Design Memo
CCC-DM-2025-028

Performance-Based Fire Engineering: When You Need It

What You Need to Know

Not every building fits the standard fire safety rules. When the NCC's Deemed-to-Satisfy (DtS) provisions do not work for your design, a performance solution fills the gap. A qualified fire engineer analyses the building and proves it meets the NCC's safety objectives through engineering, not just prescriptive rules.

The Rules

  • The NCC allows two compliance paths: DtS provisions or Performance Solutions. Both are equally valid (NCC Part A2.2)
  • Performance Solutions must follow a structured process: brief, analysis, evaluation, and report (NCC A2.2(4), effective 1 July 2021)
  • A Performance Based Design Brief (PBDB) must be agreed with all stakeholders before analysis begins. This is a mandatory hold point (NCC A2.2(4))
  • Four assessment methods can demonstrate compliance: evidence of suitability, verification methods, comparison with DtS, or expert judgement (NCC A2.2)
  • The Australian Fire Engineering Guidelines (AFEG 2021) published by the ABCB provides the accepted methodology. It replaced the older IFEG 2005 for Australian use
  • The Fire Engineering Report (FER) becomes a fire safety measure for the life of the building. A copy must stay on-site at all times

What This Means in Practice

You need a performance solution when DtS provisions conflict with the building design. Common triggers include travel distances that exceed DtS limits, open-plan floors larger than the allowed fire compartment size, and atriums connecting multiple levels. Heritage buildings, warehouses with high storage, and change-of-use projects also frequently need them.

For a Class 5 office building, DtS allows 20 m travel to an exit or 40 m total to a choice of two exits. Many modern office floor plates push past these limits. A fire engineer can model the actual fire and smoke behaviour, prove the evacuation time is safe, and justify longer travel distances with compensating measures like sprinklers, smoke detection, and wider corridors.

The process has two stages. First, the fire engineer prepares a Fire Engineering Brief (FEB) that sets out the scope, the DtS deviations, the analysis methods, and the acceptance criteria. All stakeholders sign off before any modelling starts. Second, the Fire Engineering Report (FER) contains the full analysis: fire modelling, evacuation calculations, and the engineered solution that meets the NCC Performance Requirements.


Key Design Decisions

1

Do You Need a Performance Solution?

If any part of your design cannot meet DtS provisions, you need one. Common examples: floor plates exceeding compartment limits, atriums, reduced fire resistance levels, or boundary setback shortfalls. Ask your building certifier early.

Trade-off: A performance solution adds engineering fees (from a few thousand dollars for a single-issue solution to $20,000 or more for complex multi-issue projects) and typically 2-8 weeks to the program, but it can avoid costly DtS retrofits and give the architect more design flexibility.
2

When to Engage the Fire Engineer

Bring the fire engineer in at concept design. The fire strategy shapes exit locations, compartment sizes, and smoke management zones. Late engagement means late redesigns.

Trade-off: Early engagement fees are a small fraction of total project cost, and far less than redesign costs if fire issues surface at DA or CC stage.
3

Choosing the Right Assessment Method

Comparison with DtS is the simplest: show your solution is equal to or better than the prescriptive rules. Verification methods use NCC-prescribed tests or calculations. Expert judgement applies where modelling is not feasible. Most commercial projects use a combination.

Trade-off: More rigorous methods (fire modelling, evacuation simulation) cost more but give the certifier and fire brigade stronger evidence for approval.
4

Managing Fire Brigade Referral

In most states, performance solutions must be referred to the fire brigade (FRNSW in NSW, QFD in QLD). Referral fees apply and can exceed the fire engineer's fees on smaller projects. Factor these into the project budget from the start.

Trade-off: Early referral avoids surprises at construction certificate stage. Fire brigade referral fees vary by state and project size. Check with your local authority early and include these fees in the project budget.

Who Needs to Know What

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References

  1. National Construction Code 2022, Volume One, Part A2.2 — Compliance with the NCC
  2. Australian Fire Engineering Guidelines (AFEG) 2021, Australian Building Codes Board
  3. International Fire Engineering Guidelines (IFEG) 2005, ABCB (superseded in Australia by AFEG 2021)
  4. NCC 2025, Volume One, Section C — Fire Resistance
  5. NCC 2025, Volume One, Section D — Access and Egress
  6. NCC 2025, Volume One, Section E — Services and Equipment

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