effect that the existing requirements for non
residential parts of the building have on the requirements of the
FPAA101H system where these parts make up a limited proportion of
the building.
FPAA101H currently requires the sprinkler protection of
non-residential parts of the building to be hydraulically designed
for the relevant hazard class as per AS 2118.1:2017, which can
result in a significant increase of sprinklers required to
operate-anywhere from 4 to 30 sprinklers-compared to the 2
sprinklers required for the residential portions of the
building.
While appropriate where a significant proportion of the building
is non-residential, when the significant proportion is residential,
this can have a disproportionate effect on the system. This is
especially the case where it triggers a building that would
otherwise not require a pumpset and/or water storage tank to cover
the requirements of the hydrant system or residential parts of the
building to now require such equipment, creating considerable cost
impacts both through the need for such equipment but also to house
such equipment.
On review, FPA Australia has acknowledged the feedback and
drafted an option for more limited system requirements that can be
(but are not required to be) applied where the non-residential part
of the building makes up a limited proportion of the building.
The limitations on the size of these parts have been aligned
with the application of FPAA101D under the BCA. Also, while the
limited system requirements have been similarly aligned with
FPAA101D they retain a more nuanced approach consistent with the
existing approach of FPAA101H to treat the different hazard classes
differently (whereas FPAA101D applies a flat level of protection to
non-residential parts of buildings).
Other changes
In addition to the above changes, a variety of editorial and
minor technical changes have been made to address minor errors and
issues identified with the Technical Specification since its
introduction.