Fire Statement or fire safety strategy at planning stage

A fire statement is a planning document required by Article 9A of the Town and Country Planning (Development Management Procedure) (England) Order 2015 for applications involving relevant buildings, and without it the application is invalid. A fire safety strategy is a fire engineering document prepared against BS 9991 or BS 9999 to demonstrate compliance with the Building Regulations. Comparing fire statement vs fire safety strategy is comparing a validation requirement with a design document, and schemes that treat them as interchangeable lose time at both ends.

What Planning Gateway One requires

Planning Gateway One brought fire safety into the planning decision for higher-risk residential buildings. It works through two mechanisms.

The first is the fire statement itself, submitted on the prescribed form with the application. It sets out the principles of the fire safety design as they affect the planning matters within the authority's control, such as site layout, access for fire appliances, water supplies for firefighting, and the position and form of the building.

The second is consultation. The Health and Safety Executive, acting as the Building Safety Regulator, is a statutory consultee on applications for relevant buildings and responds to the authority on the fire safety aspects of the scheme.

Both are planning processes. Neither of them discharges anything under the Building Regulations.

Which buildings are caught

The trigger is the definition of a relevant building. In broad terms it covers buildings containing two or more dwellings, or educational accommodation, that meet the height threshold of 18 metres or more, or seven or more storeys.

Height measurement matters and it is measured in a prescribed way rather than from any convenient datum. A scheme sitting close to the threshold should confirm the measurement early, because crossing it changes the validation requirements, the consultee list and the later regulatory route.

The higher-risk building threshold and its planning consequences sets out where that line falls and why schemes at six or seven storeys need to resolve it before submission.

Buildings below the threshold do not need a fire statement. They still need to satisfy the Building Regulations, and many authorities will still ask design questions about appliance access and hydrant provision through the transport and layout documents.

Mixed schemes need care. A podium block of flats reaching the threshold alongside lower terraces on the same application brings the whole application within the requirement, because the test is whether the development involves the provision of a relevant building. Splitting an application to avoid that is not a sound plan, and officers see it for what it is.

What a fire safety strategy adds

A fire safety strategy is a different animal. It is the document that describes how the building achieves the functional requirements of Part B of the Building Regulations, covering means of warning and escape, internal and external fire spread, and access and facilities for the fire service.

It is written against BS 9991 for residential buildings or BS 9999 for other building types, or by a fire engineering approach under BS 7974 where a departure from the standard guidance is proposed.

The strategy usually contains everything in the statement and a great deal more. That is why some teams write the strategy first and extract the statement from it, which works well provided the statement stays within the planning matters it is supposed to address.

Competence for each document

The Article 9A requirement is that the fire statement is prepared by a competent person, and in practice that means someone with fire engineering competence appropriate to the building. It is not a document for the architect to assemble from the standard details.

A fire safety strategy is unambiguously a fire engineering document and requires a fire engineer. Both are report types where a qualified professional is legally or practically required, and a PlanScope draft is a starting point for that professional rather than a substitute for their judgement.

Ask for the individual's qualifications and experience of buildings of this type and height, not just the practice's. The Building Safety Regulator's response will engage with the substance, and a thin statement produces a request for further information that stops the clock.

Validation consequences of getting it wrong

The fire statement is a validation requirement. An application for a relevant building submitted without one will not be validated, and the eight or thirteen week clock does not start.

Worse, a statement submitted in the wrong form, or one that describes the building generically without engaging with the site, will usually survive validation and then generate a holding objection from the Regulator. That is the expensive failure, because it arrives weeks in and sits on the file until answered.

Three things cause it most often. A statement written before the massing is fixed, so appliance access cannot be demonstrated. No engagement with water supplies and hydrant provision. And nothing on how the external wall construction approach relates to the height and use.

The detail of what the statement has to contain is covered in fire statements at Planning Gateway One.

Sequencing against the design programme

1. Establish the height and storey count against the relevant building definition at feasibility stage, using the prescribed measurement method.
2. Appoint the fire engineer before the planning drawings are frozen, so appliance access and hydrant positions inform the layout rather than following it.
3. Prepare the Fire Statement from the emerging design and submit it with the application on the prescribed form.
4. Develop the Fire Safety Strategy through technical design for the later gateways.
5. Keep the two aligned, because a strategy that departs from the statement raises an obvious question.

Point two is the one that saves money. Fire appliance access, hardstanding positions and hydrant provision are site layout decisions, and retrofitting them to a consented scheme is far harder than designing them in.

There is a coordination point worth stating plainly. The fire engineer, the transport consultant and the landscape architect are all designing the same piece of ground. Appliance hardstanding, refuse vehicle tracking and a courtyard planting scheme compete for the same square metres, and the fire requirement is the one that cannot give way.

And expect the programme to be longer than a conventional major application. The consultation, the responses and the coordination between the fire engineer and the design team all take time that a 13 week determination period does not obviously allow for.

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.