Energy Statements

An Energy Statement is usually a concise but technically supported explanation of a proposal’s energy strategy for planning purposes. Its central task is to show how the design has addressed the relevant policy, rather than to reproduce every building-services calculation. It may be called an energy strategy, sustainability statement, energy and carbon report, low-carbon energy statement or similar title. The label is less important than the policy hook, the defined assessment boundary and the evidence.

In practical terms, the report commonly brings together the architectural and services choices that affect energy demand: massing, orientation, glazing, insulation, airtightness assumptions, heating and hot-water systems, cooling where relevant, ventilation, lighting, controls, renewable generation and possible connection to decentralised energy. It may also address phasing, grid capacity, feasibility, viability, overheating and monitoring where those matters are required by local policy or a condition. The appropriate scope remains local and proposal-specific.

The National Planning Policy Framework (NPPF) published on 17 August 2026 supplies the national context. Its climate policies address mitigation and, where relevant, conserving energy and resources and using available decentralised low-carbon energy networks. Its renewable and low-carbon energy policies ask plans to identify opportunities and give substantial weight to stated benefits. Its information-requirements policy says additional local information must be grounded in a development-plan policy, proportionate to the development’s scale and potential impact, and differentiated by development scale where appropriate.

The NPPF does not prescribe the chapters of an Energy Statement or impose an England-wide savings target. Similarly, national renewable-and-low-carbon-energy guidance says there is no quota a Local Plan must deliver. A local policy may legitimately be more specific, but only its actual adopted wording, scope and metric should be applied to the application.

Essential definitions

National context versus local planning requirements

The quickest way to avoid an incomplete report is to keep the different regimes visible. National policy establishes the planning context and limits around proportionate information. The local plan, validation list and conditions tell the team what is actually asked for. Building Regulations set a distinct statutory minimum for building work. Methodologies and professional guidance turn design data into evidence but do not, by themselves, create a planning obligation.

The Planning Practice Guidance (PPG) on climate change says local requirements should sit in the Local Plan, be supported by robust and credible evidence, and pay careful attention to viability. 2 It is useful context, but its climate-change page was last updated in 2019. Read it alongside the NPPF in force and the current adopted local documents. Historic material, including references to former standards, should not be repurposed as a contemporary national target without checking its continuing status.

Your energy statement needs to evidence the efficiency of a new development by incorporating details such as the materials used for building, insulation, renewable energy technologies and low-carbon heating systems.

As a rule, Energy Statements should adhere to the London Plan’s Energy Hierarchy:

• Be lean: Use less energy. This requires a ‘fabric first’ approach, focusing on reducing the amount of energy lost through insulation, glazing, and air tightness of the project.
• Be clean: Ensure future proofing by connecting to an existing District Heat Network, establishing an on-site low-carbon communal network, or providing for future connections.
• Be green: Incorporate renewable energy technologies to generate energy on-site.
• Be seen: Outline strategies for monitoring and measuring energy consumption and emissions after completion.
• Zero carbon: Account for the carbon offset payment required to meet the zero-carbon standard. The London Plan mandates a 35% reduction in CO2 emissions.

A credible Energy Statement explains both the design logic and the calculation boundary. Show which outcome arises from passive design and fabric, fixed services and controls, heat-network or low-carbon heat strategy, and renewable generation. Do not casually convert between energy demand, energy-use intensity, primary energy, carbon, installed capacity or percentage-of-demand: a local policy may use one measure but not another.

Fabric, form and passive design

Describe the design assumptions that underpin the strategy: proposed form and orientation, construction and glazing performance, solar-control approach, ventilation, air-permeability assumption, shading and major constraints. These choices affect heating and cooling demand, plant selection, renewable roof capacity and overheating risk. Coordinate the approach with conservation, daylight, flood risk, noise, ecology, fire, access and townscape constraints where relevant. If a constraint limits a measure, explain the committed response. Do not present an assumed airtightness result as an as-built outcome.

Fixed services, low-carbon heat and controls

State the heating, hot-water, ventilation, cooling, lighting and control strategy to the level appropriate for the application. Identify the system type and key modelling assumptions where used, and explain interactions with fabric. Heat pumps, cooling and restricted window opening need early coordination around electrical demand, plant space, noise, façade design and overheating evidence.

Renewable generation, heat networks and grid capacity

For renewable generation, state installed capacity, estimated annual yield, usable roof or ground area, orientation, shading, self-consumption or export treatment, maintenance access, phasing and known grid constraints. Apply the local policy’s metric. A renewable percentage, carbon reduction, roof-area expectation and energy-demand proportion are not equivalent calculations.

For a heat network, establish whether one exists or is planned and whether a local policy, zoning status or condition applies. Evidence should cover feasibility, capacity, route, connection terms, building interface, metering, operating temperatures, losses, peak capacity, phasing and a fallback if connection is not deliverable. Government policy recognises heat networks and zoning powers, but a nationwide connection obligation should not be assumed. A communal system is not automatically a low-carbon network.

Transparent calculation evidence

State whether results cover regulated energy only, whole-building operational energy or a stated subset; whether they apply to one building or a phase; and whether they are design-stage or as-built. Record the model and software version, weather and occupancy assumptions where relevant, emissions-factor basis, treated floor area, calculation date, exclusions and rounding. Follow any policy-prescribed assumptions exactly.

Embodied carbon, offsetting and post-occupancy monitoring are not England-wide defaults. Tie them to the applicable policy, condition or agreed brief. London is a policy-specific example: major developments require detailed energy assessments, and referable applications must calculate and reduce whole-life-cycle carbon. It is not a template for every English authority.

A compliance model answers a defined regulatory question using a prescribed methodology and assumptions. An operational model estimates energy in use under stated patterns of occupancy, equipment use, management and control. Both can be valuable, but they are not interchangeable.

CIBSE TM54 is professional guidance for estimating operational energy at design stage, including operating patterns, non-HVAC uses, management, sensitivity testing, reporting and quality assurance. It is not a universal statutory Energy Statement requirement. Where operational modelling is needed, report regulated, unregulated/process and total energy separately; define tenant fit-out, small power, catering, servers, occupancy, weather and controls; and do not describe a forecast as measured performance.

• Assuming a national target or generic template. England has neither a universal format nor an England-wide planning carbon or renewable-energy quota. Start with current local policy and validation requirements.
• Treating Part L as the whole planning answer. SAP or SBEM/NCM results can be central evidence, but Part L and planning assess different statutory questions.
• Confusing validation with planning merits. Check the formal, current local list, then make the policy case against the adopted development plan and material considerations.
• Using historic guidance as a current target. The climate-change PPG contains legacy material and was last updated in 2019; reconcile it with the NPPF in force and the current local plan.
• Combining incompatible boundaries. Do not compare regulated SAP/SBEM energy with whole-building operational energy, or imply that an EPC is a metered-energy forecast.
• Selecting the wrong methodology edition. Check the actual Part L, SAP/NCM and transitional route for the building work, including higher-risk-building arrangements where relevant.
• Naming a heat network without delivery evidence. Address capacity, route, losses, temperatures, metering, agreement, phasing and fallback.
• Claiming renewable yield without assumptions. State capacity, usable area, orientation, shading, access, export/self-consumption and grid position, then apply the policy metric.
• Leaving completion evidence too late. Assign owners for model updates, air testing, commissioning, EPCs and condition discharge before procurement.
• Overpromising operational performance. A model is only a forecast unless a defined monitoring route produces actual performance data.