What a fire statement must cover at Gateway One

A fire statement goes in with the planning application where the development involves a relevant building, which means, broadly, a building containing two or more dwellings or educational accommodation that is 18 metres or more in height or has seven or more storeys. The fire statement Gateway One content is not open-ended. It follows a form published by the Secretary of State, and the Health and Safety Executive reads it as a statutory consultee under the Town and Country Planning (Development Management Procedure) (England) Order 2015. What the form asks for is planning-stage reasoning about siting, access, water and layout. It is not the building's fire engineering strategy.

That distinction is where most submissions go wrong. Design teams either send a 90-page strategy and hope it covers the ground, or send four lines of reassurance. Neither survives the consultation.

Which buildings are caught

Article 9A of the 2015 Order sets the trigger. Two conditions have to be met together: the building has to contain the relevant use, and it has to meet the height or storey test. A tall office block with no residential content is outside the requirement. A six-storey block of flats at 17 metres is outside it as well, until the top of the top floor moves above 18 metres.

Height is measured to the floor surface of the top storey, taken from ground level, and plant-only levels at roof level are excluded from the storey count. On a sloping site the measurement point matters enough to be worth agreeing with the authority before the drawings are frozen. A scheme sitting at 17.6 metres on one elevation and 18.2 metres on another is a scheme that needs the form.

Mixed use buildings catch people out. The residential content pulls the whole building into scope, so a ground-floor commercial unit under six storeys of flats does not dilute the test.

The same care applies to a scheme of several blocks on one application site. The test is applied building by building, so one tall block among four low ones brings the form with it, and the answers then have to deal with that block specifically rather than the site in general.

What the statement is answering at planning stage

The form is built around a simple question: does the proposed layout create fire safety problems that cannot be fixed once the footprint, the access and the massing are fixed by a permission?

So the answers are about things planning actually controls. Where the building sits relative to the highway. Whether an appliance can reach it. Whether there is room for a hardstanding that will take the weight of a pump. Whether the water main in the street can deliver enough flow. Whether escape routes discharge somewhere usable rather than into a service yard.

Answers have to be about this site. A response that says provision will accord with the relevant standards tells the consultee nothing, and it will come back asking the same question with less patience.

There is a second, quieter purpose. The form creates a written record, early, of the assumptions the design rests on. When those assumptions change two years later, that record is what lets the team see whether the change matters.

Site access and water supplies for firefighting

Two sections carry most of the weight. The first covers emergency vehicle access: the route from the adopted highway, carriageway widths, turning provision, gradients, gate and barrier arrangements, and the position of hardstandings relative to the entrances they serve. Where access runs through a courtyard or over a podium, the loading capacity of the deck belongs in the answer.

The second covers water. State the source, the expected flow, the position of hydrants relative to the building, and whether any of that depends on a new connection. If you have not yet had a written response from the water undertaker, say so rather than assuming a figure. Flow assumptions that turn out to be wrong at Gateway Two are expensive, because by then the building footprint is consented.

Construction-stage access to the same site is a separate matter and belongs in the construction plan, though the two should not contradict each other. If you have already written the routing section of a construction management plan, check it against the permanent access arrangement described here.

Layout, escape and the external walls

The escape section asks for the evacuation strategy in principle. Stay put or simultaneous evacuation. Number of stairs. Whether the strategy depends on a firefighting shaft, an evacuation lift or a smoke control system. At planning stage nobody expects a calculated travel-distance schedule, but the strategy stated here is the one the scheme will be held to, and changing from one stair to two later is a design change that rarely survives contact with a viability appraisal.

External walls are the section people write most carefully. Describe the intended build-up and the approach to materials on the external walls and specified attachments, including balconies. Where product selection has not been made, say that it has not been made and state the performance the design assumes. Do not name a product you have not checked.

Balcony construction deserves its own sentence rather than a cross-reference. So does anything attached to the wall that a fire could run up: solar panels, cladding to plant enclosures, timber screening to terraces. These are the details that generate consultation questions, and they are easier to settle on a drawing than on site.

Who should author it

Fire engineering competence is legally required here. The statement supports a regime created by the Building Safety Act 2022 and is read by a regulator with fire engineers on staff, so it needs an author who can defend the answers. A Fire Statement drafted by a planner and signed by nobody in particular does not meet that bar.

PlanScope can produce an AI-assisted draft that structures the answers to the form and flags every point where site data is missing, with a "to be confirmed" marker rather than an invented figure. That draft is a starting point for the fire engineer, not a substitute for one. The same applies to the longer Fire Safety Strategy, which is a fire engineering document throughout. If you do not have a fire engineer on the team, the professional reviewer route exists for exactly this sign-off.

The regulator as a statutory consultee

The Health and Safety Executive comments; it does not decide. Its response goes to the local planning authority, which weighs it with everything else. In practice a response saying fire safety matters have not been adequately considered is close to fatal, because the authority has no independent basis to disagree.

The consultation runs on the normal statutory timetable, so build it into the programme rather than treating it as background noise. Responses often ask for one specific thing: a swept path, a confirmed hydrant position, a section through the podium. Answering that quickly usually costs less than arguing.

Where building control takes over

Gateway One closes when permission is granted. Everything after that sits with the Building Safety Regulator under the building control regime: the detailed design, the fire strategy proper, the change control process during construction and the final sign-off before occupation.

What planning fixes is the envelope those later stages have to work within. A permission that locks in a single access point, a constrained turning head or a footprint with no room for a second stair has narrowed the options long before anyone applies for building control approval. That is the real reason the form exists, and the reason a thin answer at this stage tends to be paid for twice.

This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it. If you want to see which of the 66 report types your scheme is likely to need, Enter your postcode on PlanScope and work through the guided flow.

PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.