The competency and sign-off section of a fire statement
Article 9A requires a fire statement from a competent person, but names no qualification. Here is who can credibly sign one, what evidence to file with it, and what the regulator checks.
Fire statement competency sign off is the part of Planning Gateway One that trips up otherwise careful applications. Article 9A of the Town and Country Planning (Development Management Procedure) (England) Order 2015 requires a fire statement with any application for planning permission involving a relevant building, and the published form has to be completed by a competent person. There is no register you can point at and no single qualification that discharges the duty, so the design team has to make a judgement and then be able to defend it. Getting that judgement wrong is one of the commonest reasons an application stalls before the Health and Safety Executive has even looked at the drawings.
Which buildings trigger the duty
Article 9A applies in England to a relevant building, which means a building containing two or more dwellings or educational accommodation that is 18 metres or more in height, or has seven or more storeys. Either limb is enough. A six-storey block at 18.2 metres is caught, and so is a seven-storey block at 17 metres.
Measure carefully and show the measurement on the drawings. Height is taken from ground level to the floor surface of the top storey, excluding roof-top plant and machinery, and storey counting excludes a top storey used only for plant. Schemes that sit within a metre of the threshold should carry a dimensioned section, because a validation officer will not take the height on trust and neither will the consultee.
The duty attaches to the application, not to the eventual building. An outline application for a relevant building needs a statement even though the detail is reserved, and a material change during the application will need the statement updating rather than replacing.
Who is competent to author and sign
The form and its guidance expect a competent person, described as having sufficient training, experience, knowledge and other qualities to properly assist with the fire safety design of the building. That wording is deliberately open. It does not say chartered engineer, and it does not say the author must be a member of any named body.
In practice the credible authors of a Fire Statement fall into a narrow group. A fire engineer registered with the Institution of Fire Engineers at a grade that reflects design work, or registered with the Engineering Council as an incorporated or chartered engineer in a fire discipline, is the straightforward case. A fire safety consultant with a recognised fire engineering degree or diploma and a portfolio of comparable high-rise residential work is defensible. A general architectural practice completing the form itself is not, and neither is a fire risk assessor whose experience is in assessing existing buildings under the Fire Safety Order rather than designing new ones.
BS 8670 sets out the overarching framework for competence in the built environment, and PAS 8673 deals specifically with competence for managing safety in higher-risk buildings. Neither is a licence, but both give a structure for demonstrating that the person who signed has the right skills, knowledge, experience and behaviours for this building rather than for buildings in general.
What the regulator does with the statement
The Health and Safety Executive is the statutory consultee for relevant applications, acting through the Building Safety Regulator. It reviews the fire statement and the submitted drawings and advises the local planning authority on whether fire safety matters have been adequately considered at the planning stage.
The advice is not a veto. It is a material consideration, and an authority that grants permission against advice has to explain why. In practice most authorities will not determine a relevant application while the regulator's advice is unresolved, so an inadequate statement adds weeks to a programme in the most expensive place, at the end.
A useful way to think about the review is that the regulator is checking whether fire safety has shaped the scheme, not whether the scheme complies with Approved Document B. Those are different questions, and answering the second one instead of the first is a common misstep.
Planning stage information, not a building regulations submission
The statement covers what planning can actually control. Site layout and the space around the building. Access and hardstanding for fire service vehicles, including the swept path and the standing position relative to the entrances. Water supplies for firefighting and where the hydrants sit. The principles of the external wall construction and any material or detail that the elevations commit you to. The number and location of cores and staircases as a plan arrangement. Means of escape strategy at a level of principle, including whether the building is designed for stay put or for simultaneous evacuation.
What the statement does not need is a full fire engineering analysis, smoke modelling or a compartmentation schedule. Those belong to Gateway Two and to the Fire Safety Strategy that follows. Padding a planning-stage statement with detailed modelling does not improve the response and sometimes attracts questions the scheme cannot yet answer.
| Stage | What is assessed | Who decides |
|---|---|---|
| Gateway One, planning | Fire statement with the application; layout, access, water supplies, external wall principles | Local planning authority, advised by the Health and Safety Executive |
| Gateway Two, before construction | Full design against the Building Regulations | Building Safety Regulator |
| Gateway Three, before occupation | As-built information and the golden thread | Building Safety Regulator |
Evidence of competence to put in the file
Do not simply sign the form and hope. Include a short appendix that names the author, states their role, gives their registration or membership and grade, and lists two or three comparable relevant buildings they have worked on. Say whether the author was appointed by the applicant directly or through another consultant, because responsibility for the statement should be traceable to a named person and not to a practice letterhead.
Where the author is not a registered fire engineer, the appendix has to work harder. Set out the qualification, the years of relevant design experience and the professional indemnity position. Anyone reviewing the professional sign-off route for this kind of document is asking a simple question about whether the person who signed would stand behind the statement at an inquiry.
One honest uncertainty. There is no published threshold for competence under Article 9A, so two reasonable reviewers can disagree about a borderline author, and the safest course on a marginal appointment is to ask the regulator's view informally at pre-application stage rather than after submission.
Why statements come back
The pattern is fairly consistent. Forms completed by someone whose experience is in existing-building risk assessment rather than new design. Statements that describe an intention to comply with guidance instead of describing what the scheme does. Fire service access shown as a note rather than as a drawn swept path against the actual kerb radii and parking layout. No water supply information at all, because the applicant assumed the water undertaker would deal with it later. External wall build-ups left as a performance aspiration when the elevations already commit to a particular cladding depth.
And one that is easy to avoid. A statement that answers a different building. Reusing a form from an earlier scheme without changing the storey count or the core arrangement is visible immediately, and it damages the credibility of everything else in the submission.
Coordinating with the rest of the team
The fire statement has to agree with the architectural drawings, the landscape layout, the Transport Statement and the drainage design, because fire appliance access competes with tree planting, cycle stores, podium levels and attenuation features for the same ground.
Sequence the work so the fire engineer sees the layout before it is frozen. On a constrained site the access requirement will move the building, and discovering that at sketch stage costs nothing. Then hold a single coordination review where the fire engineer, the architect and the civil engineer sign off the same site plan, with the appliance standing position and the hydrant locations marked on it.
Illustrative example. A seven-storey block of 38 flats on a corner plot, with a proposed single stair and a podium car park below. The fire engineer identifies at sketch stage that the appliance standing position cannot be achieved within 18 metres of the dry riser inlet without removing two parking bays and relocating a proposed street tree. The layout changes, the fire statement records the standing position on a dimensioned plan, and the regulator's response raises no objection. The figures here are illustrative rather than taken from a decided application.
A Fire Statement is a report type where a licensed or competent professional is legally required, and a PlanScope draft is a starting point for that professional rather than a substitute for them. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval. This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it.
Browse the 66 PlanScope report types to see where the fire statement sits alongside the rest of a high-rise residential submission.
Frequently asked questions
Which buildings need a fire statement with a planning application?
In England, a relevant building under Article 9A of the Development Management Procedure Order 2015. That means a building containing two or more dwellings or educational accommodation which is 18 metres or more in height, or has seven or more storeys. Either limb is enough on its own, so a seven-storey block below 18 metres is still caught.
Who is a competent person for the purposes of a fire statement?
Someone with sufficient training, experience, knowledge and other qualities to properly assist with the fire safety design. No single qualification is prescribed. A fire engineer registered with the Institution of Fire Engineers at a design grade, or an Engineering Council registrant in a fire discipline, is the straightforward case. General architectural practices completing the form themselves are not.
Is the Health and Safety Executive response binding on the council?
No. The regulator advises the local planning authority as a statutory consultee and its advice is a material consideration rather than a veto. In practice most authorities will not determine a relevant application while the advice is unresolved, so an inadequate statement adds programme time at the most expensive point.
Does the fire statement have to show Approved Document B compliance?
No. Gateway One deals with what planning can control, so site layout, fire service access and standing positions, water supplies for firefighting, core arrangement, external wall principles and the escape strategy at the level of principle. Detailed compliance and compartmentation belong to Gateway Two and the fire safety strategy that follows.
What competence evidence should go in with the form?
A short appendix naming the author, their role, their registration or membership grade, and two or three comparable relevant buildings they have worked on. State who appointed them and confirm the professional indemnity position. Where the author is not a registered fire engineer, set out the qualification and the years of relevant design experience instead.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.