What the Gateway One consultee looks for

At Gateway One the statutory consultee is reading your planning drawings for fire service access, water supply, external wall build-up and evacuation strategy, and it is reading them as a fire engineer rather than as a planner. The consultation arises under Article 9A of the Town and Country Planning (Development Management Procedure) (England) Order 2015, which requires a fire statement with applications for relevant buildings: broadly, buildings containing two or more dwellings or educational accommodation that are 18m or more in height, or have seven or more storeys.

The practical consequence for a developer is that a layout which works commercially can fail on a turning circle. Fix that at the design stage and Gateway One becomes a three week formality.

The consultee role at the planning stage

The Health and Safety Executive, exercising the Building Safety Regulator function, has been a statutory consultee on these applications since August 2021. Its role is limited to fire safety matters relevant to the planning decision, which means the things that are hard or impossible to change after permission: where the building sits, how appliances reach it, where the water comes from, and the broad principles of escape.

It is not reviewing detailed fire engineering. That belongs at Gateway Two, under the Building Safety Act 2022 regime, when the building control application goes in. Treating the planning stage submission as a Gateway Two document wastes money and tends to produce a statement that answers the wrong questions.

Responses fall into a small number of categories: no comment, comments or advice for the authority to take into account, or a response raising concerns about the principles of the scheme. The last of those is the one to avoid, because it lands in the officer's report and is quoted in full.

Site access and the questions asked first

Access is where most comments originate, and the questions are predictable because they come from Approved Document B and the fire and rescue service's operational needs.

The matters to resolve on the site plan are:

• Hardstanding and carriageway capable of carrying a pumping appliance, with the load capacity stated rather than implied.
• Turning provision at the end of any dead-end approach, dimensioned and demonstrated by a swept path drawing rather than a drawn circle.
• The distance from the appliance parking position to the dry or wet riser inlet and to the building entrance, measured on the plan.
• Gradients on the approach, gates and barriers, and who holds the key.
• Whether access is maintained during construction and in the completed scheme, which differs where a podium or basement car park is involved.

Show the appliance on the drawing. A swept path analysis with the appliance dimensions annotated answers the question before it is asked, and it is a small piece of work compared with redesigning a courtyard.

Water supply for firefighting

The second recurring theme is water. The consultee wants to know that there is enough of it, at the right pressure, close enough to the building.

That means identifying existing hydrants within the relevant distance of the building entrances and risers, confirming available flow and pressure with the water undertaker rather than assuming, and proposing new hydrants where the existing provision falls short. Where a scheme relies on a tank and pump arrangement, say so and show where the plant sits, because it takes space that has to come from somewhere.

Get the undertaker's flow data early. The response time for a hydrant flow enquiry is frequently longer than the time left in a determination period once the consultee has asked the question.

External wall construction at outline stage

External wall build-up is awkward at planning stage because the detail is not designed yet, and the consultee knows that. What it wants is a statement of the principles: the intended wall construction, the approach to combustibility, the treatment of balconies and their materials, and how cavity barriers and cladding junctions will be dealt with at the next stage.

Where the application is in outline or the materials are to be conditioned, say what the parameters are and commit to the approach rather than leaving it blank. A fire statement that defers everything invites a response saying the principles cannot be assessed, which is not the same as approval.

Balconies deserve explicit treatment. They are the element most often raised, because combustible balcony construction has a documented history of spreading fire externally, and the planning drawings show them clearly.

Evacuation strategy and the planning layout

Evacuation is a Gateway Two subject with a planning tail. What matters at this stage is the part of the strategy that fixes the layout: the number and position of escape stairs, the location of the firefighting shaft, the evacuation lift provision, and the assembly area outside the building.

Second staircase provision has been the live issue for tall residential buildings since the change to the statutory guidance for buildings above 18m, which came with transitional arrangements. Check the current edition of Approved Document B rather than relying on a note from a previous scheme, because the position has moved and the transitional dates matter to anything already in design.

A second stair is not a detail. It changes the core, the net to gross ratio and the unit mix, so a scheme designed on a single stair and submitted on the hope that it falls outside the requirement is carrying a serious risk. Where a building sits just under the threshold, the margin needs to be real and measured, and fire evidence for a building just below the threshold looks at how to demonstrate that.

A Fire Statement is one of the report types where a licensed or competent professional is legally required: the document has to be prepared by somebody with the necessary fire engineering competence, and an AI-assisted draft is a starting point for that professional rather than a substitute for them.

How a holding response is resolved

Where the consultee raises concerns, the resolution is almost always drawing-based rather than argumentative. Identify the specific point raised, change the drawing, and reissue with a short covering note that maps each comment to the amendment.

Three things speed it up. Dealing with the comments in the order they were made, so the reviewer can follow. Reissuing the drawing with a revision letter and a revision cloud. And copying the case officer, because the determination clock is the officer's problem and they will chase the consultee for you.

Where the point is one of principle rather than detail, a short meeting is worth more than three rounds of correspondence. Basement and below-ground accommodation is a frequent example, and the arguments in safe egress from habitable basement rooms show why that conversation is better had in person.

Timing against the determination period

The consultation period for a statutory consultee is 21 days, and a major application carries a 13 week determination period. Those two facts are the whole scheduling problem: a consultee response arriving in week five, needing a revised layout, a new swept path drawing and a hydrant flow enquiry, does not fit comfortably into the remaining eight weeks.

The sequence that works runs backwards from submission:

1. Fix the building height and storey count, and confirm whether Article 9A applies.
2. Commission the fire engineer to advise on access, water and stair strategy before the layout is frozen.
3. Submit the hydrant flow enquiry to the undertaker.
4. Produce the swept path analysis and the access plan.
5. Prepare the fire statement on the published form, with the drawings referenced.
6. Submit, and expect the consultee response within the consultation period.

An illustrative example

A nine storey residential block is proposed on a backland site with a single access from a residential street. The fire statement identifies appliance access to within 18m of the riser inlet, a swept path drawing shows a pumping appliance turning within the courtyard, and a hydrant flow test confirms available flow at the nearest hydrant. The consultee raises one comment, about balcony materials, which is answered by a commitment to limited combustibility and a condition on materials. This example is illustrative and does not describe any real scheme or consultee response.

Where the scheme is above the height threshold, the detailed strategy that follows at Gateway Two will be a Fire Safety Strategy to BS 9991 or BS 9999, again a fire engineering document requiring a competent professional author.

This is general guidance, not legal advice. Fire safety requirements change and are matters for a qualified fire engineer, so verify the current position in Approved Document B and with your local planning authority.

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. Enter your postcode on PlanScope to see which fire and structural reports your scheme is likely to need.