Fire safety and policy D12 in a London application

Policy D12 fire safety in London operates alongside the national fire statement requirement rather than instead of it. The London Plan asks all development proposals to achieve the highest standards of fire safety, and asks major development to submit a fire statement produced by a suitably qualified third party assessor who is independent of the design team. Separately, the national procedure order requires a fire statement on a prescribed form for relevant buildings, with the building safety regulator consulted. A major London scheme of eighteen metres or more engages both.

Developers who treat these as one document usually find out at validation. The forms are different, the triggers are different, and the independence requirement is specific to the London policy.

What policy D12 requires at application stage

The policy works in two parts. The first applies to all development and sets out what the proposal has to demonstrate: construction methods and products that minimise fire risk, suitable and convenient means of escape for all building users including people who cannot use stairs, features that reduce the risk to life, suitably positioned unobstructed outside space for fire appliances and for operations, and appropriate access for fire service personnel.

The second applies to major development and asks for a fire statement from a third party assessor with the competence to produce it. Independence is the operative word: the assessor should not be part of the design team producing the scheme.

What the statement should cover at this stage is strategy, not detail. The evacuation approach and its justification, the arrangement of cores and escape routes, the provision for people with reduced mobility, the location and size of fire appliance access and hardstanding, water supply and hydrant provision, and how the strategy is expected to develop through the later regulatory stages.

Resist the temptation to submit a detailed fire strategy at planning. It will be out of date before the detailed design stage, and inconsistencies between it and the later documents create problems at Gateway Two.

How it relates to Gateway One

Planning Gateway One is the first of three regulatory gateways under the building safety regime. It applies at planning application stage to relevant buildings, broadly those reaching at least eighteen metres or seven storeys and containing two or more dwellings or educational accommodation, and it requires a fire statement on the prescribed form submitted with the application. The building safety regulator, within the national health and safety body, is a statutory consultee and its response goes to the local planning authority.

The verification to run at the start of any London scheme is simple. Is the building a relevant building for the national requirement? Is the scheme major development for the London policy requirement? Those two questions have four possible combinations and each needs a different submission.

Verify the current definition of a relevant building before relying on the table, because the thresholds and the scope have been amended since the regime began.

A Fire Statement is one of the report types where a competent professional is legally required rather than merely advisable. The statutory framework is explicit about competence, and an AI-assisted draft is a starting point for that professional rather than a substitute for their judgement.

Evacuation strategy and lift provision

The evacuation strategy drives the core design, and the core design drives the efficiency of the whole building. So this is a planning-stage decision in substance even though it reads as a technical one.

London design policy asks for at least one lift per core in residential development to be a suitably sized fire evacuation lift. A lift of that specification needs a protected lobby, a secondary power supply and controls, and it is physically larger than a standard passenger lift. On a constrained plot that changes the core footprint and therefore the net to gross ratio, which is why it has to be settled before the massing is fixed. Our note on optimising site capacity under London Plan policy D3 covers the capacity side of the same calculation.

Evacuation strategies for residential buildings range from stay-put, where compartmentation holds and only the affected flat evacuates, to simultaneous or phased evacuation. The choice affects alarm provision, stair width and stair number, and it should be stated and justified in the statement rather than assumed.

Provision for residents who cannot use stairs is the part most often thin. Say where refuges are, how communication works from them, and how the evacuation lift fits the strategy.

Site access for fire appliances

This is a layout question and it is where planning and fire engineering actually meet.

The requirements concern the position and dimensions of hardstanding for pumping appliances relative to the building and to dry riser inlets, the carrying capacity and width of access routes, turning provision where a vehicle cannot drive through, and the location of hydrants and the available water supply. On schemes with podium decks, basement car parks or shared surfaces, the loading capacity of the deck for an appliance is a structural decision that has to be made early.

Landscape designers and fire engineers disagree about hardstanding positions more than any other item. Resolve it on the general arrangement drawing rather than leaving it as a note, because a scheme that moves an appliance bay at technical design stage usually loses planting, parking or both.

Who is competent to author the statement

For the national requirement, the statement must be prepared by someone with the fire engineering competence to do so. For the London requirement, that person must also be independent of the design team.

In practice, that means a fire engineer with relevant chartered or professional standing and demonstrable experience of buildings of the type proposed. Name the author, state their qualifications and state the basis of their independence in the submission. Authorities have begun asking for exactly that, and an unnamed statement invites a request for further information.

Where a scheme needs an independent reviewer for a draft document, a professional directory can be a route to one. Our professional directory lists reviewers who can review and sign off AI-assisted drafts, and for a fire statement that review is the substantive work rather than a formality.

Conditions and later gateways

Expect conditions requiring the development to be carried out in accordance with the approved fire statement, and sometimes requiring a detailed fire strategy to be submitted before particular stages.

Gateway Two follows at the pre-construction stage for higher-risk buildings, requiring the regulator's approval of the detailed design before building work starts. Gateway Three follows at completion, before occupation. The documents at those stages are different and far more detailed, and a Fire Safety Strategy prepared to the relevant British Standard is a fire engineering document requiring a competent professional.

Keep the planning statement and the later strategy consistent. Where the design changes between stages, say so and explain the change rather than quietly substituting a different strategy, because the regulator will compare them.

Submission content

A workable London submission for a major scheme of this kind contains the national fire statement on the prescribed form where the building is a relevant building, the policy statement from the independent assessor, a set of drawings showing cores, escape routes, refuges, appliance access and hardstanding, hydrant locations and water supply information, and a short note in the planning statement explaining how each limb of the policy is met.

Submit the appliance access arrangement as a dimensioned drawing rather than a description. That one drawing resolves more consultation comments than any amount of text.

This is general guidance rather than legal advice. Check the current policy wording, the current definition of a relevant building and the regulator's published requirements before relying on anything here.

Browse the PlanScope report types to see which documents a London major application is likely to need. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.