Fire statement content at Planning Gateway One
A Gateway One fire statement is a prescribed form, not a bespoke report. What belongs in each section, from appliance access and water supplies to the evacuation strategy and the author declaration.
A fire statement is a prescribed document on a prescribed form, and the validation officer checks the form before anyone reads the content. Article 9A of the Development Management Procedure Order 2015 requires one to accompany an application for development involving a relevant building, and the fire statement content gateway one expects follows the structure of that form: the design principles, the site layout, access and water for firefighting, escape and evacuation, external wall construction, and the management assumptions that make the strategy work in use.
Written well it is eight to twelve pages. Written badly it is a page of assertions, and the Health and Safety Executive says so in its consultation response.
Which buildings require a statement
The requirement bites on a relevant building. In broad terms that means a building containing two or more dwellings, or educational accommodation, which has seven or more storeys or is 18 metres or more in height.
Height is measured from ground level to the floor surface of the top storey, excluding any top-level plant or machinery area. Storey counting follows the same logic. Get this wrong and you either submit an unnecessary document or fail validation, and the second is the expensive error.
The statement must be submitted on the form published by the Secretary of State. A bespoke report does not satisfy the requirement, however good it is, although a longer technical annex can sit behind the form.
Two consequences follow for the application as a whole. The Health and Safety Executive is a statutory consultee on these applications at Planning Gateway One, and its comments are planning comments rather than building control comments. And Gateways Two and Three under the Building Safety Act 2022 come later, through the building control route for higher-risk buildings, so Gateway One is about land use and layout decisions that are hard to reverse once permission is granted.
| Gateway | Regime | What it tests |
|---|---|---|
| One | Planning, article 9A DMPO | Fire statement with the application, HSE as statutory consultee |
| Two | Building control, Building Safety Act 2022 | Design and construction approval before work starts |
| Three | Building control, Building Safety Act 2022 | Completion certification before occupation |
Site layout and fire service access
This is the section where planning can actually change the outcome, because layout is fixed by the permission.
Set out the vehicle access route to the building, the hardstanding positions for pumping appliances and the distance from the appliance position to the dry or wet riser inlet. Show the carrying capacity and the turning provision. Then state the assumptions: appliance weight, outrigger loading if a high reach appliance is relied upon, and the gradient of the approach.
Private drives, podium decks and basement car parks are where schemes come unstuck. A courtyard reached through a 3.5 metre archway will not take an appliance, and discovering that after permission means redesigning the entrance.
Say what the surrounding development does to access on three sides, and whether a neighbouring site could later block a route you are relying on. An assumption that depends on third-party land should be flagged rather than buried.
Water supplies for firefighting
State the source, the location and the flow and pressure assumed, and say where the evidence comes from. A statement that says water supplies will be provided in accordance with Building Regulations is not an answer.
The content that satisfies a reviewer covers the position of existing hydrants relative to the appliance positions, any new hydrants proposed, confirmation sought from the water undertaker on available flow, the provision for riser inlets, and any on-site storage or tank proposed where the mains cannot deliver.
Where the undertaker's confirmation has not yet arrived, say so and say when. An honest gap with a date attached reads far better than a confident sentence that turns out to be wrong at Gateway Two.
Means of escape and evacuation strategy
Name the strategy rather than describing it loosely. Simultaneous evacuation, stay put with phased evacuation, or a progressive horizontal approach each carry different consequences for the plan form, and the plan form is what the planning permission locks in.
Cover the number and position of staircases, protected lobbies, the travel distances in the worst-case flat position, the provision for evacuation lifts, refuges, and the arrangements for residents who cannot use stairs. Where an evacuation alert system is proposed, say so.
The second staircase expectation for tall residential buildings has been introduced into Approved Document B with transitional arrangements, so state which version of the Approved Document the design is being taken forward under and verify the current position before submission. A fire statement that is silent on the staircase question invites a consultee comment that costs a month.
Personal emergency evacuation planning and the management of vulnerable residents belong in the ongoing management section rather than here, but the design has to make them possible.
External wall construction principles
At planning stage the question is principles rather than product specification, and the honest answer is usually a performance statement plus a stated intention.
Say what classification of materials is intended for the external walls, balconies and any attachments, how cavity barriers and fire stopping will be dealt with in principle, and whether combustible material is proposed anywhere in the build-up. Where the building is in a category for which particular restrictions apply, say which and confirm the design respects them.
Balconies, soffits, solar shading and green walls are where planning and fire pull in different directions, because the elevational treatment the design officer likes may be the one the fire engineer will not accept. Resolve that before submission rather than at condition stage, because a change to the material palette after permission usually needs an application to vary.
A Fire Statement is the Gateway One document. The fuller Fire Safety Strategy to BS 9991 or BS 9999 sits behind it and develops through the later gateways, and both are documents for which a competent fire engineer is legally required under the Building Safety Act 2022 framework and article 9A. An AI-assisted draft is a starting point for that professional, never a substitute.
Ongoing management assumptions
Fire safety in use depends on management, and the statement should be explicit about what the design assumes somebody will do.
Six items that reviewers look for:
- who the responsible person and the accountable person will be, by role rather than by name
- the maintenance and testing regime assumed for alarms, risers, smoke control and evacuation lifts
- how access routes and appliance positions will be kept clear, including any parking management
- how residents will be informed of the evacuation strategy, and how that is maintained as tenancies change
- the arrangements for personal emergency evacuation planning
- how information will be handed over and kept current for the building's life
Keep it to assumptions and roles. A management plan is a Gateway Two and occupation-stage document, and over-promising at planning stage creates conditions nobody can discharge. The practical sequencing of post-permission obligations is covered in what to do in the first month after planning permission.
Author competence and the declaration
The form carries a declaration, and the person signing it is making a professional statement.
National guidance expects the statement to be prepared by a person with the necessary fire engineering competence, and the Health and Safety Executive reads the document in that light. In practice that means a chartered or incorporated fire engineer, or an engineer with demonstrable experience of tall residential buildings, and it means naming them.
Three things to include about the author: their professional qualification and registration, the scope of what they have assessed, and the limitations of the assessment at this stage of design. Stating limitations is not a weakness in this document. It is what distinguishes a fire statement from a brochure.
Where the design team does not include a fire engineer, the review route matters. PlanScope's professional directory is the route for requesting review and sign-off of a draft by a suitably qualified reviewer, and the review request and sign-off flow records the declaration.
Draft the statement alongside the Design and Access Statement so the two agree on core positions, access, massing and materials. Divergence between them is the fastest way to a consultee objection. To see which documents a tall residential application is likely to need, enter your postcode on PlanScope and work through the guided questions.
This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it. For specialist technical reports, qualified professional input may be required. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.
Frequently asked questions
Which buildings need a fire statement with the application?
Relevant buildings under article 9A of the Development Management Procedure Order 2015, which broadly means buildings containing two or more dwellings or educational accommodation with seven or more storeys or a height of 18 metres or more. Height is measured from ground level to the floor surface of the top storey, excluding roof-top plant areas.
Can a bespoke fire report replace the form?
No. The statement must be submitted on the form published by the Secretary of State, and validation is checked against that. A detailed technical annex can accompany the form and is often useful, but the form itself has to be completed. Submitting a report alone is a common reason for failed validation.
How does Gateway One relate to Gateways Two and Three?
Gateway One sits in the planning system, with the Health and Safety Executive as statutory consultee on relevant buildings. Gateways Two and Three sit in the building control regime for higher-risk buildings under the Building Safety Act 2022, covering approval before work starts and certification before occupation. Layout decisions are hardest to change after Gateway One.
What should the statement say about water supplies?
The source, hydrant positions relative to appliance standing positions, the flow and pressure assumed and where that figure came from, riser inlet locations, and any on-site storage where the mains cannot deliver. Where confirmation from the water undertaker is outstanding, say so and give a date rather than asserting compliance.
Does the statement have to address the second staircase question?
It should. The second staircase expectation for tall residential buildings has been introduced into Approved Document B with transitional arrangements, so state which version the design follows and verify the current provisions before submission. Silence on the point reliably attracts a consultee comment and delays determination.
Who can prepare and sign a fire statement?
A person with the necessary fire engineering competence, which in practice means a chartered or incorporated fire engineer or someone with demonstrable experience of tall residential buildings. Name them, state their registration, set out the scope assessed and record the limitations at this stage of design.
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.