Energy Statement structure using the energy hierarchy
An energy statement that follows the hierarchy reports a carbon figure at every stage. Here is the structure officers expect and the tables that go with it.
An energy statement structured to the hierarchy reports a carbon number at the end of every stage, so a reader can see exactly where the savings came from. The sequence is be lean, be clean, be green and, in London, be seen. Each stage takes the emissions figure left by the stage before it and reduces it, and the statement's tables carry that figure through from the Part L baseline to the residual position. Get the energy statement structure hierarchy right and the officer can check the arithmetic in ten minutes.
Most rejected statements fail on presentation rather than engineering. A strategy that is sound but reports percentages without the underlying tonnes gives the reviewer nothing to verify.
The hierarchy and what each stage reports
Be lean covers demand reduction through the building fabric, form, glazing ratios, air permeability, thermal bridging and efficient ventilation. Be clean covers heat supply, including connection to an existing or planned heat network and communal systems. Be green covers renewable generation on the site. Be seen covers monitoring and reporting of actual performance once the building is occupied.
The London Plan sets the policy framework for this, with major development expected to be net zero-carbon and a minimum on-site reduction beyond the Building Regulations baseline, together with a minimum saving from energy efficiency alone before any technology is counted. The figures are in policy SI 2 and the supporting Greater London Authority guidance, and both are revised periodically, so quote the current version.
Outside London, check the adopted local plan. Many authorities have adopted the same structure, and some have set their own percentage targets or moved to an energy use intensity approach.
Baseline and the regulatory reference case
Start with a clear statement of what is being compared. The baseline is the notional building under the current edition of Approved Document L, modelled with the same geometry, orientation and use as the proposal.
Say which edition of Part L applies, which calculation methodology was used, which software and version, and who carried out the modelling. Where the scheme is phased, say which parts of the development the figures cover.
The baseline table should give regulated carbon dioxide emissions in tonnes per year, split between residential and non-residential where the scheme is mixed. Unregulated emissions are reported separately if the authority asks for them, and should never be mixed into the same total.
Fabric first measures and their savings
The be lean section describes what the building does before any plant is switched on. U-values for each element, window and door performance including g-values, the design air permeability, the thermal bridging approach, and the ventilation strategy with the specific fan power and heat recovery efficiency where mechanical ventilation is used.
Give the numbers rather than the adjectives. A table listing the notional and proposed U-value for wall, roof, floor, window and door, with the air permeability alongside, does more than three paragraphs of description.
Then report the emissions figure after the be lean stage and the saving against baseline in tonnes and as a percentage. That percentage is the one tested against any minimum energy efficiency requirement in policy.
| Stage | What it covers | Figure reported |
|---|---|---|
| Baseline | Part L notional building | Regulated emissions, tonnes per year |
| Be lean | Fabric, form, glazing, ventilation | Emissions after demand reduction and saving |
| Be clean | Heat networks, communal systems | Emissions after heat supply measures |
| Be green | On-site renewable generation | Residual emissions and cumulative saving |
| Be seen | Post-occupancy monitoring | Reporting commitment and metering strategy |
Heat networks and communal systems
The be clean section has to answer a specific question before anything else. Is there an existing or planned heat network within reach of the site, and if so, has connection been investigated.
Set out the enquiry made, the response received, the distance to the nearest connection point and the technical or commercial reasons if connection is not proposed. Where an authority has a heat network policy, an unanswered enquiry is a straightforward reason to return the statement.
Where connection is not viable now, describe the futureproofing. A plant room sized and located for a future connection, space for a heat exchanger, and a distribution system designed for the right flow and return temperatures are the standard commitments.
Communal heat pump arrangements are usually reported here rather than under be green, and the statement should be explicit about which stage claims the saving so that nothing is counted twice.
Renewables and the residual position
The be green section covers on-site generation, most commonly photovoltaic panels and heat pumps where they are not already counted at the be clean stage.
For photovoltaics, give the array area, the orientation and tilt, the assumed yield, the installed capacity and the annual generation. Show the array on a roof plan, because the number of times a stated capacity cannot physically fit alongside the proposed plant, rooflights and maintenance access is remarkable.
Then report the residual regulated emissions and the cumulative saving against baseline. This is the figure the offset calculation uses, and it is the figure a condition will refer to.
Coordination matters at this point. A roof carrying photovoltaics, air source heat pumps, a green roof for drainage and biodiversity, and plant for ventilation is a crowded roof, and the drainage and ecology strategies need to agree with the energy one. A Sustainability Statement usually draws those threads together.
Offset payments where a shortfall remains
Where policy sets a net zero target and the on-site measures fall short, boroughs with an offset mechanism accept a cash-in-lieu payment for the residual emissions. The calculation multiplies the residual tonnes per year by a published price per tonne and by a period, commonly 30 years.
Take the price from the authority's current published guidance rather than from an earlier scheme, because the figure is reviewed. Show the calculation in full in the statement, with the residual emissions, the price, the period and the resulting sum, so the section 106 drafting has a figure to attach to.
Monitoring under the be seen stage
Where the be seen requirement applies, the statement sets out how actual performance will be measured and reported after occupation. That means a metering strategy covering the regulated end uses, a commitment to report at the agreed intervals, and the identification of who holds the obligation once the developer has sold the building.
Landlords and management companies inherit this, so the commitment needs to be capable of being passed on. Setting it out clearly in the statement is easier than negotiating it into a section 106 obligation at the end of the process.
Figures and tables officers expect
A statement that is easy to check gets checked quickly. Include a single summary table at the front showing baseline, be lean, be clean and be green emissions with percentage savings, then the detailed tables behind it.
Include the modelling outputs as an appendix. Include the roof plan showing the array. Include the U-value schedule. And state clearly which parts of the scheme each figure covers.
Two related documents usually travel with it. An Overheating Risk Assessment to check that the fabric strategy does not create a summer problem, and on larger schemes a Whole Life Carbon Assessment covering embodied emissions that the energy statement does not touch.
The Energy Statement page sets out what the document covers and who normally prepares it. Browse all 66 report types to see what else a major residential application carries.
This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it.
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Frequently asked questions
What is the difference between regulated and unregulated emissions?
Regulated emissions come from the fixed building services covered by the Building Regulations, meaning heating, hot water, ventilation, cooling and fixed lighting. Unregulated emissions come from everything else, principally appliances, cooking and small power. Planning targets are normally set against regulated emissions, though some authorities ask for unregulated figures to be reported alongside for transparency.
Which baseline should the statement use?
The notional building defined by the current edition of Approved Document L, calculated for the same geometry and use as the proposal. State the edition, the software and the calculation methodology, and keep the baseline consistent across every table. Comparing a proposal against an older edition of Part L inflates the apparent saving and is the error officers spot first.
Does every council use the be lean, be clean, be green hierarchy?
It originates in London Plan policy and applies to development in Greater London, where a fourth be seen stage adds post-occupancy reporting. Many authorities outside London have adopted the same structure in local plan policy or supplementary guidance because it is a clear way to present the case. Check the adopted local plan before assuming the targets transfer.
How are carbon offset payments calculated?
Where a borough operates an offset fund, the payment is based on the residual annual regulated emissions after on-site measures, multiplied by a price per tonne and by a period, commonly 30 years. The price is published by the authority and reviewed periodically, so take it from the current guidance. The payment is normally secured through a section 106 obligation.
Do I need a separate overheating assessment?
Usually yes, and it should be consistent with the energy strategy. Approved Document O sets the Building Regulations position, and planning authorities often ask for a dynamic assessment to CIBSE TM59 for residential schemes. Passive measures that reduce overheating can conflict with fabric measures that reduce heat loss, so run the two assessments together rather than in sequence.
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.