Who can author a Fire Statement at Gateway One

A fire statement competent author is not defined by a single licence, but the expectation is clear enough in practice: a chartered or professionally registered fire engineer, or someone with equivalent demonstrable competence in fire safety design, independent enough to give the applicant an honest answer. The Building Safety Regulator, sitting inside the Health and Safety Executive, is a statutory consultee at Planning Gateway One and reads these documents for a living.

Getting the author right matters more than the document's length. A short statement written by a competent fire engineer that answers the questions on the form is worth more than forty pages assembled by someone who has not done it before.

Which buildings trigger the requirement

Article 9A of the Town and Country Planning (Development Management Procedure) (England) Order 2015 requires a fire statement with applications for relevant development. That means development involving a building containing two or more dwellings, or educational accommodation, which meets the height test of 18 metres or more, or seven or more storeys.

The threshold uses the same measure that runs through the Building Safety Act 2022 for higher-risk buildings, which is deliberate. What starts at Gateway One continues through Gateways Two and Three under the building control regime.

Check the trigger carefully on schemes that sit close to the line. A building at 17.8 metres is outside Article 9A, but if a later design change adds a plant enclosure or raises a parapet the position shifts, and an application validated without a fire statement will need one.

The requirement is procedural, so a missing statement is a validation issue rather than a merits issue. Authorities will not validate the application without it.

What the statement has to address

The statement is made on the published form, and the form sets the agenda. It asks about the principles and approach to fire safety for the scheme rather than about product specifications.

The substance falls into a handful of areas.

• Site layout, including the position of the building relative to boundaries and neighbouring structures.
• Emergency vehicle access, hardstanding positions and the route a fire appliance takes from the public highway.
• Water supplies for firefighting, including hydrant positions and available flow.
• Means of escape and the vertical circulation strategy.
• The approach to external walls, materials and any specialist features.
• How the development relates to the local fire and rescue service and its operational needs.

This is a planning-stage document about siting, access and strategy. It is not the detailed fire safety strategy that follows under the building control gateways, though the two must be consistent, and an applicant who writes them in the wrong order usually discovers a conflict late.

Fire engineering competence and what it looks like

There is no statutory register of fire statement authors. What there is instead is a set of recognisable markers.

Professional registration with the Engineering Council as a chartered or incorporated engineer, held in a fire engineering discipline. Membership of the Institution of Fire Engineers at a grade that reflects assessed competence. A record of comparable buildings, evidenced by project references rather than a list of sectors.

Ask three questions when appointing. Which comparable schemes have you taken through Gateway One? What did the Regulator ask on those, and how did the design respond? And are you free to tell the design team something they will not want to hear?

That last question is the one that matters. The value of a competent author lies in the advice given before the layout is fixed, not in the document produced afterwards.

A licensed or competent professional is legally required for this work, and an AI-assisted draft is a starting point for that professional rather than a substitute. The fire statement page sets out what the document covers, and the circumstances in which an authority can push back on an author are described in when a council can reject a report because of its author.

The Building Safety Regulator as consultee

The local planning authority consults the Regulator on relevant applications, and the response comes back as a consultation reply within the period the Order allows for statutory consultees.

The Regulator's comments tend to focus on the things a planning decision can actually control: access for fire appliances, the space around the building, hydrant provision and the broad escape strategy. Comments about detailed construction are usually deferred to the later gateways, which is the correct division of labour.

An unresolved comment is a practical problem rather than a veto. The planning authority weighs it, but few officers will recommend approval over an unanswered concern from the Regulator about appliance access, because the fix is often a layout change rather than a specification change.

Where a design stage statement fails

The recurring failures are structural rather than technical.

1. The statement is written after the layout is fixed, so fire appliance access has to be retrofitted into a parking court that cannot take the loading or the turning circle.
2. Hydrant provision and available flow are asserted rather than confirmed with the water undertaker, and the figures do not survive checking.
3. The vertical circulation strategy has not been tested against current expectations for residential buildings above the height threshold, including the position on staircase provision. Check the current Approved Document B and its transitional arrangements rather than working from an older edition.
4. The statement contradicts the transport drawings, because the fire engineer and the highways consultant never spoke.
5. It describes a building that the elevations do not show, usually after a value engineering exercise changed the massing.

An illustrative example: a scheme of 96 flats in a building of 19 metres was designed with a landscaped courtyard on the approach elevation and appliance access from a side street. The fire engineer was appointed after the planning drawings were complete and found the appliance could not achieve a pump position within the required distance of the dry riser inlet. Moving the inlet and widening a section of the access route resolved it, at the cost of two courtyard trees and a redesign of the entrance. This example is illustrative rather than a real case.

Coordination with the design team

Bring the fire engineer in with the architect and the highways consultant, at the point where the site layout is being tested rather than resolved.

Three coordination points repay the effort: the appliance route and pump positions against the parking and landscape layout, hydrant positions against the utilities drawings, and the core strategy against the residential layout. Each of those costs almost nothing to change on a sketch and a great deal to change on a submission.

Where a reviewer is needed to check a draft before it goes in, the professional directory is the route to someone who will put their name to it.

Programme consequences of a late instruction

A fire statement cannot be written properly in a week, because the author needs the layout, the access drawings, the utilities information and confirmation from the water undertaker.

Instructing late produces one of two outcomes. Either the statement is thin, and the Regulator's response asks for the information that should have been in it, adding weeks to the determination. Or the statement is honest about a design problem, and the drawings change after submission, which means re-consultation.

The broader background to the regime, including how Gateway One sits alongside the later gateways, is set out in Planning Gateway One and the fire statement requirement. Appoint early, and treat the fire statement as a design input rather than a submission document.

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.