Fire safety evidence on a London planning application

London plan fire safety evidence goes further than the national requirement, and the difference catches applicants out. Article 9A of the Development Management Procedure Order 2015 requires a fire statement only for relevant development involving a relevant building, which in broad terms means residential buildings of 18 metres or seven storeys and above. The London Plan requires a fire statement for all major development, prepared by a third party suitably qualified assessor. So a six-storey block of 60 flats in a London borough needs fire safety evidence even though the national trigger is not met.

Work out which requirement applies before you commission anything. The two documents overlap but they are not the same, and submitting the national form where the London Plan wanted an assessor's statement wastes a consultation cycle.

What the London Plan asks for beyond national requirements

Policy D12 of the London Plan requires all development to achieve the highest standards of fire safety, and sets out what that means in substance: construction materials and methods, means of escape for all building users including people who need level access, passive and active fire safety measures with their management and maintenance arrangements, a clear evacuation strategy, access for fire service personnel and equipment, water supplies for firefighting, and an approach to future modification that does not undermine the base build protection.

Policy D5 adds the requirement for evacuation lift provision, so that disabled occupants and visitors are not dependent on assistance down a stair in an emergency. At least one suitably designed lift per core is the expectation, and more where the building's size and use require it.

Two features of the policy matter for programme. It applies at major development scale rather than at 18 metres, and it requires third party authorship rather than a statement from the design team. Both have cost and lead-time consequences that belong in the fee proposal.

How it interacts with the national fire statement

Where both apply, one document can serve both purposes provided it covers the national form's content and the policy's content, and provided its author satisfies both tests.

A Fire Statement of either kind is a document where a licensed or competent professional is legally required, and PlanScope's draft is a starting point for that professional rather than a substitute for them. The national form is prescribed, so use the current published version rather than a copy from an earlier scheme.

Note that the second staircase requirement for taller new residential buildings has been brought into Approved Document B with transitional arrangements, and both the threshold and the dates have moved since first announced. Check the current edition before fixing a core strategy, because a scheme designed on a single stair can become undeliverable between application and construction.

Site layout, access and water supply content

The parts of the fire strategy that really are planning matters are the ones that cannot be changed later without changing the layout.

Fire service access is the first. Appliance routes need the geometry to work for a pumping appliance, including carriageway width, turning provision, gradient and the maximum distance from the appliance parking position to the dry riser inlet or the building entrance. Courtyard schemes and podium decks are where this fails, because the deck is often not designed for appliance loading.

Water supply is the second, and it is routinely left out. The strategy should state the hydrant provision, the flow required and whether the existing mains can deliver it, with the water undertaker's confirmation where a reinforcement is needed. A reinforcement is an off-site work with its own programme.

The third is the relationship between buildings. Separation distances, external wall construction facing a boundary, and the position of escape routes relative to neighbouring buildings all constrain the footprint. Where the capacity argument has pushed the massing, these constraints need testing against it, and the method for that sits alongside the design-led capacity work described in optimising site capacity under policy D3.

Evacuation strategy and lift provision

The evacuation strategy is the part of the statement that most often reveals a problem with the plan rather than with the fire engineering.

Answer each of these explicitly. Is the strategy stay put, simultaneous evacuation or phased. How many stairs serve each core and what are their widths. Where are the firefighting shafts. Where are the evacuation lifts, and what is their power supply and protected lobby arrangement. Where is the refuge provision and how does it communicate with the fire service. And how does a resident with a personal evacuation plan actually leave the building.

Evacuation lifts have planning consequences. They need a protected lobby at each level, a secondary power supply, and a core large enough to accommodate both the lift and the firefighting provision. Adding one at technical design stage rather than at planning stage pushes the core outward and loses area on every floor.

Where a scheme converts an existing building rather than building new, the strategy has to work with what is there, and conversions driven by permitted development rights carry the same policy expectations as any other major scheme, as discussed in Article 4 directions in London and office to residential.

Who is competent to author the evidence

The London Plan asks for a third party suitably qualified assessor, which is read as someone independent of the design team with demonstrable fire engineering competence. In practice that means a chartered engineer with fire engineering experience, commonly a member of the Institution of Fire Engineers, able to state their qualifications and the basis of their assessment in the document.

The statement should name the author, state their qualifications and professional membership, and describe the basis of their appointment. Anonymous statements, or statements signed off by the architect, get queried.

Where the scheme also needs a detailed fire engineering strategy to a British Standard, that is a separate document from the planning statement, and the relationship between the two should be explained rather than left implicit. A Fire Safety Strategy to BS 9991 or BS 9999 is a fire engineering document requiring a competent professional author.

Where the Building Safety Regulator becomes involved

For relevant buildings, the Building Safety Regulator within the Health and Safety Executive is a statutory consultee at Planning Gateway One. It comments on the planning application, focusing on the matters that planning can actually influence: site layout, access, water supplies and the fundamentals of the escape strategy.

Gateway Two sits before building work starts and Gateway Three before occupation, both outside the planning process. The point of Gateway One is to stop a scheme reaching Gateway Two with a layout that cannot accommodate a compliant strategy.

A response from the regulator asking for further information is common and is not a refusal. Answer it in writing, with revised drawings where the point is layout-related, and ask the borough to record the resolution in its committee report.

Conditions and reserved matters

On a detailed application, expect a condition requiring development in accordance with the approved fire statement, and often a further condition requiring a detailed fire strategy to be approved before works above ground level.

On an outline application the position is harder. The fire statement at outline stage should address everything the outline fixes, which means access, appliance routes, separation distances, water supply and the number and position of cores where those are set by the parameter plans. Matters that depend on detailed design can be reserved, but the parameter plans must leave room for them. An outline consent with a maximum building footprint too tight for the required core is a problem discovered at reserved matters, when there is nothing left to adjust.

Where phasing is involved, state how fire service access and water supply work during each phase and not only at completion. Access across an incomplete podium is a real constraint and the regulator asks about it.

Browse all 66 PlanScope report types to see which documents a major London 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.