Be Seen reporting and post occupancy energy monitoring

Be Seen is the fourth step of the London energy hierarchy, and it asks developers to measure and report what a building actually uses once people are in it. The reporting runs in three stages: as-designed figures submitted with the planning application, as-built figures after construction, and in-use figures reported annually for at least five years after occupation, uploaded to the Greater London Authority's monitoring portal.

The commitment looks administrative and is really a design matter. If the meters are not there, or they are there but measure the wrong boundaries, the data cannot be produced at all. Developers discover that in year one of the reporting period, by which time the building is sold.

What the Be Seen stage requires

The reporting is structured around a small set of operational metrics rather than the compliance outputs most project teams are used to producing.

Expect to report total energy use intensity, expressed in kilowatt hours per square metre of gross internal area per year, covering regulated and unregulated energy. Space heating demand separately. On-site renewable energy generation, both the total generated and the proportion used on site. And total carbon emissions derived from the measured consumption. Residential and non-residential elements are reported separately, in the same way their compliance cases are kept apart.

Verify the current metric list and the portal requirements in the applicable guidance before fixing the metering schedule, because the detail has been revised since the policy was introduced and the borough may add its own expectations.

The policy applies to applications referable to the Mayor, and boroughs have been adopting similar requirements for smaller schemes through local plan policy and condition. Outside London the same thinking is appearing in local plans and in client standards, so a national developer is likely to meet a version of this requirement regardless.

Why compliance modelling is not a prediction

This is the point the whole exercise rests on and it is worth stating clearly in any submission.

A Part L calculation is a compliance tool. It uses standardised occupancy, standardised internal gains, standardised hours of use and, for dwellings, a defined set of regulated loads. It deliberately excludes unregulated energy such as appliances, small power, lifts, external lighting and server rooms. It is not an estimate of what the building will consume.

So reporting Be Seen as-designed figures taken straight from the compliance model produces numbers that cannot be compared with measured consumption, and the comparison is the purpose. The as-designed prediction should be an operational energy estimate using realistic occupancy, realistic hours and the unregulated loads included, which is the territory of the CIBSE operational energy methodology rather than of SAP or SBEM.

That distinction has a programme consequence. An operational energy model is additional work, commissioned from the same team but not produced automatically by the compliance route, and it has to be in the fee at planning stage.

The metering needed to produce the data

Build the meter schedule from the reporting metrics backwards. Every number you will have to report in year three needs a meter that measures it in year one.

Two failure modes recur. Unmetered loads, usually a small landlord supply tapped off a tenant board during construction, which makes the total irreconcilable forever. And meters installed but never commissioned, labelled or connected to a data collection system, so the readings exist in a plant room and nowhere else.

Specify automatic meter reading with a data logger and a nominated data destination, not manual reads. Five years of monthly manual readings across a residential block will not happen.

Where a heat network serves the building, metering and billing are separately regulated, and the requirements of the heat network metering and billing regime should be designed in alongside the planning obligation rather than discovered later.

Who collects and submits it

The obligation attaches to the applicant and the land, and the building will have changed hands. That gap is the practical problem.

Decide at planning stage who will hold the duty in year five and write it into the documents. The realistic options are the freeholder or investor where the asset is retained, the managing agent under an instruction in the management agreement, the developer retaining a contract with a monitoring consultant for the reporting period, or a right to manage company or residents' management company where the block is sold on long leases.

The last option is the weakest. A residents' management company has no interest in a planning obligation it did not sign and no budget line for it, so if that is the end state the reporting has to be funded in advance or carried out by a consultant under a contract that survives the handover.

Data from individual dwellings raises a protection question. Report at aggregate level, using whole-block totals rather than dwelling-level consumption, and where dwelling-level data is used, use it anonymised and in aggregate. Access to smart meter data for individual homes is not within the developer's gift, which is one reason landlord and block-level metering carries the reporting rather than individual supplies.

Reporting intervals after occupancy

The structure is straightforward once someone owns it.

1. As-designed submission with the planning application, based on an operational energy estimate rather than the compliance model.
2. As-built submission after construction and commissioning, updated for what was actually installed.
3. In-use reporting annually, for at least five years from first occupation, based on measured data.

Two timing points matter. The first year of occupation is not representative, because a building fills gradually, commissioning continues and controls are still being tuned, so report it and expect it to look odd. And the reporting year has to be defined in the obligation, because a calendar year, a financial year and a year from practical completion give different answers and arguments about which applies waste everybody's time.

Set a diary reminder tied to the obligation, held by someone whose job will still exist. The most common failure is not a bad number, it is a missed submission.

How the obligation is secured

Authorities use conditions, section 106 obligations or both, and the drafting is where developers can usefully push.

Ask for the reporting obligation to be clear about who reports, from what date, for how long, in what format and to whom. Ask for the trigger to be first occupation of a defined phase rather than of the whole development, on a phased scheme. And ask for a mechanism that recognises a transfer of the duty, so the obligation can pass to the party who actually holds the meters.

Where a monitoring fee is charged, check what it covers and whether it recurs annually. And check whether the obligation requires anything beyond reporting, because an obligation to achieve a stated in-use performance figure is a different and much heavier commitment than an obligation to report what the figure turns out to be.

The reporting commitment belongs in the energy statement as a described strategy with a meter schedule, not as a sentence promising compliance. Where the scheme is also producing a sustainability statement, keep the two consistent about who does the monitoring.

Designing the metering strategy early

The work that prevents all of the above is a one-page meter hierarchy drawing produced at planning stage and carried through to the electrical and mechanical packages.

It should show every incoming supply, every submeter, what each one measures, the boundary between landlord and tenant, the generation metering, the heat metering, the data logger and where the data goes. Name the data owner on the drawing. Then check it against the reporting metrics line by line.

Three habits that save the project later. Allow a small contingency of spare metering positions, because end uses get reorganised between planning and completion. Require meter commissioning, labelling and a point-to-point data check as a handover deliverable, witnessed, not just certified. And ask for the as-built meter schedule as a document in the operation and maintenance manual, so the next owner can find out what is measured without opening cupboards.

One honest observation. Measured in-use consumption will usually exceed the compliance figures, often substantially, and that is a feature of the compliance method rather than evidence of a failed building. The useful comparison is between the operational prediction and the measured result, and a project team that sets that expectation at planning stage avoids an awkward conversation three years later. Where the scheme also has a whole life carbon assessment, the in-use data eventually tests the operational assumptions in that too.

And if the strategy is all-electric, the metering also gives you the load data that makes the next scheme's connection application easier, a point touched on in peak electrical demand and all-electric heating.

This is general guidance, not legal advice. Energy modelling and monitoring strategies should be prepared by a suitably qualified assessor, and councils usually expect a named author for this work.

To see which energy and sustainability documents a scheme is likely to need, enter your postcode on PlanScope and work through the guided questions. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.