Fire, Structural and Basements

Writing a fire statement section by section

7 min readBy PlanScope Editorial Team

Article 9A of the Development Management Procedure Order requires a fire statement on the published form for relevant development. Here is what each part has to say and why statements get returned.

The fire statement form at planning is a validation document with a narrow job: to show the local planning authority, and the Health and Safety Executive as statutory consultee, that fire safety has shaped the scheme rather than been bolted onto it. Article 9A of the Town and Country Planning (Development Management Procedure) (England) Order 2015 requires one for relevant development, which in broad terms means buildings containing two or more dwellings or educational accommodation that are 18 metres or more in height or have seven or more storeys. It must be submitted on the form published by the Secretary of State, and it must be prepared by somebody with the fire engineering competence to stand behind it.

That last point is not a style preference. A fire statement is a document where a competent professional is legally required, and an AI-assisted draft is a starting point for that professional rather than a substitute for them.

The published form and how it is structured

The form is a fixed set of numbered questions rather than a free-form report, which catches out architects used to writing a design narrative. Each question has a box, and the discipline is to answer the question asked rather than to cross-refer to a drawing pack and hope.

Three habits make a difference. Answer in the box and attach the drawing as supporting evidence rather than the other way round. Use the same terminology as the form, so that an officer checking validation can tick each item without interpretation. And where an answer is not applicable, say why rather than leaving the box empty, because an empty box reads as an omission.

Download the current version of the form before each submission. It has been revised since it was introduced, and a superseded version is a straightforward validation refusal.

Describing the principles of the fire strategy

This is the question that distinguishes a real statement from a template. What is wanted is the fire safety approach for this building: the evacuation philosophy, the compartmentation strategy at a level of principle, whether sprinklers or another suppression system are proposed, and the reasoning that connects those choices to the form and layout you have drawn.

Keep it at the level planning can act on. The authority is not assessing compliance with Approved Document B, which happens later, and a statement that reads as a building control submission invites questions nobody at planning can answer. What planning can act on is anything that would change the scheme if it were wrong: core position, stair numbers, building footprint and depth, and access arrangements around the perimeter.

State clearly where a decision is still open, and what the options are. A statement that pretends certainty about a suppression strategy the client has not agreed is worse than one that sets out two routes and says which is preferred.

Site layout and access for fire appliances

Planning controls the ground. That makes layout the part of the fire statement with the most planning consequence, and the part most often answered with a generic paragraph.

Describe the vehicle route from the public highway to the building, its width and the turning provision, the hardstanding positions, the gradient where it matters, and any gates or bollards with the arrangements for operating them. Where the route crosses a podium, a basement deck or a rain garden, say what structural and drainage implications that carries, because those are the ones that unravel a landscape design at technical design stage.

Access is also where tree retention, parking layout and refuse strategy collide. Resolving appliance access after the landscape drawings are issued is a reliable way to lose a tree you promised to keep.

Water supplies for firefighting

The form asks about water supplies, and the honest answer at planning stage is often incomplete. What you can give is the location of existing hydrants relative to the building, confirmation that the water undertaker has been approached, and the position of any proposed tank or additional hydrant on the site plan.

Get the undertaker's correspondence started early. Flow and pressure data takes time to come back, and a scheme relying on a new main or a booster set has a cost and a programme consequence that a client should hear before permission rather than after.

Where a tank or pump room is proposed, show it on the plans at the right size. A plant room that appears for the first time at technical design has to come out of saleable area or go somewhere that needs a fresh amenity assessment.

Evacuation strategy and management

Set out whether the building is designed for stay put, simultaneous evacuation, phased evacuation or an evolving strategy, and the implications for stair capacity and for the alarm system. Explain how disabled occupants are provided for, including evacuation lifts where they are proposed and the refuge arrangements that go with them.

Management is part of the answer. A stay put strategy depends on an institution that maintains compartmentation over decades, and in a building with multiple ownerships that is a real question rather than a rhetorical one. Say who will hold responsibility for the fire strategy in occupation.

Where the building is below the relevant threshold but close to it, the arguments about what evidence to supply voluntarily are different, and our note on fire evidence for a building just below the threshold covers that position.

Emergency vehicle access and hardstanding

Element What the statement should state Where it is shown
Route from highway Width, surfacing, gradient, turning provision Site plan and section where levels change
Hardstanding Position, dimensions, loading assumption Site plan
Gates and bollards Operation and access arrangements Site plan and boundary treatment drawing
Hydrants Existing and proposed positions, distance to entrances Site plan and utilities drawing
Dry or wet riser inlets Position relative to appliance stance Ground floor plan

Dimensioned positions carry far more weight than prose. An officer who can measure the appliance stance off the submitted plan has no reason to ask a question, and the statutory consultee response comes back shorter.

Who must author the statement

Fire engineering competence, evidenced. In practice that means a fire engineer or a fire safety consultant with relevant professional membership, instructed early enough to influence the layout. An architect can coordinate the submission and should, but authorship of the fire statement sits with the competent person.

The same applies with more force to a Fire Safety Strategy prepared to the relevant British Standard, which is a fire engineering document in its own right. Where you need help finding a reviewer to check and sign off a draft, the professional directory is the route to that review rather than a substitute for appointing a designer.

Fees for this work are modest against the cost of a redesign at Gateway Two. Appointing the fire engineer after planning permission is the single most expensive sequencing decision available on a tall residential scheme.

Common reasons a statement is returned

The recurring validation failures are mundane. A superseded version of the form. Boxes left blank. Answers that cross-refer to a drawing that was not submitted. A statement describing a different building, usually because it was copied from the previous phase.

Then there are the substantive failures that produce a consultee holding objection rather than an invalid application: no engagement with appliance access on a constrained site, a water supply answer that amounts to an intention to investigate, and an evacuation strategy inconsistent with the number of stairs drawn.

The fix is sequence. Instruct the fire engineer at the point the massing is settled, not when the application is being collated, and read the Fire Statement requirements against your drawing schedule before you submit.

This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it. Enter your postcode on PlanScope to see which supporting documents a scheme is likely to need.

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.

Frequently asked questions

Which applications need a fire statement?

Applications for relevant development under article 9A of the Town and Country Planning (Development Management Procedure) (England) Order 2015. In broad terms that covers buildings containing two or more dwellings or educational accommodation which are 18 metres or more in height or have seven or more storeys. Check the current wording of the article, because it has been amended.

Can an architect write the fire statement?

An architect can coordinate the submission, but a fire statement is a document where fire engineering competence is legally required, so authorship belongs with a competent person. Instruct them while the massing is still movable. An AI-assisted draft is a starting point for that professional to work from rather than a substitute for appointing one.

Does the fire statement have to use the published form?

Yes. The statement must be made on the form published by the Secretary of State, and using a superseded version is a straightforward validation refusal. Download the current version for each submission rather than reusing a copy from an earlier project, and answer in the boxes instead of cross-referring to a report.

How detailed should the water supply answer be?

Give the position of existing hydrants relative to the building, confirm that the water undertaker has been contacted, and show any proposed tank, pump room or new hydrant on the submitted plans at a realistic size. An answer that amounts to an intention to investigate attracts a holding objection from the statutory consultee.

Who is consulted on a fire statement?

The Health and Safety Executive is the statutory consultee for relevant development at Planning Gateway One, and its response goes to the local planning authority with the application. The authority remains the decision maker. A response that raises unresolved layout or access issues will usually stall determination until they are answered.

Sources and further reading

fire statementgateway onebuilding safetyvalidationhigh-rise

This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.

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