New requirements for planning applications in England
Following the tragic events at Grenfell Tower in 2017, the government commissioned Dame Judith Hackett to carry out an independent review of building regulations and fire safety. The ‘Hackitt Report’, as it is commonly known, stated that
“Some minimum requirements around fire safety will need to be addressed when local planning authorities are determining planning applications. This will require input from those with the relevant expertise”.
As a consequence, planning applications made on or after the 1st August 2021, will require a developer to submit a ‘fire statement’ as part of the pack of information for relevant buildings.
This requirement is in accordance with the Town and Country Planning (Development Management Procedure and Section 62A Applications) (England) (Amendment) Order 2021.
The aspiration of this requirement is to ensure that both applicants and planning authorities consider issues relevant to fire safety at the earliest opportunity.
Additional Requirements for Projects in Greater London
The Mayor of London has published The London Plan 2021. This document came into effect on 2nd March2021 and sets out the Mayor of London’s spatial development strategy. It provides the framework for how London will develop over the next 20-25 years.
Policy D5 and D12 of The London Plan place additional requirements for planning applications for relevant buildings in Greater London. Examples include mitigation for the use of a ‘stay-put’ evacuation strategy, the inclusion of additional evacuation lifts and more onerous requirements for the qualifications of fire safety consultants producing fire statements.
Which Planning Applications Require A Fire Statement?
All planning applications for relevant buildings will require a fire statement. A relevant building is described as any building which;
• Contains 2 or more dwellings or educational accommodation, and
• Is either 18m or more in height, or has 7 or more storeys.
In addition, fire statements are also required for applications in the following circumstances;
• The redevelopment of an existing relevant building.
• A development within the curtilage of a relevant building.
Do Outline Planing Applications Require A Fire Statement?
The intention of the new legislation is to ensure that developers and planning authorities consider fire safety at the earliest opportunity. This would imply that a fire statement should be provided with outline planning applications. However, for projects outside of greater London this is not the case and the inclusion of a fire statement for outline planning applications is not a statutory requirement.
In Greater London, to comply with The London Plan, an outline fire statement should be provided with outline planning applications for relevant buildings.
What Is An Outline Fire Statement?
An outline fire statement is a brief summary of the fire safety considerations for a relevant building. The London Plan describes it as a ‘high-level’ document which is less detailed than the fire statement provided as part of a full planning application.
The Mayor of London has produced a guidance note which details how an outline fire statement should be completed.
What Is a Fire Statement?
A fire statement is evidence that fire safety matters have been considered as part of the planning application. The information within the fire statement should be focused and concise. It should be specific and relevant to the development. It should also reflect the scale, type and complexity of the proposed building.
The fire statement must include any specific technical complexities within the building. Fire Safety consultants will be required to highlight any aspects of the proposed design which departs from standard guidance. Consultants should provide as much detail as possible to demonstrate that fire safety has been adequately considered and incorporated into the plans. This may include a summary of any mitigation used to justify a departure from standard guidance.
It should be noted that the information required for inclusion in a fire statement relating to a project in greater London is more onerous than from projects elsewhere in the country.
How is Fire Statement Produced?
The Secretary of State has published a standardised form which can be completed by a suitably qualified fire safety consultant. The publication of a standard form is intended to ensure consistency in the way in which information is provided. It also intends to ensure that information contained within a fire statement is focused on fire safety matters as they relate to land use planning.
The standardised form produced by The Secretary of State does not incorporate the additional requirements imposed by The London Plan. As such, fire safety consultants must create a document independently which demonstrates that Policy D5 and D12 of The London Plan have been adequately considered.
Both the Secretary of State and the Mayor of London have produced separate guidance notes which outline how a fire statement should be completed.
Who can Produce a Fire Statement?
Strict requirements for qualifications and experience are placed on fire safety consultants permitted to write a fire statement. Whilst the requirements are similar throughout England, the London Plan does impose more onerous requirements of the author. The requirements are listed below.
|Town and Country Planning|
Procedure and Section 62A
(Amendment) Order 2021
|London Plan 2021|
|The engineer must be registered with the Engineering Council with the post-nominals IEng(Incorporated Engineer) or CEng(Chartered Engineer) after their name.||YES||YES|
|The engineer should also be registered with the Institute of Fire Engineers with the post nominals MIFireE after their name.||NO||YES|
|Suitably qualified and competent professional with the demonstrable experience to address the complexity of the design being proposed in terms of fire safety.||OPTIONAL|
(May be used as an alternative means to demonstrate competence if qualification criteria cannot be met).
How can AESG help?
The planning application process has been modified with the inclusion of new legislation. Failure to comply with the changes can cause significant project risk. Any delay in the project can have a substantial impact on time and money, something developers and clients can ill afford.
AESG can help navigate smoothly through this process by providing the following support;
Assess the project and define which specific requirements apply. This will ensure that our clients are not wasting time or money on work that is not required for planning applications.
Create a bespoke road map detailing the steps that will be taken on order to be compliant with relevant legislation.
Assess the design and highlight any aspects which fall outside of standard guidance documents. AESG will discuss options with the client to reduce project risks. Where necessary, our team will draw on engineering principles and project experience to adequately mitigate any departures.
Create an overall fire strategy for the building, demonstrating that fire safety has been considered from the outset. As part of this process, AESG will propose an evacuation strategy suitable for the building use and design. Where required, our team will justify the use of a ‘stay-put’ evacuation strategy. We will discuss which mitigation best suits the scheme taking into account design aspirations, practicability, and cost.
Produce outline fire statements, fire statements or bespoke reports for inclusion in planning applications. Our UK team have both the level of qualifications and the relevant experience to provide this service on any project irrespective of size or complexity.
Provide support during the planning approvals process giving our clients comfort that they are not alone.
Utilise our bespoke Fire+ service in order to provide a digital platform for our clients to store building information during its life cycle. This service will allow our clients to be fully prepared for requirements of the new the Building Safety Bill. In particular the ‘gateway’ process and the ‘golden thread’ of information requirements.
THE GATEWAY PROCESS
AESG’S FIRE+ UPHOLDS THE GOLDEN THREAD OF BUILDING DATA
Fire+ can be utilized for Existing and New Buildings
Fire+ can be utilized for existing and new buildings, this will demonstrate compliance from the ‘Duty Holders’. The ‘Duty Holders’ for existing buildings must demonstrate compliance and also introduce a golden thread of information.
AESG can assist the ‘Duty Holders’ to achieve this and compliance by introducing a retrospective fire strategy, this covers;
• Executive Summary
• Principal Fire Safety Features
• Development Description
• Goals, Objectives and Performance Requirements
• Building Population
• Fire Alarm and Detection System & Smoke Control
• General Provisions
• Internal Fire Spread (Linings)
• Structural Protection
• External Fire Spread
• Fire Service Access and Facilities
• Management Strategy
• Conclusions and Recommendations
If the building is less complex, AESG would introduce a Fire Safety Management Plan which includes;
• Conclusions and Recommendations Property Details
• Conclusions and Recommendations Fire Safety Systems
• Conclusions and Recommendations Fire Strategy Overview
• Conclusions and Recommendations Fire Safety Planning
• Conclusions and Recommendations Fire Safety Organization and Control
• Fire Safety Monitoring and Review
• Fire Emergency Procedure
Fire+ will ensure that all building safety information is placed into a central database so the nominated‘Responsible Person/s’ can keep track of all issues relating to Fire and Building safety.
If any building defects are reported, Fire+ will ensure you can raise the associated defect and then close down the action once remedial works have been completed.
If the remedial works have not been addressed Fire+ will remind you, this will ensure you stay compliant.
Facade Investigation Services
Our Facade Consultants can also support the duty holders with the development of these fire statement. They can:
1) Review record documentation. Collect/collate relevant information and provide desktop studies for key building elements:
2) Attend Site, after contractor opens up cladding and investigation of as-built condition, followed by detailed report.
3) Comparison Studies – where Client has multiple assets, especially on the same development:
If remediation is confirmed as a pathway to compliance, we offer a full facade consultancy service in addition to our fire consultancy services from tender stage, during construction and through handover, preserving the Golden Thread of information at all times. The benefit is that both fire and facade consultancy functions are provided by the same entity under one insurance, giving the client peace of mind and reducing consultancy touch points thereby enhancing speed of response in all areas.
How can AESG help?
AESG is a specialist consultancy, engineering and advisory firm headquartered in London, Dubai and Singapore working on projects throughout Europe, Asia and Middle East. We pride ourselves as industry leaders in each of the services that we offer. We have one of the largest dedicated teams with decades of cumulative experience in sustainable design, fire and life safety, façade engineering, commissioning, data management for the built environment, waste management, environmental consultancy, acoustics and carbon management.
Associate Fire and Life Safety Director, AESG
25 years of working within the Fire Service and the British Army, he brings with him extensive expert knowledge in conducting FRA’s, developing Fire Strategies, (ADB, PAS911, BS999)Fire Safety Management Plans, Fire Evacuation Strategies, Fire Engineering solutions and also in undertaking façade inspections to ensure compliance with building regulations.
With his technical skills, expertise and understanding of the regulatory environment he advises clients on the appropriate fire and life safety strategy.
Fire Engineer, AESG
Kieran has over 15years’ experience in fire fighting and fire engineering. Having attended a number high rise incidents in London, he has a unique understanding of building performance during a fire situation. He has a passion for fire safety and building design and draws on challenges he faced in buildings which were designed well and buildings which were designed poorly.
Kieran has been the project lead on a number of major residential developments in London and the UK. Kieran is a member of the Institute of Fire Engineers.
Associate Façades Director, AESG
Chouaib is our Associate Director of Façades for the UK. Asan Architect and Building Envelope Specialist with an MSc in Façade Engineering he brings with him over 20 years of experience working with international architects and clients, and possesses a successful track record of direct involvement in developing façade solutions and managing the delivery process from inception to completion on various project types and sizes, ranging from small and simple to major and complex, and spanning across a wide range of industries. Heis also a fellow of the SFE (Society of Façade Engineering, UK).
With his passion for sustainable and innovative design and commitment to technical excellence, he plays a key role in our commitment to delivering service excellence to our clients.
James Dickson is a Building Envelope Specialist with an honours degree in Mechanical Engineering. He has over 30 years of multicultural experience in construction with20 years of Facade & Envelope experience across the UK, USA, Europe, Middle East and Far East. Having worked as a Client Representative, Client Consultant, Main Contractor, Subcontractor and Subcontractor’s Consultant, he appreciates construction challenges from all viewpoints and is quick to find solutions to the trickiest problems. He has a passion for computing and how it can transform business, especially construction.
He is interested in Digital Twins, parametric design, coding, production automation, augmented reality, and any computing field which promises to modernise construction methods. He enjoys writing and specifying automation code.
Associate – Digital Delivery
Rohan is AESG’s Associate – Digital Delivery. He is an alumnus of The Ohio State University in Columbus, Ohio. Rohan has served as a Mechanical Engineer and Digital Handover Specialist, with over 8 years of experience in the Building Services Industry spanning various project sectors such as education, industrial, commercial, residential, infrastructure, hospitality, and retail.
Having worked on various projects within the MENA region, he has developed expertise for the execution of digital handovers on projects and promotes the management and delivery of project data through the use and implementation of COBie & ISO 19650 standards.
AESG is an award-winning global provider of fire safety consultancy pairing technical knowledge with practical experience to provide strategic solutions to our clients. We pride ourselves in being leaders in the industry in each of the services that we offer. Whilst there may be an amount of uncertainty or trepidation in complying with the changes. AESG are equipped to provide definitive guidance and support from the outset.
For further information relating to specialist consultancy engineering services, feel free to contact us directly via email@example.com
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