Fire Statement content, section by section

A Fire Statement is not a fire strategy. It is a planning document, submitted on the form published by the Secretary of State under Article 9A of the Development Management Procedure Order 2015, that explains the fire safety thinking behind a scheme at the point when the layout, the massing and the access arrangements are being fixed. The Health and Safety Executive, acting as the Building Safety Regulator, is consulted on it, and that consultation is Planning Gateway One.

The question the form keeps asking, in different words, is this: what has been decided about fire safety that the planning permission would lock in? Answer that and the document writes itself. Answer with a building regulations compliance narrative and the Regulator will ask for more.

The principles the statement works to

Start by naming the framework. A reader needs to know whether the design follows Approved Document B, a British Standard such as BS 9991 for residential buildings or BS 9999 for other building types, or a fire engineered approach under BS 7974, and whether a combination is proposed.

Then state the design decisions that follow from it and that planning cannot easily change later:

• the number and arrangement of staircases serving each building, and whether any part relies on a single stair
• the evacuation strategy in principle, whether stay put, simultaneous, or phased
• the compartmentation concept at the level of blocks and cores rather than individual walls
• whether sprinklers or other suppression are proposed, and where
• whether any element of the design departs from the guidance and relies on an engineered justification

Be explicit about what is settled and what is not. A statement that says the stair arrangement is fixed and the internal compartmentation will be developed at the next stage is more useful than one that implies everything is resolved.

The second staircase question deserves its own paragraph. Expectations for tall residential buildings have moved, and the current position in Approved Document B and its transitional arrangements should be checked at the date of submission rather than assumed from a previous project. Where a second stair is proposed, say how it affects the core area and the unit mix, because that is a planning consequence.

Site layout and access information

This is the part of the Fire Statement that properly belongs in planning, because site layout is what the permission controls.

Describe and draw the route a fire appliance takes from the public highway to each building, the hardstanding positions, the distance from each hardstanding to the relevant entrance and to the dry or wet riser inlet, and the turning provision. Say what the carriageway construction will be and what load it is designed to carry. Where the route passes over a podium, a basement slab or a service trench, say so.

Then deal with the things that get in the way. Gates and rising bollards need an access arrangement and a statement of who holds the means of opening them. Tree pits, planters, cycle stands, bin presentation points and visitor parking all end up in the same strip of ground as the appliance hardstanding, so the fire access drawing and the landscape drawing need to be overlaid before submission rather than after. Where a building sits close to the height threshold, the access case is read alongside the question of whether the statement was needed at all, which is the subject of fire evidence for a building just below the threshold.

Where the development forms part of a larger site, explain how the fire safety arrangements work across the whole, including shared access routes and phasing. A phase that relies on an access road built in a later phase needs a condition and a temporary arrangement, and saying so in the statement avoids a late objection.

Water supply information

Water supply is the section most often left thin, usually because the information sits with the water undertaker and nobody asked for it early enough.

What to include:

1. The existing hydrant positions within a stated distance of the buildings, taken from the water undertaker's or fire and rescue service's records rather than from a site visit.
2. The proposed hydrant positions, where new ones are needed, shown on the layout.
3. The available flow and pressure at the connection point, evidenced by a written response from the undertaker.
4. Whether a water tank and pump arrangement is proposed, and where it sits, because a tank room takes floor area and an external tank takes site area.
5. For buildings with risers, the inlet positions and their relationship to the appliance hardstanding.

If the flow and pressure response has not arrived by submission, say that it has been requested, give the date, and state the assumption you are working to. That is far better received than silence, and it gives the officer something to condition.

Means of escape in outline

Outline is the operative word. The Fire Statement should explain the escape strategy at the level of the building, not specify door closers.

Cover the escape route arrangement from each part of the building, the stair widths and whether they are protected, the refuge provision and where refuges sit, and whether an evacuation lift is proposed and within which core. Then address evacuation for people who cannot use stairs unaided, because that is now expected and because the spatial implications are fixed by the planning permission. A refuge that cannot hold two wheelchairs, or a core with no room for an evacuation lift, is a planning problem dressed as a building control one.

Basement and lower ground accommodation needs its own treatment. Escape from below ground level is more constrained, travel distances are shorter and the policy position on habitable rooms there is contested, as safe egress from habitable basement rooms sets out.

Say what external escape routes depend on. A final exit discharging into a courtyard that is gated, or onto a roof terrace, needs to be described because the landscape proposals could otherwise close it.

Construction products and external walls

External wall construction is the subject the Regulator reads most carefully, and the one where a vague answer attracts the most follow up.

Describe the external wall build up for each facade type by reference to a drawing number, and state the reaction to fire classification of the materials proposed. For a relevant building, Regulation 7(2) of the Building Regulations 2010 restricts the materials that may be used in external walls and specified attachments, and the statement should confirm the approach taken to that restriction rather than leaving it to be inferred.

Cover the elements that sit in front of or through the wall: balconies and their decking, solar shading, rainscreen cavities and cavity barriers, insulation type, window and door framing, spandrel panels, and any green wall or planting system. Balconies and roof terraces are a recurring source of comment because the construction and the surface finish are often unresolved at planning stage.

Where a material is still to be selected, give a performance specification rather than a product name, and accept a condition requiring the final specification to be submitted. A performance specification that cannot be met by any available product is worse than no specification, so check it with the facade consultant before it goes in.

The detailed design of all of this belongs in a Fire Safety Strategy prepared to the relevant standard. The Fire Statement's job is to confirm that the planning proposal does not foreclose a compliant solution.

Where detail is deferred to Gateway Two

The gateway structure under the Building Safety Act 2022 framework means the Fire Statement does not have to answer everything, and pretending otherwise produces a document that is both long and unconvincing.

Gateway One is about planning: layout, access, water supply, the escape concept and the external wall approach. Gateway Two is the building control approval stage before construction, where the full fire strategy, detailed compartmentation, product specifications and testing evidence are examined. Gateway Three comes at completion.

So the useful structure for the deferral is a short schedule at the end of the statement listing, for each topic, what is fixed now, what is deferred, and to which stage. That schedule does three things: it tells the Regulator the author understands the process, it gives the planning officer a basis for conditions, and it protects the applicant from being asked at planning stage for information that cannot exist yet.

One final practical point. The Fire Statement must be on the prescribed form and must accompany the application. Submitting the narrative as a standalone report without the form is a validation failure, and the determination period does not begin until it is right.

Enter your postcode on PlanScope to see which reports a relevant building at your site is likely to need.

PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval. A Fire Statement must be prepared by someone with the necessary fire engineering competence under the Building Safety Act 2022 framework and Article 9A of the Development Management Procedure Order 2015, so an AI-assisted draft is a starting point for that professional rather than a substitute. This article is general guidance rather than legal advice.