Fire Statement in Newham

A Fire Statement is a written document, submitted as part of a planning application, that sets out how fire safety has been considered and designed into a development at the planning stage. It is not a full technical fire-engineering design — that comes later, at building control — but it demonstrates that the fundamental fire-safety decisions have been thought through before permission is granted, and that the scheme as drawn can actually accommodate a safe and workable fire strategy. In other words, it is the point at which fire safety becomes a planning matter rather than something left entirely to a later stage when the building's form is already fixed and difficult to change.

The document goes by more than one name, which causes some confusion. Under national law the required document for high-rise residential schemes is called a 'Fire Statement' and is submitted on a specific government form. Under the Mayor of London's London Plan it is required by Policy D12 and is sometimes called a Fire Statement, a Planning Fire Safety Strategy or a D12 statement, and for the largest and most complex buildings it is a fuller fire strategy. The essential purpose is the same across all of them: to show, in a document a planning case officer and fire-safety consultee can assess, how the development achieves a high standard of fire safety through its layout, access, escape provision, water supply and design features.

Crucially, a Fire Statement is about the things that planning actually controls or influences: where the building sits on the site, how fire appliances reach it and where they can stand, where the escape stairs and cores are, how occupants get out and gather safely, how firefighting water is supplied, and the broad approach to detection, alarm, compartmentation and external wall construction. These are precisely the matters that are hard or impossible to change once the building form is settled — which is exactly why the regime moved them to the planning stage. A Fire Statement written properly is a summary of a real fire strategy that has shaped the design; written badly, it is a generic document that describes a scheme the design cannot actually deliver.

For a Newham scheme, the practical significance is that the Fire Statement is a validation requirement on the applications that need one: without it, or with an inadequate one, the council can refuse to validate the application, or refuse the application itself. And on relevant high-rise buildings it triggers a statutory consultation with the Health and Safety Executive, whose advice the council must take into account before deciding. It is, in short, a document that can hold up or sink a major scheme if it is not done properly — and one that adds real value when it is.

There are two separate triggers, and a scheme can hit one, both or neither. The first is the Mayor of London's London Plan Policy D12, which requires a Fire Statement to be submitted with planning applications for major development. In planning terms 'major development' for housing means ten or more dwellings, or a site of 0.5 hectares or more; for other uses it means 1,000 square metres or more of floorspace, or a site of one hectare or more. Because Newham is a London borough, Policy D12 applies to every major application in the borough — so a great many Newham residential schemes need a D12 Fire Statement regardless of their height.

The second trigger is national: Planning Gateway One, introduced by changes to the planning regime that came into force on 1 August 2021. This requires a Fire Statement, on the government's prescribed form, for any planning application for a 'relevant building' — defined as a building that contains two or more dwellings (or educational accommodation) and is either 18 metres or more in height, or seven or more storeys. Height is measured from ground level to the floor surface of the top storey, excluding roof-top plant. For any building that meets that definition, the Fire Statement is a mandatory part of the application and the Health and Safety Executive becomes a statutory consultee that the council must consult before granting permission.

The two regimes overlap but are not identical, and it is worth being precise about the combinations. A large low-rise scheme — say twelve houses, or a block of flats of four or five storeys — is 'major development' and so needs a D12 Fire Statement, but is below the Gateway One height and storey thresholds, so it does not trigger the national form or HSE consultation. A tall residential building of eight storeys triggers both: it is major development under D12 and a relevant high-rise building under Gateway One. And a very small scheme — a single house, or a pair of flats in a low building — triggers neither national requirement, though the London Plan's broader expectation that all development achieves a high standard of fire safety still applies through Policy D12 Part A.

Because getting this wrong causes real delay — a missing or wrong-type Fire Statement is one of the commonest reasons a major application fails validation — we establish exactly which requirements your scheme triggers at the very start. We confirm the height and storey count against the Gateway One definition, check the major-development thresholds against your unit count and site area, and identify whether the HSE consultation will apply. That determines what has to be prepared, on which form, and by whom, and it lets us build the fire-safety case into the design from day one rather than discovering a gap at submission.

The London Borough of Newham lies in the east of the capital, north of the Thames, and was created in 1965 from the former county boroughs of East Ham and West Ham. For much of its modern history it was a place of docks, railways, gasworks and factories: the Royal Docks — the Royal Victoria, Royal Albert and King George V — were once the largest enclosed docks in the world, the Thames Ironworks built ships at Bow Creek, and the Lower Lea Valley was a dense industrial landscape. The closure of the docks and the decline of that industry in the second half of the twentieth century left the borough with vast tracts of brownfield land, and with it the raw material for one of the largest urban regenerations in Europe — a regeneration that has been delivered overwhelmingly in the form of high-density flats, many of them in tall buildings.

That regeneration crystallised around the 2012 Olympic and Paralympic Games. The Queen Elizabeth Olympic Park at Stratford, the transformed Stratford City and Westfield, the ExCeL exhibition centre in the Royal Docks and the emerging residential districts of Canning Town and the dockside have reshaped the borough's north and its riverside. Landmarks now range from the ArcelorMittal Orbit and the London Stadium to the Emirates Air Line cable car, the University of East London's dockside campus, and the historic Green Street market and Upton Park — the latter forever associated with West Ham United, whose former Boleyn Ground is itself now a housing development. The council frames much of this growth as its 'Arc of Opportunity', running from Stratford and the Olympic Park down the Lower Lea Valley and east through the Royal Docks to Beckton.

This geography is precisely why fire statements matter so much here. Newham has one of the densest concentrations of tall residential buildings in the country — the skyline of the Royal Docks, Canning Town and Stratford is now defined by apartment towers — and it has among the highest housing-delivery targets of any London borough, with the great majority of those homes being flats, many at height. The borough's own definition of a 'tall building' in its Local Plan is comparatively low: six or more storeys, so that what other places would call mid-rise is treated as tall in Newham. A large share of the schemes coming forward in the borough therefore sit at or above the point where fire statements and the gateway regime bite.

Newham also carries the legacy of that high-rise growth. The council has committed to a five-year Residential Building Safety Strategy to make all of its high-rise residential buildings safe by 2029 — a programme covering eighty-seven blocks, at a cost of around £63.5 million, to bring them into line with the post-Grenfell regime and the Building Safety Act 2022. That gives the borough an unusually direct, first-hand understanding of what fire safety in tall buildings means, and it sharpens the seriousness with which the council and its consultees scrutinise the fire-safety case for new development. For an applicant, knowing where your plot sits in this landscape — its height context, whether it is a tall-building location, its relationship to fire-service access and water infrastructure — is the starting point for a credible Fire Statement.

The Fire Statement exists because of a specific catastrophe. On 14 June 2017 a fire at Grenfell Tower in west London spread up the outside of the building through combustible cladding and killed seventy-two people. The disaster exposed profound failures across the whole system of designing, building, regulating and managing high-rise residential buildings, and it prompted the most significant overhaul of building safety in a generation. Part of that overhaul was the recognition that fire safety could not be left until building control; it had to be considered from the earliest design decisions, which are made at the planning stage.

The government commissioned Dame Judith Hackitt to carry out an independent review of building regulations and fire safety. Her final report, published in May 2018, made fifty recommendations and set out a new philosophy for high-risk buildings: a 'golden thread' of information carried through the building's whole life, clear accountability, and a series of 'gateways' at which safety must be demonstrated before a project can proceed. The government accepted the recommendations, and the result was the Building Safety Act 2022 and its three-gateway regime — Gateway One at planning, Gateway Two before construction, and Gateway Three at completion — together with the Building Safety Regulator and a much stricter regime for higher-risk buildings.

Planning Gateway One was the first of these to take effect, coming into force on 1 August 2021. From that date, planning applications for relevant high-rise residential buildings had to include a Fire Statement on a prescribed form, and the Health and Safety Executive — the body that hosts the Building Safety Regulator — became a statutory consultee on those applications. The purpose was simple and direct: to ensure that fire-safety considerations are genuinely inherent in the design before planning permission is granted, so that a scheme cannot receive permission for a form that cannot then be made safe. It closed the gap that Grenfell had so tragically exposed.

In London, the Mayor moved in parallel and, in some respects, further. The London Plan 2021 introduced Policy D12 on fire safety, requiring all development to achieve the highest standards of fire safety and requiring major development to be accompanied by a Fire Statement prepared by a suitably qualified professional — a requirement that reaches many schemes below the national high-rise thresholds. For a borough like Newham, with its exceptional concentration of tall and major residential development, these two overlapping regimes mean that fire safety is now a front-line planning issue on a large proportion of the schemes brought forward, and a well-prepared Fire Statement is central to getting them approved.

London Plan Policy D12 is the Mayor's fire safety policy, and it is the primary reason so many Newham schemes need a Fire Statement. The policy is in two parts. Part A applies to all development, requiring every proposal to achieve the highest standards of fire safety and to be designed to identify, manage and reduce the risk of fire — including safe means of escape for all building users, appropriate evacuation strategies, and suitable access and facilities for the fire and rescue service. Part B goes further and requires all major development to submit a Fire Statement, prepared by a suitably qualified and competent person, setting out how the scheme achieves those standards.

The policy is deliberately demanding and it is applied across all London boroughs, Newham included. The Mayor's supporting London Plan Guidance on fire safety fleshes out what is expected. It distinguishes between a fuller Fire Statement for major and more complex development and a more succinct Planning Fire Safety Strategy for smaller schemes, but the underlying content is consistent: the document must explain the fire-safety principles adopted, the site layout and access, the means of escape and evacuation strategy, the water supply for firefighting, and the design features that reduce fire risk. The guidance is clear that this is a planning-stage strategy, not a substitute for the detailed Building Regulations fire design, but it must be substantive enough for the council and its consultees to judge whether the scheme can be made safe.

London Plan Policy D12 also connects to two related policies that shape tall residential buildings in particular. Policy D5 on inclusive design requires that, in developments where lifts are installed, at least one lift per core is a suitably sized fire evacuation lift capable of being used to evacuate people who need level access — a significant provision for the elderly, disabled and mobility-impaired, and one that has to be designed into the cores from the outset. And Policy D3 and the design policies require the safe and dignified evacuation of all building users to be planned into the layout. Together these mean that in London the fire-safety expectation is not just 'stay put and wait for the brigade' but a genuinely designed, inclusive approach to getting people out.

For a Newham scheme the practical effect is that a D12 Fire Statement has to be prepared by a suitably qualified person — the Mayor's guidance points to an independent, suitably qualified chartered or incorporated engineer with appropriate fire-safety registration and membership of the Institution of Fire Engineers — and it has to describe a real strategy that the design can deliver. We prepare or coordinate the D12 Fire Statement as an integral part of the application, working with the right qualified professionals, so that the fire-safety case is made properly and the council can take the point as read rather than as an open question.

Planning Gateway One is the national fire-safety requirement at the planning stage, and it applies on top of the London Plan for the tallest residential schemes. Since 1 August 2021, a planning application for a 'relevant building' must include a Fire Statement on the government's prescribed form. A relevant building is one that contains two or more dwellings (or educational accommodation) and is either 18 metres or more in height, or has seven or more storeys — measured to the floor surface of the top storey, excluding roof-top plant, and counting storeys above ground level. For any scheme in Newham that meets this definition, the Fire Statement is mandatory and follows a defined national format.

The distinctive feature of Gateway One is the statutory consultee role of the Health and Safety Executive. The HSE — which hosts the Building Safety Regulator — must be consulted by the council on planning applications for relevant high-rise buildings, and the council must take its advice into account before granting permission. The HSE reviews the Fire Statement to check that fire safety has been genuinely considered at the planning stage, that the site layout supports fire-service access and firefighting, that the general approach to escape and evacuation is sound, and that there are no fundamental fire-safety problems baked into the proposed form. Its involvement means the Fire Statement is read by a specialist regulator, not just a general planning case officer.

The prescribed Gateway One Fire Statement covers a focused set of matters: the fire-safety principles and approach adopted in the design; the site layout, including the position of the building and its access; provision for fire-service vehicle access and for water supply for firefighting; and details of any fire-safety consultation undertaken. It is deliberately concentrated on the things planning controls — layout, access and water supply — because those are the matters that are difficult to change once permission is granted and that most affect whether the fire and rescue service can operate effectively. It does not replace the far more detailed fire design that follows at Gateway Two and building control.

For an applicant the important point is that Gateway One is a hard requirement, not a matter of judgement: if the building meets the relevant-building definition, the statement and the HSE consultation are unavoidable, and getting the statement wrong or thin invites objection from a specialist regulator. We identify at the outset whether a scheme is a relevant building, prepare the Gateway One Fire Statement on the correct form with the right technical input, and manage the HSE consultation through the application — so that the statutory fire-safety hurdle is cleared cleanly rather than becoming a source of delay or refusal.

Whichever regime applies, a Fire Statement is built around a consistent set of topics, and understanding them is the key to preparing a good one. The first is the fire-safety principles and approach adopted in the design: what fire strategy the building follows (for example, the evacuation philosophy — 'stay put' with compartmentation, or simultaneous evacuation, or a phased approach), and how that strategy informs the layout, the cores, the compartmentation and the escape provision. This is the intellectual spine of the document, and everything else follows from it. A statement that cannot articulate a clear, appropriate strategy for the building type and height is a statement that describes a design that has not really been thought through.

The second is the site layout and fire-service access. The statement must describe the position of the building on the site, the surrounding buildings and access routes, and — critically — how fire appliances will reach the building and where they can stand to work: road widths, turning circles, hardstanding, proximity to entrances and to the firefighting cores. It must also identify suitably positioned, unobstructed outside space that fire appliances can use and that can serve as an evacuation assembly point. On tight urban plots in Newham this is often one of the hardest requirements to satisfy, because the space for appliance access competes with everything else the plot has to accommodate.

The third is the means of escape and the evacuation strategy, and the fourth is the water supply for firefighting. The statement must explain how all building users — including disabled and mobility-impaired occupants — will get out safely in a fire, how the escape routes and stairs are arranged, and, in London, how the evacuation-lift requirement is met. It must also set out the arrangements for firefighting water: hydrants, mains capacity, and any dedicated firefighting supply, so that the fire and rescue service has the water it needs. These are the operational realities that decide whether a building is safe to fight a fire in and safe to escape from.

The fifth strand is the design features that reduce fire risk: detection and alarm systems, active measures such as sprinklers or other suppression, passive measures such as compartmentation and fire-resisting construction, and the approach to external walls and any cladding — a matter of intense scrutiny since Grenfell. Alongside these, the statement records the building's basic parameters (use, classification, number of storeys, occupancy) and any fire-safety consultation undertaken. A good Fire Statement pulls all of this together into a coherent, building-specific narrative that a planner and a fire-safety consultee can follow; a poor one recites generic paragraphs that could apply to any building and that the design cannot actually deliver.

One of the clearest lessons of the post-Grenfell reforms is that fire safety must be handled by people who are genuinely competent to do it. This is written into the London Plan requirement: a D12 Fire Statement must be produced by a suitably qualified and competent person, and the Mayor's guidance is specific about what that means. It points to an independent, third-party, suitably qualified professional — in practice a chartered or incorporated engineer with a fire-safety specialism and appropriate registration, typically with at least member-level status of the Institution of Fire Engineers. The point is that the person signing the statement must be able to demonstrate real fire-engineering knowledge and experience relevant to the complexity of the development.

'Independent' is an important word here. The intent is that the fire-safety assessment is not simply a self-certification by the design team but carries the input and, where appropriate, the sign-off of a suitably qualified fire professional who can give an objective view. On a straightforward major scheme the fire input may be relatively contained; on a complex tall building it will involve a dedicated fire engineer working alongside the architect and the wider design team from the earliest stages. The council and the HSE both expect to see that the statement is the product of genuine competence, not a template completed by a generalist.

This has a real bearing on how a project should be resourced. The temptation — especially on tighter budgets — is to treat the Fire Statement as a form to be filled in at the end, by whoever is available. That approach fails in two ways: the statement is not credible to the regulators, and, more fundamentally, the fire strategy it is meant to describe was never actually designed into the building. The right approach is to bring the appropriate fire-safety competence in at the start, so the strategy shapes the design and the statement simply records a strategy that already exists and works.

At Crown, we coordinate the fire-safety input for your scheme as part of a single, integrated design service. We work with suitably qualified fire engineers, brief them properly on the scheme, and make sure the fire strategy is developed alongside the architecture, structure and services rather than after them — so the Fire Statement is prepared by the right people, says what it needs to say, and describes a building that can genuinely be made safe. On the simplest schemes we prepare the planning fire-safety documentation directly; on complex tall buildings we lead the coordination and bring the specialist fire engineer into the team from day one.

A common misunderstanding is that the Fire Statement replaces, or duplicates, the fire-safety design done under the Building Regulations. It does neither. The Building Regulations — specifically Approved Document B, which gives practical guidance on meeting Part B of the regulations — govern the detailed fire-safety design of the building: the compartmentation, the fire resistance of elements, the travel distances to stairs, the protected lobbies, the fire doors, the detection and alarm, the smoke control, the external wall construction and the fire-service facilities. That work is done in detail after planning permission, and it is checked by building control (or, for higher-risk buildings, by the Building Safety Regulator at Gateway Two).

The Fire Statement operates one level up from that detail, at the planning stage. Its job is to demonstrate that the planning decisions — the building's form, its position on the site, its access, its escape strategy and its water supply — are consistent with a design that can go on to satisfy Part B. It has to show that the building can be made safe, not to prove in full detail that it has been. This is why the Fire Statement concentrates on layout, access, escape and water supply: those are the matters planning controls, and they are the matters that constrain what the detailed Part B design can later achieve. If the planning form makes a compliant Part B design impossible, that is a problem that has to be caught at the planning stage, and the Fire Statement is the mechanism for catching it.

In practice the two are deeply connected, because a Fire Statement written without a real understanding of Part B is worthless. The whole value of the planning-stage strategy is that it anticipates the Building Regulations design — it sets the escape strategy, the number and position of stairs, the compartmentation approach and the access and water arrangements in a way that Part B can then deliver. This is exactly why the statement must be prepared by someone with genuine fire-engineering competence: they are, in effect, sketching the fire strategy that the detailed Part B design will later flesh out.

For an applicant, the takeaway is that the Fire Statement and the Building Regulations fire design are two stages of one continuous process, not two separate exercises. We design them as a continuum: the planning-stage fire strategy that supports the Fire Statement is developed with the eventual Part B design in mind, so that permission is granted for a scheme that can actually be built and signed off, rather than one that has to be redesigned when the building-control detail exposes a fire-safety problem the planning form cannot solve.

The Fire Statement is the planning-stage element of a much larger safety regime created by the Building Safety Act 2022, which implemented the recommendations of the Hackitt review. The Act established a new, far more rigorous approach to 'higher-risk buildings' — broadly, buildings of at least 18 metres or seven storeys containing at least two residential units — overseen by the Building Safety Regulator, which sits within the Health and Safety Executive. It is the same body, the HSE, that acts as the statutory consultee at planning, which gives a welcome consistency: the regulator that reviews the Fire Statement at Gateway One is part of the organisation that will oversee the building through its construction and life.

The Act's regime is built around three gateways. Gateway One is the planning stage — the Fire Statement and the HSE consultation described on this page. Gateway Two is a hard stop before construction begins: for higher-risk buildings, the full detailed design must be approved by the Building Safety Regulator before work can start on site, a much more demanding process than traditional building control. Gateway Three is at completion, when the Regulator must be satisfied the building has been built in line with the approved design before it can be occupied and registered. The gateways are sequential and each is a genuine checkpoint, which is a profound change from the old system in which fire-safety design could evolve informally right through construction.

Running through all three gateways is the 'golden thread' of information — a recommendation of the Hackitt review now embedded in the Act. The golden thread is a complete, accurate, accessible and up-to-date digital record of the building's design, construction and safety information, maintained throughout its life so that everyone responsible for the building understands it and can keep it safe. For a new higher-risk building the golden thread begins to form at the design stage, and the fire strategy that underpins the Fire Statement is one of its earliest and most important components. Getting the fire thinking right at Gateway One is therefore the first link in a chain that continues for the whole life of the building.

The reason all of this matters at the Fire Statement stage is that a scheme heading for higher-risk status has to be designed, from the very start, to pass not just planning but Gateway Two and Gateway Three as well. A building whose form is settled at planning without regard to the far stricter Gateway Two design approval is storing up trouble. We design tall and higher-risk buildings with the whole gateway regime in mind, so the planning-stage fire strategy and the Fire Statement are the opening moves of a coherent journey to a building the Regulator will approve — not an isolated document that ignores what comes next.

For tall residential buildings — which are common in Newham — two design requirements now bear directly on the fire strategy and, therefore, on the Fire Statement. The first is the second-staircase rule. Following amendments to the statutory guidance in Approved Document B, new residential buildings with a top occupied storey at or above 18 metres must be provided with more than one common staircase. The requirement comes into force on 30 September 2026, with transitional arrangements for schemes already sufficiently progressed by that date (broadly, work started and sufficiently advanced by then or within eighteen months, up to 30 March 2028). It responds directly to the fire-safety concerns raised after Grenfell, giving occupants and firefighters a second, independent protected escape and access route.

This rule has a major effect on the design of any tall Newham scheme, and it is exactly the kind of thing a Fire Statement has to grapple with at the planning stage. A stair core is one of the largest and least flexible elements of a building's plan, and providing two of them fundamentally changes the floor layout, the efficiency, the number of flats per floor and the viability of a tall building. Because the escape strategy is central to the Fire Statement, a scheme at or above 18 metres has to show a credible two-staircase arrangement in its planning-stage fire strategy, not discover the need for it after permission when the form is fixed. Getting the second staircase into the design from the first sketch is one of the clearest examples of why fire safety belongs at the planning stage.

The second requirement concerns evacuation lifts. In London, Policy D5 requires that where lifts are installed, at least one lift per core is a suitably sized fire evacuation lift, capable of evacuating people who need level access — a vital provision for disabled, elderly and mobility-impaired occupants who cannot use stairs in an emergency. The evolving national guidance is moving in the same direction, expecting evacuation-lift provision alongside the second staircase in the tallest residential buildings. Evacuation lifts, like second stairs, take space and have to be positioned and sized correctly within the cores, so they too must be planned into the layout from the start and described in the Fire Statement.

Together, the second-staircase rule and the evacuation-lift requirement mean that the fire strategy for a tall Newham building shapes its whole plan — the number, size and position of the cores, the number of flats per floor, the efficiency of the building and, ultimately, its viability. This is precisely why we develop the fire strategy alongside the architecture from the outset on any tall scheme, and why the Fire Statement is best prepared by a team that has designed those elements in rather than one asked to describe them after the event. On tall buildings, fire safety is not a constraint bolted onto the design; it is one of the primary drivers of the design.

A Newham application is judged against the Newham Local Plan 2018 — adopted in December 2018 as a fifteen-year plan looking ahead to 2033 — read together with the London Plan 2021 and national policy. On fire safety, the London Plan's Policy D12 does much of the heavy lifting, because it applies across all London boroughs and directly requires the Fire Statement for major development. But Newham's own Local Plan and its approach to tall buildings add local context that shapes how fire safety is treated in the borough, and the borough's own building-safety programme makes it a particularly well-informed and attentive authority on these matters.

Newham's Local Plan takes tall buildings seriously and defines them at a comparatively low threshold. The borough's Tall Buildings Study, part of the Local Plan evidence base, treats a tall building as one of six or more storeys — so buildings that many authorities would regard as mid-rise are 'tall' in Newham's terms, and 'mid-rise' in the borough is roughly six to eight storeys. The plan steers height to appropriate locations, chiefly the opportunity areas and town centres of the Arc of Opportunity, and requires taller schemes to be justified on design, townscape and amenity grounds. Because so many Newham schemes are at or near the point where the fire-statement and gateway thresholds bite, fire safety is a live consideration on a large share of the borough's applications.

The council's design and safety policies require development to provide for safe evacuation and to design in fire safety, echoing and reinforcing the London Plan. In practice, on a major or tall scheme in Newham you can expect the fire-safety case to be scrutinised carefully: the council will look for a proper Fire Statement by a suitably qualified person, will consult the HSE on relevant high-rise buildings, and will expect the escape strategy, fire-service access, water supply and — on tall buildings — the second-staircase and evacuation-lift provision to be demonstrated. The borough's own experience of retrofitting fire safety into eighty-seven existing high-rise blocks under its 2024–2029 Residential Building Safety Strategy gives it an acute, practical appreciation of what fire safety in tall buildings actually requires.

Because the exact policy numbering and detailed requirements evolve as the Local Plan is reviewed and the London Plan is updated, we confirm the current applicable policies and validation requirements for your specific site at the start of every project. We then design the fire strategy and prepare the Fire Statement to meet the London Plan Policy D12 requirement, the Gateway One requirement where it applies, and Newham's local expectations together — so the fire-safety case is made against every relevant test rather than a generic one, and the council can take it as read.

It helps to see how the fire-statement requirements land on the different kinds of scheme brought forward in Newham. The largest and most obvious case is a residential tower or tall block in one of the opportunity areas — the Royal Docks, the Lower Lea Valley, Canning Town or around Stratford — where a building of eight, ten, twenty or more storeys is squarely a relevant high-rise building under Gateway One and major development under D12. Here the Fire Statement is central: it triggers the HSE consultation, it has to show a credible two-staircase arrangement and evacuation lifts, it has to demonstrate fire-service access and water supply on what are often tight, complex sites, and it is prepared by a dedicated fire engineer working within the design team from the outset.

A common middle case is a mid-rise apartment building of, say, five to eight storeys on a regeneration or infill plot. If it reaches 18 metres or seven storeys it is a relevant high-rise building and hits both regimes; if it is a little lower it may be major development (ten or more flats) and so need a D12 Fire Statement without triggering Gateway One or the HSE consultation. Newham's low tall-building threshold — six storeys — means many of these buildings are treated as tall in local terms even where they fall just below the national high-rise thresholds, so the fire-safety case still receives real attention. Establishing exactly where a mid-rise scheme sits against the thresholds is one of the first things we do.

A third case is a larger low-rise residential scheme — a terrace of houses, or a small block of a few storeys, that reaches ten or more dwellings or half a hectare. This is 'major development' and so needs a D12 Fire Statement (or the more succinct planning fire safety strategy the Mayor's guidance allows for simpler schemes), even though it is well below the high-rise thresholds and does not involve the HSE. The fire-safety case here is more contained — a low-rise building has simpler escape and access requirements — but the document still has to be prepared properly by a suitably qualified person and describe a real strategy.

Finally, there are the schemes that trigger neither national requirement — a single house, a pair of flats, a small extension — where a formal Fire Statement is not required but the London Plan's general expectation of a high standard of fire safety still applies, and good design still has to provide safe escape and sensible fire-service access. Across all these cases the principle is the same: we identify exactly which requirements apply, design the fire strategy to suit the scheme's scale and height, and prepare the right document — full Fire Statement, planning fire safety strategy, or none — so the application is neither under-prepared nor burdened with a document it does not need.

Our approach to the Fire Statement starts long before anyone writes a word of it, because the statement is a record of a fire strategy that has to be designed into the building. At feasibility we establish whether the scheme is major development, whether it is a relevant high-rise building, and therefore which requirements apply — the D12 Fire Statement, the Gateway One statement and HSE consultation, or a more succinct planning fire safety strategy. That determines who needs to be involved and when, and it lets us set the escape strategy, the cores, the fire-service access and the water supply as fundamental design decisions from the first concept rather than as afterthoughts.

On tall and complex schemes we bring a suitably qualified fire engineer into the team at the concept stage. Working with the architect, the structural engineer and the building-services designer, they help set the evacuation philosophy, the number and position of stairs (including the second staircase on buildings at or above 18 metres), the evacuation-lift provision, the compartmentation approach, and the fire-service access and water-supply arrangements. Because these decisions shape the plan so profoundly, taking them early — with real fire-engineering competence — is what makes the eventual building both safe and viable. The Fire Statement then records a strategy that already exists and works.

We prepare the statement itself to suit the regime that applies. For a Gateway One relevant building it is completed on the government's prescribed form, covering the fire-safety principles, the site layout and access, the fire-service vehicle access and water supply, and the consultation undertaken, with the supporting fire strategy behind it. For a D12 major-development scheme it is prepared to the Mayor's guidance, either as a full Fire Statement or, on simpler schemes, as the more succinct planning fire safety strategy, and signed off by the suitably qualified person the policy requires. Throughout, the document is written to be building-specific and coherent — a real narrative a case officer and the HSE can follow — rather than a generic template.

Crucially, the Fire Statement is coordinated with everything else in the application. The escape strategy it describes has to match the floor plans; the fire-service access has to match the site plan and landscaping; the evacuation lifts and second staircase have to appear in the cores on the drawings; and the whole fire approach has to be consistent with the structure (which provides the compartmentation and fire resistance) and the services. Because Crown designs the architecture, structure and services together and coordinates the fire input, the Fire Statement and the drawings tell one consistent story — which is exactly what the regulators are looking for, and exactly what a fragmented, last-minute approach fails to deliver.

A Fire Statement is one document in a package, and on a major or tall Newham scheme that package is substantial. The application will typically include the existing and proposed drawings (site plan, floor plans, elevations and sections), a planning statement, a design and access statement, and a suite of technical documents that varies with the site: a flood risk assessment and drainage strategy, an energy statement, a daylight and sunlight assessment, a transport statement, a contamination report, an arboricultural report, a heritage statement where relevant, and an affordable-housing and viability position on qualifying schemes. The Fire Statement sits within this package and has to be consistent with all of it.

The connections run in several directions. The Fire Statement's escape strategy and core layout have to match the floor plans and the design and access statement. Its fire-service access and unobstructed outside space have to be reconcilable with the site plan, the landscaping, the drainage and the amenity and play space — all of which compete for the same limited ground on a tight plot. Its evacuation-lift and second-staircase provision affect the internal layout, the unit count and therefore the housing mix and viability. And its treatment of external walls and cladding connects to the elevations, the materials and the energy and fabric strategy. A Fire Statement drawn up in isolation from these documents will contradict them, and those contradictions are exactly what a careful case officer or the HSE will seize on.

This is why the Fire Statement cannot sensibly be treated as a standalone deliverable produced at the end by a separate consultant. It is an integral part of a coordinated application, and the fire strategy it describes has knock-on effects across the whole scheme — on the layout, the unit count, the amenity, the site plan and the viability. The best applications are the ones where the fire strategy was one of the design drivers from the start, so that the Fire Statement, the drawings and the other documents all describe the same, coherent building.

We prepare the whole application as one coordinated package, with the Fire Statement and the fire strategy woven in from the outset. That means the fire-safety case supports, rather than contradicts, the rest of the application; the case officer and the HSE see a consistent scheme; and the fire requirements have been reconciled with everything else the plot has to accommodate before submission rather than exposed as conflicts afterwards. On a major or tall scheme, that coordination is one of the single biggest factors in a smooth passage through validation and determination.

The commonest and most avoidable failure is simply omitting the Fire Statement, or submitting the wrong type. A major-development application without a D12 Fire Statement, or a relevant high-rise application without a Gateway One statement on the correct form, can fail validation outright — the council will not even start to assess it until the missing document is provided. This is a pure process failure, entirely avoidable by establishing at the outset which requirements the scheme triggers, and it is one of the most frequent reasons major applications stall at the very first hurdle.

The second common failure is a generic, template Fire Statement that is not specific to the building. Regulators — and the HSE in particular — can spot a statement that recites standard paragraphs without engaging with the actual scheme: no clear evacuation philosophy for this building's height and type, vague or absent detail on fire-service access and water supply on this site, no real account of the escape strategy, the cores or the external wall construction. A statement like this fails to demonstrate that fire safety has genuinely been considered, which is the entire point of the exercise, and it invites objection or a request for far more information.

The third failure is a mismatch between the Fire Statement and the design. The statement describes a two-staircase building but the plans show one stair; it claims fire appliance access that the site plan cannot accommodate; it assumes water supply or hardstanding that is not shown; or its escape strategy does not fit the floor layout. These contradictions arise when the fire strategy was not designed into the scheme but written up afterwards to match a fixed design that cannot actually support it — and they are precisely what a specialist consultee looks for. They can force a wholesale redesign after permission, or a refusal, or a difficult and expensive amendment.

The fourth is leaving fire safety too late in the design, so that fundamental requirements — the second staircase on a tall building, the fire-service access on a tight plot, the evacuation lifts, the unobstructed outside space — cannot be accommodated once the form is fixed. Fire safety is a primary design driver on major and tall schemes, not a finishing touch, and discovering a fire-safety problem after the layout is settled is one of the most costly mistakes in the whole process. Our approach — establishing the requirements at the outset, bringing in the right fire competence early, and designing the strategy into the building from the first concept — is aimed squarely at avoiding every one of these failures.

The Fire Statement rarely travels alone. On a major or tall residential scheme it sits within a full suite of supporting documents, several of which interact with it directly. The design and access statement, which explains the design rationale and how the scheme is accessed, has to be consistent with the fire strategy — the cores, the escape routes, the fire-service access and the inclusive-evacuation provision all appear in both. The planning statement, which sets out how the scheme meets the development plan, will reference the fire-safety policies and the Fire Statement as part of the policy case. And the transport statement and site plan have to reconcile fire-appliance access and hardstanding with the wider access and servicing strategy.

Several technical documents share ground with the Fire Statement. The drainage and flood-risk documents matter because escape and fire-service access have to work even in flood conditions on Newham's low-lying sites. The energy and fabric strategy connects to the external wall construction and cladding, which the Fire Statement addresses and which is under intense scrutiny post-Grenfell. On the largest schemes, a full fire strategy report or fire-engineering report may sit behind the Fire Statement, providing the detailed reasoning the summary statement distils. And after permission, the detailed Building Regulations Part B design and, for higher-risk buildings, the Gateway Two submission to the Building Safety Regulator take the fire thinking to its full technical depth.

There are also related fire documents that belong to different stages of a building's life and should not be confused with the planning Fire Statement. A fire risk assessment under the Regulatory Reform (Fire Safety) Order is an operational assessment of an occupied building, carried out and kept up to date by the responsible person — a different exercise from the planning-stage Fire Statement, though the two are connected by the golden thread of information. Understanding which document belongs to which stage — planning, construction, occupation — is part of getting the whole safety picture right, and it is something we help clients navigate.

Because these documents overlap and have to be consistent, they are best prepared together by a coordinated team. We prepare or coordinate the design and access statement, the planning statement and the technical reports alongside the Fire Statement, so the fire strategy is reflected consistently across the whole application and does not contradict the very documents that are meant to support it. On a major scheme, that internal consistency is what makes the application easy for the council and the HSE to assess and hard for them to object to.

The cost of preparing a Fire Statement depends heavily on the scale and complexity of the scheme. For a straightforward major low-rise development, a planning fire safety strategy or a contained Fire Statement by a suitably qualified person is a relatively modest part of the overall design cost. For a complex tall building that is a relevant high-rise, involving a dedicated fire engineer working within the design team from concept stage, developing a full fire strategy and the second-staircase and evacuation-lift arrangements, the fire input is a more significant line — but it is proportionate to the risk, and it is far cheaper to do properly at the start than to fix after a refusal or a Gateway Two rejection. We scope the fire-safety work to your specific scheme and give you a clear fee before any work begins.

The Fire Statement itself does not carry a separate council fee — it is part of the planning application — but you should budget for the wider costs of a major application: the council's planning application fee, which is set nationally and scales with the number of dwellings; any pre-application advice fee; the specialist reports the scheme needs (flood, drainage, transport, daylight, energy, contamination and so on); and, on qualifying schemes, the Community Infrastructure Levy (both the Newham borough CIL and the Mayoral CIL on the net new floorspace) and any Section 106 obligations. The fire input sits within the design fees rather than the council's charges, and we set the whole picture out at the start so there are no surprises.

On timescales, the fire strategy is developed alongside the design, so it does not usually add a separate block of time — provided it is started early. What does add time is leaving it late: discovering a fire-safety problem after the design is fixed, or having to redesign to accommodate a second staircase or fire-service access that was not planned in, can cost weeks or months. On relevant high-rise buildings the HSE consultation runs as part of the application period, and a well-prepared Fire Statement that the HSE can readily assess helps that consultation run smoothly rather than generating requests for further information that delay the decision.

The broad economics are the same as with every part of a major scheme: money is rarely lost on doing the fire-safety work properly and early, and it is frequently lost on refusals, redesigns, failed validations and Gateway Two rejections caused by fire-safety problems that should have been caught at the planning stage. A credible Fire Statement, describing a fire strategy genuinely designed into the building, is one of the most cost-effective investments you can make in getting a Newham major or tall scheme approved and built.

The process starts with feasibility. We survey the site, confirm its planning history and constraints, and establish which fire-safety requirements the scheme triggers — whether it is major development under D12, a relevant high-rise building under Gateway One, or both — so the fire strategy can be built into the design from the first concept. On tall schemes this is where the escape strategy, the cores, the second staircase and the fire-service access are first set, and where the fire engineer joins the team. Getting this right at feasibility is what prevents the costly late surprises that derail so many major applications.

Newham offers pre-application advice, and on a major or tall scheme it is very often worth using — particularly where the building is high-rise, sits on a constrained site, or raises a finely balanced design question. A written steer from the council reduces the risk of a refusal and flags concerns early, and on relevant high-rise buildings early engagement with the HSE's Planning Gateway One service can be valuable in surfacing fire-safety issues before the formal application. We prepare and manage the pre-application process where it adds value, and use it to test the fire strategy alongside the rest of the design.

We then prepare the full drawing package and supporting documents — including the Fire Statement on the correct basis for the scheme — submit the application to Newham through the Planning Portal, and manage it through validation and determination. On a relevant high-rise building the council consults the HSE as statutory consultee, and we manage that consultation, responding to the HSE's and the case officer's queries and providing additional fire-safety information where it is needed. Minor applications run against an eight-week statutory target from validation and major applications against a thirteen-week target, with larger or committee-decided schemes commonly taking longer.

Once permission is granted, the fire thinking continues into the detailed design. The planning-stage fire strategy is developed into the full Building Regulations Part B design, and for higher-risk buildings the scheme goes to the Building Safety Regulator for Gateway Two approval before construction and Gateway Three before occupation. Because we design the fire strategy with the whole gateway journey in mind, the Fire Statement is the opening move of a coherent process that carries through to a building the Regulator will approve — rather than an isolated planning document that ignores what has to follow.

Crown Architecture prepares major and tall residential schemes across Newham and the surrounding east London boroughs, and we handle fire safety as an integral part of a single coordinated design service — the architecture, the structure, the building services and the fire strategy developed together. That matters more on the fire-safety case than on almost any other aspect of a scheme, because the fire strategy shapes the building's form, its cores, its unit count and its viability, and it has to be reconciled with the structure that provides the compartmentation, the services that run through it, and the site plan that has to accommodate fire-service access. Designed in isolation, the fire strategy clashes with everything else; designed together, it makes the building both safe and buildable.

We know the regime that applies in Newham: London Plan Policy D12 and the Fire Statement it requires for major development; Planning Gateway One and the relevant-high-rise threshold that brings in the national form and the HSE consultation; the second-staircase rule from 30 September 2026 and the evacuation-lift requirement; the Building Safety Act's three gateways and the golden thread; and Newham's own low tall-building threshold and its serious, first-hand focus on high-rise safety through its 2024–2029 building-safety programme. We use that knowledge to establish the right requirements at the outset and to design the fire strategy to meet them all together.

Just as importantly, we bring the right competence in at the right time. On simpler major schemes we prepare the planning fire-safety documentation directly; on complex tall buildings we lead the coordination and bring a suitably qualified fire engineer into the team from the concept stage, so the Fire Statement is prepared by the people the policy requires and describes a strategy that has genuinely shaped the design. We prepare a coordinated, self-consistent application in which the Fire Statement, the drawings and the other documents all describe the same coherent building — which is exactly what the council and the HSE are looking for.

And we stay with the project. We manage the application through Newham's validation and determination, manage the HSE consultation on relevant high-rise buildings, respond to queries, and then carry the fire thinking forward into the detailed Building Regulations design and, for higher-risk buildings, the Building Safety Regulator's Gateway Two and Gateway Three processes. The aim is a single, accountable point of contact and a coherent fire-safety journey from the first concept to a building that is approved, built and safe — rather than a Fire Statement handed over in isolation and a client left to navigate the regulators alone.

If you are planning a major or tall residential scheme in Newham, send us the site details and what you have in mind, and we will tell you honestly which fire-safety requirements apply, how they will shape the design, and how to get the scheme approved.