What a fire statement must contain under Article 9A

A fire statement under article 9A of the Development Management Procedure Order 2015 has to be made on the form published by the Secretary of State, and it has to answer that form's questions about the development in front of the planning authority. It is a planning document about the fire safety consequences of the things planning controls: where the building sits, how big it is, how appliances reach it, where water comes from, and how the layout supports getting people out.

Architects reach for a house template. Do not. Councils validate against the published form, and a document that answers the same material in a different order comes back.

The form and its scope

The statement accompanies applications for planning permission involving a relevant building, meaning one containing two or more dwellings or educational accommodation that is at least 18 metres in height or has at least seven storeys. Get that threshold question settled first, because the entire requirement turns on it.

What the form asks about falls into five groups:

1. The principles and concepts applied to the fire safety design, and the standards or guidance relied on.
2. Site layout, including the position of the building, distances to boundaries and to other buildings, and external features that affect fire spread or access.
3. Emergency vehicle access and hardstanding, including the route from the adopted highway and the space available for appliances to set up.
4. Water supplies for firefighting, including hydrant locations and provision for internal supplies.
5. The approach to means of escape and the evacuation strategy at a level of principle, and how the design supports it.

There is also space to explain how the proposals have taken account of policy and guidance, and to identify anything still to be resolved at a later stage.

What belongs in it and what does not

The line to hold is planning relevance. If a decision the planning system makes could change the answer, it belongs. If it is a detailed design matter for the Building Regulations, it does not.

Belongs: the position of the building relative to boundaries, the width and load-bearing capacity of access routes, the location of appliance parking, the arrangement of cores in relation to the massing, the position of hydrants, the space set aside for firefighting shafts, and the implications of the evacuation strategy for the number and position of stairs.

Does not belong: door hardware, detection and alarm specification, compartment wall constructions, cavity barriers and product certification. Those sit with the Building Regulations and the Building Safety Regulator at the later gateways.

The grey area is the evacuation strategy. Whether a building is designed for stay put, simultaneous evacuation or a phased approach has direct consequences for core arrangement and stair provision, so state the strategy and its planning consequences without turning the statement into a fire engineering report. A full Fire Safety Strategy to BS 9991 or BS 9999 is a different document for a different stage.

Competence and who signs it

This is a report type where competence is not optional. A Fire Statement should be prepared by someone with the fire engineering competence to stand behind its conclusions, and an AI-assisted draft is a starting point for that person rather than a substitute. The Health and Safety Executive is consulted on the application and its response will reflect the quality of what it is given.

Two practical consequences. Appoint the fire engineer early enough to shape the layout rather than to describe it, because a statement written after the drawings are frozen usually documents problems instead of solving them. And name the author and their qualifications in the statement, since the consultee response often turns on whether the reader can tell who wrote it.

Where you need a reviewer with the relevant competence, the professional directory is one route to finding someone to look at a draft before it is submitted.

Making it consistent with the drawings

The most common cause of a poor consultee response is not error, it is contradiction. The statement says appliances approach from the north, and the site plan shows a landscaped strip there. The statement describes a single-stair building, while the general arrangement shows two cores.

A workable discipline is to cross-reference every substantive statement to a drawing number and revision. Then, when the scheme changes during determination, the cross-references tell you what needs updating.

Include or reference the following drawings:

• A site plan showing appliance access route, turning and setting-down space, and hydrant positions
• A section or elevation with the height measurement annotated against the ground datum
• Typical floor plans showing core positions and escape routes at principle level
• A boundary distance plan where separation distances are relevant

Where the application is in outline, or where the building is one of several on a wider site, say clearly which building the statement covers and on what assumed parameters. Statements that describe a parameter-based scheme without stating the assumptions are the ones that attract a holding objection.

Timing, consultation and change

Once the application is validated, the council consults the Health and Safety Executive. Expect the response to raise questions, and build time for that into the programme rather than treating it as an exception.

If the scheme changes materially during determination, the fire statement has to change with it. A statement describing a layout the applicant has abandoned is worse than useless, because it invites a consultee comment on something nobody is proposing.

Illustrative example: a 19-metre block of 46 flats over a podium car park, with the only vehicular approach along a shared surface designed as a pedestrian-priority street. The statement that works sets out the appliance route with dimensions, confirms the surface loading, shows where the pump appliance sets down relative to the firefighting shaft, and identifies the hydrant. The statement that fails says access is achievable and refers to a drawing that shows planters in the route.

One more thing worth building into the fee. Where the site has restricted access, an existing highway that cannot be widened, or a podium deck with load limits, get the appliance access question tested by the fire engineer before the massing is settled. Redesigning a core because a pump appliance cannot reach the building is expensive at any stage and ruinous after consent.

After Gateway One

Gateway One is the planning stage. Gateways Two and Three sit under the Building Safety Act 2022 regime with the Building Safety Regulator and use a related but separate definition of higher-risk buildings set out in 2023 regulations. Assumptions carried across without checking cause real difficulty at the point of construction, particularly for building types treated differently between the two regimes.

Keep the fire statement in the project record and hand it on. The design rationale it captures is the reference point for the later submissions, and a scheme that reaches Gateway Two with no record of why the layout is as it is spends money rediscovering it.

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.