Gateway 1 and London Plan D12, UK wide
Planning Fire Statements and Gateway 1
Since 1 August 2021 a planning application for a relevant high-rise residential building must be accompanied by a fire statement on the form prescribed by the Secretary of State. AL23 Safety prepares Gateway 1 fire statements and the independent third party fire strategies that London Plan Policy D12(B) calls for, on schemes UK wide.
What is a planning fire statement?
The first building safety hurdle and the one most schemes meet unprepared
A fire statement is a standalone document submitted with a planning application. It sets out the fire safety principles, concepts and approach applied to each building, the site layout, emergency vehicle access, the water supplies available for firefighting, the consultation already undertaken and any local fire safety policies. It is signed by the person who wrote it. That person must be a suitably qualified engineer with relevant experience in fire safety.
Gateway 1 is the planning stage of the three gateway regime built around higher-risk buildings. It comes first, long before construction. Gateway 2 before work starts and Gateway 3 before occupation follow later and are covered on our Gateway 2 and Gateway 3 support page. Decisions taken at Gateway 1 about massing, access and stair provision are extremely hard to unwind at Gateway 2, which is why the statement deserves engineering input rather than a planning consultant's best guess.
The statutory scope is confined to planning matters. A fire statement does not duplicate Building Regulations or Fire Safety Order compliance and the local planning authority has no building control enforcement role through it.
Who needs one
The threshold test and the traps inside it
A building containing two or more dwellings or educational accommodation
that is 18 metres or more in height or has 7 or more storeys, whichever is reached first.
Height is measured
from ground level on the lowest side of the building to the upper floor surface of the top storey, excluding rooftop plant and machinery.
Storeys entirely below ground are not counted
A mezzanine counts as a storey where its floor area is at least 50 per cent of the largest storey that is not below ground.
The trigger is the application type
, covering the provision of a relevant building, its development or works within its curtilage. The statement covers the whole development site including the space between buildings.
Care homes, hotels and short-term holiday lets are not dwellings for this test
They do not trigger a fire statement on their own. This is a common error because care homes and hospitals are in scope for Gateway 2 and Gateway 3.
Exempt
Outline applications, section 73 applications for development without compliance with previously attached conditions, plus applications for a material change of use where the building will no longer be a relevant building on completion.
In London, separately
Policy D12(B) applies to all major development proposals, whatever the height. A London scheme can need the national form, the London Plan fire statement, both or neither.
The regulations that apply
Your legal framework, in plain terms
The Town and Country Planning (Development Management Procedure and Section 62A Applications) (England) (Amendment) Order 2021, SI 2021/746, inserted article 9A into the Town and Country Planning (Development Management Procedure) (England) Order 2015. It came into force on 1 August 2021. The same instrument added the fire safety regulator to the statutory consultee table at Schedule 4 of the 2015 Order. In London the London Plan, adopted in March 2021, layers development plan policy on top of that national requirement.
Article 9A of the DMPO 2015
A fire statement, on the form published by the Secretary of State, must accompany a relevant planning application.
Schedule 4 to the DMPO 2015, Table paragraph (zg)
Makes the fire safety regulator a statutory consultee on those applications.
The Building Safety Regulator (Establishment of New Body and Transfer of Functions etc.) Regulations 2026, SI 2026/20
From 27 January 2026 the consultee is the Building Safety Regulator rather than the Health and Safety Executive.
London Plan Policy D12(A)
All development proposals must achieve the highest standards of fire safety, including unobstructed outside space for appliances and assembly, passive and active measures, construction that minimises fire spread and suitable means of escape with an associated evacuation strategy that can be updated and published. It also requires appropriate access and equipment for firefighting.
London Plan Policy D12(B)
All major development proposals should be submitted with a fire statement that is an independent fire strategy produced by a third party suitably qualified assessor.
London Plan Policy D5(B5)
The inclusive design limb, which in relevant development requires at least one evacuation lift per core suitable for evacuating people who need level access. We paraphrase this rather than quote it.
Two honest points. First, the gov.uk planning practice guidance page on fire safety and high-rise residential buildings was last updated on 20 August 2021 and still names the Health and Safety Executive as consultee. It is out of date. Second, the response period for the consultee is widely quoted as 21 days. We have not been able to confirm that from a primary source so we plan around the authority's own committee timetable rather than a number we cannot stand behind.
What the service covers
Every part of the form and the strategy behind it
- A trigger assessment confirming whether article 9A applies, with the height and storey calculation written down so the validation officer does not have to guess.
- Part 3 of the form, the competence statement for the author, within its 200 word limit.
- Part 4, the record of fire safety consultation undertaken and how the findings were addressed.
- Parts 5 and 6, the site layout plan with block numbering cross-referenced to the building schedule, plus the schedule itself covering height, storeys, proposed use, standards applied, balcony classification, external wall classification, evacuation approach, suppression and accessible housing to M4(2) or M4(3).
- Parts 7 and 8, technical complexities and departures from the standards named in the schedule, plus the issues affecting fire safety across balconies, external walls, evacuation, suppression and accessible housing.
- Part 9, how local development document fire safety policies have been incorporated.
- Parts 10 to 13, the fire service access proposals, emergency road vehicle access to site entrances, appliance siting and the firefighting water supply, including whether the scheme relies on existing operable hydrants.
- Part 14, the fire service site plan showing vehicle routes, appliance siting, personnel access, risers, assembly points, lift features and hydrant locations.
- For London major development, a standalone independent fire strategy addressing all six limbs of D12(B), with the competency evidence set out at the front.
- The evacuation lift position for D5(B5), coordinated with the accessible housing mix and with personal emergency evacuation planning where the scheme will need it in occupation.
- A consistency check between the fire statement and the emerging design so the Gateway 2 submission does not contradict what planning was told.
Our process
Concept first, form second
- 01
Trigger and scope
We confirm whether article 9A applies, whether D12(B) applies and which of the two documents your scheme needs. On a mixed scheme we do this block by block.
- 02
Concept fire strategy
We work with the design team on stair provision, access, water supply and evacuation approach while the layout can still move. This is the part that saves money.
- 03
Statement drafting
We complete the prescribed form to its word limits, build the building schedule and produce the fire service site plan, then sign as author.
- 04
Consultee engagement
We respond to the Building Safety Regulator and to fire and rescue service comments and we handle officer questions during determination.
- 05
Carry-through
We hand the concept strategy forward so the Gateway 2 support team develops it rather than starting again.
What you get
A submission the validation officer can accept first time
- The completed fire statement form, all 16 parts, signed and dated by the named author.
- The building schedule table, with a line for each use and storey combination.
- The fire service site plan and the block-numbered site layout plan.
- Where the scheme is major development in London, a standalone independent third party fire strategy addressing D12(B) with competency evidence at the front.
- A departures schedule listing every point where the design steps away from the named standards, with the justification for each.
- A short carry-forward note setting out what is fixed at planning and what remains open for Gateway 2.
What we need from you
Enough design to be honest about
- Site layout, floor plans, sections and elevations at current revision, with the height to the top storey floor level stated.
- The schedule of uses and unit numbers for each block, including any educational accommodation.
- Any pre-application correspondence with the local planning authority or the fire and rescue service.
- Access and highways information, including tracking drawings, road widths, gradients and hardstanding.
- Water supply information, including hydrant locations and mains capacity where it is known.
Why AL23 Safety
Fire engineering judgment, written in planning language
Independent by default
We are not your architect. Where D12(B) requires a third party suitably qualified assessor, we can be that party without an internal conflict to manage.
Accountable
If the layout will not support the access or the escape strategy, we say so while the drawings can still change rather than writing around it.
One team, three disciplines
Fire engineering, fire safety and health and safety in-house so the concept strategy at planning is written by the people who will defend it later.
UK wide
We prepare fire statements for schemes across the UK from our Manchester base, including London major development.
Before the application goes in
Planning is the cheapest place to fix a fire strategy
A fire statement written after the layout is frozen can only describe the problem. Bring us in while the stair cores and the appliance route are still negotiable.
Common questions
Answers, up front
Cannot see your question? Get in touch and we will answer it directly.
Contact usCount dwellings or educational accommodation first, then measure height and storeys. If the building has two or more dwellings and reaches 18 metres or 7 storeys, article 9A applies. Care homes, hotels and holiday lets do not count as dwellings for this test, which surprises people. We will run the check for you before you commit to anything.
The Building Safety Regulator, since 27 January 2026. It replaced the Health and Safety Executive under SI 2026/20. Some published guidance has not caught up and still names the HSE, which causes confusion at validation stage.
No. They are two different documents with two different triggers. The national form is triggered by the 18 metre or 7 storey relevant building test. Policy D12(B) is triggered by major development in London regardless of height. A scheme can need one, both or neither.
Policy D12(B) as adopted asks for an independent fire strategy produced by a third party suitably qualified assessor so an author inside the design team is difficult to defend. The competency criteria attached to that policy sit in unadopted draft guidance rather than in policy and boroughs interpret it with some variation. We recommend an external author and we set out the competency evidence at the front of the document.
A concept strategy and statement for a single block with a settled layout is quicker than a phased masterplan with several use classes. Cost is driven by the number of blocks, the number of use and storey combinations in the building schedule, whether a full D12(B) strategy is needed alongside the national form, plus how much design development is still required. We look at the drawings before we price the work rather than quoting blind.
No. Its statutory scope is planning matters only. Building Regulations compliance is tested at Gateway 2 by the Building Safety Regulator as building control authority and the Fire Safety Order applies once the building is occupied. The fire statement should be consistent with all of that but it does not discharge any of it.
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