Tall building fire safety expectations in London

Tall building fire safety in London runs on two requirements that do not share a threshold. Article 9A of the Development Management Procedure Order 2015 requires a fire statement with applications for relevant buildings, which are broadly residential buildings of 18 metres or more in height or seven or more storeys, and triggers consultation with the Health and Safety Executive as the Building Safety Regulator at Planning Gateway One. London Plan fire safety policy goes wider, expecting a fire statement produced by a suitably qualified third party assessor with all major development proposals.

So a five-storey block of 14 units in a London borough sits outside Article 9A and inside the London Plan requirement. Applicants who prepare only for the national test get a validation query, and applicants who prepare only for the regional one submit the wrong form.

This is a regional requirement layered on a national one, and the distinction matters when the same design team works across borough boundaries and outside the capital.

What the national requirement covers

Article 9A applies to applications for planning permission for development involving a relevant building, and it requires the fire statement to be submitted on the form published for the purpose. The HSE is a statutory consultee, and its Gateway One response addresses fire safety matters relevant to planning: site layout, access and water supplies for the fire service, and the extent to which the proposal considers fire safety in the design.

The building must be prepared by someone with the fire engineering competence to do it. A Fire Statement is a report where a professional with the necessary competence is legally required rather than merely advisable, because the Building Safety Act 2022 framework and Article 9A both proceed on that basis, and PlanScope's Fire Statement draft is a starting point for that professional rather than a substitute for them.

Approved Document B has been amended in relation to second staircases in taller residential buildings, with transitional arrangements attached. Check the current edition and the transitional dates before fixing a core, because the core layout is the single hardest thing to change after planning permission.

Where the London requirement goes further

The regional policy differs on three axes.

The third party assessor point is the one that catches design teams. A statement written by the scheme's own designers may satisfy the national requirement and still not satisfy the regional expectation of independence. Commission the assessor early, because an assessor brought in at the end tends to ask for changes the design can no longer absorb.

London Plan policy also addresses evacuation and inclusive access, expecting new residential buildings to provide for the evacuation of all occupants including disabled residents. In practice that drives evacuation lift provision, refuge areas at protected stair lobbies, and a stated evacuation strategy rather than an unspoken assumption of stay put.

Evacuation strategy and what to state plainly

The evacuation strategy is a planning matter because it determines the number of stairs, the position of the cores, the lift provision and the corridor arrangement. Write it down.

1. State the strategy: stay put with a single stair, simultaneous evacuation, phased evacuation, or a progressive horizontal approach.
2. Say how disabled occupants evacuate, and which lifts serve that purpose.
3. Identify refuge locations and the communication arrangements from them.
4. Describe the arrangement for the fire and rescue service: access route, appliance position, dry or wet rising main, firefighting shaft and lift.
5. Say what water supply is available and whether the supply needs reinforcement, because that may need a utility agreement and a lead time.

A statement that says the building will comply with the Building Regulations tells a planning officer nothing. What the officer needs is the consequence for the drawings: how many stairs, where they land, and what the roof and elevations have to accommodate. Smoke control shafts belong in that same conversation because they take space at every floor and terminate visibly at roof level.

Referable schemes and the extra loop

Applications that meet the referable thresholds go to the Mayor for a stage one report and again at stage two, and the thresholds include schemes of 150 or more residential units and buildings above a stated height, which is lower for sites adjoining the River Thames. Referral adds a formal consultation stage with its own timetable.

For fire safety the practical effect is that the statement is read by a third reviewer with regional policy in front of them. Inconsistencies between the fire statement, the design and access narrative and the drawings get found. Issue them as a coordinated set, and make sure the storey heights and stair counts agree across all three.

Coordinating with Gateway One rather than duplicating it

Gateway One and the London Plan requirement ask overlapping questions, and the sensible response is a single document structured to answer both. Assemble it once.

• One fire statement, on the published form where Article 9A applies, with the regional matters covered in the same document or in a clearly cross-referenced appendix.
• One set of fire strategy drawings: site access and appliance positions, escape routes, compartmentation, firefighting shaft, and roof level terminations.
• One schedule of assumptions, listing what has been assumed about water supply, service access and the eventual building control route, and flagging what remains to be confirmed.
• A named author with stated competence, and a statement of independence where the regional policy expects a third party.

Gateway Two and Gateway Three follow under the building control regime rather than the planning one, and the fire safety strategy developed later to BS 9991 or BS 9999 is a fire engineering document in its own right. The Fire Safety Strategy is likewise a report where professional competence is legally required, and it should be developed from the planning stage statement rather than started again.

Two practical failures recur. The first is water supply reinforcement discovered after permission, because nobody asked the undertaker at concept stage and the local main turns out to be undersized for the required flow. The second is an appliance access route that works on the site plan and then fails once the refuse strategy, tree pits, level changes and the substation position are drawn on top of it. Neither is a fire engineering problem. Both are coordination problems, and both cost far less to solve before the drawings are issued. The design narrative in the Design and Access Statement should carry the same access route, the same appliance standing position and the same hydrant locations as the fire drawings, because a reviewer who finds two versions will ask which one is being applied for.

Heritage buildings raise the harder version of the same question, where escape provision and historic fabric pull against each other, and that tension is covered in the note on fire safety in listed buildings.

This is general guidance, not legal advice. For specialist technical reports, qualified professional input may be required. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.