Who can write a Gateway One fire statement for planning

The fire statement that accompanies a planning application for a tall residential building has to be prepared by someone with fire engineering competence, and the form itself asks who wrote it and what qualifies them. If you are asking who can write a fire statement, the honest answer is that there is no statutory register, so the burden falls on you as applicant to appoint someone whose competence you could defend if the Health and Safety Executive queries the submission. In practice that means a chartered or incorporated engineer with fire engineering experience on buildings of the type proposed.

Where the fire statement requirement comes from

Article 9A of the Town and Country Planning (Development Management Procedure) (England) Order 2015 requires a fire statement with applications for relevant development. It was inserted in 2021 and it applies where the development involves the provision of one or more relevant buildings.

A relevant building is one containing two or more dwellings, or educational accommodation, that meets the height condition: 18 metres or more in height, or seven or more storeys, whichever is reached first. That definition drags in student accommodation and some institutional residential schemes that people assume are outside it.

The statement must be on the form published by the Secretary of State. It is not a free-form document, and a bespoke fire strategy report submitted instead of the form does not satisfy the requirement, though it can and usually should be appended to it. This first stage is commonly called Planning Gateway One, sitting ahead of the building control approval and completion stages under the Building Safety Act 2022 regime.

The competence the regulator expects

The form asks for the name, professional qualifications and relevant experience of the author. There is no licensing scheme for fire engineers in the way there is for, say, an ecologist holding a survey licence. What exists instead is a set of recognised indicators.

• Chartered or incorporated engineer registration through the Engineering Council, with fire engineering as the practising discipline.
• Membership of the Institution of Fire Engineers at a grade that reflects assessed competence rather than subscription alone.
• Demonstrable experience on buildings of comparable height, use and construction, including any relevant work on external wall systems and evacuation strategy.
• Professional indemnity insurance that actually covers fire engineering advice on higher-risk buildings, which is not a given.

Ask for evidence of all four before appointment. And ask to see it in writing. The competence question has become sharper since the Building Safety Act 2022 introduced duties around competence for those working on higher-risk buildings, and a designer who cannot evidence their own competence is a risk you carry rather than one they carry.

Where a scheme is complex, the practical answer is often a named lead fire engineer supported by a practice, with the individual identified on the form. Anonymous corporate authorship invites a request for further information.

How the Health and Safety Executive reviews it

For applications involving relevant buildings, the Health and Safety Executive is a statutory consultee at the planning stage. It reviews the fire statement against the matters that are properly planning matters and responds to the local planning authority within the consultation period.

What comes back is not an approval. It is a consultee response that the authority weighs alongside everything else, and it can be a request for more information, a set of comments, or a substantive objection. A response that identifies gaps in the statement usually means a resubmission of the form rather than a refusal, provided the design principles are sound.

The most common gaps are practical rather than theoretical: no dimensioned fire appliance access shown on the site plan, no confirmation of the available water supply for firefighting, no statement about how the layout works if one stair is compromised, and no explanation of how the fire strategy interacts with the proposed external wall build-up.

Scope at planning stage against building control

The planning stage deals with the things planning can actually control. The building control stage deals with detailed design. Keeping the two apart saves a great deal of wasted effort.

A Fire Statement prepared for planning should therefore be shorter than people expect and more spatial than people expect. Where a fuller document is needed, a Fire Safety Strategy to BS 9991 or BS 9999 is the fire engineering document, and both are areas where a competent professional is legally required rather than merely advisable. An AI-assisted draft can structure the narrative and the policy framing, and it cannot supply the engineering judgement.

Programme implications for a relevant building

Appoint the fire engineer at the same time as the architect, not after the layouts are fixed. Three decisions get made early and are expensive to unpick later: the number and position of stair cores, the position and width of the fire appliance route, and the extent of the external wall system.

A single stair scheme is the sharpest example. Where policy or regulation points towards a second stair for buildings above a given height, adding one after the massing is set costs floor area on every level and can undermine the viability case. Get the fire engineer's view on that in week one.

Budget for a resubmission cycle. If the regulator responds with questions at week five of a thirteen week determination period, you need the author available to respond inside two weeks rather than in a month's time.

Appointing and briefing a fire engineer

A short, specific brief gets a better fee and a better document.

1. State the building height in metres and the storey count, and say how both were measured.
2. Confirm the use: dwellings, student accommodation, or a mix, and whether any part is institutional.
3. Provide the site plan showing the adopted highway, the proposed access route and any gradients or restrictions.
4. Provide the general arrangement plans and the core strategy, even in outline form.
5. Say what the external wall build-up is likely to be, including balconies and any combustible elements.
6. Confirm who is completing the form and who signs it.
7. Ask for the response to any consultee comments to be included in the fee, with a stated turnaround.

Where you need help identifying a reviewer who can sign off a draft, the professional directory is the route PlanScope provides for professional review and sign-off. 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, and the height condition and form requirements are set by legislation that changes, so check the current article 9A wording and the published form before submitting. Browse the report types on PlanScope to see what else a tall residential scheme is likely to need.