Our question is regarding the calculation of the largest fire risk concentration within the fire risk sub-module described in article 132 in the Delegated Regulation (EU) 2015/35.

We are unsure about how to understand the definition of the radius of 200 meters mentioned in article 132 2. (b). “all buildings are partly or fully located within a radius of 200 meters."

Below we have set up 3 examples.

Imagine 3 buildings with the following setup:

•            Building A: TSI of 1000 million €

•            Building B: TSI of 500 million €

•            Building C: TSI of 500 million €

•            All three buildings are square shaped with side length equal to 200

meters.

•            The buildings are placed in such a way, that the centers of the buildings

create a right-angled triangle with the right-angle in building B

•            Distance from the center of Building A to the center of Building B equals

390 meters

•            Distance from the center of Building B to the center of Building C equals

410 meters

•            Distance from the center of Building A to the center of Building C equals

566 meters

Example 1:

A circle with radius 200m is placed with its center between the three buildings, resulting in all three building being partly covered by the circle.

Largest fire risk concentration = 1000 + 500 + 500 = 2000 million €

Example 2:

A circle with radius 200m is placed with the center of the circle being in the center of the building with the largest TSI, Building A, resulting in only Building A being covered by the circle.

Largest fire risk concentration = 1000 million €

Example 3:

Since Building A is large (200m x 200m) the circle in example 2 does not cover a very large area around the building.

If the area is instead interpreted as 200m from the outer walls of Building A, such that every building with a distance (outer wall to outer wall) of less than 200m from Building A is covered, then both Building A and Building B are covered, since the outer wall of Building B is only 190 meters from the outer wall of Building A.

Largest fire risk concentration = 1000 + 500 = 1500 million €

Question:

Which of the above examples is correct according to article 132? Should the largest fire risk be 2000 million €, 1000 million € or 1500 million €?

Also, shall the simplification in article 90 c) be interpreted as example 2 or 3?