What is a Planning Fire Safety Strategy?
A Planning Fire Safety Strategy is a report that is required as part of the planning process and demonstrates that the development proposals achieve the highest standards of fire safety.
After the disastrous Grenfell Tower fire on 14 June 2017, the government commissioned the Independent Review of Building Regulations and Fire Safety led by Dame Judith Hackitt. The review highlighted the need to transform the fire and building safety regime and recommended that: "some minimum requirements around fire safety will need to be addressed when local planning authorities are determining planning applications and will require input from those with the relevant expertise.”
Peter Baker, Chief Inspector of Buildings, at Health and Safety Executive said that the changes would: “ensure that fire safety is considered from the very beginning of a building’s life and that developments benefit from integrated thinking on fire safety.”
Following the Hackitt Review, new planning requirements came into force on 1st August 2021, known as ‘Gateway One’ which has two key components:
to require the developer to submit a Fire Statement setting out fire safety considerations specific to the development with a relevant application for planning permission for development which involves one or more ‘relevant buildings’, and
to establish the Health and Safety Executive as a statutory consultee for relevant planning applications
‘Relevant buildings’ at Planning Gateway One contain two or more dwellings or educational accommodation and meet the height condition: 18m or more in height, or 7 or more storeys.
Shortly before, and in anticipation of the introduction of Gateway One, a new London Plan was published in March 2021 which stated that: “The matter of fire safety compliance is covered by Part B of the Building Regulations. However, to ensure that development proposals achieve the highest standards of fire safety, reducing risk to life, minimising the risk of fire spread, and providing suitable and convenient means of escape which all building users can have confidence in, applicants should consider issues of fire safety before building control application stage, taking into account the diversity of and likely behaviour of the population as a whole.”
To this end, the London Plan established ‘Policy D12 – Fire Safety’.
Policy D12 – Part A states:
“In the interests of fire safety and to ensure the safety of all building users, all development proposals must achieve the highest standards of fire safety and ensure that they:
1) identify suitably positioned unobstructed outside space:
a) for fire appliances to be positioned on
b) appropriate for use as an evacuation assembly point
2) are designed to incorporate appropriate features which reduce the risk to life and the risk of serious injury in the event of a fire; including appropriate fire alarm systems and passive and active fire safety measures
3) are constructed in an appropriate way to minimise the risk of fire spread
4) provide suitable and convenient means of escape, and associated evacuation strategy for all building users
5) develop a robust strategy for evacuation which can be periodically updated and published, and which all building users can have confidence in
6) provide suitable access and equipment for firefighting which is appropriate for the size and use of the development.”
To demonstrate development proposals have achieved the highest standards of fire safety and satisfy the requirements of Policy D12 Part A, applicants should submit a Planning Fire Safety Strategy (PFSS).
Where the applicant considers parts of or the whole policy do not apply, this should be justified in a Reasonable Exception Statement (RES).
Part B of Policy D12 relates only to major development proposals, i.e., those that meet the criteria of Gateway One (contain two or more dwellings or educational accommodation and meet the height condition: 18m or more in height, or 7 or more storeys), and requires the submission of a Fire Statement; a more comprehensive version of a Planning Fire Safety Strategy.
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