Fire statement content: the matters Article 9A lists
The fire statement is a prescribed form, not a report you structure yourself. Here is what each matter needs at planning stage, and what belongs in the later strategy.
The article 9a fire statement content is prescribed by a form, not by a template you write yourself. Article 9A of the Development Management Procedure Order 2015 requires a fire statement to be submitted on the form published by the Secretary of State for the purpose, and the matters it asks about are fixed. An architect preparing a submission for a relevant building needs to know what those matters are, how much detail each one needs at planning stage, and which of them the drawings have to support.
A relevant building here means one containing two or more dwellings, or educational accommodation, that is 18 metres or more in height or has seven or more storeys. Below that threshold Article 9A does not apply.
Why a prescribed form is used
The form exists to make the submission consistent across 300-odd planning authorities and to give the Health and Safety Executive, as the statutory consultee at Planning Gateway One, a predictable document to review.
That has two consequences for the preparer. The structure is not negotiable, so a well-written narrative report does not satisfy the requirement. And the answers have to be self-contained, with cross-references to specific drawing numbers rather than invitations to look through the submission.
The form also asks who prepared it and on what basis. Fire statements are documents where a competent professional is legally required, so this field matters: the Building Safety Act 2022 framework expects the author to have the necessary fire engineering competence, and a draft prepared by anybody else is a starting point for that professional rather than the finished submission.
Site layout and the space around the building
This is the part of the statement with the most planning content, because it deals with things the layout decides and the Building Regulations assume.
- The position of the building relative to site boundaries and to other buildings
- Separation distances where external fire spread is in issue
- Clear space for fire service operations, including where it coincides with landscaping, parking or podium structures
- Levels and gradients, which govern whether an appliance can actually get where the plan says it can
- Any constraint the site imposes, such as a railway boundary, a watercourse or a retained tree with a root protection area over the access route
Draw the access route on a dedicated plan rather than relying on the general site layout. Reviewers look for the swept path and the turning head, and an access strategy shown only as a dashed line invites a request for more information.
Emergency vehicle access
The questions here are about dimensions and reach. Can a pumping appliance get within the required distance of the dry riser inlet or the building entrances, is the route wide enough and strong enough, and can the appliance leave without reversing a long distance.
Three recurring problems at planning stage:
- An access route designed to a residential road standard that cannot take the axle loading of a fire appliance
- A gated or bollarded route with no agreed arrangement for emergency access
- A podium deck or basement over which the appliance has to stand, with a structural capacity nobody has confirmed
Each of those costs less to solve on a plan than after permission. The third in particular can change the structural frame, which is why the fire input belongs in the design team from the start rather than at submission.
Water supplies for firefighting
The statement has to say where the water for firefighting comes from. In practice that means existing or proposed hydrant locations, the flow available, and whether a new main or a static supply such as a tank is needed.
Get the water undertaker's position early. A hydrant requiring a new connection is a long-lead item, and in some areas flow testing takes weeks to arrange. Where the available flow is marginal, the answer may be a tank and a pump, which has a footprint and a maintenance regime that the layout has to accommodate.
| Matter | Detail expected at planning stage | Detail deferred to the strategy |
|---|---|---|
| Site layout and separation | Dimensioned plan, constraints identified | Facade fire performance calculations |
| Appliance access | Route, widths, turning, loading principle | Final swept path and construction detail |
| Water supplies | Hydrant positions and whether a new supply is needed | Flow rates, riser sizing, pump specification |
| Means of escape | Evacuation principle and stair numbers | Stair widths, lobby smoke control, travel distances |
| Construction method | Material approach and any unusual systems | Full specification and third-party certification |
Means of escape and compartmentation at outline level
The planning stage answer is the principle, not the detail. How many stairs, what the evacuation strategy is, and whether the plan depth and core position are consistent with that strategy.
Single stair against two stair is the decision with the biggest planning consequence, because it changes the core, the plan depth and the achievable unit mix. Say which it is and why, and describe the evacuation approach in a sentence or two. The stair widths, travel distances, lobby arrangements and smoke control belong in the fire safety strategy that follows at Gateway Two.
What the statement should not do is promise a performance it has not analysed. "Compartmentation will comply with Approved Document B" is weaker than a short paragraph saying what the compartmentation strategy is and where the fire engineer's analysis will develop it.
Construction method and materials
At planning stage this means the approach rather than the specification. The structural frame type, the external wall construction in principle, whether any combustible material is proposed in the external wall of a relevant building, and any modern method of construction that affects fire performance.
Volumetric and panelised systems need a word here, because their fire behaviour depends on the system and its cavity barriers rather than on generic assumptions. If the scheme is going to use one, say so now rather than introducing it after permission.
Where an existing building is being retained, the fabric's performance and the structural approach to it are both relevant, and the two are usually assessed together, which structural appraisal of a building proposed for retention deals with. A Structural Survey of the retained fabric is usually the document that informs both.
Outline against detailed applications
An outline application with reserved matters cannot answer every question, and the form has to be completed anyway. The honest approach is to answer at the level the application has reached, state which matters are reserved, and identify where the information will come from.
What catches schemes out is a permission granted on an outline fire statement with conditions requiring compliance with approved drawings, where the later strategy needs a change the drawings do not allow. Build the flexibility into the description of development and the conditions, or expect a section 73 application later.
An illustrative example
A 19 metre, six storey block of 36 flats over a commercial ground floor, on a corner site with a single vehicular access, with the building reaching seven storeys at one end. The example is illustrative.
The threshold matters more than anything else here, because at seven storeys at any point the building is caught by the height condition even if its overall height were below 18 metres. The statement then explains access from the single entrance, hydrant positions confirmed with the undertaker, a single stair with the evacuation principle stated, and the external wall approach. The scheme that stalls is the one where nobody checked the storey count and the application was submitted without the form.
Omissions that delay validation
- The wrong form, or an earlier version of it
- No stated author or no competence information
- Answers referring to the design and access statement instead of answering
- No drawing numbers against the layout and access answers
- Height or storey count stated inconsistently with the drawings
The product pages set out what each document covers: the Fire Statement for Article 9A and the Fire Safety Strategy for the design stage.
This is general guidance, not legal advice. 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?
Those meeting the Article 9A definition of a relevant building: containing two or more dwellings or educational accommodation, and either 18 metres or more in height or seven or more storeys. The storey count catches schemes whose overall height is below 18 metres, so check both limbs against the drawings before deciding the form is not needed.
Can I submit a narrative report instead of the form?
No. Article 9A requires the statement to be on the form published for the purpose, and a narrative report does not satisfy it however thorough. Supporting drawings and appendices can accompany the form, and the answers themselves should be self-contained with cross-references to specific drawing numbers rather than pointing to other documents.
How much detail is expected on means of escape at planning stage?
The principle rather than the specification. State the number of stairs, the evacuation strategy and whether the core position and plan depth are consistent with it. Stair widths, travel distances, lobby smoke control and compartmentation detail belong in the fire safety strategy produced for Gateway Two, not in the planning submission.
What does the form ask about water supplies?
Where firefighting water will come from: existing or proposed hydrant positions, whether the available flow is sufficient, and whether a new main or a static supply such as a tank is required. Approach the water undertaker early, because a new connection or a flow test is a long-lead item and a tank and pump solution needs space in the layout.
What happens with an outline application?
The form still has to be completed, answered at the level the application has reached, with reserved matters identified and the source of the later information stated. The risk to manage is a permission conditioned to approved drawings that the eventual fire strategy needs to change, so build flexibility into the description of development and the conditions.
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.