The escape strategy section of a Fire Statement

The escape strategy section of a Fire Statement is not a means of escape calculation. At Planning Gateway One the question is narrower and more architectural: does the site layout, the massing and the position of the cores allow a workable evacuation strategy to exist at all, and has the applicant thought about it before the building form is fixed. Travel distances, door widths and smoke ventilation sizing belong to the building control process that follows.

Article 9A of the Town and Country Planning (Development Management Procedure) (England) Order 2015 is what makes the statement a validation requirement, and the Health and Safety Executive, acting as the Building Safety Regulator, is the statutory consultee. The statement has to be submitted on the form published by the Secretary of State, which constrains how you write it.

What Gateway One asks the planning system to decide

Gateway One exists because some fire safety decisions cannot be undone once planning permission has fixed the geometry. Where the building sits on the plot, how far it stands from its neighbours, whether a fire appliance can reach three sides of it, where the water comes from, how many cores the plan will support: all of that is settled by the planning layout.

So the statement covers the principles, concepts and approach to fire safety applied to each building in the development, the site layout, emergency vehicle access and water supplies, what consultation has been carried out on fire safety, and how any local development plan policy on fire safety has been taken into account.

Read that list carefully and you will see what it excludes. Compartmentation detail, internal linings, alarm categories and sprinkler design are outside it. Submitting them anyway does not help, and it invites questions the planning system cannot answer. Our note on when an application needs an Article 9A fire statement covers the trigger in detail.

Relevant buildings and the height condition

The requirement bites on a relevant building, meaning one containing two or more dwellings or educational accommodation, where the building meets the height condition of 18 m or more in height, or seven or more storeys.

Three practical points follow.

Height is measured to the specified datum in the legislation rather than to the top of the parapet or the top of the plant enclosure, so a building that looks marginal on a section drawing needs the measurement checked against the defined method before you decide you are outside the regime.

Storey counting includes the ground storey and excludes specified plant levels, so a seven-storey building at 17 m is caught by the storey limb even though it fails the height limb. The two tests are alternatives.

And the definition of relevant building for Gateway One is not identical to the higher-risk building definition used later in the Building Safety Act 2022 regime for Gateways Two and Three. Our note on the higher-risk building threshold and what it changes at planning sets out where the two diverge.

Describing the escape strategy at planning stage

What the regulator wants in this section is a clear statement of the evacuation approach and evidence that the layout supports it. Four or five pages, with drawings, does it.

Start with the strategy itself. Say whether the building is designed for a stay-put approach with compartmentation and a single stair, for simultaneous evacuation, or for phased or progressive horizontal evacuation, and say why that choice suits the building type and occupancy. For residential accommodation with vulnerable occupants, or for student accommodation with a managed evacuation, the reasoning differs.

Then show how the plan delivers it:

• the number and position of escape stairs on a typical floor plate, marked on a plan rather than described in prose
• the arrangement between flat entrance doors and the stair, and whether the corridor is a common corridor, a lobby approach or a deck access
• the provision for accessible means of escape, including refuges and any evacuation lift, since lift positions are a layout decision
• the final exit positions at ground level and where they discharge to
• the assembly area, and whether it can be reached without crossing the fire service access route
• external escape routes, including any that pass across podium decks or courtyards

Include the personal emergency evacuation principle where the occupancy warrants it, and where smoke control in common areas is the determinant of the corridor layout, say so. That interaction is one to settle with the fire engineer before the corridor plan is frozen.

Stair cores, second staircases and the site plan

The number of staircases is the single biggest planning-stage fire decision, because it changes the floor plate, the core position and often the viability of the massing.

Approved Document B was amended in 2024 to introduce an expectation of a second staircase in new residential buildings above 18 m, with transitional arrangements attached. Those arrangements have dates, and the position you rely on has to be the one in force at the time of your application, so check the current version and the transitional provisions on gov.uk before you commit a single-core layout. Treat any summary, including this one, as a prompt to verify rather than as the answer.

Where a second stair is provided, the statement should show that the two stairs are independent of each other: separated on plan, served by separate lobbies, discharging separately at ground level, and not sharing a single route across the site to the street.

Where a single stair is proposed for a building below the threshold, say so explicitly and set out the compensating features. A regulator reading an ambiguous plan will ask.

Fire service access and water supplies

This is the part that most often produces a comment from the fire and rescue authority, and it is entirely a layout matter.

Show the fire appliance access route on the site plan, with the carriageway width, the turning provision, the gradient and the pump appliance standing position relative to the building entrances and the dry or wet riser inlets. The dimensional requirements sit in Approved Document B, and the threshold at which a wet rising main replaces a dry one is a height question covered in our note on dry risers, wet risers and the height that separates them.

Then deal with water. Identify the existing hydrant positions, state whether new hydrants are proposed and where, and say whether the water undertaker has confirmed that the available flow meets the fire and rescue authority's requirement. Where that confirmation is still outstanding, say so and give the date of the enquiry rather than leaving a silence.

Two layout traps recur. Gated or bollarded access routes that are shown on the landscape drawing but not reconciled with the fire access strategy. And podium schemes where the appliance can reach the podium edge but not the building entrances above or below it.

What the Building Safety Regulator looks for

The regulator's advice to the local planning authority is about whether fire safety has been addressed in relation to matters the planning system controls. The comments that recur are practical.

Whether the drawings and the narrative agree. A statement describing two stairs and a floor plan showing one is the most common failure.

Whether the site layout has been tested against the access requirement rather than asserted to comply. Show the swept path or the appliance standing position on a drawing.

Whether external escape and fire service access have been considered together with the landscape design, the levels and the boundary treatments, all of which are usually drawn by different people.

Whether the applicant has consulted the fire and rescue authority, and what that authority said. The form asks about consultation, and a blank there reads badly.

Whether the local plan carries a fire safety policy, which several authorities now have, and whether the statement addresses it by policy number.

Competence of the author

A Fire Statement has to be prepared by someone with the necessary fire engineering competence. This is one of the report types where professional input is legally expected rather than merely advisable, under the Building Safety Act 2022 framework and article 9A. An architect can assemble the layout information and the drawings, but the strategy and the judgement behind it should come from a fire engineer, and the form asks who prepared the statement.

The statement is also distinct from a fire safety strategy prepared to BS 9991 or BS 9999, which comes later and goes much further. Do not submit one in place of the other.

PlanScope can draft the planning-stage structure and the policy framing of a Fire Statement, with missing site facts flagged rather than invented, as a starting point for the fire engineer who will complete and sign it. For specialist technical reports, qualified professional input may be required. To see what else a scheme at this height is likely to need, enter your postcode on PlanScope.

PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.