Planning Policy Position Statement

1. Issue Identification

The Government’s commitment to deliver 1.5 million homes within five years will shape communities for generations. Safe outcomes depend on the planning process working effectively: determining whether residents live in places that are both sustainable and safe. Planning decisions have long-term consequences, as choices made at the planning stage affect the communities that will inhabit the area long after they are made.

Ensuring adequate firefighting access and water supplies is a key priority for fire and rescue services (FRSs). Streamlined planning may deliver housing more quickly, but without safeguards, the risks of insufficient access or water provision may only become apparent when operational personnel need them during an incident. This may have a significant impact on the safety of both personnel and members of the public. It is essential that new developments include reliable water supplies for firefighting, accessible routes for emergency vehicles, and up-to-date community risk profiles.

FRSs act as statutory consultees at the Building Regulations stage on new build applications and building alterations, and previously, under the Planning Act (2008) were consulted on Nationally Significant Infrastructure Projects (NSIPs),[i] although the consultation requirements for NSIPs were removed in December 2025.[ii] Applicants and planning authorities are encouraged to undertake early engagement with FRSs as a matter of best practice on specific types of high-risk sites, such as grid-scale Battery Energy Storage Systems (BESS) and waste transfer/processing sites. FRSs may provide comments in accordance with their duties under the Fire and Rescue Services Act 2004, which may address critical safety issues.

Although the planning and Building Regulations stages are separate processes, issues are not always addressed consistently across them. This can lead to misconceptions, including the belief that FRS access and site positioning are fully resolved and approved during planning.

The Government has also sought to accelerate housing delivery by expanding Permitted Development Rights (PDR) for Change of Use. However, this can allow buildings to be converted or extended without full scrutiny, potentially creating fire safety risks. Without safeguards, such approaches may embed lower safety standards that are costly and difficult to rectify later. Streamlining planning must not result in buildings that require remediation in the future.

2. NFCC Position

NFCC supports the Government’s ambition to increase affordable housing supply and recognises the potential of streamlined planning policy to accelerate delivery. However, increasing the number of homes should not come at the expense of safety. New developments must ensure buildings and infrastructure are located and designed in ways that appropriately manage fire risk within communities. Delivering more homes must go hand in hand with ensuring they are safe, sustainable, and resilient. Strengthening safety within the planning process would deliver better outcomes and reduce the need to revisit applications further down the line.

This position statement reflects planning processes and legislation in England, though we note that some of the issues, particularly around funding, integration of planning and building standards, and ensuring robust fire safety in all developments, are also relevant to the devolved administrations. We encourage the devolved governments to engage proactively with their FRSs on these issues, including recognising emergency services as critical infrastructure within planning and funding frameworks.

3. Recommendations

NFCC calls on the Government to:

  • Ensure that FRS have provision for suitable access and firefighting water so that they can adequately and safely attend incidents. This should include:
    • A requirement for Spatial Development Strategies to include specific sections on fire safety.
    • A requirement for adequate firefighting access and facilities to be included in local plans. It should be necessary for any local plans to include a confirmation that adequate access, facilities, and supply of firefighting water exist for all premises. For premises subject to PDR, it should be highlighted that these facilities will need to be provided as part of the initial approval of outline planning permission.
    • An express requirement that all planning approval for buildings, no matter the size or usage, is predicated on an adequate water supply for firefighting.[iii]
    • No building should be occupied unless the Registered Building Inspector is satisfied there is adequate provision of water for firefighting, including compliance with part B5 of the Building Regulations.
    • Better specification of appropriate pressures and flow rates. Current guidance for the provisions for the supply of water for firefighting is too vague and has not ensured that appropriate supplies of water for firefighting are achieved.
  • Improve oversight in the planning process to reflect FRS expert advice on fire safety, including:
    • Retaining a statutory mechanism for FRS engagement with Nationally Significant Infrastructure Projects, or clear guidance requiring developers to consult with the relevant FRS where proposals impact fire safety, operational response, or resilience.
    • In circumstances where FRSs are consulted, ensure there is a mechanism that requires FRS concerns to be addressed.
    • Updates to legislation and statutory guidance to ensure the mitigation of risks posed by climate change are safely and appropriately incorporated.
  • Ensure greater focus on the Building Regulations and their functional requirements within Permitted Development Rights:
    • Remove the ability for commercial to residential conversions to be developed under PDR.
    • Introduce a requirement for the whole of a building converted to residential purposes under PDR to comply with the Building Regulations 2010 (as amended), rather than just that part subject to actual building work.
    • Require developers to engage with a Building Control Body if PDR are being applied and ensure that any PDR converting a building to residential use (or an addition to existing residential premises) is accompanied by a fire statement outlining how the required levels of fire safety, such as compartmentation, will be achieved.
  • Ensure FRSs are properly funded to ensure adequate emergency services infrastructure that meets the needs of the communities they serve:
    • New definitions of infrastructure for Section 106 agreements and the Community Infrastructure Levy (CIL) should be created. Specifically, these should recognise the emergency services as “infrastructure” and clarify that this definition encompasses equipment, resources, and facilities.
    • Developers must be required to meet the cost of initial fire hydrant installations, as identified by local FRSs, if it forms part of the planning permission approval. FRSs should not have to bear the cost of these hydrant installations.

4. Supporting Evidence

Part 1: FRS provisions within planning

The Building Regulations 2010 state that “[a] building shall be designed and constructed so as to provide reasonable facilities to assist firefighters in the protection of life.” This does not qualify what is “reasonable” or whether this requirement extends beyond the fabric of the building to hydrants, fire suppression systems, water storage tanks, and open water supplies. This lack of clarity, coupled with a lack of responsibility on developers to provide appropriate water provisions, creates a significant challenge for FRSs.

FRSs frequently see buildings coming through the planning process with only minimal provision for firefighting infrastructure, or with key elements negotiated out, particularly access arrangements and firefighting shafts. This results in delays when FRSs engage on these aspects at the Building Regulations consultation stage, sometimes requiring significant redesign or creating tension between fire safety and development costs. In some cases, alternative guidance is used, such as the Department of Transport’s Manual for Streets,[iv] to justify reduced vehicle access widths. If documents other than the Building Regulations guidance are used at the planning stage, these should accurately reflect current Building Regulations guidance to avoid further issues later in the planning process.

The continuous review of Approved Document B (ADB) needs to include a full review of B5: access and facilities for FRSs, to ensure any gaps between planning provisions and Building Regulations can be addressed or removed. This should consider vehicular access, water provisions, when firefighting shafts are provided, and ventilation provisions in corridors and basements.

NFCC have highlighted the importance of equity of evacuation within our Building Regulations and Guidance Position Statement.[v] ADB provides that to achieve compliance it is necessary to meet the criteria that “All people can escape to a place of safety without external assistance.”[vi] Equitable evacuation and effective FRS access are closely connected. If planning provisions do not accommodate adequate firefighting shafts, buildings may be unable to meet functional requirements without a later redesign.

Another area of ambiguity is the requirement for access for a fire appliance within 45 metres of every point within the footprint of the building. Guidance is required regarding hose laying distances to avoid convenient interpretations and should stipulate suitable routes for firefighters to lay a hose (for instance, not point-to-point on a map, or on the other side of a motorway).

It is a major concern for FRSs that premises are being built without provision for water for firefighting, and those dwellings are being inhabited. No property should be occupied unless the Registered Building Inspector is satisfied that there is adequate provision of water for firefighting, including compliance with part B5 of the Building Regulations. In some circumstances, it can be years before the provision of water can be confirmed as satisfactory, as either hydrant provision is inadequate, or the water undertaker has not installed them.

The current provisions for water supplies for firefighting are vague and inadequate, particularly in ADB Volume 1: Dwelling Houses, which lacks equivalent requirements to those in Volume 2. NFCC recommends a fundamental review of these provisions, including:

  • A clear requirement for all buildings to have a sufficient firefighting water supply, regardless of size or use.
  • Clearer specification of appropriate pressures and flow rates, and backup systems.
  • Mandatory inclusion of hydrant details and water supply on completion paperwork.
  • Clarification of suitable hose laying routes within ADB.[vii]

Fire hydrants

Ensuring adequate fire hydrant flow rates is particularly important for many building types, including high-rise developments and warehouses without sprinklers. Poor flow rates can limit FRSs’ ability to effectively fight fires, increasing risks to firefighters and the public, and potentially leading to greater damage to buildings and the environment.

Inadequate pressure and flow rates place additional demands on FRSs, requiring more firefighters, pumping appliances, and equipment (such as high-volume pumps) to move water over longer distances to the fireground. This can delay firefighting operations and increase risks to life and property.

There is no legislation specifying minimum fire hydrant flow rates. However, ADB references guidance suggesting minimum flow rates of up to 1,500 litres per minute for buildings above 18m. Existing hydrants will often not provide the minimum flow rates that are laid out in building design guidance due to targets for other areas, such as leakage reduction. This can make it difficult to ensure buildings have appropriate water supplies in line with the national guidance document on the Provision of Water for Firefighting.[viii] While ADB does not prescribe flow rates, it permits a stored water supply of at least 45,000 litres. Where this is used in place of a hydrant, or shared with fire suppression systems, it can create uncertainty about the availability of water for firefighting, as seen within warehouses. NFCC has highlighted the need for a full review of the firefighting provisions within ADB,[ix] which should include an examination of appropriate pressures and flow rates.

There are a growing number of examples of new development sites where the design of the network will significantly restrict access to water for firefighting in an emergency. Mains and boundary valves are being sized for domestic supply purposes. The use of 63mm mains has become increasingly widespread; however, these are not suitable for attaching a fire hydrant to and risk collapsing the main during an incident. Many FRSs advocate for 90mm mains, though further engagement is needed to determine appropriate standards. Clear, enforceable guidelines are needed to ensure hydrants are integrated into development plans with suitable mains sizing, ensuring a usable flow rate for firefighting. FRSs can provide advice, while infrastructure designers and building control officers are responsible for implementation.

Water supplies for firefighting were a key subject of the Grenfell Tower Inquiry, with Dr Stoianov’s evidence[x] highlighting the critical importance of adequate flow rates and water pressure, as well as the possible need to add further detail to the national guidance document on the provision of water for firefighting. Of particular note is the evidence that insufficient flow rates from the firefighting hydrants limited the vertical reach of the water jets produced by the London Fire Brigade’s pumping appliances during the Grenfell Tower fire and necessitated periodic pausing of firefighting efforts to allow the onboard tanks to refill. This learning is particularly relevant as high-rise buildings become more common across the UK.

Part 2: Reflection of FRS advice

In all areas where FRS advice is sought, or where FRS advice is sought at later stages of development, NFCC is clear that there should be duties on the bodies receiving FRS comments to respond to these comments, or to demonstrate how any FRS concerns have been satisfied or addressed.

Nationally Significant Infrastructure Projects (NSIPs)

For FRSs, early and meaningful engagement at the pre-application stage of the NSIP process has proven critical in ensuring that fire safety, resilience, and operational response requirements are properly integrated into NSIPs. Experience from projects such as the Lower Thames Crossing demonstrates that robust early engagement can lead to significant improvements in safety-critical design features, including cross-passage spacing, water supplies, riser provision, smoke control systems, and operational planning, which would be difficult to achieve at later stages.

However, this mechanism was removed in December 2025 through the Planning and Infrastructure Act 2025. Without a statutory trigger, there is a real risk that developers may overlook or minimise FRS engagement, particularly on projects where fire safety risks are not immediately obvious but have long-term operational and community safety consequences. The statutory consultation requirement for NSIPs provides an essential safeguard to maintain consistent, high standards of fire safety, and operational readiness.

A statutory mechanism for FRS engagement in NSIPs needs to be retained, or, at a minimum, clear guidance must be established requiring developers to consult with the relevant FRS where proposals impact fire safety, operational response, or resilience. Guidance should promote a consistent approach to engagement and consider cost recovery mechanisms to support the specialist technical input required from FRSs.

Flooding and environmental impacts

There is a need for both flooding and environmental impacts to be taken into account at the planning stage. Eight of the 89 risks included in the UK Government’s National Risk Register are identified as climate-change-related extreme weather events.[xi]

Planners have long played a role in ensuring new developments address climate change adaptation and mitigation. The revised National Policy Planning Framework (2023) states that all building plans “should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes, and the risk of overheating from rising temperatures.”

However, the Building Regulations 2010 in England and supporting statutory guidance (the Approved Documents) have yet to reflect best practice in relation to climate change in new residential buildings. This has created a gap between the planning and building control application stages of the process and is potentially a missed opportunity for a more future-proofed and resilient Building Regulations framework.

Residential

The planning stage is a vital opportunity to ensure fire safety is considered early, before critical elements of a development’s design are locked in.

While it is acknowledged that planning and Building Regulations are separate matters focused on different issues, there is a misconception that once planning approval has been granted, then Building Regulations approval is already assured.

The level of detail contained in a full planning application varies, but it will usually include elements critical to emergency service access, such as: vehicular access in and around the site; firefighting shafts and escape stairs; plant and refuse rooms; and details of residential units.

Local planning authorities and those submitting plans should ensure they pay appropriate regard to the functional requirements of the Building Regulations 2010 to avoid concerns which may be raised at the building control application stage. There may be opportunities to strengthen and clarify the technical understanding of planning authorities in order to reduce reliance on external consultees and avoid issues at later stages.

Part 3: Permitted Development Rights 

Experience of FRSs indicates that conversions of offices to housing have produced buildings with a wide range of serious defects, such as poor FRS access and facilities, inadequate compartmentation, unsafe external wall systems, inappropriate ventilation systems, and inadequate means of escape for residents, often making them unsafe for occupancy.

The conversion of commercial premises to multiple residential buildings under PDR has already increased the number of buildings with fire safety issues and could inadvertently lead to a further increase at a time when the regulatory system is struggling to address those already built within the current building safety crisis.

Building work carried out under PDR must still comply with the Building Regulations 2010 (as amended), which in turn ought to support compliance with the Regulatory Reform (Fire Safety) Order 2005 (as amended) (the FSO). However, this is often not checked.

There is a common misconception that planning permission is the only approval needed in order to build. Planning permission does not demonstrate compliance with the Building Regulations or the FSO. It also cannot be used to demonstrate compliance with new requirements within the Building Safety Act 2022. After achieving planning permission, developers should also engage a building control body. However, the experience of FRSs suggests that many owners/developers are not following this process.

The PDR process should not be carried out in isolation from other regulatory functions and supporting guidance, as they are inextricably linked. For example, where a PDR commences above an existing building, there is no explicit requirement to enhance the fire safety measures in that existing part of the building. This can increase risks within new parts of the building should a fire develop in the existing building below.

There remains a disconnect between the non-worsening conditions of Building Regulations and the expectations of continuous improvement set by the FSO. Non-worsening is commonly interpreted as allowing fire precautions to be removed and replaced on a like-for-like basis – meaning a building can be refurbished many times, but the general fire precautions may never be improved. Non-worsening conditions are commonly cited and utilised within PDR projects, resulting in lost opportunities to improve safety. The risk profile and levels of vulnerability of those occupying the building increase when a premises moves from commercial to residential. However, the use of the non-worsening provisions can result in inadequate fire safety provisions, a lack of suitable and sufficient means of escape, fire detection, or warning systems for residents.

The whole building’s fire safety requirements should be considered, including but not limited to the part subject to actual building work. Such an approach would encourage early engagement between developers and building control bodies and ensure the final residential building meets modern fire safety standards, without impacting the Government’s aims in extending PDR.

Part 4: Infrastructure Levy

New developments of all kinds inevitably place additional demands on fire and rescue, ambulance, and police services. These are manifested not just in terms of the increased volume of calls, but also the requirements for “blue light” buildings, vehicles, equipment, and other infrastructure required to serve the new developments during their lifetime.

Under the existing planning system in England, there are two mechanisms by which financial mitigation is given to infrastructure providers: Section 106[xii] agreements and the Community Infrastructure Levy (CIL). However, emergency services face significant challenges accessing the funds distributed by these mechanisms, and in most cases are unsuccessful.

In March 2023, the Government recognised the need[xiii] for emergency services to be involved and considered within local infrastructure delivery strategies, including consideration of infrastructure funds raised through CIL and Section 106 within the subsequently halted proposals for an Infrastructure Levy.

While Section 106 agreements raise circa £6–7 billion each year across England, the emergency services receive almost none of this. The Section 106 system started in 1990, and the most recent national survey undertaken in 2025 found that England’s 94 emergency services had received a total of £35 million over 35 years.[xiv]

The outcome under the CIL is no better. That system raises circa £600 million annually for infrastructure, yet the 94 emergency services have received only circa £2 million over 15 years since the CIL system started in 2010.[xv]

FRSs in England previously received capital funding from Government to maintain the integrity and quality of the buildings through which firefighters protect the public. However, this funding was removed in 2014/15. This has led to issues with the FRS asset base, including:

  • Disrepair in older fire stations, particularly in some County Council FRSs.
  • Diversity and dignified facilities – further investment would unlock FRSs’ ability to invest in their estates in a way that reflects the ambition to diversify the workforce, helping to ensure dignified facilities for all staff and the public, including women and those with a disability. Dormitories, non-private facilities, and shared showering and washing arrangements are still the reality in some fire stations.
  • The ability to implement best practice and high-quality measures to improve decontamination procedures.
  • Improved and different firefighter training facilities to reflect the growing body of evidence to support new, different, and more effective firefighting tactics.

FRSs (and other emergency services) must fund the infrastructure required by new development schemes from within their existing budgets. This means diverting funding from established communities and diluting operational coverage and other services across the entire area covered by the “blue light” service in question. This is precisely the kind of impact that the planning system is supposed to avoid but instead is happening continually across the nation.

New definitions of infrastructure for Section 106 agreements and the CIL should be created, recognising the emergency services as “infrastructure”, and clarifying that this encompasses equipment and facilities. This would allow emergency services to have an equal seat at the negotiation table alongside other stakeholders, allowing for their infrastructure to be accounted for at the earliest stages of development.

There is precedent for this: the Levelling-up and Regeneration Act 2023 contained similar recognition of the emergency services in relation to the, now halted, Infrastructure Levy (not to be confused with the CIL).

Government needs to ensure that infrastructure is in place at the point at which it is required. If the emergency services cannot provide sufficient coverage to a building development due to mitigation not being provided when needed, the safety and wellbeing of the people at the site in question will be put at risk until such time it is provided.

FRS provision within the Infrastructure Levy

The Infrastructure Levy has been used by some FRSs to fund hydrant provision; however, this requires close working with the local planning authority as this is a planning condition. The cost of hydrant installation is not mandated to be borne by the developer, even though it forms part of the planning permission process. The application of hydrant installation can be arduous for FRSs, such as London Fire Brigade, which has 33 planning authorities within its area. As a result, the cost of installing hydrants for new development sites is falling to FRSs, placing additional pressure on already stretched public funds. This seems outside of the spirit of the legislation. The installation of hydrants would add a negligible proportionate cost to many development projects, particularly given the scale and profitability of these developments.

All developments, no matter the size or usage, should provide an adequate water supply for firefighting.[xvi]

References

[i] NFCC-Streamlining-Infrastructure-Planning-Consultation-Response-27-Oct-25.pdf

[ii] Planning and Infrastructure Act 2025 – Parliamentary Bills – UK Parliament

[iii] This would normally be provided by the provision of hydrant(s) attached to a suitably sized main that delivers an appropriate flow rate for firefighting but may also be complemented or provided by storage tanks, open water sources, or a combination.

[iv] Manual for Streets, 29 March 2007

[v] NFCC Building Regulations and Guidance Position Statement

[vi] Approved Document B (fire safety) volume 1: Dwellings, 2019 edition incorporating 2020, 2022 and 2025 amendments collated with 2026 and 2029 amendments.

[vii] To reduce ambiguity, there must be clear and prescriptive guidance on how hose laying distances relate to travel distances within buildings, ensuring consistency in design and allowing FRSs to operate safely and effectively in a wide range of scenarios.

[viii] National Guidance Document on the Provision of Water for Firefighting (4th edition; June 2025) NFCC (corrected).pdf

[ix] Technical_review_of_ADB_-_1_March_2019_-_FINAL.pdf

[x]ISTRP00000002_Dr_Stoianov_report___Chapter_2__Report_Overview_and_Key_Conclusions.pdf (grenfelltowerinquiry.org.uk)

[xi] NFCC Climate Change Position Statement

[xii] Town and Country Planning Act 1990

[xiii] Levelling-up and Regeneration Bill – Hansard – UK Parliament

[xiv] This figure excludes the circa £22 million Suffolk Constabulary were awarded via the Development Consent Order granted to the Sizewell C Nuclear Power Station planning application. As this was a unique set of circumstances for various reasons, it is cited separately.

[xv] As of the Association of Police and Crime Commissioners and National Police Estates Group survey in 2025

[xvi] This would normally be provided by the provision of hydrant(s) attached to a suitable size of water main delivering an appropriate flow rate for firefighting but may also be complemented or provided by fire suppression systems, storage tanks, open water sources, or a combination thereof.

Equalities Impact Assessment

NFCC Planning Position Statement Equalities Impact Assessment