Fire statement content: the plans and the narrative

A fire statement at Planning Gateway One has to answer the fire safety questions that planning can actually determine: site layout, access for fire appliances, water supplies for firefighting, the escape strategy in principle, and the construction phase. Fire statement content is set by the published form, which is a prescribed form rather than a free narrative, and the Health and Safety Executive reads it as the statutory consultee. Everything that belongs to detailed design, from cavity barriers to sprinkler head spacing, belongs at the later gateways.

The threshold catches relevant buildings: those containing two or more dwellings, or educational accommodation, with seven or more storeys or a height of 18 metres or more. Article 9A of the Development Management Procedure Order 2015 is the provision that requires the statement, in force since 1 August 2021.

What the statement must address at planning stage

The form asks for the principles, concepts and approach to fire safety, and then works through a defined set of headings. The ones that carry the most weight at planning stage are:

• Site layout and the relationship of the building to its boundaries and to neighbouring structures.
• Emergency vehicle access, including the route from the public highway, hardstanding positions and turning provision.
• Water supplies for firefighting, covering hydrant positions and available flow.
• Means of escape for all occupants, including disabled occupants, and the evacuation strategy adopted.
• Passive and active measures in outline, and the approach to limiting external and internal fire spread.
• Facilities provided for the fire and rescue service.
• Fire safety during construction.
• Arrangements for ongoing maintenance and monitoring of the measures described.

Answer each heading in terms the planning decision can act on. Where the answer is a dimension, give the dimension. Where it is a strategy, name the strategy. A statement that says access will comply with the relevant standard tells the consultee nothing it can check.

Plans and drawings that accompany it

The statement is only as good as the drawings behind it. Submit, as a minimum:

1. A site plan showing appliance access routes from the adopted highway, with widths, gradients and turning circles dimensioned and the swept path of the relevant appliance drawn.
2. Hardstanding positions marked against the building, with the distance from the standing position to the furthest point of the building and to the dry or wet riser inlet.
3. Hydrant positions, existing and proposed, with distances from the building entrances.
4. Typical floor plans showing stair cores, lobbies, the firefighting shaft and the location of lifts, with escape routes indicated.
5. A section through the building giving the height to the finished floor level of the top storey, measured from the ground level, so the threshold calculation can be checked.
6. A roof plan where there is plant, a terrace or any occupied level above the top storey.

That last point catches people. Height for the purposes of the threshold is measured to the floor surface of the top storey, and rooftop plant is normally excluded, so a building that looks over 18 metres may not be a relevant building and one that looks under it may be. Draw the dimension and state the datum.

Access and water supply narrative

The access narrative needs to be written from the appliance outwards, not from the building. Start with the route a pump takes off the highway, identify any gate, barrier, bollard or crossover on that route, and say who holds the key or the override. Then state the standing position and how far it is from the riser inlet.

Water supply is the item most often thin. Hydrant provision is a matter for the fire and rescue service and the water undertaker, so the honest position at planning stage is often that existing hydrants have been located, available flow has been requested from the undertaker, and additional hydrants will be provided where the flow is inadequate. Say that, name the undertaker, and give the date of the enquiry.

Where the site has a private access road or a shared courtyard, the long-term legal arrangement for keeping that route clear matters as much as its geometry. An access route that becomes a parking area within two years of occupation is a real failure mode.

Building design and the evacuation strategy

Name the evacuation strategy and justify it. For most residential buildings at this height the strategy is stay put, supported by compartmentation, a single or multiple stair arrangement and a firefighting shaft. Where simultaneous or phased evacuation is proposed instead, the consequences for stair capacity, alarm provision and management need to be set out, because they affect the planning form of the building.

Two matters sit squarely in planning rather than in building control. The first is the number and position of stair cores, because that is a plan decision that cannot be unwound at Gateway Two. The second is external wall build-up in principle, because material and finish are matters the planning authority determines on appearance as well as safety.

Structural fire protection and loading interact with the frame, so where the scheme adds storeys to an existing building the structural evidence and the fire strategy have to be written together. The Structural Survey and the fire documents should not reach different conclusions about the frame.

Matters properly left to later gateways

Gateway Two sits before construction and is where the detailed design is assessed by the Building Safety Regulator. Gateway Three sits at completion. A planning stage statement that attempts the detailed design invites comments it cannot resolve and creates a document the applicant will have to contradict later.

So leave out cavity barrier details, specific product selections, sprinkler and detection design, fire door specifications and compartmentation drawings. Reference them as matters for the later gateways and move on. A short paragraph saying which items are reserved and to which gateway is a sign of a competent statement rather than an omission.

The deeper strategy document, a Fire Safety Strategy written to the relevant British Standard, is the vehicle for that detail, and it is a fire engineering document in its own right.

Author competence and the declaration

The form asks who prepared the statement and what their competence is. Give the name, the organisation, the professional membership and a short statement of relevant experience with buildings of this type. Fire engineering competence is a legal requirement here rather than a preference: the statement supports a decision under the Building Safety Act 2022 framework, and a licensed or competent professional is legally required for this document. An AI-assisted draft is a starting point for that professional, never a substitute.

Where a building sits just under the threshold, the temptation is to submit nothing. The reasoning for and against that is set out in the note on fire evidence for a building just below the threshold.

How the regulator responds

HSE as the Gateway One consultee reviews the statement and returns comments to the planning authority within the consultation period. The comments are advice to the authority rather than an approval, and they commonly ask for specific items: a dimensioned access plan, confirmation of hydrant flow, or clarity on the evacuation strategy.

Answering those requests well is largely a matter of having drawn the information in the first place. Where escape from below ground accommodation is involved, the reasoning in the note on safe egress from habitable basement rooms applies in the same way.

Draft the supporting documents for a relevant building on PlanScope, then send the fire statement to a competent fire engineer for review and sign-off before submission.

This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it. 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.