Fire Statement content checklist for Gateway One
A fire statement is a validation requirement for relevant buildings, made on a published form. Here is what each section has to answer and where applications come unstuck.
A fire statement gateway one submission is not a fire strategy and it is not a Building Regulations document. It is a specific form, required by article 9A of the Town and Country Planning (Development Management Procedure) (England) Order 2015, that must accompany a planning application for development involving a relevant building. Leave it out and the application is invalid. Fill it in loosely and the Health and Safety Executive, as statutory consultee, will say so in its response.
This is a checklist for the architect assembling the pack, written around the published form.
Which buildings the requirement covers
The duty applies to applications for planning permission for development that involves a relevant building, which in broad terms means a building containing two or more dwellings or educational accommodation, and which either is 18 metres or more in height or has seven or more storeys.
Work through these before deciding you do not need one:
- Does the scheme contain two or more dwellings, or educational accommodation for children or students?
- Measure the height from ground level to the floor surface of the topmost storey, excluding roof plant and machinery.
- Count storeys, ignoring any below ground level.
- Where the scheme is a change of use or a conversion, ask whether the completed building meets the test, not the building as it stands today.
- For an outline application, check whether the matters reserved leave the height undetermined in substance, and speak to the validation team early.
Mixed-use blocks catch people out. A podium of commercial floorspace with residential above is a relevant building if the completed building meets the height or storey test, and the commercial storeys count.
The published form and the sections it asks for
The statement has to be made on the form published by the Secretary of State, so do not submit a bespoke report in its place. Attach supporting drawings and technical notes to the form by all means, but the form is the document that satisfies article 9A.
Its structure follows the fire safety matters relevant to a planning decision rather than to construction. The principles and approach being taken to fire safety, the site layout, emergency vehicle access and water supplies, access and equipment for firefighting, the resources and facilities available, the design of the building itself, and any implications for future development on or adjoining the site.
Answer each against the planning decision in front of the officer. The question is whether the layout, access and massing being applied for can accommodate a workable fire strategy, not whether every detail has been resolved.
Site layout, access and water supplies
This is where planning has real influence, because the arrangement of buildings, roads and open space is fixed by the permission and is expensive to change later.
- Show the fire service vehicle route on a drawing, with carriageway widths, turning head dimensions and the swept path of an appliance
- Confirm the proximity of pumping appliance parking to the firefighting shaft entrance
- State the location and capacity of hydrants, and whether an on-site supply or a static tank is proposed
- Identify any gated access, barrier, height restriction or shared private drive that an appliance must pass
- Where podium decks or basement parking are proposed, state whether the deck is designed to carry appliance loading
- Note any constraint from an adjoining site, a tree preservation order or a levels change that limits access
Water supply evidence should reference an enquiry to the water undertaker rather than an assumption. Officers notice the difference.
Building design and escape principles
The form asks for the fire safety principles rather than a full strategy, but the answers commit the scheme to an approach.
Set out the number and location of stairs and whether a single stair is proposed, the evacuation strategy being assumed, the provision of firefighting shafts and lifts, the approach to external wall construction and materials, and the location of the building's compartments in relation to the massing shown on the drawings. Where the scheme relies on an engineered solution rather than Approved Document B guidance, say so plainly and name the standard being used.
Consistency is the thing that gets checked. If the Design and Access Statement describes an open ground floor with a single core and the fire statement describes two stairs, the discrepancy will surface at consultation.
What the Building Safety Regulator looks for
The Health and Safety Executive, acting as the Building Safety Regulator, is consulted on applications for relevant buildings at Gateway One. Its response goes to the local planning authority and is a material consideration.
Responses tend to focus on matters the permission would lock in. Whether appliance access is physically deliverable, whether the stair and core arrangement supports the stated evacuation strategy, whether the site layout leaves room for the firefighting facilities described, and whether the information supplied is specific enough to be assessed at all. Vague answers attract a request for further information, which stops the clock on a project rather than the drawing board.
A separate Fire Safety Strategy under BS 9991 or BS 9999 sits behind the statement at design stage. It is a fire engineering document and remains the responsibility of a competent fire engineer.
Who is competent to prepare it
There is no statutory register for fire statement authors, but the content requires fire engineering judgement, and both regulator responses and professional guidance point towards someone with demonstrable competence in fire safety engineering. In practice that means a chartered or registered fire engineer, or a fire engineering practice, working alongside the architect.
An architect can compile the form and coordinate the drawings. The technical answers about evacuation strategy, external wall construction and firefighting provision should be authored by the fire engineer, and the form should record who prepared them. A Fire Statement drafted without that input tends to read as a description of the building rather than an assessment of its fire safety, and it is the assessment the regulator wants.
Timing against validation
The statement is a validation requirement, so it must exist at submission. That has programme consequences.
Commission the fire engineer at the same time as the structural engineer, not after the planning drawings are frozen. Allow time for a water supply enquiry and for a swept-path exercise on the access, because both can force layout changes. Run a coordination check across the fire statement, the access drawings, the planning covering letter and the design documents in the week before submission, and resolve every inconsistency then.
One honest uncertainty. The boundary of the relevant building definition gets argued over, particularly for student accommodation and for schemes whose height sits close to 18 metres. Where you are within a metre of the threshold, submit the statement anyway. The cost of preparing one is far smaller than the cost of an invalid application and a lost committee cycle.
Where PlanScope drafts supporting documents for a scheme like this, it produces AI-assisted drafts structured to UK planning policy and flags site facts that need confirming. A fire statement is a professionally required document, so treat any draft as material for your fire engineer to complete and sign off. You can see how it sits with the rest of the pack on the report index.
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 planning applications need a fire statement?
Applications for planning permission for development involving a relevant building, meaning a building with two or more dwellings or educational accommodation that is 18 metres or more tall or has seven or more storeys. The requirement comes from article 9A of the Development Management Procedure Order 2015 and applies at the point of validation.
Can I submit my own report instead of the form?
No. Article 9A requires the statement to be made on the form published by the Secretary of State, so a bespoke fire report does not satisfy the requirement on its own. Supporting drawings, swept path analysis and technical notes can be appended to the form, and doing so usually improves the regulator's response.
How is the 18 metre height measured?
Height is measured from ground level to the floor surface of the topmost storey of the building, and roof plant or machinery is excluded. Storeys below ground level are not counted when totalling storeys. Where a scheme sits within a metre of the threshold, prepare the statement anyway rather than risk an invalid application.
Who has to prepare the fire statement?
There is no statutory register, but the content calls for fire engineering judgement, so a chartered or registered fire engineer should author the technical answers. An architect can compile the form and coordinate the drawings. Record on the form who prepared each part, because the regulator reads the statement as an assessment rather than a description.
What happens after the statement is submitted?
The local planning authority consults the Health and Safety Executive as the Building Safety Regulator at Gateway One. Its response is a material consideration in the planning decision. Vague or inconsistent answers usually draw a request for further information, which delays determination rather than resolving the issue at design stage.
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.