Report Deep Dives

Author declarations in a fire statement

8 min readBy PlanScope Editorial Team

The prescribed fire statement form asks who prepared it and why they are competent. The Building Safety Regulator reads that section before the technical content.

Fire statement author competence is the part of a Gateway One submission that a planning consultant cannot fix with better drafting. The prescribed form asks who prepared the statement and what makes them qualified to do it, and the Building Safety Regulator reads that answer before it reads the technical content. A statement with an articulate description of the evacuation strategy and a blank or vague competence section attracts the same response as one with no strategy at all.

So the first decision on a relevant building is not what to write. It is who signs.

What the form asks about the author

The requirement comes from Article 9A of the Town and Country Planning (Development Management Procedure) (England) Order 2015, inserted in 2021. Where an application involves a building containing two or more dwellings or educational accommodation, and the building is 18 m or more in height or has seven or more storeys, the application must be accompanied by a fire statement in the form published by the Secretary of State.

The form is prescribed, which means the headings are not yours to rearrange. Alongside the sections on the building, the site, access for the fire service, water supplies and the evacuation strategy, it asks for the identity of the person who completed it and for information about their competence to do so, including whether they hold any relevant third party accreditation. The authority checks the form is complete at validation. The Health and Safety Executive, acting as the Building Safety Regulator, is the statutory consultee and assesses the substance.

What the Order does not do is name a qualification. There is no statutory list of people entitled to author a fire statement, which surprises consultants who expect something like the licensing regime for ecology work. The gate is practical rather than statutory: an unsupported competence claim produces an unsatisfactory response from the regulator, and the local planning authority then has a consultee objection on its file.

How competence is evidenced in practice

A competence statement that works does three things. It names the individual rather than the firm. It sets out qualifications and registration with dates. And it connects the person's experience to this building type and this question, rather than to fire safety generally.

Useful content, roughly in descending order of weight:

  • Chartered Engineer registration with the Engineering Council through the Institution of Fire Engineers, with the registration number.
  • Membership grade of the Institution of Fire Engineers, with the grade stated accurately.
  • A degree or master's in fire engineering or fire safety engineering, with the awarding institution and year.
  • Listing on a recognised register of fire engineers or a third party accreditation scheme, named and dated.
  • Specific project experience on buildings of comparable height, occupancy and evacuation strategy, described in enough detail to be checked.
  • Continuing professional development relevant to the current regulatory framework.

What does not work: "over 20 years in the fire industry", a firm's accreditation offered in place of an individual's, a fire risk assessor qualification offered as evidence of fire engineering design competence, and a membership grade inflated by one level. The regulator's reviewers are fire engineers and they read these sections carefully.

The underlying framework is the competence regime built around the Building Safety Act 2022 and the British Standard on core criteria for building safety competence, which sets out skills, knowledge, experience and behaviours as the four limbs. Writing the competence statement against those four limbs rather than as a list of letters after a name reads better and is harder to pick apart.

Relevant memberships and what they signify

Credential What it indicates
Chartered Engineer registered through the Institution of Fire Engineers Assessed engineering competence at chartered level in fire engineering
Incorporated Engineer registered through the Institution of Fire Engineers Assessed competence at incorporated level, usually applied rather than design-led
Member or Fellow of the Institution of Fire Engineers Peer assessed experience at the stated grade
Graduate or Associate grade Progression grades, not evidence of independent design competence
Fire risk assessor certification Competence in assessing existing buildings in use, a different discipline
Chartered membership of a building services or structural body Relevant adjacent competence, not a substitute for fire engineering

The distinction between designing a fire strategy and assessing an existing building's fire risk is the one most often blurred on these forms. Both are legitimate professions. Only one of them is being asked for at Gateway One.

A Fire Statement for a relevant building requires an author with the necessary fire engineering competence, and the regime under the Building Safety Act 2022 and Article 9A treats that as a requirement rather than a preference. An AI-assisted draft can structure the form, gather the site information and flag what is missing, but the statement must be prepared and owned by that professional and is not something a drafting tool can supply.

Scope of responsibility and its limits

The author is declaring competence to complete the fire statement, which is a planning stage document about the principles of fire safety as they affect the design, layout and access arrangements. It is not a declaration that the building will comply with the Building Regulations, and it is not the fire safety strategy.

Say so in the statement. A short scope paragraph identifying what the author relied on, what was assumed and what is reserved for the later stages prevents the document being read as something it is not. Typical entries:

  1. Drawings relied on, by number and revision, with the date.
  2. Assumptions about structural fire resistance periods to be confirmed at detailed design.
  3. Assumptions about the fire service's access and water supply to be confirmed with the fire and rescue authority.
  4. Matters reserved for the Gateway Two submission to the Building Safety Regulator.
  5. Any area where the design is not yet fixed, with the parameters within which the fire strategy holds.

The full engineered document comes later. A Fire Safety Strategy prepared to the relevant British Standard is a fire engineering document in its own right and needs the same competence, applied in more depth. Keeping the two clearly separate in correspondence saves a lot of confusion with clients who think one has bought the other.

Where a planning consultant must stop

A planning consultant can do a great deal on a Gateway One submission without authoring it. Coordinating the information, obtaining the drawings at the right revision, liaising with the fire engineer and the architect, submitting the form, managing the consultation and responding on planning matters are all proper work.

What the consultant should not do is complete the technical sections and put their own name in the competence box. Two reasons, and the second is the one that bites. First, the regulator will see a planning qualification offered as fire engineering competence and respond accordingly. Second, the consultant has then taken on a duty of care in a discipline their professional indemnity policy almost certainly excludes.

The practical division that works: the fire engineer owns the statement and the competence declaration, the architect owns the drawings it refers to, and the consultant owns the application and makes sure the three arrive together at the same revision. Where the design team has no fire engineer, saying so to the client early is better than discovering it at validation. The professional directory is the route by which a draft is sent for review and sign-off by a named reviewer.

Design narrative is a grey area. A fire engineer's input often needs translating into the Design and Access Statement so the two documents do not contradict each other, and that translation is consultant work. Just make sure the fire statement is the source and the design statement follows it, never the reverse.

Liability and professional indemnity questions

Three questions to settle before the statement is issued.

Does the author's professional indemnity policy cover fire engineering design on buildings of this height and use, and is the cover on an each-and-every-claim basis or in the aggregate? Post-Grenfell, fire safety exclusions and height restrictions in policies are common, and a firm may be insured for existing building assessment and excluded from new design.

Is there a collateral warranty or reliance letter in favour of the client, the funder or a future purchaser, and does the author's scope match what those parties will rely on?

Who updates the statement if the scheme changes, and is that within the original fee? Fire statements are rarely issued once.

None of that is planning advice, and none of it is optional on a building of this scale.

Keeping the declaration current on a resubmission

The statement relates to a specific design at a specific revision. Change the design and the statement needs revisiting, which includes a fresh look at whether the competence declaration is still accurate for the person signing.

The triggers that usually require a reissued statement: a change to the number or position of stair cores, a change to the evacuation strategy, an increase in height or storey count, a change of use affecting occupancy, a change to fire service access or the position of the pumping appliance space, and any change to the external wall build-up.

Where a section 73 application or a set of amended plans alters any of those, expect the authority to reconsult the Building Safety Regulator, which means a fresh assessment of the statement as submitted. A revision table on the front page, listing the drawing revisions each version responds to, is the simplest way to keep that legible across a long application.

One honest uncertainty. The boundary between what has to be settled at Gateway One and what can properly be reserved to Gateway Two is still being worked out in practice, and different design teams draw it in different places. Stating your position explicitly in the scope paragraph is more defensible than leaving it implicit.

PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval. For specialist technical reports, qualified professional input may be required.

Frequently asked questions

Who can prepare a fire statement for Planning Gateway One?

The Order does not name a qualification, but the form asks for the author's competence and any third party accreditation, and the Building Safety Regulator assesses the answer. In practice that means someone with assessed fire engineering competence, usually chartered registration through the Institution of Fire Engineers or an equivalent evidenced route.

Which buildings need a fire statement with a planning application?

Applications involving a building that contains two or more dwellings or educational accommodation, and which is 18 m or more in height or has seven or more storeys. The requirement sits in Article 9A of the Development Management Procedure Order 2015 and the statement must be on the form published by the Secretary of State.

Can a planning consultant complete the fire statement?

A consultant can coordinate, submit and manage the consultation, but should not complete the technical sections or put their own name in the competence section. A planning qualification offered as fire engineering competence will draw an adverse consultee response, and most professional indemnity policies exclude fire engineering design.

Is a fire risk assessor qualification enough?

Usually not. Fire risk assessment concerns existing buildings in occupation and is a separate discipline from designing a fire strategy for a new or substantially altered building. Both are legitimate professions, but Gateway One is asking about design competence, and the regulator's reviewers read the distinction carefully.

Does an amended scheme need a new fire statement?

If the change affects stair cores, the evacuation strategy, height or storey count, occupancy, fire service access or the external wall build-up, then yes. Expect the authority to reconsult the Building Safety Regulator on the revised statement. A revision table listing the drawing revisions each version answers keeps that legible.

Sources and further reading

fire statementgateway onebuilding safety actcompetencefire engineeringvalidation

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.

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