The be seen requirement and post-construction reporting
The be seen stage of the London Plan energy hierarchy requires as-built and in-use energy data after completion. The metering strategy and the ownership of the obligation decide whether it can be met.
Be seen london plan reporting is the part of the energy policy that outlives the planning application. The London Plan energy hierarchy runs Be Lean, Be Clean, Be Green, Be Seen, and the fourth stage requires actual energy performance to be monitored and reported after the building is finished, then again once it is occupied. Design-stage calculations stop being the end of the obligation and become the figure you will be measured against.
That changes two things for a developer: the metering strategy has to be designed in, and somebody has to be contractually responsible for reporting years after practical completion.
Where the requirement comes from
The policy sits in the London Plan's energy policy, and the Greater London Authority publishes monitoring guidance that sets out what has to be reported, in what format, and through which online platform. The requirement applies to development referable to the Mayor, and many boroughs apply it to other major schemes through their own local policies and standard conditions.
The underlying reason is a performance gap that the industry has known about for years. Buildings designed to a compliance target frequently use substantially more energy in operation, and a design calculation on its own never surfaces that. Reporting does.
Check the current version of the guidance before you write a condition or price a monitoring package, because the reporting platform, the data fields and the templates have been revised since the policy was adopted.
What has to be reported, and when
Reporting happens in two phases, and the second one is the one people underestimate.
| Stage | What is submitted |
|---|---|
| As-built | Final calculated performance for the building as constructed, with the energy strategy as delivered |
| In-use | Measured energy consumption and on-site generation, reported annually for a period of at least 5 years from occupation |
The as-built submission is a design exercise using the completed specification. The in-use submission is a metering exercise, and it needs real data, which means the meters and the data collection have to exist and work. A scheme that reaches practical completion without a functioning metering strategy cannot comply, and the condition will already have been discharged on a promise that cannot be kept.
Reporting is usually required separately for the regulated and the unregulated energy, and for landlord and tenant supplies. Decide the reporting boundary early, because a block with a commercial unit, a landlord supply and 60 flats has at least three boundaries that could be drawn.
As-built against as-designed
The comparison is the point of the exercise, so expect the gap to be scrutinised.
Common sources of divergence are worth listing, because each one is avoidable:
- a heat pump installed with a higher design flow temperature than the calculation assumed, which lowers the achieved seasonal performance
- an array reduced in size during value engineering, with no revised calculation
- air permeability tested worse than the design figure
- a heat network connection that was safeguarded but not completed, leaving an interim system in place
- communal plant running continuously because the controls were never commissioned properly
The last is the biggest single cause of in-use figures exceeding design figures, and it is a commissioning failure rather than a design one. Where a heat network connection was part of the strategy, the sequencing matters, and the points in safeguarding a future heat network connection feed directly into whether the as-built report matches the permission.
Fabric performance is the other recurring gap, and the junction detailing covered in thermal bridging detail at planning stage is where the heat loss modelled at planning stage either holds or does not.
The condition wording to expect
Standard wording has settled into a recognisable shape, and reading it carefully is worth an hour of anyone's time.
Expect a condition requiring submission of the as-built data within a stated period of practical completion, submission of in-use data annually for at least 5 years from first occupation, upload to the specified platform in the specified format, and submission to the borough as well. Some conditions add a requirement to explain any divergence beyond a stated margin and to propose remedial measures.
Two drafting points matter to a developer. The trigger for the in-use period should be clear, because first occupation of a phased scheme is ambiguous and a block-by-block definition is better than a scheme-wide one. And the obligation should be capable of being performed by whoever will own the building, which brings us to the harder question.
Metering and the design consequences
You cannot report what you do not measure, and retrofitting metering into a finished building is expensive and sometimes impossible.
The metering strategy needs to separate end uses so the report can attribute consumption. That generally means heat meters on each dwelling connection, separate metering of communal plant and landlord services, dedicated metering of on-site generation rather than a net figure, and a data collection route that does not depend on somebody reading a meter in a locked cupboard once a year. Automatic meter reading with a data logger and a remote connection is what makes 5 years of reporting practical.
Design implications follow. Plant room space for the metering and the data equipment. Network connectivity to the plant room. A commissioning schedule that includes verification of each meter against a known load. And a maintenance budget, since a failed data logger produces a gap in the reported series that cannot be reconstructed.
Where a whole life carbon position has also been secured, the operational data feeds that too, which is why a Whole Life Carbon Assessment and the energy monitoring strategy should be written by people who have spoken to each other.
Who holds the obligation after sale
The condition attaches to the land, so it binds whoever owns the building. In practice that is the long leaseholder, the freeholder or the management company, none of whom were in the room when the condition was agreed.
The way this fails is predictable. A developer sells the completed block, the management company has no reporting budget, no data access and no idea the condition exists, and nobody submits anything in year three. The planning authority then has an unresolved breach against a party that cannot fix it.
Handle it in the documents. Put the reporting obligation into the management agreement with a costed line in the service charge. Pass the data access rights and the logger credentials across at handover with the operation and maintenance manuals. Name the obligation in the sales pack. And if you are buying a completed building in London, ask for the energy condition and the reporting history during due diligence, because you are acquiring the liability with the asset.
Aggregate reported data rather than reporting individual dwelling consumption, and check the current guidance on how resident data should be handled before any collection starts.
Why submissions get rejected
The rejections are mostly administrative, which makes them annoying and avoidable.
- Unregulated energy omitted, so the submission cannot be compared with the approved strategy.
- No metering strategy, or a strategy that cannot separate the end uses the template requires.
- Data submitted for a different boundary from the one used at design stage.
- A gap in the annual series caused by equipment failure, with no explanation.
- Upload in the wrong format or to the wrong platform, which is a template problem rather than a data problem.
- Divergence from the approved figures with no narrative explaining it.
Illustrative example. A 90 flat block with communal air source heat pumps, 40 kWp of photovoltaics and a landlord supply serving corridors and a lift. Reporting needs dwelling-level heat metering, separate metering of the heat pumps, dedicated generation metering, landlord supply metering, and a logger with a remote connection. Specify that at stage 4 and the 5 year obligation costs very little. Discover it at handover and it costs a great deal.
PlanScope drafts an Energy Statement from your project answers and inserts a flag wherever a calculated figure is missing, so the modelling and the monitoring data still come from your assessor. Reports should be reviewed before submission, and compliance and monitoring work needs a qualified energy assessor. This is general guidance, not legal advice; check the current London Plan guidance and your borough's condition wording before relying on it.
PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.
Frequently asked questions
What does the be seen stage of the London Plan require?
Monitoring and reporting of actual energy performance after the building is complete. In practice that means an as-built submission based on the completed specification, then measured in-use energy consumption and on-site generation reported annually for a period of at least 5 years from occupation, uploaded in the format the published guidance specifies.
Which schemes does it apply to?
Development referable to the Mayor of London, and other major schemes where a borough applies the requirement through its own local policy and standard conditions. Check the borough's conditions as well as the London Plan, because the local wording often sets the reporting trigger, the submission route and the divergence threshold.
What metering does compliance need?
Enough separation to attribute consumption by end use: heat meters on dwelling connections, separate metering of communal plant and landlord services, dedicated metering of on-site generation rather than a net figure, and automatic meter reading with a logger and remote connection so that 5 years of data can be collected reliably.
Who is responsible for reporting after the developer sells?
The condition attaches to the land, so it binds the owner, which is usually the freeholder, long leaseholder or management company. Put the obligation in the management agreement with a costed service charge line, hand over data access and logger credentials at completion, and raise it in due diligence when buying a completed London building.
Why are be seen submissions rejected?
Mostly for administrative reasons: unregulated energy omitted, a metering strategy that cannot separate the required end uses, data reported for a different boundary from the design-stage one, gaps in the annual series with no explanation, the wrong template or platform, and divergence from approved figures with no narrative.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.