Fire statement or fire safety strategy: when each applies

The fire statement or fire safety strategy question has a clean answer: the fire statement is a planning document on a prescribed form, and the fire safety strategy is a fire engineering document for Building Regulations. They sit at different gateways, they answer different questions, and one cannot be substituted for the other.

A fire statement is required under article 9A of the Town and Country Planning (Development Management Procedure) (England) Order 2015 for relevant applications, which is how Planning Gateway One works in practice. A fire safety strategy prepared to BS 9991 or BS 9999 is what demonstrates compliance with Part B, and it goes to the building control body or the Building Safety Regulator later.

What each document is for

The fire statement deals with the planning-relevant aspects of fire safety. Site layout and how a fire appliance reaches the building. Water supplies for firefighting. The principles of the evacuation strategy. The construction of external walls in principle. It exists so that fire safety influences the design before the layout is fixed by a permission, and so that the Health and Safety Executive, as statutory consultee, can comment while the layout can still change.

The fire safety strategy is a technical compliance document. Means of escape distances and capacities, compartmentation, structural fire resistance periods, smoke control, sprinkler and detection provision, firefighting shafts and the design fire scenarios behind any performance-based analysis. Where a fire engineering approach departs from the guidance, BS 7974 provides the framework for that analysis.

One shapes the planning permission. The other shapes the building. Both are needed on a tall residential scheme, and each is expected to be prepared by someone with fire engineering competence, so treat any draft of either as a starting point for that person rather than as the finished document.

Which stage of the process each belongs to

The gateway structure introduced under the Building Safety Act 2022 framework puts them in sequence.

Gateway One applies from the planning application. Gateway Two is the building control approval application, which for a higher-risk building goes to the Building Safety Regulator before work starts. Gateway Three is the completion certificate. The fire statement is the only one of the three that a planning consultant normally handles.

Who is competent to prepare each

Both documents call for fire engineering competence, and neither is a form-filling exercise.

The fire statement should be completed by someone competent to give the answers it asks for, which in practice means a fire engineer or a professional with equivalent demonstrable experience of fire safety design. A planning consultant can assemble the drawings and the site information, and should not be signing the technical content.

A fire safety strategy to BS 9991 or BS 9999 is unambiguously a fire engineer's document. Where the design uses a performance-based route rather than following the guidance, the analysis needs someone with modelling experience and the professional standing to defend it. Chartered membership of the relevant institution is the usual marker, and the Building Safety Regulator will look at the competence of the author.

There is honest uncertainty in the market about what "competent" means at the margins, because competence frameworks under the 2022 Act regime have been developing since it was passed. Where the scheme is significant, pick someone whose credentials you can evidence rather than someone who will do it quickly.

Overlap in content and where it diverges

Four topics appear in both documents, and consistency between them is what reviewers check.

1. Fire service access. The statement describes how appliances reach the building and where they park. The strategy specifies the access road loading, turning provision and the distance from the appliance to the dry or wet riser inlet.
2. Water supplies for firefighting. The statement establishes that adequate supplies exist or can be provided. The strategy specifies hydrant locations, flow rates and riser arrangements.
3. Evacuation strategy. The statement sets out the principle, for example stay put or simultaneous evacuation. The strategy sets out the alarm system, the stair capacity and the evacuation of people who cannot use stairs.
4. External wall construction. The statement addresses the approach in principle. The strategy addresses reaction to fire classifications and the detail of cavity barriers.

The divergence is everything else. Internal compartmentation, escape travel distances, smoke ventilation design and structural fire resistance periods do not belong in a fire statement, and site access constraints, neighbouring land and the relationship to the highway do not belong in a strategy.

Write the statement so the strategy can be built on it. A statement that commits to an appliance route across land you do not control creates a problem that only a new planning application can solve.

Consequences of submitting the wrong one

Getting this wrong costs weeks rather than money, which on a funded scheme amounts to the same thing.

Submit a BS 9991 strategy in place of the fire statement and the application is liable to fail validation, because article 9A requires the prescribed form. Councils vary in how strictly they apply it, and relying on a lenient validation team is a poor plan.

Submit a fire statement to building control and it demonstrates nothing about Part B compliance, because it was never designed to. The building control body will ask for the strategy.

Omit the fire statement where the development is within scope and you lose the Health and Safety Executive consultation, which the local planning authority has to carry out before determining the application. A permission granted without it is vulnerable.

The scope trigger is worth checking rather than assuming. Article 9A is keyed to relevant buildings of 18 m or more in height, or seven or more storeys, containing two or more dwellings or educational accommodation. Measure the height on the same basis the legislation uses, and check the storey count including any basement treatment, before concluding you are outside it. Airspace and rooftop schemes cross the threshold more often than people expect, which our note on airspace development above flats covers.

Sequencing across the gateways

Run the fire engineer's appointment ahead of the planning submission, not after it. The sequence that works looks like this:

1. Appoint the fire engineer at concept design, before the site layout is fixed.
2. Agree the evacuation strategy in principle, because it drives core numbers and stair widths.
3. Test appliance access and water supply against the site constraints, and adjust the layout while that is still free.
4. Prepare the Fire Statement from that work and submit it with the application.
5. Respond to the Health and Safety Executive comments, amending the layout where needed rather than deferring the issue to building control.
6. Develop the Fire Safety Strategy for the Gateway Two application, consistent with the permitted layout.
7. Track changes between the two, and check whether any of them need a section 73 variation.

Step seven catches people. A change to the appliance route, the stair core position or the number of storeys after permission is a planning change as well as a technical one.

Managing both on one project

One fire engineer, appointed once, carrying the argument across both regimes. Splitting the planning statement and the Building Regulations strategy between two consultants produces documents that disagree, and the Building Safety Regulator reads both.

Keep a single register of fire safety commitments made in the planning submission, with the drawing reference and the condition or obligation that secures each one. When the strategy develops and something has to change, you can see immediately whether the change touches a planning commitment. Structural capacity evidence follows the same discipline on upward extensions, as our note on roof extensions and structural capacity sets out.

This is general guidance rather than legal advice. A licensed or competent fire engineering professional is legally required for both documents on relevant buildings, so check the scope and the requirements with your local planning authority and your fire engineer before relying on any of this.

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