Does the requirement depend on height?
No. The London Plan requirement applies to all major development, not only to buildings reaching the gateway one height or storey thresholds. Westminster's guidance expressly distinguishes the London requirement from the additional national gateway process. Check whether the planning proposal is major rather than using height as the sole screening test. [2]
A mixed-use or commercial project can therefore need a London Fire Statement even though it is not a tall residential building. Where gateway one also applies, establish whether coordinated documents can satisfy both requirements without omitting the prescribed national information. [1] [3]
What should it explain?
The London Plan identifies the principal subjects: the building's construction approach, materials and products; escape arrangements, including for people who need assistance; measures to limit fire spread; access and facilities for firefighting; and how fire safety will be maintained through future changes. These matters should relate to the scheme being submitted. [1]
The useful output is not a list of regulations. Ask the assessor to identify the assumptions that influence the layout, then show where those assumptions appear on the architectural and site drawings. Highlight any aspect that still needs a design decision rather than describing an unresolved issue as compliant.
For example, the team should be able to trace the proposed fire-service access from the site plan into the statement. Likewise, a proposed escape principle should be consistent with the cores and circulation shown on the submitted floor plans.
Who should be appointed?
Policy D12 calls for an independent third-party assessor with suitable qualifications. Its supporting text refers to relevant fire-engineering competence and experience, proportionate to the scale and complexity of the project. Ask the proposed assessor to explain both their independence and their experience of comparable buildings. [1]
Set out the appointment carefully. A planning-stage statement, ongoing fire-engineering design, construction inspections and a later operational fire risk assessment are different tasks. Do not assume they are all included in a quotation simply because it uses the phrase “fire strategy”.
Coordinate it before the layout is fixed
The point of planning-stage assessment is to address issues early, while access and layout can still change. National gateway guidance similarly explains that land-use planning fire matters should be integrated at the earliest stage rather than deferred wholesale to technical approval. [3] [4]
Before submission, check the drawing revision list, the extent of the development covered and any reliance on adjoining land or existing facilities. If the scheme changes, ask the assessor to confirm whether the statement remains valid for the revised design.
The draft new London Plan is under consultation until 15 October 2026. Its emerging provisions are not adopted replacements for the requirements described here. [5]