Fire statement and design and access statement together

On a residential building of 18 metres or more, or seven or more storeys, you will be submitting both a Fire Statement under Article 9A of the Development Management Procedure Order 2015 and a Design and Access Statement under Article 9. They are written by different people, usually at different times, and they describe the same staircases, the same courtyard and the same front door. When they disagree, the Building Safety Regulator notices, and Planning Gateway One stalls.

Coordinating them is not difficult. It mostly means agreeing one set of drawings, one set of terms and one person who reads both documents before submission.

Where the two documents overlap

The Fire Statement deals with fire safety matters specific to the development as a planning consideration: the principles adopted, site layout and access for the fire and rescue service, water supplies, means of escape in outline, the external wall construction and the storage and management arrangements that affect fire risk. It is submitted on the published form for relevant buildings and triggers consultation with the Health and Safety Executive as the Building Safety Regulator.

The Design and Access Statement explains the design principles and concepts behind amount, layout, scale, landscaping and appearance, and then explains access: how access policy has been applied, what consultation took place, how inclusive design has been addressed, and how people will reach and move through the development.

Four subjects sit in both documents.

• Site access and the route a vehicle takes from the public highway to the building
• Entrances, cores and vertical circulation, including the number and position of staircases and lifts
• Inclusive access and, by extension, how disabled occupants leave the building in an emergency
• External materials and the facade build-up, described for design reasons in one document and for fire performance in the other

Those four are where contradictions live.

Inclusive access and inclusive evacuation

Most design and access statements describe step free access, lift provision, accessible parking and compliance with Approved Document M and BS 8300. Very few say anything about how a wheelchair user gets out during a fire.

That silence used to be acceptable. It is not now. Evacuation strategy for disabled residents has become a live planning and building safety question, covering refuge areas, evacuation lifts, the design of the protected stair enclosure and the space needed at each storey for someone waiting for assistance. The planning stage decisions that matter are spatial: how wide the stair is, whether there is room for an evacuation lift inside the core, and whether the refuge can hold more than one wheelchair.

Write the inclusive access section of the design and access statement and the means of escape section of the fire statement as a pair. If the design and access statement claims lifetime homes style accessibility across 60 flats while the fire statement has one refuge per floor at 1,100mm by 1,400mm, somebody has not done the arithmetic.

The detailed evacuation strategy is a building control matter and belongs in a Fire Safety Strategy prepared to BS 9991. At planning stage you are proving that the strategy is possible within the envelope you are asking permission for.

Site access described consistently in both

Fire and rescue service access is the most common inconsistency, because landscape drawings and fire access drawings are usually produced by different consultants from different base plans.

Check these against each other before submission:

1. The carriageway width and construction of the access route, and whether the landscape drawing shows the same surface treatment over the same area.
2. The position and dimensions of appliance hardstanding, measured against the building face, and whether tree pits, bin stores or cycle hoops have been drawn in the same place.
3. The distance from the hardstanding to the dry riser inlet and to the main entrance.
4. Gates, bollards and barriers, including who holds the key and whether the landscape drawing shows a gate the fire statement assumes is absent.
5. Hydrant positions and the water main capacity, against the utilities drawing.
6. Vehicle tracking, which should use the same design vehicle in both the transport and the fire submissions.

Where parking and landscape proposals conflict with appliance access, the planning answer is usually a condition requiring the access route to be kept clear and a management plan, not a redesign. The condition still has to be deliverable, so say in both documents how it will be enforced on site.

Avoiding contradictions between documents

The practical risk is not that either document is wrong. It is that they use different words for the same thing, and a consultee reading both concludes the design is unresolved.

A short cross reference table at the front of each document, naming the drawing numbers both rely on, costs an hour and prevents most of this.

Who authors which section

The fire statement needs someone with fire engineering competence. The legislation and the Building Safety Act 2022 framework both assume the content is prepared by a person able to stand behind it, and the Building Safety Regulator's comments go to the planning authority. A drafting tool, including an AI-assisted draft, is a starting point for that person rather than a substitute for them.

A workable division of labour on a typical scheme:

• Fire engineer: principles, means of escape in outline, internal fire safety, external wall construction, water supply strategy
• Architect: site layout, core design, entrances, refuge locations, facade specification narrative
• Transport consultant or civil engineer: access route geometry, tracking, hardstanding construction
• Landscape architect: confirming nothing in the soft or hard landscape obstructs the access route or hardstanding
• Planning consultant or agent: the design and access statement, the policy narrative and the coordination check

The coordination role is the one most often left vacant. Give it to a named person.

Review before submission

Read both documents end to end in one sitting, with the drawings open. The errors show up quickly: a stair that is drawn in two positions, a hardstanding that falls inside a tree root protection area, an entrance described as level in one document and with a 150mm upstand in another.

Then check the submission mechanics. The fire statement goes on the prescribed form, applies to relevant buildings as defined in Article 9A, and must accompany the application rather than follow it. A missing or incomplete form is a validation failure, and the eight or thirteen week clock does not start. Buildings close to the threshold need the height and storey count evidenced rather than asserted, which is the whole of the problem with fire evidence for a building just below the threshold.

Conditions that reference both

Expect conditions that reach into both documents. Facade materials conditions require samples and construction details, and they interact with the fire statement's external wall narrative. Access conditions require the appliance route to be constructed before first occupation and kept available. Landscape conditions require planting that must not grow into the access route.

Where the scheme includes basement accommodation the two documents need to agree on escape routes from below ground level, and the policy position on habitable rooms there is its own argument, covered in safe egress from habitable basement rooms.

Draft the conditions you expect and check that both documents support them. If a condition cannot be complied with as drawn, say so at submission and propose the alternative, because discovering it at discharge stage costs a redesign and a section 73 application.

Enter your postcode on PlanScope to see which reports a relevant building at or above the 18 metre threshold 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, and for specialist technical reports, qualified professional input may be required. This article is general guidance rather than legal advice.