Material alteration ;
An alteration which results in a building being less satisfactory in relation to compliance with the requirements of Parts B1, B3, B4 or B5, than it was before, is controllable under Regulations 3 (meaning of building work) and 4 (requirements relating to building work) of the Building Regulations, as a material alteration.
Unless I am out of step, a new and improved AFD system installation should not need a building regs. application ? It improves what is already there. Even in a building with a complete active system, engineered means of escape strategy, it could be gilding the lily !
If you replace and upgrade escape lighting would you put an application in ?
Building control will always say yes, as you pay them !
Just an humble opinion !