Fire safety statements under London Plan Policy D12

Policy D12 of the London Plan requires every development proposal in London to achieve the highest standards of fire safety, and requires major development proposals to submit a fire statement prepared by a suitably qualified third party. Planning Gateway One is a separate requirement under Article 9A of the Development Management Procedure Order 2015, which applies only to relevant buildings at 18m or more in height, or seven or more storeys, containing two or more dwellings or educational accommodation.

So a London scheme of 50 houses needs a D12 fire statement and no Gateway One statement. A 20-storey residential tower needs both. Knowing which route you are on, before the fee is agreed, saves a validation refusal.

What Policy D12 asks for, and from whom

D12 operates in two parts. The first applies to all development and sets out the matters a proposal has to address in its design. The second requires major development proposals to submit a fire statement, which is a document rather than a form, produced by someone suitably qualified and independent of the design team.

Major development in London follows the usual definition, so ten or more dwellings, or 1,000 m2 or more of floorspace, or a site of 0.5 hectares or more, brings D12 part B into play. That sweeps in a great deal of development that has nothing to do with tall buildings: a terrace of twelve houses, a primary school extension, a small office refurbishment above the floorspace threshold.

Verify the current wording in the adopted London Plan and in the Mayor's fire safety guidance before scoping the work, because the policy was the subject of intervention during the plan's adoption and the guidance has been issued and revised since. The structure described here is stable. The precise drafting should be read in the original.

Boroughs apply D12 through their validation lists, and the common failure is a submission that treats the fire statement as a paragraph in the design and access statement. It is a standalone document with a named author.

How D12 sits alongside Planning Gateway One

Article 9A was introduced in August 2021 as the planning limb of the Building Safety Act framework. Where an application involves a relevant building, it must be accompanied by a fire statement on the form published by the Secretary of State, and the Building Safety Regulator within the Health and Safety Executive is a statutory consultee on it.

The differences that matter:

A scheme that triggers both does not get to choose one. The form has to be submitted because the Order requires it, and the D12 report has to be submitted because the development plan requires it. What you can do is make the second draw on the first so that the content is consistent, which is the point of the final section below.

The matters a London fire statement covers

The policy lists the ground to be covered, and a statement that skips any of it invites a holding objection.

Construction method and the materials and products used, with the external wall construction described rather than left to a later package. Means of escape for all building users, including disabled occupants, with an evacuation strategy that is clearly understood and capable of being operated. Passive and active fire safety measures and how they have been coordinated. Access and facilities for the fire and rescue service, including appliance standing positions and firefighting shafts. Water supplies for firefighting, which on a London site usually means a hydrant position and a flow confirmation from the undertaker. And how the building will allow future modification without compromising the strategy.

Two of those are routinely thin. Evacuation strategy for disabled occupants needs an actual strategy, naming the refuge positions, the evacuation lift arrangements and the management responsibilities, not a sentence saying a personal emergency plan will be provided. And future modification is a genuine design question about riser capacity, compartment line continuity and whether a later change of use would break the strategy.

The spatial consequences of the strategy land on the planning drawings, which is why the plant and riser space for suppression and smoke control belongs in the accommodation schedule from the start.

Evacuation lifts, refuges and the second staircase

Three requirements have changed the shape of London residential cores in recent years, and all three affect the planning layout rather than only the technical design.

Evacuation lifts. London Plan policy on inclusive design expects buildings of 18m or more to provide at least one lift per core capable of use as a fire evacuation lift. That changes the lift specification, the shaft construction, the lobby arrangement and the power supply, and it has a footprint consequence in the core.

Refuges and evacuation management. A refuge needs to be a real space at each level, within the protected lobby or stair enclosure, sized for a wheelchair without obstructing the escape route, with two-way communication. Drawing it is the only way to show it exists.

Staircase provision. Government confirmed a requirement for a second staircase in new residential buildings above 18m, with Approved Document B amended and transitional arrangements attached. Check the current edition and the transitional position for your scheme, because the date a scheme was designed and the date it is submitted both matter. A second stair takes area from every floor, which is why it belongs in the capacity work from the beginning rather than being discovered later, a point that connects directly to the design-led approach discussed in optimising site capacity and the design-led approach.

Who is competent to author it

Both routes expect a competent author and neither will accept a generalist.

The Gateway One form asks for the author's details, and the regulator's interest is in fire engineering competence demonstrated by qualification and relevant experience. D12 asks for a third party suitably qualified assessor, which in practice means a chartered or incorporated fire engineer or an equivalent professional independent of the architect.

A fire statement is one of the report types where a competent professional is legally required rather than recommended, because of the Article 9A requirement and the Building Safety Act framework behind it. The same applies to a fire safety strategy, which is a fire-engineering document under the relevant British Standards. An AI-assisted draft can assemble the policy framework, structure the document against the required headings and flag the facts that are missing, and the engineering judgement and the authorship have to come from the qualified professional.

Appoint that person early. A fire engineer brought in at the end will tell you about the second stair, the riser space and the appliance access after the layout is fixed.

Referable schemes and the Mayor's scrutiny

Applications referable to the Mayor go through a stage one report before the borough determines them and a stage two decision afterwards, and fire safety is a matter the Greater London Authority comments on routinely.

What tends to attract a stage one comment: an evacuation strategy that relies on simultaneous evacuation without the alarm and management arrangements to support it, no evacuation lift where the policy expects one, an external wall specification left to condition, firefighting access that depends on a road the applicant does not control, and no water supply confirmation.

Answer those in the statement rather than waiting to be asked. A stage one report that raises fire safety concerns delays the borough's determination and gives objectors a quotable paragraph.

Where the scheme includes a basement, the fire strategy and the ground engineering interact, and the escape, smoke control and access assumptions should be consistent with what the basement impact assessment describes.

Producing one document that serves both routes

The efficient approach on a scheme triggering both requirements is a single fire strategy report with the Article 9A form completed from it.

Structure the report against the matters listed in the policy, with a section for each. Add an appendix mapping each section to the corresponding question on the Gateway One form, so the regulator and the borough can both navigate it. Complete the form by reference to the report rather than by paraphrasing it, because divergence between the two is what generates queries. Keep one set of drawings referenced by both. And give the report a version number and a date, since it will be updated between submission and determination and the consultee needs to know which version it holds.

One honest observation about the overlap. The two regimes ask overlapping questions for different purposes, one about planning-stage design quality in London and one about regulatory scrutiny of higher-risk buildings nationally, and the duplication is real rather than imagined. Treating it as one piece of work with two outputs is the only way to keep the fee and the programme sensible.

This is general guidance, not legal advice. Fire statements and fire strategies must be prepared by a suitably qualified professional, and PlanScope's drafts are a starting point for that professional rather than a substitute. Check the current London Plan text, the Mayor's guidance and the current Approved Document B before scoping the work.

To see which fire and technical documents a London scheme is likely to need, enter your postcode on PlanScope and work through the guided questions. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.