The London Plan Policy is the Mayor of London’s strategic vision for the capital, but what does it mean for fire safety requirements?
In March 2021, the London Plan Policy was introduced to shape how the capital will grow, aligning with the vision of the Minister of Housing, Communities and Local Government.
Here at Hydro Protect, we are specialists in the fire safety requirements mandated by the City of London, and can design, install and maintain fire sprinklers in London. We have experience working with a variety of buildings, and we can support you in creating a system that ensures your property is fully compliant with the latest Fire Safety Regulations and London Plan Policy D12.
If you wish to discuss your building’s fire safety requirements further, speak to our experts today. We’ll be happy to answer any questions you may have.
What Is The London Plan Policy D12?
London Plan Policy D12 is a core planning policy focused on fire safety, ensuring that all developments in London are designed to the highest safety standards from the outset.
The policy is split into two parts.
Policy D12(A) (All Developments)
Policy D12(A) requires that all development proposals achieve the highest standards of fire safety. Therefore, all plans must demonstrate how the design will minimise the risk of fire spread, ensuring safe and efficient evacuation for all building users, whilst also providing suitable access for emergency fire services.
Policy D12(B) (Major Developments)
Typically, under the London Plan, a major planning application refers to:
- Developments containing 10 or more residential dwellings,
- Buildings or sites with a total floorspace of 1,000m2 or larger, or a site area of 0.5 hectares or more,
- All high-rise residential buildings 18m or more in height, or 7 or more storeys,
- Educational accommodations and similar institutional buildings.
This side of the policy requires that all major planning applications be submitted alongside a fire statement.
A fire statement is an independent, standalone document. It is designed to ensure all the highest standards of fire safety are embedded into a building’s design and evacuation strategy. This includes:
- Clear plans for how occupants will escape, including provisions for people who require assistance,
- Evidence of proper site access, suitable water supplies, and facilities for fire crews,
- Identification of fire risks posed during the construction phase,
- Details on sprinkler systems, fire alarms, and compartmentation measures.
Why Is The London Plan Policy Important?
The London Plan Policy is the statutory part of the development plan for every local planning authority in Greater London. Therefore, local borough plans must conform to the policy and ensure that planning and development are integrated.
Historically, fire safety would have had late-stage design changes, sub-optimal layouts and rushed evacuation planning.
Policy D12 requires developers to integrate fire strategies at the earliest design stage, rather than waiting for later building regulation approvals. With a comprehensive fire statement, drafted by a qualified fire safety expert, fire safety considerations are encapsulated in the property from the very beginning.
Whilst prior policies restrict reliance on lifts for fire evacuations, the London Plan requires new developments with a lift to include at least one suitably sized fire evacuation lift per core. This is a key part of inclusive design, particularly for the elderly, disabled, and those with mobility impairments, for a safe and dignified evacuation.
Applicants must also consult with the London Fire Commissioners during the planning process, ensuring that emergency responders have a direct input in the building layout. This guarantees that the fire brigade has adequate access to a property and that it is structurally resilient in the event of a fire.
What are the Key Requirements of a Policy D12 Fire Statement?
Under the London Plan Policy, all developments must achieve the highest standards of fire safety by incorporating specific fire safety design criteria. The key requirements of a policy D12 fire statement are:
- Suitably positioned unobstructed outside spaces for fire appliances to be stationed and areas appropriate for use of evacuation assembly points,
- Appropriate design features to reduce life risk and the risk of serious injury, including fire detection and alarm systems, as well as passive or active fire safety measures,
- Suitable, convenient means of escape and a detailed evacuation strategy for all building users,
- Adequate water supply arrangements and infrastructure for firefighting, appropriate to the size and scale of the development.
How Do I Ensure My Development Complies?
Ensuring that your development complies with the London Plan Policy requires you to prepare and submit a robust Fire Statement, compiled by a third-party, suitably qualified fire engineer from the earliest design stages.
This document needs to address:
- Clear, robust, and safe evacuation strategies for all building occupants,
- Ensure compliance with Policy D5 (B5) by installing at least one suitably sized fire evacuation lift per core, where lifts are provided.
- Suitable and unobstructed access for fire appliances and personnel,
- Details of fire-resisting construction, sprinkler systems, and smoke control.
- Clearly designed, safe external assembly areas.
You should also ensure that your design aligns with Building Regulations Approved Document B and other relevant standards.
Never wait until the late stages of planning to ensure your development’s compliance. You must involve your local planning authority and, where appropriate, request pre-application advice from the London Fire Brigade.
The Role of Fire Sprinkler Systems in Achieving Policy D12 Compliance
Fire sprinkler systems are a critical active fire safety measure under London Plan Policy D12.
These systems ensure high safety standards by suppressing fires at their source, thus preventing structural collapse and mitigating the risks that those within the property face should evacuation strategies fail.
Automatic fire sprinkler systems limit the spread of fire and heat, protecting escape routes and giving building occupants additional time to evacuate safely. In tall residential buildings, sprinklers give fire services crucial time to conduct rescues, whilst also creating a safer environment for them too.
Sprinkler systems also allow designers to safely propose open-plan layouts, with longer travel distances to stairwells, and reduce boundary spacing between buildings without violating further fire spread regulations.
How Does The Policy D12(A) Differ?
Policy D12(A) applies to all development proposals in London, regardless of scale, requiring that every project demonstrate how its design minimises the risk of fire spread, provides safe evacuation for all building users, and facilitates suitable access for the fire and rescue service.
Where an applicant considers that part or all of Policy D12(A) does not apply to their development, this must be justified in a Reasonable Exception Statement (RES), which should clearly set out which policy criteria are not relevant and why.
Policy D12(B) then builds on this foundation by requiring all major developments to submit a full, standalone Fire Statement produced by a qualified, independent fire safety professional.
What Types Of Properties Are Affected By Policy D12(A)?
Policy D12(A) applies to all development proposals submitted to a London borough, including:
- Minor works and extensions
- Householder applications
- High-rise residential buildings
- Multi-occupancy properties
- Educational accommodation
- Commercial and mixed-use developments
- Major developments
Where a development is classified as major (10 or more dwellings, 1,000m² or more of floorspace, or a site of 0.5 hectares or more), Policy D12(B) additionally requires a full Fire Statement. For non-major developments, applicants who cannot meet certain criteria must provide a Reasonable Exception Statement (RES).
What is the Difference between a Gateway One Fire Statement and a Policy D12/D12(A) Statement?
| Feature | Planning Gateway One (PGO) | London Plan Policy D12 & D12(A) |
| Origin & Authority | National Legislation: Introduced via the Town and Country Planning (Amendment) Order 2021, and now embedded within the Building Safety Act 2022 framework. | Regional Policy: Governed by the Greater London Authority (GLA) via the Mayor’s London Plan. |
| Geographical Reach | Applies nationwide across all of England (including London). | Applies only within the 32 Greater London boroughs and the city of London. |
| Applicable Buildings & Thresholds | Strictly High-Risk Buildings (HRBs): Only applies to buildings containing 2+ dwellings or educational accommodation that are 18+ metres in height OR 7+ storeys. | All Developments: D12(A) applies to every planning application in London (including minor works/extensions). D12B applies to all Major Developments (10+ dwellings, 1,000+ sqm floor space, or large sites). |
| Core Planning Focus | Strictly High-Risk Buildings (HRBs): Only applies to buildings containing 2+ dwellings or educational accommodation that are 18+ metres in height OR 7+ storeys. | All Developments: D12(A) applies to every planning application in London (including minor works/extensions). D12B applies to all Major Developments (10+ dwellings, 1,000+ sqm floor space, or large sites). |
| Technical Content Required | Focused and concise. Typically includes:
| Highly comprehensive. Must explicitly cover:
|
| The “Sprinkler” Factor | Evaluates external water infrastructure, but rarely dictates internal suppression unless it dictates appliance layout. | Heavily influences the inclusion of active systems. Fire sprinkler/suppression strategies are explicitly leveraged to meet the “minimising risk to life” and “preventing fire spread” clauses. |
| Who Must Author It? | Must be completed by a suitably qualified and competent person who can demonstrate relevant experience and qualifications in fire safety. There is no mandatory professional registration, but competence must be evidenced on the standard government-issued pro forma. | Strict Professional Threshold: Must be an independent, third-party, qualified professional—stipulated as a Member or Fellow of the Institution of Fire Engineers (IFE) or a Chartered/Incorporated Fire Engineer. |
| Statutory Consultee / Reviewer | The Building Safety Regulator (BSR), operating through the Health and Safety Executive (HSE), acts as the statutory consultee and reviews the submission under the Building Safety Act 2022. | Reviewed directly by the Local Planning Authority (LPA) planning officers, often in consultation with the London Fire Brigade (LFB). |
| Standardised Template? | Yes. Applicants must complete a rigid, nationwide government-issued pro forma. | Yes. The GLA provides standard templates, but the scale of information scales proportionally with the size and complexity of the development. |
At What Stage of the Planning Process Must D12 and D12(A) be Submitted?
D12 and D12(A) documents must be submitted during the initial planning stage. They are required as a part of the validation process for your local planning authority to assess whether a proposed development meets the highest standards of fire safety during the earliest stage of the design process.
Who is Qualified to Write a London Plan Fire Statement?
Paragraph 3.12.9 of Policy D12 explains that a third-party, independent, and suitably-qualified person with relevant experience in fire safety should produce a Fire Statement. This experience could be an engineering chartered membership registered with the Engineering Council by the Institution of Fire Engineers, or a suitably qualified and competent professional with demonstrable experience to address the complexity of the proposed design. This must be evidenced in the fire statement.
Essentially, a Fire Statement should only be produced by a competent professional.
What Happens if a Development Fails to Meet Policy D12 Standards?
Failure to meet Policy D12 standards typically results in a rejected planning application, construction delays or legal enforcement action.
If you are required to submit a D12 Fire Statement and fail to do so, or if the provided strategy is deemed insufficient, your local council may refuse to process the application. Failure to integrate a suitable fire safety system can add additional costs and project delays.
Should any work proceed without adhering to the approved D12 fire strategy, the local planning authority may issue Stop Work Orders or Planning Enforcement Notices to stop the construction. Then, developers may be required to apply for costly retrospective planning permission or be required to undo unapproved work to achieve compliance.
The Greater London Authority and local planning authorities conduct compliance audits, and where key fire safety requirements are breached, the development fails Building Control checks. This means that the building cannot be legally or safely occupied.
Should the building fail to incorporate key evacuation routes, active fire suppression systems or emergency vehicle access, it can result in criminal prosecution under the Regulatory Reform (Fire Safety) Order 2005, leading to heavy fines or even imprisonment. This applies to those responsible for occupied premises who fail in their ongoing fire safety duties, and is distinct from the planning enforcement rules described above. For higher-risk buildings, the Building Safety Act 2022 further establishes criminal liability for dutyholders who fail to comply with the gateway process or who submit false or misleading information to the Building Safety Regulator.
Are You Compliant?
Ensuring that you have all of the provisions in place for regulatory compliance is vital.
Our team of fire sprinkler engineers often work closely with developers, architects and planning authorities to simplify the compliance process.
If you require any further guidance on the London Plan Policy D12 of D12(A), get in touch with our team today.