Energy metering and the be seen reporting stage

Be Seen is the fourth stage of the energy hierarchy in the London Plan, and it obliges development to measure and report actual operational energy performance after the building is occupied rather than stopping at the design calculation. Reporting runs at three points: as designed, as built, and then annually in use for a minimum period after completion. It is secured by planning condition or by a planning obligation, which makes it a live liability on the scheme long after the contractor has left.

The part that catches developers is not the reporting. It is that you cannot report data you did not meter, and the metering strategy has to be fixed at design stage.

Why in-use reporting was introduced

Design-stage compliance calculations were never meant to predict energy bills. They compare a notional building with the actual one under standardised assumptions about occupancy, weather and controls, which is the right tool for demonstrating compliance and the wrong tool for estimating what a building will consume.

The result is the performance gap. Buildings routinely use more energy in operation than the compliance calculation implies, for reasons that include commissioning quality, control settings, unregulated loads, occupancy patterns and plant that never runs in the mode it was designed for. None of that is visible unless somebody measures it.

The policy response was to require the measurement and publication of real data, so that the gap is visible for individual schemes and so that a body of evidence accumulates across many buildings. Whether or not you think that is the right policy, it is the requirement, and the way it bites is through the consent.

Outside London, some authorities have adopted similar monitoring requirements through local plan policy. Check the adopted policy and any supplementary guidance rather than assuming the London approach applies or does not.

What has to be reported and when

Three submissions, at three defined points.

1. As designed, submitted at or around the planning stage, drawn from the energy strategy that supports the application.
2. As built, submitted after practical completion, reflecting what was actually installed and commissioned rather than what was specified.
3. In use, reported annually from actual metered consumption for the period the condition or obligation specifies.

The in-use stage is the one with teeth, because it depends on data that only exists if the building was metered properly and only reaches you if somebody is contractually obliged to hand it over.

The data required is metered energy consumption broken down in the way the reporting template asks for, together with on-site generation, and it is reported through the platform the policy specifies. Check the current template and platform before you design the metering, because the breakdown you have to report determines the meters you need.

Metering strategy at design stage

This is the deliverable that should come out of the planning stage alongside the Energy Statement. Produce it as a document, not as a line in a specification.

• Separate metering by end use, so that heating, hot water, ventilation, lighting, small power and any process load can be reported distinctly.
• Separate metering by building and by tenure where a scheme has more than one block or a mixed tenure arrangement.
• A clear landlord and tenant split, with the boundary drawn so that landlord services can be reported without needing tenant consent.
• Automatic meter reading with half-hourly data and a data logger, rather than meters that somebody has to walk round and read.
• Metering of on-site generation, including both generation and export where photovoltaics are installed.
• Heat metering that complies with the heat network metering and billing requirements where a communal or district system serves the scheme.
• A named data owner, a storage arrangement and an agreed export format.

Retrofitting sub-meters into a completed building costs several times what it costs to install them, and in an occupied residential block it may not be practical at all. That is the single most expensive mistake available here.

Where a scheme is built in phases, decide early whether reporting is by phase or for the whole site, because it changes the metering hierarchy. Our note on energy masterplanning across a phased site covers how that interacts with the wider strategy.

The performance gap and what reporting exposes

Once real data arrives, three things tend to show up.

Heating consumption above prediction, often traceable to control strategies that leave systems running outside occupied hours, or to a heat network with high distribution losses. Communal system losses in particular can be a large share of total heat delivered, and they are invisible at design stage unless someone models them.

Unregulated loads that the compliance calculation never counted, which in an office can be the largest single item.

Commissioning shortfalls, where the plant works but not in the sequence designed. This is where the money is, because it is usually fixable.

Predicting operational energy properly at design stage is a different exercise from compliance modelling, and there are recognised methods for doing it. Using one of them gives you a figure you can defend when the in-use data arrives, rather than a compliance number that was never a prediction. It also connects sensibly to the embodied carbon picture set out in a Whole Life Carbon Assessment.

How the obligation is secured

Two mechanisms, sometimes both.

A planning condition requiring submission of the as-built data before occupation and the in-use data annually thereafter. Conditions are enforceable by breach of condition notice, and they do not run against a successor in quite the way an obligation does.

A planning obligation under section 106, which binds the land, binds successors and can carry a monitoring fee, a reporting mechanism and sometimes a financial consequence for failure to report. On a referable scheme this is the usual route.

The drafting detail to watch is who the obligation binds once the building is sold. A developer who has sold the freehold to an investor and the flats to owner-occupiers still has an obligation unless it has been properly passed on. Deal with this in the sale documents and the management company structure, not by hoping.

For a build to rent scheme, or one with a single long-term owner, this is straightforward. For a for-sale residential block with a resident management company, it needs designing.

Missing a reporting milestone

The consequences are less dramatic than they sound and more annoying than they look.

A missed as-built submission usually sits as an undischarged condition against occupation, which is a problem for sales and for lenders. A missed in-use report is a breach of an obligation, which the authority can pursue and which will surface on any future application on the same land or by the same applicant.

There is also a practical cost. Reconstructing a year of consumption data after the fact, from billing records, for a building with inadequate metering, is expensive consultancy work that produces poor data.

The best insurance is an appointment. Name the party responsible for reporting, put it in a contract with a fee attached, and give them access rights to the data at the point the building is handed over.

Designing the strategy to be deliverable

Work backwards from the annual report and the design falls out of it.

Write a one-page specimen of the report you will have to file in year three. List every number on it. Ask which meter produces each number, who reads that meter, who owns the data, and what contractual right you have to obtain it. Any number without a complete answer is a gap to close before the drawings are issued.

Then check the leases. A landlord with no right to receive tenant consumption data cannot report it, and inserting that right after letting is a negotiation you will lose.

This is general guidance, not legal advice. Monitoring requirements, reporting templates and platforms are set by the relevant authority and change, so confirm the current position with your local planning authority before designing the metering. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.

Browse all 66 PlanScope report types to see how the energy and carbon documents fit together in an application pack.