Why fire safety appears at planning stage
Policy D12 asks applicants to consider matters that can be affected by the layout of a site and building: access for fire appliances, escape, assembly arrangements, fire spread and facilities for firefighting. These matters can affect the feasibility of a design before detailed building regulations drawings are produced. [1]
For a small home project, the planning question might be whether an extension blocks existing access, changes the way occupants escape or introduces a relevant external-layout issue. The information should explain the actual proposal rather than paste a generic paragraph saying that the eventual builder will comply.
What does the council want?
Read the relevant borough's current validation instructions. Redbridge expressly asks for a Planning Fire Safety Strategy for householder applications unless a Reasonable Exceptions Statement applies. This provides a practical example of a borough implementing D12 proportionately: the first task is to establish which document is appropriate. [2]
A useful brief asks the designer to identify the existing situation, the proposed changes and the planning-related fire matters affected. Coordinate any explanatory drawing with the submitted site and floor plans. Where the project has no relevant effect, explain that conclusion using the council's accepted exception procedure rather than silently omitting the subject.
The NPPF published on 17 August 2026 also requires application information to be proportionate and relevant under DM2. A borough-specific document request should therefore be read with both the proposal's effects and the national approach in mind. [3]
Do not confuse three different documents
A proportionate householder strategy is not the same as London's independent Fire Statement for all major development under D12(B). Nor is it the statutory planning gateway one fire statement, which applies to particular relevant buildings and application types. Those routes have different triggers and submission expectations. [1] [4]
A small extension should not be commissioned as though it were a major residential block without first checking the actual requirement. Conversely, a short householder template is not an appropriate substitute where the major-development or gateway route applies.
Who prepares it, and what happens later?
Ask the project designer to establish the planning scope and bring in a competent fire specialist where the issues exceed the designer's expertise. The major-development Fire Statement has an explicit independent, suitably qualified assessor requirement; do not assume that this requirement automatically applies to every minor statement. [1]
Planning fire-safety information does not replace the building regulations design and approval process. Keep decisions made at planning stage available to the later design team so the technical scheme does not contradict the access or escape principles previously assessed. [4]
The draft new London Plan remains a proposal as at 2 October 2026. It should be monitored for future changes to the policy framework, but should not be presented as having already replaced D12. [5]