Who can write a Fire Statement for Planning Gateway One

A Gateway One fire statement has to come from someone with fire engineering competence. Article 9A of the Development Management Procedure Order 2015 requires the statement itself, on the form published by the Secretary of State, and the Building Safety Act 2022 framework sits behind the competence expectation. No statute names a register or a qualification, which leaves architects and planning agents deciding for themselves what competence looks like.

The answer, in practice, is a fire engineer with relevant high-rise residential experience, appointed early enough to change the plan.

When a fire statement is required at application stage

The trigger is a relevant building. That means a building containing two or more dwellings, or educational accommodation, which is either at least 18 metres in height or has seven or more storeys.

The requirement applies to applications for planning permission involving such a building, which catches new build, and it catches material alterations to existing relevant buildings too. Two points cause confusion:

• Height is measured to the floor surface of the top storey above ground level in the usual convention used across the building safety regime, so a scheme at 17.9 metres and seven storeys still qualifies on the storey count.
• The requirement bites at planning application stage, so it applies whether or not the scheme has been designed to the level of detail a fire engineer would prefer.

An application for a relevant building without a fire statement will normally be held at validation. That alone is a reason to commission it alongside the drawings rather than after them.

The competence the regulator expects

Nobody issues a fire statement licence. What exists is a set of proxies that the Health and Safety Executive and local planning authorities use, and it pays to be able to evidence all of them:

• A relevant qualification in fire engineering or a closely related discipline.
• Professional registration or membership at an appropriate grade, with the Institution of Fire Engineers being the obvious route for fire engineers, alongside chartered engineering registration.
• Demonstrable experience of buildings of the same type, height and construction, since a competent author on a school is not automatically competent on a 20-storey residential tower.
• Continuing professional development covering the post-2017 regulatory changes.
• Professional indemnity insurance that covers fire engineering advice, which has become materially harder to obtain and is worth checking rather than assuming.

The design team's role is coordination. An architect assembles the drawings, the access strategy and the material specifications, and the fire engineer forms and signs the technical judgements. Where a practice completes the form itself because the fee looked avoidable, the consultee response tends to say so.

Where the statement sits against a full strategy

Two documents, two moments, two audiences.

The fire statement answers the questions planning can actually influence: where the building sits, how fire appliances reach it, whether there is space for firefighting access and water supply, how the layout affects escape, and what the external wall build-up will be in principle. The fire safety strategy resolves the engineering.

Consistency between them matters more than people expect. Where a strategy later contradicts the statement on core arrangements, the planning permission may no longer describe what is being built.

How the consultee response is handled

The Health and Safety Executive is consulted by the local planning authority and replies to it. The response is advice on the fire safety matters within the planning remit, and the authority weighs it with everything else before determining the application.

Responses commonly ask for more information rather than objecting outright, and the requests cluster around the same subjects: appliance access route dimensions and turning, hardstanding loading, hydrant provision and water supply, the position and number of stair cores, the location of the fire service access point relative to the entrance, and the treatment of the external walls.

Answering those properly takes days if the engineer is already appointed and weeks if they are not. Build a contingency into the determination programme, and expect an extension of time request if the response arrives late in the period.

It also pays to read the response as a design document rather than a hurdle. Where the regulator asks about hydrant spacing or a turning head, the underlying question is whether a pumping appliance can actually get to the building and work there, and the answer usually improves the scheme. Applicants who treat the queries as a form-filling exercise tend to receive a second round of them.

Common gaps in submitted statements

Reviewers see the same shortcomings repeatedly.

Generic content that describes national policy without describing the building. A statement that could apply to any tower is worth nothing to a consultee. Missing site information, particularly appliance access geometry and hydrant locations, which have to come from a drawing rather than a paragraph. Silence on the external wall construction, on the basis that materials are a Gateway Two matter, when the planning drawings already commit to an appearance. No stated assumptions, so the reader cannot tell what the engineer relied on. And a version mismatch, where the statement describes an earlier layout than the drawings submitted with it.

Illustrative example: a nine-storey residential block on a constrained urban site, with the fire appliance access shown on a plan that predates the removal of a service yard. The statement describes access that the submitted layout no longer provides, and the consultee response asks for a resubmission. Two months lost to a drawing revision nobody circulated.

The fix is dull and effective. Freeze the drawing set that will be submitted, issue it to the fire engineer with a revision number, and require the statement to name that revision on its front page. Then check the submitted pack against the list before it goes to the portal.

Appointing early enough to influence the design

The fire engineer's influence is greatest at the point the core is being positioned and the site strategy is being set. That is months before a planning application, and it is where the appointment pays for itself.

A practical sequence:

1. Appoint at concept design, once massing and storey count are indicative.
2. Test appliance access and water supply against the site constraints before the layout is fixed.
3. Confirm the stair and core strategy in principle, since retrofitting a second stair after planning is expensive and visible.
4. Draft the fire statement against the drawings that will actually be submitted, with a version control note.
5. Keep the engineer engaged through determination to answer the consultee.

The fire statement is required at Planning Gateway One for relevant buildings under the Building Safety Act 2022 framework and article 9A of the Development Management Procedure Order 2015, and it must be prepared by someone with the necessary fire engineering competence. PlanScope can draft the surrounding documents and structure the statement, and the professional directory is the route to a reviewer who can check and sign off the work. 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. This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it.